2. Vision and Objectives

The vision is patently irrational. You cannot increase the quality of life for residents and workers by subjecting them to increased aviation noise, pollution and the utter misery of night flights. Other than by the poorly-used railway station, the airport is reachable only via residential roads. The local road network is not able to cope with the proposed volume of traffic and this will have a negative impact on the local area.
It is important to note that the Saxon Business Park is in fact largely going to be filled with existing businesses relocated from Eldon Way in Hockley, which is proposed for demolition by the Hockley Area Action Plan. It is therefore dishonest to suggest to the Secretary of State that the Saxon Business Park is bringing exclusively new jobs to the area.
It must also be noted that it is overly optimistic to suggest that large numbers of employers will relocate next to an airport that will impose noise disruption, danger and an increasingly congested road network. If anything, there is a danger that many employers, like the local population, would prefer to move away.
Expanded operations at the airport have now been in place for just over one year and it is now clear that the overwhelming majority of passengers are UK citizens who are travelling abroad. Precise information is not yet available on the number of foreign tourists attracted to LSA, but we will work to secure this information before the examination.
However, to provide an interim guide, if approximately 800,000 UK passengers have flown abroad, that is equivalent to a trade loss of £316 million which equates to 12,640 jobs lost from the Essex and London economy. (Based upon UK average of £395 spent abroad per passenger.)
The JAAP is grossly misleading in failing to make any reference to the huge scale of loss of revenue to this area.
Another area that has been overlooked is the massive loss of wealth to the area caused by devaluation of property under and near the flight path.
Again, information is not yet finalised but reports from surveyors specialising in compensation suggest that some homes will have been devalued by up to 15%, many hundreds, possibly thousands by between 5 and 10%. If it is indeed true that 4500 homes have lost what is claimed, then the local economy may have been deprived of over £50m.
We really must challenge the statement "and with only a fraction of the residential noise impacts of other airports". The number of complaints from people concerning noise belies this statement. Furthermore, the area is already subject to low level flights both visible and audible en route to London City Airport, which has been added to by those to LSA.
We must also challenge the statement that "The runway extension is a key factor in the ability of the airport to accommodate the latest advances in medium sized passenger aeroplanes (100 to 150 seats), which are quieter and more fuel efficient than their predecessors, and can take-off in shorter distances and depart more quickly from local airspace." This is not correct; even extended to 1799m, the runway remains short. Future fuel efficient airliners require longer runways.
Finally, the suggestion that a new link road has been built to facilitate access to the airport needs to be challenged. At the Public Inquiry into the stopping up of a section of Eastwoodbury Lane and Footpath 121, it was categorically denied by LSA that this route would be used to access the airport. It was claimed that traffic would be directed via Manners Way, an existing residential street.

The vision is unsound. It was stated during the previous consultation that the Saxon Business Park will be mostly formed from businesses which currently occupy space in Eldon Way, Hockley and are expected to move from there as the Hockley Area Action Plan (HAAP) gets under weigh. The railway station at the airport is much under-used and the local roads are struggling under the pressure of traffic as well as the size of some of the vehicles which wish to approach the airport. It is also misleading to indicate that revenue comes into the town as a result of having an airport here. It has been shown that revenue is taken out of the country to as many destinations as the airport has flights for. A link road was built purely to divert Eastwoodbury Lane from its ancient course. It is now being referred to as an improved access to the airport. This is blatantly untrue, since a great part of the raod looks exactly as it did 50 years ago.

The Southend-on-Sea Core Strategy is a cleverly & carefully worded paragraph that is harmless when read in isolation & out of context but a blatant contradiction when taken with the JAAP.
".., and the quality of life for all its citizens" sounds somewhat hollow along side "..there is a need to release the potential of Southend's land and buildings to achieve measurable improvements ...". So Quality of Life equals the legal right to throw you out of your house and flatten it, screw up the road system & concrete over all green/playing/public recreation areas.

Why build on green belt land when there is an existing business park off of Cherry Orchard Way that is only 30% used. Why relocate a well established rugby club when it is fine where it is. Why mention the airport work when it has already been completed.

