Thames Estuary Airport Objections – from Kent County Council

Report 6 Appendix A

1. Ecological objections

Significant negative impact on the Thames Estuary Special Protection Areas

The Thames Estuary has significant areas of internationally protected wildlife habitats - Special Protection Areas (SPA) – which see some 300,000 migrant birds on an annual basis. As Natura 2000 sites, SPAs are afforded the highest level of legal protection. Under the EU Habitats and Species Directive (92/43/EEC), all Member States have a duty to protect Natura 2000 sites from deterioration of their natural habitats and the habitats of their component species. This is applied in England through the Conservation (Natural Habitats etc.) regulations 1994, as amended.

An airport situated in the Thames Estuary would damage (and potentially destroy) significant areas of the SPA and it is therefore difficult to see how the proposed airport will be able to show that, beyond reasonable scientific doubt, it would not negatively impact the SPA. In order for the project to go ahead, it will need to demonstrate “imperative reasons of overriding public interest” and show no alternative exists. Even if these tests could be satisfied, large scale compensation, through recreation of damaged or lost habitat, will be required to address the effects on the Greater Thames Estuary SPAs – it is considered that adequate compensation could not be found within the area (or potentially elsewhere).

Significant negative impact on the Outer Thames Estuary Proposed Special Protection Area

The Outer Thames Estuary Proposed Special Protection Area (pSPA) has been identified as the wintering area for 38% of the UK red-throated diver population (Listed on Annex 1 of the EC Birds Directive). As above, it is considered that an airport situated in the estuary would have a significant negative impact on areas of this pSPA. In addition to direct disturbance of the birds, for which the area is proposed, their primary prey species (sprat and herring) are also likely to be negatively affected. Sprat and herring are particularly sensitive to noise and vibration, and construction and operational activities have the potential to negatively affect the submerged sand banks where this species live. pSPA are afforded the same level of protection as designated SPAs and the same requirements, and concerns over meeting these requirements, outlined above would apply to this proposed site.

Management of bird strike risk and detrimental effect of this on the SPA’s bird populations

In order to ensure the safety of aircraft and passengers using an airport situated in the estuary as proposed, extensive bird control measures would need to be undertaken (e.g. bird scaring and nest control). The Government’s Aviation White Paper noted that the estuary airport presented a significantly higher risk of bird strike than at any other major airport in the UK – even with management, up to 12 times higher. Furthermore, the

Page 1 of 14 previous proposal for an airport at Cliffe highlighted major bird strike safety concerns which “could not be managed to an acceptably low level of risk”.

In an area of key international and national importance for birds, the extent of the measures necessary to reduce the risk of bird strike to acceptable levels would be highly detrimental to the Special Protection Areas, legally protected for their bird populations.

Bird disturbance from aircraft activity in the Special Protection Areas

In addition to the detrimental affects on the bird population from direct damage of the SPA and management of bird strike, disturbance from the noise, sight and lighting of day and night aircraft movements are also of concern. This is particularly applies to the vitally important intertidal feeding areas of mudflat and saltmarsh in the SPA.

Potential inhibition of SPA enhancement and potential deterioration of site

The aerodrome authority would have a right to comment on, and object to, land management changes that may become bird attractants within 13km of the aerodrome. Such objections, if upheld, would inhibit any future SPA enhancement/management measures, potentially leading to the SPAs’ condition becoming unfavourable.

Potential negative changes to hydrological and sedimentary estuary processes and resulting loss of intertidal habitat

The ability of the area to support the internationally and nationally important bird populations could be diminished if the proposed development results in changes to the hydrological and sedimentary regimes of the Estuary. Intertidal habitats (e.g. mudflats, saltmarsh and seagrass) are dependent on the stability of these regimes and are crucial to the Thames Estuary ecosystem, whilst also contributing to the management of flooding risk.

A barrier across the estuary would have significant effects, including a reduction in the tidal range and loss of intertidal habitat. These concerns are supported by the Thames Estuary 2100 (TE2100) project. This project has predicted that 1,200 hectares of salt marsh and mudflat could be lost this century as a result of sea level rise and efforts are being made to recreate this loss in order to comply with EU habitats and birds directives. The proposed airport development would make this objective even more of a challenge to meet.

Potential flood risk impacts

The Thames estuary is particularly vulnerable to sea level rise and flooding. The full impact of the airport development in terms of flood risk to land and properties along the length of the estuary will require extensive study (particularly if incorporating a barrier) and must consider existing management policies within the relevant Shoreline Management Plans.

Reduction in water quality and pollution from airport construction and operation

Water pollution, as a result of the construction (for example suspended sediment) and operational phases (for example runway runoff) of the proposed airport development, is highly likely to be detrimental to the intertidal habitats of the Thames Estuary (including those in the SPAs).

Page 2 of 14

TE2100 research suggests that the construction of a barrier would adversely affect the water quality of the Thames, and would result in difficulties in meeting Water Framework Directive (2000/60/EC) standards as a result of “the impoundment of polluted waters.” This “impoundment” would be particularly severe if a tidal energy unit was incorporated into the project.

Detrimental impact of Thames Estuary fisheries

The Thames Estuary is a significant nursery and spawning ground for many commercially important fish and hosts important shellfisheries. The health of these fisheries is important to the ecosystem as a whole, in addition to their economic and anthropogenic importance. The proposed airport could adversely affect these fisheries through:

• Increased levels of suspended solid concentrations. • Noise and vibrations causing avoidance behaviour, physiological damage or mortality. • Artificial lighting affecting reproduction and migration. • Reduced fish movement and migration, particularly relevant for barrier option.

Disturbance of, and negative impact on, protected marine species

Protected species such as short-snouted seahorses (legally protected under Wildlife & Countryside Act 1981 (as amended), and UKBAP species) common and grey seals (legally protected under the Conservation of Seals Act 1970) and cetaceans (legally protected under Conservation (Natural Habitats etc) Regulations and EU Habitats Directive) are known in the waters of the Thames Estuary.

These marine species will be vulnerable to any reduction in the quality of the habitat and noise and vibration impacts – likely affects of the proposed airport.

2. Historic Environment/Heritage objections

General

The Thames estuary has formed an arterial route into the heart of England for at least 400,000 years. As a result of this important strategic location the estuary is extremely rich in archaeological remains from the Palaeolithic to the second world war. It also contains buried prehistoric landscapes, preserved as sea level rose after the end of the last glaciation.

In the estuary between Cliffe and Herne Bay there are records of 462 shipwrecks, many of which date from the last world war, including the SS Montgomery which is located 250m to the north of the Medway Approach Channel. The wreck contains about 3000 tons of explosives, including about 1400 tons of TNT; it has been surveyed and is regularly checked for its condition.

Because of its strategic position the estuary has always been important for defence of the realm, with many nationally important sites from the Tudor period to WW2, including the Maunsell Sea Forts located in the estuary on Red Sands and the Shivering Sands, close to the suggested airport location off Sheppey.

Page 3 of 14 The north coasts of the Hoo peninsula and Sheppey are particularly important historically because of their key positions protecting access to the inner Thames estuary, Medway estuary and Swale sea channel respectively.

Each of the possible landfall sites is considered below:

Sheppey landfall

Within 3 km of the suggested road route lie: • more than 1,440 Historic Environment Record records. These include: • 276 listed buildings (43 Grade I or Grade II*) • 8 scheduled monuments (Minster Abbey, Castle Rough medieval moated site, Murston old church, Chetney Cottage anti-aircraft site, Shurland House and Queenborough Castle, Boxted Roman villa, Church Farm ringwork), • 12 conservation areas and • 8 parks and gardens included in the Kent Historic Gardens Compendium.

