LONDON ASHFORD AIRPORT

LONDON ASHFORD AIRPORT AT RUNWAY EXTENSION

ENVIRONMENTAL STATEMENT

December 2006

Prepared for Prepared by London Ashford Airport Parsons Brinckerhoff Ltd Lydd Airport Parnell House Ashford 25 Wilton Road Kent London SW1V 1LW TN29 9QL

LONDON ASHFORD AIRPORT

RUNWAY EXTENSION

ENVIRONMENTAL STATEMENT

December 2006

Prepared for Prepared by London Ashford Airport Parsons Brinckerhoff Ltd Lydd Airport Parnell House Ashford 25 Wilton Road Kent London SW1V 1LW TN29 9QL LAA

RUNWAY EXTENSION ES

ENVIRONMENTAL STATEMENT - TABLE OF CONTENTS

Page GLOSSARY OF ABBREVIATIONS AND TERMS

1 INTRODUCTION 1

2 EIA METHODOLOGY 24

3 LYDD AIRPORT 29

4 PROJECT DESCRIPTION 39

5 PLANNING POLICY FRAMEWORK 55

6 GROUND CONDITIONS 90

6.1 Introduction 91

6.2 Legislative Drivers 91

6.3 Assessment Methodology 92

6.4 Baseline Environment (Existing Conditions Scenario) 93

6.5 Baseline Environment (Future Assessment Conditions Scenario) 96

6.6 Predicted Impacts (Construction Works) 96

6.7 Predicted Impacts (Operational Impacts) 97

6.8 Proposed Mitigation (Construction Impacts) 97

6.9 Proposed Mitigation (Operational Impacts) 99

6.10 Residual Effects 99

6.11 Summary 99

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7 WATER RESOURCES AND FLOOD RISK 101

7.1 Introduction 102

7.2 Legislative Drivers 102

7.3 Assessment Methodology 103

7.4 Baseline Environment (Existing Conditions Scenario) 103

7.5 Baseline Environment (Future Assessment Conditions Scenario) 109

7.6 Predicted Impacts (Construction Works) 111

7.7 Predicted Impacts (Operational Impacts) 112

7.8 Proposed Mitigation (Construction Impacts) 113

7.9 Proposed Mitigation (Operational Impacts) 114

7.10 Residual Effects 115

7.11 Summary 115

8 SOLID WASTE MANAGEMENT 117

8.1 Introduction 118

8.2 Legislative Drivers 118

8.3 Baseline Environment (Existing Conditions Scenario) 123

8.4 Baseline Environment (Future Assessment Conditions Scenario) 123

8.5 Predicted Impacts (Construction Works) 124

8.6 Predicted Impacts (Operational Impacts) 125

8.7 Proposed Mitigation (Construction Impacts) 126

8.8 Proposed Mitigation (Operational Impacts) 127

8.9 Residual Effects 129

8.10 Summary 130

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9 LAND USE 131

9.1 Introduction 132

9.2 Legislative Drivers 133

9.3 Assessment Methodology 135

9.4 Baseline Environment (Existing Conditions Scenario) 140

9.5 Baseline Environment (Future Assessment Conditions Scenario) 140

9.6 Predicted Impacts (Construction Works) 141

9.7 Predicted Impacts (Operational Impacts) 141

9.8 Proposed Mitigation (Construction Impacts) 141

9.9 Proposed Mitigation (Operational Impacts) 141

9.10 Residual Effects 142

9.11 Summary 142

10 ECOLOGY AND NATURE CONSERVATION 143

10.1 Introduction 144

10.2 Legislative Drivers 144

10.3 Assessment Methodology 145

10.4 Baseline Environment (Existing Conditions Scenario) 153

10.5 Baseline Conditions (Future Assessment Conditions Scenario) 162

10.6 Predicted Impacts (Construction Works) 163

10.7 Predicted Impacts (Operational Impacts) 166

10.8 Proposed Mitigation (Construction Impacts) 170

10.9 Proposed Mitigation (Operational Impacts) 173

10.10 Residual Effects 174

10.11 Summary 175

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11 BIRD CONSERVATION AND HAZARD MANAGEMENT 176