The declared policy of the UK government the EU and the ICAO is to separate residential areas from air traffic. The development of London Southend Airport is in direct contravention of this policy.
There are more residential properties around this airport than any other in the UK. Statements such as "ensuring a good quality of life for its residents and workers" and "the quality of life for all its citizens" conflict directly with the declared aim of massively increasing the number of air movements and passengers passing through London Southend Airport as outlined in this section. The increased levels of noise, air, water and light pollution that this traffic both air and road will generate will impoverish the quality of life of thousands. Further the statement "and with only a fraction of the residential noise impact of other airports" is factually incorrect. To reach the estuary aircraft taking off on the 24 runway must first pass over Leigh and its population. In the same way aircraft landing on the 06 runway from the estuary must equally do so. Taking off on the 06 runway and landing on the 24 runway aircraft pass directly over residential housing within a few hundred metres of the runway end.
The reasons for the development of the DP World container port is to enable the next generation of new super large container ships now coming into service to be accommodated. These are too large and their draft requirements too great to enable them reach Tilbury. These ships because of increasing fuel costs will come to dominate the container trade and cause Tilbury to close as a container port. Jobs gained at DP World will lead to jobs being lost at Tilbury. Increased traffic at the new port will contribute to the levels of air pollution to which the councils seem to be determined to add by the expansion of London Southend Airport.
The government is currently prosecuted in the High Court for permitting levels of air pollution in the London area to exceed those allowed by EU legislation and failing over the years to take appropriate action to reduce them. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. It is the equivalent of permitting a drunken driver to administer his or her own breath test. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport is a blatant failure of duty of care. Just because current legislation does not make such provision mandatory is no reason for a caring council to not do it. A prevailing wind brings in pollution from London and nine air routes pass directly over both towns many both visible and audible. These distribute pollution from above and in the future a busy container port close by is set to increase further. To this toxic mix London Southend Airport plans to increase its contribution. The apparent determination to turn Southend and Rochford into a pollution black spot makes a mockery of statements such as "a great place to live, do business and visit" or "make Rochford the place of choice in the county to live, work and visit".
If the authors of this document care to refer to a map of the UK they will discover that Ebbsfleet is in Kent the other side of the estuary and is in no way connected with the JAAP area. It is worth noting at this point that the owners of Manston Airport after year trying to sell it are now proposing closure and change of use of the site to one more profitable and useful. This development exposes the false claims of a shortage of runways in the Southeast. As Kent councillors once considered Manston Airport or Kent International Airport as they ostentatiously renamed it, would become a British Airways hub it just proves how wrong councillors with delusions of grandeur can be. Failure to address the concerns identified above render this section of the draft unbalanced. To be lawful the Submission Draft must be balanced.

London Southend Airport Company Ltd has been involved in the development of the JAAP and has been supportive of the overall direction of the plan. Section 2.3 describes the vision for the JAAP area to 2031. However, the vision for the airport after 2020 will depend on the outcome of the Airports Commission's work and any National Policy Statement on Aviation.

Essex Chambers of Commerce strongly supports the JAAP area for development as a strategic employment area to support the growth in jobs and views this as an important economic driver for the local economy.

We refer to the objective 'Ensuring a high quality public realm and environment for residents and workers'. As noted in Appendix 3 -5 of the Sustainability Appraisal (SA), this objective is quite non-specific in what a 'high-quality' environment is and could cover quite a broad spectrum of matters. The SA states that the objective should be extended to cover natural environment protection for its own sake and not simply as a resource for 'residents and workers' and the public realm. We support this, especially as all the other objectives relate to social and economic matters.

We suggest the objective would benefit from being amended as follows, in line with the recommendations of your Sustainability Appraisal:

'Ensuring a high quality built environment whilst protecting and enhancing the natural environment.'

RE: MY OBJECTIONS TO SOUTHEND AIRPORT EXPANSION

I am writing with a number of objections to the proposed expansion of Southend Airport. I object on the following :-

1. I object to the increase in night flights which will cause major disturbance to local residence with vastly increased aircraft noise.

2. I object to the increase in road traffic and the congestion and pollution which this will bring with it. The A127 is already severely congested merely on a sunny day with people visiting Southend and a few road improvements will not be enough with the huge increase in cars for airport users. Far from being good for the town this will deter visitors as they will not want to sit in traffic as it totally spoils a day out.

3. I object to the vast increase in pollution which will affect air quality in the area seriously affecting the health of local residents and our children. This is a very sought after area to live in because of its peace and quiet and fresh air which will be ruined by this expansion. We should be protecting what makes people want to come and visit a seaside town not destroying it.

4. I object because I don't believe the airport visitors will stop in the town and spend money. They will have suitcases with them and will simply use the airport as a hub not spending money in the town however we get left with all the noise, pollution, congestion and reduced quality of life.

