London Southend Airport and Environs Joint Area Action Plan Submission Document

The statements made in Introduction, General Principles and Airport Policies undermine Policy LS1 because they are unsound.

1. False claims relating to employment creation.

In the way that the introduction in this section refers to employment creation it becomes clear that the entire policy of the two councils towards the airport is based on nothing more than wishful thinking. An incorrect assumption that the airport will attract wealth and investment, thereby creating jobs is repeated again and again until this falsehood becomes reality. This incorrect assumption has become a mantra for the councils and many councillors, repeated in an attempt to justify this unsustainable development. The JAAP and its assumptions stand in complete opposition to evidence based policy.

The reality is that the UK aviation tourism industry exports more wealth that it imports. In 2012 this was around £11.2 Billion, which is equivalent to the loss of around 500,000 jobs. By expanding aviation and offering new routes the two councils encourage ever larger numbers of people to travel abroad. Indeed in the first year of operation it is understood that the most popular destination has proven to be Amsterdam with many thousands of people choosing to travel to the Netherlands simply because the airport began to offer this route. Had the route not been offered facility the approximately 105,000 passengers would have spent that disposable income on other things.

For many years this group sought to encourage the two councils to adopt a genuinely sustainable economic model, which included the development of the huge potential for eco-tourism in and around the rivers Thames and Crouch (cycling, cycling off-road and on-road, wind surfing, sailing, kayaking, walking, etc) but instead of choosing an economic model that would keep UK wealth within the UK, the councils adopted a policy of exporting wealth and widening the UK's trade deficit.

Attempts are currently underway to establish the precise details on the numbers of flights taken from the airport in the first year of operation. This group is attempting to establish the number of passengers who have flown abroad, the number of internal flights/passengers and the number of foreign tourists who have used the airport to travel to the UK. We are also working to break this detail down to establish the number of passengers who have moved from using Stansted to using Southend Airport and also the number of passengers who have been tempted to fly abroad simply because the airport is sufficiently close.

Prior to expansion a number of councillors argued that expanded operations at the airport would bring thousands of tourists to the town, filling the local shops with new customers and creating hundreds possibly thousands of jobs. Great play was also made by the airport owners and the two councils that rushing through expansion would enable the airport owners to use the 2012 Olympics to "showcase" the airport.

In reality the truth was very different. Very few foreign tourists have been tempted to use the airport at Southend. It should be noted that Biggin Hill attracted more than 850 special Olympic charter flights, and Cambridge airport a similar number, but we have been unable to establish if the airport at Southend attracted any at all.

This group has asked that Southend Borough Council be required to undertake a post implementation review of the first year of operations at the airport to provide both councils with evidence upon which to base future decisions. We have sought the precise data because only when the two councils are forced to confront the scale of the failure of their projections and predictions will they have any chance of producing a JAAP or any other development policy that creates long term jobs in the area.

The public will have read different data and projections in the local media relating to the number of flights and passengers handled by the airport. At one time people were led to believe that the airport was on target to handle around 1 million passengers in the first 12 months of operation but the number may be a little lower than this. To provide a guide to the employment implications of this we offer a scenario of 100,000 internal passengers and 800,000 passengers who travel abroad. The average UK tourist spend abroad is believed to be £395, which means that those 800,000 passengers will have exported £316 million abroad. This equates to the loss of 12,640 jobs from the Essex and London economy - dwarfing the jobs that it is claimed have been created by airport expansion.

The very last thing that an economy should do when it is suffering the longest period of stagnation in decades, is to encourage its population to export wealth. Instead of encouraging people to holiday abroad, government should be looking at ways to encourage people to holiday within the UK, spending disposable here. The very last thing the two local councils should have done is to discourage people from spending disposable income on entertainment in Essex by encouraging people to travel and take wealth abroad. The scale of wealth exported in the first year may well be equivalent in magnitude to the loss of over 12,000 jobs.

2. Incorrect assumptions regarding noise from aircraft

It is noted that the document says "London Southend Airport must be able to accommodate new and future aircraft models that are quieter and more fuel efficient".

The Secretary of State must be informed of this, often repeated claim and asked to get at the facts. The two local councils should be required to face up to the reality of the situation.

