Sunmission from the Essex and Kent Fisheries
(names removed)
Environment Agency Permitting and Support Centre
Water Quality Team Quadrant 2
99 Parkway Avenue
Sheffield S9 4WF
5th June 2014
Dear Sir/Madam
,
RE Application EPR/HB3790ND/A001 Southend Airport
NGR discharge points: TQ 86238 89024, TQ 86863 89849, TQ 87504 89849 and TQ 87598 89254:
Receiving environment: Prittle Brook and Eastwood Brook leading to the River Roach: Effluent type:
Trade effluent consisting of deicer: Volume: Eastwood Brook Outlet 1: 360 cubic metres per day,
Eastwood Brook Outlet 2: 714 cubic metres per day, Prittle Brook Outlet 1: 1,845 cubic metres per
day, Prittle Brook Outlet 2: 2,354 cubic metres per day
I write to express serious concerns that this Authority has with regard to the above mentioned
application from London Southend Airport Co. Ltd. to discharge deicing chemicals in the form of
potassium acetate into the water courses known as Prittle Brook and Eastwood Brook which in turn
discharge into the receiving waters of the River Roach and Crouch
.
The importance and sensitivity of these waters is demonstrated by the following factors:
-
As you will be aware the Roach and Crouch support commercial fisheries for molluscan shellfish
including Native Oysters Ostrea edulis, Rock Oysters crassostrea gigas and clams. The estuaries
also support commercial and recreational fisheries for a range of fin fish species. The estuary also
supports an important diversity of marine species and habitat
.
As a result of its importance for birds, marine species and habitat the area is designated as a
European Marine Site Special Area of Conservation and last year was designated as a Marine
Conservation Zone.The ‘Upper Crouch, Upper Roach and Roach and Lower Crouch’ are designated as
‘Shellfish Waters’ under the Surface Waters(Shellfish) (Classification) Regulations 1997 which is now
transposed into the water Framwork Directive.The waters of the Roach and Crouch are designated as a
Bivalve Molluscan production Area under EC Regulations 854/2004
.
This Authority holds the ‘River Roach Oyster Fishery Order 2013’ which was granted by the Secretary
of State for the rearing and production of both Native Oysters and Rock Oysters. There are also a number of
privately owned shellfish beds within the Roach
.
The designation, last year, of the Blackwater, Crouch, Roach and Colne Marine Conservation Zone
specifically requires the recovery of Native Oyster populations and Native Oyster habitat with in this
area. The Kent & Essex IFCA is now working towards achieving this
.
The Kent & Essex IFCA’s serious concerns relate to the potential impact of increased pollution
resulting from the input of these deicing chemicals into the watercourse. Concerns have been
expressed in the past with regard to pressures upon these waters from effluent discharges which
impact upon natural marine populations and shellfish production within this area
.
It is considered that any increase in effluent or contaminant discharge into these waters would be
totally unacceptable and that serious efforts should be made to reduce or eliminate any existing discharges
This Authority would appreciate your very serious consideration of these concerns which it is felt should result in
your refusing this application