5. I object because many houses in the area will be devalued because they are no longer pleasant places to live.

7. I object because our school children will be disturbed by the increase in aircraft noise which will affect many schools lessons.

The increased expansion of the airport will not ensure a good quality of life for residents or workers. Instead we will be subject to more noise, pollution & a substantial reduction in the value of our homes, not to mention the accompanying ill health many people will suffer from having our peaceful environment shattered.

The increased expansion of the airport will not ensure a good quality of life for residents or workers. Instead we will be subject to more noise, pollution & a substantial reduction in the value of our homes, not to mention the accompanying ill health many people will suffer from having our peaceful environment shattered.

The vision is patently irrational. You cannot increase the quality of life for residents and workers by subjecting them to increased aviation noise, pollution and the utter misery of night flights. Other than by the poorly-used railway station, the airport is reachable only via residential roads. The local road network is not able to cope with the proposed volume of traffic and this will have a negative impact on the local area.



It is important to note that the Saxon Business Park is in fact largely going to be filled with existing businesses relocated from Eldon Way in Hockley, which is proposed for demolition by the Hockley Area Action Plan. It is therefore dishonest to suggest to the Secretary of State that the Saxon Business Park is bringing exclusively new jobs to the area.

It must also be noted that it is overly optimistic to suggest that large numbers of employers will relocate next to an airport that will impose noise disruption, danger and an increasingly congested road network. If anything, there is a danger that many employers, like the local population, would prefer to move away.



Expanded operations at the airport have now been in place for just over one year and it is now clear that the overwhelming majority of passengers are UK citizens who are travelling abroad. Precise information is not yet available on the number of foreign tourists attracted to LSA, but we will work to secure this information before the examination.



However, to provide an interim guide, if approximately 800,000 UK passengers have flown abroad, that is equivalent to a trade loss of £316 million which equates to 12,640 jobs lost from the Essex and London economy. (Based upon UK average of £395 spent abroad per passenger.)



SAEN notes on SEEFoE response: Please note that on 22/3/2013, after SEEfoE made its submission, new data was published by the airport. This showed that a total of 721,661 passengers flew from the airport in the year leading up to February 2012.



The JAAP is grossly misleading in failing to make any reference to the huge scale of loss of revenue to this area.



Another area that has been overlooked is the massive loss of wealth to the area caused by devaluation of property under and near the flight path.



Again, information is not yet finalised but reports from surveyors specialising in compensation suggest that some homes will have been devalued by up to 15%, many hundreds, possibly thousands by between 5 and 10%. If it is indeed true that 4500 homes have lost what is claimed, then the local economy may have been deprived of over £50m.



We really must challenge the statement "and with only a fraction of the residential noise impacts

of other airports". The number of complaints from people concerning noise belies this statement. Furthermore, the area is already subject to low level flights both visible and audible en route to London City Airport, which has been added to by those to LSA.



We must also challenge the statement that "The runway extension is a key factor in the ability of the airport to accommodate the latest advances in medium sized passenger aeroplanes (100 to 150 seats), which are quieter and more fuel efficient than their predecessors, and can take-off in shorter distances and depart more quickly from local airspace." This is not correct; even extended to 1799m, the runway remains short. Future fuel efficient airliners require longer runways.



Finally, the suggestion that a new link road has been built to facilitate access to the airport needs to be challenged. At the Public Inquiry into the stopping up of a section of Eastwoodbury Lane and Footpath 121, it was categorically denied by LSA that this route would be used to access the airport. It was claimed that traffic would be directed via Manners Way, an existing residential street.

The vision is patently irrational. You cannot increase the quality of life for residents and workers by subjecting them to increased aviation noise, pollution and the utter misery of night flights. Other than by the poorly-used railway station, the airport is reachable only via residential roads. The local road network is not able to cope with the proposed volume of traffic and this will have a negative impact on the local area.

It is important to note that the Saxon Business Park is in fact largely going to be filled with existing businesses relocated from Eldon Way in Hockley, which is proposed for demolition by the Hockley Area Action Plan. It is therefore dishonest to suggest to the Secretary of State that the Saxon Business Park is bringing exclusively new jobs to the area.
It must also be noted that it is overly optimistic to suggest that large numbers of employers will relocate next to an airport that will impose noise disruption, danger and an increasingly congested road network. If anything, there is a danger that many employers, like the local population, would prefer to move away.

