London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.

1. Summary

On the basis of the information given CPREssex would reject scenarios (options) 2(b) and 3.

Our assessment of the key issues shows why. Ultimately it is about the inherently unsustainable nature of aviation expansion.

Globally this is first and foremost about aviation's contribution to climate change. Locally it is a matter of quality of life versus unsustainable development. Whilst there are claimed local economic advantages, we contend that only the enhancement of the MRO activity without aviation growth by a factor of 40 times appears to be achievable without unacceptable environmental damage.

The aviation-growth business model predicated on growth in low-cost, short-haul tourist flights is overall a negative contributor to the UK economy. (In 2007 the UK trade balance in travel and tourism showed a record £19.5bn deficit. It creates tourism jobs overseas at the expense of jobs in the local, regional and UK economies.)

Recourse to National policy for support is increasingly seen to be ill founded. Increases in fuel prices, the general economic downturn and the growing recognition of the seriousness of climate change threats have altered aviation market conditions and have led authoritative bodies to call for a review of national aviation policies.

Current policy runs counter to the government's own policy for sustainable development.

We believe that the preservation and enhancement of the quality of life is the most important responsibility of local authorities and this cannot be squared with a huge increase in aviation activity and the associated development.

We have noted some information gaps that need to be filled. We also found that the IOR report was poorly linked to the Draft Sustainability Appraisal and Evidence Base Report. This made it sometimes difficult to locate relevant underlying information.

CPRE can make only limited comments, or none, on some important impacts notably on biodiversity/ecology, air quality and built heritage.

The Councils/Airport Owners should ensure they consult Essex Wildlife Trust, RSPB, Society for Protection of Ancient Buildings and any relevant local bodies on these issues.

2. Environmental Issues

2.1 Green Belt

Only scenarios 1 and 2(a) are claimed to involve no change to the Metropolitan Green Belt (MGB). However Fig 5.1 p54 shows an incursion into the MGB an extension to area (vi). And Fig 5.2, Scenario 2(a), in fact shows two incursions into the MGB. These apparent contradictions require explanation.

The other two scenarios proposing large growth in passenger aviation activity document progressively greater negative impacts (Tables 11.5.3 and 11.5.4). The results would be increasingly damaging and, scenario 3 would involve loss of about 50% of green belt currently outside the airport boundary but within the JAAP area.

CPRE is wholly against any loss of MGB, especially so in this part of the UK which is already becoming over-developed. The Green Belt prevents urban sprawl and the merging of nearby urbanisations. It provides openness and varying degrees of tranquillity and a habitat for wildlife. It contributes to quality of life, mental and physical health and well-being.

We find some statements referring to Green Belt to be somewhat euphemistically worded and references to mitigation/compensation that misrepresent the reality of what is proposed. We do not wish to 'nit-pick' but these are important documents and lack of clarity could mislead. Examples are:

Under Option 2(b) the Sustainability Appraisal says:
"Although no designated areas of landscape value are located within the site, the series of hedgerows, scattered trees, ruderal [sic] vegetation and other greenery within the greenbelt area provide a landscape character to the area which will be reduced under this proposal. Enhancements to areas v and ix provide compensation to this significant negative effect, therefore the medium growth scenario is marked negative against this objective."

We appreciate that a 'negative' rating is still given. But we do not accept that significant negative effects of this nature can be mitigated by some apparently minor, unspecified enhancements elsewhere in areas that are of a different character. Unacceptable damage is unacceptable damage.

Under Scenario 1 (low growth) there is claimed to be no landscape impact. Under scenario 2 (a) the claimed advantages and disadvantages are shown as follows:

Advantages
Expansion of country park area will potentially protect the landscape character and visual amenity of the area. The development of the Brickworks' site could potentially enhance the visual quality of the derelict area. Local recreational and amenity improvements would support the overall landscape quality in the JAAP.

Disadvantages
Situated directly to the west of the Brickworks' site, lies the Cherry Orchard Jubilee Country Park, situated within a Special Landscape Area. This area is designated for its landscape and ecological quality. Development of the Brickworks' site could potentially negatively impact on the landscape character and visual amenity of the surrounding landscape. The negative impact of visual amenity would affect both recreational users of the Country Park and surrounding areas, and residents of Cherry Orchard Lane. Similarly expansion of the employment area would have similar negative impacts on the landscape character and visual amenity of the area.

