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

Noise - why should residents south of the airport be subjected to increased noise pollution from an expanded airport?

Pollution - any increase in airbourne pollutants is unacceptable.

Safety - most accidents happen in close proximity to airports. The proposed flight path passes over a clutch of 5 schools (St Thomas More, Westcliff High for Boys/Girls, Darlinghurst, Our Lady Of Lourdes, Chalkwell Hall). Imagine the impact of a large jet coming down on say the Thomas More/Westcliff High site that houses circa 2500 pupils) The noise from 40 flights a day by jets will also have a huge effect on childrens education.

I am against any expansion of the airport, I feel that the airport should be closed altogether and the land could be used for a new hospital to replace Southend General with adequate parking and auxiliary research facilities and any further residential development which is needed within the area.

If expansion of the airport is so beneficial why have the residents around Heathrow, Gatwick and particularly Stansted been so anti any expansion within their airports? Stansted is only 45 minutes by car from here and within an hour by public transport. With the continued decline in air transport, as proved by the figures for the last six months at Stansted, I fail to see any need for the expansion of Southend airport.

At the moment Southend airport is used as a dustbin for obsolete aircraft to come in to be serviced which are banned from other UK airports.

The road system throughout Hockley, Rochford, Rayleigh and Southend is struggling and an expansion of the airport would only compound the problem.

Obviously any expansion would increase noise pollution and CO2 emissions.

I am worried that an increase to air traffic and the size of aeroplanes will increase noise and air pollution: this could the thin end of a Stansted wedge, which no-one could welcome other than those with a commercial interest (and who probably don't live in or have concern for the area anyway).

Pollution,noise and congestion.
Encouraging ecological ideals, providing better cycle paths. better public transport and road improvements and best practices in noise reduction.
(Purpose built area for aircraft that are ground running engines that have noise diffusers/reduction barriers).

The above Report is very helpful but a significant piece of information is missing.

Can you please provide the noise footprint for approaching and departing aircraft for the present situation and Scenario 1, Scenario 2(a) & (b), and Scenario 3.

Once I have received this information I will be in a position to respond to your Report.

Thank you for your assistance.

I wish to record my comments on this report. The main problem is that the report focuses on the proposed redevelopment of a relatively small area with virtually no consideration fo the effects that this will have on the wider community and particularly those areas under the flight path from the airport runway. Although the benefits and disbenefits of the various proposals are given for the area within the JAAP there is almost no consideration for the disbenefits for Leigh-on-Sea generally.

I appreciate that there are existing planning consents for the development of the airport with a station, hotel, new terminal and new control tower and that all of these can be implemented. I would, however, vigorously oppose any application for an extension of the existing runway to enable the airport to handle larger and noisier aircraft. Whilst Halcrow refer to the possibility of protecting those living and working within the area of the JAAP they have nothing to say about the inevitable increase in noise levels which woudl be suffered by those under the flight path. These would cause particular disruption to the many schools in Leigh-on-Sea - St. Christopher's, Blenheim Park, St. Thomas Moore, Westcliff High Schools, Our Lady of Lourdes, Darlinghurst, West Leigh and St. Michael's.

In addition to an increase in noise there would be an inevitable increase in air pollution. On page 13 of their Scoping Report Halcrow draw attention to a decline in the air quality in St. Laurence Ward and opint to an increase in air traffic as a potential cause - and this from an airport operating well below its potential capacity.

On page 10 of their Sustainability Appraisal Halcrow say that on any development following an extension of the runway "the increase in aircraft emissions and related noise will be inevitable, therefore the effect on transport, air and noise quality is assessed to be significantly negative." The cumulative effects of noise and pollution would seriously degrade the quality of life in Leigh-on-Sea and no doubt cause a sharp drop in the value of residential property.

It is hoped that the development of the airport will lead to the creation of more employment within the JAAP but Halcrow point out in their Scoping Report of January 2008 that employers in the area are unable to fill existing vacancies due to the lack of skilled personnel. If more jobs are created it would seem that the only way to fill them will be by attracting workers from outside Southend and Rochford. This will create further pressures on housing and facilities within the greater Southend Area.

Noise, pollution, increased traffic and property blight. Stop further expansion of the airport.

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 greatest bthrest posed by expansion of aviation is the increase in CO2 emissions.
This issue is not only the paramount moral issue of our time it is also a crucial national security and economic issue. It is absolutely vital that polluting activities are reduced dramatically if we are to avert mass loss of land in Essex to sea level rise. The economic impacts of such an outcome would be catastrophic.

Do not develop the airport as valuable green space will be lost, noise pollution will rise and congestion will increase making our area less livable.

I do not envisage noise and pollution being a great problem. Modern airliners are both quiet and clean compared with a few years ago. Technology is moving very rapidly in this area.

It should be borne in mind that in just one day the burning of the rain forests puts more CO2 into the atmosphere than that created by flying 8 million passengers across the Atlantic Ocean. A busier Southend Airport is hardly going to effect the world climate.