The route of the M2 link passes through a landscape rich in heritage sites. These include the home of British aviation at Muswell Manor, Leysdown, an important area of Roman and medieval salt working and a landscape known to contain numerous prehistoric sites at Kingsborough Farm and Shrubsoles Hill, Brambledown.

Further to the west the route crosses an important historic landscape in the marshes of southern Sheppey with its military remains from the Second World War including pillboxes and defence obstacles and maritime assets including historic barges, wharves and jetties. The area is also likely to be rich in palaeoenvironmental remains.

Across the Swale at Iwade excavations have revealed extensive archaeological remains including cremation burials and extensive enclosures, field boundaries and settlement evidence from the bronze Age and iron ages and activity from the Anglo-Saxon and medieval periods. At Grovehurst evidence of important neolithic activity has been found and Milton Regis is thought to have been a Saxon royal estate centre from at least the sixth century AD. Significant remains are likely to be encountered in this area.

Cliffe landfall

A proposed site at Cliffe would be likely to have a high adverse impact on important archaeological and historical features. These features include the full range of findspots, occupation sites, Listed Buildings, and military and industrial structures dating from the Palaeolithic through to the recent past. The Historic Environment Record lists: • more than 1,000 records on the Hoo Peninsula including: • more than 60 listed buildings • five Scheduled Monuments (Cliffe Fort, Cooling Castle, Slough Fort, St. Mary’s Priory and the Coastal Artillery Defences at Grain). • three other nationally important sites within the Peninsula are due to be considered by English Heritage for scheduling (Cliffe Cement Works A & B, Curtis’s and Harvey’s explosive factory and a decoy pond.

In addition to the protected sites there are a large number of sites and findspots in the area. The recorded sites represent only a small proportion of the actual resource likely to be present. Prehistoric sites have been located at Cliffe, Allhallows, High Halstow and the

Page 4 of 14 Isle of Grain, the location of a major multi-period site. Recent survey work produced a significant increase in the number of Iron Age and Roman sites. Similar estuary locations in Essex and elsewhere have demonstrated that this type of location has a high archaeological potential.

In addition to this, the area is likely to contain a particularly high potential for palaeoenvironmental data for what may prove to be a largely intact archaeological landscape. This information alone is likely to be of regional and even national importance.

Whitstable

The Whitstable area from Graveney to Chestfield contains more than • 470 records in the Historic Environment Record. These include: • 7 scheduled monuments (6 of them related to salt-working indicating the importance of the theme in this area • more than 100 listed buildings, plus another 100 on the Canterbury City Council local list, and • 7 conservation areas, including those related to the historic town of Whitstable.

In addition to the protected sites there are numerous heritage assets in the area. There are numerous prehistoric sites from Swalecliffe, Radfall Corner and Brooklands Farm, including the site of a prehistoric log boat from Seasalter. Anglo-Saxon and medieval remains are also known from the area including another log boat from Graveney. A recent study has also identified an important defence landscape in the area with numerous surviving assets related to the Second World War. The most important heritage asset in the area may is probably the medieval and post medieval town of Whitstable itself. This is one of Kent’s heritage ‘gems’ and the setting of the town would certainly be damaged were an airport to be located anywhere in the vicinity.

As with the two other sites the inter-tidal zone is of very high potential for the discovery of archaeological remains in this area and a recent inter-tidal survey discovered dozens of new sites that certainly extend out beneath the sea.

3. Planning and Transport Objections

Economics

Airport reputed to cost some £40bn. Unclear how it would be funded and what element of public funding would be required. A new offshore airport is likely to be significantly worse value for money than other options with which it would need to compete, unless Government sought to regulate prices and investment in the London airport network, contrary to its policies and actions towards privatisation.

Thames Estuary Airport (TEA) would need to attract at least one major airline alliance to switch from Heathrow. The airline industry very reluctant to move from Heathrow and most unlikely to do so unless offered very attractive deal on landing charges, reducing income for the airport. To be viable a new hub airport would require extensive seeding – moving significant existing services from Heathrow in particular to provide an attractive choice of routes from the outset so that the new airport could compete. There are no

Page 5 of 14 established or internationally accepted policy mechanisms which could ensure such relocation of airline operations.

A new offshore airport requires major investment at the outset, and lacks flexibility in the face of market change because it cannot be developed incrementally. It is an “all or nothing” proposal.

TEA is poorly positioned in relation to the catchment area of the South East which currently focuses west of London. It is poorly positioned to capture market share particularly from Heathrow.

Would not be ready until 2030, ie 20 years hence. There will be a need to expand runway capacity at the existing London airports in the interim (Heathrow, Stansted and/or Gatwick), further eroding viability of TEA.

Continued significant growth in air travel (after the recession) is far less certain than in the past with the need to comply with carbon targets. It is more likely that costs of air travel will rise significantly above inflation

Maximising capacity at existing runways (including Manston), incremental expansion at existing London airports and development of regional airports is better to meet the changing levels of demand rather than big bang approach which is inflexible and highly risky

Transport

TEA requires extensive and costly new road and rail infrastructure which is likely to attract significant opposition. Strategically the location is a ‘cul de sac’ – it is the only destination on the routes needed to serve it and as such their viability depends entirely on the success of the airport

If successful, TEA would increase traffic on strategic road and rail links in Kent – no figures available but likely to be significant over a large area of Kent

• would strain capacity on A2/M2 (already mostly four lanes) with little scope for significant increase in capacity. Would probably require widening of three lane sections of M25, two lane M26, three lane M20 and two lane A249 with appropriate junction improvements

• would cause pressure on the capacity of HS1 and Kent domestic rail services using HS1 (Eurostar likely to be immune).

It is very unlikely that by 2030 there will be spare capacity on High Speed 1 which is linked to the Channel Tunnel for passenger and freight services, and provides commuter services in Kent and East London. The stopping patterns and terminal location must be attractive to long distance air travellers.

Significant adverse impact therefore on Kent’s economic development plans (Ashford, E Kent etc) which depend on maximising existing and planned transport infrastructure.

Page 6 of 14 Urban Development & Regeneration

The urbanisation and travel impacts of a new airport with 4 runways will be very great. Little of the additional pressure could be absorbed in the immediate area of landfall for the road and rail links to the airport. Major green-field land release would be required in Kent and Essex.

To be viable the new airport must transfer passengers from other South East airports. A dramatic pace of urban development and investment in public services would be needed in advance of the airport opening to provide workforce and services on day one of the airport operation. There would be matching under capacity and loss of activity in the Heathrow area.

The services and labour supply required to support the airport would need to be located as closer to the island as possible. Little development could be absorbed in Sheppey and Southend requiring major development on green-field land in Kent and Essex.

Safety National Air Traffic Services (NATS) was concerned over severe problems a new airport at Cliffe would create. TEA could be expected to raise similar problems that need to be fully investigated.

The proposed airport construction in the Estuary could have significant consequences for flood protection within London and the Thames Estuary area. The implications would need detailed assessment

EHW/Feb10

Page 7 of 14 Thames Estuary airport: Oakervee feasibility review RSPB critique

Summary Douglas Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October 2009 following a request from London’s Mayor, Boris Johnson for the feasibility of an airport in the Thames Estuary to be evaluated. An airport in this location is not a new idea; it has previously been considered and rejected, partly because of the ecological sensitivity of the Thames Estuary Location. The Thames Estuary has nine internationally important nature conservation designations, the majority of which relate to rare and vulnerable bird species.

These designated sites already experience significant pressure from an array of existing activities and developments that occur in that broad location. The pressure also continues to increase, with several other projects, such as major port developments and energy infrastructure, being proposed in the area.

