1. Introduction

AsWE LIVE DIRECTLY UNDER THE FLIGHT PATH ALONG WITH MANY OTHERS, MORE THAN ANY OTHER REGIONAL AIRPORT IN THE UK,IT IS GREATLY MISLEADING OF THE JAAP DOCUMENT TO SUGGEST THAT THE 2 LOCAL COUNCILS HAVE DONE ANYTHING TO TO LIMIT OR REDUCE THE NUMBER OF PEOPLE WHO SUFFER FROM AIRCRAFT NOISE. THE COUNCILS HAVE LET THE LOCAL PEOPLE DOWN BY USING THEIR POWERS TO INCREASE THE FLIGHTS AND NOISE. MORE NIGHT FLIGHTS POSES A SERIOUS THREAT TO THE HEALTH OF ALL WHO LIVE UNDER THE FLIGHT PATH.THE DOCUMENT IS UNSOUND, HALF THE JOBS IT CLAIMS IT HAS GENERATED ARE JOBS TRAMSFERED FROM STANSTEAD AND NOT NEW JOBS. THE AIR PORT HAS TAKEN £MILLIONS OUT OF THE LOCAL ECONOMY BY THE DEVALUATION THE PROPERTY ON THE FLIGHT PATH AND IN THE SURROUNDING AREA OF THE AIRPORT INCLUDING OURS AND OUR NEIGHBOURS WHO ARE FINDING IT DIFFICULT TO SELL. THE LAST JAAP PROCESS SHOWED THAT AROUND 80% OF THE RESPONDANTS DID NOT WANT THE HIGH GROWTH SCENARIO FOR THE AIRPORT EXPANSION. lAST YEAR AN OPINION POLL SHOWED THAT 61% OF LOCAL PEOPLE WERE AGAINST THE EXPANSION OF TE AIRPORT

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.


The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion.

We are submitting this represtation on behalf of Westcliff Rugby Club.
We are a Community Amateur Sports Club (CASC). We have approximately 600 active members being:- 125 Senior players in 5 teams
; 325 Youth players from the age of 6 up to 19 years
; 150 Non-playing members

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.





The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion.

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.
The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion.

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. Southend and Rochford councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stansted. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.
The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion. Why have local views been ignored so completely?

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are sucking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad. And it is impossible to reduce greenhouse gas emissions by flying ever more aircraft. The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy. Worse still the councils have squandered public money on various facilities associated with the airport and the airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.



The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion.

This stage of the JAAP has completely ignored the previous representation made by residents, including myself. To get to this stage the councils have decided that the airport is fully supported, yet the respondents indicate that this is not the case. the concept and therefore the outcome is flawed.

We object to further expansion of the airport as local residents we are already suffering from the noise of the planes and the smell of the fuel on a regular basis.
Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK, How can this have been agreed in the first place let alone being further expanded this will only cause more misery and suffering for the local population.

The document is biased. Page 8 mentions the area (Southend) will benefit from the airport. No justification is offered to support the statement.

Page 10 paragrpah 2: how will smart card help tackle congestion? The local roads are already at capacity, taking more traffic will increase congestion, regardless of whether bus passengers are paying by card or cash.

Page 11 paragraph 1: mentions 20% of airport passengers should use public transport. What happens when they is not achieved?

