5.5 Scenario 3: High Growth

This option is the only sustainable option to ensure the future of the airport and the economic benefits into the area.

To succeed,the airport needs to offer a meaningful range of flights to the local population.
The small runway extension is necessary to enable airline flights.
Technology improvements since the original heyday of the airport mean that aircraft are much quieter and fuel efficient than in the 1960's and 1970's, and will continue to develop in this way. This option is in-line with Government white-paper policy, (make the most use of existing runways), and Thames Gateway and EEDA policies.

Totally against any runway expansion

See comments re low growth

I fully support this option.

This would be absolutely devastating for the local community in terms of quality of life.
Air & noise pollution would be unacceptable,and disruptive to a huge number of people living in Southend,Rochford and reaching as far as Leigh & Hadleigh.The vehicle traffic generated would exascerpate an already heavily congested infrastructure.

This article appeared in The Guardian today, Thursday 7 August:

Climate change: Prepare for global temperature rise of 4C, warns top scientistDefra's chief adviser says we need strategy to adapt to potential catastrophic increaseJames Randerson, science correspondent The Guardian


http://www.guardian.co.uk/environment/2008/aug/06/climatechange.scienceofclimatechange

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.

There will be serious road congestion, pollution,disruption. Southend is a geograpical 'deadend'.Theres only one direction in and out of Southend.Passengers will have to avoid driving to Southend between 7am-9am, or 3pm-6pm Monday-Friday, avoid Bank Holiday weekends, and sunny weekends and days that SUFC are playing at home or they WILL miss their flights. Most people will NOT travel down by train. Southend will have a small catchment for passengers with most people preferring Stanstead with its better connections. If the airport expands significantly I believe it will end up being a white elephant when people start deserting it.

The expansion of a polluting industry like aviation is irresponsible.
It is now absolutely clear that the planet's climate is changing dangerously, with the propect of mass loss of life. Polluting activities must be reduced by 50% globally by 2050. The UK share, of this scale of cut, is equivalent to cuts of between 80 and 90% - ruling out expansion of a number of industries, including aviation.

I feel the only economically viable solution for the future of Southend Airport is to extend the runway so that it is attractive to aircraft operators who can truly maximise the benefit of Southend's strategic location. Coupled with a fast rail link into Stratford it would become the airport of choice for businessmen getting to Docklands, wishing to avoid the overpriced and congested London City airport. It would also be able to attract short-haul local holidaymakers wishing to avoid the trauma of travelling to Stansted, Gatwick or, even worse, Heathrow and the extensive costs involved in parking at those airports. There are terrific opportunities for increased local employment and with the improving technology of modern aircraft the noise and environmental pollution would be small. Southend Airport has alkways suffered form a lack of suitable investment leaving it such a poor shadow of its former self. Let's take the opportunity now to maximise on the terrific asset we have.

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 protected. This scenario would make life very unpleasant for many residents in the surrounding areas.

I am totally opposed to this option
and to any runway expansion

FoNKM is totally opposed to this option
and to any runway expansion
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
It is time for local, regional and national government to act to prevent damaging climate change

I fear very strongly that if this were to go ahead, there would be much regret in the long term - go and have a look around Luton Airport!

The character & reason for living in a semi-rural location will be gone for ever - only people who stand to makes a few quid will support this option.

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.

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.

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

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

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

Employment potential and the overall Vision

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

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

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

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

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

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

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

The Green Belt

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

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

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

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

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

The Areas for Change

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

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

The Scenarios

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

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

Cherry Orchard Brickworks

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

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

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

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

I am writing to voice my objection to the Proposed Extension of the Runway at Southend Airport.

I understand that the Airport already has permission for a new control tower, terminal building, station and hotel, however if the Runway is extended this could facilitate larger planes which in turn will lead to an increase in the number of flights and consequently a lot more noise over Leigh.

The JAAP quotes a possible 40 flights a day, which is verified in an article in the Evening Echo dated 11th June. However, the Echo later quotes a possible 160 flights a day (25th June) which would mean a flight every few minutes (and this figure is probably more accurate given that you wish to achieve 2 million passengers a year).

I also have concerns that Southend Airport has permission to fly 24 hours a day - does this mean that we all have sleepless nights to look forward to?

When I purchased my property in Leigh on Sea I was fully aware of the Airport and its relatively low level of activity. Had I wished to suffer from constant noise pollution from aircraft I would have moved to Stansted.

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

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

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

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

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

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

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

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

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

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