11.1 Introduction 177

11.2 Legislative Drivers 177

11.3 Assessment Methodology 178

11.4 Baseline Environment (Existing Conditions Scenario) 187

11.5 Baseline Environment (Future Assessment Conditions Scenario) 210

11.6 Predicted Impacts (Construction Works) 211

11.7 Predicted Impacts (Operational Impacts) 212

11.8 Proposed Mitigation (Construction Impacts) 216

11.9 Proposed Mitigation (Operational Impacts) 216

11.10 Residual Effects 221

11.11 Summary 222

12 LANDSCAPE AND VISUAL AMENITY 224

12.1 Introduction 225

12.2 Legislative Drivers 225

12.3 Assessment Methodology 225

12.4 Baseline Environment (Existing Conditions Scenario) 230

12.5 Baseline Environment (Future Assessment Conditions Scenario) 235

12.6 Predicted Impacts (Construction Works) 236

12.7 Predicted Impacts (Operational Impacts) 238

12.8 Proposed Mitigation (Construction Impacts) 239

12.9 Proposed Mitigation (Operational Impacts) 239

12.10 Residual Effects 239

12.11 Summary 239

Table 12.4 241

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13 CULTURAL HERITAGE AND HISTORIC ENVIRONMENT 248

13.1 Introduction 249

13.2 Legislative Drivers 249

13.3 Assessment Methodology 252

13.4 Baseline Environment (Existing Conditions Scenario) 255

13.5 Baseline Environment (Future Assessment Conditions Scenario) 261

13.6 Predicted Impacts (Construction Works) 262

13.7 Predicted Impacts (Operational Impacts) 263

13.8 Proposed Mitigation (Construction Impacts) 263

13.9 Proposed Mitigation (Operational Impacts) 263

13.10 Residual Effects 263

13.11 Summary 264

14 TRAFFIC AND TRANSPORT 265

14.1 Introduction 266

14.2 Legislative Drivers 266

14.3 Assessment Methodology 266

14.4 Baseline Environment (Existing Conditions Scenario) 270

14.5 Baseline Environment (Future Assessment Conditions Scenario) 274

14.6 Predicted Impacts (Construction Works) 279

14.7 Predicted Impacts (Operational Impacts) 279

14.8 Proposed Mitigation (Construction Impacts) 285

14.9 Proposed Mitigation (Operational Impacts) 285

14.10 Residual Effects 287

14.11 Summary 288

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15 AIR QUALITY 289

15.1 Introduction 290

15.2 Legislative Drivers 292

15.3 Assessment Methodology 294

15.4 Baseline Environment (Existing Conditions Scenario) 301

15.5 Baseline Environment (Future Assessment Conditions Scenario) 306

15.6 Predicted Impacts (Construction Works) 310

15.7 Predicted Impacts (Operational Impacts) 311

15.8 Proposed Mitigation (Construction Impacts) 316

15.9 Proposed Mitigation (Operational Impacts) 317

15.10 Residual Effects 318

15.11 Summary 318

16 NOISE AND VIBRATION 320

16.1 Introduction 321

16.2 Legislative Drivers 321

16.3 Assessment Methodology 321

16.4 Baseline Environment (Existing Conditions Scenario) 328

16.5 Baseline Environment (Future Assessment Conditions Scenario) 331

16.6 Predicted Impacts (Construction Works) 333

16.7 Predicted Impacts (Operational Impacts) 335

16.8 Proposed Mitigation (Construction Impacts) 341

16.9 Proposed Mitigation (Operational Impacts) 341

16.10 Residual Effects 342

16.11 Summary 342

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17 SOCIO-ECONOMIC 343

17.1 Introduction 344

17.2 Assessment Methodology 344

17.3 Baseline Environment (Existing Conditions Scenario) 349

17.4 Baseline Environment (Future Assessment Conditions Scenario) 363

17.5 Predicted Impacts (Construction Works) 363

17.6 Predicted Impacts (Operational Impacts) 364

17.7 Proposed Mitigation (Construction Impacts) 369

17.8 Proposed Mitigation (Operational Impacts) 369

17.9 Residual Effects 369

17.10 Summary 369

18 CUMULATIVE IMPACTS 371

18.1 Introduction 372

18.2 Legislative Drivers 372

18.3 Assessment Methodology 372

18.4 Baseline Environment (Existing Conditions Scenario) 373

18.5 Summary 379

19 SUMMARY TABLES 380

19.1 Construction Mitigation 381

19.2 Operation Mitigation 387

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RUNWAY EXTENSION ES

RUNWAY EXTENSION ES – LIST OF FIGURES

LYDD AIRPORT 3.1 Airport Location 3.2 Current Facilities 3.3 Existing Circuit Patterns 3.4 ILS Non-Directional Beacon 3.5 ILS Approach Offset

PROPOSED DEVELOPMENT 4.1 Drainage Strategy - Land Drainage Proposals 4.2 Drainage Strategy – Proposed Runway Drainage 4.3a Proposed Development Footprint 4.3b Proposed Development Footprint 4.4 Proposed Carparking to Accommodate 300,000 Passengers

GROUND CONDITIONS 6.1 Soil Types 6.2 Geology Map 6.3 Groundwater Vulnerability 6.4 Proposed and Existing SSSI and California Bearing Ratio (CBR) Test Locations

WATER RESOURCES AND FLOOD RISK 7.1 River Quality Targets Measuring Points & Standing Surface Water 7.2 Flood Zones and Coastal Defence

LAND USE 9.1 Land Usage Map 9.2 Agricultural Land

ECOLOGY AND NATURE CONSERVATION 10.1a Designated Sites of Nature Conservation Importance 10.1b Proposed Designated Sites of Nature Conservation Importance 10.2 Phase I Habitat Map 10.3 Habitat Map Target Notes 10.4 Protected and Uncommon Fauna and Flora of the Lydd Airport Site and Surrounds 10.5 Bats of the Lydd Airport Site and Surrounds 10.6a Aquatic Mammals Survey 10.6b Aquatic Mammals Survey (North)

BIRD CONSERVATION AND HAZARD MANAGEMENT 11.1 Breeding Birds Survey Area (2006) 11.1 Breeding Birds Survey Results Legend (2006) 11.1 (A1) Breeding Birds Survey Results (2006) 11.1 (A2) Breeding Birds Survey Results (2006) 11.1 (A3) Breeding Birds Survey Results (2006) 11.1 (B1) Breeding Birds Survey Results (2006) 11.1 (B2) Breeding Birds Survey Results (2006) 11.1 (C) Breeding Birds Survey Results (2006) 11.1 (D) Breeding Birds Survey Results (2006) 11.1 (E1) Breeding Birds Survey Results (2006) 11.1 (E2) Breeding Birds Survey Results (2006) 11.1 (E3) Breeding Birds Survey Results (2006) 11.1 (F1) Breeding Birds Survey Results (2006) 11.1 (F2) Breeding Birds Survey Results (2006) 11.1 (G) Breeding Birds Survey Results (2006) 11.2 Overwintering Birds Survey Area 11.3 Local Sites of Ornithological Interest 11.4 Safeguarding Areas 11.5 Breeding Birds Survey Results (2005)

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LANDSCAPE AND VISUAL AMENITY 12.1 Zone of Visual Influence

CULTURAL HERITAGE AND HISTORIC ENVIRONMENT 13.1 Sites of Archaeological Interest 13.2 Historic Ordnance Survey maps (A) 13.3 Historic Ordnance Survey maps (B)

TRAFFIC AND TRANSPORT 14.1 Home Borough of South East Air Passengers 14.2 Drive Time Catchment of London Ashford Airport 14.3 Distribution of Vehicle Trips on Surrounding Road Network 14.4 Locations of Traffic Surveys 14.5 Hammonds Corner - 2005 Flows (August Average) 14.6 Hammonds Corner - 2007 Flows with 300,000 Passengers per annum without Runway Extension 14.7 Hammonds Corner - 2009 Flows with 300,000 Passengers per annum with Runway Extension 14.8 Proposed Construction Vehicle Route 14.9 Proposed Junction Improvements to Hammonds Corner Roundabout 14.10 Traffic Flow Increases

AIR QUALITY 15.1 Study area and selected residential and sensitive receptors 15.2 Wind roses for Herstmonceaux for 1997 to 2001 3 15.3 Total ambient air annual mean nitrogen dioxide (NO2) concentrations (μg/m ), based on current (2005) airport activities.

15.4 Annual mean nitrogen deposition from local sources (kgN/ha/yr), based on current (2005) airport activities. 3 15.5 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ), based on baseline airport activities. 3 15.6 Total Ambient Air Annual Mean Nitrogen Dioxide (NO2) Concentrations (μg/m ) based on LAA serving 300,000 Passengers per annum without the runway extension 15.7 Annual Mean Nitrogen Deposition from Local Sources (kgN/ha/yr) based on LAA serving 300,000 Passengers per annum without the runway extension. 3 15.8 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ), based on LAA serving 300,000 Passengers per annum without the runway extension. 3 15.9 Total Ambient Air Annual Mean Nitrogen Dioxide (NO2) Concentrations (μg/m ) based on LAA serving 300,000 Passengers per annum with the runway extension. 15.10 Annual Mean Nitrogen Deposition from Local Sources (kgN/ha/yr) based on LAA serving 300,000 passengers per annum with the runway extension 3 15.11 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ), 300,000 Passengers with the runway extension. 15.12 Roadside concentrations of nitrogen dioxide (NO2) and particulates (PM10), predicted for the B2075 between Hammonds Corner and the Lydd airport approach road. 15.13 Roadside concentrations of nitrogen dioxide (NO2) and particulates (PM10), predicted for the A259 through the centre of New Romney

