3. Development Proposals for the JAAP

Support for the reference under the description of Area iv that it is intended that the tennis courts at the northern end of the estate will remain in situ as this provides clarity that the tennis facilities will be retained.

Section 3.1 repeats the assertion that the extended runway will allow for the use of modern, quieter medium-sized aeroplanes, whereas in fact the most fuel efficient airliners require a longer and wider runway than that which now exists at LSA.
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.
The claim that 6200 additional jobs will be created at the industrial estates needs to challenged. Firstly, this assumes that all spaces created within the business parks will be used. Given the current economic climate and the amount of vacant office space around Southend, this appears to be unlikely. Also, as previously mentioned, the local authorities' intention is to fill at least some of the space with businesses relocated from other sites in the area (Eldon Way to be demolished). Therefore, these would not be *additional* jobs.
Section 3.3 on "Balancing development with environmental enhancement" - it must be noted that local residents have reported adverse health impacts as a result of increased operations. For example, children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead, directing jet exhaust into the park.
It must be noted that unlike its competitors, LSA has no pipeline to supply its fuel, which is brought to the site by road tanker. This suggests that increased storage capacity is needed for jet fuel which poses a further threat to the local area.
Pollution such as VOCs (volatile organic compounds), carbon monoxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, unburned hydrocarbons and soot are all produced by aircraft engines. There are no catalytic converters on aircraft engines! Also, the smoke produced by aircraft tyres on touchdown contain particles of rubber containing toxic heavy metals. With housing closer to the airport than at any other UK airport, this cavalier disregard for the health of residents demonstrates how irresponsible the local authorities have been.
At section 3.4, the JAAP clearly advocates an increase in capacity on the highway network in order to facilitate additional traffic to the airport. This is in contravention of Government policy on climate change by increasing pollution from cars. It is also self-contradictory as point vi. advocates greater use of sustainable transport in order to reduce car traffic.
It is now becoming abundantly clear that far from encouraging greater rail travel as LSA at one time claimed, it is actually going into competition with the rail network by providing flights to destinations such as Newquay and Edinburgh.
We object to any proposal to build on agricultural land, which is needed to protect the country's food security.

The statement that the modern planes are quieter and more fuel-efficient does not fit in with the fact that I am frequently woken early in the morning by what sounds like 4-propellor planes warming up before take-off. This can go on for more than 5 minutes whilst the crow-scarer blasts birds off the runway, and has been known to happen as early as 6.05am! Money is being spent abroad as UK citizens fly out on business or holiday. We were told that 6500 jobs would be created at Southend airport, and even though at present, there have been three-quarters of a million passengers, there has been no marked increase in jobs created.

All the so called evidence base for the use of the airport and the growth of air travel is dated early 2000s. Airport Master Plan 2005. Future Development of Air Transport in UK 2002. Future of Air Transport White Paper 2003. A lot of changes to environment, global warming, diminishing fossil fuels should surely have impacted the previous 'blue sky' thinking.
The Hepworth Acoustic Report 2008 - a report on what ? The large aircraft were not flying then which makes it really relevant.

Most of the work detailed has already been done. There are already plans to improve the junctions on the A127. If this work were to go ahead one of the main items that need to be addressed is the lack of public transport to this area.

Section 1 refers to the Airport Masterplan of 2005, but it should be noted that the planning permission for the runway extension has overtaken that Masterplan

I write to you to express my disgust at Rochford and Southend Councils Development and JAAP Plans for Southend Airport.

You are destroying Rochford, my home and birthplace, Eastwood Church (my baptism) Eastwood my childhood home, and Rochford Church (home of my ancestors) with noise and pollution etc.

Also you are allowing the destruction of wildlife of the River Roach, the most unspoilt river area on the east coast.

This river teamed with kingfishers, egrets and heron (etc), all gone or killed from upper Roach.

It has Canada and Brent geese by flocks of hundreds, all under threat of culling. The river is a breading ground for seals, and last summer porpoise.

It is a valuable shellfish industry which can easily be killed off by pollution, ie airport antifreeze, chemicals etc.

Unacceptable!

The roads can't take any increase in traffic, you say people must walk or cycle (the disabled?), you wish to destroy an industrial site for planes, build a new one in a flood area?, when the first is unfulfilled!, and claim 5000 new jobs (this smacks of madness).

There is no road or infrastructure for this development in our delicate area.

Object only if major roadworks will affect Rochford Road widening and removal of properties, otherwise fine.

Would have like a letter rather than flyer that many people threw out along with junk mail on Easter Saturday.

