London Southend Airport and Environs Joint Area Action Plan Preferred Options

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.

Dear Sirs,

Essex wildlife Trust (the Trust) would like to take this opportunity to make the following comments on the London Southend airport and Environs Joint area action plan (JAAP).

The response, for ease of reading and clarity has been broken down into relevant sections and our comments on each made clear.

- The Future Development and role of London Southend Airport.
- Lengthening of the runway by a further 189 meters with the view to point number 2.
- Increased number of passenger movements through the airport through increased number of flights and larger aeroplanes (1 million passengers by 2012 and 2 million passengers by 2030)
- Employment area and associated infrastructure.

The Trust does not object to the extension of the runway (as discussed in the JAAP Preferred options document Section 3 issue 1), on the grounds of direct impact to biodiversity within the footprint of the development site but does object on the grounds of indirect impacts on biodiversity.

The Trust wishes to raise an objection and comment on concerns on the expansion of the airport through increased passenger capacity and the extension to the runway in relation to the long term effects increased numbers of commercial flights into Essex will have on increased carbon emissions and the sub sequential impacts through Climate Change on local, National and international biodiversity.

The government and local authorities have over recent years developed and released plans and policies for the future of sustainable development in this Country, how we can work towards reducing our CO2 emissions and subsequently reduce our impacts on Climate Change through a variety of reports, papers, guidance and bills.

It is important for the future of Essex to secure long term protection and enhancement of biodiversity through sustainable development implemented through robust policies and implementation of those policies.

The Trust does not believe that this JAAP preferred options adequately achieves and implements the policies that have been set out from national government through to the Local Development Framework for both Southend-on-sea Borough Council and Rochford District Council.

The expansion of Southend Airport is driven by the governments recommendation within the Air Transport White Paper (ATWP), the Trust is concerned with this decision and believes that further expansion of yet another airport within the county is fundamentally unsustainable and will result in a serious decline in quality of life for people and wildlife in the vicinity for many generations.

In making comments on the JAAP Preferred Options there has been several policy documents referred to, mainly pertaining to nature conservation, CO2 emissions and Climate Change.

The Trust objects to the expansion of the airport, it is of the opinion the preferred options through increased passenger numbers and larger planes is an unsustainable development. and objects to the indirect loss of features of biodiversity, which they believe conflicts with local, national and regional policies brought into effect with the principle aim of protecting and preserving biodiversity.

Aviation is the worlds fastest growing source of greenhouse gas emissions which are proven to negatively contribute to climate change, while they currently contribute to around 3.5% of global emissions this figure could rise to as high as 15% by 2050. Aviation is the most unsustainable form of transport. Global warming is already having and will, in an increasing way have a major and damaging impact on biodiversity in the south East both nationally and internationally.

It is stated in the JAAP document section 3 - Issues Preferred Options

'Lengthening the runway is not simply to allow larger aircrafts to use the runway. The modern generation of medium sized passenger aeroplanes that will be accommodated as a result of the runway extension are quieter and more fuel efficient, the end result is that the environmental impact of enabling the operation and efficient use of larger aircraft is lessened on the surrounding area'.

It is highly questionable that technological advances in jet engine efficiency will bring about a net reduction in greenhouse gas emissions to be in line with the current proposals released by the government under the climate change bill of a reduction in all greenhouse gasses by 60% by 2050.Or that noise pollution will be significantly abated, these future benefits are of course welcomed by the trust as a way of working toward reducing emissions from aviation but it seems clear that any benefits created through fuel efficient engines will simply be swamped by increases in aircraft use.

With increased rainfall, rising sea levels and slow geological land sink, it is clear that the south east of England will be severely affected by climate change and its associated environmental changes.

With increased flood risk there will be significant loss of important habitats and their biodiversity. Not to mention the increased risk of flooding to the population of Castle Point and Southend on sea which currently has a large percentage of its population living below sea level and reliant entirely on hard sea defences for their safety.