NOISE & VIBRATION 16.1 Baseline Noise Monitoring Positions 16.2 INM Noise Contours - Baseline 16.3 INM Noise Contours - 300,000 Passengers without Runway Extension 16.4 INM Noise Contours - 300,000 Passengers with Runway Extension 16.5 Indicative Night Time Noise Contours

SOCIO-ECONOMIC ISSUES 17.1 Education and Health Services for Lydd and the Surrounding Area

CUMULATIVE IMPACTS 18.1 Cumulative Impacts - Proposed and Existing Developments

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RUNWAY EXTENSION ES

RUNWAY EXTENSION ES – LIST OF PLATES

LANDSCAPE AND VISUAL AMENITY

Plate 12.1 View 1. Looking south west from dune tops at the back of Greatstone-on-Sea public car park Plate 12.2 View 2. Looking west from the west end of Baldwin Road, Greatstone-on-Sea Plate 12.3 View 3. Looking North West from the shingle platform at the back of the caravan park in Greatstone-on-Sea at a point opposite the causeway to ‘The Mirrors’ Plate 12.4 View 4. Looking North West across the shingle ridges from the west end of Taylor Road, Lydd-on-Sea Plate 12.5 View 5. Looking North West from ‘The Mirrors’ information plaques Plate 12.6 View 6. Looking north from the northern extremity of the Dungeness shingle where it gives way to farmland Plate 12.7 View 7. Looking north east from the airport access road at the western corner of the airport Plate 12.8 View 8. Looking east from the public footpath that skirts the north west corner of Lydd Golf Course Plate 12.9 View 9. Looking south east from the public footpath between New Romney and Belgar Farm Plate 12.10 View 10. Looking south east from the B2075 Romney Road from its junction with Caldecot Lane Plate 12.11 View 11. Looking south from the eastern part of Church Lane on the southern edge of New Romney Plate 12.12 View 12. Looking south west from the west end of Baldwin Road, Greatstone-on-Sea at a twin- engined aircraft landing at Lydd Airport.

TRAFFIC AND TRANSPORT

Plate 14.1 B2075 junction with A259, looking towards A259 Plate 14.2 Give way markings on B2075 at A259 junction

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GLOSSARY OF ABBREVIATIONS

% Percent

< Less than

> Greater than

µg Microgram

AADT Annual Average Daily Traffic

ACI Airport Council International

ACN Aircraft Classification Number

AFFF-LF Aqueous Film Forming Foam – Low Freeze

AGL Aeronautical Ground Lighting

ALC Agricultural Land Classification

AONB Area of Outstanding Natural Beauty

APIS Air Pollution Information System

APU Auxilliary Power Unit

AQ Air Quality

AQS Air Quality Strategy

ATC Air Traffic Control

ATC Automated Traffic Counts

AVGAS Aviation Fuel

BAP Biodiversity Action Plan

BATNEEC Best Available Technology Not Entailing Excessive Cost

BPM Best Practicable Means

CAA Civil Aviation Authority

CDM Construction Design and Management Regulations

CEMP Construction Environmental Management Plan

CLEA Contaminated Land Exposure Assessment

COFAR Common Options for Airport Regions

CSM Conceptual Site Model dB Decibel

DEFRA Department of the Environment and Rural Affairs

DME Distance Measuring Equipment

DMRB Design Manual for Roads and Bridges

DTI Department of Trade & Industry

EA Environment Agency

EIA Environmental Impact Assessment

EPA 1990 Environment Protection Act 1990

ES Environmental Statement

EU European Union

FIS Flight Information Service

FOE Friends of the Earth

Ft Foot/Feet

FTE Full Time Equivalent

GDP Gross Domestic Product

GR Grid

Ha Hectare

HGBI Herptofauna Groups of Britain and Ireland

HGV Heavy Goods Vehicle

HLC Historic Landscape Characterisation

HSE Health & Safety Executive

Ibid Ibidem (Latin) as previously cited

ICAO International Civil Aviation Organisation

IDB Internal Drainage Board

IEEM Institute of Ecological & Environmental Management

IKF Integrated Kent Franchise

ILS Instrument Landing System IMD Index of Multiple Deprivation

Impact Effect on identified receptor

K Thousand

KCC Kent County Council

Keq Constant (called the equilibrium constant)

KM Kilometre

KMBRC Kent & Medway Biological Records Centre kVA Kilo Volt Amps

KWT Kent Wildlife Trust

Lmax Maximum sound level

LA90 Equivalent Continuous Noise Level – representing the Sound Pressure Level exceeded 90% of the time

Leq Equivalent Continuous Noise

LAA London Ashford Airport At Lydd

LAQM Local Air Quality Management

LATS Landfill Allowance Trading Scheme

LDD Local Development documents

LLA Local Landscape Area

LNR Local Nature Reserve

LPA Local Planning Authority

LTMA London Terminal Manoeuvring Area

LTO Landing and Take-off m Metre m2 Square metres m3 Cubic metres mm Millimetres

N Nitrogen

NAQIA National Air Quality Information Archive NAQS National Air Quality Strategy

NDB Non-Directional beacon

NE North East

NMR National Monuments Record

NMVOC Non-methane Volatile organic Compounds

NNR National Nature Reserve

NO2 Nitrogen Dioxide

NOx Nitrous Oxides

NTS Non Technical Summary o Degrees

ODPM Office of the Deputy Prime Minister now Department for Communities and Local Government

OEF Oxford Economic Forecasting

OSL Optically Stimulated Luminescence

PaH Polycyclic Aromatic Hydrocarbons

PAPI Precision Approach Path Indicator

PB Parsons Brinckerhoff Limited`

PCN Pavement Classification Number

PM Particulate Matter

PPA Passengers Per Annum

PPB Parts per billion

PPC Pollution Prevention Control

PPE Personal Protective Equipment

PPG Planning Policy Guidance

PPS Planning Policy Statement

RASCO Regional Air Services Co-Ordination Study

RESA Runway Extension Safety Area

RFC Ratio to Flow Capacity RFFS Rescue Fire Fighting Services

RPA Rural Priority Area

RPB Regional Planning Bodies

RPB Regional Planning Body

RPG Regional Planning Guidance

RPG Regional Planning Guidance

RSPB Royal Society for the Protection of Birds

RW Runway

SAC Special Area of Conservation

SAM Scheduled Ancient Monument

SCP Sustainable Consumption and Production

SDC Shepway District Council

SEEDA South East England Development Agency

SEERA South East Regional Assembly

SEERA South East England Regional Assembly

SEETB South East England Tourist Board

Sewer Local term for drainage ditch

SI Statutory Instrument

SLA Special Landscape Area

SMR Sites and Monuments Record

SO2 Sulphur Dioxide

SOx Sulphur Oxide Gases

SPA Special Protection Area

SSSI Site of Special Scientific Interest

SWMP Site Waste Management Plan

TA Transport Assessment

TSE Tourism South East UKBAP United Kingdom Biodiversity Action Plan

VOCs Volatile Organic Compounds

VOR VHF Omnidirectional Radio

WCA Wildlife & Countryside Act 1981

WRAP Waste Resources Action Plan

ZVI Zone of Visual Influence

GLOSSARY OF TERMS

GLOSSARY OF LAA TERMS RUNWAY EXTENSION ES

Ambient Noise The totally encompassing sound in a given situation, at a given time, including noises from any source in any direction.

