4. Policies

Object

Representation ID: 29170

Received: 16/03/2013

Respondent: South East Essex Friends of the Earth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

This is a vanity project which history will show will do immense damage to the local economy, the quality of life of residents and seriously damage the environment.

Object

Representation ID: 32274

Received: 05/04/2013

Respondent: Mrs Catherine Theobald

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It is not made clear enough to the layman what is meant by B1 and B2 Class development is. It is clear that Southend Council intends to build over the remainder of its green belt land in this area,and Rochford Council is beginning to do the same.

Object

Representation ID: 32310

Received: 08/04/2013

Respondent: Hawkwell Residents Association

Agent: Hawkwell Residents Association

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 32445

Received: 23/04/2013

Respondent: Mrs C Mann

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

There seems to be a desperation for accolades for future growth without any considered thought about how this will impact on the current residents. Rochford will be completely overshadowed by the scale of this development and subsumed into one big industrial park. This is a vanity project which history will show will do immense damage to the local economy, the quality of life of residents and seriously damage the environment.

Object

Representation ID: 32527

Received: 25/04/2013

Respondent: Mr Jamie Brigstock

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In whose opinion does the extended runway have a "smaller environmental impact on the area"? This is opinion, JAAP should be factual.

JAAP says airport been operational for more than 75 years. I requested volume numbers per year, Matthew Thomas refered me to LSA for the figures. The comment should only be made if passenger volumes are comparable over the years with projected numbers.

Page 39 refers to flights being slightly higher as they come into land as a result of the runway extension. When asked to provide extact figures, Matthew Thomas refered me to the CAA.

Object

Representation ID: 32590

Received: 26/04/2013

Respondent: Mr Graham Whitehead

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

To develop a facility that is being rapidly overtaken by events is unbalanced. The Submission Draft is required by statute to be balanced, lack of balance makes it unlawful.

Object

Representation ID: 32641

Received: 15/04/2013

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The childcare sufficiency data suggests that there is a general need in several Rochford wards for additional childcare provision. An increase in jobs and wider employment opportunities would impact on the assessment of future need for provision. The Plan should note that there will be a need to provide additional childcare places and provision in the local area, although it is difficult to be precise on the scale and timing of additional provision at this point in time.

Object

Representation ID: 32642

Received: 15/04/2013

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Essex County Council would consider any co-location/joint working opportunities for Library provision that might arise from the proposals in the Plan. In particular any which would assist in promoting and achieving the document's objectives, especially in regard to enhancing career related training and development opportunities and improving quality of life/leisure.

Object

Representation ID: 32651

Received: 24/04/2013

Respondent: Miss M A Townsend

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

On Page 34 Table 1 of the DPD indicates a maximum of 53,300 Total Aircraft movements in 2020. These figures include and identify 5,400 of 'maintenance, test and training, military, etc'. On Page 42 of the DPD under Environmental Controls schedule there is an annual cap on total aircraft movements of 53,300 excluding...'military flights'.

These figures and explanations do not seem to be aligned as one includes military flights and the other excludes them.

Also, Page 34 does not identify the extent or description of 'etc'. This could be interpreted in future in any way the Airport Operators etc deemed in their favour and in alignment with the rest of this Planning document etc.

The value and accuracy of the document must be questioned as being unbalanced and therefore unlawful.

Object

Representation ID: 32652

Received: 24/04/2013

Respondent: Miss M A Townsend

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Page 33 of the DPD states the JAAP seeks 'fuel efficient planes that have a smaller environmental impact...'. This statement is false as none of the planes identified in Page 39 of the DPD are in any way 'fuel efficient'. From their basic design fundamentals, large amounts of energy are required just to keep the weight of the contraptions off the ground. This large energy required is provided by the consumption of large amounts of fuel in the planes engines. Aeroplane travel will never be 'fuel efficient'. This explanation can be quite clearly understood by reading 'Sustainable Energy - Without the Hot Air' by author Prof. David C. MacKay, Cambridge University (the Government's Energy Advisor).

In terms of energy consumption, turbo prop and jet aircraft all mandate an energy consumption in excess of 40 kWh/100 passenger-km. The corresponding figures for passenger cars are 20, tram 9, coach 6, London Underground 4.4 and High Speed Rail 3 - kWh/100p/km respectively hence the use of the term 'fuel efficient planes' is completely incorrect and deliberately misleading.

