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

Thank you for your consultation on the above document. Having reviewed the document I wish to make the following comments in response to the questions posed within the document:

Q 2.2
The issue of land contamination in the Airport study area should not be overlooked. There is the potential for contamination to be present in areas around the site where development/redevelopment may take place. Development should be seen as an opportunity to remediate land and bring it back into effective use in accordance with PPS23.

Water use/resource and water quality are also omitted from the document. Growth of Southend airport and associated development will place additional pressures upon water resources, wastewater treatment and disposal and surface water run off. Large scale development offers opportunities for initiatives for water harvesting and water recycling systems as part of the overall drainage and water management strategy at a site wide level. To achieve the Government's aim of sustainable development, more efficient use of water in new and existing developments is essential. Within the drainage strategy there are opportunities to improve the water quality discharged from the site.

There is no clear steer on waste issues during or after construction. We would wish to see a commitment to high rates of recycling of demolition materials and measures to incorporate recycled materials within the construction. We would like to see a commitment in this development to minimise construction waste at the design stage. We would also like to see those involved in this development commit to measures to minimise waste to landfill and avoid disposal of unused materials.

The implications of the Water Framework Directive must be understood and incorporated within the development of the airport if it may affect the local waterbodies. The Water Framework Directive (2000/60/EC) is a major opportunity to improve the whole water environment and promote the sustainable use of water. It applies to all surface water bodies, including lakes, streams, rivers, estuaries and coastal waters out to one mile from low water, and to artificial waters such as canals. It also applies to groundwater.

Q 3.2
The Objectives discuss 'Ensuring a high quality environment for residents' with explicit reference to noise pollution and protection of green space but the wider environment is not considered in the objectives. The importance of improving and enhancing greenspace and biodiversity, limiting and adapting to climate change, reducing flood risk, minimising waste, improving land quality, improved water quality are not addressed. This objective could be expanded to consider protecting and enhancing the whole environment.

Q 4.4
Any future employment growth in the JAAP should be directed away from the Flood Risk areas, as identified on the Environment Agency Flood Zone Maps.

Q 4.8
Every opportunity should be taken to protect and enhance any existing habitats and protected species present in the JAAP area. The creation of habitat will help contribute towards local targets, eg. Biodiversity Action Plans (BAPs) and meet the requirements of PPS 9: Biodiversity and Geological conservation.

Sustainable Drainage Systems (SuDS) can help reduce the impact of flooding arising from development. SuDS schemes can help reduce surface water runoff rates and volumes whilst also addressing water quality issues, if implemented during development of sites around the airport.

Q 4.9
One of the greatest long-term challenges affecting development of the airport is that of climate change; both the need to adapt to a changing climate and limit any possible future change.

Adaptation to the already inevitable change could involve choices such as providing new open space and green infrastructure that can provide urban cooling, SuDS and conserve and enhance biodiversity.

We want to see greater emphasis on managing demand for water, as well as using water more efficiently to help manage pressures on water resources. Climate change is expected to reduce the amount of water available, particularly in the South East, whilst, at the same time, we continue to use even more water.

We need to manage biodiversity in different ways in the face of climate change. Whilst making sure our existing protected sites are resilient to climate change, we need to move to landscape scale approaches to managing habitats to help encourage the movement of species as the climate changes.

While limitation of future climate changes can involve the highest possible level of resource and energy efficiency to reduce emissions. Further information is available in PPS1 supplement: Planning and Climate Change.

We support using larger amounts of renewable energy from a wider variety of sources, helping limit greenhouse gas emissions. Development should seek to secure the highest viable resource and energy efficient standards and maximise sustainable transport options.

Q 4.10
Improvements in public transport and more sustainable transport links are welcomed.

Q 4.12
Some of the specific areas of change listed in this document have significant environmental constraints that may limit development. Comments are made below in relation to each of the sites:

ii) Part of this areas falls within Flood Zones 2 (medium risk) and 3 (high risk), in the areas adjacent to the river to the north of this section. According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
iii) The entire area of this site falls within Flood Zone 3 (high risk). Development in Flood Zone 3 must be subject to the sequential test of PPS25, to demonstrate that there are no other reasonably available sites in lower flood zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
iv) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe. Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site.
v) The Biodiversity and habitat value of this area must be assessed when considering this site for redevelopment. PPS9 promotes the need to protect and enhance biodiversity during redevelopment.
vi) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located with in the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
vii) No constraints
viii) No constraints
ix) Land adjacent to the railway has the potential to be contaminated. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.
x) No constraints
xi) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. Use of the site as football pitches/sports recreation areas forms an acceptable use within the flood zone. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1 (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe. Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site.