The Royal Commission on Environmental Pollution in its report The environmental effects of Civil Aircraft in Flight (2002) concludes that if unchecked, air travel will become one of the major sources of anthropogenic climate change by 2050 but they fear the government shows little sign of recognising this.

The Trust therefore wishes to raise an objection to the flight and passenger intensification at Southend airport.

The reason, are due to the adverse ecological impacts arising from global warming, directly attributed to air pollution through increased greenhouse gas emissions, the increase in frequency and size of aircrafts using Southend Airport will exacerbate the negative impact on biodiversity arising from increased greenhouse gasses and the breach of several international, national and local planning policies.

National Policies
It is the opinion of the Trust that indirect loss of biodiversity interest through climate
change, accelerated by anthropogenic factors through the release of greenhouse gasses
into the atmosphere of which increased aviation is a major contributing factor, conflicts
with statutory provisions and government advice brought into effect with the principle aim of protecting and preserving biodiversity and also, national and regional planning policies in
reference to achieving sustainable development.

These issues are considered in more detail as follows:

PPS 1 & 9
Sustainable development of planning is the core principle of PPS1. A widely used
definition for sustainable development is:

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." (Ref: World
Commission on Environment and Development in 1987).

Sustainable development must not result in a net loss of biodiversity, but should conserve and ideally enhance it. The Trust is concerned that the Southend airport expansion proposal is going to result in a loss of biodiversity this means that the development proposed is not a sustainable development and ought to be refused in line with the guidance provided by paragraph 1(vi) of PPS9.

'The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of any such alternatives, local planning authorities should ensure that, before planning permission is granted, adequate mitigation measures are put in place. Where a planning decision would result in significant harm to biodiversity and geological interests which cannot be prevented or adequately mitigated against, appropriate compensation measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused'.

Natural Environment and Rural Communities Act 2006 - makes it clear that local planning authorities must place biodiversity very high on the agenda when it says (at section 40 (1): "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity."

By the nature of the project it's very difficult to imagine a more harmful affect on the global environment. Far from conserving biodiversity, the expansion of Southend airport will do the opposite, as it will result in the loss of biodiversity in the UK.

Regional Policies -

East of England Plan - The revision to the Regional spatial strategy for the East of England.

Planning and Compulsory purchase Act 2004 supported by the Regional Spatial Strategy (RSS) and the East of England Plan (EEP) The revision to the Regional spatial strategy for the East of England (May 2008) sets out the aims of the government on how as a region we can contribute to sustainable development.

The current RSS runs from now until 2021 but sets out visions for the longer term, with specific reference on reducing the regions impact on and exposure to climate change.

One of the key drivers of the policy 'reconciling growth with protection of the Environment' (EEP section 1- Introduction). This is further strengthened by the objectives set out in section 2 of the EEP document stating the region will achieve its sustainable development aims by 'improving and conserving the regions environment by:

• Ensuring the protection and enhancement of the regions environmental assets, including the built and historic environment, landscape and water.
• Protecting and where appropriate, enhancing biodiversity through the protection of habitats and species and creating new habitats through development.

It is the view of the Trust that by increasing passenger and flight numbers through the airport Southend-on-sea Borough Council and Rochford District Council are directly contradicting the aims set out in the above policies.

The EEP goes then further to describe to the local authorities what is expected of their policy documents when approaching the issue of carbon emissions and biodiversity stating:

Local development documents and other strategies relevant to spatial planning within the region should:
a) help meet obligations on carbon emissions; and
b) adopt a precautionary approach to climate change by avoiding or minimising potential contributions to adverse change and incorporating measures which adapt as far as possible to unavoidable change.

In particular, the spatial strategy seeks to ensure that development;
- respects environmental limits by seeking net environmental gains wherever possible, or at least avoiding harm, or minimising, mitigating and/or compensating for that harm.

Climate change is almost certainly the most significant challenge facing nature conservation today, with the potential to have significant impacts on the future of UK and global biodiversity.

The Trust believes that climate change is a major obstacle to the achievement of an environmentally sustainable future and that the policies highlighted by the government as being crucial to the achievement of sustainable development are not being implemented at a local level in Southend and Rochford.