Please also note the comments of Dennis Bushnell, Chief Scientist at NASA's Langley Research Centre that the Aviation Industry is mature. 'There is not much left to gain except the glacial accretion of a percent here and there over long time periods.' (New Scientist 24 February 2007 - Page 33).

Hence the DPD is flawed, incorrect and unbalanced making it unsound and unlawful.

Object

Representation ID: 32654

Received: 24/04/2013

Respondent: Miss M A Townsend

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Proposal Map referred to on Page 35 shows the operational boundary of London Southend Airport and the extent of the JAAP area. There is no mention of the implications of this designated JAAP area to owners of properties falling within this 'boundary'. Homeowners living within this designated area are entitled to know precisely what the effect of this 'boundary' will be to them, particularly as their property values are potentially blighted.

This is a serious omission of important information and renders the policy statement incomplete, unbalanced and unsound.

Object

Representation ID: 32662

Received: 25/04/2013

Respondent: Mr B J Free

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Future of Air Transport White Paper 2003 is now recognised to be seriously flawed and generally discredited. London Southend Airport is not and will never have the potential to be a regional airport. A proliferation of small loss making airports in the UK is a gross misapplication of national investment. The country cannot afford the investment necessary to bring all of them up to the standards that would enable them to operate in the future environment of reduced greenhouse gases. A modest number of passengers are not sufficient and will not provide enough income to each to enable them to afford to buy and operate the equipment required.

Stansted Airport currently operating at little over 2/3 capacity is barely 60 minutes from Southend and can be reached by rail and aircoach. Potential passengers within 60 minute of Southend are within 60 minutes of Stansted. London Southend Airport serves no useful purpose and complicates an already complicated air traffic control zone.

The 26 kilometre diameter Bird Control Zone around London Southend Airport includes both Two Tree Island and Wallasea Island. Wallasea Island contains an EU directed conservation area designed to provide replacement habitat for migrating wading birds displaced by the DP World Port development. The detonation of explosive devises in an attempt to avert the risk of bird strikes is unlikely to be permitted when this development is completed. There are reports of Herons being found dead.

The development of the Airport can only be done at the expense of a worsening of the environment and quality of life for those living in the area. To claim otherwise is false. Virtually unlimited night flying was only permitted at Southend in an attempt to increase income to pay off the debt incurred to construct the runways and runway lighting. To quote from the minutes of the old Airport Committee "It is wrong to deliberately restrict the 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 present policy is little better. Such a policy will be at the expense of a worsening of the environment and quality of life for those living in the area and not as stated in the document.

The numbers and type of flights presented in Table 1 are entirely speculative. Potential operators have already fallen by the wayside. The only significant operator easyJet is on record as negotiating with suppliers such as Airbus and Boeing to replace their current fleet with Chapter 4 complaint aircraft. A 180 seat aircraft would appear to be the preferred option. The selected type would not be chosen to suit London Southend Airport. Those types currently being considered require runways longer and stronger than that at Southend. The policy of these suppliers is to take existing operators aircraft in part exchange. The change over of the fleet could therefore be rapid.

This development is not economic and the best course of action for the area and the country is for it to close. This closure may well be forced on it. If its role as a regional airport had been truly recognised it would not have lain dormant for most of the 75 years as quoted. What has happened in the past is irrelevant to potential claims for compensation for loss of value of property. The extension to the runway marks a clear change in the operation of the Airport and if properties have lost value as a result the owners are entitled to compensation.

The aviation fantasists responsible for writing the 2003 White Paper have a lot to answer for. A shareholder in the company currently attempting to develop the Airport described its management as having made the wrong decisions at the wrong time and is now paying the price. London Southend Airport is one of them. The squandering of large sums of shareholder capital cannot justify the continuation of an unsuitable and unsustainable project. In a similar way Southend Council has continued to persist in trying to develop the Airport because to do otherwise would mean admitting making a mistake and wasting taxpayers money.

In view of the above the document cannot be considered to have been drawn up in a rational manner and is therefore unbalanced. To be legally compliant the document is required to be balanced, by failing to do so the Submission Draft is rendered unlawful.

Object

Representation ID: 32663

Received: 25/04/2013

Respondent: Mr B J Free

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The document states that "London Southend Airport must be able to accommodate new and future aircraft models that re quieter and more fuel efficient".