The document states that "London Southend Airport must be able to accommodate new and future aircraft models that are quieter and more fuel efficient"
The description of the A319s currently operating from the Airport as the most modern and fuel-efficient is incorrect. These aircraft conform to chapter 3 of annex 16 to chapter 30 of the Chicago Convention. The specification for chapter 4 aircraft was agreed in 2006 and it is the policy agreed this year to aggressively replace chapter 3 aircraft with chapter 4 aircraft in order to meet commitments on reducing emissions. The replacement for the current A319 is the A319neo (new engine option). Both Boeing and Airbus are offering conversions by re-engining existing narrow bodied airliners to meet the new standard. The new engines provide greater fuel economy and therefore lower emissions of CO2; but are heavier, larger in diameter and produce less maximum power. This has the effect of increasing the takeoff run meaning that the increase in runway length has been negated. It also increases the landing weight and approach speed putting more impact load on the runway.
The operating costs of the A319neo (156 seats) and the A320neo (180 seats) are virtually the same and orders for the A319neo have dried up. Fewer than 30 A319neos but more than 1,400 A320neos are currently on order. EasyJet has no A319neos on order having converted their orders for A319s to A320neos, these aircraft are heavier and require a runway longer and stronger than that now at Southend.
EasyJet are said to be considering the Bombardier C series but only the CE100 (125 seats max) and CE300XT (145 seats max) could fly from Southend at maximum take off weight. The XT indicates extra thrust meaning the aircraft is over engined. The Bombardier C series cannot accommodate a standard airline freight container in its hold, and is therefore unlikely that this type will be suitable for easyJet operations. Airlines generally prefer a single soured fleet.
Of the aircraft currently using or proposed to use Southend, the Fokker 100, Boeing 737 600 series and Boeing 717 are chapter 3 aircraft. The Embraer 195 is a chapter 3 aircraft and requires a runway of 2,179 metres at maximum takeoff weight. Only the turboprop aircraft operating from the Airport such as the ATR 52/72 of Aer Arran have chapter 4 compliance. Correct decisions cannot be based on false or misleading information. The councils rely too heavily of the Airport for aviation related advice and this is heavily tainted by self interest.
The vast majority of passengers flying from London Southend Airport are seasonal holidaymakers. It is the current policy of easyJet to move its passenger profile away from holiday traffic to the more lucrative business travellers. To this end they have introduced allocated seating and some seating with increased legroom. Few if any of the routes currently being offered appear to have any potential for business travel. It would seem that the decision of easyJet to come to Southend has more to do with internal politics within the company than hard economics. EasyJet moved to East Midlands Airport but left in 2009 citing lack of profitability of seasonal holiday traffic which included flights to Faro and Ibiza. Aer Arran has already abandoned two of its routes, OLT Express has gone into receivership and Air Maestrick has delayed a decision to come to Southend.
The aviation industry is committed to reducing the amount of greenhouse gas emissions from its aircraft. The move to Chapter 4 aircraft is part of this process. The elimination of stacking where aircraft circle aimlessly waiting to land will make an additional major contribution to this process of reduction. The further development of Precision Air Navigation by which an aircraft will fly under computer control via satellite link in the most economical manner and land immediately on arrival is part of this scheme. To ensure immediate landing on arrival the airports that will be permitted to operate in the future must have autoland systems it is unlikely that Southend Airport would be able to justify the cost of the installation and running of such a system, or that the location is suitable. The large number of small airports in the UK complicate the air traffic control system and without autoland systems they will be unable to fully participate in the programs to reduce greenhouse gas emissions and will be forced to close. The standard length for a regional airport is likely to be set at 2,500 metres unless there are exceptional circumstances.
The consultation document looks forward to 2020 without any reference to the developments in aviation that will take place in that timespan. In view of this the document cannot be considered to have been drawn up in a rational manner and is therefor illogical and unbalanced. It is a legal requirement that such a document must be balanced, as it is not it is therefore unlawful.