The negative impacts clearly outweigh positive impacts. The net result of Brickworks site development would be negative. We cannot comment on the degree to which "local recreational and amenity improvements would support the overall landscape quality in the JAAP" for one thing these improvements are not specified. Also, this is ultimately a quality of life issue and requires direct input from local residents as to what matters and why.

In the Table under para 5.4.1 in the IOR report against Green Belt the text says:

"The Green Belt boundary would be revised to reflect development land requirements for the period of the JAAP. This would include taking the Green Belt around the airport boundary and any new land allocations justified through the future role of the area. By drawing the Green Belt tight to new allocations no further scope for development would be envisaged in the JAAP area."

This is largely unintelligible. Figure 5.3 on p 66 shows the reality approximately 50% of Green Belt outside the airport boundary (but inside the JAAP) will be lost.

2.2 Noise

The IOR and other documents acknowledge that there would be increased noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

The impact of an additional 2 million passengers travelling to and from the airport in an already congested area of surface transport cannot be countenanced unless a very large proportion indeed travel by public transport. Any proposal for expansion of passenger aviation must be accompanied by funded plans to achieve this.

In 2007, according to CAA statistics, there was a total of about 878 ATMs carrying 49,000 passengers (average passengers per flight 560. One million passengers per annum at the same loading would mean some 17,800 ATMs on average 49 flights per day. If 2 million passengers were carried the result would be around 35,700 ATMs 98 flights per day, on average. (all projections are based on the current runway/aircraft type and load factor)-

According to local opinion, a sizeable portion of Western Southend could be affected by noise from the increased numbers of flights. The greatly increased flights will be heard and seen over most of the town and a large part of Westcliff, Leigh and Eastwood will no longer be able to enjoy the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools which would be close to the flight paths.

It does not take much imagination to realise the impact on the quality of life to local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

2.3 Light Pollution

There is no reference to lighting impacts either light pollution or light nuisance. New airport buildings and car parks are potentially damaging sources of the former. If located near to residential areas they may also constitute light nuisances. New buildings in the industrial areas within the JAAP would be subject to the same comments. Light pollution and light nuisance should be covered in all scenarios.

2.4 Surface Water

The Sustainability Appraisal (SA) says (appendix 1):

"The airport will continue discharging waste-water into the brooks within the site through the interceptor. Any natural growth of the airport activities is likely to decrease [sic] or maintain the current bad water quality in the brooks."

We assume that 'decrease' as used here means 'make worse'. This would be unacceptable in terms of potential impact on landscape and wildlife. This statement applies to scenario 1. Other scenarios are likely to make the water quality progressively worse. We echo a later statement in the SA.

"It is imperative for the detailed development plans to set out strategies to ensure the water quality is maintained." albeit current quality is said to be poor.

2.5 Agriculture

We note that under scenario 3 the runway would be extended into agricultural land. Whether or not this is currently used for crops, the real and growing threat of food shortages (virtually inevitable with world and UK population growth) argues against any reduction of agricultural land. We have to preserve the means to produce as much as possible of our food in the UK. The increasing cost of 'food miles' also points to producing more at home.

2.6 Biodiversity

This is not our area of expertise. We are however pleased to note the statement in the SA in relation to Scenario 1 that:

"A detailed ecological assessment and management plan shall be required to predict and influence the biodiversity structure in the JAAP area."

There are similar more specific statements on other scenarios. We would be opposed to any scenario that has a negative impact on biodiversity.

2.7 Build Heritage

The Evidence Base Report Part 1 Para 5.8.2 p66 says

There are 81 listed buildings within the wider area covered, of which 3 lie within the study area. These buildings are:

A milestone on the verge of the Southend Road (NMR listed building No. 123241) which is a Grade II listing;
'Cherry Orchard' (NMR No. 123182) a timber-framed 17th century Grade II listed house, and;
The Church of St Laurence and All Saints (NMR No 122902) on Eastwoodbury Lane which is a Grade I listing.

There are two more listed buildings that appear to abut the northwestern corner of the study area boundary. These are both Grade II listings:
Nos. 17 and 19 Southend Road (NMR No 123240) and;
Nos. 39 and 41 Southend Road (NMR No. 123242).

