London Southend Airport and Environs Joint Area Action Plan Preferred Options

Object

Representation ID: 9229

Received: 08/04/2009

Respondent: CPREssex

1.1 Green Belt

Preservation of Metropolitan Green Belt (MGB) is a fundamental tenet of planning policy, set out in PPG2. . There is a distinct lack of clarity in the consultation document - e.g the map on p14 has no key and it was necessary to refer back to the council and to the June 2008 Issues and Options report to get an adequate picture of the current land use plan.

Having done so and assessed the proposals, our response is:

• We cannot accept the loss of MGB land to the north of aviation way, marked ii(a) and ii(d) on p14.
• The land at iii(c) is also MGB and needs to stay as such. It needs no alteration to its use or classification. (The proposal for this site is unclear).
• The land at ii(b) likewise is MGB and should be preserved as such. It should not be re-classified. The preferred option includes the re-location of Westcliff Rugby Club and refers to policy ENV2 which in turn refers to policy E7. The proposed re-location of the rugby club facilities will have to be funded by the Saxon Park area 2 development. This is an unnecessary and interdependent chain of actions, which have no demonstrable link to expansion of the airport or its runway except to help fund them. The simplest and only environmentally acceptable answer is to retain the Green Belt land as such and leave the rugby club where it is.

We note the reference to revising Green Belt boundaries: Some Local Planning Authorities in Essex have been encouraged to reconsider their MGB > boundaries in the Regional Spatial Strategy. But Rochford is not one of these. PPG2 requires that Green Belt boundaries should only be altered in 'exceptional circumstances'. (PPS2 Green Belts). The scale of alteration proposed here is very large and would be hugely detrimental to the value and purpose of the MGB in providing open and essentially unspoilt countryside dividing the conurbations of Rochford and Southend. The prospect of further encroachment of urbanisation is unacceptable.

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.

The industrial development (Saxon Business Park) proposed to the north of Aviation Way is totally unacceptable both in its scale and character on Green Belt land.

Also, situated directly to the west of the Brickworks' site, and the MGB land north of Aviation way lies the Cherry Orchard Jubilee Country Park, within a Special Landscape Area. This area is designated for its landscape and ecological quality. Industrial development of land on the other side of Cherry Orchard Lane would have a negative impact on the landscape character and visual amenity of this 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.

This proposal in no way constitutes 'exceptional circumstances' for such a large incursion into the green belt. Only the small area marked (iii) on the 'areas for change' map might be considered for employment use for the MRO business (and only the MRO business) if there is no other alterative. Even so this should not be considered a precedent for any further alterations in Green Belt boundary.

A 'green buffer' and new public open space, referred to in the POR, are not planning gains. They in no way compensate for the loss of existing green belt land and would alter its classification making it less protected and more vulnerable to future development.

Object

Representation ID: 9230

Received: 08/04/2009

Respondent: CPREssex

1.2 Agricultural Land

The document gives no information as to the agricultural quality of this land - areas (v), (x) and (xi). Whether or not this is currently used for agricultural purposes - crops or livestock 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.

In particular we regard any proposal to develop agricultural land in order to advance aviation activity and thereby contribute to climate change - which will further damage the UK's food security - as an unsustainable and perverse policy.

In terms of current usage we consider the proposed loss of recreational facilities for active exercise such as cricket, football or rugby or allotments would be detrimental to quality of life and, potentially, the health of those who use these facilities.

The preferred option for Area (v) is a case in point. Instead of the facilities now available this piece of land would be carved into two by a 'safeguarded' 'corridor' earmarked to become a link road. The implication is that both the allotments and cricket pitch would be lost and the amenity value of the two remaining strips of 'public open space' would be vastly devalued.

Comment

Representation ID: 9231

Received: 08/04/2009

Respondent: CPREssex

1.3 Noise

The POR has nothing material to say about noise. It makes no reference to previous acknowledgements in the IOR and other documents that there would be more noise both from increased surface transport (unless fully mitigated by a modal shift to public transport) and from increased air transport movements (ATMs).

Yet noise is perhaps the most abhorred side effect of aviation. Over the longer term development may well lead to quieter aircraft. But this gain would be drowned out by an increase from 863 Air Transport Movements (ATMs) in 2008 to at an estimated 25,000 ATMs (assuming average aircraft occupancy increased from 49 in 2008 to 80 at the 2million passengers per annum (mppa) throughput level.

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 would be heard and seen over most of the town, and a large part of Westcliff, Leigh and Eastwood would no longer be able to enjoy a the quiet of their back garden on a weekend afternoon. There are also concerns about the several local schools that would be close to the flight paths.

Without projected noise contour maps no specific assessments can be made. But it does not take much imagination to realise the impact on the quality of life of local residents and the potential loss of tranquillity in the surrounding countryside to the north and east of Southend.

Object

Representation ID: 9232

Received: 08/04/2009

Respondent: CPREssex

1.4 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. Lights on aircraft in flight, especially coming in to land, can also inflict light nuisance on residential properties near to the airport.


1.5 Surface Water-

There is no reference to potential impacts on surface water or to matters raised in the consultation on the IOR. We would refer to the Sustainability Appraisal (SA) provided at that time (June 2008), which 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 applied to scenario 1 in the IOR - the lowest level of expansion. The scenario proposed in the POR, involving a much higher level of expansion is likely to make the impact on water quality worse.

