1 Introduction

Please refer to the attached document which lists all concerns with process and lack of information provided by the Councils concerned in respect of the JAAP. Again the demands placed upon objectors are onerous (as with the HAAP), namely the requirement to complete on-line or to file an individual form per objection are unfair and unwarranted. I understand however that this advice is actually waived upon request and as per my conversation with your offices! Attach one report for your attention lising all my issues with the JAAP at this time.
I expect a response to all queries raised.
The Councils have been extremely negligent in their duty to provide sufficient information.
At the present time the proposals are unacceptable in their entirety and there is nothing to suggest my opinion will change. I additionally support the comments made by campaign for protection of rural Essex (England) in their submission.
I am writing to object to the proposals contained within the London Southend Airport and Environs Joint Area Action Plan Preferred Options Dated February 2009.
I have a number of general objections regarding the process, documentation and manner of delivery as well as specific objections to the proposals and list these as follows:-
Flawed Process of Presentation.
1) There was little initial notification to the public of the first stage of consultation or the ramifications of not responding. We appear to have reached stage 2 of the process by default and dictation by the Councils, with stage 1 swept swiftly 'under the carpet' rather than the opportunity given to residents to undertake a considered process of weighing up the options. I do not believe that the majority, or even an adequate portion , of local residents understand the process and the JAAP documents do little to address this. Neighbouring authorities, that are also affected, will have had little input into the process and their residents no understanding of what is going on or what influence they can have. As such the process is flawed and details supplied inadequate. Unless the councils can demonstrate evidence to the contrary.
2) The selection of option three again has been decided adequate consideration of other options.
Whilst Southend Council have at least gone through the motions of offering roadshows to assist understanding RDC appear to have relied solely on advertising.
Notwithstanding this both Councils have failed to provide adequate information within the document, given their support of the proposal it must be concluded that this is a deliberate rather than just a negligent act and again calls into question the whole process.
As a bare minimum the JAAP should include :-
. Existing and post extension flight paths (how these may vary in inclement weather)
. Stacking arrangements in the event of runway closure/delays
. Basic statistics showing likelihood of inclement weather/runway closures and, as such how many times a year stacking arrangements and flight path changes are likely to be implemented and the anticipated number of flights this will affect.
. The types of aircraft able to take off, both before and after the extension (cargo, passenger and 'other')
. The minimum and maximum number of flights permitted (including split between cargo passenger, maintenance, training, testing) and flight times (including scheduled, non-scheduled, charter, training/testing/maintenance)
. The noise levels generated at ground level by the planes at altitudes - a noise map?
. expected plane altitude at say half mile intervals from take off/landing
. expected traffic volume increases (Stobart and other firms lorries and vans) for A127, A130 and B1013 (Rayleigh - Hockley - Rochford Road), as a result of airport expansion and closue of Eastwoodbury Lane
. Expected train timetable changes (including non-scheduled freight movements) and anticipated delays as a result of new passenger trains.
. the fact that the trains for the airport are not going to provide a local service (thus local commuting to the airport by train remains inconvenient)
. confirmation as to whether or not Stobart can apply (and whether or not the councils have any power or inclination to prevent or resist) to make rail freight movements to the airport or the immediate vicinity
. Which jobs are genuine new jobs, type etc and which will be transferred from other parts of the district (and lets not limit ourselves to Rochford and Southend, because undoubtedly Castle Point and Basildon will be affected)
. A summary of the impact of other developments in the area, including redevelopment of Hockley, Stambridge Road, Hawkwell, Daws Heath etc etc. These should be clearly marked on a flight path map also.
. Confirmation of detailed plans for inevitable road expansion schemes that will be required to support increased road traffic. Particularly A127, where proposals incorporate the Public Safety Zone and whether the expansion will be used to push through the unwanted development of a bypass via Hullbridge/North Rayleigh/Hockley and Rochford?
As such I would view this as a basic dereliction of Council duty - failure to inform and ensure that the interests of residents are looked after. I understand also that this may breach the Freedom of Information Act and RDC's own consultation strategy
3) The Councils have apparently selected the least popular option, although conveniently neglected to inform residents as to how or why this decision was arrived at. The only factor that seems to offer any support for their decision is 'increased jobs'. Various figures are quoted all prefixed by the worlds 'upto'. This term is 'up to' is sufficiently vague to mean that any number (including negative ones) below the figure quoted would be deemed a success. As such it has no place in the document as it constitutes mere speculation. Hard facts and details of how conclusions are arrived at are needed.
As such the information provided is surely skewed and the Councils are seemingly abusing their position in recommending the proposal with absolutely no solid evidence to back up the position.
4) The connection of this scheme with other projects in the area, notably a number of house building projects including those mentioned in 2) above, is not made clear Government document PPS12, makes clear reference to :-
Every local planning authority should produce a core strategy which includes :
1) an overall vision which sets out how the area and the places within it should develop;
2) strategic objectives for the area focussing on the key issues to be addressed;
3) a delivery strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered . Locations for strategic development should be indicated on a key diagram; and
4) clear arrangements for managing and monitoring the delivery of the strategy.
Whilst this document is no doubt available somewhere it should be included with the JAAP, since without it the JAAP is not placed in the required context, without clear direction it is impossible to understand how or why this is intended to be part of the core strategy.
Additionally how have residents been consulted on the overal strategy, because if that exercise is flawed - and certainly the desire to build more homes in a densely populated area, whilst simultaneously expanded an airport, demonstrates that it is, then much if not all of the sub-plans such as this area also flawed.
PPS12 also refers to
Period of operation
4.13 The time horizon of the core strategy should be at least 15 years from the date of adoption.
As above there is no clear advices as to where the JAAP fits in the core strategy or where we are in the time horizon. Again the document lacks context, although it even states that it must be read in context, it provides little clue on how to do this.
PP12 also refers to
Statements of Community Involvement:
An SCI should
. Explain clearly the process and methods for community involvement for different types of local development documents and for the different stages of plan preperation. This needs to include details of how the diverse sections of the community are engaged, in particular those groups which have been underrepresented in previous consultation exercises.
. Identify which umbrella organisations and community groups need be involved at different stages of the planning process, with special consideration given to those groups not normally involved.
. Explain the process and appropriate methods for effective community involvement in the determination of planning applications and where appropriate refer to Planning Performance Agreements.
. Include details of the LPA's approach to pre-application discussions.
. Include the LPAs approach to community involvement in planning obligations (S106 agreements).
. Include information on how the SCI will be monitored, evaluated and scrutinised at the local level.
. Include details of where community groups can get more information on the planning process, for example, from Planning Aid and other voluntary organisations.
. Identify how landowner and developer interests will be engaged.
These above items from the PPS demonstrate the assistance that should be given to ordinary residents (and others) in the process. As mentioned by Campaign for Protection Rural Essex a number of organisations should have been consulted including RSPB; Essex Wildlife Trust etc. It is disingenuous and perhaps even negligent of the council not to include these within the Action Plan. Most people have very little experience of dealing with documents such as this and it is only at this late stage in the process (given that we've already passed through stage 1) that RDC and Southend BC have offered even limited advice. Even having read as much as I can in the past few weeks, I (and I am certainly not alone in this) have very little information regarding :- the crucial stages in the process; whether residents can succeed in resisting or changing any aspect of the proposals - RDC really should explain the steps in simple terms. At the moment we seem to progress from one stage to the next with absolutely no guidance. For instance:- I understand from information received from other sources in relation to the airport, that unless I head this document as an objection it is merely treated as a comment. I believe petitions are ignored. I will need to get my wife to make a separate submission in order for her views to be considered, even though we agree. The council seems quite happy to tell people how to make positive comments, but far less inclined to advise on how to object - hardly democracy and clearly demonstrating a deficiency and unfairness in the process, that should be revisited before we move ahead.
PPS12 again
Justification of Core Strategies
4.36 core strategies must be justifiable: they must be:
. founded on a robust and credible evidence base; and
. the most appropriate strategy when considered against the reasonable alternatives.
As above we cannot be sure that the base is robust and credible or indeed the most appropriate when considered against reasonable alternatives, since we don't know how and why the initial alternatives were first selected and then rejected. The JAAP provides no evidence base to affirm that the selection or the process is credible and again the JAAP requires review and re-issue.
If this is the preferred option, what was the basis for selection and will any ideas arising from the consultation be put forward for further consideration? Is it possible (likely) that if decent alternatives are proposed in stage 2 the preferred option will be amended and re-submitted? If not then, again, the process is flawed.
5) The document produced glowingly mentions the positive aspects and underplays the negative - surely the document should be impartial and genuinely enable residents to make up their own mind? Plenty of rhetoric about jobs new businesses etc but no details and certainly no information on the negatives, noise, congestion, loss of property value, decline in overall living standards etc. Basic research reveals Stobart's close ties with Tesco and Network Rail are we going to end up with a huge Tesco distribution centre supporting the airport, similar to their Dudley operation?
While the JAAP includes a brief note that the airport is unsuitable for large scale cargo operation (only a niche operation). The terms 'large-scale' or 'niche' are undefined, will mean different things to different peope and are therefore meaningless in the context of the JAAP, again this requires clarification and re-issue. Notwithstanding this the actual use is surely the decision of the owners and not the councils? Stobart management are already quoted as saying upon the purchase of the airport 'we have found our Southern Base', doesn't really sound like they are planning a limited operation, quite the opposite.
It is also unclear where any 'new' jobs and businesses will come from. Given the proposals and redevelopment of Hockley it is apparent that a number will come from there and therefore aren't really new. Again disingenuous of RDC in relation to the HAAP (and Southend BC not to make this clear in the JAAP that a proportion of jobs at the Airport sites will actually be moved from Hockley)
6) The document itself is devoid of factual information, although admitting that aspects will be supplied later, this itself smacks of a rush job. We find ourselves moved on to a stage from which there is no going back without having the facts adequately presented. It seems that the councils are either negligent in preparation of the facts or trying to hide something.
Development of the airport could bring about a fundamental change to the area, not necessarily for the better and it is in resident's interest for all information to be divulged as soon as possible.
It also uses a number of undefined terms, notably around the word 'sustainable'. It could mean 'long-term use with minimal environmental impact', but it the council are not clear what meaning they are seeking to attach. Equally, there are (source Wilkipedia) different types of sustainability. Economic, Environmental and Sociopolitical, so there is significant room for confusion as to meaning and I'm quite sure most people have no understanding what is meant by sustainability in the context of the JAAP.
7) The council is geared very much to receiving information via the internet, whilst undoubtedy this is cost effective; it is unfair on those residents that do not have internet access, particularly the elderly who make up a significant proportion of the population in the area. It is doubtful therefore that the views obtained will actually be representative of all residents. I note at election time certain parties are very keen to get their voters to polling stations and will provide transport - I wonder how keen those same councillors are to dedicate time and petrol to those residents wishing to get assistance in completing JAAP.
Completion on line is actually quite difficult and near on impossible if you have lengthy comments to make. Again the councils are colluding to dissuade residents from making anything but the briefest of contributiions.
Additionally the representation form states that each objection/comment requires completion of a separate form. Clearly this is actually designed to put people off commenting. Although I understand from a telephone conversation with RDC planning department that the council will accept one form with clearly listed comments. I would have to question whether RDC/Southend BC can actually determine what form objections may take. Again the process appears flawed, as this is biased towards acceptance of JAAP. At best this builds mistrust between residents and the councils as to motive; at worst it is downright dishonest.