The July 2005 AMP said (p45 paras 146 and 147) said:

"146...new requirement to introduce Runway End Safety Areas (RESAs) led to considerations of a runway reconfiguration, which was eventually rejected. The RESAs now in place are 90m in length at the northeast and 240m in length at the southwest end. Additionally, at the southwest end, Eastwoodbury Lane is now protected by traffic lights and an automatic barrier, which are activated when certain aircraft take off. In these ways the safety requirements of the CAA have been met. Land has been acquired on lease for these improvements.
147 Although the issue of the proximity of St Laurence and All Saints Church remains, and this has been accepted by the Civil Aviation Authority, there is no requirement now or in the future to disturb any of the graves. The Airport will continue to work with the Church authorities to find a way to reduce the infringement of the CAA regulation in respect of the boundary fence and trees.

But the Evidence Base Report Part 2 Table 11.5.3 p138 says:

"Land development could impact on the setting of existing features of archaeological and cultural heritage interest eg Church of St Laurence and All Saints, and could also potential [sic] damage unknown/buried features of interest."

Table 11.5.4 p 141 has the same statement in respect of Scenario 3

We find this very disturbing and trust the church authorities are fully informed of this issue. We need a clear unequivocal statement if any proposed development option would infringe CAA regulations in such a way as to result in impact/damage to the church (or other listed buildings) and, indeed of any known threat to built heritage.

3.1 Modal Shares

Section 4.1 of Part 1 of the Evidence Base p26 refers to

The Airport's Surface Access Strategy published in August 2006 and the Transport Assessment for the proposed new Parkway Station undertaken by Bettridge Turner and Partners in 2005 were analysed in order to obtain further information about the surface access to the study area.

The new railway station could hopefully contribute to an increase in non-private car access to the airport. Para 4.3.5 p30 reveals

"According to the Airport Surface Access Strategy, the staff survey carried out in 2006 revealed that 79% of staff drive to work alone, 7% car share, 11% use bicycle, 4% use motorcycles, 3% use the bus and 5% walk to work. 50% of car users say it is the quickest way."

This is the only indicator given of the likely modal split under current circumstances. We have found no forecasts in the evidence base of future modal splits with passenger numbers vastly increased to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p40 lists surface access recommendations. These are purely aspirational. We find it unacceptable that the development proposals in the JAAP have no concrete accompanying surface access plan, nor any clear statement of who would be responsible for funding including the share to be borne by the airport owners.

Surface access forecasts and modal shares need to be published for all scenarios.

Any growth in passenger numbers should be catered for by maximum use of public transport. Any development plan should seek to greatly reduce the number of journeys by car, without which it would be unsustainable and environmentally damaging. Together with the increased air traffic movements, hugely increased road traffic will damage air quality creating both a health hazard and potential damage to the natural environment.

A genuinely sustainable surface access strategy is required.

3.2 New Station

Conceptually this would be a welcome development and would contribute to improvement in surface access modal split.

We are however concerned that the proposed car parking for commuters at the new station would lead to increased car journeys an unsustainable outcome the proposers should prepare surface access forecasts for all scenarios.

3.3 Scenario 3 Road Closure

We are unclear about the possible implications of the proposed re-routing of Eastwoodbury Lane.

4. Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport in its Airport Master Plan4, although very large in percentage terms are not large in absolute numbers. Nevertheless, aviation emissions are a significant contributor to climate change both via the amount of CO2 emissions and through the radiative forcing effect that means a tonne of CO2 at flight altitudes has almost twice the impact of a tonne at ground level.

Government figures show that in 2005 aviation accounted for 13% of total UK climate change damage. That is an understatement because it is based on departing flights only: if the calculation is based on return flights by UK citizens in 2007 the figure would be nearer 20%. The figure for CO2 alone is 6.3%, but this is multiplied by 2 to take radiative forcing into account. This was confirmed by Gillian Merron, Aviation Minister, in response to a Parliamentary Question by Peter Ainsworth, in the Commons on 2nd May.

The UK has set targets for CO2 reduction across industry. But aviation emissions if allowed to increase on the 'predict and provide model' will negate this target. By 2050 it is claimed, aviation will represent 29% of UK carbon emissions, a calculation based on a 60% cut on 1990 levels of all emissions excluding aviation. But if all our emissions, including aviation, are to be cut by 80% by 2050 as is now recommended by scientists, aviation's proportion will look very much higher than 29%. This makes any increase in aviation activity fundamentally unacceptable from the climate change viewpoint unless it could be achieved on a carbon neutral basis.

