London Southend Airport and Environs Joint Area Action Plan Submission Document
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London Southend Airport and Environs Joint Area Action Plan Submission Document
1. Introduction
Representation ID: 29167
Received: 16/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The JAAP is fundamentally flawed, irrational, many of the objectives are undeliverable and it contradicts three of the four key objectives in the Government's Aviation Policy Framework.
The JAAP consultation process has been flawed from the start and it has been clear that the councils had made their minds up before seeking the views of the public.
This plan will result in massive increases in greenhouse gas emissions, a deterioration in health of the local population caused by additional noise and it permits LSA to continue to ignore the views of local people.
The JAAP is fundamentally flawed, irrational, many of the objectives are undeliverable and it contradicts three of the four key objectives in the Government's Aviation Policy Framework.
Before going into detail on these points, it is important to stress that the local community is appalled that the original JAAP process and consultation was ignored, it was suspended when London Southend Airport (LSA) submitted its planning application and has only now been resurrected after the Airport has extended the runway, facilitating a massive expansion in operations.
The original JAAP process showed that the majority of people opposed the scale of expansion that had been proposed by the Councils and their views were completely ignored. More recently, this group conducted its own public opinion poll and found that 61% of people still oppose expansion of the airport.
Turning to the Aviation Policy Framework, it is irrational to the point of being perverse to suggest that the JAAP will make its contribution to ensuring that the aviation sector makes a contribution to reducing global greenhouse gas emissions. It is impossible to expand operations at Southend Airport to the extent planned and reduce greenhouse gas emissions. It is fantasy to assume otherwise.
Southend Airport is surrounded on all sides by large numbers of houses, indeed it has more housing in its immediate vicinity than any other regional airport in the UK. It is therefore grossly misleading for the JAAP document to suggest that the local councils have done anything to limit or reduce the number of people who suffer from aircraft noise. The councils have failed in their duty of care to the local population by doing everything in their power to increase flights and therefore noise. The disgraceful decision to allow night flights poses a serious threat to the health of the people who now have to suffer absolute misery caused by this irresponsible and callous development.
The airport is responsible for its own Airport Consultation Committee and selects the members itself. This results in an entirely toothless organisation that does not represent the views of the local population. Indeed, the residents action committee - SAEN - has been refused membership of this committee. It is therefore impossible to suggest that LSA engages in a meaningful way with its local stakeholders.
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London Southend Airport and Environs Joint Area Action Plan Submission Document
2. Vision and Objectives
Representation ID: 29168
Received: 16/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
* Quality of life cannot be improved by subjecting people to more noise and pollution.
* Job creation claims are misleading because many jobs are simply being moved from another business park a few miles down the road
* Few employers likely to relocate next to an airport
* Airport takes substantial money and jobs out of the local economy both directly and through loss of property value
The vision is patently irrational. You cannot increase the quality of life for residents and workers by subjecting them to increased aviation noise, pollution and the utter misery of night flights. Other than by the poorly-used railway station, the airport is reachable only via residential roads. The local road network is not able to cope with the proposed volume of traffic and this will have a negative impact on the local area.
It is important to note that the Saxon Business Park is in fact largely going to be filled with existing businesses relocated from Eldon Way in Hockley, which is proposed for demolition by the Hockley Area Action Plan. It is therefore dishonest to suggest to the Secretary of State that the Saxon Business Park is bringing exclusively new jobs to the area.
It must also be noted that it is overly optimistic to suggest that large numbers of employers will relocate next to an airport that will impose noise disruption, danger and an increasingly congested road network. If anything, there is a danger that many employers, like the local population, would prefer to move away.
Expanded operations at the airport have now been in place for just over one year and it is now clear that the overwhelming majority of passengers are UK citizens who are travelling abroad. Precise information is not yet available on the number of foreign tourists attracted to LSA, but we will work to secure this information before the examination.
However, to provide an interim guide, if approximately 800,000 UK passengers have flown abroad, that is equivalent to a trade loss of £316 million which equates to 12,640 jobs lost from the Essex and London economy. (Based upon UK average of £395 spent abroad per passenger.)
The JAAP is grossly misleading in failing to make any reference to the huge scale of loss of revenue to this area.
Another area that has been overlooked is the massive loss of wealth to the area caused by devaluation of property under and near the flight path.
Again, information is not yet finalised but reports from surveyors specialising in compensation suggest that some homes will have been devalued by up to 15%, many hundreds, possibly thousands by between 5 and 10%. If it is indeed true that 4500 homes have lost what is claimed, then the local economy may have been deprived of over £50m.
We really must challenge the statement "and with only a fraction of the residential noise impacts of other airports". The number of complaints from people concerning noise belies this statement. Furthermore, the area is already subject to low level flights both visible and audible en route to London City Airport, which has been added to by those to LSA.
We must also challenge the statement that "The runway extension is a key factor in the ability of the airport to accommodate the latest advances in medium sized passenger aeroplanes (100 to 150 seats), which are quieter and more fuel efficient than their predecessors, and can take-off in shorter distances and depart more quickly from local airspace." This is not correct; even extended to 1799m, the runway remains short. Future fuel efficient airliners require longer runways.
