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

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.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

* Questionnaire Timing - We believe that it is good that you are consulting local interested parties but do not believe that a website questionnaire is the best and fairest way to do it. The document is too large and there are too many questions to answer. The response to your questionnaire is expected by the 8 Aug 2008, as many organisations only meet once a month this would make it almost impossible for them to respond. The whole process seems to be driven by a very fast timetable, which does not seem to give much time for objections to be lodged.

* Future Growth - Does the planned expansion take into account the latest cost of fuel that we believe will greatly affect travel in the near future?

* Green Belt - We believe moderate improvements to the airport and surrounding light industrial estate are necessary for the area but all of the proposed options seem to include loss of greenbelt land. Once again land is being chipped away to suit a particular development. We are strongly against the use of green belt or farm land for any future development but any improvement to amenities and lessening of the impact to the environment has to be welcomed.

* Night Flights - No mention is made of night flights that we would object to, given that the proposed 2 million passengers per year would almost certainly need a 24/7-flight pattern. In addition the pollution created by the aircraft and traffic increase needs to be quantified. We believe there are limited night flights at the moment, if flights are increased all night flights should be eliminated completely.

* Socially & Environmental - We can see the need for economic improvements and we are all for local transport improvements but it is not clear what you have in mind to improve the area socially and environmentally as mentioned in the report. The proposed use of Prittlewell & Eastwood brook to dispose of surface water, what are the appropriate measures mentioned in the report to overcome pollution? This may in addition also create a flooding problem as we believe no volume tests have been carried out.

* Local Employment - Any increase in local employment can only be good but not by using green belt or farm land. We believe you should aim for low scale employment growth. It seems to us all options are driven by more jobs. The people who live in this area moved here because of its rural nature. If they had wished to live by a major airport they would have all moved to Stansted! We believe a new hotel can only be good for the area but we are not sure a new rail station is necessary when the one a Rochford is only a mile away. This would only slow down the train service that would need to make an additional stop.

. Roads & Infrastructure - The local roads could not support the numbers of people travelling to the airport via the current system as there are existing problems. We believe the airport is beneficial to the area but do not believe that we will get the road improvement that would be required for a larger expansion. Even if money was available for major road improvements there is no room for additional roads. The only way to really improve the A127 is to build a bypass. Bus and rail services are in the hands of private companies that cannot be dictated too. Any improvement in cycle ways would be nice. We cannot see why a shuttle bus link from the station to the airport could not be provided. Diverting Eastwoodbury Lane would be very costly and inconvenient but it could be dropped in an underpass as works at Heathrow.

* Noise Pollution - Additional noise has got to be a major consideration that may be eased by the use of quieter planes but what level of noise pollution is to be expected? This includes more cars, delivery lorries, coaches/buses, aircraft and increased train activity.

* Railway Safety - The existing railway line is in close proximity to the runway. If a plane came in short of the runway, as one did recently at Heathrow, the high voltage would make the accident ten times worse. If a train were present at this point it would be a major disaster.



To summarise we believe the only real way to ensure a high quality environment for residents is to limit the number of flights and consequently the size of the airport. The airports objective should be to keep it simple and not aim too high. In our opinion this location is not the suitable for a major airport but some increase in capacity could be beneficial. We therefore conclude that the airport should only be used for and have a modest increase in light industry, plane maintenance, business flights, cargo and limited UK and European holiday flights.

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.

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

Southend Borough Council and Rochford District Council London Southend Airport and Environs Joint Area Action Plan Development Plan Document: Initial Consultation on Issues and Options

We are writing in response to your letter received on the 30 June, seeking views on the above document.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with Development Plan Documents is therefore that they will help deliver, and provide the spatial framework for:
• sustainable economic development and regeneration in the East of England, and in particular,
• the Regional Economic Strategy (RES) A Shared Vision: the regional economic strategy for the East of England, 2004).

The RES recognises the area as a priority for regeneration and growth as it lies within the Thames Gateway Growth Area. EEDA is also a core funder of Renaissance Southend and is providing expertise and resources to develop and implement key regeneration strategies for Southend.

You should be aware that the new RES is due to be published shortly and therefore as the JAAP progresses, this new strategy will need to be taken into account.