Paragraph 1.2 Policy Evidence Base
In formulating a document concerning the development of an Airport it would seem to me that the report "What are Airport's Impacts Planning Guide Part 2" by C. Weston would be an obvious choice to include in the Evidence Base. This interesting and informative document is conspicuous by its absence. Furthermore it is easily downloaded via the Internet at no cost. The information it contains on the sources of pollution produced on airports is especially relevant with housing so close to London Southend Airport.
The information on bird strikes again is very relevant. I understand also from the Webb that a company called Safeskys has been engaged to monitor and administer the 26 kilometre diameter Bird Control Zone around the Airport. This stretches out a far as Wallasea Island where an EU directed conservation area to compensate for the loss of habitat for migratory wading birds, caused by DP World Port, is being established at considerable cost. I have been told that a number of dead herons have been found and this is very disturbing.
It is hard to imagine how a document such as this Submission Draft can have been written without consideration of the points that I have raised. The absence of the Planning Guide quoted indicates strongly that they have not been. This makes it unbalance and unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

Southend Airport has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and noise.
The JAAP does not take into account the adverse impacts on communities on the south side of the River Thames especially the Hoo Peninsula. The JAAP does not take into account the adverse impacts on amenity caused by noise and loss of visual amenity in this tranquil area. Residents have already complained to Southend Airport about noisy low flying aircraft over the village of Cliffe Rochester Kent. With the arrival of Easyjet to Southend Airport with their low flying and incredibly noisy aircraft it is already an absolute nightmare.
The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by the irresponsible and callous expansion of the airport. I have major concerns about Southend Airport operating night flights.
The document is unsound, it is based upon a series of false assumptions, including the claim that it will create jobs and that the airport is in any way "sustainable". Operations at Southend Airport are taking money out of the UK economy by encouraging ever larger numbers of people to take holidays abroad.
The first year of operations at the airport indicate that around 500 jobs have been created, of which around half were transferred from Stanstead. However an analysis provided by SEEFoE suggests that the number of tourists who travelled abroad exported around £300 million from the UK economy, which is equivalent to over 10,000 jobs lost to the Essex/London economy.
The airport has stripped £millions out of the local economy by devaluing property near the airport and flight path.
The last JAAP process showed that around 80% of respondents did not want the high growth scenario for airport expansion and an opinion poll last year showed that 61% of local people opposed expansion.
It is impossible to reduce greenhouse gas emissions by flying ever more aircraft. I am very concerned that any growth in air travel would result in the failure of Government to meet its target to cut CO2 emissions by 80% by 2050. The JAAP does not appear to take into account the adverse impacts of CO2 emissions from aviation, not just locally but nationally and internationally. Aviation is the fastest growing sector in terms of UK emissions.
I object to the proposed expansion plans due to the contribution it will make to climate change and the impacts this will have on biodiversity.
Any expansion at airports in the Thames Gateway will make it difficult, probably impossible for the Thames Gateway to achieve its emissions targets.

Please find attached a representation form and representations submitted on behalf of Essex County Council to the Draft Submission Document for the Southend Airport and Environs Joint Area Action plan, February 2013.

I would like to draw your attention to the lack of balance in the Evidence Base on which the Submission Draft is based. Sound conclusions cannot be reached if this Evidence Base is skewed in one direction. There are 22 reports but none on Third Party Risk, Bird Strikes or Pollution. The 2003 White Paper with its policy of predict and provide is now discredited. The new Government aviation policy (Draft Aviation Policy D.5 2013) no longer advocates new runways indicating that it does not now believe that there is a runway shortage. It also acknowledges some of the shortcomings of the current metric system for monitoring community annoyance. The following reports are available on the Internet and these should have been consulted for a sound judgement to be made. A structure is only as sound as the foundation on which it rests.
- The Aviation Environmental Federation (AEF) report Airport Risk and the Public Interest to Draft National Planning Policy Framework October 2011 Daniel Hewitt.

- The Aviation Environmental Federation (AEF) report Public Safety Zones: current policy and the case for change.

- What are Airport's Impacts Planning Guide Part 2 C. Weston.

- The Sky's the Limit: Policies for sustainable Aviation the Institute for Public Policy Research (IPPR).

- R&D Report 9636 Third Party Risk near Airports and Public Safety Zone Policy.

- Department for Transport DFT Circular 1/2002 10th July 2002 Control of Development in Airport Public Safety Zones.