The JAAP relies too much on the reader having a detailed knowledge of planning terminology and documentation, mentioning a significant number of undefined, unexplained and unreferenced terms and documents (as mentioned later) and omitting adequate cross-referencing. As such it is an inaccessible, inadequate document not fit for purpose and until it is adequately amended and re-issued the consultation process is flawed.
8) Rochford Council's own Leisure document refers to Rochford being the 'Green Gateway', clearly there is a desire to put a wall up given the amount of building that has occurred in the West of the District - this needs to stop. The local infrastructure cannot cope:-
B1013 is a hugely busy Road already - HAAP refers to 15,000 + vehicles back in 2007 and significant building has taken place since then. If the Airport expansion takes place, and RDC regretfully support this, then further transport issues will arise.
What plans are considered for a major disaster, large aircraft crashing on residential or occupied business property? In the US 7 of the last 8 fatal commercial airline crashes involved regional airlines (BBC 12th May 2009) or indeed hijack, bearing in mind proximity to major centres of population, power stations etc.
What additional policing/customs and immigration officers will be supplied, both at the airport and elsewhere in the region? Not only do illegal immigrants use lorries to access the country (and a cargo terminal will increase the amount of vehicles in this part of Essex), but aircraft have also previously been used (e.g at Stansted). Additionally there are the increased risks associated with drug smuggling, particularly given that criminals may seek to use the nearest available market for contraband. There is also an increased likelihood (with increased vehicles) or road traffic offences, which speed cameras do not address. What additional resources will be provided to the NHS to deal with the upsurge in stress, sleeplessness and associated problems including violence and accidents?
9) No explanation has been given as to why RDC/Southend BC support Government policy (I have asked my local councillors and MP to explain this apparent anomaly) there seems to be no desire to protect the quality of life enjoyed by residents, certainly much of this part of Essex has previously shown (in Government statistics) to be one of the least deprived areas of the country, yet the proposals seem to treat it as though it is one of the most deprived - is this wishful thinking on the part of the compile? As recently as 2006 Southend was calculated to be the best place to retire to.
10) Both Councils are keen to promote the area as a great place to visit yet surely this will be the death knell for tourism, the only visitors will be those waiting for a plane to get away from an overly congested cargo handling centre.
11) There is no clear mention of what controls are able to enforce (and indeed whether they would agree on these). Given the track record of local authorities but locally and countrywide in rejecting and/or enforcing actions against big business and national government e.g totally inability to prevent McDonald's and Tesco building where they like and the fiasco of the change of use of Bullwood Hall prison I rather suspect that if the expansion is approved Stobart's will ride roughshod over any objections from residents irrespective of whether the council's support the residents.
12) No account appears to have been taken of the wider questions regarding airport usage. Aside from the environmental impact, the reduction of carbon emissions etc is supposed to be at the forefront of business, government and local authority strategies, and the JAAP clearly goes contradicts this. Why have the following not been mentioned.
a) Southend is only accessible from the East and North (there is so little to the West it is hardly worth mentioning and is obviously cut off fromt Kent by the Estuary). As such the Pool of passengers it is supposed to be attracting is actually very limited. To the North sits Stansted whilst to the East, London and the various airports accessible from there.
b) Why the runway is being extended to 1799m and not 1800m (something I believe to do with extra regulation), when this doesn't actually allow for any passenger planes that are larger than the current users to land.
c) With perhaps the exception of Luton, every major airport easily accessible from London i.e Gatwick, Stansted, Heathrow and London City itself have expansion plans in the pipeline, as such the need for expansion of Southend as a passenger airport is questionable if not foolhardy.
d) Most recent figures for air travel suggest that this form of transport is actually declining.
It would actually suggest that the freight forwarder Eddie Stobart has an entirely different motive for expanding the airport.
13) Apart from neglecting to place sufficient significance upon the fact that a freight forwarders now own the airport and thus that the expansion will cause increased in cargo shipments in the air and on the ground, I fully support the comments made by Campaign for Protection for Rural Essex (part of CPREngland).
14) The councils have made no mention of the plans to ease road congestion that expansion will undoubtedly bring. I anticipate that you will seek to resurrect the misguided and previously rejected plans to further develop on green belt by building a bypass across Hullbridge, North Rayleigh Hockley and Rochford, just exacerbating the over-development of this area.
Nor is the impact upon rail timetable and whether there is sufficient rolling stock available for the new train service (i.e whether existing commuter carriage availability will be cut to provide airport services) explored.
Specific Areas of the Report
1.1 - Integrate land use, transport and regeneration proposals. Arguably this area is not in need of significant regeneration, the decision seems to have been taken with no investigation of regeneration needs (certainly no evidence is provided) and one might question why redevelopment is actually necessary).
Reference to 'managing growth and change by establishing development and design principles' - where are these, who decides them and what is the decision making progress?
Safeguarding areas and places sensitive to change - surely development of the airport contradicts this, the development includes extensive building in green belt, a definite area sensitive to change.
JAAP is one of a number of DPD's and must apparently be read in conjunction with them, but there are no clues as to which ones or how or where you can find these - again a fundamental failing of the document and the process.
1.2 - Detailed examination, undertaken by whom and what evidence supports this? Although reference is made to such items such as best practice guidance, socio-economic statistics and published data etc - this document is wholly bereft of specific evidence of factual support and this appears to be a deliberate strategy employed by the councils (motive unclear) to prevent such data being challenged i.e the council saying we looked at the data and concluded, but not specifying which data and how they arrived at the conclusion. Surely this is not an open government and seems suspicious if not dishonest and/or negligent.
1.3 - Sustainability Appraisal - a term not fully explained. Apparently stage one required a scoping report, although again this is unexplained and we have no idea of the basis of this. Omission of even a path of reference, let alone an appendix is again a dereliction of duty.
1.4 - The JAAP will provide 'framework' for regeneration and expansion of London Southend'. Leaving aside the fact that Southend is not London (although the way development is going it seems inevitable it will be a suburb, probably this century), it seems decided then we are going to expand the airport. Surely you cannot make this statement, there is a process to go through (even if you are paying lip service), legally this statement is incorrect, as it can only provide a 'suggested framework'.
The JAAP apparently takes into account the current uses, transport, impacts, etc although as I shall make clear later anyone taking the time to read the whole document will realise that it is hopelessly inadequate, merely stating that it takes factors into account but providing no evidence or examples.
Again this paragraph is, at best, misleading and borders on dishonest. It seeks to reassure people that the negative impacts have been taken into account (in fact the opposite appears to be the case) without providing any evidence that they have.
1.5 - Feedback, where was this obtained, who considered it, how did they arrive at the conclusions, who reviews, again a flawed, unsubstantiated statement and process.
1.6 - Paragraph 1 final world 'sustainable' an undefined term within the context of the document.
Future of Transport White Paper (again not provided as an appendix) I understand that this is opposed by a number of environmental Groups and itself needs reviewing given recent changes in the economic climate and the overall downturn in aircraft usage, independent of the recession.
Para 2 - It is hugely questionable as to why Southend Airport requires expansion when, as already mentioned, in passenger terms, it has such a poor catchment area. It is inaccessible from the South due to the Estuary; to the East is the North Sea, to the North a much better sited airport and infrastructure in terms of Stansted, leaving only the West as a population centre. However anyone living to the West has the choice of Gatwick, Heathrow, Stansted, Luton and London City, all, with the possible exception of Luton having expansion planned.
Part 3 significant job opportunities - again undefined as to what significant means and what type of jobs are referred to (McJobs)?. Given the competition from the above airports it would require significant, unwelcome further expansion for business to be attracted because of the airport. Businesses decisions are made for reasons unrelated to the airport, yet the report suggests that development would be a major driver for business (but does not say why or what type of business). Southend lost virtually every major office employer since I worked there in the 1980's. Most major insurers and brokers merged and moved out of Victoria Avenue, as did various government departments (due to National government strategy) and BT, this had absolutely nothing to do with the airport and attracting these businessses back will probably have equally little to do with an airport.
Why is the commuter belt aspect of the region completely ignored? Many people commute to work and bring money back to spend locally. Similarly the retirement aspect is also ignored completely. It is questionable whether there is any great need for huge swathes of industry in this part of Essex.
Tourism desination is an absolute joke, the region is overdeveloped and the only tourists would be waiting for a plane to get away.
Para 4 - why is only the airport considered to be a drive for economic development? Holidaymakers pass straight through to their destination and most companies are cutting back on expenses such as business flights and use of technology (video-conferencing etc) renders their need redundant. We can surely only be talking about freight movement????
Again paragraph 4 refers to 'employs a significant number' is non-specific as to quantum or job types. Are you including the airport trading estate? I've shopped there, but I've never flown from Southend, it is totally unrelated and again the document is misleading.
Surprisingly the JAAP refers to a specific document, but gives no clues as to where to find the Rochford Core Strategy Preferred Options Document.
Para 5 - Transport issues are understated and it really does seem rather pointless to even attempt to expand such a small airport and blight the whole area for good for a few weeks in 2012. European visitors would be far better served by train, whilst longer haul flights cannot land on a runway this size.
Para 6 Who sees the airport as important for development and prosperity? Another vague statement dressed as fact. I see it as actually the beginning of a sustained decline in the area as the affluent move away, house prices fall due to noise and congestion from air and road freight and the area goes into, pardon the pun, terminal decline. Again future employment needs take little account of commuting.
2.1
Para 1 The context against which the JAAP is set is now outdated, having been drawn up in time of boom and when it was inconceivable that banking institutions would have to be underwritten by National Government to the extent they now are. The financial pattern of this and other countries have changed fundamentally and it will be a significant time before things get back to normal (over 20 years), loans are no longer freely available and the 'Vision' clearly needs to be re-visited.
Para 2 - refers to quality of life for residents is mentioned, but actually not expanded upon in the report. It is quite clear that expansion of the airport will reduce the quality of life for all but a very few number of residents i.e those fortunate enough to be directly employed in senior positions.
Para 3 - London Southend Airport as a 'major employer' - again an undefined term
. How many people does the airport directly employ (I suspect that many of the jobs are in fact secondary and even if the airport closed work would be taken up by other airports e.g Stansted or London City and the jobs would remain within commutable distance)?
. How many of the jobs are actually in the adjacent business park and in reality unrelated to the airport?
. How many of the jobs will actually be lost upon expansion (e.g those at the flying clubs that are being pushed out, businesses that are forced to close due to congestion etc)?
. How many of the jobs would actually remain if the airport was unaltered?
. Why isn't the spare capacity being used?
. What could be done to improve the spare capacity usage?
. What are the costs/benefits in picking up the spare capacity?
. Why, if the airport is so important, won't it become a success without expansion?
All basic questions the JAAP fails to address.
Para 4 - what is the 'current and emerging policy framework in the area'? again an undefined and meaningless phrase.
Para 5/6 - Southend core strategy - wonderful, what other options were considered and why is Rochford so keen to support this if, as this document so clearly demonstrates, there are so few advantages and so many disadvantages for the area and its residents.
Para 7 to end
Who are/what is Renaissance Southend Regeneration Framework? Another undefined term. How they have arrived at the conclusion it should be a centre for international air services and then contradicted this by saying it would be a 'great place to live' - when it so clearly wouldn't with a huge number of planes flying over head day and night. Rochford Council have a similar objective in making this a great place to live!!! I've lived in the region all my life, with these proposals I have no desire to continue to do so (but my options will be restricted by the resultant slump in house prices the expansion will cause)
Again there is very little mention that most of the towns in the region are actually dormitory towns for London e.g. Rayleigh. The desire to encourage employment is actually questionable on this basis. Higher salaries are always available in the City and vast airport expansion would probably require a significant number of migrant (possibly overseas) workers to fill vacancies.