ADMS 3 Industrial Air Pollution Model modelling the impact of existing and proposed industrial installations

Area source A real or theoretical source that radiates as a plane. Sound from an area source radiates plane waves rather than spherical waves, particularly if the area source is large relative to the wavelength of the sound produced.

A-Weighting Generally, the ear is most sensitive to frequencies in the range 1 to 4 kHz. The A-weighting is a filter that can be applied to measured results at varying frequencies, to mimic the frequency response of the human ear, and therefore better represent the likely perceived loudness of the sound. SPL readings with the A-weighting applied are represented in dB(A).

Background Noise This is defined as the LA90 of the residual noise.

Biodiversity Action The Biodiversity Action Plan is the UK's initiative to maintain and enhance Plan biodiversity. Natural England and other organisations from across all sectors are committed to achieving the Plan's conservation goals over the next 20 years and beyond.

Baseline Studies1 Studies of existing environmental conditions against which any future changes can be measured or predicted.

Clear Area This is an area clear of all obstructions to a very low flying aircraft during an aborted landing or in an emergency take off situation.

Clinical waste Any waste defined in accordance with the Collection and Disposal of Waste Regulations 1998 and the Controlled Waste Regulations 1992 (as amended)

Controlled Waste A broad category of waste that is subject to Environment Agency regulation. Controlled wastes include inert , hazardous , non-hazardous , and clinical waste sub-categories

Cumulative Impact Impacts that result from incremental changes caused by other past, present or reasonably foreseeable future actions together with the project.

Do Nothing1 Predicted future environmental conditions which would exist in the absence of the development

Environmental A process in which information on the environmental effects of a project is Assessment1 collected and taken into account by decision makers

Ecosystem1 Community of interdependent plants and animals interacting in their environment

Environmental Assessment of the likely effects of a project on the environment. The Statement Statement1 is submitted by the developer in conjunction with an application for planning permission

LAA

GLOSSARY OF TERMS RUNWAY EXTENSION ES

Environmental Consequences for human being in terms of health and well-being, including that Effects1 of ecosystems and natural systems on which human survival depends resulting from the environmental impacts

Environmental The processes whereby a change, which may be adverse, beneficial, or both is Impacts1 brought about in the existing environment as a result of development activities

Equivalent The Equivalent Continuous Level represents a theoretical continuous sound, Continuous Level over a stated time period, T, which contains the same amount of energy as a (Leq,T) number of sound events occurring within that time, or a source that fluctuates in level.

For example, a noise source with an SPL of 80 dB(A) operating for two hours during an eight-hour working day, has an equivalent A-weighted continuous level over eight hours of 74 dB, or LAeq,8hrs = 74 dB.

The time period over which the Leq is calculated should always be stated.

Fauna1 All members of the animal kingdom including vertebrates (birds, mammals and fish) and invertebrates (insects)

Flora1 Members of the plant kingdom including ferns, mosses, and liverworts, algae and phytoplankton, fungi and lichens

General Aviation All civil aviation operations other than scheduled air services and non-scheduled air transport operations for remuneration or hire.

Graded Area Clear and Graded area is clear of all obstructions to a very low flying aircraft during an aborted landing or an in an emergency take off situation, which is also (Clear and Graded graded to ensure that it can be accessed by emergency vehicles. Area)

Hazardous Waste Defined by the Hazardous Waste (England and Wales) Regulations 2005 (as amended) and the Lists of Wastes (England) Regulations 2005 (as amended) and special measures apply to the management of such wastes

Inert waste Chemically inert, non-combustible, non-biodegradable and non-polluting waste as defined by the Landfill (England and Wales) Regulations 2002 (as amended)

Initial Noise Ambient prevailing noise in an area before any changes to the existing noise climate

Line Source A theoretical source of sound, with length only, often used to model long, thin sound sources, such as roads.

Loudness A subjective assessment differing individually. The human ear perceives loudness in a logarithmic fashion. Generally, a perceived doubling or halving of loudness will correspond to an increase or decrease in SPL of 10dB. Note that a doubling of sound energy corresponds to an increase in SPL of only 3dB.

Mitigation1 Any process, activity or thing designed to avoid, reduce or remedy adverse environmental impacts likely to be caused by a development project LAA

GLOSSARY OF TERMS RUNWAY EXTENSION ES

Noise A noise can be described as an unwanted sound. Noise can cause nuisance.

Noise Sensitive Any identified receptor likely to be affected by noise. These are generally human Receptors (NSR's) receptors, which may include residential dwellings, work places, schools, hospitals, and recreational spaces.

Non-hazardous any waste which is not hazardous or inert waste waste

Nitrous Oxides Nitrous Oxides formed during high temperature combustion processes from the oxidation of nitrogen in the air or fuel. The principal source of nitrogen oxides - nitric oxide (NO) and nitrogen dioxide (NO2), collectively known as NOx - is road traffic; other sources being power stations, heating plants and industrial processes.

Octave In reference to the frequency of a sound, an octave describes the difference between a given frequency and that which is double that frequency, e.g. 125Hz to 500Hz, or 4kHz to 8kHz.

Octave/Third A sound made up of more than one frequency can be described using a Octave Bands frequency spectrum, which shows the relative magnitude of the different frequencies within it. The possible range of frequencies is continuous, but can be split up into discrete bands, often an octave or third-octave in width. Each octave band is referred to by its centre frequency, generally 63Hz, 125Hz, 250Hz, 500Hz, 1kHz etc.

PaH Polycyclic Aromatic Hydrocarbons are members of a large group of organic compounds widely distributed in the atmosphere, whose molecular structures contain two or more aromatic rings fused together. Because of their low vapour pressures, some PAHs are present at ambient temperatures in air, both as gases and associated with particles. They are formed naturally in the environment, e.g. thermal geological reactions and natural fires and through human activities in all processes involving incomplete combustion of carbon- based fuels e.g. emitted during burning of common fuels, i.e. coal, oil, wood and gas. Tobacco smoke is an important source in indoor air.

Pathway1 The routes by which impacts are transmitted through air, water, soils or plants and organisms to their receptors

Point Source A theoretical source of sound, with zero size and mass, often used as an approximation to model small sources. Sound from a point source radiates spherically in all directions.