5. Economic Factors

5.1 Local Factors

We would support council policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We note that MRO employment currently outweighs aviation employment by a factor of about 7 (910 to 140). 7 However, the skill sets would be totally different and, with some exceptions, the aviation jobs would be lower skilled.

We note the evidence base report draws on the employment forecasts made in July 2005 Master plan. These relate to the proposal to increase aviation to 2mppa on the existing runway.

*The growth of the airport to 2 mppa by 2030 will result in a significant increase in employment associated with the airport and aviation industry from current levels. Total employment supported by the airport to 2030 under this growth model is 2,400 FTEs. This includes 2,110 direct FTEs (910 air side and 1,200 MRO); 100 indirect and 190 induced FTEs. Within the plan period to 2021 the report indicates that in 2020 the employment supported would be 2,160 FTEs including 1,900 direct FTEs (700 air side and 1,200 MRO); 90 indirect and 170 induced FTEs. Therefore, the additionality created by this growth model to 2020 (over and above 2005 employment) is 1,110 FTEs including 970 direct FTEs and 140 indirect/induced FTEs."

This shows the forecast incremental FTE employment to be 290 MRO (32%) and airside 770 (550%). It supports the general expectation that an increase in aviation activity of itself generates predominantly lower skill, service jobs. The skill sets required for many of these jobs are reported to be in short supply in the area, according to prior studies (6) quoted on ps 128 and 129 of the Evidence Report Part 2.

There are no forecasts for the extended runway option but the source assumes that the above staff levels would be reached earlier.

In both cases the required aviation staff would apparently need to be drawn from outside the area, involving travel much of it by car on current modal share information an unsustainable outcome.

5.2 Wider Issues

On wider economic issues our comments are:

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK has released a new report, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade.

Low cost flights are under pressure from the high cost of oil and increased charges. Inclusion of aviation in the EU Emissions Trading Scheme will also have an impact. Flights from Stansted, far from rising to its current 25mppa cap, have fallen in the past two years from 24mppa to 22mppa in 2007.

BAA now acknowledges that the second Stansted runway will not open until at least 2015 (assuming approval is given).

It is inferred, but not clearly stated in the IOR that aviation growth would be based on the low-cost short haul model. It should be noted that in terms of the UK economy this has a negative impact. More such flights will put further strain on the UK trade balance in travel and tourism which showed a record 19.5bn deficit in 2007 (£18.4bn in 2006) and will create tourism jobs overseas at the expense of jobs in the local, regional and UK economies.

We find the appeal to appeal to complete the expansion programme in time for the London Olympics somewhat irrational. This will be a short-term 'blip' that can in no way justify a development that will be irreversible and have a lasting impact on the community and local environment as well as on the wider scale.

6. National Policies

The December 2003 Air Transport White Paper (ATWP) states "The Government recognises the benefits that the expansion in air travel has brought to people's lives and to the economy of this country. Its increased affordability has opened up the possibilities of foreign travel for many people, and it provides the rapid access that is vital to many modern businesses. But we have to balance those benefits against the environmental impacts of air travel, in particular the growing contribution of aircraft emissions to climate change and the significant impact that airports can have on those living nearby."

The government has also committed to sustainable development ("A Better Quality of Life, A Strategy for Sustainable Development" ...quot; 1999)

We contend that the core strategy of the ATWP at national and Essex levels is inherently flawed and that the massive growth in aviation envisioned by the plan is unsustainable and runs counter to the government's own principles of sustainable development.

The ATWP has also been overtaken by events not least the growing awareness of the seriousness of the climate change threat.

Concern has been such that the Sustainable Development Commission (SDC) together with the Institute for Public Policy Research (IPPR) has proposed adoption of a totally new approach to aviation policy making. Including a review of the ATWP.

In relation to local plans, the Sustainability Appraisal Report (SAR) carried out by independent consultants for East of England Regional Assembly (EERA) prior to publication of its draft plan underlines the fundamental unsustainability of aviation expansion.

"But the acceptance of growth at all, and the reference to an 'acceptable balance' between economic benefits and environmental and other considerations, still fails to grasp the point that further growth in air travel provision is environmentally unsustainable.