There is a strong level of strategic support for the development of Southend Airport. The Government's Air Transport White Paper identifies the important role that smaller airports can provide in meeting the demand for air travel. In addition, it identifies the important role that such airports can play in contributing to regional economic development, and in the case of Southend specifically the white paper also promotes the development of additional capacity for business aviation.

The Regional Spatial Strategy reiterates the support in the White Paper for the growth of Southend Airport to meet local demand and to contribute to local economic development, particularly in niche markets such as business aviation, passenger routes not served by larger airports and employment uses that would benefit from an airport location. The RSS also notes the importance of ensuring that proposals for airport expansion take account of the needs of surface access provision and the shift towards more sustainable travel modes.

The RES is similarly reflective of the Government's Air Transport White Paper. Goal 6, Priority 1 in particular, supports the sustainable growth of the region's airports and the business and employment opportunities that can occur as a result. Southend is identified specifically in ensuring that the region remains attractive to businesses. The RES also seeks to ensure that airport growth is planned for in an integrated matter with regeneration strategies, the supply of high quality employment land/space and road & rail infrastructure.

EEDA therefore supports the proposed expansion of the airport as articulated through the JAAP.
By maximising the benefits of the airport location to develop further employment opportunities, the Councils will not only be meeting the aspirations of the Air Transport White Paper, but also providing a significant contribution towards the regional job growth targets. This is important as the JAAP identifies the airport as playing an important role for the sub-region in meeting the job targets as set out in the RSS given its potential attractiveness and location adjacent to the A127 corridor.

The JAAP identifies three potential growth scenarios. EEDA's view is that in supporting the growth of the airport and delivering the scale of ambition as stated, then the aspiration must be to ultimately deliver Option 3, the High Growth scenario. The use of the airport and the potential for significant new business development is currently significantly constrained by a range of issues including the facilities, the scale of the runway and access to the airport itself. In order to fully address these issues in a sustainable manner, then the critical mass of development associated with Option 3 is likely to be required. In addition, whilst Option 2b will potentially deliver similar numbers of flights, this is likely to be less deliverable without the additional runway extension that is proposed through option 3.

Whilst there is clearly significant capacity for flights and the potential for new industrial and business premises, the JAAP also identifies, that for the current businesses in the area, proximity to the airport is not usually an important factor. In the light of this, in justifying the scale of development as potentially proposed, the document needs to be much clearer on the evidence of demand for airport based businesses and indeed, wider employment opportunities in this location and how the JAAP as proposed will meet this demand through the identified options. For example, reference to the Roger Tym & Partners work carried out in support of the Regeneration Framework and the Core Strategy might be appropriate.

In planning for growth, consideration also needs to be given to potential conflicts between the different users of the airport, particularly given the aspirations to grow passenger numbers. Care must be taken to ensure that in maximising the benefits of additional passenger flights, the niche business opportunities at the airport such as the business flights and the maintenance / repair industries are not compromised. It may be that in considering distribution of space and access and egress arrangements it may be desirable to group the aviation oriented jobs in one place -possibly with a layout design and management that could in due course allow them a secure entrance.

Finally, it must be noted, of course, that the development of option 3 will potentially have environmental impacts on the local area and in particular, will require some reconsideration of green belt boundaries to the north. In the light of this, if the Councils' are to pursue a high growth scenario for the airport, then a strong case linking demand to the requirement for this green belt land will need to be made.

If you would like to discuss any of these matters in further detail, please do not hesitate to contact me at the above address.

We write on behalf of C and S Associates, owners of land which comprises part of the Brickworks site, Cherry Orchard Way, as shown on the red line plan provided.

We understand that the rest of the Brickworks site is controlled by Parkers Land who are represented by J B Planning Associates and we understand that they will make separate representations on the Joint Area Action Plan. There have been discussions between the two parties and we are in agreement with their representations.

The Brickworks site falls within the area of the London Southend Airport & Environs Joint Area Action Plan (JAAP) and has been identified as a 'specific are of change' in the draft document.

The draft document sets out four possible scenarios for development of the area: scenario 1 proposes no designation for the site; scenarios 2a and 2b propose designation of the site for limited residential development; and scenario 3 proposes designation for mixed use comprising residential and employment.

C and S Associates support scenarios 2a, 2b and 3 but do not support scenario 1.

C and S Associates support the proposed designation of the land, as identified as site i in the JAAP scenarios, for residential development or residential led mixed use development.

