Full text:
With Reference to Project 3 - Risks and Impacts
Since the lengthening of the runaway and the associated ineffective drainage schemes which were applied, the grounds of Rochford Hundred Golf Club have suffered an unprecedented number of ground water floods, in turn causing serious business interruption, loss of income, and restoration expense. It is very evident that the additional drainage systems installed on the airfield are not adequate to contain sufficient volumes of storm water.
The Northside MRO extension is planned to be erected directly within a Level 3 Floodrisk area, and it is our view that this will inevitably lead to a worsening of the already intolerable level of ground water that is deposited onto the golf course floodplain directly from the airfield. In fact Page 46 of the Atkins report to which you refer - the "Flood Risk Constraints Report" (Dec 2009) - sets out that such wide scale mixed a development would inevitably increase the surface water runoff into neighbouring streams and ditches, and that a common way of dealing with this is 'SUDS'.
To mitigate the risk, as detailed on Page 72 of the JAAP, the Airport propose to 'engage early with the Environment Agency to ensure appropriate flood management'. Part of this process may be subject to 'sequential testing prior to the application'. However, you are already in possession of the Atkins Report, which on Page 47 concludes:
"The existing Greenfield nature of much of the JAAP area means that the requirement to mitigate surface water runoff to existing rates is likely to need a large amount of attenuation and/or storage features, with significant implications on land take. SUDS techniques offer an attractive method of controlling runoff in this manner, but it is noted that the current proposal to provide airport-related and mixed-use development alongside the watercourses leaves little room for SUDS and may mean that required runoff rates are unachievable given the current layout".
It is our view that the Mitigation comments as shown on Page 72 of the JAAP are misleading, and could be interpreted as being disingenuous, bearing in mind that 3 years have elapsed since the Atkins Report, relative failure of SUDS and other litigants to date. The mitigation comments are not in our view a true reflection of the Atkins findings, and as such the presentation of the JAAP is not sound.
We further submit that it is not sound to exclude from any such testing, statistics, and impacts, the surrounding downstream floodplain areas. The assessment of the current floodrisk and its impacts should be very clearly assessed and catalogued throughout the surrounding area thus ensuring that if the MRO plans proceeds to be built a clear benchmark of pre-works water levels has been established.
Should the 'surface water compensatory floodplain storage' fail to ensure no increase in flood risk from the development to its neighbouring areas, including land owned by Rochford Hundred Golf Club, the Directors of Rochford Hundred Golf Club, and other affected neighbouring land owners, will have clear evidence on which to seek recompense in law.
We believe the risks of additional runoff to date (as set out clearly by qualified specialists in the above report) have not been effectively mitigated, and that with the further significant planned development under the JAAP there will be additional frequency and severity of flooding to neighbouring areas. This is contrary to PPA25 and hence means that the JAAP proposals are not sound.
With Reference to Aircraft Testing and the Control and Limitation of Noise
We note from Page 43 of the JAAP various limitations being placed on the landing of excessively noisy aircraft (QC2 - QC4). However the rationale for the runaway extension, as depicted on Page 16 makes great store that the 150-seater A319's are quieter and more CO2 efficient. The document is not sound because there is no correlation between the implied excessive noise interference to the neighbourhood of an aircraft taking off, to that of 'endless' full thrust engine testing.
Whilst the DB levels at take off constitute a short period of noise interference to us as immediate boundary sharing neighbours, even at the QC1 rating of the A319, the prolonged full thrust testing of up to QC4 (the equivalent of a 747 Jumbo Jet departing!) would be utterly intolerable.
Page 44 describes that 'appropriate' arrangements have been made to deal with ground noise, however the only specific is the inclusion of 7-days per week time 'restrictions'. We submit that these are not, in any form 'appropriate', 'reasonable' or sound. It is, and would be the common public consensus, that testing hours, if necessary at all, should be limited to Monday - Friday 9.00am to 5.00pm - the standard hours of work for local residents. It is in our view that Saturday and Sunday testing hours would be wholly inappropriate, ill considered, deeply disturbing, and highly offensive to neighbours.
The JAAP document fails entirely to expand on any other schemes to alleviate ground noise. It is our view that the installation of jet engine testing noise baffles should be an obligatory measure. The current process of allowing jet blast, tail stream, and noise to be project, unabated, across open land is unacceptable.
A further obligatory measure should be the statutory regulation of aircraft direction when engines are being tested (which way it is the aircraft pointing). These regulations should be published and placed into the public domain. Given statutory regulation, noise abatement provisions can be better contemplated.