Expanded operations at the airport have now been in place for just over one year and it is now clear that the overwhelming majority of passengers are UK citizens who are travelling abroad. Precise information is not yet available on the number of foreign tourists attracted to LSA, but we will work to secure this information before the examination.

However, to provide an interim guide, if approximately 800,000 UK passengers have flown abroad, that is equivalent to a trade loss of £316 million which equates to 12,640 jobs lost from the Essex and London economy. (Based upon UK average of £395 spent abroad per passenger.)

The JAAP is grossly misleading in failing to make any reference to the huge scale of loss of revenue to this area.

Another area that has been overlooked is the massive loss of wealth to the area caused by devaluation of property under and near the flight path.

Again, information is not yet finalised but reports from surveyors specialising in compensation suggest that some homes will have been devalued by up to 15%, many hundreds, possibly thousands by between 5 and 10%. If it is indeed true that 4500 homes have lost what is claimed, then the local economy may have been deprived of over £50m.

We really must challenge the statement "and with only a fraction of the residential noise impacts
of other airports". The number of complaints from people concerning noise belies this statement. Furthermore, the area is already subject to low level flights both visible and audible en route to London City Airport, which has been added to by those to LSA.

We must also challenge the statement that "The runway extension is a key factor in the ability of the airport to accommodate the latest advances in medium sized passenger aeroplanes (100 to 150 seats), which are quieter and more fuel efficient than their predecessors, and can take-off in shorter distances and depart more quickly from local airspace." This is not correct; even extended to 1799m, the runway remains short. Future fuel efficient airliners require longer runways.

Finally, the suggestion that a new link road has been built to facilitate access to the airport needs to be challenged. At the Public Inquiry into the stopping up of a section of Eastwoodbury Lane and Footpath 121, it was categorically denied by LSA that this route would be used to access the airport. It was claimed that traffic would be directed via Manners Way, an existing residential street.

Again this appears to have been pre-decided by the authorities without taking into account the objections. Stobart have already indicated that they received such obliging terms for taking over the airport they couldn't refuse and have proceeded with development without consideration to local resident or in some instances planning requirements. RDC and SBC are not being open and transparent about their dealings with Stobart or why they are so keen to ignore residents. The document itself could have been written by Stobart - quiet aircraft, there really is no such thing at 3 a.m

Quality of life will not improve for residents by subjecting them to increased aviation noise, pollution and the misery of night flights.
The local road network will be unable to cope with the proposed volume of traffic.
Therefore we object to any further expansion of the airport.

Page 13 paragraph 2: taken out of context - the reason the noise is a fraction of other airports is because the number of flights was only a fraction.

Page 14 paragraph 4,5,6: It is not clear of why Saxon Business Park is dependant on the airport being expanded

I SUPPORT THIS. I have nothing to add concerning this particular heading. To leave as 'No Comment' gives the impression that the writer has not got a view either way. Those who do not comment must be assumed to be in favour, however, those who object will not interpret it as such.

2.1 Objection:- Southend Airport has one of the highest density of population directly under the flight path and within the PSZ so how can it have 'only a fraction of the residential noise impacts of other airports.'2