The facts is that the description of the A319s currently operating from the airport as the most modern and fuel efficient is incorrect. These aircraft conform to chapter 3 of annex 16 to chapter 30 of the Chicago Convention. The specification for chapter 4 aircraft was agreed in 2006 and it is the policy agreed this year to "aggressively" replace chapter 3 aircraft with chapter 4 aircraft in order to meet commitments on reducing emissions. The replacement for the current A319 is the A319neo (new engine option). Both Boeing and Airbus offer conversions by re-engineering existing narrow bodied airliners to meet the new standard. The new engines provide greater fuel economy and therefore lower emissions of CO2; but are heavier, larger in diameter and produce less maximum power. This has the effect of increasing the take-off run meaning that the increase in runway length has been negated. It also increases the landing weight and approach speed putting more impact load on the run way.

The operating costs of the A319neo (156 seats) and the A320neo (180 seats) are virtually the same and orders for the A319neo are understood to have dried up. Fewer than 30 A319neos but more than 1,400 A320neos are currently on order. EasyJet has no A319neos on order, having converted their orders for A319s to A320neos. These aircraft are heavier and require a runway longer and stronger than that now at Southend Airport.

If EasyJet were to purchase the Bombardier C series of aircraft only the smaller capacity planes could be used - CE100 (125 seats) and CE300XT (145 seats). Of the aircraft currently or proposing to use Southend, the Fokker 100, Boeing 737-600 series and Boeing 717 are chapter 3 aircraft. The Emraer 195 is a chapter 3 aircraft and requires a runway of 2,179 metres at maximum takeoff weight. Only the turboprop aircraft operating from the airport, such as the ATR 52/72 of Aer Arran have chapter 4 compliance.

The implications of this are that easyJet and other airlines with larger aircraft will eventually stop using Southend airport. The fact that the JAAP makes no reference to this impending tension provides the very strong impression that the two councils have been blind to the various factors that suggest the long term future of the airport is bleak.

It is important to remember that the airport cannot be expanded further in the future. There is a railway and main road at one end and a 1,000 year old, Grade I listed, church at the other end, which the airport owner has guaranteed will never be moved or demolished.

Expanded operations at Southend Airport is what unsustainable development looks like. Expanded operations at Southend Airport is what policy failure looks like.


3. Environmental

Several references are made in this section to environmental considerations (e.g. "expansion is, however, only acceptable if it is undertaken subject to strict environmental controls").

This is grossly misleading to the point of being offensive. The scale of annoyance and distress being caused to the local population by noise from the airport is callous. Around 80% of the population under and close to the flight path, and close to the airport suffer unacceptable noise. Airport operations regularly disturb the sleep of local people and disrupt schools during normal work hours. There have been a constant stream of complaints about the complaints monitoring system used by the airport such that it has lost all credibility.

The reality is that only around 20% of the population close to airport operations do not feel their quality of life is being adversely impacted by expanded operations. Our opinion poll found that those people tended to be elderly but this was not exclusively the case.

Our challenge to the two councils is to arrange an independent opinion survey of those living around the airport and under the flight path. This will demonstrate that few members of the local population agree that "expansion (has)... been undertaken subject to strict environmental controls" and the vast majority of people vigorously object to night flights.

The JAAP document should be reworded to emphasise that the two councils have fought to secure the very weakest environmental controls and protection for the local population. The decision to permit any night flights is seen as a disgrace by the overwhelming majority of residents (but people do accept flights in an emergency). The decision to expand an airport so close to densely populated residential areas was callous in the extreme.

While the airport must be asked to provide an annual report to the council (page 32 para 20) it is vital that the two councils commission an annual report on the views of the local population living within 2 miles of the airport and the flight path (a genuine survey that gives people the chance to express all areas of concern).

Under general principles it is stated that "the much needed development must not be at the expense of a worsening of the environment and quality of life for those living in the area". In the light of the fact that expanded operations have broken this crucial requirement, a requirement that is so important to the local population and is set out so clearly in the JAAP, we demand that immediate steps be taken to reduce the scale of operations at the airport, beginning with a ban on all movements on the airfield prior to 8am and after 10pm.

Turning to the argument that increasing flights at Southend airport will save the local population from travelling to Stansted, and the suggestion in the JAAP that this will reduce the number of miles travelled by car there are two issues that ought to have been considered. The failure to comment upon these two issues suggests that the analysis in support of the JAAP is incomplete: 1. The proximity of Southend airport to the large urban population in south Essex is attracting some people to travel who would not otherwise have done so. Most of these people travel to and from the airport by car. Typically this is by the "kiss and fly" method that involves 4 car journeys. 2. Southend airport now offers more internal flights, demonstrating that far from supporting the use of public transport it is now going into competition with the railways. It must also be noted that the new railway station at the airport is poorly used, indicating that the very significant council taxpayer contribution to airport infrastructure has been squandered.