Q5.1 5.3: The following comments are made in relation to each potential growth scenario.

5.2 Scenario 1: Low Growth

Under the section of Environmental issues Flood risk is classed as Medium. This is incorrect. Part of Aviation Way Business Park falls within Flood Zone 3, the high risk flood zone.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks.

5.3 Scenario 2(a): Medium Growth

Business park extension to the North of Aviation Way is appropriate as there are no significant environmental constraints. The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.

Under the section of Environmental issues Flood risk is classed as Medium. This is incorrect. Part of Aviation Way Business Park falls within Flood Zone 3, the high risk flood zone.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks. This will help improve the water quality of Rayleigh and Eastwood Brooks. Enhancement of water features should also be considered in line with the Draft Sustainability report accompanying this JAAP.

Environmental enhancements to site (v), (ix) (ii) and (iii) are encouraged.

Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.

5.4 Scenario 2 (b): Medium Growth Aviation Cluster

Area (iii) to the west of the current airport ancillary area is entirely located in Flood Zone 3. The sequential test (PPS25) must demonstrate that there are no reasonably available alternative sites within lower flood risk areas before development areas can be allocated within the high risk flood zone.

Extension of the Airport Boundary to include a field adjoining the north maintenance zone takes in an area of high risk Flood zone. Any extension to this boundary would give the impression that development in this area is appropriate. This is not the case. All development should be directed to the lowest flood zones first. The aim of PPS25 is to steer all new development to areas at the lowest probability of flooding (PPS25 para D1). Only where there are no alternative sites within lower flood risk zone (applying the sequential test) would development be appropriate. However, within the airport boundary and the JAAP study area there are considerable areas of Flood Zone 1 that would be more appropriate for development.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks.

Environmental enhancements to the area are encouraged. Existing habitats should be protected and enhanced where possible. In line with the draft Sustainability Appraisal, a comprehensive ecological impact and management study should be commissioned to identify relevant issues for the site.

Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.

5.5 Scenario 3: High Growth

MRO: Area (iii) to the west of the current airport ancillary area is entirely located in Flood Zone 3. The sequential test (PPS25) must demonstrate that there are no reasonably available alternative sites within lower flood risk areas before development can be allocated within the high risk flood zone.

Extension of the Airport Boundary to include a field adjoining the north maintenance zone takes in an area of high risk Flood zone. Any extension to this boundary would give the impression that development in this area is appropriate. This is not the case. All development should be directed to the lowest flood zones first. The aim of PPS25 is to steer all new development to areas at the lowest probability of flooding (PPS25 para D1). Only where there are no alternative sites within a lower flood risk zone (applying the sequential test) would development be appropriate. However, within the airport boundary and the JAAP study area there are considerable areas of Flood Zone 1 that would be more appropriate for development.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks. The level of pollution incidences should not be allowed to increase. Measures can be incorporated into development to reduce the risk of a pollution event occurring.

The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.

Environmental enhancements to the area, including Eastwood Brook are encouraged. In line with the draft Sustainability Appraisal, a comprehensive ecological impact and management study should be commissioned to identify relevant issues for the site.

In the draft Sustainability Appraisal this option scores negatively against many environmental objectives. The above comments should be taken on board, particularly with respect to enhancement and mitigation measures to ensure that the final plan scores positively against the environmental objectives.

Draft Sustainability Appraisal

In the comparison of each scenario against the environmental objectives, flood risk is given little consideration. Many of the areas for intensification of development of new development fall within the high flood risk areas (not medium as stated).

According to PPS25 new development in flood risk areas should be avoided, therefore these scenarios would score negatively against a flood risk objective.

Development in low flood risk areas should also seek to reduce the impact of flooding arising from development by appropriate management of surface water runoff.

p6 Environment section does not include Water Resource, nor does it address Waste Management. Climate Change should be expanded to include other measures in 4.9 above.

Medium and High Growth Scenario opportunities to use site wide initiatives for heat and Power (CHP), waste management, surface water management should be considered under these scenarios. Large scale development provides greater opportunities for a co-ordinated approach to many issues.