The environmental effects of an airport in this location are likely to be significant and wide ranging. They could include the loss of protected habitat, disturbance of sensitive protected species, increased atmospheric emissions, including emissions of greenhouse gases, and alteration to the hydrodynamics of the Estuary resulting in accelerated patterns of erosion and/or deposition. These effects could lead to a population scale decline of bird populations in and around the Thames Estuary. The scale of potential effects would result in likely significant effects on protected habitats and species in the internationally designated nature conservation sites. These adverse effects would be very difficult, and in all probability, impossible to mitigate.

Given the range of alternatives solutions to the airport available and in the absence of imperative reasons of overriding public interest, an airport in the Thames Estuary could not be consented without contravention of UK law on the protection of nature conservation. The RSPB therefore views the proposal as a totally unfeasible and impractical scheme.

2 Introduction

An airport in the Thames Estuary has previously been considered in the Government’s 2003 Aviation White Paper, to which all key players, including the aviation industry, contributed. The White Paper conclusively ruled out an airport in the Thames Estuary. Despite this however, London’s Mayor, Boris Johnson, requested a study into the feasibility of the potential for an airport in the Thames Estuary. Subsequently, Douglas Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October 2009. From the very outset of London’s Mayor first raising the idea of developing a major new airport in the Thames Estuary, the RSPB has had serious concerns about the likely environmental consequences. However, the Feasibility Review falls short of adequately considering the likely environmental effects of such a proposal and thus the feasibility of creating an airport in the estuary. As such, the Review fails to alleviate the RSPB’s concerns regarding the likely direct and in-direct environmental effects, as well as the consequences on the UK’s ability to meet commitments to its climate change targets.

The importance of the Thames Estuary and the designated sites for conservation The RSPB is pleased to see that Oakervee acknowledges the internationally outstanding, sensitive environment of the Thames Estuary: “When reviewing the Thames Estuary and the creation of a sustainable future for London and the South East of England…we must recognise the sensitivity of the environment and safeguard it to the best of our ability. The challenges we face in the Thames Estuary are complex and the approach needs to be rethought if we are to avoid leaving future generations an even

Page 8 of 14 bigger challenge with an even bigger price tag.” (page 21).

The challenges in the estuary are indeed complex, and the consequent approach to managing the estuary needs to reflect this. With such a proposal likely to result in significant environmental damage, a “rethought approach” for a “sustainable future”, as Oakervee suggests, should logically discard the idea of an estuary airport as wholly unfeasible.

The Thames Estuary is a dynamic place formed by the meeting of the Thames, the North Sea and the landforms of London, Kent and Essex. The estuary is an area of outstanding international importance for birds; reflected by a network of Special Protection Areas designated under EU Directive and protected accordingly. The estuary has the highest concentration of bird species in internationally important numbers in the south east. The diversity of waterbird species places the estuary in the top five internationally important sites in the UK, out of 143 recorded. Whilst the Oakervee Review acknowledges the conservation importance and environmental sensitivities of the estuary, it wholly fails to comprehend the real implications of an airport in the estuary, instead choosing to adopt the line that the environmental harm arising from such an airport can be managed. Thames activities/developments

The Thames Estuary area is currently the focus of many existing activities including large-scale commercial port operations, minerals extraction, dredging, transportation, recreation and numerous energy projects. The area is also presently the focus for new developments in a variety of sectors including further large-scale port and energy projects.

These activities alone, and together with other pressures such as climate change, exert a significant pressure on the sensitive habitats and species in the Thames Estuary. These existing pressures may also be exacerbated if potential future developments that may also have an impact on the estuary, such as the proposed lower Thames crossing, get the go ahead.

Impacts on designated nature conservation from an airport in the Thames Estuary As acknowledged in the Feasibility Review, an airport in the Thames Estuary could clearly result in significant environmental effects:

“It takes little imagination to appreciate that if any of the proposals or schemes under consideration were introduced without appropriate amelioration measures then the impact on this precious ecological reserve could be disastrous and in this day and age almost certainly unacceptable” (page 28).

However, despite recognising this, the Review fails to understand that an airport in the estuary is an impractical and unfeasible proposition, with very little opportunity to apply “appropriate amelioration measures”. As such, an airport will undoubtedly result in significant damage to the environment, protected habitats and species. Further to this, it is unfortunate and disappointing that the Review, when listing the impacts of an 4 airport in the Thames (on page 40), does not identify potential significant environmental harm as a “disadvantage”. Instead, the Review proceeds with considering a broad location of a possible airport as approximately “7Km to 10Km north east of Whitstable in the direction of the Shivering Sands Fort and The Kentish Flats Wind Farm”.

Due to its location, the proposal has the potential to directly and indirectly impact on of a range of internationally protected nature conservation sites (Special Protection Areas

Page 9 of 14 (SPAs), Special Areas of Conservation (SACs) and Ramsar sites), including: - Essex Estuaries SAC; - Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar; - Benfleet and Southend Marshes SPA and Ramsar; - Thames Estuary and Marshes SPA and Ramsar; - Medway Estuary and Marshes SPA and Ramsar; - The Swale SPA and Ramsar; - Thanet Coast SAC; and - Thanet Coast & Sandwich Bay SPA and Ramsar.

In addition, the airport would have a direct impact in the Outer Thames proposed SPA (pSPA), and the Margate and Long Sands possible SAC (pSAC). Government policy affords the same level of protection for a pSPA as it would a designated SPA. A candidate SAC (cSAC) is also afforded the same level of protection as a classified SAC. However, although the pSAC is not afforded the same protection as a cSAC, we strongly recommend that this site be considered as though it were a cSAC, since this classification is likely to come into effect by the end of 2010. Designated for a wide range of species and habitats, these sites are also underpinned and protected by the national Site of Special Scientific Interest (SSSI) notification. The Feasibility Review also identifies that access to the airport would be via new road and rail infrastructure from the Kent and Essex coastlines. Whilst not certain at this stage, it is suggested that tunnels would be utilised for the sea section of the routes. The broad location of these new infrastructure developments could potentially coincide with the Thanet Coast & Sandwich Bay SPA and Ramsar, The Swale SPA and The Swale SAC, on the Kent coastline in addition to the Benfleet and Southend Marses SPA and Ramsar, the Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar, and the Essex Estuaries SAC on the Essex coastline.5

There are clearly, therefore, a large number of internationally designated nature conservation sites that could be affected (both directly and in-directly) by a new airport in the Thames Estuary. The potential impacts on protected bird species, from the airport alone, are numerous and significant. These include: - direct loss of bird foraging habitat (and thus a reduction of food resource) in the Outer Thames Estuary pSPA; - disturbance to birds from airport construction, including noise, vibration and lighting effects, resulting in displacement of a large (foraging) area in the estuary; - disturbance to birds from airport operation, resulting in displacement of a large (foraging) area in the estuary; - direct loss of (foraging, roosting and/or loafing) coastal and inland bird habitat due to airport transport links to Essex and Kent; - disturbance to coastal and inland sites from associated transport links to Essex and Kent; - potential alterations to hydrodynamics – flow changes can resulting accelerated patterns of erosion and/or deposition and therefore potential loss of intertidal habitat; - atmospheric pollution - NOx is the principal pollutant arising from aircraft and road traffic associated with airports. Deposition of nitrogen compounds (nitrates (NO3), nitrogen dioxide (NO2) and nitric acid (HNO3)) can cause eutrophication of soils and water. This alters the species composition of plant communities and can eliminate sensitive species; and - water pollution as a result of accidental spillage of aviation or other fuel. From loss of foraging, roosting and/or loafing habitat, through direct and indirect habitat loss and from increased human disturbance, bird populations could face decline in and around the Thames Estuary. This will have knock on effects for the environment and wider ecosystem because of the Thames Estuary’s international importance (being in the top five internationally important sites in the UK) due to the numbers of waterbirds found there during winter and on migration1.