Hi tech businesses tend to be low scale employers and no examples are given of 'high value employment'. This is pie in the sky aspiration with no basis in fact; it should be only be included in the JAAP if noted as such.
2.2
Para 1 - again refers to unreferenced material, planning documents etc, and it is impossible to know if this has been fairly assessed or just the bits chosen to fit.
The objectives are:
. Creation of sustainable and high value employment and other land uses within the study area; - what is 'high value' and what 'other land' - this is a vague and washy statement requiring amendment.
. Maxamising the economic benefits of a thriving airport and related activity: - is this at all costs?
. Ensuring appropriate improvements in sustainable transport accessibility and facilities; what is appropriate (who decides) and sustainable again undefined what other plans are the Council's proposing to run off the back of airport expansion? the rightly rejected Hullbridge to Rochford bypass???
. Ensuring a high quality environment for residents whether expressed through noise pollution management or protection of green space: what about congestion, air quality from road pollution etc?
. Maximum return on public investment through attracting inward investment; and is this at all costs?
. Efficient use of existing employment land resources. Is this at all costs?
2.3
Economic growth and new jobs. Again no consideration that the area is largely dormitory, no mention of the type of jobs and the fact that the airport expansion could have a negative effect with wealthy moving away and the area actually being an undesirable place to live, spiralling into decline.
Para 2 - Why will it be successful when there is significant competition from Gatwick, Heathrow, London City, Luton and Stansted all of which have better infrastructure and passenger pools as well as expansion plans. The proposed runway extension offers no increase in options for passenger plane access, as it cannot cope with any larger planes than the present runaway, as such the extension should be rejected as it fulfils no purpose.
Passengers will travel on the same planes they do at the moment and no plane is quiet or fuel efficient, especially when you consider that in excess of 20,000 flights per annum will take place (25,000 according to CPRE). It could even be argued that Southend should withhold expansion until plane technology improves to allow even shorter take-off and landing?
Conclusion would be that passenger use is to be secondary to cargo use and that Stobart have little intention of promoting the passenger aspects, except as a means of additional profit to their core operation, the movement of freight.
Fast food access is not possible the speed limit on the A127 is now 50mph for large stretches and is interrupted by numerous sets of traffic lights. Congestion problems will be exacerbated by any increased cargo usage at the airport, which will see the number of vehicles increase. No mention here of closure of Eastwoodbury Lane/A127 Public Safety zone or use of A130 or B1013 all of which will be problematic.
Para 3
Maintenance and repair - this implies that faulty aircraft will be flying over densely populated areas in order to be fixed. Given that the last time Southend had a significant cargo operation a plane crashed on Rayleigh (at night, on the only commercial premises in a residential district) it may be tempting fate to suggest that you are rather chancing residents luck with this proposal.
Restrictions on night flights - again unspecified as to what these will be and how they will be enforced. No consideration to schools, hospices, hospitals, etc etc let alone resident.
Part 4 - award winning, which award and by whom a vague statement. How can this be an enhanced Green Lung - it was built on open fields, it is disingenuous of the council to suggest otherwise, could we not have had a wide open space rather than a confined Country Park?
We've already lost significant open space, including recreational amenities to make way for Tesco's RBS etc and the link road developments. What are the 'quality jobs', undefined term and how is it to be guaranteed that they are for local people - if they are that good surely everyone will want it; again this is a misleading statement and should be withdrawn or amended.
Part 5 - Lets be clear an area for plane spotters and the poor souls living nearby.
Part 3 - Issue 1
Para 1 The railway increases the catchment, but doesn't decrease the competition from other better designed and strategically placed airports, notably Stansted. The rail line doesn't allow locals to access the airport so actually offers no benefit to those in the near vicinity.
Para 2 - Runway size is a constraint; this is not necessarily a bad thing and does give the local authorities an element of control that they relinquished when they sold a 199 year lease. It is actually doubtful that increased runway size makes the runway any more attractive to any operators. Smaller sized airlines are continually going bust and the proposed size does not open the airport to use by any passenger planes that cannot already use the site. The reference to quieter and more fuel efficient are not backed up by any facts. What are we talking about in terms of decibels (residents have little concern about fuel efficiency as this is a trading issue)? It is hardly beneficial if we currently have 50 aircraft flying per day making 150dB of noise each, but expansion leads to 10dB noise reduction per aircraft, but 100 more aircraft taking off every day.
The economic benefit is limited in terms of passenger spend as there is no expansion of the airport facilities and passengers will therefore travel straight through without spending locally.
Again no mention of cargo planes or indeed maintenance/training etc aircraft i.e the flights the council cannot control. I have referred to concerns regarding maintenance and flying of faulty planes in the area.
Issue 2
Para 1 - Excepting that we are talking about a dormitory town (and questioning why large scale employment is so crucial) why is the JAAP considered as the only key to employment and what is the connection to high-tech business. You can't just mention them in the same sentence for them to be connected there has to be a basis in fact and the report (unsurprisingly given that it is bereft of facts) omits to explain the connection. Given that Southend had in the 80's a significant number of office based employers and has now lost most of them, what makes it think that it can attract and retain such employers now? Again no clues as to methodology, only we'll build a big airport and they will come.
Para 2 - Does not make clear where this land is coming from, although it is surely green belt that is being lost, again, in the same area Cherry Orchard Way. Lots of talk about new jobs in business parks, although again nothing to say whether these are actually new to the immediate area or just movement from Hockley (closure of Eldon Way) or indeed other commutable areas in Essex.
Issue 3
Again sustainable is used without meaning. Only noise and air quality are mentioned, although cannot be certain that this will be in relation to road air and rail traffic. No note on water quality, loss of green belt etc. This is not new public open space; areas of open space are being lost and have been lost in the course of the development around notably Cherry Orchard Way and Eastwoodbury Lane.
What are the controls on the airport being considered; are they enforceable (particularly if challenged by the owner) and who will monitor?
What is sustainable transport policy? Again an unexplained term.
This section is undoubtedly unfairly biased and required re-submission.
Issue 4
I understand that the A127 has it's own restrictions on development as per liberal councillor Graham Langley. I would question therefore whether the council's real intention is not to place a bypass through Hullbridge, North Rayleigh, Hockley and Rochford, a plan previously rightly rejected?
i) there is no linkage to public transport and never has been. Deregulation of buses means that these do not link to rail services and the new rail station is not for use by locals. A13, A127 B1013 are already congested, A127 has speed restrictions and Eastwoodbury Lane will be closed and moved.
ii) Locals are forced to use cars due to lack of public transport connections and the fact that the airport rail service will not serve local stations. Bus services are systematically cut e.g 7 & 8 through Hockley and there is no direct link from Liverpool St Rail Line to C2C either by bus or rail. It is nigh on impossible to get people to refuse to use their cars and CPRE statistics show that the vast majority of workers and passengers will always prefer cars to public transport. Luggage and Public Transport do not make a good mix.
iii) What are the new routes - again nothing specifically mentioned, in the short term B1013 already (according to HAAP taking over 15,000 vehicles daily) will be used as a shortcut, increasingly so when the A127 speed cameras start to work and it becomes congested with cargo lorries. Again conclusion is that council will seek to introduce an unwanted bypass through green belt. Essentially the council are creating a problem expanding the airport and seeking to solve it to the detriment of residents with loss of more green belt.
Issue 5
Brickworks - there was I thinking the current policy was to build more houses not demolish existing ones. Another business park is to be built on open space, yet there is little demand for such a park, with vacant units througout both regions, plus Basildon etc. The council are using the flawed plans for Hockley and surrounding areas including the demolishing of Eldon Way to provide a false demand. This is disingenuous and wasteful (i.e not environmentally friendly), why demolish perfectly serviceable existing units just to create new ones? If access is so poor surely this should have been addressed when the bypass was build a few years back, what investigations are taking place into this waste of money?
B1 - again questionable that the demand exists
Area ii b) given the above is actually sensible to move the rugby club to an even more inaccessible spot? Some of these plans would have been more sensible if Southend United Football Stadium had been moved to Warners Bridge site of Southend Rugby Club (floodlights aren't an issue Highbury didn't have pylons), the railway station would have served a dual purpose (and SUFC could have got into Europe!!) The Rugby Club could then have either shared with Westcliff or moved to the site of Fossetts Way new SUFC stadium, more green belt would have been protected and transport links for the football stadium would at least have been maintained, another missed opportunity.
ii c) a green lung, nice that this has been acknowledged, a pokey site between an industrial estate and an airport runway i.e it can't be used for anything else, be honest don't try and dress it up as something it isn't, it is wholly insufficient for the purpose described.
iii) Why is more land being given over, the airport was given away as a freebie (£1) and the local authorities have little control over usage. Keep the land and keep control, allowing the hand over of more land compounds the earlier errors surrounding the 199 year lease.
iv) Identified as inefficient by whom and in what way? Another vacuous, unstabstantiated statement. does the cost of improvement outweight any potential benefit and who is expected to finance this? If units are not fit for purpose then surely it is up to the landlord or tenant to improve them not the taxpayer.
v) Loss of another sports pitch in the area then. We will soon be left with loads of concrete and designated country parks as only green areas, another poor suggestion. Presume East West Corridor will mean a road being built and houses will inevitably follow as the area will be termed 'under-used' within a decade.
vi) 'opportunity sites' - presumably for development? At least this is located next to existing industrial units.
vii) Flying Clubs - all to be kicked out (despite the fact they they do employ people)
viii) opportunity sites - say what you mean development sites, again the JAAP is trying to dress up the unpalatable.
ix) A green buffer a derelict site with a few horses and occasional circus. I hardly feel grateful, this area is currently an eyesore and clearly the report writer as with area ii c) couldn't think of another use. The flying clubs could be retained if the railway line was moved back here!
x) and xi) Loss of yet more amenities for Southend (once home to the largest amateur football league in the country). Demolition and rebuilding of a road that is only a few years old and at last admission that public transport isn't the answer so a park and ride service is required (although this could be omitted forcing passengers to use public transport)!!
4 Policies pg 17
Introduction Para 2 - It is apparently important to put the JAAP into context, but absolutely no attempt by the compiler to do so. It is unreasonable to expect ordinary residents with little or no experience to have to undertake lengthy research of information that the council have. In fact it could be argued that the council withholding this information is a deliberate attempt to prevent opposition, or perhaps just a glaring omission?
Energy saving technology is to be used (save lots of energy reject expansion) and sustainable drainage - what is this, yet another example of poor drafting.
Accepted that the JAAP cannot be looked at without plans for S.E. Essex, but again no clues and why are we restricted to this part of Essex why ignore Stansted and indeed other airport developments that the target passenger pool can use???? Again JAAP is flawed.
Employment allocations
Introduction
Why high scale employment growth? The term isn't explained, what type of employment and what are the employment aspirations. The area has relatively low unemployment, admittedly many people do not work locally, but this is because of the dormitory (and indeed retirement nature of this part of Essex, that the expansion will undermine and ultimately destroy. There is a limited pool of labour and there are no supporting statistics regarding the composition of the current labour pool or the required labour pool, there seems little point in creating jobs that cannot be filled.
Additional floor space - is this purely within the JAAP, what about other plans locally e.g HAAP where floor space is being reduced, meaning businesses are moving and new jobs are not created, just being relocated at the whim of the councils. The JAAP cannot on one hand say that it must be looked at in context and then ignore the context, this document is flawed again.