Potential Impacts1 Impacts which could occur in the absence of appropriate design modifications and preventative measures

Predicted Impacts1 Thos impacts which are predicted as a consequence of the development, although the nature and severity of their effect will be conditioned by the scope for mitigation

Producer Anyone whose activities produce waste or anyone who carries out pre- processing, mixing or other operations resulting in a change in the nature or composition of this waste LAA

GLOSSARY OF TERMS RUNWAY EXTENSION ES

Public Safety Zone The bulk of the effort to control risk in aviation has been concentrated at (PSZ) protecting the occupants of aircraft. It is only relatively recently that some governments and aviation authorities as a result of increasing aircraft activity and more accidents taking place near the runway thresholds, that are beginning to consider the risks to the public under flight paths in these areas.

Within the PSZ's there are safety benefits from preventing any new development or change of use, which would result in a significant increase in the numbers of people within the zone. The PSZ is based on a risk contour using a 15 year period of aviation forecasts, which allows for a reasonable period of stability after their introduction and allows for growth.

Not all countries have policies on PSZ’s as there are no recommendations by the ICAO on the subject. Some countries such the UK the policy on PSZ’s is administered by the Department of Transport. In the US Runway Protection Zones are established by the Federal Aviation Administration (FAA) and in Ireland by the Irish Aviation Authority (IAA)

Lydd Airport PSZ’s

Since the extent of the PSZ area is a function of aircraft movements, the 10-4 risk contours for 2 and 5mppa remain clear of developed areas with only few properties affected. But development to support higher throughputs, including significant runway extension would have substantial impact on residential areas to the NE of the airport. The shape and length of the PSZ has been taken from the SERAS report on Lydd Airport.

An example of the dimensions of a PSZ based on a 15 year aircraft movement forecast for Luton Airport is shown on Fig. 4.9

Ramsar The Convention on Wetlands of International importance, especially as Waterfowl Habitats, is an intergovernmental treaty that aims to stem the progressive encroachment on and loss of wetlands now and in the future.

Receptor1 A component of the natural or man made environment such as water, building, plant affected by impact

Recovery and Recovery and recycling means the recovery of waste into products, materials or Recycling substances whether for the original or other purposes. It does not include energy recovery. Commonly applied to non-hazardous wastes such as paper, glass, cardboard, plastics and metals. However, hazardous wastes (e.g. solvents) can also be recycled by specialist companies, or by in-house equipment

Residual Noise This is the ambient noise minus the specific noise, i.e. the remaining noise when the specific noise source is removed.

Restricted Zone This is the zone at the end of a runway where the Planning Authority may restrict the type of permitted development due to a possible increase in risk.

Reuse Reuse means any recovery operation by which products or components that have become waste are used again for the same purpose for which they were conceived; LAA

GLOSSARY OF TERMS RUNWAY EXTENSION ES

Runway Strip CAP 168 requires a cleared strip of 300m wide for instrument runways code 3 and 4. of which the first 105m from the centreline are graded and have sufficient (Clear and bearing strength to support an aircraft without causing major damage to the Runway Area) undercarriage of an aircraft in the event of an coming off the runway during take- off or landing.

The ILS being installed to serve runway 22 would require the establishment of the 300m wide strip. This would render unusable all of the existing aircraft parking apron to the southeast of the terminal area and the partial parallel taxiway (see figure 4.5). There are no other major problems associated with the establishment of an instrument runway strip at the airport.

Scoping1 Initial stage in determining nature and potential scale of environmental impacts arising from the proposed development, and assessing what further studies are required to establish their significance.

Sound Power The Sound Power Level defines the rate at which sound energy is emitted by a Level (SWL) source, and is also expressed in dB. It is defined as follows:

SWL (dB) = 10 Log10(W/Wref) where W = Sound Power (in Watts)

Wref = Reference Power 1 picoWatt

Sound Pressure The Sound Pressure Level has units of decibels, and compares the level of a Level (SPL) sound to the smallest sound pressure generally perceptible by the human ear, or the reference pressure. It is defined as follows:

SPL (dB) = 20 Log10(P/Pref) where P = Sound Pressure (in Pa)

Pref = Reference Pressure 2x10-5 Pa

An SPL of 0dB suggests the Sound Pressure is equal to the reference pressure. This is known as the threshold of hearing.

An SPL of 140dB represents the threshold of pain.

Sulphur Oxide Sulphur Oxide Gases formed when fuel containing sulfur (mainly coal and oil) is Gases burned and during metal smelting and other industrial processes.

Specific Noise A component of the ambient noise, associated with the specific source under investigation.

Treatment Recovery or disposal of waste

UKBAP United Kingdom Biodiversity Action Plan

Volatile Organic Defined as under the VOC Protocal (Geneva 1991) as “all organic compounds of Carbons anthropogenic nature, other than methane, that are capable of producing photochemical oxidants by reations with nitrous oxides in the presence of sunlight”. VOCs are involved in formation of ground level ozone and depletion of the ozone layer contributing to the greenhouse effect as methane and photochemical oxidants are greenhouse gases. LAA

GLOSSARY OF TERMS RUNWAY EXTENSION ES

Waste means any substance or object which the holder discards or intends or is required to discard

REFERENCE

1. Department of the Environment Planning Research Programme: Preparation of Environmental Statements for Planning Projects that require Environmental Assessment, A Good Practice Guide, HMSO 1995

CHAPTER 1

INTRODUCTION

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1 INTRODUCTION

1.1 Introduction

1.1.1 London Ashford Airport (LAA) at Lydd (formerly Lydd Airport) is located some 2km to the east of the town of Lydd, on the Dungeness Peninsula in the south east corner of Kent. The airport is licensed by the Civil Aviation Authority (CAA) and the capacity of LAA is determined by the existing terminal facilities which can currently support up to 300,000 passengers per annum1. Some 2,817 passengers passed through LAA in 2005, which was only a visual approach airport at the time, but the significant recent investment, and particularly the introduction of the automated instrument landing system (ILS), means that the airport is becoming increasingly attractive to airline companies and figures to date indicate that numbers have doubled over the last year. Indeed, historically the airport has seen up to 230,000 passengers per annum pass through its doors in peak years, and its new management structure has recently developed a business plan that, if successful, will see similar numbers passing through the airport in the near future.

1.1.2 To ensure a sustainable future for the airport, and in accordance with National Government requirements, LAA has developed a masterplan to cover proposed developments at the airport up to and including the year 2014. This masterplan, which has been lodged with the Department of Transport, the CAA and Shepway District Council, allows for the expansion of the airport to up to 2,000,000 passengers per annum2 in accordance with both national objectives and local planning policies. The masterplan layout is provided in Appendix 4.1.

1.1.3 As part of the long term aspiration, LAA proposes to increase the length of the existing north-south runway by just under 20% from 1505m to 1799m, and to add a new 150m starter extension to its northern end (“known as the Proposed Development and the Project”). These works, which are the subject of this Environmental Statement (ES), will not of themselves affect either the type of aircraft or numbers of passengers that will pass through the airport, but would allow any aircraft flying out of the airport to carry greater fuel loads, hence allowing them to service a greater range of (more distant) destinations than at present. Furthermore the increase in runway length will allow the same number of passengers to be carried with a smaller number of aircraft movements. This proposed runway extension is the subject of the current planning application and Environmental Statement (ES) and further details are provided in Chapter 4 of this document.