Proposal doesn't offer any significant supportable benefits for future generations and certainly doesn't enhance the quality of life of present local inhabitants.Fully concur with Mr Richard Postlethwaite's representation ID 13312.

The outline of growth for the airport by 2030 is a horrific vision for the people who live near or under the flight paths. Our lives have already been blighted by the development of the airport to its current level & any increase in the volume of air traffic would be

The outline of growth for the airport by 2030 is a horrific vision for the people who live near or under the flight paths. Our lives have already been blighted by the development of the airport to its current level & any increase in the volume of air traffic would be horrendous. We are already subjected to our peace and quiet being regularly shattered, our sleep disturbed & pollution raining down on us regularly. To be subjected to the increase in volume of air traffic outlined would be intolerable & unjustified in the highly populated residential area's afffected

Section 3.1 repeats the assertion that the extended runway will allow for the use of modern, quieter medium-sized aeroplanes, whereas in fact the most fuel efficient airliners require a longer and wider runway than that which now exists at LSA.



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.



The claim that 6200 additional jobs will be created at the industrial estates needs to be challenged. Firstly, this assumes that all spaces created within the business parks will be used. Given the current economic climate and the amount of vacant office space around Southend, this appears to be unlikely. Also, as previously mentioned, the local authorities' intention is to fill at least some of the space with businesses relocated from other sites in the area (Eldon Way to be demolished). Therefore, these would not be *additional* jobs.



Section 3.3 on "Balancing development with environmental enhancement" - it must be noted that local residents have reported adverse health impacts as a result of increased operations. For example, children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead, directing jet exhaust into the park.



It must be noted that unlike its competitors, LSA has no pipeline to supply its fuel, which is brought to the site by road tanker. This suggests that increased storage capacity is needed for jet fuel which poses a further threat to the local area.



Pollution such as VOCs (volatile organic compounds), carbon monoxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, unburned hydrocarbons and soot are all produced by aircraft engines. There are no catalytic converters on aircraft engines! Also, the smoke produced by aircraft tyres on touchdown contain particles of rubber containing toxic heavy metals. With housing closer to the airport than at any other UK airport, this cavalier disregard for the health of residents demonstrates how irresponsible the local authorities have been.



At section 3.4, the JAAP clearly advocates an increase in capacity on the highway network in order to facilitate additional traffic to the airport. This is in contravention of Government policy on climate change by increasing pollution from cars. It is also self-contradictory as point vi. advocates greater use of sustainable transport in order to reduce car traffic.



It is now becoming abundantly clear that far from encouraging greater rail travel as LSA at one time claimed, it is actually going into competition with the rail network by providing flights to destinations such as Newquay and Edinburgh.

We object to any proposal to build on agricultural land, which is needed to protect the country's food security.

Section 3.1 repeats the assertion that the extended runway will allow for the use of modern, quieter medium-sized aeroplanes, whereas in fact the most fuel efficient airliners require a longer and wider runway than that which now exists at LSA.

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.



The claim that 6200 additional jobs will be created at the industrial estates needs to be challenged. Firstly, this assumes that all spaces created within the business parks will be used. Given the current economic climate and the amount of vacant office space around Southend, this appears to be unlikely. Also, as previously mentioned, the local authorities' intention is to fill at least some of the space with businesses relocated from other sites in the area (Eldon Way to be demolished). Therefore, these would not be *additional* jobs.



Section 3.3 on "Balancing development with environmental enhancement" - it must be noted that local residents have reported adverse health impacts as a result of increased operations. For example, children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead, directing jet exhaust into the park.



It must be noted that unlike its competitors, LSA has no pipeline to supply its fuel, which is brought to the site by road tanker. This suggests that increased storage capacity is needed for jet fuel which poses a further threat to the local area.



Pollution such as VOCs (volatile organic compounds), carbon monoxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, unburned hydrocarbons and soot are all produced by aircraft engines. There are no catalytic converters on aircraft engines! Also, the smoke produced by aircraft tyres on touchdown contain particles of rubber containing toxic heavy metals. With housing closer to the airport than at any other UK airport, this cavalier disregard for the health of residents demonstrates how irresponsible the local authorities have been.



At section 3.4, the JAAP clearly advocates an increase in capacity on the highway network in order to facilitate additional traffic to the airport. This is in contravention of Government policy on climate change by increasing pollution from cars. It is also self-contradictory as point vi. advocates greater use of sustainable transport in order to reduce car traffic.