Upto 4950 jobs, how is this figure arrived at? It is unsubstantiated and unsupported and meaningless. Up to means just that any figure (including a negative) lower than 4950 is up to the JAAP requires amendment (again). In the area - is this the JAAP area, S E Essex? Are they JAAP related jobs and what are they - 'McJobs'? Same applies to the additional 750 jobs in Aviation Way. Non-specific, non factual and misleading.
E1 - another unsubstantiated figure, unclear if the jobs above are included in this figure or not. How do you split the jobs 50/50, who measures this and who is to say whether the airport brought those jobs. Remember a significant number of insurance companies merged in the 1990's and Southend lost jobs as a result, it had little to do with council policy. Just as conceivably an organisation could decide to move to Southend or Rochford, with airport expansion having no bearing on that decision.
E2 - Is this suggesting that in the middle of a recession busineses will have to pay to upgrade, I feel their sights may be elsewhere. No details on the financial contribution are given - how much taxpayer's money will be poured in and, as with the airport sold on at a loss? Are businesses going to be asked to donate or taxed, won't this be a disincentive to relocate?
This requires more detail and a lot more thought from the councils.
E3 - It is not reasonable to expect significant numbers of employees to walk or cycle unless they live very close to the units. Anyone living any distance will have to negotiate extremely busy (and probably busier roads), the cycle paths may well prove to be a waste of money, cause further unnecessary traffic to motor vehicles and should be properly costed.
Again business contributions comments as per E2 above
E4 E7 - No additional comment given rejection of the entire concept
E8 - As above how are job totals arrived at?
Overall comment on how and why businesses will contribute and what will be cost to residents
London Southend Airport
Introduction
Recognised that Airport can provide a boost - recognised by whom? another unsubstantiated and flawed statement.
Agree should have quieter aircraft, but fuel efficiency is a business decision not a local authority one.
Why must these aircraft be 150 seats again not explained?
Will aircraft development not actually catch up with the airport i.e. over the next decade larger aircraft landing on shorter runways (we then have a problem that we've bigger aircraft than the council currently envisage).
Why is the runway set at 1799m (I believe to avoid additional regulation of 1800, + runways)?
Are there any passenger aircraft with a full payload that cannot access at present that but can at 1799m? If so what types, what noise levels.
Expected that use will be passenger - expected by whom? Certainly not me. It is owned by freight forwarders who have stated they 'have found (their) Southern base'. Low Cost Airlines such as Easty Jet have a fleet requiring longer runways that proposed, who is the new airport aimed at?
Para 2 Growth in MRO - this means defective aircraft will be flown in over densely populated areas - the potential for disaster is huge and the council could/should be held accountable if a crash occurs (as it did in the 1980's).
If there is a demand for high skilled jobs, it is unlikely that applicants exist in sufficient number in this area and therefore, we would be reliant on migrant workers.
Whilst it is not considered desirable for the airport to handle large volumes of freight how much control would the council actually have over this? If the owners want to ship freight can they be stopped? If they want to extend the rail line (and Stobarts already have close ties with both Network Rail through Stobart Rail and Tesco's in terms of freight delivery) can they be prevented? If they want to run HGV's and vans in and out what can the council do? This is their core business. I would suggest that the professional businessmen at Stobarts are more than capable of giving amateur councillors the run around when it comes to what the airport will be used for. Local Authorities are very poor at refusing planning changes when business puts through a commercial reason. The first of these will be 'we can't attract viable passenger numbers we need to increase freight movements'. Once the extension is approved it cannot be repealed.
Para 3
Environmental constraints - no clues as to what these are how they are enforced (indeed if they can be) and what penalties are if airport users do no comply (saying sorry won't be enough) - will they pay compensation to individuals, where will the burden of proof lie? JAAP is deficient again.
The JAAP is also deficient in that no map of flight paths, stacking arrangements or noise levels at altitude (CPRE refer to these as noise contour maps). It seems anomalous to let the operator make his own statement, surely, if this extension takes place the council need to set noise levels and dictate to the user? Road noise (either freight or passenger) is completely omitted, as is rail noise.
Currently train services do not run through the night, but do stop near local stations when operating. The airport timetable will have non-stop trains. Additionally no details of freight movements, all of this is a complete omission and a justifies re-issue of the JAAP.
The A127 is an insufficient carriageway in its current form, particularly following the misguided speed reductions. Cycling facilities just take up vehicle space. I understand that there are limitations on the improvements that can be undertaken on the A127 due to it in part running through the Public Safety Zone, where major roads are not permitted, this is sufficient in itself to justify refusal of the proposal.
LS1 - this support of the expansion policy is unexplained. Why are 2 Tory councils supporting a misguided Labour policy, which basically entails concreting over anywhere that votes conservative? Solid reason should be provided for expansion.
LS2 - Permission
. Airport related - how tenuous does the link have to be for permission to be granted? this is yet another vague statement.
. Agreed baseline - this is undecided, does it require constant noise at one site or intermittent noise again far too vague. No details on who determines/measures etc. I will wager that all complaints about noise will be refuted by the operator. What about non-passenger flights, cargo, maintenance, training etc etc.
. Contributes to road infrastructure needs - positively or negatively and to what extent?
. Modal shift - what are the targets how and who measures the movement and who assesses whether the application is actually reasonable.
Again the JAAP is too vague to be meaningful.
LS3 - what sort of statement, what must this include. The JAAP note is meaningless and needs to be more prescriptive.
LS4 - again JAAP should be more prescriptive, this is meaningless.
LS5 - this is a restriction on the usage of residents property - does this contravene human Rights Legislation??
LS6 - Mentioned previously what is justification in passenger terms to increase the runway. Is there actually an advantage to the council and the residents to refuse 1799m, but approve 1800m?
LS7 -
. Times, unacceptable, 2300 is too late; this is some hours after dark in winter and makes no consideration in particular of the disruption that wil be caused to the sleeping pattern of children. Early mornings are also an issue for similar reasons. No mention is made of unscheduled flights and of cargo flights etc etc. The number of flights is not mentioned. If successful no-one will ever have another peaceful weekend.
. Cargo flights - require more restriction than just noise levels. No passenger flights at night (in noise controlled jets), but loads of cargo flights throughout the night using any available aircraft. what about maintenance/testing/training flights etc
. Routing - existing routes aren't shown, what are the plans for future routes. Again the JAAP is not fit for purpose.
. Helicopters - what more or less, operating heights? As these are vertical take off they could surely reach altitude over the airport before moving off?
. Restricted to what - will it pick up maintenance training testing etc?
. Ground running again unspecified JAAP too vague
. Training movements again unspecified JAAP too vague.
Terminal Facilities
TF1 repeats LS7, why? Is there in fact missing information here.
Maintenance repair and Overall
MRO1-3 what is justification for this, as previously stated surely this just increases the danger that the airport poses in a densely populated area. The possibility of contributions from business at the current time are surely fanciful.
Airport Development Zone
What criteria will be used to decide if development supports the airport and why is retail use refused?
Transport
What sorts of contributions are expected? What about the B1013, there is absolutely nothing to stop drivers using this as a cut through, especially given the days and reduced speed limits on A127?
T1 - where is this proposed to run?
T2 - and this?
T3 - why dual this road, unless there are plans to reintroduce the bypass via Hullbridge/Rayleigh/Hockley. Dualling only encouraes further traffic along the over used B1013 via Rayleigh
T4 as T3 this is encouraging traffic away from preferred route of A127
T5 - Loss of public amentities
T6 - there remains little incentive to use anything but a car, no car parking facilities forces the use of public transport - radical but true?
T7/8 - what sort of contribution - inevitably the tax payer will fund the bulk of this and how will the bill be met - wholly by Southend? who decides on contribution?
T9 - these are not provided with the JAAP again an omission
Environment
Introduction, this is not a green lung, the development is taking place on the green lung. already, the developments along and of Cherry Orchard Way have eaten into this and I understand that the development will downgrade further land making it easier to develop the area in the future. The green belt boundary isn't 'reviewed', it is obliterated. This is unacceptable.
Para 3 - what are 'high levels of environmental efficiency?' and 'sustainable drainage' more vacuous statements. These need to be clarified the document is once more deficient.
ENV1 - unacceptable loss of green belt (again) both councils seem to really object to green belt principles and look for any opportunity to develop such sites apparently seeing them as an inconvenience rather than a necessity and a desirable asset.
ENV2 - this is not new - it is open at prsent and it is at best misleading and at worst a downright lie to call it new. The JAAP is once more factually erroneous
ENV3 - as 2 above.
ENV4 - and if no contribution arrives does it happen or does the taxpayer get saddled with the bill? How will contributions be collected, surely this is a tax on new enterprise?
ENV5 not new public space again incorrect
ENV6 - this is constitutes 'no change' presumably because the land is so poorly sighted it is permitted to escape development
5.1 - JAAP provides no idea of what scale of limitations will be i.e. one in 3 units are occupied, how many jobs will result, how many of the contributions will be made.
5.2 - intended to provide detailed information - need more details now, not a washy statement that it is 'intended'. Sorry intended to but didn't get around to it. Should say 'Full details will be provided'.
5.3 You have my views. The report JAAP itself is deficient in factual information and misleading in the extreme. There is a lack of information given to the individual and it is not apparent that the council have advised necessary interested parties e.g RSPB. As such the process is substantially flawed, sufficiently so for the whole of this stage to be delayed whilst the JAAP is re-issued with sufficient information and clarification.
From my understanding of the proposals the councils are to a varying degree being incredibly naive, disengenuous, negligent and as such untrustworthy. Again this is sufficient to warrant review of the JAAP.
I understand that as part of the review process Rochford councillors visited Southampton Airport. I would suggest that although the runway size is comparable, to undertake a visit to an airport that doesn't permit night flights except in extenuating circumstances (max 10 per month 100 a year) and out of season is not going to provide any great insight. Especially given that the European Region Association (ERAA) shows the following freight movements Southend and Southampton in 2008:-
Southend 443 Tonnes reducing 19.6% from 2007
Southampton 264 tonnes reducing 10.5% from 2007
So the two airports are not as comparable as has been suggested especially since freight cargo uses older, noisier (propeller aircraft) rather than those 'quiet' jets for passengers and Southend is now owned by a freight forwarder.
Additionally back in 2002 the DfT recognised the lack of appeal of Southend as a suitable site.
5.4 Annual monitoring reports as main vehicle - who is going to pay for this? Planning departments are overworked generally who is going to ensure reports are issued in time, accurately, will business be able to wriggle out of conditions imposed.
Manston - an upper limit of 3 million passengers per annum was assumed. Manson has a long runway, and has a relatively supportive planning environment. Key constraints are its geographic positon in relation to the major sources of demand and noise impacts over the nearby town of Ramsgate.
Shoreham - an upper limit of 500,000 passengers per annum was assumed. The runway length is the key constraint to development.
Southend - a capacity of 2 million passengers per annum was assumed. constraints are the ability to lengthen the runway and noise impacts on residential areas of Southend.
12.13 In total, therefore, these airports might contribute capacity of about 6mppa by 2030. While our assessment of the contribution of each airport is not definitive, it is clear that, taken as a group, their overall contribution to meeting demand in the South East would be very small. Furthermore, it is doubtful that they would attract the level of traffic shown above if additional runways were built at major airports in the South East. In practice, passengers and airlines may prefer, even in a highly constrained situation, to fly from more distant, but larger airports outside the SERAS region.
12.14 some of the options discussed in Chapters 7-11 might have very direct implications for some of these smaller airports. For example, development of a new airport at Cliffe would probably require Southend to close.