The description of the A319s currently operating from the Airport as the most modern and fuel-efficient is incorrect. These aircraft conform to chapter 3 of annex 16 to chapter 30 of the Chicago Convention. The specification for chapter 4 aircraft was agreed in 2006 and it is the policy agreed in 2012 to aggressively replace chapter 3 aircraft with chapter 4 aircraft in order to meet commitments on reducing emissions. The replacement fro the current A319 is the A319neo (new engine option). Both Boeing and Airbus are offering conversions by re-engining existing narrow bodied airlines to meet the new standard. The new engines provide greater fuel economy and therefore lower emissions of CO2; but are heavier, larger in diameter and produce less maximum power. This has the effect of increasing the takeoff run meaning that the increase in runway length has been negated. It also increases the landing weight and approach speed putting more impact load on the runway.

The operating costs of the A319neo (156 seats) and the A320neo (180 seats) are virtually the same and orders for the A319neo have dried up. Fewer than 30 A319neos but more than 1,400 A320neos are currently on order. EasyJet has no A319neos on order having converted their orders for A319s to A320neos, these aircraft are heavier and require a runway longer and stronger than that now at Southend.

EasyJet are said to be considering the Bombardier C series but only the CE100 (125 seats max) and CE300XT (145 seats max) could fly from Southend at maximum take off weight. The XT indicates extra thrust meaning the aircraft is over engined. The Bombardier C series cannot accommodate a standard airline freight container in its hold, and is therefore unlikely that this type will be suitable for easyJet operations. Airlines generally prefer a single source fleet.

Of the aircraft currently using or proposed to use Southend, the Fokker 100, Boeing 737 600 series and Boeing 717 are chapter 3 aircraft. The Embraer 195 is a chapter 3 aircraft and requires a runway of 2,179 metres at maximum takeoff weight. Only the turboprop aircraft operating from the Airport such as the ATR 52/72 of Aer Arran have chapter 4 compliance . Correct decisions cannot be based on false or misleading information. The councils rely too heavily on the Airport for aviation related advice and this is heavily tainted by self interest.

The vast majority of passengers flying from London Southend Airport are seasonal holidaymakers. It is the current policy of easyJet to move its passenger profile away from holiday traffic to the more lucrative business travellers. To this end they have introduced allocated seating and some seating with increased legroom. Few if any of the routes currently being offered appear to have any potential for business travel. It would seem that the decision of easyJet to come to Southend has more to do with internal politics within the company than hard economics. EasyJet moved to East Midlands Airport but left in 2009 citing lack of profitability of seasonal holiday traffic which included flights to Faro and Ibiza. Aer Arran has already abandoned two of its routes, OLT Express has gone into receivership and Air Maastricht has delayed a decision to come to Southend.

The aviation industry is committed to reducing the amount of greenhouse gas emissions from its aircraft. The move to Chapter 4 aircraft is part of this process. The elimination of stacking where aircraft circle aimlessly waiting to land will make an additional major contribution to this process of reduction. The further development of Precision Air Navigation by which an aircraft will fly under computer control via satellite link in the most economical manner and land immediately on arrival is part of this scheme. To ensure immediate landing on arrival the airports that will be permitted to operate in the future must have autoland systems it is unlikely that Southend Airport would be able to justify the cost of the installation and running of such a system, or that the location is suitable. The large number of small airports in the UK complicate the air traffic control system and without autoland systems they will be unable to fully participate in the programs to reduce greenhouse gas emissions and will be forced to close. Paul Kehoe Chief Executive of Birmingham Airport is on record offering the opinion that the UK has twice the number of airports it needs. The standard length for a regional airport is likely to be set at 2,500 metres unless there are exceptional circumstances.

The consultation document looks forward to 2020 without any reference to the developments in aviation that will take place in that timespan. In view of this the document cannot be considered to have been drawn up in a rational manner and is therefore illogical and unbalanced. It is a legal requirement that such a document must be balanced, as it is not it is therefore unlawful.

Object

Representation ID: 32668

Received: 25/04/2013

Respondent: Mr B J Free

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Government policy on air travel is in a state of flux witness the delays on decisions regarding the provision of increased runway capacity in the Southeast. The effects of climate change are being increasingly felt and policies to reduce greenhouse emissions are being pursued with vigour.

It is EU policy to replace domestic flights with fast rail. Steps are being taken to standardise rolling stock to facilitate cross boarder traffic. Low level high speed rail tunnels have been constructed beneath both the Alps and Pyrenees.

Lufthansa and Air Berlin have withdrawn domestic services that can no longer compete with rail. Both the German and Dutch railways have been cleared to open services to Stratford through the Channel Tunnel, they will start as soon as new rolling stock is delivered.