Paragraph 2.1 Policy Vision
The declared policy of the UK government the EU and the ICAO is to separate residential areas from air traffic. The development of London Southend Airport is in direct contravention of this policy.
There are more residential properties around this airport than any other in the UK. Statements such as "ensuring a good quality of life for its residents and workers" and "the quality of life for all its citizens" conflict directly with the declared aim of massively increasing the number of air movements and passengers passing through London Southend Airport as outlined in this section. The increased levels of noise, air, water and light pollution that this traffic both air and road will generate will impoverish the quality of life of thousands. Further the statement "and with only a fraction of the residential noise impact of other airports" is factually incorrect. To reach the estuary aircraft taking off on the 24 runway must first pass over Leigh and its population. In the same way aircraft landing on the 06 runway from the estuary must equally do so. Taking off on the 06 runway and landing on the 24 runway aircraft pass directly over residential housing within a few hundred metres of the runway end.
The reasons for the development of the DP World container port is to enable the next generation of new super large container ships now coming into service to be accommodated. These are too large and their draft requirements too great to enable them reach Tilbury. These ships because of increasing fuel costs will come to dominate the container trade and cause Tilbury to close as a container port. Jobs gained at DP World will lead to jobs being lost at Tilbury. Increased traffic at the new port will contribute to the levels of air pollution to which the councils seem to be determined to add by the expansion of London Southend Airport.
The government is currently prosecuted in the High Court for permitting levels of air pollution in the London area to exceed those allowed by EU legislation and failing over the years to take appropriate action to reduce them. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. It is the equivalent of permitting a drunken driver to administer his or her own breath test. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport is a blatant failure of duty of care. Just because current legislation does not make such provision mandatory is no reason for a caring council to not do it. A prevailing wind brings in pollution from London and nine air routes pass directly over both towns many both visible and audible. These distribute pollution from above and in the future a busy container port close by is set to increase further. To this toxic mix London Southend Airport plans to increase its contribution. The apparent determination to turn Southend and Rochford into a pollution black spot makes a mockery of statements such as "a great place to live, do business and visit" or "make Rochford the place of choice in the county to live, work and visit".
If the authors of this document care to refer to a map of the UK they will discover that Ebbsfleet is in Kent the other side of the estuary and is in no way connected with the JAAP area. It is worth noting at this point that the owners of Manston Airport after year trying to sell it are now proposing closure and change of use of the site to one more profitable and useful. This development exposes the false claims of a shortage of runways in the Southeast. As Kent councillors once considered Manston Airport or Kent International Airport as they ostentatiously renamed it would become a British Airways hub it just proves how wrong councillors with delusions of grandeur can be. Failure to address the concerns identified above render this section of the draft unbalanced. To be lawful the Submission Draft must be balanced.

Paragraph 2.2 Policy Objectives of the JAAP
This policy statement lists five bullet points most of which are contradicted by the proposed actions.
The connectivity promoted by the Airport is of a very limited kind. The vast majority of the passengers attracted to flights from London Southend Airport are seasonal holidaymakers. Few use the railway station, some come by coach or taxi but the majority arrives and departs by private car. Apart from the increase in air pollution, this traffic by clogging up the limited road access to the area is an impediment to commercial activities that contribute to the wealth of the majority of residents. For the majority most of the time this does not improve connectivity quite the reverse in fact is true.
Such congestion will act as a deterrent to future investment in the area and may in fact drive away current businesses. Airport passengers pass through the area without stopping and only the operators of the Airport stand to gain from them coming. This is hardly an efficient use and upgrading of existing employment and land resources.
The last thing that an airport does is to ensure a high quality public realm and environment for residents and workers. If those who propose this development had consulted "What are Airport's Impacts" Planning Guide Part 2 by C. Weston they would not have made such a foolish statement. This guide is available by download from the Internet and I submit its availability in evidence.
The undesirable effects of airports were totally disregarded in the Submission Draft. To develop one so close to residential housing as proposed does not conform to Government, European Union or the International Civil Aviation Organisation (ICAO) policy.
This section of the Submission Draft is therefore unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

Paragraph 2.2 Policy Objectives of the JAAP
This policy statement lists five bullet points most of which are contradicted by the proposed actions.
The connectivity promoted by the Airport is of a very limited kind. The vast majority of the passengers attracted to flights from London Southend Airport are seasonal holidaymakers. Few use the railway station, some come by coach or taxi but the majority arrives and departs by private car. Apart from the increase in air pollution, this traffic by clogging up the limited road access to the area is an impediment to commercial activities that contribute to the wealth of the majority of residents. For the majority most of the time this does not improve connectivity quite the reverse in fact is true.
Such congestion will act as a deterrent to future investment in the area and may in fact drive away current businesses. Airport passengers pass through the area without stopping and only the operators of the Airport stand to gain from them coming. This is hardly an efficient use and upgrading of existing employment and land resources.
The last thing that an airport does is to ensure a high quality public realm and environment for residents and workers. If those who propose this development had consulted "What are Airport's Impacts" Planning Guide Part 2 by C. Weston they would not have made such a foolish statement. This guide is available by download from the Internet and I submit its availability in evidence.
The undesirable effects of airports were totally disregarded in the Submission Draft. To develop one so close to residential housing as proposed does not conform to Government, European Union or the International Civil Aviation Organisation (ICAO) policy.
This section of the Submission Draft is therefore unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