I object to the proposed expansion plans due to the contribution it will make to climate change and the impacts this will have on biodiversity
As the UK is committed to a reduction in greenhouse gas emmissions I do not see how any development of the airport in the JAAP can possibly be mitigated. Aviation is the fastest growing sector in terms of UK emissions, and the European Commission points out if current growth continues emissions from international flights from EU airports will have grown by 150% from 1990-2012.
National, regional and local government need to act to prevent damaging climate change.

FoNKM objects to the proposed expansion plans due to the contribution it will make to climate change and the impacts this will have on biodiversity
As the UK is committed to a reduction in greenhouse gas emmissions we do not see how any development of the airport in the JAAP can possibly be mitigated. Aviation is the fastest growing sector in terms of UK emissions, and the European Commission points out if current growth continues emissions from international flights from EU airports will have grown by 150% from 1990-2012.
National, regional and local government need to act to prevent damaging climate change

Carbon & fuel emissions from aircraft and car increase, actual and perceived increase in noise pollution from aircraft and road traffic, increased traffic in the general area of Southend. Mitigation measures in earlier answers

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.

I am bitterly opposed to the expansion of Southend Airport. There is enough noise from the air traffic already - helicopters, weekend flyers and the low flying planes coming in and out for servicing - at times it seems they will take our roofs off - the flight path is very close.

Also traffic in this area is considerable already - where are any new roads to come from. The railway is crowded enough without another station. National Express have recently stopped the use of senior rail cards between 4.30 and 6.30 because of over crowding on the Liverpool Street/Southend trains. Rochford is a pleasant place to live - I can see all this changing and to whose advantage?

It is not as if an alternative is very far away - even a bus runs from Southend to Stansted. I trust Rochford Council will not support Southend Council's plans to extend the airport - I cannot think of a single advantage for local residents.

We have read the London Southend Airport and Environs JAAP Issues and Options report.

We strongly object to the proposed scenario 2b and scenario 3 because, as you well know, these would have a major detrimental impact on the highway network and biodiversity of the surrounding area and greatly increase air and noise pollution from aircraft and traffic for those of us who live in surrounding areas.

The potential for 6000 new jobs cannot outweigh the detrimental impact on the environment for many years to come. This is a time when we are supposed to be concerned about carbon emissions and pollution.

The A13 and A127 are congested every rush hour, and by day-trippers visiting Southend and Leigh on sunny days and holidays. These roads cannot take the extra traffic from 2 million aircraft passengers a year. Where will the money come from to improve these roads? How will this increase in traffic affect the quality of life for those residents that live near to these main roads?

The trarget of 2 million passengers a year would mean 40 passenger jet movements a day landing and taking off over Leigh. What will it be like to have large aircraft going over our houses 3 to 4 times an hour? What will this do for the value of our houses? Many residents in Leigh-on-Sea retired to the area for its peace and quiet. It has been said to be one of the most desirable places in the UK to live but this will not be the case with a major airport on our doorstep.

The LSACL intends phase 2 to be completed in time for the 2012 London Olympics. The Olympics will last only a few weeks but we will have to live with the impact of the airport for years.

All residents or council taxpayers should have been more adequately informed of the details of the report.

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.

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

Dear Sirs,

I am following up further to my comments of yesterday with regard to the above. My objections were brief due to time constraints and the deadline imposed.

I would like to add further, I am a commuter and unfortunately have to travel on the Liverpool Street, where the trains are always full with people standing, there is no air conditioning and very little space for brief cases/shopping let alone suitcases. The commuter pays a lot of money for their season ticket and when the trains run 30 minutes and beyond we can claim and I have a substantial amount towards next years season ticket. The Liverpool Street line would therefore be vitally important part of the expansion plan am I to assume that you have been in discussions with this line to arrange more trains? We certainly we need this and trains that can accommodate luggage. If we were talking about the Fenchurch Street line I could understand they provide a far better service and don't have people standing, air conditioning and luggage areas.

Secondly, the road infrastructure that we have at present could not cope with further traffic.

Currently the pollution and noise that we have from the airport is small but you can certainly still smell when you are servicing the larger aircraft, as a resident we would be subject to this 24 hours a day and 7 days a week.

I moved to Rochford 11 years ago on the new small Bellway estate off of Millview Meadows, rochford at that time was a very pleasant place to live but gradually it is being destroyed by building on any parcel of land whether it is suitable or not and the buildings are not always in keeping with the conservation area. The shops are continually closing and the new ones in the square are certainly not being taken up. We have to contend now with certain drinking establishments having licence for music irrespective of consideration for the residents and a lot are elderly. If the expansion goes ahead which I am sure it will do because its money and business then it would be a total nightmare. A lot of people on our estate will look to move I for one certainly and I resent being driven out of my home. So I for one say a very definite NO to Southend Airport.