The Brickworks site is previously developed land and currently lies derelict and detracts from the surrounding landscape. Significant costs are likely to be associated with the clean up of the site. Without development it will be difficult to achieve this.

Residential development will assist in enabling Rochford to meet the PPS3 requirement to identify a 15 year housing land supply.

Designating the site in this way this will retain some flexibility and allow the owners to work with Rochford DC to achieve a development which is beneficial to the area.

C and S Associates support changes to the green belt boundary to enable development of the Brickworks site. The draft JAAP recognises that without this amendment this may hinder development and we agree with this; the green belt boundary can be amended to enable this beneficial development to take place without compromising any adjoining green belt. The site can provided with defensible boundaries which will afford future protection of the surrounding green belt, should it remain, and so development will not threaten the function and purpose of the green belt.

In addition to this letter we have made an electronic submission answering the specific questions raised in the JAAP document.

If you require any further information, please do not hesitate to contact me, should you wish to discuss any aspect of the relevant issues, we will be pleased to assist.

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.

As Managing Director of Dedman Property Services, and in support of Southend Airport, I would like to submit my responses to some of the questions raised in the JAAP Options and Issues as follows;

Q3.1 - I agree with the overall vision for the JAAP which is generally in line with the aims and objectives of regional planning policy and also stakeholders like Renaissance Southend and local business groups.

Q4.1 - Assuming that the potential of the airport is optimised by Scenario 3, I see it as a catalyst for major employment and business growth as well as an efficient transport hub.

Q4. 4 - Providing the infrastructure proposed is implemented, I consider the area appropriate for growth in employment, particularly when made more easily accessible.

Q4.5 - Very much so, particularly with the level of improvements set out in Scenario 3.

Q4.7 - Yes the Green Belt should be revised in line with Scenario 3. Rochford District Council has an abundance of green Belt remaining and the buffer between Rochford and Southend would be maintained.



Q4.12 - Yes

Q5.1 - Scenario 3 is clearly my preference. I see the airport as a major asset to Southend and the wider area and its potential should be maximised rather than wasted. Scenario 1 would not realise any potential for growth and Scenarios 2 (a) and (b) could result in some investment being made at the risk of no return or benefit to the area in financial or other terms. The extension to the runway is of paramount importance to facilitate the immense potential.

The Southend Borough is already relatively densely developed and highly populated. A significant level of investment here will attract businesses by providing a high quality environment. It will also provide income to provide the necessary mitigation measures required to offset the environmental impact that will inevitably result from the increase in activity.

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

I support limited expansion of Southend Airport, with reference to the article in "Rochford District Matters", I support option 1 Low Growth and Option 2a Medium Growth.

My main concerns are :

a) Inevitable development which would gobble up surrounding rural area.

b) The other two options include the addition of a new railway station at the airport. If this is done, Network Rail have indicated that they would close both Rochford stations and Prittlewell, as the three would be too close.So the new station would have to accomodate all the commuters from Rochford, and carparking be provided for many of them. The airport could easily have a shuttle bus to start with and in the longer term an underground or covered "travalator" (flat escalator) between station and airport terminal. This would be far better for all passengers, rather than making the railway exclusive for a yet unproven number of air passengers.

We are writing in response to your letter received on the 30 June, seeking views on the above document.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with Development plan Documents is therefore that they will help deliver, and provide the spatial framework for:
sustainable economic development and regeneration in the East of England, and in particular,
the Regional Economic Strategy (RES) A Shared Vision; the regional economic strategy for the East of England, 2004).

The RES recognises the area as a priority for regeneration and growth as it lies within the Thames Gateway Growth Area. EEDA is also a core funder of Renaissance Southend and is providing expertise and resources to develop and implement key regeneration strategies for Southend.

You should be aware that the new RES is due to be published shortly and therefore as the JAAP progresses, this new strategy will need to be taken into account.

There is a strong level of strategic support for the development of Southend Airport. The Government's Air Transport White Paper identifies the important role that smaller airports can provide in meeting the demand for air travel. In addition, it identifies the important role that such airports can play in contributing to regional economic development, and in the case of Southend specifically the white paper also promotes the development of additional capacity for business aviation.

