London Southend Airport and Environs Joint Area Action Plan Preferred Options

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.

Southend Airport & Environs Joint Area Action Plan (JAAP)

Thank you for consulting Natural England about the above document. Natural England's comments are as follows.


1. On-site impacts

Natural England notes that the land directly affected by the proposed airport expansion is of relatively limited nature conservation value. Protected species may be present, but any impacts upon such species could almost certainly be addressed through appropriate mitigation measures.


2. Potential impacts upon statutorily designated sites and areas

Noise and disturbance
The proposed development would result in a significantly increased frequency of overflights of the Dengie SSSI, SPA, Ramsar site and NNR; and of the Crouch and Roach SSSI, SPA and Ramsar site by aircraft during approaches. If the typical altitude of such overflights remains unchanged from that currently employed, and taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that the increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which these sites are designated. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that the approach path would be at a shallower slope than currently employed, resulting in overflights of these designated sites taking place at significantly lower altitudes than at present.

There would also be an increase of a similar scale in the number of overflights of the Benfleet and Southend Marshes SSSI, SPA and Ramsar site during departures. However, in view of the altitude at which such overflights normally take place, and also taking into account the ability of most birds to become habituated to regularly-occurring noise disturbance, Natural England is satisfied that this increased frequency of overflights would not be likely to result in any significant impact upon the interest features for which this site is designated.

Air quality
The proposed development would be likely to result in the above coastal designated sites being subjected to increased levels of exposure to oxides of nitrogen and other pollutants, both from the increased number of flights and from increased surface transport associated with the development. As a consequence, these sites would also be likely to be subjected to increased nitrogen deposition and acid deposition. However, Natural England does not consider that these coastal sites are particularly sensitive to this form of airborne pollution and, consequently, is satisfied that the proposed development would not be likely to result in any significant impact upon the interest features for which these sites are designated.

In addition to the above coastal sites, there are also a number of terrestrial designated sites in the vicinity, including Garrold's Meadow SSSI, Great Wood & Dodds Grove SSSI, Hockley Woods SSSI, and Thundersley Great Common SSSI. It is likely that these sites would also be subjected to increased levels of atmospheric pollutants and deposition as a result of increased flights and/or the associated increased surface transport; although probably to a lesser degree than the above coastal sites. In the absence of any detailed modelling of pollutants or deposition, it is not possible at this stage to determine the scale of any such impacts although, in view of the semi-urban locations of these SSSIs, it is unlikely that this would constitute a major proportion of the total pollution impact upon these sites. However, Natural England reserves the right to object to any subsequent application if modelling does show a significant impact upon any statutorily designated site.

Surface Water run-off
There is potential for the above-mentioned designated sites to be affected by the increased surface water run-off resulting from the increased area of hard surfaces and this would need to be addressed through the provision of suitable balancing ponds or storage tanks. During the winter months, run-off from the runway, taxiways and aircraft hardstandings may be contaminated by de-icing chemicals such as glycol or urea, and adequate measures would need to be put into place to deal with any such chemicals before the water is discharged to the wider environment.

Potential impacts resulting from displacement of existing activities
If the proposed development were to result in the relocation of existing activities such as flying clubs to other airfields then this could potentially result in impacts upon other designated sites. In the absence of any details, it is not possible to consider this issue further at the current time. However, Natural England reserves the right to object to any subsequent application if it becomes apparent that any such displaced activities would be likely to have a significant impact upon any statutorily designated site.


3. Wider environmental issues

Contribution to climate change
Natural England notes that the aviation sector is a significant and rapidly increasing contributor to climate change, due to its emissions of CO2 and other greenhouse gases (GHGs). According to forecasts, aviation could be responsible for 10-15% of the UK's carbon dioxide emissions by 2020; implying that aviation growth as envisaged in the Aviation White Paper is likely to be incompatible with meeting the UK's climate change targets.

Natural England is, therefore, concerned about the potential impacts of the proposed expansion of airports across the UK. The debate on UK aviation is hampered by a lack of agreement on basic data and forecasting. This is identified in the recent Sustainable Development Commission (SDC) report which states that "much basic evidence on which current and future [aviation] policy is based, is in dispute". The SDC report highlights a disagreement on the economic arguments for and against aviation (for example, the extent and significance of the tourism deficit). Other research has highlighted that the cost-benefit analysis undertaken for the Aviation White Paper focused primarily on predicted time savings for passengers, but did not include monetary estimates for environmental disbenefits such as impacts on biodiversity and landscape. In addition positive and adverse impacts cannot be quantified and are not always represented in the cost benefit analysis of expansion so that, for example, the Department for Transport's cost benefit analysis for new runways at Stansted and Heathrow remained positive even when worst case GHG emissions scenarios were used.

Loss of tranquillity
The increased number of aircraft movements associated with the proposed airport expansion would be likely to result in a further degradation of the sense of tranquillity experienced by visitors to this part of the Essex coast and its estuaries.

Constraints on future habitat creation or enhancement
Natural England is concerned that the safeguarding requirements associated with the proposed airport expansion may potentially be more stringent than at present and could place restrictions upon future opportunities for habitat creation or enhancement in the vicinity of the airport, particularly of wetland sites likely to attract birds (eg managed coastal realignment sites). Both the 'Thames Estuary 2100' report and the emerging Essex Shoreline Management Plan have identified the need for significant additional areas of new coastal and wetland habitats in order to compensate for the ongoing losses resulting from 'coastal squeeze' due to climate change and sea level rise.


I hope that the above comments are of assistance in progressing the JAAP. If you have any queries about the contents of this letter, please do not hesitate to contact me again.