SA Recommendations Within this section we would welcome a commitment to level 4 or above of the code for sustainable homes and BREEAM Excellent rating for commercial and industrial buildings. We would also welcome a commitment to produce % of energy from renewable sources for the site.

Evidence Base report

For information it is likely that a South Essex Water Cycle Study & Strategic Flood Risk Assessment update will be commissioned shortly. Should these studies go ahead, the results should feed into the Sustainability Assessment report.

Flood Zone 3 is classified as the high risk flood zone, see PPS25 table D1. This definition of the flood zones should be used for planning purposes. The reports refer to the flood risk being classified as medium, this is probably taken from the definitions used on the Environment Agency website that is used for household insurance purposes. These definitions are not to be used for planning purposes.

The local authorities should be lobbying central governemrnt to ensure a ban upon night flights.

More biodiversity and accessible footpaths and cycle paths so locals can enjoy the green spaces.

provision of easily accessible informal green recreation space for people from the larger area.
provision of attractive public surface transport in the area.
Strict safety measures to ensure no pollution of local land or water courses in the area

Public perception may target the large commercial operators as noise and frequency concern some. However the airport has the potential to be a market leader in small (transatlantic capable) business aircraft and services which bring bespoke services and prestigous passengers and aircraft. This also relies on the runway extension.

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.

* 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.

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

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

General comments and context

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

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

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

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

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

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

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

Joint Area Action Plan [JAAP]

1. Introduction

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

2. Assets, Opportunities and Constraints

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

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

3. Vision and Objectives

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

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

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

4. Issues and Options

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

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

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

5. Potential JAAP Scenarios

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

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

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

Draft Sustainability Appraisal

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

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

JAAP Evidence Report [Halcrow June 2008]

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

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

Yours sincerely




Katharine Fletcher
Regional Planner, East of England

cc Southend Borough Council

Enc: English Heritage letter dated 12 March 2003

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

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

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

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

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

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

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

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

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

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

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

4.6 Are there additional options to consider?
No reply

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

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

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

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

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

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

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

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

5.2 How could your preferred scenario be further enhanced?

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

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

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

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

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

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

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

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

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

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

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

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

Green infrastructure can be generally characterised as green spaces which:

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

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



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

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

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



Q2.1 Yes



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



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



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



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



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



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



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



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



Q4.12 Yes



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



Kind Regards

Clare West, on behalf of Clients

Dedman Planning & Regeneration Ltd

Response to L S A & Environs Issues & Options Report

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


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

Yes, fully reported and understood

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

No, none

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

Yes

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

Yes

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

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

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

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

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

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

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

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

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

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

Q4.5 Will the area be attractive to investors?

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

Q4.6 Are there additional options to consider?

None

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

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

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

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

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

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

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

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


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

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

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

Yes

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

None

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

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

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

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

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

None

In answer to your list of questions appendix A Q2.2,-4.6,-4.8,-4.10,-4.11,-5.3. Could all deal with Road Infrastructure which would be totally inadequate, cheap, and will not impress the local motorist or residents.

The closure of Eastwoodbury Lane, would increase traffic through Hockley-Hall Road-Rochford Station-Sutton Road-Warners Bridge.

An underpass to replace the road closure before the extension would be cheapest and show you were interested in the local community.

The dualing of road to West of the Airport.
Traffic heading South could be stopped at the roundabouts, with increased traffic into West of Airport and would need traffic lights at least.

Q4.11 The only replacement to the car comes from space ship enterprise "beam me up Scottie".

Best wishes for your airport enterprise.

Apologies for late response and hand written reply.

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

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

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

We are writing to you with regards to your consultation in relation to the possible expansion of London Southend Airport.

We have read through the consultation documents and have got to oppose to the two scenarios that would mean the biggest expansion of the airport.

We live on the current flight path of the airport traffic that flies over the Blenheim area and at the moment it is just about tolerable. If the flights are increased to the amount that the Airport wants we could see the complete destruction of the way we live.

We are already woken in the mornings by large planes flying over and if we are sitting in our garden and one flies over, we cannot hear each other speak. One of the reasons we bought our house was due to the large garden it has. To have a possible 4 planes an hour flying overhead, every hour would be a nightmare. We would loose the use of our garden as a place of relaxation, our right for a good night sleep and also any peace and tranquillity everybody deserves in their home. Also to ensure that there are only four planes an hour, does that mean we will have to put up with night flights? This would be completely unfair to residents under the flight path as the planes coming over already wake us up! What is Southend Airport going to do to minimise the noise/vibration that will be emitted by the Boeing 737's that they will be using? The noise of the current planes is bad enough without the use of larger planes.

