London Southend Airport and Environs Joint Area Action Plan Preferred Options

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Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Issue 2

Representation ID: 9239

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

4. ECONOMIC FACTORS

4.1 Demand Trends

Rising fuel costs, other charges and the current economic climate have depressed passenger demand. UK airports handled 1.9 per cent fewer passengers in 2008 compared with 2007. Traffic declined most in the final quarter of the year, with four million fewer passengers handled from October to December 2008 than in the same months of 2007

CAA statistics also showed that at the London airports - Heathrow, Gatwick, Stansted, Luton and London City - the fall was two per cent overall, with the largest decline in both absolute and percentage terms at Stansted (with a 1.4 million drop in passengers, representing a 6.0 per cent decline).

Stansted is arguably the best reference for Southend in terms of business model. Flight numbers there fell by 7% in 2008 - from 208,000 to 193,000.

Southampton Airport is, according to local by press reports, regarded as something of a 'role model' for Southend. Total flight numbers there have fallen for the past 3 years - from 58,000 in 2005 to 51,000 in 2008.

Unless there is an unexpectedly quick reverse in current economic conditions, these trends are unlikely to alter in the next few years. Indeed the Department for Transport (DfT), on 31 March 2009, released its revised long-term forecasts for Stansted. These show a forecast demand figure of 46.5m passengers per annum (mppa) in 2030. This is 25.5mppa lower than the forecast made only 5 months ago, in November 2007.

Economic analysts concerned with Stansted expect that the UK GDP forecasts, due in April 2009, will result in a further reduction to 43 mppa or lower.

This surely is not the time to be considering a major investment in developing Southend Airport.

Air Cargo
"Air freight felt its worst decline in September, since the technology bubble burst in 2001, with similar results or more decline expected over the coming months. International volumes were down 7.7% year-on year, with all regions except the Middle East and Africa reporting negative results, according IATA. Year on year air cargo grew just 0.1%."

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS1 - General Policy

Representation ID: 9240

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

4.2 Contribution to the Economy

The POR says (p20)
"It is expected that the airport will be used primarily for passengers supporting a number of Fixed Based Operators (FBOs). However, it is also expected that the airport will see growth in its maintenance, repair and overhaul facilities (MRO) supporting the provision of a range of high skilled jobs in the area. It is not considered desirable for the airport to handle significant volumes of freight due to its location and the pressure that this would place on the local highway network, although it is recognised that some growth in the handling of niche (high value low volume) cargo could be taken forward without compromising the airport's core passenger and MRO functions."
Elsewhere (P8) the POR refers to destinations "as far away as the South of Spain." and the use of 150-seater aircraft.

These statements confirm the inference in CPREssex' response to the IOR that aviation growth would be based on the low-cost short-haul leisure-flight model, whereby Southend airport would be operating as a small-scale version of Stansted.

This aviation business model in fact has a negative impact on the UK economy: The UK trade balance in travel and tourism 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.

Businesses are reported to be planning to reduce not increase air travel. The WWF-UK released a report in 2008, which shows that the majority of UK FTSE 350 businesses hope to cut business flights in the coming decade. '

More such flights will exacerbate this adverse economic impact.

We find the aspiration 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 21-year development that will be irreversible and have a lasting impact on the community and local environment as well as on a wider scale.

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Issue 2

Representation ID: 9241

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

4.3 Employment

In CPREssex' response to the IOR we expressed support for policies to safeguard and enhance the Maintenance Repair and Overhaul (MRO) business, its employment and skill base. We noted that MRO employment then outweighed aviation employment by a factor of about 7 (910 to 140). However, the skill sets would be totally different and (with some exceptions) the aviation jobs would be lower-skilled.

We note that the LSACL 2008 annual report showed direct airport employment at the airport to be 92 . The POR gives no figures for MRO employment.

The employment increases that the POR claims will ensue all relate to the business parks - existing -Aviation Way (AWBP) - and proposed new - Saxon Business Park (SBP) and at Nestuda Way (NWBP).

On page 11, first paragraph, of the IOR it says:

"In economic benefit terms it is considered that under this preferred option, the airport would act as a driver for the local economy, providing direct employment as well as enhanced opportunities for wider aviation related and business employment."
There is nothing in the POR to substantiate this claim. There is no evidence adduced to link the creation of any of these jobs to the expansion of aviation activity or the lengthening of the runway.

But in all cases the new businesses assumed to be attracted to the SBP and the NWBP and to the revamped AWBP would be expected to contribute to infrastructure works necessitated, it would appear, primarily by the expansion of the airport.

The unsupported claim that aviation expansion will in some way increase employment in unrelated areas is repeated throughout the POR.

We noted that the council's resume of responses to the IOR reported the following from EERA:

"EERA also state that nearly a third of business surveyed were deterred from locating in the area because of the proximity of the airport and that this will be a significant factor deterring B1 (Office/light industrial) uses that, as the supporting evidence highlights, will be the most likely source of employment growth".