It is now becoming abundantly clear that far from encouraging greater rail travel as LSA at one time claimed, it is actually going into competition with the rail network by providing flights to destinations such as Newquay and Edinburgh.



We object to any proposal to build on agricultural land, which is needed to protect the country's food security.

Section 3.1 repeats the assertion that the extended runway will allow for the use of modern, quieter medium-sized aeroplanes, whereas in fact the most fuel efficient airliners require a longer and wider runway than that which now exists at LSA.

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.

The claim that 6200 additional jobs will be created at the industrial estates needs to be challenged. Firstly, this assumes that all spaces created within the business parks will be used. Given the current economic climate and the amount of vacant office space around Southend, this appears to be unlikely. Also, as previously mentioned, the local authorities' intention is to fill at least some of the space with businesses relocated from other sites in the area (Eldon Way to be demolished). Therefore, these would not be *additional* jobs.

Section 3.3 on "Balancing development with environmental enhancement" - it must be noted that local residents have reported adverse health impacts as a result of increased operations. For example, children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead, directing jet exhaust into the park.

It must be noted that unlike its competitors, LSA has no pipeline to supply its fuel, which is brought to the site by road tanker. This suggests that increased storage capacity is needed for jet fuel which poses a further threat to the local area.

Pollution such as VOCs (volatile organic compounds), carbon monoxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, unburned hydrocarbons and soot are all produced by aircraft engines. There are no catalytic converters on aircraft engines! Also, the smoke produced by aircraft tyres on touchdown contain particles of rubber containing toxic heavy metals. With housing closer to the airport than at any other UK airport, this cavalier disregard for the health of residents demonstrates how irresponsible the local authorities have been.

At section 3.4, the JAAP clearly advocates an increase in capacity on the highway network in order to facilitate additional traffic to the airport. This is in contravention of Government policy on climate change by increasing pollution from cars. It is also self-contradictory as point vi. advocates greater use of sustainable transport in order to reduce car traffic.

It is now becoming abundantly clear that far from encouraging greater rail travel as LSA at one time claimed, it is actually going into competition with the rail network by providing flights to destinations such as Newquay and Edinburgh.

We object to any proposal to build on agricultural land, which is needed to protect the country's food security.

Again assumption that only "quiet" aircraft will be using the airport. Last time I looked Stobart were running a business, this means that they won't be asking any prospective airline "how noisy are your planes?", but "how much are you willing to pay?".
Passenger numbers are forecast to increase and yet no traffic survey has been undertaken - particularly on the B1013, which was NOT listed on previous documentation as a recommended route for airport access - the arguments put forward were that most passengers would arrive by train and that the A127 was to be the preferred vehicular route. Jobs a

Page 16 paragrpah 3: final sentence refers to the impact being 'lessened' on the surronding area. How can it be lessened from zero before the airport was expanded.

Further references to Saxton Business Park, but no explanation of why the business park could not exist without the airport.

Page 18: What controls will be put in place to minimise environmental and social impact. Without a tangible measurement, this is pure fiction and not relevant.

I SUPPORT THIS. I have nothing to add concerning this particular heading. To leave as 'No Comments' gives the impression that the writer could be a 'Don't Know' and 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. Who the heck compiled this document?

3.1 Larger aircraft are not necessarily modern or quieter.

Paragraph 3,1 Policy The future development and role of London Southend Airport
The conclusion drawn in the Airport Masterplan 2005 that the railway station was fundamental to increasing the attractiveness of the Airport was not based on any evidence merely on accepted wisdom. The evidence provided by the failure of the shuttle bus from Rochford station was ignored and the station now built is little used. Potential passengers from East London can travel by rail to Stanstead for a greater choice of destination in less time than to Southend. Improvements to the rail link to Stanstead now being carried out and planned for the future will further improve the attractiveness of Stanstead that currently operates at little more than 2/3 capacity.
Aviation moves faster than council decision making. Further more the councils take their aviation advice from the Airport and this is tainted by self-interest. The need to reduce the emissions of greenhouse gases resulted in the adoption in 2006 by the committee on aircraft emissions of the Chicago Convention of the specification for Chapter 4 aircraft in annex 16 of Chapter 30. Aircraft such as the Airbus A320neo (new engine option) or the Boeing 737 max series are significantly (up to 15%) more fuel efficient, but require longer runways. As a result a runway 1,799 metres in length will no longer be long enough to accommodate future narrow bodied airliners of the type and size favoured by airlines such as easyJet. The Airbus A319ceo (current engine option) now flying from the Airport and the Embraer 195, which has yet to do so, are Chapter 3 aircraft. An Embraer 195 at full fuel and payload requires a runway 2,179 metres long. Economics and EU policy will force the aggressive adoption of Chapter 4 aircraft to the detriment of London Southend Airport.
Virtually all of the North Side extension for Maintenance Repair and Overhaul is in floodzone level 2 & 3. This is contrary to government policy for development in the flood plane. In addition who would install expensive equipment or get insurance for such in an area like that? Why propose its development before studies of flooding risk have been carried out? Such a proposal is seriously flawed and irrational. Not taking into account the real circumstances, history and likely future developments render this section of the Draft unbalanced. To be lawful the Submission Draft must be balanced.