Page 10 of 14 Safety and bird strike

The hazard to aircraft from bird strike is well known and at estuary sites, an obvious concern. The Feasibility Review, although recognising bird strike as an issue, suggests it is solvable:

“data indicates that although bird strikes are a real issue there are ways to overcome the problem without being aggressive towards the birds. Whilst much is written on how best to resolve the problem and should be reviewed in detail, I believe the issue should be addressed with the RSPB to find the right solution for the Thames Estuary” (page 51). The RSPB considers it impossible to control bird strike risk for an airport in this location without “being aggressive towards birds”, since attempting to control the risk of bird strike will require many invasive techniques, including intensive and wide spread bird scaring. In the RSPB’s response to the Air Transport White Paper in 20032, we drew attention to our concerns regarding aircraft safety at an airport at Cliffe, which was to be located in the midst of the Greater Thames (in a similar position to that of a possible Thames Estuary airport). With regards to an airport at Cliffe and the 2003 Air Transport White Paper, several studies were undertaken to assess bird strike, including research commissioned by the Secretary of State for Transport. All studies concluded a significant risk of bird strike, with the Secretary of State’s report (by CSL and BTO, published in March 2003) concluding that: “Without a comprehensive and aggressive bird management programme in place, incorporating careful and considered airport design, appropriate habitat management and active bird control, an airport could not operate safely in this location. Even with such world class management and mitigation measures in place, the hazard posed by birds is severe and would probably be higher than at any other major UK airport.” Pages 203-4 of the CSL/BTO report place this in perspective. The expected number of damaging bird strikes at an airport at Cliffe would be between 2.97 and 8.65 per year, whilst total hull loss would be expected to occur between 1 in 102 years and 1 in 297 years. Yet, for ten of the largest civil airports in the UK, the estimated rate of total hull loss is between 1 in 304 and 1 in 1210 years, with a mean of 1 in 653.5 years. 2 Future Development of Air Transport in the UK – South East (Second Edition), RSPB consultation, May 2003 7 In other words, the hazard associated with the Cliffe option was, at best, equal to the greatest risk at any of the top ten UK civil airports in 2003 and, at worst, the level of risk was up to 12 times higher. And this is with a bird hazard management regime in place which would have a major adverse impact on the waterfowl and waterfowl habitats of the SPA. The RSPB therefore concluded that the level of bird strike risk associated with the Cliffe option was unacceptable, in terms of human safety. We further concluded that the habitat modification and active bird scaring measures associated with reducing the level of bird strike risk even to this unacceptably high level was also wholly unacceptable in terms of its implications for the SPA. With many similarities between possible airports at Cliffe and in the Thames Estuary, we are very concerned that the risk of bird strike could be of at least a similar scale and nature. A key consideration in assessing bird strike risk is bird flight lines. However, the Feasibility Review does not attempt to provide any primary information on bird movement within the broad airport location, but instead makes reference to flight path mapping provided by MetroTidal: “MetroTidal in their studies have produced a map of the flight paths across the estuary and is included as Figure 20 below. If this is representative of the actual situation it would appear that the likely location is relatively free from

Page 11 of 14 bird movements. This coincides with my own visit to the area” (page 51)”. It is very concerning that the conclusion is reached that “the likely location is relatively free from bird movements” when the MetroTidal study appears to relate to a location further to the west of the broad airport location. Furthermore, the robustness of the MetroTidal data is unclear, as no details are provided on the timing or duration of the study. Decision making With any proposal for an airport in the Thames Estuary, the Habitats Regulations 19943 (among other requirements such as environmental impact assessment) will apply. And as such the relevant competent authority will have to determine whether the project is likely to have a significant effect on either the Ramsar sites4, the SPAs, pSPA5 and/or the SACs (known collectively as the European sites) either alone or in combination with other plans or projects6.

The Likely Significant Effect Stage - any project not directly connected with or necessary to the management of an European site is to be subject to an appropriate assessment of its implications for that site in view of the site's conservation objectives if it cannot be excluded, on the basis of objective information, that it will have a significant effect on that site, either individually or in combination with other plans or projects. If the project is likely to have such an effect there is a legal duty for the competent authority to make an appropriate assessment of the implications for the European sites in view of those sites’ conservation objectives. The project can only receive permission if it can be ascertained that it will not adversely affect the integrity of the European sites7.

As part of the appropriate assessment mitigation measures can be considered. The Feasibility review in recognising the potential impacts on the environment, suggests that: “It will…be necessary to pioneer mitigation measures to create equal habitats to maximise the survival potential of all.” However, whilst there may be some mitigation measures available to avoid and/or reduce the harm, providing “equal habitats” will only compensate for the harm/loss rather than avoid or reduce the harm. The RSPB believes that many effects of such a proposal on protected species cannot be mitigated, and therefore adverse effects cannot be avoided.

If it cannot be ascertained that the project will not adversely affect the integrity of the European sites, the provisions in regulations 49 and 53 of the Habitats Regulations would fall for consideration namely that there are no less damaging alternative solutions to the project, there are imperative reasons of overriding public interest to justify the project receiving permission despite the adverse effects on the integrity of the European sites and that compensatory measures can be provided before those effects occur. The RSPB believes that there are alternatives solutions to the project and that there are no imperative reasons of overriding public interest. Finally, we believe it would also be extremely challenging, if not impossible, to replicate the habitats lost elsewhere.

Climate change The RSPB welcomes the Feasibility Review’s acknowledgement of the seriousness of climate change and the recognition of the scale of reductions in emissions required: “Recent revisions to government policy with respect to climate change and the requirement for an 80% reduction in carbon emissions by 2050 must be the driving force behind many major decisions and how we live in the years to come.” (Page 23).

It is therefore surprising and concerning that the Review fails to address the issue that the carbon costs (of both constructing and operating a new airport in the Thames Estuary) would be entirely at odds with the Government's carbon reduction commitments. Such a proposal will lock the UK into yet more carbon-intensive infrastructure for decades. If the airport were to be progressed therefore, it would place a huge and

Page 12 of 14 expensive burden on other sectors of the economy to decarbonise even further to account for the contribution from aviation.

With the greater travel distances between London and the proposed airport compared to London’s existing airports8, the additional distances required to travel to the new airport would have a further significant carbon cost. In any serious proposal, we would expect to see detailed analysis of the carbon cost of building and operating the airport, together with measures for mitigating the substantial carbon release. However, we do not believe that a development of this size or nature could adequately mitigate these impacts in an increasingly carbon-constrained world. Conclusion

We are very concerned that the Thames Estuary is even being considered as a location for a new international airport. The proposal is likely to harm the sensitive estuarine habitats and species of the designated sites through habitat loss, noise disturbance and atmospheric pollution.

Given the evidence of the impacts of climate change on biodiversity and the significant and rapidly increasing contribution aviation is making to global warming, the RSPB also has serious concerns that a new airport is likely contribute to environmental degradation via exacerbating climate change and would seriously hamper all attempts to cut the UK’s greenhouse gas emissions.

3 Conservation (Natural Habitats &c.) Regulations 1994 as amended (the Habitats Regulations) 4 As a matter of government policy the procedures applicable to SPAs and SACs apply to Ramsar sites - Paragraph 5 of ODPM Circular 06/05 5 Government Policy affords the same level of protection for a pSPA as it would a designated SPA 6 Regulation 48(1) of the Habitats Regulations 7 Regulation 48(5) of the Habitats Regulations 8 The proposed airport would be some 96 km to Charing Cross, whilst Heathrow is only 28 km and Gatwick 47 km from Charing Cross.