The two councils should commit to reporting annually on how airport passengers travel to and from airport and the impact the scale of road travel has upon congestion. The JAAP notes that the road network cannot cope with the projected 2 million passengers forecast so annual reporting will serve to provide better information to future administrations and provide a guide to a better informed decision making process.

4. Compensation under 1973 Land Act

On page 33 the JAAP makes reference to the impact of expanded operations on the value of property. The implication is not clear but it is noted that the airport has been in existence for 75 years. What was needed from the two councils was specific and clear guidance for the local population on the scale of noise insulation that could be obtained from the airport owners and the process for making claims under the 1973 Land Act to secure financial compensation for loss of value of property. The two councils have been consistently condemned by the local population for the lack of advice it has given to people. In the light of the substantial scale of financial losses both councils should undertake to explain to all people within 3 miles of the airport and the flight path what their rights are and the process for going about securing compensation. Leaving this task to the residents action group (SAEN) amounts to a gross dereliction of the duty of care the two councils ought to show to the population that has been hit so hard and cruelly. It is important to note that the scale of compensation owed to the local population might exceed £50million. The expansion of operations at the airport has not merely inflicted huge damage upon the quality of life of local people, it has also stripped £millions from the wealth of the community.

5. Annual Reports

Page 34 indicates the number of reports that the airport owner should produce. In the light of the scale of criticism of the complaints procedure, the councils should ensure that the scale of public dissatisfaction with airport operations should be identified by using an independent reputable opinion polling service. It is vital that the two councils commission an annual report on the views of the local population living within 2 miles of the airport and the flight path (a genuine survey that gives people the chance to express all areas of concern).

The airport owner should also report annually on the number of foreign visitors who travel to the UK, the number of UK residents who travel abroad and the number of passengers who fly to UK destinations that are served by a railway network.

Summary

Under "Airport Policies" on Page 35, it is noted that the JAAP supports in principle expansion to 2 million passengers. In the light of statements elsewhere in the JAAP, noting the importance that expansion must not be at the expense of the quality of life of residents, the JAAP should be amended to note that the two councils will work to reduce the scale of operations at the airport until those living close to the airport are satisfied that it no longer causes an unacceptable nuisance. This section of the JAAP should also note that if expanded operations cause a greater out-flow of tourist wealth than income, the two councils will work to reduce the scale of operations, shifting efforts to encouraging people to holiday at home - within the UK.

At page 35 the JAAP refers to the need for a sustainable operating strategy and includes reference to a "carbon and environmental management plan". It is important that the JAAP should acknowledge the scientific reality that aviation is not sustainable. Any suggestion that it is sustainable is irrational. Aviation could be sustainable if fuel were to be derived from non-fossil fuel resources and any greenhouse gases emitted were captured and sequestered. But fuel currently derived from sources such as algae are believed to be so prohibitively expensive that only the super rich could ever afford to fly.

The airport owners should be required to publish annually the total quantity of the various greenhouse gas emissions associated with the flights to and from the airport, and all emissions from the ground based operations.

The airport should also be required to publish an annual report and certificate on compliance with the handling of de-icing and other contaminants. This report should detail how contaminated water and other effluent are handled and detail any leaks into the surrounding water courses.

It is irrational and dangerous not to include these.

The councils should also require that the airport owners undertake to investigate all complaints relating to other contaminants that land on property and provide an annual report on the outcome of these investigations.

Page 35 notes that planning applications will be welcomed that contribute to modal shift. The JAAP should in fact set out what penalties it will put in place to deter the airport owners from offering flights to destinations that can be reached by rail.

Page 36 should be enhanced to show what steps the two councils will take to ensure that the thousands of householders who are entitled to compensation under the 1973 Land act are informed of their rights and what steps the two councils will take to help residents to make claims.

In view of the appalling policy failure, that expansion at Southend airport represents, the two councils must be required to accept responsibility for the serious financial harm they have inflicted upon the community and demonstrate what it will do to help people to secure compensation for loss of value of property.

This section should be enhanced to show that the airport owner will settle claims for financial compensation under the 1973 Land Act in a timely manner.

This policy statement shows that the two councils have no clear strategy for tackling the added congestion that expanded operations at the airport will cause. What is needed is a more vigorous, proactive strategy that provides for penalties as road traffic increase. The airport should be required to increase car parking charges, introduce drop off charges and offer rail discounts as a means of encouraging rail travel. These penalties and incentives should increase until the road traffic associated with increased operations at the airport have been brought down to capacity of the current road network.

Under no circumstances should the taxpayer be required to fund road widening or new road construction to facilitate a business that sucks so much money and employment out of the UK economy.