Please refer to the attached document which lists all concerns with process and lack of information provided by the Councils concerned in respect of the JAAP. Again the demands placed upon objectors are onerous (as with the HAAP), namely the requirement to complete on-line or to file an individual form per objection are unfair and unwarranted. I understand however that this advice is actually waived upon request and as per my conversation with your offices! Attach one report for your attention lising all my issues with the JAAP at this time.
I expect a response to all queries raised.
The Councils have been extremely negligent in their duty to provide sufficient information.
At the present time the proposals are unacceptable in their entirety and there is nothing to suggest my opinion will change. I additionally support the comments made by campaign for protection of rural Essex (England) in their submission.
I am writing to object to the proposals contained within the London Southend Airport and Environs Joint Area Action Plan Preferred Options Dated February 2009.
I have a number of general objections regarding the process, documentation and manner of delivery as well as specific objections to the proposals and list these as follows:-
Flawed Process of Presentation.
1) There was little initial notification to the public of the first stage of consultation or the ramifications of not responding. We appear to have reached stage 2 of the process by default and dictation by the Councils, with stage 1 swept swiftly 'under the carpet' rather than the opportunity given to residents to undertake a considered process of weighing up the options. I do not believe that the majority, or even an adequate portion , of local residents understand the process and the JAAP documents do little to address this. Neighbouring authorities, that are also affected, will have had little input into the process and their residents no understanding of what is going on or what influence they can have. As such the process is flawed and details supplied inadequate. Unless the councils can demonstrate evidence to the contrary.
2) The selection of option three again has been decided adequate consideration of other options.
Whilst Southend Council have at least gone through the motions of offering roadshows to assist understanding RDC appear to have relied solely on advertising.
Notwithstanding this both Councils have failed to provide adequate information within the document, given their support of the proposal it must be concluded that this is a deliberate rather than just a negligent act and again calls into question the whole process.
As a bare minimum the JAAP should include :-
. Existing and post extension flight paths (how these may vary in inclement weather)
. Stacking arrangements in the event of runway closure/delays
. Basic statistics showing likelihood of inclement weather/runway closures and, as such how many times a year stacking arrangements and flight path changes are likely to be implemented and the anticipated number of flights this will affect.
. The types of aircraft able to take off, both before and after the extension (cargo, passenger and 'other')
. The minimum and maximum number of flights permitted (including split between cargo passenger, maintenance, training, testing) and flight times (including scheduled, non-scheduled, charter, training/testing/maintenance)
. The noise levels generated at ground level by the planes at altitudes - a noise map?
. expected plane altitude at say half mile intervals from take off/landing
. expected traffic volume increases (Stobart and other firms lorries and vans) for A127, A130 and B1013 (Rayleigh - Hockley - Rochford Road), as a result of airport expansion and closue of Eastwoodbury Lane
. Expected train timetable changes (including non-scheduled freight movements) and anticipated delays as a result of new passenger trains.
. the fact that the trains for the airport are not going to provide a local service (thus local commuting to the airport by train remains inconvenient)
. confirmation as to whether or not Stobart can apply (and whether or not the councils have any power or inclination to prevent or resist) to make rail freight movements to the airport or the immediate vicinity
. Which jobs are genuine new jobs, type etc and which will be transferred from other parts of the district (and lets not limit ourselves to Rochford and Southend, because undoubtedly Castle Point and Basildon will be affected)
. A summary of the impact of other developments in the area, including redevelopment of Hockley, Stambridge Road, Hawkwell, Daws Heath etc etc. These should be clearly marked on a flight path map also.
. Confirmation of detailed plans for inevitable road expansion schemes that will be required to support increased road traffic. Particularly A127, where proposals incorporate the Public Safety Zone and whether the expansion will be used to push through the unwanted development of a bypass via Hullbridge/North Rayleigh/Hockley and Rochford?
As such I would view this as a basic dereliction of Council duty - failure to inform and ensure that the interests of residents are looked after. I understand also that this may breach the Freedom of Information Act and RDC's own consultation strategy
3) The Councils have apparently selected the least popular option, although conveniently neglected to inform residents as to how or why this decision was arrived at. The only factor that seems to offer any support for their decision is 'increased jobs'. Various figures are quoted all prefixed by the worlds 'upto'. This term is 'up to' is sufficiently vague to mean that any number (including negative ones) below the figure quoted would be deemed a success. As such it has no place in the document as it constitutes mere speculation. Hard facts and details of how conclusions are arrived at are needed.
As such the information provided is surely skewed and the Councils are seemingly abusing their position in recommending the proposal with absolutely no solid evidence to back up the position.
4) The connection of this scheme with other projects in the area, notably a number of house building projects including those mentioned in 2) above, is not made clear Government document PPS12, makes clear reference to :-
Every local planning authority should produce a core strategy which includes :
1) an overall vision which sets out how the area and the places within it should develop;
2) strategic objectives for the area focussing on the key issues to be addressed;
3) a delivery strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered . Locations for strategic development should be indicated on a key diagram; and
4) clear arrangements for managing and monitoring the delivery of the strategy.
Whilst this document is no doubt available somewhere it should be included with the JAAP, since without it the JAAP is not placed in the required context, without clear direction it is impossible to understand how or why this is intended to be part of the core strategy.
Additionally how have residents been consulted on the overal strategy, because if that exercise is flawed - and certainly the desire to build more homes in a densely populated area, whilst simultaneously expanded an airport, demonstrates that it is, then much if not all of the sub-plans such as this area also flawed.
PPS12 also refers to
Period of operation
4.13 The time horizon of the core strategy should be at least 15 years from the date of adoption.
As above there is no clear advices as to where the JAAP fits in the core strategy or where we are in the time horizon. Again the document lacks context, although it even states that it must be read in context, it provides little clue on how to do this.
PP12 also refers to
Statements of Community Involvement:
An SCI should
. Explain clearly the process and methods for community involvement for different types of local development documents and for the different stages of plan preperation. This needs to include details of how the diverse sections of the community are engaged, in particular those groups which have been underrepresented in previous consultation exercises.
. Identify which umbrella organisations and community groups need be involved at different stages of the planning process, with special consideration given to those groups not normally involved.
. Explain the process and appropriate methods for effective community involvement in the determination of planning applications and where appropriate refer to Planning Performance Agreements.
. Include details of the LPA's approach to pre-application discussions.
. Include the LPAs approach to community involvement in planning obligations (S106 agreements).
. Include information on how the SCI will be monitored, evaluated and scrutinised at the local level.
. Include details of where community groups can get more information on the planning process, for example, from Planning Aid and other voluntary organisations.
. Identify how landowner and developer interests will be engaged.
These above items from the PPS demonstrate the assistance that should be given to ordinary residents (and others) in the process. As mentioned by Campaign for Protection Rural Essex a number of organisations should have been consulted including RSPB; Essex Wildlife Trust etc. It is disingenuous and perhaps even negligent of the council not to include these within the Action Plan. Most people have very little experience of dealing with documents such as this and it is only at this late stage in the process (given that we've already passed through stage 1) that RDC and Southend BC have offered even limited advice. Even having read as much as I can in the past few weeks, I (and I am certainly not alone in this) have very little information regarding :- the crucial stages in the process; whether residents can succeed in resisting or changing any aspect of the proposals - RDC really should explain the steps in simple terms. At the moment we seem to progress from one stage to the next with absolutely no guidance. For instance:- I understand from information received from other sources in relation to the airport, that unless I head this document as an objection it is merely treated as a comment. I believe petitions are ignored. I will need to get my wife to make a separate submission in order for her views to be considered, even though we agree. The council seems quite happy to tell people how to make positive comments, but far less inclined to advise on how to object - hardly democracy and clearly demonstrating a deficiency and unfairness in the process, that should be revisited before we move ahead.
PPS12 again
Justification of Core Strategies
4.36 core strategies must be justifiable: they must be:
. founded on a robust and credible evidence base; and
. the most appropriate strategy when considered against the reasonable alternatives.
As above we cannot be sure that the base is robust and credible or indeed the most appropriate when considered against reasonable alternatives, since we don't know how and why the initial alternatives were first selected and then rejected. The JAAP provides no evidence base to affirm that the selection or the process is credible and again the JAAP requires review and re-issue.
If this is the preferred option, what was the basis for selection and will any ideas arising from the consultation be put forward for further consideration? Is it possible (likely) that if decent alternatives are proposed in stage 2 the preferred option will be amended and re-submitted? If not then, again, the process is flawed.
5) The document produced glowingly mentions the positive aspects and underplays the negative - surely the document should be impartial and genuinely enable residents to make up their own mind? Plenty of rhetoric about jobs new businesses etc but no details and certainly no information on the negatives, noise, congestion, loss of property value, decline in overall living standards etc. Basic research reveals Stobart's close ties with Tesco and Network Rail are we going to end up with a huge Tesco distribution centre supporting the airport, similar to their Dudley operation?
While the JAAP includes a brief note that the airport is unsuitable for large scale cargo operation (only a niche operation). The terms 'large-scale' or 'niche' are undefined, will mean different things to different peope and are therefore meaningless in the context of the JAAP, again this requires clarification and re-issue. Notwithstanding this the actual use is surely the decision of the owners and not the councils? Stobart management are already quoted as saying upon the purchase of the airport 'we have found our Southern Base', doesn't really sound like they are planning a limited operation, quite the opposite.
It is also unclear where any 'new' jobs and businesses will come from. Given the proposals and redevelopment of Hockley it is apparent that a number will come from there and therefore aren't really new. Again disingenuous of RDC in relation to the HAAP (and Southend BC not to make this clear in the JAAP that a proportion of jobs at the Airport sites will actually be moved from Hockley)
6) The document itself is devoid of factual information, although admitting that aspects will be supplied later, this itself smacks of a rush job. We find ourselves moved on to a stage from which there is no going back without having the facts adequately presented. It seems that the councils are either negligent in preparation of the facts or trying to hide something.
Development of the airport could bring about a fundamental change to the area, not necessarily for the better and it is in resident's interest for all information to be divulged as soon as possible.
It also uses a number of undefined terms, notably around the word 'sustainable'. It could mean 'long-term use with minimal environmental impact', but it the council are not clear what meaning they are seeking to attach. Equally, there are (source Wilkipedia) different types of sustainability. Economic, Environmental and Sociopolitical, so there is significant room for confusion as to meaning and I'm quite sure most people have no understanding what is meant by sustainability in the context of the JAAP.
7) The council is geared very much to receiving information via the internet, whilst undoubtedy this is cost effective; it is unfair on those residents that do not have internet access, particularly the elderly who make up a significant proportion of the population in the area. It is doubtful therefore that the views obtained will actually be representative of all residents. I note at election time certain parties are very keen to get their voters to polling stations and will provide transport - I wonder how keen those same councillors are to dedicate time and petrol to those residents wishing to get assistance in completing JAAP.
Completion on line is actually quite difficult and near on impossible if you have lengthy comments to make. Again the councils are colluding to dissuade residents from making anything but the briefest of contributiions.
Additionally the representation form states that each objection/comment requires completion of a separate form. Clearly this is actually designed to put people off commenting. Although I understand from a telephone conversation with RDC planning department that the council will accept one form with clearly listed comments. I would have to question whether RDC/Southend BC can actually determine what form objections may take. Again the process appears flawed, as this is biased towards acceptance of JAAP. At best this builds mistrust between residents and the councils as to motive; at worst it is downright dishonest.