EEP - Section 8 - Environment

Policy ENV1 areas and networks of green infra structure (Definition of green infrastructure EEP pg 51 = networks of protected sites, nature reserves, green spaces, waterways and green linkages) should be identified, created, protected, enhanced and managed to ensure an improved and healthy environment is available for present and future communities.

Essex is an exceptional county which is under ever increasing development pressure to expand existing airports, ports, transport links and housing.

For these developments to be genuinely sustainable, they cannot go ahead at the expense of wildlife.

We would like to see a mitigation strategy to include the need for large areas of linked land in the form of green corridors and green grids throughout Southend and Rochford. This provision will be imperative in the future to ease the pressures on biodiversity due to climate change.

The pressures of climate change on biodiversity will be great, and it is important to allow sufficient space for habitat shift and expansion. It is imperative that there is no nett loss of biodiversity.

EEP - section 9 Carbon Dioxide emissions and renewable energy.

As a signatory to the climate change convention the UK Government have an obligation to actively achieve the commitments it has signed up to under the Kyoto protocol to reduce its greenhouse gas emissions by 12.5% below those of the 1990 levels by 2012, this further strengthened by the 2007 Climate Change Bill which aims to reduce greenhouse gas emissions to at least 60% by 2050.

It is the view of the Trust that in allowing the expansion and development of Southend Airport will add to the levels of greenhouse gasses including Carbon Dioxide emissions which directly contradicts the policies outlined by government in the Climate Change Bill.
The Trust believes

"We should hand on the next generation an environment no less rich than the one we ourselves inherited".

It is the Trust's view that this is an unsustainable development that will result in serious adverse impacts on nature conservation on a global scale.

Local Area Agreement - LAA2

The local area agreement 2 is a commitment made between the government and the Essex partnership of public, private and third sector organisations to serve the overarching vision of the Essex Strategy. The agreement includes targets important to Our People: Our communities: Our World.

The target Our world seeks to promote sustainability and protect the counties physical environment. Some of the key issues in achieving this are 1. Climate Change 2. Environmental Protection 3. Energy Generation.
Included in this are priorities 9 - A smaller carbon footprint with less waste. And 10 A well managed environment.

Local Policies

Southend-on-sea Local Development Framework Core Strategy

Strategic objective SO15 states:

'Secure the application of sustainable construction and operation in all development, in particular through prudent use of natural resources, energy efficiency and the maximum use of renewable and recycled resources, in order to prevent or minimise local contributions to climate change and its associated risks and the depletion of non- renewable resources'.

Although the Trust approves of the is policy to reduce the risk of climate change as it shows that the local authority is aware if the implications of unsustainable development will have on a local, national and global scale, if the increased number of flights and passenger numbers where to go ahead it is hard to see how any future efforts of the Rochford District to minimise their input on climate change through reuse or resources and recycling will go anyway to counteract the greenhouse gas emissions that the airport will be creating, causing this policy to be pointless from the outset.

SO16 then goes on to state:

'Protect, conserve and enhance the towns historic and natural environment and assets, including both its biodiversity resources, species and habitats and its heritage conservation resources'.

Again the Trust is unclear how increasing the number of passenger numbers to two million and all the associated greenhouse gas emissions to achieve this is going any way to achieving an enhanced natural environment for species and habitats.

Rochford District Council Core Strategy

States that Rochford District Council

'will endeavour to ensure that the districts landscape, historical character, agricultural land, wildlife habitats, undeveloped coast and other natural resources are not adversely affected, where measures are unavoidable we will ensure that measures are in place to mitigate any negative effects.

Sustainable development requires effective protection of the environment and careful use of natural resources. It involves accommodating necessary change while maintaining and where possible enhancing the quality of the environment for visitors and local residents'.

The Trust finds it difficult to believe that increasing the number of flights, larger planes and increased visitor numbers and the associated necessary infrastructure is maintaining and certainly not enhancing the quality of the local environment for people and wildlife.