We are not naïve in thinking that nothing should be done to the airport in bringing more jobs and prosperity to the town but why should it be to the suffering of the people who live under the flight path and the surrounding areas? Why must the airport be extended to such an extent that it will affect the way people live? There must be a way of bringing money into the area without upsetting so many residents (i.e. scenario one of the consultation).

Two million passengers a year is such a large leap we really don't think that the infrastructure could cope with this. We cannot see how the roads will be able to cope with the amount of traffic that expansion to the airport would create. Yes there is currently planning permission for a railway station but to think that people will use this other than their own car is madness. Everyone will prefer to drive his or her own car. I use the A127 daily and during rush hour the road is completely chock a block going into and out of Southend. I can't see how the roads will be able to deal with the influx of traffic.

There is also the environmental element as well. The government constantly talk about protecting the environment with regards to pollution, we can't see how creating more air traffic is going to help this. The council wish to promote the Southend area, as a place for tourists to come and visit but if the airport expands the constant noise/vibrations of the aeroplanes will actually put people off of coming here. Leigh, Hockley and Rochford are all areas which will be affected by the noise and are places where people enjoy going to country pubs, walks etc.

If in the very unfortunate event that the higher impact scenarios are chosen (which we feel has already been decided!), the council must ensure that everything is done to protect the people who will be affected by this, i.e. conditions that airport must follow re the amount of flights it can use, flight times (to allow people to sleep without being woken up/none on Sundays), mass reduction of noise and vibrations, which need to be closely monitored by the relevant council departments. We think this is the very least the council should do to protect the needs of the taxpayers affected.

We both feel that Southend Council have not advertised the fact that this consultation period is going on and how members of the public can comment. We have spoken to many of our neighbours and they had no idea what was happening and that they could consult. Everything we have read in the local papers says that there is a consultation but we feel that nothing clearly states that residents need to comment to the council. We know that Rochford Council have advised the majority of their residents with details of the Joint Action Plan through their paper 'Rochford Matters' and therefore everyone has been given the opportunity to be involved. We don't feel that Southend Council has done the same and are very disappointed in this.

Please find enclosed several letters that were sent into 'The Leigh Times' which we feel echo the feelings of many of us in the Leigh area.

I am deeply concerned by the news that Southend Airport intends to extend the runway to allow larger planes to use the airport.

Of the options offered in the London Southend Airport and Environs Joint Area Action Plan, I prefer Scenario 1 the "Low Growth (do minimum)" option.

In addition to the comments on the attached letter, I wish to make the additional comments for inclusion as part of the consultation process:

Communication

I am appalled at the poor communication of a project with such far reaching consequences. I only heard of these plans via the letter which was posted through my door on Monday 4th August (which is signed and at the front of this note), explaining that any comments had to be in by Friday 8th August.

My parents, who have lived in Manners Way near Warners Bridge, for over 50 years and will obviously be very affected by the plans, have had no information whatsoever sent to them.

Road Congestion

There is already far too much traffic for the size of road from Rochford to Warners Bridge and at several times during the day a journey which should take five minutes often takes up to 20 minutes.

Earlier in the year a planning application to site a recycling unit at Warners Bridge was rejected due to the lack of road infrastructure, therefore it would suggest that any application to increase traffic in this area woudl also be rejected.

Air Pollution

We already suffer from air pollution due to the airport and we often have to close our windows due to the smell of aviation fuel, this could make living in the area unbearable, particularly if it is hot and humid in the summer, due to the increased aircraft.

Noise Pollution

We moved to Rochford 11 years ago, as at that time it was a fairly quiet village. I have MS and need peace and quiet to rest. Unfortunately, the place has grown considerably and it is no longer the peaceful place it was, however, any plans other than the "Low Growth" option will make it extremely noisy in terms of aircraft and traffic and unfortunately, a less desirable place to live and therefore we may not find it easy to sell our house if we wished to move to somewhere quieter.

I am appalled at the lack of consideration given to current residents in the area and feel that the focus is on government targets and making money which will not find its way back to residents.

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

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

RSPB policy on increasing air travel/transport

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

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

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

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

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