5.2 Scenario 1: Low Growth (do minimum)

If this option is adopted, I would imagine that over the next few years, more and more companies would look to move their operations to other areas where they have more opportunity to expand. The number of people employed on the airport site would gradually diminish.

Hockley Parish Plan Group would like to register the following comments regarding the London Southend Airport & Environs Joint Area Action Plan, based on the views of Hockley residents as expressed in the Hockley Parish Plan.

'Any future development and expansion at Southend Airport and the surrounding area, in terms of flights, passengers, employment and businesses, must not create additional noise or air quality pollution in the Parish of Hockley, caused primarily by noisier / bigger aircraft, additional flights or new flightpaths. Any increase in traffic and transportation on the highways in the Hockley area, caused by the development and expansion, must be matched by improvements to both roads and related infrastructure.'

Regards

Tim Gleadall
Vice Chairman
Hockley Parish Plan Group

This would be acceptable.

this is my preferred option.

This option would be the end of the airport. The airport would not generate the investment required to maintain the services it currently provides to the operators on the airport.
This option would potentially reduce the airport to an unlicenced aerodrome with the potential loss of 1500 skilled workers from the area.

Why isn't airport closure a possible scenario. Of those put to the public this is the only one that is anywhere near acceptable.

This is the only option that will not have a hugely negative impact on the lives of the thousands of residents living under the flight path and airport surrounding area, and commuters on our already congested roads to and from Southend.

This is the only option i would support

I support the low growth (do minimum) option.

This is my prefered suggestion

I support this Low Growth option as the only sensible way forward.

This is the only option that I would support

This is the only sustainable and palatable option for the area. Many residents are already subjected to a lot of aircraft noise and pollution, even at night. Weekends are bad enough with recreational flying (ironically often more intrusive than commercial jets) without adding even more aircraft movements

LSACL commissioned Arup to undertake an economic impact assessment of the Airport and their report will be submitted separately. Their report suggests that, without the growth of passenger services, the net increase in airport-related jobs (including indirect and induced) would be 330 by 2020. The figure of 750 additional jobs could only be achieved if non aviation jobs are attracted by the availability of space rather than by a demand for the particular airport location. The risk with the Low Growth Scenario is that as the number of aircraft and European airlines that can use Southend's existing short runway for commercial services declines, so too do the commercial opportunities for the airport. The risk of business failure for either airport based companies or even the airport increases commensurately, and consideration would need to be given to the 1200 airport based jobs that depend on these companies.

As a local resident in Little Wakering this would be the only option that we would support

I support this proposal and am totally against any extension of the runway.

I wholly support this option â€" no development should take place on this vulnerable belt of green belt between Rochford and Southend, and certainly not development related to aviation, an activity that responsible authorities should be looking to discourage. The non green belt parts of the JAAP area should be redeveloped for housing and business, uses that are needed by most residents of SE Essex in one form or another, unlike aviation which is needed by almost nobody.

This would mean less employment in the area. Specialised jobs would leave the airport.

I believe it would be inappropriate for the reasons of poor infrastructure,environmental and local community impacts to do anything more than minimal improvements to the existing site.A reliance on an industry that has been proven to be very fragile to economic & social conditions both in the UK & globally would be short sighted.

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.

This is the least dangerous of the options. A responsible approach would be to seek a gradual reduction of aviation capacity in the UK - as part of a strategy to avert catastrophic climate change.

In my view, all planning should take into account that both car and air transport needs to be reduced, for environmental reasons. This seems, therefore, the best option.

I do not wish to see any increase in airport traffic, this would not be consistent with government targets for CO2 reduction and the green belt area should be saved.

of the options presented this is the only one that I might possibly support
However I wish to qualify this by stating that we are not obliged to cater for the predicted demand for air travel. The sector makes a disproportionate contribution to climate change and should be included in targets for cutting emissions There should not be an assumption that there is a requirement to develop the airport
Options 1, 11 and 111 will undoubtedly act as drivers for increased CO2 emissions at a time when national, regional and local government should act to prevent damaging climate change.

There would appear to be no case for the expansion of air traffic at Southend within the the wider context of environmental damage and fuel costs. Similarly the green belt should be preserved."Blue sky thinking" would be to develop Southend as a "Slow city" rather than dvelop traditional commerce and industry which has had its day.

of the options presented this is the only one that FoNKM might possibly support
However we wish to qualify this by stating that we are not obliged to cater for the predicted demand for air travel. The sector makes a disproportionate contribution to climate change and should be included in targets for cutting emissions There should not be an assumption that there is a requirement to develop the airport
Options 1, 11 and 111 will undoubtedly act as drivers for increased CO2 emissions at a time when national, regional and local government should act to prevent damaging climate change.