We therefore concur with 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."

Object

Representation ID: 9233

Received: 08/04/2009

Respondent: CPREssex

1.6 Public Safety Zone

Policy LS5 says:
'It is recognised that the current Public Safety Zone for London Southend Airport will need to be reviewed when the runway is extended.'

This review should be carried out before and be part of the planning application.

Object

Representation ID: 9234

Received: 08/04/2009

Respondent: CPREssex

1.7 Other Environmental Issues

There is no mention of other important environmental issues - notably wildlife conservation, biodiversity and built heritage. These matters must be addressed in any planning application that may follow this consultation. We trust the councils have included the RSPB, Essex Wildlife Trust, English Heritage and the Society for the Protection of Ancient Buildings (SPAB) in the consultation process.


1.7 Climate Change

We appreciate that the increase in passenger numbers/aircraft movements proposed by Southend Airport, although very large in percentage terms is 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 more than twice the impact of a tonne at ground level .

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 205O as recommended by the Committee on Climate Change and accepted by the government in 2008, 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.

Comment

Representation ID: 9235

Received: 08/04/2009

Respondent: CPREssex

2. RUNWAY EXTENSION

The original Airport Master Plan (April 2005) envisaged, on a medium growth scenario, a little over 2.1 million passengers in 2030. This was without an extended runway. We understand the arguments that the runway extension might enable this level to be reached earlier and that it would allow larger and ostensibly quieter aircraft to be used; also that the 2 mppa might be carried with fewer ATMs if the right routes, carriers and demand levels were achieved to enable major use of larger aircraft.

However, in our response to the IOR (4 August 2008) CPREssex argued that this option (Scenario 3) was unacceptable - as was scenario 2(b). We refer the councils back to this document. We said:

"The other two scenarios [scenarios 1 and 2(a)] - 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.

Our position has not changed

We have referred to the net growth in noise impact of the increase in ATMs whether with the existing or extended runway. It should also be noted that merely flying quieter aircraft is only an advantage if there are no more of them. It is aircraft that disturb people in their houses and gardens not decibels.

No reference is made to potential impacts on All Saints Church - a Listed Building - or nearby residential properties. The current runway ends at Eastwoodbury Lane and so aircraft taking-off/landing do so some way from the church and houses. The extended runway would mean planes taking-off/landing beside the church and much closer to the houses. Noise and lighting impacts would be greatly exacerbated. We need far greater clarity on the possible consequences for the church and it's functioning.

We have also drawn attention to the unacceptable land-take proposals consequent on the runway extension.

The POR contains no reference to demolition of or impacts on residential or other properties. The impacts of the proposed new link road are not spelled out. In the absence of any specific information the most reasonable assumption is that there would be negative effects on communities in the area.

Object

Representation ID: 9236

Received: 08/04/2009

Respondent: CPREssex

Policy LS7 - Operation of New Runway says that Planning permission for the runway extension will be supported subject to conditions on:

1. The restriction of scheduled passenger flights to between the hours of 06:30 and 23:00 local time Mondays to Saturdays and 07:00 to 23:00 local time on Sundays;
2. The operation of cargo flights, outside the hours specified above, will be controlled by an agreed noise quota;
3. The routing of aircraft on both take off and approach to reduce noise and environmental impact;
4. The operation of helicopters;
5. The restriction on operation of aircraft types for commercial and freight operations to aircraft specified in the ICAO Chapters 3 and 4 of Annex16 - Environmental Protection, Volume I - Aircraft Noise to the Convention on International Civil Aviation (International Civil Aviation Organisation);
6. Engine ground running; and
7. Aircraft training movements for aircraft with a seating capacity of over 50.

On point 1, night (sleeping) hours would reasonably be accepted to be 22:30 to 07:00, not 23:00 to 06:30. There should be no flights between these hours - either passenger or cargo.

With the exception of point 5 none of the other points tells us anything material. This is another inadequacy of the document. Comment is not possible unless we know what the conditions are.

Support

Representation ID: 9237

Received: 08/04/2009

Respondent: CPREssex

3.1 Surface Access Plan and Modal Share

We are not experts in this area. However we believe we can justifiably make the following comments.

We approve Policy LS4 - Surface Access Strategy, which says:
The airport operator will be required to prepare a Surface Access Strategy, the first version to be submitted in advance of any applications for planning consent, and thereafter an update of the strategy to be submitted every five years.
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 costed and funded plans to achieve it.

Section 4.1 of Part 1 of the Evidence Base we considered in responding to the IOR refers to

"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 found no forecasts in the evidence base at that time of future modal splits when with passenger numbers up to 1mppa and eventually 2mppa.

This is a vital issue given current road congestion in the area. Para 4.5.1 p 40 in the Evidence Base lists surface access recommendations. These were, and are, purely aspirational. We found it unacceptable that the development proposals in the IOR had 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.

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.

Comment

Representation ID: 9238

Received: 08/04/2009

Respondent: CPREssex

3.2 New Station

Conceptually this might contribute to improvement in surface access modal split. But this outcome appears largely aspirational.

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 council's should prepare surface access forecasts for all scenarios, including this 'preferred option' to enable informed assessment of the contribution a new station might make to the aviation business.

Reportedly the investment by Stobart Ltd is in part dependent on the development of the station going ahead.

Under the present state of information we cannot see how POR would admit any informed assessment of surface access proposals by those with expert knowledge.