Page 13 of 14

Page 14 of 14 Thames Estuary Airport

Visit to Kit Malthouse by Medway Council 2 March 2010

Cllr Rodney Chambers – Leader of the Council Cllr Paul Godwin – Leader of the Labour Group Cllr Maureen Ruparel – Leader of the Liberal Democrat Group Cllr Tony Goulden – Leader of the Independent Group Robin Cooper – Director of Regeneration, Community and Culture John Staples – Media Manager

www.medway.gov.uk Location Map Medway and Airport

Thames Estuary Airport

MANSTON 10 reasons to oppose the airport

Medway’s View

1. An airport would cause environmental destruction to sites of special scientific interest and internationally important areas where hundreds of thousands of birds migrate to annually.

2. As the Thames Estuary is a hub for hundreds of thousands of birds, there would be a significant risk of bird strike. Even with an aggressive bird hazard management programme, such as shooting or scaring birds away, the bird strike hazard would be up to 12 times higher than at any other major UK airport (source: RSPB)

3. An airport would increase the pressure for additional major development due to the increased attractiveness of the area to business. This could result in vast swathes of Kent and Medway being lost to development. At least 320 businesses are directly associated with Heathrow, there are hundreds more supporting industries and Heathrow employs 72,000 people. If the Thames Estuary airport were to replace Heathrow many of these people would move to Kent and Medway, leading to significant house building and infrastructure requirements.

4. The airport feasibility report by engineer Douglas Oakervee did not consider the risks associated with operating an airport in close proximity to the existing import facility for liquified natural gas (LNG) at Thamesport.

5. Kent International Airport at Manston has one of the longest runways in Europe and this could be connected to the high speed train link already in place at far less cost.

6. The cost of a new airport would be prohibitive.

7. The noise, light and air pollution would be intolerable.

8. The airport would be fogbound and affected by high winds.

9. Nearly nine out of 10 international airlines that use Heathrow are against an estuary airport.

10. Existing airports already have potential to increase capacity. For example, Birmingham says it could double the passengers it carries. A high speed rail link from London to Birmingham is already on the cards.

The effect on wildlife Associated risks Medway’s Liquid Natural Gas site at Grain Agenda Item: 11A

COUNCIL 14 JANUARY 2010 THAMES ESTUARY AIRPORT – FEASIBILITY REVIEW

Portfolio Holders: Councillor Rodney Chambers, Leader Councillor Phil Filmer, Front Line Services Report from: Robin Cooper, Director of Regeneration and Development Author: Steve Hewlett, Head of Integrated Transport

Summary

This report advises Members of the Thames Estuary Airport – Feasibility Review, published in October 2009.

1. Budget and Policy Framework

1.1 The issue is whether to review Medway Council’s opposition to the plans to construct a new Thames Estuary Airport.

1.2 This is a matter for Council because of the potential for decisions which may seek to amend the existing policy framework and budget.

2. Background

2.1 Following a report to Cabinet on 17 February 2009, on 5 March 2009 Full Council considered proposals from the Mayor of London, Boris Johnson for a new Thames Estuary Airport. Full Council agreed the following:

The Council object to the Mayor of London’s proposal to construct a Thames Estuary Airport on the following grounds: (i) It is unnecessary and not wanted (ii) The cost of an airport would be prohibitive (iii) The current infrastructure would not cope with huge increases in traffic (iv) The environmental damage would be catastrophic (v) The noise, light and air pollution would be intolerable (vi) The risk of air strike from migrating and nesting wildfowl would be

high especially as this is an internationally important site for wildlife (vii) The airport would be disproportionately affected by fog and high winds (viii) The airport would lead to blight in the surrounding area including falling property prices and uncertainty for many years about inward investment into Medway (ix) Kent County Council is promoting Manston as an airport destination and this provides a viable alternative

2.2 The Mayor for London has employed Douglas Oakervee OBE to advise him on the feasibility of an estuary airport. In October 2009 the Feasibility Review was published, which provides more information than was available when Members considered the proposal earlier in the year. However, the details are still not subject to any formal consultation as they are not a proposal from government.

2.3 This report is intended to enable Members to consider whether they wish to review their previous decision taking into account the more detailed information that is now available.

3. Summary of the Thames Estuary Airport - Feasibility Review

3.1 The study states that a new major airport serving London and the South East will be needed by 2030, stating that the Department for Transport’s “overwhelming” evidence showed a capacity shortfall of “about 70m passengers per annum by 2030, even when all other potential expansion is put in place”. The study notes that Heathrow has been functioning at 99% operational efficiency, with approximately 477,000 Air Traffic Movements in 2008, and the prospect of this increasing to 605,000 by 2020.

3.2 The review has identified a number of alternative Thames Estuary Airport schemes that it alleges are being promoted by various organisations. Several of these schemes have a direct, physical impact on Medway, including schemes promoted by: • Thames Reach Airport Limited and Metrotidal Limited • Sir Terry Farrell & Scott Wilson

3.3 The study identifies the predicted level of growth in North Kent and considers that the full potential of the regeneration goals will not be reached without a catalyst, such as improved infrastructure and transport links.

3.4 The report considers the main advantages and disadvantages of an estuary airport and these details are reproduced in table 3.1 in this report.

Table 3.1 Impact of an offshore airport (Taken from Thames Estuary Airport - Feasibility Review, prepared by D. Oakervee OBE) Advantages Disadvantages

• 24 hour operation • Distance from Central London • Minimal pollution and transport links • Approach not over central • Reluctance of Airlines to move London and perceived loss of • Reduced risk for residents premium revenue • Incremental expansion without • Air movement complicated disruption over SE England • A green airport • Possible loss of interline traffic • The catalyst for regeneration • Move in the centre of gravity and wealth creation for business • No CPO of land • Capital costs will be high. How will it be paid for?

3.5 Whilst the report considers that the project is technically viable, it does recognise that the “delicate ecology of the area” and “very large bird populations” must be central to any decision. Whilst the report does not favour a specific location, it considers the most likely site would be in the outer estuary some 4½ to 6 miles north east of Whitstable in the direction of Shivering Sands Fort and the Kentish Flats Wind Farm.

3.6 The report considers that economies of scale could be achieved by considering how the scheme could be integrated with the demands of other government departments, such as adding in estuary crossings and renewable energy farms. Furthermore, the study refers to the final draft Thames Estuary 2100 report (TE2100), which details future problems as a result of rising sea levels and extremes in weather conditions largely brought about by climate change. TE2100 suggests a multifunctional barrier with both transport links and tidal energy generation would provide a more cost effective and sustainable solution. The airport study considers that this proposition would be further improved if provision for an estuary airport was made.

3.7 The report acknowledges that the Thames Estuary is one of the most important ecological sites in Europe and forms a key part of the huge ecosystem surrounding the North Sea. It recognises that not only are birds protected by stringent EU and UK legislation, but so too are certain species of fish, molluscs and crustaceans, to ensure safe and secure breeding grounds.

3.8 The report considers that whilst the present investment will provide new transport links such as Crossrail, Thameslink and HS2, further improvements in the Thames estuary “will be necessary to support the existing housing programmes let alone the expansion, development and regeneration that would result should the major infrastructure being proposed by this review be constructed”.

3.9 The review makes reference to the findings of the Dartford River Crossing Study – A Lower Thames Crossing. The route options for a crossing were shown diagrammatically in the Lower Thames Crossing study and have been reproduced at Appendix A. The study discarded options D1, D2 and E. The study was considered by Cabinet on 2 June 2009, when Members supported recommending to government that options A, B & C be taken forward for further consideration. However, the airport review considers that options D & E are worthy of further consideration because: • Option D is the alignment on which Metrotidal’s scheme is based • Option E alignment would be close to where access is likely to be needed for an estuary airport and outer barrier.