1.1.4 In addition to the Runway Extension, the Masterplan also includes proposals to build a new terminal building. A separate detailed planning application will be submitted for a new terminal building that will allow up to a maximum of 500,000 passengers per annum to pass through LAA. The terminal building planning application will be accompanied by its own ES assessing the impacts of the terminal building development. Although separate to this ES, the terminal building ES is cross-referred to in this ES.

1.1.5 As part of the supporting documentation for the Proposed Development planning application, Parsons Brinckerhoff Ltd (PB) have been commissioned to undertake an Environmental Impact Assessment (EIA) and prepare an ES for the Runway Extension. The ES (this document) should be read in conjunction with both the

1 This figure is based on the 1987 British Airports Authority’s (BAA) Report on Lydd Airport 2 The development of LAA to 2 million passengers would result in the airport being able to provide a service akin to those of some of the smaller regional airports such as Bristol.

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detailed planning application and other supporting documents, including the Transport Assessment (TA) and the Supporting Planning Statement whilst the masterplan should be referred to for a greater understanding of the long term proposals for the airport.

1.1.6 It should be noted that whilst the proposed runway extension and terminal buildings are both included within the Masterplan, neither is reliant upon the other for its commercial viability, and the runway extension will of itself just reduce the number of flights needed to achieve whatever total number of passengers the terminal can support. The applications are therefore not be considered to be inter-dependent, and for this reason, whilst this ES and the proposed terminal building ES do cross reference each other, they have not been combined within a single volume as either of the components may proceed without the other in accordance with good business practice.

1.2 The Environmental Impact Assessment Process

1.2.1 The high sensitivity of the Dungeness area, in terms of both human and ecological receptors, means that environmental considerations have been identified as being of key importance from the outset of the Proposed Development and have been taken into account throughout the development of the Proposed Development design.

1.2.2 The statutory requirement to undertake an Environmental Impact Assessment (EIA) for the Proposed Development is set out in the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, SI 1999 No 293 as amended by the Town and Country Planning (Environmental Impact Assessment) (England and Wales) (Amendment) Regulations 2000, SI 2000 No 2867 (together known as "the Regulations"). The Regulations apply to two separate lists of projects:- (i) "Schedule 1 projects" for which an Environmental Impact Assessment is required in every case and (ii) "Schedule 2 projects" for which an Environmental Impact Assessment is required only if the particular project in question is judged likely to give rise to significant environmental effects. It is considered that the proposed development does not come within Schedule 1 of the Regulations. However, the proposed development does fall within paragraph 10(e) of Schedule 2 of the Regulations, being the construction of airfields where the threshold is the extension to the runway. Following discussions with the Local Authority, Shepway District Council (SDC), it is agreed that the proposed development is likely to give rise to significant environmental effects and accordingly SDC has made a request for an environmental statement to be submitted with the planning application. Additionally, whilst the airport has a number of Permitted Development Rights (see Section 1.4) these do not include major changes to runway layouts.

1.2.3 The EIA has been undertaken bearing in mind national and international best practice guidance such as the Environment Agency’s ‘Scoping Guidelines on EIA of Projects’ (2002). Within each chapter of the ES appropriate consideration has been paid to the range of impacts that could arise during both construction and operation of the proposed facilities.

1.2.4 The EIA process itself has provided a procedural and management technique to allow consideration of the potential environmental effects of the proposed development and to allow development of appropriate mitigation to manage any adverse effects. It has involved extensive compilation, evaluation and presentation of all the likely significant environmental effects and is intended to assist SDC to consider and determine the planning application.

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1.2.5 The key EIA stages, each of which is described in more detail below3, include the following:

• Project Screening

• Project Scoping

• The EIA (Baseline data collection, Predicted Impacts, Mitigation, Reporting)

• Stakeholder Consultation

Project Screening

1.2.6 As described above, the Proposed Development is considered to be a Schedule 2 Project under the Regulations. As such, and given the environmental sensitivity of the region and the potential for likely significant environmental impacts, it was agreed with SDC that it should be subject to an EIA.

Project Scoping

1.2.7 Scoping is a process used to identify at an early stage, from all the project’s possible impacts, those that are the significant issues requiring greatest attention in the further assessment. For the proposed runway extension, the project scoping has involved both a review of previous studies in the area and consultation with key organisations. A detailed Scoping Report was produced (see Appendix 1.1) and submitted to SDC on 26th August 2005. A formal scoping opinion was received from SDC on the 19th December 2005 and the issues raised have been addressed in this ES wherever practical.

3 Detailed assessment methodologies are provided in Chapter 5.

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Table 1.1 Scoping Opinion Comments (Runway Extension)

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1 Different alternatives to the proposals at LAA, should be examined (for example, An analysis of alternatives is included in Chapter 4 to address 4.5 alternative sites and layouts, construction practices, plant and equipment and these issues. The “Future Assessment Conditions” has also been operating processes.) The “do nothing” scenario should also be addressed. included as a representing the “do-nothing “scenario as the airport has the ability to grow to 300 000 passengers without or without the proposed project. This scenario is addressed in each chapter.

Alternative airport locations are also addressed and are part of the 4.4 project needs case

2 It is useful to consider the distribution to all residencies of the NTS, Information on the public consultation programme is 1.3 details of public exhibitions /meetings to be held, where to obtain or view summarised in Chapter 1. the ES, methods available to comment upon the proposals and potential 1.7 environmental impacts.

3 The EIA should include implementation of mitigation measures, assessment of This is addressed within each chapter as appropriate. All the effectiveness in minimising significant adverse impacts, and prediction of any residual impacts should be included throughout.

4 Environmental Management Plans (EMP) should be developed to outline Key issues to be included in EMPS are addressed within each All monitoring impacts and demonstrate compliance with legislation e.g. noise. chapter as appropriate. The development of approved construction and operation EMPs are expected to be requirements of any planning consents agreed.

5 Uncertainties in predicting impacts or success of mitigation measures should be Limitations in the assessment methodologies are addressed within All highlighted. each chapter as appropriate.

6 Details of current operations should be included, including information on Details of current operations are addressed in Chapter 3. Noise 3.5 passenger numbers, hours of operation, flight types, frequency of flights, flight levels are addressed in Chapter 16. paths, aircraft types and noise levels. 16.4

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7 The layout of the airport and infrastructure, should be provided and illustrated Airport layout and infrastructure is provided in Figures 4.1 – 4.3. 4.2 within the context of land use. The dimensions and footprint of the proposed and local landuses are shown in Figure 9.1. Given the ecological terminal building should be provided and supported by drawings. A Landscape importance of the area, and the open nature of the landscape Plan should be provided. which is not suited to extensive planting, a habitat management plan (rather than Landscape Plan) is expected be developed in conjunction with Natural England as part of any planning conditions.