The Regional Spatial Strategy reiterates the support in the White Paper for the growth of Southend Airport to meet local demand and to contribute to local economic development, particularly in niche markets such as business aviation, passenger routes not served by larger airports and employment uses that would benefit from an airport location. The RSS also notes the importance of ensuring that proposals for airport expansion take account of the needs of surface access provision and the shift towards more sustainable travel modes.

The RES is similarly reflective of the Government's Air Transport White Paper. Goal 6, Priority 1 in particular, support the sustainable growth of the region's airports and the business and employment opportunities that can occur as a result. Southend is identified specifically in ensuring that the region remains attractive to businesses. The RES also seeks to ensure that airport growth is planned for in an integrated matter with regeneration strategies, the supply of high quality employment land/space and road and rail infrastructure.

EEDA therefore supports the proposed expansion of the airport as articulated through the JAAP. By maximising the benefits of the airport location to develop further employment opportunities, the Councils will not only be meeting the aspirations of the Air Transport White Paper, but also providing a significant contribution towards the regional job growth targets. This is important as the JAAP identifies the airport as playing an important role for the sub-region in meeting the job targets as set out in the RSS given its potential attractiveness and location adjacent to the A127 corridor.

The JAAP identifies three potential growth scenarios. EEDA's view is that in supporting the growth of the airport and delivering the scale of ambition as stated, then the aspiration must be to ultimately deliver Option 3, the High Growth scenario. The use of the airport and the potential for significant new business development is currently significantly constrained by a range of issues including the facilities, the scale of the runway and access to the airport itself. In order to fully address these issues in a sustainable manner then the critical mass of development associated with Option 3 is likely to be required. In addition, whilst Option 2b will potentially deliver similar numbers of flights, this is likely to be less deliverable without the additional runway extension that is proposed through option 3.

Whilst there is clearly significant capacity for flights and the potential for new industrial and business premises, the JAAP also identifies, that for the current businesses in the area, proximity to the airport is not usually an important factor. In the light of this, in justifying the scale of development as potentially proposed, the document needs to be much clearer on the evidence of demand for airport based businesses and indeed, wider employment opportunities in this location and how the JAAP as proposed will meet this demand through the identified options. For example, reference to the Roger Tym & Partners work carried out in support of the Regeneration Framework and the Core Strategy might be appropriate.

In planning for growth, consideration also needs to be given to potential conflicts between the different users of the airport, particularly given the aspirations to grow passenger numbers. Care must be taken to ensure that in maximising the benefits of additional passenger flights, the niche business opportunities at the airport such as the business flights and the maintenance/repair industries are not compromised. It may be that in considering distribution of space and access and egress arrangements it may be desirable to group the aviation oriented jobs in one place â€" possibly with a layout design and managements that could in due course allow them a secure entrance.

Finally, it must be noted, of course, that the development of option 3 will potentially have environmental impacts on the local area and in particular, will require some reconsideration of green belt boundaries to the north. In the light of this, if the Councils' are to pursue a high growth scenario for the airport, then a strong case linking demand to the requirement for this green belt land will need to be made.

If you would like to discuss any of these matters in further detail, please do not hesitate to contact me at the above address.

We need to see rail connections and better facilities in place in time for the 2012 Olympics at Southend Airport - obviously this woudl only generate substantial revenue if combined with additional runway length.

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.

Re: Planning Policy Document, London Southend Airport JAAP

The main Question that I would like to answer is Q5.3. I think that Scenario 1 should include the Runway Extension. My contention for this is that this would allow for fully laden Aircraft such as Boeing 737 Type to take off and land, therefore encouraging Operators of this type of Aircraft to use Southend Airport, and would allow the Airport and it's Environs to develop naturally, in order to keep pace with the increased usage. I futher think that diverting Eastwoodbury Lane to be unnecessary, as the existing road could be channelled under the Runway Extension as applied on other Airport sites.

I generally agree with Q3.1, although I believe that some of the proposals go beyond what is required for, what is essentially a small Airport.

Regarding Q4.2, I believe that, as I have already stated the natural progression from extending the Runway will drive the local economy forward, and that Facilities already exist to support the Airport. eg Engineering, Supplies etc.

Q4.4 Employment will always expand when opportunities are in place.

Q4.5 Investors will usually be attracted where opportunities exist.

Q4.7 I do not believe that the Green Belt should be revissed, as I am sure that Brownfield Sites already exist.