The JAAP relies too much on the reader having a detailed knowledge of planning terminology and documentation, mentioning a significant number of undefined, unexplained and unreferenced terms and documents (as mentioned later) and omitting adequate cross-referencing. As such it is an inaccessible, inadequate document not fit for purpose and until it is adequately amended and re-issued the consultation process is flawed.
8) Rochford Council's own Leisure document refers to Rochford being the 'Green Gateway', clearly there is a desire to put a wall up given the amount of building that has occurred in the West of the District - this needs to stop. The local infrastructure cannot cope:-
B1013 is a hugely busy Road already - HAAP refers to 15,000 + vehicles back in 2007 and significant building has taken place since then. If the Airport expansion takes place, and RDC regretfully support this, then further transport issues will arise.
What plans are considered for a major disaster, large aircraft crashing on residential or occupied business property? In the US 7 of the last 8 fatal commercial airline crashes involved regional airlines (BBC 12th May 2009) or indeed hijack, bearing in mind proximity to major centres of population, power stations etc.
What additional policing/customs and immigration officers will be supplied, both at the airport and elsewhere in the region? Not only do illegal immigrants use lorries to access the country (and a cargo terminal will increase the amount of vehicles in this part of Essex), but aircraft have also previously been used (e.g at Stansted). Additionally there are the increased risks associated with drug smuggling, particularly given that criminals may seek to use the nearest available market for contraband. There is also an increased likelihood (with increased vehicles) or road traffic offences, which speed cameras do not address. What additional resources will be provided to the NHS to deal with the upsurge in stress, sleeplessness and associated problems including violence and accidents?
9) No explanation has been given as to why RDC/Southend BC support Government policy (I have asked my local councillors and MP to explain this apparent anomaly) there seems to be no desire to protect the quality of life enjoyed by residents, certainly much of this part of Essex has previously shown (in Government statistics) to be one of the least deprived areas of the country, yet the proposals seem to treat it as though it is one of the most deprived - is this wishful thinking on the part of the compile? As recently as 2006 Southend was calculated to be the best place to retire to.
10) Both Councils are keen to promote the area as a great place to visit yet surely this will be the death knell for tourism, the only visitors will be those waiting for a plane to get away from an overly congested cargo handling centre.
11) There is no clear mention of what controls are able to enforce (and indeed whether they would agree on these). Given the track record of local authorities but locally and countrywide in rejecting and/or enforcing actions against big business and national government e.g totally inability to prevent McDonald's and Tesco building where they like and the fiasco of the change of use of Bullwood Hall prison I rather suspect that if the expansion is approved Stobart's will ride roughshod over any objections from residents irrespective of whether the council's support the residents.
12) No account appears to have been taken of the wider questions regarding airport usage. Aside from the environmental impact, the reduction of carbon emissions etc is supposed to be at the forefront of business, government and local authority strategies, and the JAAP clearly goes contradicts this. Why have the following not been mentioned.
a) Southend is only accessible from the East and North (there is so little to the West it is hardly worth mentioning and is obviously cut off fromt Kent by the Estuary). As such the Pool of passengers it is supposed to be attracting is actually very limited. To the North sits Stansted whilst to the East, London and the various airports accessible from there.
b) Why the runway is being extended to 1799m and not 1800m (something I believe to do with extra regulation), when this doesn't actually allow for any passenger planes that are larger than the current users to land.
c) With perhaps the exception of Luton, every major airport easily accessible from London i.e Gatwick, Stansted, Heathrow and London City itself have expansion plans in the pipeline, as such the need for expansion of Southend as a passenger airport is questionable if not foolhardy.
d) Most recent figures for air travel suggest that this form of transport is actually declining.
It would actually suggest that the freight forwarder Eddie Stobart has an entirely different motive for expanding the airport.
13) Apart from neglecting to place sufficient significance upon the fact that a freight forwarders now own the airport and thus that the expansion will cause increased in cargo shipments in the air and on the ground, I fully support the comments made by Campaign for Protection for Rural Essex (part of CPREngland).
14) The councils have made no mention of the plans to ease road congestion that expansion will undoubtedly bring. I anticipate that you will seek to resurrect the misguided and previously rejected plans to further develop on green belt by building a bypass across Hullbridge, North Rayleigh Hockley and Rochford, just exacerbating the over-development of this area.
Nor is the impact upon rail timetable and whether there is sufficient rolling stock available for the new train service (i.e whether existing commuter carriage availability will be cut to provide airport services) explored.
Specific Areas of the Report
1.1 - Integrate land use, transport and regeneration proposals. Arguably this area is not in need of significant regeneration, the decision seems to have been taken with no investigation of regeneration needs (certainly no evidence is provided) and one might question why redevelopment is actually necessary).
Reference to 'managing growth and change by establishing development and design principles' - where are these, who decides them and what is the decision making progress?
Safeguarding areas and places sensitive to change - surely development of the airport contradicts this, the development includes extensive building in green belt, a definite area sensitive to change.
JAAP is one of a number of DPD's and must apparently be read in conjunction with them, but there are no clues as to which ones or how or where you can find these - again a fundamental failing of the document and the process.
1.2 - Detailed examination, undertaken by whom and what evidence supports this? Although reference is made to such items such as best practice guidance, socio-economic statistics and published data etc - this document is wholly bereft of specific evidence of factual support and this appears to be a deliberate strategy employed by the councils (motive unclear) to prevent such data being challenged i.e the council saying we looked at the data and concluded, but not specifying which data and how they arrived at the conclusion. Surely this is not an open government and seems suspicious if not dishonest and/or negligent.
1.3 - Sustainability Appraisal - a term not fully explained. Apparently stage one required a scoping report, although again this is unexplained and we have no idea of the basis of this. Omission of even a path of reference, let alone an appendix is again a dereliction of duty.
1.4 - The JAAP will provide 'framework' for regeneration and expansion of London Southend'. Leaving aside the fact that Southend is not London (although the way development is going it seems inevitable it will be a suburb, probably this century), it seems decided then we are going to expand the airport. Surely you cannot make this statement, there is a process to go through (even if you are paying lip service), legally this statement is incorrect, as it can only provide a 'suggested framework'.
The JAAP apparently takes into account the current uses, transport, impacts, etc although as I shall make clear later anyone taking the time to read the whole document will realise that it is hopelessly inadequate, merely stating that it takes factors into account but providing no evidence or examples.
Again this paragraph is, at best, misleading and borders on dishonest. It seeks to reassure people that the negative impacts have been taken into account (in fact the opposite appears to be the case) without providing any evidence that they have.
1.5 - Feedback, where was this obtained, who considered it, how did they arrive at the conclusions, who reviews, again a flawed, unsubstantiated statement and process.
1.6 - Paragraph 1 final world 'sustainable' an undefined term within the context of the document.
Future of Transport White Paper (again not provided as an appendix) I understand that this is opposed by a number of environmental Groups and itself needs reviewing given recent changes in the economic climate and the overall downturn in aircraft usage, independent of the recession.
Para 2 - It is hugely questionable as to why Southend Airport requires expansion when, as already mentioned, in passenger terms, it has such a poor catchment area. It is inaccessible from the South due to the Estuary; to the East is the North Sea, to the North a much better sited airport and infrastructure in terms of Stansted, leaving only the West as a population centre. However anyone living to the West has the choice of Gatwick, Heathrow, Stansted, Luton and London City, all, with the possible exception of Luton having expansion planned.
Part 3 significant job opportunities - again undefined as to what significant means and what type of jobs are referred to (McJobs)?. Given the competition from the above airports it would require significant, unwelcome further expansion for business to be attracted because of the airport. Businesses decisions are made for reasons unrelated to the airport, yet the report suggests that development would be a major driver for business (but does not say why or what type of business). Southend lost virtually every major office employer since I worked there in the 1980's. Most major insurers and brokers merged and moved out of Victoria Avenue, as did various government departments (due to National government strategy) and BT, this had absolutely nothing to do with the airport and attracting these businessses back will probably have equally little to do with an airport.
Why is the commuter belt aspect of the region completely ignored? Many people commute to work and bring money back to spend locally. Similarly the retirement aspect is also ignored completely. It is questionable whether there is any great need for huge swathes of industry in this part of Essex.
Tourism desination is an absolute joke, the region is overdeveloped and the only tourists would be waiting for a plane to get away.
Para 4 - why is only the airport considered to be a drive for economic development? Holidaymakers pass straight through to their destination and most companies are cutting back on expenses such as business flights and use of technology (video-conferencing etc) renders their need redundant. We can surely only be talking about freight movement????
Again paragraph 4 refers to 'employs a significant number' is non-specific as to quantum or job types. Are you including the airport trading estate? I've shopped there, but I've never flown from Southend, it is totally unrelated and again the document is misleading.
Surprisingly the JAAP refers to a specific document, but gives no clues as to where to find the Rochford Core Strategy Preferred Options Document.
Para 5 - Transport issues are understated and it really does seem rather pointless to even attempt to expand such a small airport and blight the whole area for good for a few weeks in 2012. European visitors would be far better served by train, whilst longer haul flights cannot land on a runway this size.
Para 6 Who sees the airport as important for development and prosperity? Another vague statement dressed as fact. I see it as actually the beginning of a sustained decline in the area as the affluent move away, house prices fall due to noise and congestion from air and road freight and the area goes into, pardon the pun, terminal decline. Again future employment needs take little account of commuting.
2.1
Para 1 The context against which the JAAP is set is now outdated, having been drawn up in time of boom and when it was inconceivable that banking institutions would have to be underwritten by National Government to the extent they now are. The financial pattern of this and other countries have changed fundamentally and it will be a significant time before things get back to normal (over 20 years), loans are no longer freely available and the 'Vision' clearly needs to be re-visited.
Para 2 - refers to quality of life for residents is mentioned, but actually not expanded upon in the report. It is quite clear that expansion of the airport will reduce the quality of life for all but a very few number of residents i.e those fortunate enough to be directly employed in senior positions.
Para 3 - London Southend Airport as a 'major employer' - again an undefined term
. How many people does the airport directly employ (I suspect that many of the jobs are in fact secondary and even if the airport closed work would be taken up by other airports e.g Stansted or London City and the jobs would remain within commutable distance)?
. How many of the jobs are actually in the adjacent business park and in reality unrelated to the airport?
. How many of the jobs will actually be lost upon expansion (e.g those at the flying clubs that are being pushed out, businesses that are forced to close due to congestion etc)?
. How many of the jobs would actually remain if the airport was unaltered?
. Why isn't the spare capacity being used?
. What could be done to improve the spare capacity usage?
. What are the costs/benefits in picking up the spare capacity?
. Why, if the airport is so important, won't it become a success without expansion?
All basic questions the JAAP fails to address.
Para 4 - what is the 'current and emerging policy framework in the area'? again an undefined and meaningless phrase.
Para 5/6 - Southend core strategy - wonderful, what other options were considered and why is Rochford so keen to support this if, as this document so clearly demonstrates, there are so few advantages and so many disadvantages for the area and its residents.
Para 7 to end
Who are/what is Renaissance Southend Regeneration Framework? Another undefined term. How they have arrived at the conclusion it should be a centre for international air services and then contradicted this by saying it would be a 'great place to live' - when it so clearly wouldn't with a huge number of planes flying over head day and night. Rochford Council have a similar objective in making this a great place to live!!! I've lived in the region all my life, with these proposals I have no desire to continue to do so (but my options will be restricted by the resultant slump in house prices the expansion will cause)
Again there is very little mention that most of the towns in the region are actually dormitory towns for London e.g. Rayleigh. The desire to encourage employment is actually questionable on this basis. Higher salaries are always available in the City and vast airport expansion would probably require a significant number of migrant (possibly overseas) workers to fill vacancies.