Paragraph 3,2 Policy The future of the JAAP as an employment area
The shortage of affordable industrial premises is the principle brake on the development of employment and the councils should address this problem not indulge in flashy vanity projects. The developers of shiny new industrial estates expect too high a rent to make them affordable to start-up companies. Most of these are forced to start life in disused barns or church halls if they can find them. The document offers no explanation as to how achieving 2 million passenger a year at the Airport would lead to employment in the proposed Saxon Business Park. The A319s operated by easyJet have minimal galley space and serve no hot meals on their short flights. There would be no requirement to have catering facilities to provide in-flight meals for their aircraft at Southend. Ryanair only employ 106 staff for every 1 million passenger carried. The re-location of IPECO to the Saxon Business Park would only move jobs not create them and leave premises in the Aviation Way empty. Rochford Rural District Council has closed and demolished the Foundry Industrial Area and is planning the same for the Eldon Way Business Park; both in Hockley. It is reasonable to conclude that there is not a shortage of such provision locally especially as that in Aviation Way is not fully occupied. If the recommendations of R&D Report 9636 to radically change the shape of the Public Safety Zone is adopted this could prevent the proposed development of a business park at the junction of Prince Avenue and Nestuda Way. The Submission Draft in this section is as outlined above unbalanced. The Submission Draft must be balanced to be lawful.

Paragraph 3.3 Policy Balancing development with environmental enhancement
The document states that "It is accepted that the environmental impacts (noise and air quality, in particular) will need to be carefully monitored as a result of the increased numbers of aircraft and vehicle movements in the area."
Further it continues "control on the operation of the Airport to ensure quality of life is maintained for residents"
These two statements are incompatible monitoring is not control. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport means that it is unable to monitor air pollution. Further the Airport has no control over the emissions of pollution from aircraft. Children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead directing jet exhaust into the park. Airports are a major source of pollution see "What Are Airport's Impacts" Planning Guide 2 C. Weston
No mention is made in the report of the need to provide increased storage capacity for the increasing quantities of jet fuel that will be required if the number of flights increase as hoped. This has implications for safety and pollution by spillage and vaporisation. Unlike its competitors Southend has no pipeline to supply its fuel and this undermines the Airports competitiveness. Aviation fuel must at the moment be supplied by road tanker with increased cost and greenhouse gas emissions.
Pollution as VOC (volatile organic compounds) from the storage and distribution of aviation fuel in increasing quantities at the Airport is only one in a long list of polluting activities created by airports. Aircraft engines produce carbon monoxide, carbon dioxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, un-burnt hydrocarbons and soot. There are no catalytic converters on aircraft engines. The smoke produced as the aircraft tyres touch the runway on landing contains particles (PM particulate matter) of rubber containing toxic heavy metals. With housing closer to the Airport than at any other airport this indicated a cavalier disregard for the health as well as the safety of the residents that the councillors purport to represent. Airports also produce light pollution attracting and disorienting animal and insect life.
The document states "Furthermore, the JAAP has been subject to independent Sustainability Appraisal and Habitats Regulation Assessment to ensure that environmental and social are considered and addressed where necessary."
No indication has been given as to who the independent assessor was and no indication given that the extent and nature of pollution produced by airports has been understood. As What are Airport's Impacts Planning Guide Part 2 C. Weston was not included in the reports referred to in formulating the JAAP it is unlikely that this was adequately done.
Failure to address implication of the pollution caused by a busy airport so close to residential areas means that the document cannot be considered to have been logically drawn up and so is irrational and unbalanced. A balanced Submission Draft is a statutory requirement and this lack of balance makes it unlawful.