8 Environmental issues associated with current operations, and measures to Existing management measures are addressed in Chapter 4. All control them, e.g. complaints and noise should be addressed. Impacts associated with existing operations are included in each Chapter.

9 Other elements that will be required to deliver the stated objectives should be Additional elements to deliver the objectives are described in 4.2 included. Where relevant this should include issues such as runway safety Chapter 4. Potentially significant impacts associated with forecast margins, surface drainage, sewage disposal or management, water supply, passenger levels are included within each Chapter. All parking facilities, fuel storage areas, Instrument Landing System, access arrangements and further infrastructure, as well as potentially significant impacts assessed according to forecast passengers levels.

10 Proposals should be placed into the context of the overall airport masterplan and The overall Masterplan is described in Chapter 1 and a Masterplan 1.1 a masterplan should be provided to illustrate all components of the development Layout drawing is provided in Appendix 4.1. within the footprint of the LAA.

11 The EIA should assess both, the most likely design and the worst case design Following on from the analysis of alternatives, a single design has 4.6 (where applicable) as well as a likely timescale and an identification of conditions been proposed for the project (as described in Chapter 4) and this required for development to commence. has been used as the basis for the assessment. Rather, it is important to note that it is not correct to simply assess the worst case. It is the development proposal which must be assessed and the likely significant effect resulting.

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12 Lighting proposals should be discussed. These are addressed in Chapter 4, with visual impacts is included 4.2 within the overall evaluation and reported in Chapter 12 Table 12.4

13 The development should be assessed against national, regional and local This is addressed in Chapter 5. 5.3 – planning policies, and reference should be made to the Future of Air Transport 5.5 White Paper and the Civil Aviation Bill.

14 Changes to Policy TP25 Lydd Airport, should be reviewed and the proposal This is addressed in Chapter 5. 5.5 tested against the Policy and placed into the context of the maximum potential capacity that the airport can accommodate under existing permissions.

15 The applicant must demonstrate the need for the proposals, The need for the project is included in Chapter 4 . 4.4

16 The applicant must pay attention to regulations 48 and 49 of the Conservation of These are addressed in Chapter 10. 10.2 Natural Habitats Regulations (1994).

17 A Construction programme is required to include phasing and duration, main The construction programme and activities are addressed in 4.2 construction activities, (including piling), likely plant, numbers of vehicles Chapter 4. Construction impacts are addressed in each chapter. generated and distribution over the construction period, infrastructure Waste issues are specifically addressed in Chapter 8, and noise 8.5 requirements such as access arrangements and construction compounds, levels in Chapter 16. production of construction waste: types, estimates of volume and management (preferably reuse on site). Details of noise generating activities/equipment that 16.3 may result in significant impacts, e.g. auxiliary power units should be provided.

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18 Details are required of passenger forecasts, hours of operation, frequency of Anticipated flight details and passenger forecasts are addressed in 4.3 flights, anticipated aircraft types, anticipated flight types, noise levels from the Chapter 4. Noise levels are addressed in Chapter 16. Whilst engines, and flight paths. A range of scenarios should be discussed including busiest periods of the year will depend upon the business plans of 16.3 – the busiest period in the year, and worst case impacts. the airlines using the airport the worst case scenarios have been 16.5 referred to, though it is the predicted impact of the proposals that have been assessed.

19 Contamination issues should be considered including identification of areas with This is addressed in Chapter 6. Further soil investigations are 6.4 potential contamination from the historic use of the LAA site, and the potential for proposed as should the planning application be successful, and land contamination from construction and operational phases. Soils should be further risk assessment work and mitigation would be developed at 6.5 surveyed and analysed for likely contaminants and levels reported quantitatively. this point should adverse findings be reported. In case of land contamination the migration of contaminants should be assessed (including pathways and receptors) and mitigation measures should be developed if necessary together with prediction of residual impacts

20 A description should be included of important geological features, including This is addressed in Chapter 6. 6.4, areas proposed for inclusion in the SSSI because of their geomorphology. A 6.5 quantitative record should be provided of valuable geological features that will be removed, destroyed or damaged. Predicted impacts should be placed into regional, national or international resource available.

21 A description and illustration should be provided of watercourses and This is addressed in Chapter 7. 7.4 surroundings, including the surface drainage system and wetland habitats. Identification and illustration of any flood zone area and existing abstractions / Fig discharges should also be included. 7.1

22 The relationship between the watercourses and the ecological integrity of the This is addressed in Chapter 10. 10.4- surrounding habitats should be described. 10.5

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23 Identification of changes in surface drainage patterns and significant impacts to This is addressed in Chapters 7 and 10. 7.5 surrounding wetland habitats should be assessed. 10.4

24 Identification and assessment of potential pollutants during the construction and This is addressed in Chapter 7. It should be noted that, given the 7.4 operation, and significant impacts on water quality should be evaluated along unusual climatic conditions at Lydd, use of antifreeze is not with spillage of toxic pollutants during the construction and operational phases. - anticipated at this airport. 7.5 Runoff from runaways (e.g. antifreeze) and impacts on the environment, including any predicted changes to the volume of runoff and implications should be discussed.

25 Potential impacts/risk from new abstractions/discharges should be described. This is addressed in Chapter 7. No new abstractions / discharges 7.5 together with proposals for sewage disposal and water supply in order to ensure are envisaged as part of the current disposals. LAA understand compliance from the water company/sewage undertaker. New off site that the sewage undertakers are able to meet their needs. connections and potential routes of any pipes, and their impacts should be identified.

26 In case of flood risk assessment, reference should be made to PPG 25. This is addressed in Chapter 7. 7.2

27 The study area should cover all areas that could impact upon the current use of This is addressed in Chapter 9. 9.5 – land. A description and illustration should be provided of current land use, 9.7 including roads, public rights of way, watercourses, agricultural land and residential properties and settlements, and ecological and geological designated sites. Consideration should be made of direct impacts (e.g. loss of land) and indirect impact (e.g. land becoming unusable).

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28 Description should be provided of designated sites, characteristics of flora and This is addressed in Chapter 10. Account has been made of the 10.4 fauna including Dungeness SSSI, Dungeness SAC, Dungeness to Pett Level proposals to expand the SPA and the proposed Ramsar Special Protection Area (SPA). Possible Wetland of International Importance designations. under the Ramsar Convention. North Lade SSSI, Dungeness National Nature Reserve. The EIA should take into account that English Nature is working to expand the Dungeness to Pett Level Special protection Area (SPA) and is also proposed as a Ramsar Site.

29 If the Ramsar site has not been designated yet, and the extension of the SSSI This is addressed in Chapter 10 and the precautionary principle 10.5 has not been adopted, those areas need to be indicated on a map and has been applied. implications should be assessed. Further, the EIA should apply the Figs precautionary principle and assume that the SSSIs are extended and that the 10.1 Ramsar site is designated. The worst case situation should assume that the designation would occur prior to the granting of planning permission and commencement of construction. 10.2

30 A desk based study and an extended phase 1 ecological survey of the site and This is addressed in Chapter 10. An extended phase 1 has been 10.3 surroundings should be undertaken. NVC surveys should be undertaken of done of the entire site and additional lower plant surveys also habitats to be totally lost to the proposal. Specialist surveys of lichens and undertaken. NVC surveys were undertaken of areas of greater bryophytes also requested. ecological interest.