Paragraph 2.3 Policy What will the JAAP area look like in the future
The sustainability of the Airport is dependent upon the availability of affordable fossil fuel at a time of accelerating demand and diminishing supply. To promote this airport expansion is over optimistic and verges on the reckless and is not sustainable.
As a result of WW2 the UK has a surfeit of runways and every local authority with a former military airfield in its area has tried to redevelop it as an airport. The result of this is too many small airports most of which lose money. This is a misdirection of investment that the country cannot afford. I am no alone in this view Paul Kehoe Chief Executive of Birmingham Airport has expressed similar views in the Times, saying the country has twice the number of airports it needs.
A regional or even sub-regional airport needs a region; Southend does not have one. How will the Airport look in 15 to 20 years? In all probability closed. It is set to join Victoria Avenue with its graveyard of disused offices as a memorial to myopic planning.
It is contrary to Government and European Union policy to encourage the increase of short domestic flights. Flights to the continent are in European terms domestic. To deliberately compete with rail within the UK is even more undesirable and German and Dutch railway companies will soon be operating into Stratford railway station.
The Submission Document contains proposals that are contrary to government and EU policy and is therefore unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

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.

Concerns I have and want answers to as follows:

The noise report states the planes used for test levels were not the actual planes to be used in future, so not relative.

What are the long term plans/usage for the areas between the inner and outer boundary. This information is crucial to the residents living on the edge of the outer boundary.

I consider this JAAP not worded or set out in a way that is friendly to local residents. It is a professionally written planning document which has made local residents feel excluded. It also suggests in my mind that it has been worded in such a way to discourage local residents/people being able to take an interest.

The word 'FRAMEWORK' has been used in a lucid fashion and does not give justice and respect to the impact of the JAAP will have to the people who have made their homes here, spent many thousands of pounds and invested many emotional hours and memories raising families etc. Be clear what the final intention is, do not deceive or play games with people. Everyone realises things don't stay the same, but be fair.

Regarding the 120 night flights, is this a capped figure, or can it be more, if so who makes that decision?

Evidence is apparent that public safety zones regarding pollutants, gasses and harmful emissions to humans, pets and the environment have not been considered or taken seriously enough in my opinion.

By extending the airport in 'stages' this avoids certain 'environmental check's that would be necessary for larger applications.

What plans are set out to ensure surrounding roads are kept safe and uncongested for local residents to go about their everyday business/lifestyle?

Local residents have not been advised that they can have any form of new glazing. In fact the airport, council or stobart have not contacted us through our door in any way to make us feel involved in the whole plan.

Bullying is the use of force or coercion to abuse or intimidate others. The behaviour can be habitual and involve an imbalance of social or physical power. It can include verbal harassment or threat, physical assault or coercion and may be directed repeatedly towards particular victims, perhaps on grounds of race, religion, gender, sexuality, or ability. [2][3] if bullying is done by a group, it is called mobbing. The victim of bullying is sometimes referred to as a 'target'.

Bullying can be defined in many different ways. The UK currently has no legal definition of bullying, [4] while some U.S. states have laws against it. [5] Bullying consists of three basic types of abuse - emotional, verbal, and physical. It typically involves subtle methods of coercion such as intimidation.

Bullying ranges from simple one-on-one bullying to more complex bullying in which the bully may have one or more 'lieutenants' who may seem to be willing to assist the primary bully in his or her bullying activities. Bullying in school and the workplace is also referred to as peer abuse. [6] Robert W.Fuller has analyzed bullying in the context of rankism.

A bullying culture can develop in any context in which human beings interact with each other. This includes school, church, family, the workplace, home and neighborhoods.

The plan is unsound and unwarranted because 2,000000 passengers is the target of the airport by 2020. This was stated on a news program by an airport representative within 48 hours of the official opening. Therefore, everything needed for this amount of people was submitted and passed by the Councils.

What is being proposed now is something that is not needed now. At no time was a figure suggested in excess of 2,000000 and therefore, no consideration for any changes to the current areas around the airport is needed. Any change would imply that the original plans submitted were not correct. Therefore, the whole airport process, in my opinion should be started again from the beginning.

This policy statement lists five bullet points most of which are contradicted by the proposed actions.

The connectivity promoted by the Airport is of a very limited kind. The vast majority of the passengers attracted to flights from London Southend Airport are seasonal holidaymakers. Few use the railway station, some come by coach or taxi but the majority arrives and departs by private car. Apart from the increase in air pollution, this traffic by clogging up the limited road access to the area is an impediment to commercial activities that contribute to the wealth of the majority of residents. For the majority most of the time this does not improve connectivity quite the reverse in fact is true.

Such congestion will act as a deterrent to future investment in the area and may in fact drive away current businesses. Airport passengers pass through the area without stopping and only the operators of the Airport stand to gain from them coming. This is hardly an efficient use and upgrading of existing employment and land resources.