Paragraph 3.4 Transport and Movement

The document undermines its own case by admitting that the local road network has limited capacity for improvement. The A127 (Prince Avenue) and B1013 (Manners Way, Southend Road and Hall Road) are part of the local road network. As the vast majority of passengers arrive and depart by private car or taxi congestion is bound to increase.
This will to be to the detriment of local residents and businesses. If the number of passengers grows to the number predicted it might well result in more jobs lost than gained.
Bullet point (I) is immediately revealed as wishful thinking by bullet point (II) admitting constraints due to availability of land and property boundaries. Further how does encouraging flights to Edinburgh, Newquay and Amsterdam all destinations that can all be reached by rail promote the use of sustainable transport? The lack of logic displayed here renders it illogical and as a result unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

Further to the publication of the London Southend Airport and Environs Joint Area Action Plan Submission Document (JAAP), we write on behalf of Cogent Land LLP (Cogent) to provide representations to the matters addressed within the document.

a) Background

Cogent represents the interests of landowners to the north of Southend - predominantly a Greenfield environment. Cogent has sought to engage positively in the production of the various policy documents guiding the future development of Southend and has submitted a number of representations to this end.

Cogent controls land within the vicinity of the London Southend Airport, which it considers could provide the opportunity to build on the aspirations of the JAAP. These landholdings are located within the administrative areas of Southend and Rochford and are capable of providing significant supporting infrastructure for the Airport, including enhanced surface access and supporting employment floorspace provision. They are also capable of providing housing growth, both to meet the needs of forecast population growth and to meet the demand for housing to accommodate the aspirations of the increasing number of employees of the airport.

b) The Vision for the JAAP

Southend is considered by Cogent to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of London Southend Airport to develop on its success as an established regional airport hub, to become an employment destination and economic pole in its own right. The vision of the JAAP should be to facilitate this, both within the JAAP area and beyond its tightly drawn boundary.

The objectives of Southend and Rochford Councils to deliver improvements to London Southend Airport are supported by Cogent. However, Cogent considers that the opportunity to enhance the potential of London Southend Airport is dependent on the delivery of further improvements to the strategic transport infrastructure network and the supporting employment function of the surrounding area. Without significantly enhanced highway access and a reservoir of employment land capable of providing a secondary or tertiary support role for the operation of the airport, the potential of London Southend Airport will remain constrained.

Indeed, Cogent considers that the full potential of London Southend Airport cannot be fully realised without extensive new highway and public transport infrastructure and provision for sufficient off-site supporting employment provision.

c) Surface Access

Cogent considers the most significant existing constraint to the potential of London Southend Airport to function as an employment destination and economic pole in its own right is surface access, and in particular, the capacity of the highway network surrounding the JAAP area.

The significance of the potential surface access constraint is confirmed with reference to the proposals to increase the operating capacity of the airport from the current level of operation (500,000 passengers per annum) to the target 2 million passengers per annum.

The Sustainability Appraisal indicates that this target increase could result in the addition of 6,000 new vehicle movements per day as a result of JAAP proposals. Equally, the Local Transport Plan identifies the airport as an asset, but one that will result in traffic growth, which must be carefully managed.

Cogent supports the recognition of the need for an enduring and comprehensive solution to the enhancement of east-west connectivity to enhance capacity - a requirement that has been recognised as being necessary since the 1980s. However, notwithstanding the proposals to make a number of improvements to existing A127 junctions - The Bell, Tesco, and Kent Elms Corner - that are contained within the document, Cogent considers that the provision of enhancements to east-west connectivity can only realistically be achieved through the continuation of the new airport access road (St Laurence Way) from Nestuda Way to Rochford Road as originally intended in the Local Transport Plan 3 Strategy Document 2011 - 2026 (page 35). Further improved links are also required westbound to join the A127, dealing with capacity constraints at the Prince Ave/A127 junction. It is also relevant to note that, of the capacity improvements required for key junctions on the local network, the majority are located to the east of the JAAP boundary, thereby confirming the significance of enhancing east-west connectivity.

It is significant that Cogent presented its vision for the enhancement of east-west connectivity within the wider network to address the shortfall in network capacity which both stifles growth and results in unnecessary rat-running through Rochford and Southend. This was formally presented to Southend on 24th May 2011. Since Southend dropped the Priory Crescent dualling proposals, Sutton Road amongst others have continued to suffer with increased flows and queuing, which can be observed on a daily basis.