Finally, the suggestion that a new link road has been built to facilitate access to the airport needs to be challenged. At the Public Inquiry into the stopping up of a section of Eastwoodbury Lane and Footpath 121, it was categorically denied by LSA that this route would be used to access the airport. It was claimed that traffic would be directed via Manners Way, an existing residential street.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
3. Development Proposals for the JAAP
Representation ID: 29169
Received: 16/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Claims made in this section are inaccurate, wilfully misleading and the policies outlined pose a serious threat to public health, the environment and will also suck millions of pounds of wealth out of the area. Thus far, the airport has only handled around 800,000 passengers per annum, but this is equivalent to a loss of £316 million (which equates to 12,640 jobs) lost from the Essex and London economy.
Section 3.1 repeats the assertion that the extended runway will allow for the use of modern, quieter medium-sized aeroplanes, whereas in fact the most fuel efficient airliners require a longer and wider runway than that which now exists at LSA.
Expanded operations at the airport have now been in place for just over one year and it is now clear that the overwhelming majority of passengers are UK citizens who are travelling abroad. Precise information is not yet available on the number of foreign tourists attracted to LSA, but we will work to secure this information before the examination.
However, to provide an interim guide, if approximately 800,000 UK passengers have flown abroad, that is equivalent to a trade loss of £316 million which equates to 12,640 jobs lost from the Essex and London economy. (Based upon UK average of £395 spent abroad per passenger.)
The JAAP is grossly misleading in failing to make any reference to the huge scale of loss of revenue to this area.
Another area that has been overlooked is the massive loss of wealth to the area caused by devaluation of property under and near the flight path.
Again, information is not yet finalised but reports from surveyors specialising in compensation suggest that some homes will have been devalued by up to 15%, many hundreds, possibly thousands by between 5 and 10%. If it is indeed true that 4500 homes have lost what is claimed, then the local economy may have been deprived of over £50m.
The claim that 6200 additional jobs will be created at the industrial estates needs to challenged. Firstly, this assumes that all spaces created within the business parks will be used. Given the current economic climate and the amount of vacant office space around Southend, this appears to be unlikely. Also, as previously mentioned, the local authorities' intention is to fill at least some of the space with businesses relocated from other sites in the area (Eldon Way to be demolished). Therefore, these would not be *additional* jobs.
Section 3.3 on "Balancing development with environmental enhancement" - it must be noted that local residents have reported adverse health impacts as a result of increased operations. For example, children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead, directing jet exhaust into the park.
It must be noted that unlike its competitors, LSA has no pipeline to supply its fuel, which is brought to the site by road tanker. This suggests that increased storage capacity is needed for jet fuel which poses a further threat to the local area.
Pollution such as VOCs (volatile organic compounds), carbon monoxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, unburned hydrocarbons and soot are all produced by aircraft engines. There are no catalytic converters on aircraft engines! Also, the smoke produced by aircraft tyres on touchdown contain particles of rubber containing toxic heavy metals. With housing closer to the airport than at any other UK airport, this cavalier disregard for the health of residents demonstrates how irresponsible the local authorities have been.
At section 3.4, the JAAP clearly advocates an increase in capacity on the highway network in order to facilitate additional traffic to the airport. This is in contravention of Government policy on climate change by increasing pollution from cars. It is also self-contradictory as point vi. advocates greater use of sustainable transport in order to reduce car traffic.
It is now becoming abundantly clear that far from encouraging greater rail travel as LSA at one time claimed, it is actually going into competition with the rail network by providing flights to destinations such as Newquay and Edinburgh.
We object to any proposal to build on agricultural land, which is needed to protect the country's food security.
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London Southend Airport and Environs Joint Area Action Plan Submission Document
4. Policies
Representation ID: 29170
Received: 16/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
This is a vanity project which history will show will do immense damage to the local economy, the quality of life of residents and seriously damage the environment.
This is a vanity project which history will show will do immense damage to the local economy, the quality of life of residents and seriously damage the environment.
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London Southend Airport and Environs Joint Area Action Plan Submission Document
5. Implementation and Delivery Plan
Representation ID: 29171
Received: 16/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
CAA guidelines are being breached on airport safety, posing an unwarranted threat to aircraft passengers and the population of the area.
The Local Authorities appear to be oblivious to this threat and are not even using up-to-date maps in section 5 of the JAAP.
Figures 5.2, 5.3 and 5.4 show the runway and Public Safety Zones (PSZs) prior to the expansion of the runway. They are therefore inaccurate and do not reflect the current situation.
Figure 5.2 is of particular concern as the orange hatched area indicating the location of the Nestuda Way Business Park will be within the current PSZ. National Planning Policy dictates that no new build should take place within the PSZ and over time, the area should be cleared of occupation.