The last thing that an airport does is to ensure a high quality public realm and environment for residents and workers. If those who propose this development had consulted "What are Airport's Impacts" Planning Guide Part 2 by C. Weston they would not have made such a foolish statement. This guide is available by download from the Internet and I submit its availability in evidence.

To quote Mark Twain "Denial, it ain't just a river in Egypt" and both Councils are in denial in respect of the impact these developments will have on the lives of their residents.

The airliners now flying from London Southend Airport may well be quieter and more fuel efficient than those in the past, but they are larger and therefore the risks involved are greater. Also despite being more fuel efficient than those in the past by being larger and burn more fuel and so produce more pollution overall not less. Aircraft engines have no catalytic converters.

The use of more fuel will require more storage capacity at the Airport and the fuel arrives by road tanker not pipeline as at most other airports. In 1957 the Airport applied to increase the number of above ground fuel storage tanks and Essex County Council opposed this. A reduced number was finally agreed after arbitration by a government minister. This is recorded in the minutes of the old Airport Committee (Minute 2730 28th October 1957 refers). It is hard to imagine why EEC would now approve it. The movement and storage of large quantities of aviation fuel produces pollution and risk before it is even burned in aircraft engines.

The undesirable effects of airports were totally disregarded in the Submission Draft. To develop one so close to residential housing as proposed does not conform to Government, European Union or the International Civil Aviation Organisation (ICAO) policy.

A large part of the development is in the flood plane and its hardening of large areas significantly increases runoff. There are even proposals to build on level 2 and 3 flood levels. The Government policy in this respect is to discourage if not actually bans such building in view of increased rainfall due to climate change. Therefore to say that the proposals are in conformity with existing and emerging local policy is incorrect.

Apart from planning considerations the government is committed to EU policies to work toward reducing and then eliminating short domestic air travel. In a European context all the flights that can be undertaken for London Southend Airport are short domestic flights. Therefore the expansion and encouragement of these flights is also contrary to government policy.

A policy that is so clearly at odds with the declared policy of government is hardly conforming to guiding principles.

The claims that there is a shortage in runway capacity are contradicted by the proposals by the owners of Manston Airport. Having failed for a number of years to sell it, they now propose to close it and put the site to other more protifable use. Also Stansted Airport is currently operating at little more than 2/3 capacity.

This section of the Submission Draft is therefore unbalanced and in conflict with government policy. Because a balanced report is required by statute it is also therefore unlawful.

The declared policy of the UK government the EU and the International Civil Aviation Organisation (ICAO) is to separate residential areas from air traffic. The development of London Southend Airport is in direct contravention of this policy.

There are more residential properties around this airport than any other in the UK. Statements such as 'ensuring a good quality of life for its residents and workers' and 'the quality of life for all its citizens' conflict directly with the declared aim of massively increasing the number of air movements and passengers passing through London Southend Airport as outlined in this section. The increased levels of noise, air, water and light pollution that this traffic both air and road will generate will impoverish the quality of life of thousands. Further the statement 'and with the only a fraction of the residential noise impact of other airports' is factually incorrect. To reach the estuary aircraft taking off on the 24 runway must first pass over Leigh and its population. In the same way aircraft landing on the 06 runway from the estuary must equally do so. Taking off on the 06 runway and landing on the 24 runway aircraft pass directly over residential housing within a few hundred metres of the runway end.

The reasons for the development of the DP World container port is to enable the next generation of new super large container ships now coming into service to be accommodated. These are too large and their draft requirements too great to enable them reach Tilbury. These ships because of increasing fuel costs will come to dominate the container trade and cause Tilbury to close as a container port. Jobs gained at DP World will lead to jobs being lost at Tilbury. Increased traffic at the new port will contribute to the levels of air pollution to which the councils seem to be determined to add by the expansion of London Southend Airport.

The government is currently being prosecuted in the High Court for permitting levels of air pollution in the London area to exceed those allowed by EU legislation and failing over the years to take appropriate action to reduce them. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. It is the equivalent of permitting a drunken driver to administer his or her own breath test. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport is a blatant failure of duty of care. Just because current legislation does not make such provision mandatory is no reason for a caring council to not do it. A prevailing wind brings in pollution from London and nine air routes pass directly over both towns many both visible and audible. These distribute pollution from above and in the future a busy container port close by is set to increase further. To this toxic mix London Southend Airport plans to increase its contribution. The apparent determination to turn Southend and Rochford into a pollution black spot makes a mockery of statements such as 'a great place to live, do business and visit' or 'make Rochford the place of choice in the country to live, work and visit'.