It is essential to provide a holistic solution to the transport network and continue the access road (St Laurence Way) from the airport, bridging the railway eastwards to the A1159 dual carriageway. Currently the railway line severs east and west Southend/Rochford with the only dual carriageway (A127/A1159) becoming single lane in either direction at Priory Crescent. Priory Crescent is the only single carriageway section of the road - stretching 35 miles from London to Bournes Green - and is located in the heart of the Southend network. In the absence of this link it is essential to consider alternatives such as the continuation of St Laurence Way eastward to join A1159. Such links will help promote access to the airport for local employment and the development of B1/B2 business parks on Cherry Orchard Way.

In addition, the opportunity to open up access to the airport railway station to the east should be fully explored as this will significantly enhance accessibility of the airport for the benefit of the local resident population, assist airport workers in getting to and from work, reduce pressure on the surrounding road network and enhance east-west connectivity. The proposals to open the eastern access to the airport railway station would comply with draft Policy T5 (Walking and Cycling), which identifies the need to improve walking linkages.

There is currently no reference to the use of Community Infrastructure Levy (CIL) receipts to the improvement in surface access infrastructure to the airport. Notwithstanding this, Cogent can confirm that it will support proposals for the introduction of CIL charging schedules from both Southend and Rochford Councils that seek to make provision for enhancements to infrastructure associated with surface access to London Southend Airport.

d) Employment Policies

The first two objectives of the JAAP are identified as the:

* Creation of sustainable, high quality and high value employment and other land uses within the study area; and
* Maximising the economic benefits of a thriving airport and related activity.

Cogent supports these objectives, but is concerned that the full scope of the stated objectives may not be achieved within the tightly drawn boundaries of the JAAP.

Whilst the employment provision elements of the JAAP focus on provision to be made within its boundaries, there is an opportunity to recognise the role that will be played by the provision of employment land capable of fulfilling a secondary or tertiary support role for the airport. It is significant that no reference is made within the JAAP to the role that can be played by adjacent sites in the maximisation of economic benefits arising from the airport. In particular, Cogent can confirm that it controls land to the west of Purdey's Industrial Estate that it considers suitable to accommodate an expansion of the existing industrial estate and highway infrastructure improvements. It is significant that the Rochford Employment Land Study 2008, cited as evidence base for the JAAP also concluded that Purdey's Industrial Estate is fit for purpose and suitable for expansion.

The JAAP recognises the role that airports can play as a catalyst for growth in the wider economy and notes that the area has the potential to attract high technology businesses and high value employment to an area. However, it is significant that the proposed employment growth will not link directly into the airport and the existing employment area at Purdey's Industrial Estate is easily accessible from the airport.

It is also relevant that the projected job provision for the employment land is derived from the Homes and Communities Agency (HCA) 'Employment Densities Guide - 2nd Edition 2010'. In terms of the B1 floorspace provision, the JAAP applies the figure of one full time equivalent (FTE) job per 11.4sq.m floorspace, in accordance with the suggested density figure for out of town locations. The HCA guide goes on to explain that the 11.4sq.m figure is a higher density by virtue of the propensity for call centre and high density administration functions to be located in out of town locations. In the context of the stated objectives of attracting high technology businesses and high value employment to the JAAP area, the use of the higher density figure would appear inconsistent. As a result, Cogent considers that the overall quantum of job provision is likely to be an over-estimate. Whilst this is not in itself considered to be a matter of overriding significance to the future strategy for the JAAP, it provides further justification to support the identification of further land for employment growth outside the JAAP area.

e) Conclusions

In order to address the objectives and vision for the JAAP, Cogent considers that the following revisions are required:

* Revision of the JAAP boundary to include nearby employment land capable of fulfilling a secondary and tertiary support role for the operation of the airport, including the expansion of Purdey's Industrial Estate;
* Make provision for an enduring and comprehensive solution to the enhancement of east-west connectivity in the area surrounding the airport;
* Exploit the opportunity to open up access to the airport railway station to the east;
* Reduce reliance on SERT in the context of its current likelihood of coming forward, at least in the short/medium term;
* Undertake sensitivity testing on the employment density assessment to allow for the identification of further land for employment expansion outside the JAAP area; and
* Make provision for the introduction of CIL charging schedules that seek to make provision for enhancements to infrastructure associated with surface access to London Southend Airport.

Finally, Cogent wishes to confirm its wish to appear at all stages of the Examinations relating to the JAAP, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed.

Iceni and Cogent trusts that the Councils will find these representations to be constructive and helpful in taking forward the JAAP. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact us.

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 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.

3. Balancing development with environmental enhancement

The Submission Draft recognises that some environmental impacts will inevitably result from more activity from the airport and new business parks that 'must be managed considerably and appropriately', the DPD continues 'It is accepted that the environmental impacts (noise and air quality, in particular) will need to be carefully monitored as a result of the increased number of aircraft and vehicle movements in the area.' The solution is apparently '...proposing detailed controls on the operation of the airport to ensure quality of life is maintained for residents.'