As to direct employment at the airport - we have looked at work done on Stansted. Professor J. Whitelegg, in his work for the 2007 inquiry into BAA's application to increase passenger numbers at Stansted quoted work by Hart and McCann that showed that for each 1mppa increase in passenger numbers direct employment would grow by 309 FTEs and indirect by 37. This is over a 10-year period - i.e an average of about 35 per annum. Starting from a low base, as in the case of Southend Airport), a higher initial figure should be used as the growth curve is 'flattening', non-linear, one). A 'best guess figure would be about 500 per 1 mppa (direct + indirect, catalytic and induced). Again this is over a 10-year period to 2020 (under 1000 for 2mppa - by 2030) - an average of 50 new jobs per annum in say the first 10 years.

(Induced employment forecasts are assessed as unreliable by Prof Whitelegg.)

Clearly some increase in MRO employment is likely to derive from growth in aviation activity (especially if one or more fixed base operators are attracted to the airport), although growth might well be achieved without expansion of the airport's aviation operations. The absence, from the POR, of any forecast for MRO employment growth leaves us unable to comment further.

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

1 Introduction

Representation ID: 9242

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

5. 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."

Developments since the publication of the ATWP have altered the context from that in which it was written. Notably:

The publication in February 2005 of PPS1 with the effect that Local Planning Authorities must promulgate and apply policies which drive down the need to use energy and so reduce emissions (at para. 13) [page 287];

The Government's position as set out, for example, in the Planning and Climate Change Supplement of PPS1 :

"The Government believes that climate change is the greatest long-term challenge facing the world today. Addressing climate change is therefore the Government's principal concern for sustainable development."[page 383]
The Climate Change Bill, setting legally binding targets for carbon emissions reductions received the royal Assent in November 2008. Although aviation and shipping will initially only be monitored, if they fail to meet targets further action will ensue.

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 underlined 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"

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

Object

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS1 - General Policy

Representation ID: 9243

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

6. CONCLUSIONS

The POR contains little evidence to support potential demand for a 2000-fold increase in passenger numbers.

Conversely current trends, economic conditions and forecasts from the DfT point to decline rather than growth

There is no evidence in the report to underpin predictions for employment growth in the JAAP area. And, with the exception of the MRO business, which is directly related to the airport, no causal relationship is demonstrated between the new jobs predicted and increasing aviation activity at the airport.

In fact the report tends to point to the airport development being dependent on employment growth rather than the reverse.

The threatened loss of Green Belt land is wholly unacceptable - and is not (with a minor exception) likely to contribute to the proposed development of the airport.

Other potential environmental impacts - notably, at a local level; noise, light pollution, loss of agricultural land; and globally the contribution to climate change by CO2 and other greenhouse gas emissions from aircraft in flight - would also be adverse.

We believe that the preservation and enhancement of quality of life of its residents is the most important responsibility of local authorities. Were this proposal carried through, we submit, on the basis of the assessment above, that the negative impact on quality of life in the area and beyond would far outweigh any direct or indirect benefits that might accrue from the growth in aviation activity.

We ask the councils to withdraw the proposal.

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

6 Timetable - Your Views

Representation ID: 9244

Received: 08/04/2009

Respondent: CPREssex

Representation Summary:

NOTE: THE CONSULTATION and THE PREFERRED OPTIONS DOCUMENT


CPREssex responded to the Draft Master Plan (April 2005) consultation and the Issues and Options Report (June 2008) consultation.

The final version of the Master Plan (July 2005) contained a very brief section on the responses to the consultation. However it showed little or no sign of having acted on or even responded materially to any of our comments or objections.

In our response to the IOR, CPREssex rejected scenarios (options) 2(b) and 3. We gave clearly argued reasons. We also noted information gaps in the IOR and were critical of the IOR's poor linkages to the Draft Sustainability Appraisal and Evidence Base Report, which made it sometimes difficult to locate relevant underlying information.

We have reviewed, but not analysed in depth, the summarised responses to the IOR. Even so it is clear that there was an abundance of reasoned objection to the higher-growth scenarios and a clear preponderance of views against scenario 3 (involving the extension of the runway).

Yet the POR pursues this scenario. We noted that even GO-East made adverse criticisms.

The POR contains no specific reference to these responses. CPREssex had to ask where they could be located. It has no clear or specific links to the evidence base other than bland statements to the effect that it has been informed by these and by the views of respondents to the prior stages.

The maps were inadequate (there being no colour-key to the Areas for Change map and no current land-use map for comparison).

The content is almost entirely aspirational and without supporting evidence or data.

Overall we found the POR inadequate as a consultation document and one that raises concern as to whether the views of respondents are being given due weight in the process.

Full text:

SOUTHEND BOROUGH COUNCIL & ROCHFORD DISTRICT COUNCIL LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN DEVELOPMENT PLAN DOCUMENT: INITIAL CONSULTATION ON PREFERRED OPTIONS DOCUMENT

Dear Sirs
I enclose the response of the Campaign to Protect Rural Essex to this document. Please confirm receipt.
A hard copy will follow by post.
Thank you

Yours faithfully

John Drake (Director to the Executive Committee)



On behalf of CPREssex

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