Hi tech businesses tend to be low scale employers and no examples are given of 'high value employment'. This is pie in the sky aspiration with no basis in fact; it should be only be included in the JAAP if noted as such.
2.2
Para 1 - again refers to unreferenced material, planning documents etc, and it is impossible to know if this has been fairly assessed or just the bits chosen to fit.
The objectives are:
. Creation of sustainable and high value employment and other land uses within the study area; - what is 'high value' and what 'other land' - this is a vague and washy statement requiring amendment.
. Maxamising the economic benefits of a thriving airport and related activity: - is this at all costs?
. Ensuring appropriate improvements in sustainable transport accessibility and facilities; what is appropriate (who decides) and sustainable again undefined what other plans are the Council's proposing to run off the back of airport expansion? the rightly rejected Hullbridge to Rochford bypass???
. Ensuring a high quality environment for residents whether expressed through noise pollution management or protection of green space: what about congestion, air quality from road pollution etc?
. Maximum return on public investment through attracting inward investment; and is this at all costs?
. Efficient use of existing employment land resources. Is this at all costs?
2.3
Economic growth and new jobs. Again no consideration that the area is largely dormitory, no mention of the type of jobs and the fact that the airport expansion could have a negative effect with wealthy moving away and the area actually being an undesirable place to live, spiralling into decline.
Para 2 - Why will it be successful when there is significant competition from Gatwick, Heathrow, London City, Luton and Stansted all of which have better infrastructure and passenger pools as well as expansion plans. The proposed runway extension offers no increase in options for passenger plane access, as it cannot cope with any larger planes than the present runaway, as such the extension should be rejected as it fulfils no purpose.
Passengers will travel on the same planes they do at the moment and no plane is quiet or fuel efficient, especially when you consider that in excess of 20,000 flights per annum will take place (25,000 according to CPRE). It could even be argued that Southend should withhold expansion until plane technology improves to allow even shorter take-off and landing?
Conclusion would be that passenger use is to be secondary to cargo use and that Stobart have little intention of promoting the passenger aspects, except as a means of additional profit to their core operation, the movement of freight.
Fast food access is not possible the speed limit on the A127 is now 50mph for large stretches and is interrupted by numerous sets of traffic lights. Congestion problems will be exacerbated by any increased cargo usage at the airport, which will see the number of vehicles increase. No mention here of closure of Eastwoodbury Lane/A127 Public Safety zone or use of A130 or B1013 all of which will be problematic.
Para 3
Maintenance and repair - this implies that faulty aircraft will be flying over densely populated areas in order to be fixed. Given that the last time Southend had a significant cargo operation a plane crashed on Rayleigh (at night, on the only commercial premises in a residential district) it may be tempting fate to suggest that you are rather chancing residents luck with this proposal.
Restrictions on night flights - again unspecified as to what these will be and how they will be enforced. No consideration to schools, hospices, hospitals, etc etc let alone resident.
Part 4 - award winning, which award and by whom a vague statement. How can this be an enhanced Green Lung - it was built on open fields, it is disingenuous of the council to suggest otherwise, could we not have had a wide open space rather than a confined Country Park?
We've already lost significant open space, including recreational amenities to make way for Tesco's RBS etc and the link road developments. What are the 'quality jobs', undefined term and how is it to be guaranteed that they are for local people - if they are that good surely everyone will want it; again this is a misleading statement and should be withdrawn or amended.
Part 5 - Lets be clear an area for plane spotters and the poor souls living nearby.
Part 3 - Issue 1
Para 1 The railway increases the catchment, but doesn't decrease the competition from other better designed and strategically placed airports, notably Stansted. The rail line doesn't allow locals to access the airport so actually offers no benefit to those in the near vicinity.
Para 2 - Runway size is a constraint; this is not necessarily a bad thing and does give the local authorities an element of control that they relinquished when they sold a 199 year lease. It is actually doubtful that increased runway size makes the runway any more attractive to any operators. Smaller sized airlines are continually going bust and the proposed size does not open the airport to use by any passenger planes that cannot already use the site. The reference to quieter and more fuel efficient are not backed up by any facts. What are we talking about in terms of decibels (residents have little concern about fuel efficiency as this is a trading issue)? It is hardly beneficial if we currently have 50 aircraft flying per day making 150dB of noise each, but expansion leads to 10dB noise reduction per aircraft, but 100 more aircraft taking off every day.
The economic benefit is limited in terms of passenger spend as there is no expansion of the airport facilities and passengers will therefore travel straight through without spending locally.
Again no mention of cargo planes or indeed maintenance/training etc aircraft i.e the flights the council cannot control. I have referred to concerns regarding maintenance and flying of faulty planes in the area.
Issue 2
Para 1 - Excepting that we are talking about a dormitory town (and questioning why large scale employment is so crucial) why is the JAAP considered as the only key to employment and what is the connection to high-tech business. You can't just mention them in the same sentence for them to be connected there has to be a basis in fact and the report (unsurprisingly given that it is bereft of facts) omits to explain the connection. Given that Southend had in the 80's a significant number of office based employers and has now lost most of them, what makes it think that it can attract and retain such employers now? Again no clues as to methodology, only we'll build a big airport and they will come.
Para 2 - Does not make clear where this land is coming from, although it is surely green belt that is being lost, again, in the same area Cherry Orchard Way. Lots of talk about new jobs in business parks, although again nothing to say whether these are actually new to the immediate area or just movement from Hockley (closure of Eldon Way) or indeed other commutable areas in Essex.
Issue 3
Again sustainable is used without meaning. Only noise and air quality are mentioned, although cannot be certain that this will be in relation to road air and rail traffic. No note on water quality, loss of green belt etc. This is not new public open space; areas of open space are being lost and have been lost in the course of the development around notably Cherry Orchard Way and Eastwoodbury Lane.
What are the controls on the airport being considered; are they enforceable (particularly if challenged by the owner) and who will monitor?
What is sustainable transport policy? Again an unexplained term.
This section is undoubtedly unfairly biased and required re-submission.
Issue 4
I understand that the A127 has it's own restrictions on development as per liberal councillor Graham Langley. I would question therefore whether the council's real intention is not to place a bypass through Hullbridge, North Rayleigh, Hockley and Rochford, a plan previously rightly rejected?
i) there is no linkage to public transport and never has been. Deregulation of buses means that these do not link to rail services and the new rail station is not for use by locals. A13, A127 B1013 are already congested, A127 has speed restrictions and Eastwoodbury Lane will be closed and moved.
ii) Locals are forced to use cars due to lack of public transport connections and the fact that the airport rail service will not serve local stations. Bus services are systematically cut e.g 7 & 8 through Hockley and there is no direct link from Liverpool St Rail Line to C2C either by bus or rail. It is nigh on impossible to get people to refuse to use their cars and CPRE statistics show that the vast majority of workers and passengers will always prefer cars to public transport. Luggage and Public Transport do not make a good mix.
iii) What are the new routes - again nothing specifically mentioned, in the short term B1013 already (according to HAAP taking over 15,000 vehicles daily) will be used as a shortcut, increasingly so when the A127 speed cameras start to work and it becomes congested with cargo lorries. Again conclusion is that council will seek to introduce an unwanted bypass through green belt. Essentially the council are creating a problem expanding the airport and seeking to solve it to the detriment of residents with loss of more green belt.
Issue 5
Brickworks - there was I thinking the current policy was to build more houses not demolish existing ones. Another business park is to be built on open space, yet there is little demand for such a park, with vacant units througout both regions, plus Basildon etc. The council are using the flawed plans for Hockley and surrounding areas including the demolishing of Eldon Way to provide a false demand. This is disingenuous and wasteful (i.e not environmentally friendly), why demolish perfectly serviceable existing units just to create new ones? If access is so poor surely this should have been addressed when the bypass was build a few years back, what investigations are taking place into this waste of money?
B1 - again questionable that the demand exists
Area ii b) given the above is actually sensible to move the rugby club to an even more inaccessible spot? Some of these plans would have been more sensible if Southend United Football Stadium had been moved to Warners Bridge site of Southend Rugby Club (floodlights aren't an issue Highbury didn't have pylons), the railway station would have served a dual purpose (and SUFC could have got into Europe!!) The Rugby Club could then have either shared with Westcliff or moved to the site of Fossetts Way new SUFC stadium, more green belt would have been protected and transport links for the football stadium would at least have been maintained, another missed opportunity.
ii c) a green lung, nice that this has been acknowledged, a pokey site between an industrial estate and an airport runway i.e it can't be used for anything else, be honest don't try and dress it up as something it isn't, it is wholly insufficient for the purpose described.
iii) Why is more land being given over, the airport was given away as a freebie (£1) and the local authorities have little control over usage. Keep the land and keep control, allowing the hand over of more land compounds the earlier errors surrounding the 199 year lease.
iv) Identified as inefficient by whom and in what way? Another vacuous, unstabstantiated statement. does the cost of improvement outweight any potential benefit and who is expected to finance this? If units are not fit for purpose then surely it is up to the landlord or tenant to improve them not the taxpayer.
v) Loss of another sports pitch in the area then. We will soon be left with loads of concrete and designated country parks as only green areas, another poor suggestion. Presume East West Corridor will mean a road being built and houses will inevitably follow as the area will be termed 'under-used' within a decade.
vi) 'opportunity sites' - presumably for development? At least this is located next to existing industrial units.
vii) Flying Clubs - all to be kicked out (despite the fact they they do employ people)
viii) opportunity sites - say what you mean development sites, again the JAAP is trying to dress up the unpalatable.
ix) A green buffer a derelict site with a few horses and occasional circus. I hardly feel grateful, this area is currently an eyesore and clearly the report writer as with area ii c) couldn't think of another use. The flying clubs could be retained if the railway line was moved back here!
x) and xi) Loss of yet more amenities for Southend (once home to the largest amateur football league in the country). Demolition and rebuilding of a road that is only a few years old and at last admission that public transport isn't the answer so a park and ride service is required (although this could be omitted forcing passengers to use public transport)!!
4 Policies pg 17
Introduction Para 2 - It is apparently important to put the JAAP into context, but absolutely no attempt by the compiler to do so. It is unreasonable to expect ordinary residents with little or no experience to have to undertake lengthy research of information that the council have. In fact it could be argued that the council withholding this information is a deliberate attempt to prevent opposition, or perhaps just a glaring omission?
Energy saving technology is to be used (save lots of energy reject expansion) and sustainable drainage - what is this, yet another example of poor drafting.
Accepted that the JAAP cannot be looked at without plans for S.E. Essex, but again no clues and why are we restricted to this part of Essex why ignore Stansted and indeed other airport developments that the target passenger pool can use???? Again JAAP is flawed.
Employment allocations
Introduction
Why high scale employment growth? The term isn't explained, what type of employment and what are the employment aspirations. The area has relatively low unemployment, admittedly many people do not work locally, but this is because of the dormitory (and indeed retirement nature of this part of Essex, that the expansion will undermine and ultimately destroy. There is a limited pool of labour and there are no supporting statistics regarding the composition of the current labour pool or the required labour pool, there seems little point in creating jobs that cannot be filled.
Additional floor space - is this purely within the JAAP, what about other plans locally e.g HAAP where floor space is being reduced, meaning businesses are moving and new jobs are not created, just being relocated at the whim of the councils. The JAAP cannot on one hand say that it must be looked at in context and then ignore the context, this document is flawed again.