It is ludicrous and reckless of the Councils to agree such a solution 0 the conflicting roles of monitoring AND controlling cannot be delegated to the airport operator itself. This decision is even more absurd when you read later in this document (Section 4 - Airport Policies (Page 36)) that '...airport operator is preparing several policy documents to set out how the airport will function both in terms of measuring environmental impacts, but following a sustainable operating strategy...' then listing 9 documents to be included. It is totally unacceptable to submit this DPD without prior scrutiny of these 'key' policy documents (particularly those involving air quality and carbon and environment management plans) and it is totally irresponsible for the Councils to take such vital far reaching decisions without verifying this key content which surely should have been finalised and in the possession of the Councils for scrutiny/agreement prior to their originally approving the airport's present operations.

Furthermore, the Councils' responsibility to residents as a duty of care should be to appoint independent specialists responsible for recording, monitoring and controlling all data - particularly the key areas of noise, air quality, carbon and environmental - and for the total costs incurred to be levied on the airport operator. It is not acceptable in a democratic legal system that the airport operator monitors itself - this is a complete conflict of interest. Where is the control? In any other sphere of control and checking there is an independent commission or 'office of regulator'. In addition, to allay suspicion of any abuse, details of the precise location of monitoring equipment and timing arrangements need to be established and publicised - local residents are affected and have a very strong interest in all the pollution hazards being imposed on them. Having recently been subjected to extremely high levels of strong aviation fuel smells in my back garden in Eastwoodbury Lane (particularly bad between 1600 and 1700 hours on 3 consecutive days w/e Sunday 24 March and at 1700 hours on Tuesday 9 April) what is the point of restricting people smoking in the Central Library etc., if you can't even breathe safely in your own garden? Despite the various vague (seemingly hollow) references to the importance of environmental impact throughout this DPD, and that this '...must not be at the expense of a worsening of the environment and quality of life for those living in the area (Page 33), no evidence has been included of the Councils' plans to offset the huge increase in carbon balance from the airport. This results in the DPD being unbalanced and extremely biased in favour of the airport operator. It is essential that evidence based studies are specified identifying where the Councils are reducing carbon emissions to help tackle climate change - this is important information that we are entitled to know as there are dangerous health hazards from the fumes and pollution created by planes whilst using the aprons, taxiways and runways all of which are far too close to existing residents, together with the misery of noise nuisance caused on take off and landing.

This DPD is not balanced as it fails to understand and thoroughly address the overall implications of pollution which affect a significant percentage of the local population and it will be irresponsible, improper and unlawful of the Councils to proceed until environmental and pollution concerns have been properly addressed.

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 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 anyway '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 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.

The shortage of affordable industrial premises is the principle brake on the development of employment and the councils should address this problem not indulge in flashy vanity projects. The developers of shiny new industrial estates expect too high a rent to make them affordable to start-up companies. Most of these are forced to start life in disused barns or church halls if they can find them.

The document offers no explanation as to how achieving 2 million passengers a year at the Airport would lead to employment in the proposed Saxon Business Park. The A319s operated by easyJet have minimal galley space and serve no hot meals on their short flights. There would be no requirement to have catering facilities to provide in-flight meals for their aircraft at Southend. Ryanair only employ 106 staff for every 1 million passengers carried.

The re-location of IPECO to the Saxon Business Park would only move jobs not create them and leave premises in the Aviation Way empty. Rochford District Council has closed and demolished the Foundry Industrial Area and is planning the same for the Eldon Way Business Park; both in Hockley. It is reasonable to conclude that there is not a shortage of such provision locally especially as that in Avaiation Way is not fully occupied.

If the recommendations of R&D Report 9636 to radically change the shape of the Public Safety Zone is adopted this could prevent the proposed development of a business park at the junction of Prince Avenue and Nestuda Way.

The Submission Draft in this section is as outlined above unbalanced. As the law requires balance in such a document this makes the Submission Draft unlawful.

The conclusion drawn in the Airport Masterplan 2005 that the railway station was fundamental to increasing the attractiveness of the Airport was not based on any evidence merely on accepted wisdom. The evidence provided by the failure of the shuttle bus from Rochford station was ignored and the station now built is little used. Potential passengers from East London can travel by rail to Stansted for a greater choice of destination in less time than to Southend. Improvements to the rail link to Stansted now being carried out and planned for the future will further improve the attractiveness of Stansted that currently operates at little more than 2/3 capacity.