London Southend Airport JAAP issues and Options Report â€" Representations on behalf of Westcliff Rugby Club

We are writing on behalf of Westcliff Rugby Club to respond to the recently published draft Joint Area Action Plan for London Southend Airport.

As you may be aware, Westcliff Rugby Club has operated from its clubhouse at The Gables on Aviation Way since the mid 1980s. With over 600 members, Westcliff RFC is one of the largest amateur sports clubs in Essex. It has a highly successful team, with its 1st XV having finished top of the London Division 3 North East league last year.

The Club is keen to invest in its facilities for members and spectators, and to consolidate its position as one of the premier clubs in the Southend area. It could do this at its existing premises, but the Club is not averse to relocating to an alternative site.

The current clubhouse is owned by the Club (on a long-term lease) and the playing fields are rented from Southend Borough Council. In relocating, the Club would ideally like to acquire a freehold land interest or otherwise move to premises with a long-term security of tenure.

In the light of the above, the Club is generally supportive of the proposals for growth set out in the JAAP. It sees the proposals for growth and investment in the area as a positive opportunity for the enhancement of recreation and sporting facilities as a complimentary part of the growth agenda.

In terms of the specific content of the document, we would respond as follows:

In response to Question 4.12, the Club generally agrees that the areas for change identified are the correct ones. It would point out that area ii(d) is not of course all agricultural land as suggested on page 48 of the JAAP, but the Club agrees with the JAAP that given the location of the site, this area would be suitable for development if an extension to the Aviation Way employment area were required.

With reference to Figure 4.1, the clubhouse, its car parks, the tennis courts to the west, and the commercial operation south of the tennis courts combine together to form a substantive area of development on the north side of Aviation Way. The clubhouse has the benefit of an existing access from Aviation Way, and could be redeveloped to provide additional commercial development in isolation, or as part of the wider development of the playing fields to the north.

In terms of the 4 growth scenarios, we would make the following comments:

Scenario 1 â€" Low growth. This option is not supported by the Club, because it would fail to capitalise on the potential for the enhancement of local sport and recreation facilities that could arise as part of a wider growth strategy.

Scenario 2(a) â€" Medium growth. This option is not supported by the Club for the same reasons as above.

Additionally, however, the Club would suggest that if Scenario 2(a) were pursued, the playing fields site (including the clubhouse) represents the most appropriate area for the northern expansion of the Aviation Way estate, on the basis that it is of lower landscape quality than the adjoining agricultural land, would utilise an area of previously developed land, and offers a site with well defined boundaries where development would have a minimal impact on the Green Belt.

Furthermore, if the Green Belt is to be amended, Government guidance seeks to ensure that any alteration relates to permanent physical boundaries, and relates to a long-term timeframe. The proposed area for release does not relate well to any existing physical boundaries, and allows no flexibility for future development should there be a need for further growth in the long-term. If this option is pursued, the playing fields and adjoining land north of the proposed employment extension should also be released from the Green Belt and safeguarded for potential future use.

Scenario 2(b) â€" Medium Growth. In response to this option, our comments in relation to the most appropriate site for expansion of Aviation Way would be as above ie. that the playing fields site would be more appropriate.

In terms of our comments under 2(a) relating to the need for a long-term Green Belt boundary, we are unclear as to where the proposed Green Belt boundary would be under 2(b). Figure 5.3 appears to show the proposed boundary revised to follow the line of the brook on the northern half of the JAAP, and we would support this as offering an appropriate long-term boundary, which would provide some flexibility for the future. However, on page 69 under Section 3 of the table in relation to Green Belt, the comment is made that the Green Belt would be drawn tightly around the new allocations. It would be helpful if this were clarified.

The positive proposals in this option for enhancement of the land adjoining the airport for recreation and amenity purposes would be welcomed, but the Club's concern is that there is no obvious mechanism for delivering that enhancement, and for that reason also, this option is also not supported.

Scenario 3 â€" High growth. The club support this option on the basis that it appears to deliver both growth and the opportunity to create new opportunities for sport and recreation within the JAAP area.

The Club would not object to relocation to the land marked at ii(b) on Figure 5.4. The Club considers that this creates an opportunity to reinforce the presence of sports facilities within the JAAP, with the football club to the east of Cherry Orchard Way, the Rugby Club, and the golf course combining to create a substantial corridor of sports-related uses, stretching between Rochford town centre to the east and the country park to the west, creating a real focus for sport and recreation.

Relocation would provide an opportunity for significant investment in sports facilities in the area. The increased value of the existing playing pitches would help to fund creation of enhanced facilities not just for the Rugby Club but for other sports uses as well. In addition, we would expect the JAAP to be underpinned by a developer contributions strategy, which could provide additional funds towards the enhancement of local sport and recreation.

For these reason, the Club supports Scenario 3.

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