3.10 The option D, Metrotidal scheme is situated near the Cliffe Airport proposal, which was rejected by the Government’s White Paper on Aviation. The scheme proposes an additional road and rail crossing of the Thames and incorporates both tidal lagoons for power generation and a Thames Barrier as well as an airport. The scheme conflicts with major conservation areas and the risk of bird strike is likely to be high. Option D directly affects Medway.

3.11 It is unclear whether option E directly affects Medway, due to inconsistencies in the Dartford River Crossing study – these errors have been reported to government, but no response has been received.

3.12 Officers are aware that the brief for the detailed Lower Thames Crossing study is being prepared by DfT. Working with our local authority partners in north Kent through a Multi Area Agreement, we have requested participation in the preparation of the brief, but this has been declined by the DfT. It is therefore unclear at this stage whether options D and E have been included in the Lower Thames Crossing study.

3.13 The review suggests that a new airport located in the Thames Estuary is likely to be approximately 60 miles from the centre of London at Charing Cross, compared to 17 miles from Heathrow, 29 miles from Gatwick and 43miles from Stansted.

The proposed location of the airport is shown in the figure below, (extracted from the review document prepared by Douglas E Oakervee OBE FRENG.)

3.14 It is clear that if an airport were to be built in the estuary, the whole pattern of traffic would change dramatically, at a national, regional and local level. An airport of this size will demand high capacity, high quality transport links, particularly to central London but also to regional and local destinations. The report places great reliance on rail links and the need to discourage the use of car trips to the site. The review recognises that if the airport were to be built, there would need to be a significant rethink regarding rail connectivity, and especially High Speed Rail from the network to the airport if a maximum journey time of 40 minutes from Central London to an estuary airport is to be achieved. The report details potential links to High Speed 1 and the proposed High Speed 2. However, the report also recognises the importance of motorway connections and proposes the following new motorway infrastructure: • connection to the south to be built across the Isle of Grain1 to link both the M2 and M20 to the airport crossing; • Estuary crossing to a rebuilt A13 in Essex and then link the improved A130/A120 to Stansted Airport and the M11.

1 This may be an error, as figure 16 shows rail across the Isle of Sheppey. This point was raised by Medway Council with the DfT on the Lower Thames Crossing study.

3.15 The review comments on the importance of trade and leisure activities that the river supports and states that “no activity must undermine the performance of the Port of London”. The review also acknowledges the significant contribution that Thamesport, Chatham Docks and the Port of Sheerness make to the UK’s economy.

4. Advice and analysis

4.1 Recent revisions to government policy regarding climate change and the requirement for an 80% reduction in carbon emissions by 2050 must be a central consideration to national air travel strategy. The review recognises that future studies should be holistic, with climate change as the main driver. Furthermore, the report acknowledges that in the past the effects of climate change “have frequently been underestimated and even now the seriousness of the problem is still being realised”. The report notes that aviation currently contributes at least 5% of the world’s total carbon emissions, plus the contribution from the activities of airports and acknowledges that a “fundamental change in air travel behaviour and technology will become a necessary if climate protection measures…are to be achieved”.

4.2 The report acknowledges that any scheme that did not undertake “appropriate amelioration measures then the impact on the precious ecological reserve could be disastrous”. However, given the scale of the likely impact, it is unclear how an acceptable level of mitigation could be achieved. Furthermore, in responding to the likely impact on the ecology, the report suggests that this must be balanced against the “many and complex issues surrounding climate change, as well as the needs and demands of a growing population”.

4.3 Regarding the potential location for an airport, the identification in the report of Upper Heyford as the “centroid for overall passenger demand for the whole of the UK” argues in favour of an airport facility to the west of London rather than the east.

4.4 There is no doubt that high speed rail would be essential to serve the airport. The Southeastern High Speed services (rather than Eurostar as mentioned in the report) demonstrate that it is feasible to offer services for journeys such as London to Ebbsfleet with high speed trains. However, this is not to say that there is sufficient capacity available in the current high speed network to accommodate the dramatic increase in service which would be needed to serve the airport. One particular constraint on capacity is the terminal at St Pancras station where there is little scope for additional international or domestic services to or from the high speed line.

4.5 The written description of the proposed high speed rail link and the arrangements illustrated in Figure 16 of the Oakervee review differ dramatically. The written description talks about a branch from HS1 via Southend and the Airport to Ashford. This would be at least 48 miles of brand new high speed line and would make little use of HS1 except in

the capacity constrained London approaches. It would not offer links for airport workers or users from North Kent to the airport except by way of Stratford or Ashford, which would be very indirect routes and lose any benefits of high speed travel. However, the illustration at Figure 16 shows a line branching off HS1 south of Sittingbourne to the Airport. In practice, HS1 is south of the North Downs in this area so the branch would need to climb the scarp of the Downs. This service would leave HS1 between Ebbsfleet and Ashford stations. Medway passengers, therefore could only access the airport with this route by “backtracking” to Ebbsfleet. Neither option would overcome the terminal and line capacity constraints at the London end of the HS1.

4.6 The report highlights the opportunities offered by HS2 – the proposed high speed line from London northwards. This line is by no means committed, with the route and the London terminal being a long way from being resolved. One benefit of the airport proposal is that it would strengthen the case for the London terminal for HS1 and HS2 being linked, which would improve cross –London travel opportunities.

4.7 The report states that “…by 2030 it is inconceivable that the lines serving both north Kent and south Essex will not have been upgraded sufficiently to enable a high speed Javelin service to the airport from the suburbs of London”. However, it is entirely conceivable that this will not happen.

4.8 Whilst the report places great emphasis on serving the site by rail, as demonstrated this is not without significant problems particularly for local accessibility. Local employment opportunities are significant, but possible problems with local access by rail services could result in a high level of unsustainable trips by car.

4.9 There is little detail of the new road links in the report. However, the written description of the links would appear inconsistent with the diagram at Figure 16 of the Oakervee review. Page 50 of the review describes the connection to the south as being “built across the Isle of Grain to link both the M2 and M20 to the airport crossing”. Figure 16 shows the rail connection to the Isle of Sheppey and it is assumed for economic purposes that the road connection would follow the same route as the rail connection. Clearly from Medway’s point of view this inconsistency is highly significant, as one option would have a direct, major impact on the area. Furthermore, the report takes no consideration of the capacity of the M2, M20 and the strategic road network further afield, which are all likely to require significant upgrading.

4.10 The impact of both the road and rail links to the proposed airport on the environment could be catastrophic and this issue has not been considered by the review.

4.11 The South East England Partnership Board is commissioning a transport study on the transport corridor between London and Dover Docks on behalf of government. This study will incorporate the M2 and

M20 corridors and it is understood that the study will not take into account the proposals in the Thames Estuary Airport Feasibility Review.

4.12 The report acknowledges that “bird strikes are a real issue” but considers “there are ways to overcome the problem without being aggressive towards birds” although it is unclear how this would be achieved. It also suggests that the RSPB should be used to resolve the issue of birds at an estuary airport. This is naïve when the RSPB have already put themselves forward as a main objector to the scheme.

4.13 The report considers that the estuary presents an opportunity for tidal energy to make a “meaningful” contribution to the overall needs of the region. But, the estuary was not identified by Government as one of the preferred locations in the UK for this purpose. Furthermore, the adverse impact of tidal energy generation on the rich inter-tidal mud flats in the estuary on which vast numbers of migratory birds feed has not been determined. In addition, the increased risk of flooding as a result of the impact of the airport on a surge tide has not been determined.