Aviation moves faster than council decision making. Further more the councils take their aviation advice from the Airport and this is tainted by self-interest. The need to reduce the emissions of greenhouse gases resulted in the adoption in 2006 by the committee on aircraft emissions of the Chicago Convention of the specification for Chapter 4 aircraft in annex 16 of Chapter 30. Aircraft such as the Airbus A320neo (new engine option) or the Boeing 737 max series are significantly (up to 15%) more fuel efficient, but require longer runways. As a result a runway 1,799 metres in length will no longer be long enough to accommodate future narrow bodied airliners of the type and size favoured by airlines such as easyJet. The Airbus A319ceo (current engine option) now flying from the Airport and the Embraer 195, which has yet to do so, are Chapter 3 aircraft. An Embraer 195 at full fuel and payload requires a runway 2,179 metres long. Economics and EU policy will force the aggressive adoption of Chapter 4 aircraft to the detriment of London Southend Airport.

Virtually all of the North Side extension for Maintenance Repair and Overhaul is in floodzone level 2 and 3. This is contrary to government policy for development in the flood plane. In addition who would install expensive equipment or get insurance for such in an area like that? Why propose its development before studies of flooding risk have been carried out? Such a proposal is seriously flawed and irrational. Not taking into account the real circumstances, history and likely future developments render this section of the Draft unbalanced. Balance is a legal requirement for a Draft such as this meaning that it is therefore unlawful.

The document states that 'It is accepted that the environmental impacts (noise and air quality, in particular) will need to be carefully monitored as a result of the increased numbers of aircraft and vehicle movements in the area.'

Further it continues 'control on the operation of the Airport to ensure quality of life is maintained for residents'

These two statements are incompatible monitoring is not control. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport means that it is unable to monitor air pollution. Further the Airport has no control over the emissions of pollution from aircraft. Children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead directing jet exhaust into the park. Airports are a major source of pollution see 'What are airport's impacts' Planning Guide 2 C. Weston.

No mention is made in the report of the need to provide increased storage capacity for the increasing quantities of jet fuel that will be required if the number of flights increased as hoped. This has implications for safety and pollution by spillage and vaporisation. Unlike its competitors Southend has no pipeline to supply its fuel and this undermines the Airports competitiveness. Aviation fuel must at the moment be supplied by road tanker with increased cost and greenhouse gas emissions.

Pollution as VOC (volatile organic compounds) from the storage and distribution of aviation fuel in increasing quantities at the Airport is only one in a long list of polluting activities created by airports. Aircraft engines produce carbon monoxide, carbon dioxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, un-burnt hydrocarbons and soot. There are no catalytic converters on aircraft engines. The smoke produced as the aircraft tyres touch the runway on landing contains particles (PM particulate matter) of rubber containing toxic heavy metals. With housing closer to the Airport than at any other airport this indicated a cavalier disregard for the health as well as the safety of the residents that the councillors purport to represent. Airports also produce light pollution attracting and disorienting animal and insect life.

The document states 'Furthermore, the JAAP has been subject to independent Sustainability Appraisal and Habitats Regulation Assessment to ensure that environmental and social are considered and addressed where necessary.'

No indication has been given as to who the independent assessor was and no indication given that the extent and nature of pollution produced by airport has been understood. As What are Airport's Impacts Planning Guide Part 2C. Weston was not included in the reports referred to in formulating the JAAP it is unlikely that this was adequately done.

Failure to address implication of the pollution caused by a busy airport so close to residential areas means that the document cannot be considered to have been logically drawn up and so is irrational and unbalanced. As balance is a statutory requirement this makes it unlawful.

The document undermines its own case by admitting that the local road network has limited capacity for improvement. The A127 (Prince Avenue) and B1013 (Manners Way, Southend Road and Hall Road) are part of the local road network. As the vast majority of passengers arrive and depart by private car or taxi congestion is bound to increase.

This will to be to the detriment of local residents and businesses. If the number of passengers grows to the number predicted it might well result in more jobs lost than gained.

Bullet point (i) is immediately revealed as wishful thinking by bullet point (ii) admitting constraints due to availability of land and property boundaries. Further how does encouraging flights to Edinburgh, Newquay and Amsterdam all destinations that can all be reached by rail promote the use of sustainable transport? The lack of logic displayed here renders it illogical and as a result unbalanced. It is a statutory requirement that a document of this type be balanced. As this document is not it is unlawful.