An assessment of the increase in Third Party Risk should have been undertaken before permission to extend the runway was granted. This is not optional it is a legal requirement. The AEF report by Daniel Hewitt was highly critical of Southend for failing to carry one out.

It is therefore my contention that the whole document lacks balance and because of this is unsound. Because it is unbalanced as required by statute it is also unlawful.

Both councils claim that by encouraging the development of an airport that what they are pursuing is a sustainable policy. Also that this policy will provide long term economic benefits for the area. This could not be further from the truth.

Firstly flying operations at airports do not make money anywhere. Landing and takeoff fees are kept uneconomically low as too many airports compete for limited passenger numbers. The few airports that do not make a loss do so by auxiliary activities, shops selling duty free goods etc. The Manchester Airport Group recent purchasers of Stansted Airport are proposing a significant increase in the size of retail facilities at the airport for this reason. I have been reliably informed that easyJet has a three year agreement to fly free of charge from Southend and a Stobart shareholder blog appears to confirm this. Paul Kehoe CEO of Birmingham Airport in a recent article in the Times reached the considered conclusion the UK had twice as many airports as it could sustain and half of them should close. With a limited customer base and facing competition from successful surrounding airports London Southend Airport is very unlikely to be among the 50% that remain open. The current government view is that no new runway will be required until 2030. It is not a case of if the Airport closes but when. In the words of a dissatisfied Stobart shareholder RIP regional airports.

Secondly the governments forecasts for growth in passenger numbers flying are constantly being reduced as reality overtakes fantasy. The figure of 500 million passengers a year in 2030 forecast in the 2003 White Paper has been reduced to 343 million in 2013 forecast. This latest forecast is also unrealistically based on national economic growth of 2% per annum and jet fuel remaining at present prices. Subsidies from central government in the form of tax relief (no fuel duty, no VAT on fuel, tickets or services) and from local government at the expense of Council tax payers had kept the price of flying artificially low. This caused a boom in flying which reached its peak in 2007 and has declined steadily every year until 2011 losing 19 million passenger in that time. There was a small lift in the Olympic year of 2012 but the decline is expected to continue. People may be getting bored with flying; Ryanair failed to give away 230,000 free flights out of 1,1 million offered in 2012 and blamed passenger inertia. The airline industry is even now pressing for the removal of Air Passenger Duty in an attempt to stimulate demand. The preferential treatment of aviation will not be allowed to continue. Brendon Sewill Cambridge economics graduate and government advisor estimates the aviation has a taxpayer subsidy of £9.2 billion per year even after the Duty of £0.9 billion has been deducted. In February 2013 AirportWatch said that the aviation tourism deficit for 2012 was £11.2 billion. Though this has been falling since the financial collapse of 2008 it still equivalent to a loss of around 500,000 UK jobs. If adjusted for fair taxation the SPASM computer program reduces predicted passenger numbers to 315 million a year by 2030.

Thirdly business travel is unlikely to ever form more than a tiny part of the passenger profile at Southend; most are seasonal holidaymakers. Only 1 in 10 top executives cited air accessibility as a reason to choose a location for business. A KPMG survey of 801 top executives of foreign owned companies gave the reason for locating to the UK quality of life. Major Japanese companies have located in the Northeast of the UK where there is no direct air link to Japan. Claims that the Airport will encourage business investment have no factual basis. Major UK businesses such as Lloyds TSB, B Sky B and Marks and Spencer have reduced their business flights by 41% in the last two years. Cutting flights and using electronic methods of communication increased efficiency with less time spent out of the office.

Finally the growth in air travel is now in the Asia Pacific region not in Europe where it is static or declining. If in doubt look at where the orders for new airliners are being placed. The first all economy 800 seat Airbus A380 enters service next year; this could be well be the future of economy flying. The prospects for UK regional airports are dire; few are likely to survive an impending cull. The council's thinking is hopelessly out of date based on flawed evidence and as such unbalanced and therefore unlawful.