Q4.10 Improvement of Rail facilities, also Local bus services, possible change to electric traction to reduce air pollution.

Q4.11 I do not think that this is possible in the short term, due to the shift working usually expected at this type of Employer.

Finally I appreciate the opportunity to comment in what I believe is a necessary facility to the communities of Rochford, Southend and surrounding areas.

Having been alerted to the existence of the above document via an article in last week's free newspaper, and after obtaining a copy from your office, I am appalled that proposals which could have far reaching effects on those who live within the area under scrutiny seem to have been a matter of some secrecy - most people I have spoken to in the short time since receiving the report have no knowledge of this report. My grandparents bought this house when it was built in 1934, it has been my home for 61 years, and I believe that I and all other households surrounding the airport - plus those affected by the flightpaths - should at least have had the courtesy of some communication, if not the whole report, back in June when apparently the document was produced as the impact of certain scenarios - if adopted - will have a major effect on us.

Unfortunately I have been left with little time to read the 100 page report properly but I quickly want to record my initial reactions. Whilst appreciating the need for planning, progress and change, I do oppose any significant change to the Airport mainly because of its unsuitable site in the midst of a high density populated area which has totally inadequate road infrastructures both locally and nationally. Certainly until actual improvements to road communications are in place with consequent improvements to traffic flow, no Airport expansion decisions should be contemplated and definitely not initiated.

With the accessibility of City, Stansted and Gatwick Airports, together with the predicted economic and environmental issues concerning fuels and emissions, I do not share the view that Southend Airport has a significant regional role to play in developing passenger traffic for the future and do not believe there will be a significant market to justify and sustain increased further commercial flights out of Southend.

I am totally opposed to the change in status of any surrounding green belt land because of the population density in this area, and I am particularly concerned about the probability of any such re-designation leading to the development of the present green belt areas into further industrial and residential zones.

I am also concerned for the plight of St Laurence & All Saints Church, its isolation from parishioners should the runway stretch of Eastwoodbury Lane be closed, and the Church's future with the added noise and pollution that any expansion of the Airport would involve.

As this huge and important issue is debated and developed in future, I would ask that more priority is given to keeping taxpayers properly informed so that we all have a better chance of responding with our views before key decisions are taken.

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.

I wish to state my objection to any expansion of Southend Airport.

This means option 1 is my preference I believe my objection is based upon the following:

Increased noise.
The flight corridor extension over residential areas and schools.
Increased air pollution in a town that has above average respiratory problems according the the local NHS Trust.
Any extension would destroy Eastwoodbury Lane, one that maybe over 1000 yeasrs old and is a landscape feature found from the first mapping by Andre and Chapman 1777 and little changed till the 1920's and the small holdings act post 1914/18.
All other options would encroach upon urban green open space south of the lane, some farmed and some parkland with wildlife meadows with reptiles. Further there is "the traditional orchard with a Biodiversity Action Plan cover from SBC and with the former as signatory to EEC the same. Also a public footpath.
The status and origin of the above green area was it offset when Tesco and RBS development occurred and transfer of land from ECC to SBC.
This is an unnecessary airport development given the public transport link with Stansted almost hourly initiated by BAA. Combine this with the present ongoing fuel crisis the future of air travel becomes precarious especially with quick turn around no frills flight companies quickly drop flight connection.
This process of consultation itself has not been easily accessible, difficult website access and pathways, newspaper articles with no how to process indicated to enable preference registration.
No indication with 3 options for extension with the peripheral land use charges.
No indication of the independence of any analysis of noise, air and environmental impacts.
The lack of proactive consultation to enable people to understand and ease option preference making, when the public reaction to this initial phase will be quoted at a later date as a satisfactory response.
Finally I would request acknowledgement of your receipt of this objection to JAAP please.

We are writing to you to express our Objections over the Expansion of Southend Airport. It seems that we are not the only residents in Leigh that are concerned over this matter. It has been my misfortune to have been off work with an illness for the last three months and at time we have had aircraft flying over us every five minutes with the cost of fuel these days and the pollution and noise the only reason we can see for the Expansion is for profit on their part not for the residents. Just ask anyone that lives near an airport whether they would like any increase in aircraft flying over them? (I don't think so).

So we would object to any expansion to Southend Airport leave the area alone and the green belt should not be compromised. Please pass on our objection to the council when they have their meeting regarding this matter.