Upto 4950 jobs, how is this figure arrived at? It is unsubstantiated and unsupported and meaningless. Up to means just that any figure (including a negative) lower than 4950 is up to the JAAP requires amendment (again). In the area - is this the JAAP area, S E Essex? Are they JAAP related jobs and what are they - 'McJobs'? Same applies to the additional 750 jobs in Aviation Way. Non-specific, non factual and misleading.
E1 - another unsubstantiated figure, unclear if the jobs above are included in this figure or not. How do you split the jobs 50/50, who measures this and who is to say whether the airport brought those jobs. Remember a significant number of insurance companies merged in the 1990's and Southend lost jobs as a result, it had little to do with council policy. Just as conceivably an organisation could decide to move to Southend or Rochford, with airport expansion having no bearing on that decision.
E2 - Is this suggesting that in the middle of a recession busineses will have to pay to upgrade, I feel their sights may be elsewhere. No details on the financial contribution are given - how much taxpayer's money will be poured in and, as with the airport sold on at a loss? Are businesses going to be asked to donate or taxed, won't this be a disincentive to relocate?
This requires more detail and a lot more thought from the councils.
E3 - It is not reasonable to expect significant numbers of employees to walk or cycle unless they live very close to the units. Anyone living any distance will have to negotiate extremely busy (and probably busier roads), the cycle paths may well prove to be a waste of money, cause further unnecessary traffic to motor vehicles and should be properly costed.
Again business contributions comments as per E2 above
E4 E7 - No additional comment given rejection of the entire concept
E8 - As above how are job totals arrived at?
Overall comment on how and why businesses will contribute and what will be cost to residents
London Southend Airport
Introduction
Recognised that Airport can provide a boost - recognised by whom? another unsubstantiated and flawed statement.
Agree should have quieter aircraft, but fuel efficiency is a business decision not a local authority one.
Why must these aircraft be 150 seats again not explained?
Will aircraft development not actually catch up with the airport i.e. over the next decade larger aircraft landing on shorter runways (we then have a problem that we've bigger aircraft than the council currently envisage).
Why is the runway set at 1799m (I believe to avoid additional regulation of 1800, + runways)?
Are there any passenger aircraft with a full payload that cannot access at present that but can at 1799m? If so what types, what noise levels.
Expected that use will be passenger - expected by whom? Certainly not me. It is owned by freight forwarders who have stated they 'have found (their) Southern base'. Low Cost Airlines such as Easty Jet have a fleet requiring longer runways that proposed, who is the new airport aimed at?
Para 2 Growth in MRO - this means defective aircraft will be flown in over densely populated areas - the potential for disaster is huge and the council could/should be held accountable if a crash occurs (as it did in the 1980's).
If there is a demand for high skilled jobs, it is unlikely that applicants exist in sufficient number in this area and therefore, we would be reliant on migrant workers.
Whilst it is not considered desirable for the airport to handle large volumes of freight how much control would the council actually have over this? If the owners want to ship freight can they be stopped? If they want to extend the rail line (and Stobarts already have close ties with both Network Rail through Stobart Rail and Tesco's in terms of freight delivery) can they be prevented? If they want to run HGV's and vans in and out what can the council do? This is their core business. I would suggest that the professional businessmen at Stobarts are more than capable of giving amateur councillors the run around when it comes to what the airport will be used for. Local Authorities are very poor at refusing planning changes when business puts through a commercial reason. The first of these will be 'we can't attract viable passenger numbers we need to increase freight movements'. Once the extension is approved it cannot be repealed.
Para 3
Environmental constraints - no clues as to what these are how they are enforced (indeed if they can be) and what penalties are if airport users do no comply (saying sorry won't be enough) - will they pay compensation to individuals, where will the burden of proof lie? JAAP is deficient again.
The JAAP is also deficient in that no map of flight paths, stacking arrangements or noise levels at altitude (CPRE refer to these as noise contour maps). It seems anomalous to let the operator make his own statement, surely, if this extension takes place the council need to set noise levels and dictate to the user? Road noise (either freight or passenger) is completely omitted, as is rail noise.
Currently train services do not run through the night, but do stop near local stations when operating. The airport timetable will have non-stop trains. Additionally no details of freight movements, all of this is a complete omission and a justifies re-issue of the JAAP.
The A127 is an insufficient carriageway in its current form, particularly following the misguided speed reductions. Cycling facilities just take up vehicle space. I understand that there are limitations on the improvements that can be undertaken on the A127 due to it in part running through the Public Safety Zone, where major roads are not permitted, this is sufficient in itself to justify refusal of the proposal.
LS1 - this support of the expansion policy is unexplained. Why are 2 Tory councils supporting a misguided Labour policy, which basically entails concreting over anywhere that votes conservative? Solid reason should be provided for expansion.
LS2 - Permission
. Airport related - how tenuous does the link have to be for permission to be granted? this is yet another vague statement.
. Agreed baseline - this is undecided, does it require constant noise at one site or intermittent noise again far too vague. No details on who determines/measures etc. I will wager that all complaints about noise will be refuted by the operator. What about non-passenger flights, cargo, maintenance, training etc etc.
. Contributes to road infrastructure needs - positively or negatively and to what extent?
. Modal shift - what are the targets how and who measures the movement and who assesses whether the application is actually reasonable.
Again the JAAP is too vague to be meaningful.
LS3 - what sort of statement, what must this include. The JAAP note is meaningless and needs to be more prescriptive.
LS4 - again JAAP should be more prescriptive, this is meaningless.
LS5 - this is a restriction on the usage of residents property - does this contravene human Rights Legislation??
LS6 - Mentioned previously what is justification in passenger terms to increase the runway. Is there actually an advantage to the council and the residents to refuse 1799m, but approve 1800m?
LS7 -
. Times, unacceptable, 2300 is too late; this is some hours after dark in winter and makes no consideration in particular of the disruption that wil be caused to the sleeping pattern of children. Early mornings are also an issue for similar reasons. No mention is made of unscheduled flights and of cargo flights etc etc. The number of flights is not mentioned. If successful no-one will ever have another peaceful weekend.
. Cargo flights - require more restriction than just noise levels. No passenger flights at night (in noise controlled jets), but loads of cargo flights throughout the night using any available aircraft. what about maintenance/testing/training flights etc
. Routing - existing routes aren't shown, what are the plans for future routes. Again the JAAP is not fit for purpose.
. Helicopters - what more or less, operating heights? As these are vertical take off they could surely reach altitude over the airport before moving off?
. Restricted to what - will it pick up maintenance training testing etc?
. Ground running again unspecified JAAP too vague
. Training movements again unspecified JAAP too vague.
Terminal Facilities
TF1 repeats LS7, why? Is there in fact missing information here.
Maintenance repair and Overall
MRO1-3 what is justification for this, as previously stated surely this just increases the danger that the airport poses in a densely populated area. The possibility of contributions from business at the current time are surely fanciful.
Airport Development Zone
What criteria will be used to decide if development supports the airport and why is retail use refused?
Transport
What sorts of contributions are expected? What about the B1013, there is absolutely nothing to stop drivers using this as a cut through, especially given the days and reduced speed limits on A127?
T1 - where is this proposed to run?
T2 - and this?
T3 - why dual this road, unless there are plans to reintroduce the bypass via Hullbridge/Rayleigh/Hockley. Dualling only encouraes further traffic along the over used B1013 via Rayleigh
T4 as T3 this is encouraging traffic away from preferred route of A127
T5 - Loss of public amentities
T6 - there remains little incentive to use anything but a car, no car parking facilities forces the use of public transport - radical but true?
T7/8 - what sort of contribution - inevitably the tax payer will fund the bulk of this and how will the bill be met - wholly by Southend? who decides on contribution?
T9 - these are not provided with the JAAP again an omission
Environment
Introduction, this is not a green lung, the development is taking place on the green lung. already, the developments along and of Cherry Orchard Way have eaten into this and I understand that the development will downgrade further land making it easier to develop the area in the future. The green belt boundary isn't 'reviewed', it is obliterated. This is unacceptable.
Para 3 - what are 'high levels of environmental efficiency?' and 'sustainable drainage' more vacuous statements. These need to be clarified the document is once more deficient.
ENV1 - unacceptable loss of green belt (again) both councils seem to really object to green belt principles and look for any opportunity to develop such sites apparently seeing them as an inconvenience rather than a necessity and a desirable asset.
ENV2 - this is not new - it is open at prsent and it is at best misleading and at worst a downright lie to call it new. The JAAP is once more factually erroneous
ENV3 - as 2 above.
ENV4 - and if no contribution arrives does it happen or does the taxpayer get saddled with the bill? How will contributions be collected, surely this is a tax on new enterprise?
ENV5 not new public space again incorrect
ENV6 - this is constitutes 'no change' presumably because the land is so poorly sighted it is permitted to escape development
5.1 - JAAP provides no idea of what scale of limitations will be i.e. one in 3 units are occupied, how many jobs will result, how many of the contributions will be made.
5.2 - intended to provide detailed information - need more details now, not a washy statement that it is 'intended'. Sorry intended to but didn't get around to it. Should say 'Full details will be provided'.
5.3 You have my views. The report JAAP itself is deficient in factual information and misleading in the extreme. There is a lack of information given to the individual and it is not apparent that the council have advised necessary interested parties e.g RSPB. As such the process is substantially flawed, sufficiently so for the whole of this stage to be delayed whilst the JAAP is re-issued with sufficient information and clarification.
From my understanding of the proposals the councils are to a varying degree being incredibly naive, disengenuous, negligent and as such untrustworthy. Again this is sufficient to warrant review of the JAAP.
I understand that as part of the review process Rochford councillors visited Southampton Airport. I would suggest that although the runway size is comparable, to undertake a visit to an airport that doesn't permit night flights except in extenuating circumstances (max 10 per month 100 a year) and out of season is not going to provide any great insight. Especially given that the European Region Association (ERAA) shows the following freight movements Southend and Southampton in 2008:-
Southend 443 Tonnes reducing 19.6% from 2007
Southampton 264 tonnes reducing 10.5% from 2007
So the two airports are not as comparable as has been suggested especially since freight cargo uses older, noisier (propeller aircraft) rather than those 'quiet' jets for passengers and Southend is now owned by a freight forwarder.
Additionally back in 2002 the DfT recognised the lack of appeal of Southend as a suitable site.
5.4 Annual monitoring reports as main vehicle - who is going to pay for this? Planning departments are overworked generally who is going to ensure reports are issued in time, accurately, will business be able to wriggle out of conditions imposed.
Manston - an upper limit of 3 million passengers per annum was assumed. Manson has a long runway, and has a relatively supportive planning environment. Key constraints are its geographic positon in relation to the major sources of demand and noise impacts over the nearby town of Ramsgate.
Shoreham - an upper limit of 500,000 passengers per annum was assumed. The runway length is the key constraint to development.
Southend - a capacity of 2 million passengers per annum was assumed. constraints are the ability to lengthen the runway and noise impacts on residential areas of Southend.
12.13 In total, therefore, these airports might contribute capacity of about 6mppa by 2030. While our assessment of the contribution of each airport is not definitive, it is clear that, taken as a group, their overall contribution to meeting demand in the South East would be very small. Furthermore, it is doubtful that they would attract the level of traffic shown above if additional runways were built at major airports in the South East. In practice, passengers and airlines may prefer, even in a highly constrained situation, to fly from more distant, but larger airports outside the SERAS region.
12.14 some of the options discussed in Chapters 7-11 might have very direct implications for some of these smaller airports. For example, development of a new airport at Cliffe would probably require Southend to close.