If the authors of this document care to refer to a map of the UK they will discover that Ebbsfleet is in Kent the other side of the estuary and is in no way connected with the JAAP area. It is worth noting at this point that the owners of Manston Airport after a year trying to sell it are now proposing closure and change of use of the site to one more profitable and useful. This development exposes the false claims of a shortage of runways in the Southeast. As Kent councillors once considered Manston Airport or Kent International Airport as they ostentatiously renamed it would become a British Airways hub it just proves how wrong councillors with delusions of grandeur can be. These same councillors are now spending council taxpayer money in an attempt to keep it open.

Failure to address the concerns and inaccuracies identified above render this section of the draft unbalanced. As such balance is a legal requirement this makes it unlawful.

There is residential housing closer to London Southend Airport than any other airport in the UK and yet it has the least controls on night flights. Prior to the hardening of the runways in 1956 the Airport opened at 0600 hours and closed at 2200 hours in the summer and at 0800 hours and closed at 2000 in the winter.

Virtually unlimited night flying was only permitted in an attempt to increase income to pay off the debt incurred to construct the original runways and add runway lighting. The old Airport Committee ruled that it was wrong to deliberately restrict growth of the Airport by disallowing use at night. A policy of allowing so many night flights was a cruel breach of the human right to an undisturbed nights sleep and the medical consequences of such disturbance well established. In practice the new proposals do little to improve on it. Such a policy will not as stated in the document 'maintain the quality of life for residents'.

The small 'Green Lungs' referred to must surely be a bad joke bearing in mind the imposition of a polluting airport into the space that should provide this between Southend and Rochford.

Business travellers at Southend are a small minority, most are seasonal holidaymakers. It is easyJet policy to attract more business travellers and that must cast doubt on its future operations at Southend.

The narrow bodied airliners that at present fly from Southend are no longer the most fuel efficient available. Economics and EU policy will force companies such as easyJet to update their fleets with more fuel efficient aircraft. These are larger and require a longer runway than Southend can provide.

The sustainability of the Airport is dependent upon the availability of affordable fossil fuel at a time of accelerating demand and diminishing supply. To promote this airport expansion is over optimistic and verges on the reckless and is not sustainable.

As a result of WW2 the UK has a surfeit of runways and every local authority with a former military airfield in its area has tried to redevelop it as an airport. The result of this is too many small airport most of which lose money. This is a misdirection of investment that the country cannot afford. I am not alone in this view Paul Kehoe Chief Executive of Birmingham Airport has expressed similar views in the Times, saying the country has twice the number of airports it needs and half should close.

A regional or even sub-regional airport needs a region; Southend does not have one. How will the Airport look in 15 to 20 years? In all probability closed. It is set to join Victoria Avenue with its graveyard of disused offices as a memorial to myopic planning.

It is contrary to Government and European Union policy to encourage the increase of short domestic flights. Flights to the continent are in European terms domestic. To deliberately compete with rail within the UK is even more undesirable and German and Dutch railway companies will soon be operating into Stratford railway station.

The Saxon Business Park serves mainly to replace the Foundry Industrial Area now demolished and Eldon Way business park scheduled to be demolished and redeveloped for housing; both are in Hockley. Only the Anglia Ruskin Medtech Campus is guaranteed to add new jobs any others at the moment identified are jobs relocated from elsewhere, therefore the promise of new jobs is mainly speculative.

It was clearly stated at the Public Inquiries that lead to the stopping up of a section of Eastwoodbury Lane and footpath 121 that St Laurence Way, described as a diversionary road, would not be used for access to the Airport. This would be via Manners Way, but this is proving not to be the case. Traffic is using Eastwoodbury Lane and St Laurence Way to reach the Airport. Both Eastwoodbury Lane and Manners Way are residential roads and the A127 is a heavily congested road carrying well over its designed capacity. So much for good road access.

As in the past with the shuttle bus from Rochford railway station few passengers use the rail to access the Airport. The assertions that the new railway station was vital for the Airports future were merely accepted wisdom not based on hard evidence.

In view of these contradictions the Submission Draft cannot be considered balanced. Legislation requires this Submission Draft to be balanced, as it is not it is unlawful.