The LDF then goes on to state:

'We are committed to the protection, promotion and enhancement of biodiversity throughout the district. Biodiversity is the variety of living species on earth, including well known trees and animals and lesser known insects and plants and the habitats they occupy. It is an essential component of sustainable development'.

The Trust does not believe that the expansion of the airport and the associated infrastructure is by any means a sustainable development and therefore the local authority is in direct breach of its own local development framework policy.

Section 4 - Policies

Employment Allocations
Policy E3 - Saxon business park should be rewritten to say:

All phases of development will be required to make a contribution towards the development of a new public open space to the north and east of the of the business park as shown on the proposals map. it is also expected that a defined contribution will be required to fund improvements to walking, cycling and long term management for wildlife within the JAAP area'.

Issue 2& 3 - The future of the JAAP as an employment area & Balancing development with environmental enhancement.

Essex Wildlife Trust has no comments on issues 2
Issue 3 - it is stated in issue 3 that:
'More activity from the airport and the allocation of a new business park will inevitably result in environmental impacts that must be managed'

Essex wildlife trust welcomes these views but would like the following wording adding to the environment policies and thinking on page 26

'the long term management funding of the open space areas will be provided from the development of the business park'.

Also the following working should be added to the environment introduction on page 25.

'The new business park and expansion of the MRO offer at the airport have been related to the development of new public open space, to provide a green lung and wildlife corridor for the area to allow for shifts in habitat requirements and species related to impacts due to climate change, for the area offer opportunities for leisure, recreation and wildlife and to link to cherry orchard jubilee country park'.

All new development must deliver high levels of environmental efficiency and to incorporate energy saving technology, sustainable drainage systems, designed to increase and enhance the area for wildlife and to meet the requirements set out in the core strategy for both local authorities'.

Policy ENV1 - Revised greenbelt boundary

The Trust does not agree with the revision of the greenbelt policy and objects to this in the JAAP.

This continuing 'moving of the goal posts' is unacceptable and unsustainable the recently released document local planning authority green belt statistics: England 2008/2009 states that there are 5 purposes of including land in greenbelts these are:

• Check the unrestricted sprawl of large build up areas
• To prevent neighbouring towns from merging into one another
• To assist in safe guarding the countryside from encroachment
• To preserve the setting and special character of historic towns
• Assist in urban regeneration by encouraging the recycling of derelict and other urban land.

It then goes on to state:
Once greenbelts have been identified the use of land in them has a positive role to play in fulfilling the following objectives.
• To provide opportunities for access to the open countryside for the urban population
• To provide opportunities for outdoor sport and outdoor recreation near urban areas
• To retain attractive landscapes and enhance landscapes near to where people live
• To improve damaged and derelict land around towns
• To secure nature conservation interest
• To retain land in agricultural, forestry and related uses.

It is the view of the trust that in redefining and reallocating areas of land for use as greenbelt land is contradicting the above green belt policy.
As a minimum the JAAP should ensure that if in re-designating areas of green belt land there is no nett loss of area and should go one step further and include a policy in the JAAP to increase and enhance the area of designated green belt to secure nature conservation interests for the future and in doing so help to mitigate against the environmental impacts created through increased flights and passenger numbers on CO2 emissions and climate change.

In summary The Trust objects to the increase in passenger numbers and increase in flight frequency and the subsequent increase in greenhouse gas emissions and the effects on biodiversity globally.

The Trust objects to the breach of several international, national, regional and local policies on greenhouse gas emissions and planning policy.

The Trust objects to the revised greenhouse policy and the re-allocation of the greenbelt surrounding the airport.

The trust would like to comment on several policies within the JAAP document to bring biodiversity to the forefront of the policy decision making process.

It is imperative that both Southend and Rochford local authorities re-assess there plans for the expansion of Southend airport in the view that it is a direct contradiction to several existing policies and goes against good sound scientific knowledge on the impacts of increased unsustainable air transport has on biodiversity on a global scale.

Please keep us informed of any developments in the expansion of Southend airport and its policies.