St Cedds church and the Blenheim school are in the public safety zone. A report published by the Aviation Environmental Federation in 2011 criticised Southend Council for failing to properly evaluate the increase of third party risk to residents within the PSZs. The CAA's survey revealed that the 28 hectares of land that includes St Cedds church and Blenheim school penetrate the obstacle plane. This could well lead to a revision to the airport licence removing the ILS capacity from runway 06 or requiring the runway to be reduced to its original length.

The scale of this risk to the continuing growth in passenger numbers that is supported by the two councils shows the grave shortcomings of the reports on which the planning consent for expansion was granted. The failure of the JAAP document to properly address these issues shows that the two councils are likely to repeat the errors made previously.

The JAAP should be amended to reflect the professional advice available in: 1. Airport Risk and the Public Interest: Draft National Planning Policy Framework Oct 2011 - Aviation Environment Federation. 2. PSZs: current policy and the case for change: Aviation Environment Federation and 3. The Sky's the Limit: Policies for sustainable aviation: The Institute of Public Policy Research (The IPPR considers that PSZs should be retitled Public Health and Safety Zones and calls on government to amend the flawed PSZ policy.

On page 38 the JAAP refers to the runway being 1,905 metres but the declared length is in fact 1,799. There are technical details relating to the construction of the runway base but the JAAP needs to be corrected. The JAAP ought also to make it clear that the runway is narrow, imposing crosswind restrictions on aircraft such as the Airbus A319. It is important that all understand the restrictions that exist upon operations at the airport.

The JAAP says that "the runway extension allows airlines to operate larger aircraft with increased passenger seating capacity." The reality is that the aircraft that will be permitted to operate from the airport in the future will carry far fewer passengers and therefore be less financially viable.

As we said above in connection with fuel efficiency:-

The fact is that the description of the A319s currently operating from the airport as the most modern and fuel efficient is incorrect. These aircraft conform to chapter 3 of annex 16 to chapter 30 of the Chicago Convention. The specification for chapter 4 aircraft was agreed in 2006 and it is the policy agreed this year to "aggressively" replace chapter 3 aircraft with chapter 4 aircraft in order to meet commitments on reducing emissions. The replacement for the current A319 is the A319neo (new engine option). Both Boeing and Airbus offer conversions by re-engineering existing narrow bodied airliners to meet the new standard. The new engines provide greater fuel economy and therefore lower emissions of CO2; but are heavier, larger in diameter and produce less maximum power. This has the effect of increasing the take-off run meaning that the increase in runway length has been negated. It also increases the landing weight and approach speed putting more impact load on the run way.

The operating costs of the A319neo (156 seats) and the A320neo (180 seats) are virtually the same and orders for the A319neo are understood to have dried up. Fewer than 30 A319neos but more than 1,400 A320neos are currently on order. EasyJet has no A319neos on order, having converted their orders for A319s to A320neos. These aircraft are heavier and require a runway longer and stronger than that now at Southend Airport.

If EasyJet were to purchase the Bombardier C series of aircraft only the smaller capacity planes could be used - CE100 (125 seats) and CE300XT (145 seats). Of the aircraft currently or proposing to use Southend, the Fokker 100, Boeing 737-600 series and Boeing 717 are chapter 3 aircraft. The Emraer 195 is a chapter 3 aircraft and requires a runway of 2,179 metres at maximum takeoff weight. Only the turboprop aircraft operating from the airport, such as the ATR 52/72 of Aer Arran have chapter 4 compliance.

In the light of the significant threat to health caused by poor air quality the JAAP should be strengthened to ensure that air quality is effectively and accurately measured in the roads leading to the airport (in Rochford District and the Borough of Southend). The JAAP should detail what steps will be taken to reduce traffic if air quality standards are not met.

Policy TF1 talks about the terminal expansion in the future tense, ignoring the fact that LSA are well on the way to completing it. Work was started on the second new terminal building without Planning Permission, demonstrating a lack of control by the local authorities. No action has been taken against the airport for this breach of planning law, demonstrating that LSA's assumption that they have the local authorities on their side was correct. The local authorities should pay greater attention to the need to properly and safely discharge sewage and other effluent. The current plans are woefully inadequate and may result in sewage backing up into the homes of local residents - a serious health threat.

Expanded operations at LSA will result in a substantial increase in greenhouse gas emissions that will contribute to an increase in extreme weather events and flooding. It is therefore irrational to build any new development in areas that are susceptible to a high risk of flooding. The two councils' policies are irrational and unsound in the extreme.