4.14 Finally, the review has not considered the risks associated with operating an airport in close proximity to the existing import facility for LNG (Liquefied Natural Gas) at Thamesport and the proposed London Array wind farm. The wind farm is a joint venture being developed by three international companies with renewable energy interests. The wind farm would be located more than 12 miles from the Kent and Essex coast in the outer Thames Estuary. This is one of three strategic areas in the UK that has been identified by government for offshore wind farm development.

5. Benefits and disbenefits to Medway

5.1 It is likely that an airport would bring significant benefits to the local economy and the regeneration of the area, by creating a significant amount of direct and indirect employment and business opportunities. However, the airport could bring major, unacceptable disbenefits, including:

• Direct environmental destruction by causing harm to Sites of Special Scientific Interest and internationally important areas where hundreds of thousands of birds migrate to annually. The airport would destroy huge areas of legally protected habitat.

• Encouraging more air travel which is likely to exacerbate climate change. Assuming the airport would create new capacity, it is likely that the proposal is contrary to the national statutory target to reduce carbon emissions by 80% by 2050. Furthermore, increased emissions from aircraft and associated passenger and freight vehicles accessing the airport could significantly add to existing local areas of known poor air quality.

• Significant risk of bird strike as the Thames Estuary is a hub for hundreds of thousands of birds. Even with an aggressive bird hazard management programme, such as shooting or scaring birds away, the bird strike hazard would be up to 12 times higher than at any other major UK airport (source: RSPB).

• Harm to areas of landscape importance by the construction of major road and rail infrastructure links from the airport to the strategic road and rail networks.

• Increased pressure for additional major development due the increased attractiveness of the area. This could result in areas of high landscape importance being lost to development, thereby being detrimental to the local environment.

• Kent International Airport at Manston has one of the longest runways in Europe that could be connected to HS1 at far less cost.

5.2 Therefore, whilst there could be economic benefits from an airport, these would be hugely outweighed by the environmental damage and other detriment to the area such an airport would bring. It is therefore considered that the additional information contained within the Feasibility Report does not alter the view taken by Cabinet on 17 February 2009 and Full Council on 5 March 2009. It is considered that only by carrying out a much more detailed wider London and the south east connectivity and accessibility study would any justification for the location of a new airport in the south east be determined.

6. Consultation

6.1 Working in partnership with Kent County Council and the RSPB, Medway Council has taken the lead on a “Stop the Estuary Airport” campaign, with high profile media campaigns and a dedicated campaign website. In summary, the campaign considers the project to be undeliverable, unaffordable and unnecessary, and has raised the following grounds for objection:

• Immense damage it would cause to the area’s internationally important wildlife and the wider environment • Exacerbate climate change • High cost of construction • Significant risk of bird strike • It would require huge unsightly highways to be built linking the airport to the motorway network

6.2 At the time of writing support, the campaign had been supported by 1,342 people on the website.

6.3 Given the concerns regarding the significant impact on the environment and the high risk of bird strikes, it is considered that meaningful proposals for environmental mitigation in line with the requirements of

the EU Birds Directive and the EU Habitats Directive are developed prior to the principle of the scheme being considered further.

7. Cabinet

7.1 The Cabinet considered this report on 5 January 2010 and its recommendations are set out in paragraph 10 below (decision no. 2/2010).

8. Risk Management

8.1 Risks associated with the development of a Thames Estuary Airport are detailed in the table below.

Risk Description Action to avoid or mitigate risk Development of Proposal to develop High profile campaign Thames Estuary an estuary report to raise awareness of airport. obtains stronger the devastating policy weight. impacts of the proposal. Respond to all published proposals.

9 Financial and legal implications

9.1 At present costs can be contained within existing budgets. However if the proposal is taken to formal consultation by the government the need to employ aviation and other experts so as to be able to consider any planning issues properly and to be represented at planning inquiries will led to significant costs to the Council.

10. Recommendation

10.1 That Council reaffirms its opposition to the plans to construct a new Thames Estuary Airport and that Douglas Oakervee (the author of the report) be contacted to:

- advise that any justification for the location of a new airport in the south east could only be considered once detailed London and the south east connectivity and accessibility studies had been undertaken;

- seek to clarify the route of the road and rail links, as detailed in the report;

- draw to his attention the risks associated with the close proximity of the existing LNG import facility at Thamesport and the proposed London Array wind farm; and

- seek early meaningful proposals for environmental mitigation in line with the requirements of the EU Birds Directive and the EU Habitats Directive.

Lead officer contact

Steve Hewlett Head of Integrated Transport Ext: 1103 Email: [email protected] .

Background papers

• Reports to Cabinet dated 17 February 2009 and Full Council dated 5 March 2009

• Thames Estuary Airport Feasibility Review (prepared by Douglas Oakwevee MBE, dated October 2009)

• Related web sites:

- Campaign website: www.stopestuaryairport.co.uk - Thames Estuary Airport – Feasibility Review: http://www.testrad.co.uk

Appendix A - Major Option Assessment routes for Lower Thames Crossing

Thames Estuary airport: Oakervee feasibility review RSPB critique

An airport in this location is not a new idea; it has previously been considered and rejected, partly because of the ecological sensitivity of the Thames Estuary Location. The Thames Estuary has nine internationally important nature conservation designations, the majority of which relate to rare and vulnerable bird species.

The scale of potential effects would result in likely significant effects on protected habitats and species in the internationally designated nature conservation sites. These adverse effects would be very difficult, and in all probability, impossible to mitigate. Given the range of alternatives solutions to the airport available and in the absence of imperative reasons of overriding public interest, an airport in the Thames Estuary could not be consented without contravention of UK law on the protection of nature conservation. The RSPB therefore views the proposal as a totally unfeasible and impractical scheme.

Introduction An airport in the Thames Estuary has previously been considered in the Government’s 2003 Aviation White Paper, to which all key players, including the aviation industry, contributed. The White Paper conclusively ruled out an airport in the Thames Estuary.

Despite this however, London’s Mayor, Boris Johnson, requested a study into the feasibility of the potential for an airport in the Thames Estuary. Subsequently, Douglas Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October 2009.

From the very outset of London’s Mayor first raising the idea of developing a major new airport in the Thames Estuary, the RSPB has had serious concerns about the likely environmental consequences. However, the Feasibility Review falls short of adequately considering the likely environmental effects of such a proposal and thus the feasibility of creating an airport in the estuary. As such, the Review fails to alleviate the RSPB’s concerns regarding the likely direct and in-direct environmental effects, as well as the consequences on the UK’s ability to meet commitments to its climate change targets.

“When reviewing the Thames Estuary and the creation of a sustainable future for London and the South East of England…we must recognise the sensitivity of the environment and safeguard it to the best of our ability. The challenges we face in the Thames Estuary are complex and the approach needs to be rethought if we are to avoid leaving future generations an even bigger challenge with an even bigger price tag.” (page 21).

2 designated under EU Directive and protected accordingly. The estuary has the highest concentration of bird species in internationally important numbers in the south east. The diversity of waterbird species places the estuary in the top five internationally important sites in the UK, out of 143 recorded.

Whilst the Oakervee Review acknowledges the conservation importance and environmental sensitivities of the estuary, it wholly fails to comprehend the real implications of an airport in the estuary, instead choosing to adopt the line that the environmental harm arising from such an airport can be managed.

Thames activities/developments The Thames Estuary area is currently the focus of many existing activities including large-scale commercial port operations, minerals extraction, dredging, transportation, recreation and numerous energy projects. The area is also presently the focus for new developments in a variety of sectors including further large-scale port and energy projects.

3 airport in the Thames (on page 40), does not identify potential significant environmental harm as a “disadvantage”.