CAA guidelines relating to dangerous obstructions within the PSZ are already being ignored and no further new obstructions in the form of a business park should be constructed. We want the CAA to bring an end to the use of the extended runway to prevent continued breach of their guidelines.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Policy E1 - General Development Considerations
Representation ID: 32011
Received: 19/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The plan is unsound because there is no credible explanation as to how the number of jobs predicted will be created as a result of increasing the number of passengers at LSA to 2million.
In fact, this plan entails moving jobs from former industrial estates to new ones.
The JAAP offers no explanation as to how achieving 2 millions passengers per annum at the airport would lead to the scale of employment in the proposed Saxon Business Park. Ryanair only employs 106 people per 1 million passengers so there is little prospect of the scale of new employment directly associated with increased aviation. The current scale of empty units within the Aviation way and other local industrial estates shows that demand remains weak and, assuming UK recovery is slow and weak, employers are more likely to seek cheaper premises than the new business parks proposed in the JAAP.
As mentioned previously, it is anticipated that the Eldon Way business park in Hockley is to be closed, relocating the businesses to the Saxon Business Park. Likewise, it must also be noted that the relocation of IPECO to the Saxon Business Park only moves jobs, this does not create new jobs.
The lack of precise explanation as to how the councils believe the thousands of new jobs are to be created shows that the JAAP is based upon mere wishful thinking that a vanity, unsustainable, carbon intensive, aviation project will somehow magic jobs out of thin air. The plan is unsound.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Policy E1 - General Development Considerations
Representation ID: 32012
Received: 19/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The policy relating to development in the PSZ is unsound because it contradicts Government policy. It is also vital that the document acknowledges that aviation is inherently unsustainable.
The policy contradicts SBC's Nottingham Declaration.
It is clear from figures 5.2 to 5.4 in the JAAP that the Councils are using the PSZ from the unextended runway. The runway extension will have moved the PSZ to the south west and this could prevent the proposed development of a business park at the junction of Prince Avenue and Nestuda Way.
It must also be noted that aviation is fundamentally unsustainable. It is highly likley that the finite supply of oil based aviation fuel, the substantial cost of synthetic replacements and the rapid pace of climate disruption (including flooding that will damage industrial units built on flood plains) will almost certainly result in a new national approach to polluting industries including aviation, necessitating the introduction of measures that reduce this activity. The consistent failure of the two councils to demonstrate any forward planning on the implications of climate mitigation shows exceptionally poor judgment on the part of the two councils.
Indeed the approach for Southend BC to the issue of climate change is contradictory. It has signed the Nottingham Declaration, commiting the council to reduce carbon emissions but, in fact, it plans an unprecedented increase in greenhouse gas emissions by encouraging and funding expansion at the airport.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Policy E2 - Aviation Way Industrial Estate
Representation ID: 32014
Received: 19/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
We explain why the thinking on job creation is flawed and point out that expanding aviation and greenhouse gas emissions dramatically increases the chances of flooding business and other property. Therefore, the plan is unsound.
The shortage of affordable industrial premises is the principle brake on the development of new employment opportunities. The owners of brand new buildings on industrial estates typically seek higher rents than other older areas so, given the tough economic climate, it is simply wishful thinking for the two councils to make the overly optimistic employment projections that they do. What is needed is for the two local authorities to concentrate their efforts on addressing the key issue of rent, rather than the vanity, unsustainable Southend Airport project upon which it continues to squander £millions of public money.
The JAAP seeks to increase greenhouse gas emissions thereby increasing the liklihood of extreme weather events that will increase flooding of property on flood plains. The thinking of the two councils is so seriously flawed and counter-productive that it poses unacceptable risks to local business and the population at large.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Policy E3 - Saxon Business Park
Representation ID: 32015
Received: 19/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
We challenge the assumptions made in connection with Bournemouth Airport and how these translate to the creation of jobs.
I must challenge the statement that "our analysis shows that growth in business numbers at Bournemouth Airport was 25%" and the conclusions that are drawn from this.
The increase in employment in areas adjacent to airports owes more to the reduction in property prices and consequent lowering of rents for industrial prtemises than to any perceived benefits asociated with the proximity to an airport. It is interesting that the JAAP uses Bournemouth Airport as an exemplar instead of Southampton. The movement of airlines and the associated jobs between these two locations in the past provides a salutary lesson to the local councils on the short term nature of such employment. Bournemouth Airport has a runway that is 2,271 metres long and it is likely that airlines (except those operating smaller aircraft on short routes) will again move from Southampton airport with its shorter runway, to Bournemouth to meet new Chapter 4 requirements. Passenger numbers peaked in 2007 (1,079,000) but have declined steadily to 613,000 in 2011.
Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Policy E8 - Nestuda Way Business Park
Representation ID: 32016
Received: 19/03/2013
Respondent: South East Essex Friends of the Earth
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
As has been said previously, a change in the position of the PSZ could prevent use of at least part of the proposed Nestuda Way Business Area.
As has been said previously, a change in the position of the PSZ could prevent use of at least part of the proposed Nestuda Way Business Area.