Such services will provide superior comfort and more importantly punctuality and reliability. This combined with the future cost and availability of fossil fuels makes the present policies unsustainable and irrational.

To develop a facility that is being rapidly overtaken by events is unbalanced. To be lawful a document such as this is required to be balanced. This makes the Submission Draft unlawful.

Object

Representation ID: 32671

Received: 25/04/2013

Respondent: Mr B J Free

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The document states that 'The extended runway is in fact 1,905 metres in length'. The declared length of the extended runway is 1799 metres TODA (Takeoff Length Available) any further length is pave and must not be used as runway, therefore the reference in the report to 1905 metre length of runway is in error. The CAA Aerodrome Chart identifies the length of 37 metre wide pave as 1856 metres; the remaining pave is 30 metre wide starter extension plus hammerhead. In addition to still being short the runway is narrow imposing crosswind restrictions on aircraft such as the Airbus 319. Its strength is also debatable. Because it is unique in the base being constructed entirely of stabilised soil, it does not fit readily into either of the standard categories of runways either flexible or rigid. It has been categorised, as flexible, but only time will tell if the ascribed PCN of 39 is correct.

Furthermore the document states 'aircraft will be slightly higher as they come in to land over Rochford'. The approach angle to the 24 runway has reverted to the standard approach of 3 degrees; which is that recommended by the International Institute of Airline Pilots Associations, who believe it should only be deviated from in exceptional circumstances. Prior to this the angle of approach to 24 was 3.5 degrees. This means that aircraft on this approach will be higher for 695 metres from the threshold but further out than this they will be lower.

The direction of takeoff and landing is determined by wind direction. The prevailing wind is from the south-west and this will bias air movements to use the 24 runway. The Airport is yet to be able to dictate the direction of the wind. An Embraer 195 at full fuel and payload requires a runway 2,179 metres long, this type has yet to operate from the Airport.

The document contains significant errors of fact outlined above which result in it being irrational and unbalanced. Being unbalanced it is also unlawful as this is a statutory requirement.

Object

Representation ID: 32672

Received: 25/04/2013

Respondent: Mr B J Free

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The opening hours at London Southend Airport are excessive and unacceptable especially for one with housing in such close proximity. No other comparable airport allows such opening hours. Up until 1956 the Airport opened at 06:00 hours and closed at 22:00 hours during summer months and at 08:00 hours till 20:00 hours in the winter. No night flights except in emergencies were permitted. Only after the Airport had accumulated excessive debt by hardening the runways and installing expensive runway lighting systems were unlimited hours permitted. It was fortunate for the residents of Southend, Rochford and surrounding areas that the bubble of air activity created by these measures soon collapsed. The cruel and unfeeling policies imposed in the past cannot be used to justify the present policies. These though they are an improvement on those in the past, they could hardly be worse, are still unacceptable.

The Submission Draft refers to the Boeing 737-300 as being likely to operate from the Airport. Only a small number of heavily modified Boeing 737-300 are currently flying. Some fly with Sky's freight operation that flies into the Airport; but to date has only used Airbus A319s there. Because of its poor safety record unmodified aircraft of this type are banned from flying in most of the world, unmodified they cannot fly in Europe.

The direction of takeoff and landing is determined by wind direction. The prevailing wind is from the south-west and this will bias air movements to use the 24 runway. The Airport is yet to be able to dictate the direction of the wind. A 50-50 distribution of takeoff and landing direction cannot be guaranteed. Except in conditions of still air or very low wind speed the weather not the Airport determines the direction of takeoffs and landings.

Without precise measuring and recording of aircraft movements any scheme of monitoring of preferred routes is unenforceable. The current practice leaving aircraft transponder not yet operating until they are well clear of the Airport makes this impossible. The proposals in this respect are merely a fig leaf designed to hoodwink residents.

The Submission Draft did not compare the opening hours proposed for London Southend Airport with those of comparable airports. Failure to do this renders it unbalanced, and as balance is a statutory requirement it is unlawful.

Object

Representation ID: 32674

Received: 26/04/2013

Respondent: K Attridge

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Please find attachment paperwork.

As stated by notes the ILS safety zone is flawed, it is known about but Councils and CAA have chosen to ignore the fact of 28 hectors or rising land exists (paperwork included) this in my opinion has been used as a smoke screen it mentions two items in this area, what it fails to identify is that every single building on the 28 hector of land is an obstacle and therefore all people in dwellings are more at risk. The CAA is currently being challenged on this, in the High Court.