Instead, the Review proceeds with considering a broad location of a possible airport as approximately “7Km to 10Km north east of Whitstable in the direction of the Shivering Sands Fort and The Kentish Flats Wind Farm”.

Due to its location, the proposal has the potential to directly and indirectly impact on of a range of internationally protected nature conservation sites (Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and Ramsar sites), including: - Essex Estuaries SAC; - Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar; - Benfleet and Southend Marshes SPA and Ramsar; - Thames Estuary and Marshes SPA and Ramsar; - Medway Estuary and Marshes SPA and Ramsar; - The Swale SPA and Ramsar; - Thanet Coast SAC; and - Thanet Coast & Sandwich Bay SPA and Ramsar.

Designated for a wide range of species and habitats, these sites are also underpinned and protected by the national Site of Special Scientific Interest (SSSI) notification.

The Feasibility Review also identifies that access to the airport would be via new road and rail infrastructure from the Kent and Essex coastlines. Whilst not certain at this stage, it is suggested that tunnels would be utilised for the sea section of the routes. The broad location of these new infrastructure developments could potentially coincide with the Thanet Coast & Sandwich Bay SPA and Ramsar, The Swale SPA and The Swale SAC, on the Kent coastline in addition to the Benfleet and Southend Marses SPA and Ramsar, the Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar, and the Essex Estuaries SAC on the Essex coastline.

From loss of foraging, roosting and/or loafing habitat, through direct and indirect habitat loss and from increased human disturbance, bird populations could face decline in and around the Thames Estuary. This will have knock on effects for the environment and wider ecosystem because of the Thames Estuary’s international importance (being in the top five internationally important sites in the UK) due to the numbers of waterbirds found there during winter and on migration1.

Safety and bird strike The hazard to aircraft from bird strike is well known and at estuary sites, an obvious concern. The Feasibility Review, although recognising bird strike as an issue, suggests it is solvable:

1 Waterbirds in the UK 2006/07 – The Wetland Bird Survey (WeBS), Graham Austin, Mark Collier, Neil Calbrade, Colette Hall and Andy Musgrove, British Trust for Ornithology, Revised edition (28 Aug 2008)

The RSPB considers it impossible to control bird strike risk for an airport in this location without “being aggressive towards birds”, since attempting to control the risk of bird strike will require many invasive techniques, including intensive and wide spread bird scaring.

In the RSPB’s response to the Air Transport White Paper in 20032, we drew attention to our concerns regarding aircraft safety at an airport at Cliffe, which was to be located in the midst of the Greater Thames (in a similar position to that of a possible Thames Estuary airport).

With regards to an airport at Cliffe and the 2003 Air Transport White Paper, several studies were undertaken to assess bird strike, including research commissioned by the Secretary of State for Transport. All studies concluded a significant risk of bird strike, with the Secretary of State’s report (by CSL and BTO, published in March 2003) concluding that:

• “Without a comprehensive and aggressive bird management programme in place, incorporating careful and considered airport design, appropriate habitat management and active bird control, an airport could not operate safely in this location.

• Even with such world class management and mitigation measures in place, the hazard posed by birds is severe and would probably be higher than at any other major UK airport.”

Pages 203-4 of the CSL/BTO report place this in perspective. The expected number of damaging bird strikes at an airport at Cliffe would be between 2.97 and 8.65 per year, whilst total hull loss would be expected to occur between 1 in 102 years and 1 in 297 years. Yet, for ten of the largest civil airports in the UK, the estimated rate of total hull loss is between 1 in 304 and 1 in 1210 years, with a mean of 1 in 653.5 years.

2 Future Development of Air Transport in the UK – South East (Second Edition), RSPB consultation, May 2003

In other words, the hazard associated with the Cliffe option was, at best, equal to the greatest risk at any of the top ten UK civil airports in 2003 and, at worst, the level of risk was up to 12 times higher. And this is with a bird hazard management regime in place which would have a major adverse impact on the waterfowl and waterfowl habitats of the SPA.

The RSPB therefore concluded that the level of bird strike risk associated with the Cliffe option was unacceptable, in terms of human safety. We further concluded that the habitat modification and active bird scaring measures associated with reducing the level of bird strike risk even to this unacceptably high level was also wholly unacceptable in terms of its implications for the SPA.

With many similarities between possible airports at Cliffe and in the Thames Estuary, we are very concerned that the risk of bird strike could be of at least a similar scale and nature.

A key consideration in assessing bird strike risk is bird flight lines. However, the Feasibility Review does not attempt to provide any primary information on bird movement within the broad airport location, but instead makes reference to flight path mapping provided by MetroTidal:

“MetroTidal in their studies have produced a map of the flight paths across the estuary and is included as Figure 20 below. If this is representative of the actual situation it would appear that the likely location is relatively free from bird movements. This coincides with my own visit to the area” (page 51)”.

It is very concerning that the conclusion is reached that “the likely location is relatively free from bird movements” when the MetroTidal study appears to relate to a location further to the west of the broad airport location. Furthermore, the robustness of the MetroTidal data is unclear, as no details are provided on the timing or duration of the study.

Decision making With any proposal for an airport in the Thames Estuary, the Habitats Regulations 19943 (among other requirements such as environmental impact assessment) will apply. And as such the relevant competent authority will have to determine whether the project is likely to have a significant effect on either the Ramsar sites4, the SPAs, pSPA5 and/or the

SACs (known collectively as the European sites) either alone or in combination with other plans or projects6.

If the project is likely to have such an effect there is a legal duty for the competent authority to make an appropriate assessment of the implications for the European sites in view of those sites’ conservation objectives. The project can only receive permission if it can be ascertained that it will not adversely affect the integrity of the European sites7.

However, whilst there may be some mitigation measures available to avoid and/or reduce the harm, providing “equal habitats” will only compensate for the harm/loss rather than avoid or reduce the harm. The RSPB believes that many effects of such a proposal on protected species cannot be mitigated, and therefore adverse effects cannot be avoided.

The RSPB believes that there are alternatives solutions to the project and that there are no imperative reasons of overriding public interest. Finally, we believe it would also be extremely challenging, if not impossible, to replicate the habitats lost elsewhere.

5 Government Policy affords the same level of protection for a pSPA as it would a designated SPA 6 Regulation 48(1) of the Habitats Regulations 7 Regulation 48(5) of the Habitats Regulations

Climate change The RSPB welcomes the Feasibility Review’s acknowledgement of the seriousness of climate change and the recognition of the scale of reductions in emissions required:

“Recent revisions to government policy with respect to climate change and the requirement for an 80% reduction in carbon emissions by 2050 must be the driving force behind many major decisions and how we live in the years to come.” (Page 23).

Such a proposal will lock the UK into yet more carbon-intensive infrastructure for decades. If the airport were to be progressed therefore, it would place a huge and expensive burden on other sectors of the economy to decarbonise even further to account for the contribution from aviation.

In any serious proposal, we would expect to see detailed analysis of the carbon cost of building and operating the airport, together with measures for mitigating the substantial carbon release. However, we do not believe that a development of this size or nature could adequately mitigate these impacts in an increasingly carbon-constrained world.

Conclusion We are very concerned that the Thames Estuary is even being considered as a location for a new international airport. The proposal is likely to harm the sensitive estuarine habitats and species of the designated sites through habitat loss, noise disturbance and atmospheric pollution.

Given the evidence of the impacts of climate change on biodiversity and the significant and rapidly increasing contribution aviation is making to global warming, the RSPB also

8 The proposed airport would be some 96 km to Charing Cross, whilst Heathrow is only 28 km and Gatwick 47 km from Charing Cross.

9 has serious concerns that a new airport is likely contribute to environmental degradation via exacerbating climate change and would seriously hamper all attempts to cut the UK’s greenhouse gas emissions.