31 Surveys should be undertaken of reptiles, amphibians (in particular great crested This is addressed in Chapter 10. The surveys have been carried 10.3 newts), terrestrial and aquatic invertebrates, mammals (including badgers, bats, out as requested. otter and water vole). The ecological make up of all water bodies including ditches, ponds and sewers should be described. All surveys should be carried out by specialists at appropriate time of the year, over a sufficient time period and at a sufficient frequency.

32 The River Habitat Survey mentioned on the scoping report has been questioned Given the questions over this approach a ditch profile survey with 10.3 by a number of consultees. associated detailed habitat and species surveys has been undertaken of the drainage ditches instead.

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33 Breeding birds surveys should follow the BTO’s Common Bird Census Whilst the initial survey was less intense than required by CBC, 11.3 methodology. subsequent surveys have followed this approach, as addressed in Chapter 11.

34 Investigation and when possible quantification of bird strikes, flight paths and Where practical, investigations have been undertaken of bird flight 11.3 migration patterns. Birds identification using mobile bird detection radar as well paths and migration patterns to provide a basis for the bird strike as visual identification. If the EIA does not include the above surveys, the ES risk assessment. Mobile bird detection radar has not been should justify that sufficient data has been provided from other sources to assess employed as enough bird movement data is believed to be the impacts. available from existing monitoring studies in the area (including lengthy records from both the RSPB and the Dungeness Bird Observatory). Any data obtained on a one-off seasonal basis was not felt to be adequate to alter any of the conclusions that would be reached from a review of this historic data.

35 English Nature, RSPB and Dungeness Bird Observatory requested further bird This approach has been followed in recent surveys as described 11.4 surveys and for the Study Area to be extended to the south of the airport to further in Chapter 11. include areas of importance for bird species (such as Denge Marsh). The wintering birds survey (a Wetland Bird Survey based), should cover a full two sessions. One survey visit should be made per month from October to March.

36 Issues to consider include potential disturbances to gravel pits, bird These are addressed in Chapter 11. 11.5 movements/fight paths and changes to these movements over time, season or changes in feeding patterns, weather conditions, bird strike precautions. 11.6

37 The impact of increased levels of air pollution from aircraft and traffic on This approach has been used, as described in Chapter 15. 15.5 sensitive habitats within 200m of the pollution source should be considered. The precautionary principle should be applied to dust suppression mitigation measures by using a 200m radius where important habitats are sensitive to changes in air quality.

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38 Impacts on sea birds and bird exclusion on water bodies in the area should be This is addressed in Chapter 11. 11.5 considered. Bird control should be considered. 11.6

39 The scoping report does not identify methods of determining habitat or species These have been taken into account as described in Chapter 10. 10.3 sensitivity, conservation importance or predicting impact magnitude and significance. The IEEMs guidelines for Ecological Impact Assessment (July 10.4 2005) should be used.

40 Mitigation measures for great created newts, bats or badgers should make These have been taken into account as described in Chapter 10. 10.6 reference to English Nature or DEFRA guidance. Proposals should provide Further details of wildlife gains will be developed in consultation wildlife gains and the ES should describe how these measures will be delivered. with Natural England as part of the proposed biodiversity action plan for the airport.

41 A desk study is required of current and future landscape baseline, considering This has been done, as addressed in Chapter 12 12.1 – sensitive receptors, landscape character, landscape condition and landscape 12.4 value.

42 Landscape and visual impact assessments should be assessed separately. The This has been undertaken and is addressed in Chapter 12. 12.3 assessment of impacts should be a combination of magnitude and landscape resource quality/value. The distance of sensitive receptors should be considered for both, landscape and visual impact assessment. Landscape assessment should be undertaken on the context of National landscape Character Area. Landscape assessment should be undertaken on the context of National Profile and County Landscape designations.

43 Potential impact of Listed Buildings, Scheduled and other Ancient Monuments This has been undertaken and is addressed in Chapter 13. 13.3 should be considered.

44 Potential landscape impacts of presence of aircraft in the sky should be It has been undertaken and is referenced in Chapter 12. 12.5 considered.

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45 The use of Zones of Visual Influence (ZVI) diagrams is recommended, and This has been undertaken and is addressed in Chapter 12. Fig results should be used to determine the location of the viewpoints. 12.1

46 All key viewpoints that are likely to be significantly affected are assessed, and it All key viewpoints were agreed with SDC and photomontages 12.4 is not necessarily limited to a maximum of 6. It is recommended that selected illustrating impacts from key viewpoints produced. viewpoints are agreed with SDC. Photomontages illustrating the impact from key Fig viewpoints should be produced. 12.1

47 The worst case scenario should consider weather conditions. For the landscape assessment clear conditions have been 12.3 assumed to represent a reasonable worst case (ie most visible) scenario.

48 Evaluation of the Archaeological potential including impacts on Scheduled This has been undertaken and is addressed in Chapter 13 13.3 Monuments and early aviation structures within and surrounding the application site should be undertaken. Cultural Heritage issues should be addressed and guidance from the Institute of Field Archaeologists should be followed. Desk study should include consultation with the county archaeologist and the Research Trust.

49 Mitigation measures for significant impacts should be agreed with the County No significant effects are expected as a result of the proposed 6.6 Archaeologist. development, although an archaeological watching brief will be implemented during construction. Impacts to geological resources 13.7 are discussed in Chapter 6.

50 Some depth below the present ground surface should be considered. Only limited excavations below ground level are required and the 13.7 use of a watching brief (as outlined in Chapter 13) should ensure that no significant impacts occur.

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51 Examination of the airport history should be undertaken - archaeological This has been undertaken and is addressed in Chapter 13. 13.3 remains and buildings associated with the World War II role of Lydd as an Advanced Landing Ground could have historic aviation interest. Examination of field boundaries, hedgerows, drains etc and the traditional field patterns affected in and around the airport should be undertaken.

52 Reference should be made to the National Air Quality Objectives and Local Air This has been undertaken and is addressed in Chapter 15. 15.2 Quality Management Areas, as well as local air quality monitoring. Sensitive receptors, including humans and ecosystems, should be assessed. 15.4

53 English Nature recommends a 200m radius to be applied to ecologically A 200m radius has been considered, and the nitrogen deposition 15.3 sensitive areas, include ecologically designated areas where fuel dumping may assessment has not been restricted to the SSSI. Fuel dumping is have an effect, and those within 200m of a road, which will be used by airport not an approved or common operating procedure, and as such has related traffic. Assessment of the nitrogen deposition should not be limited to the been excluded from the assessment. SSSI, and should consider SAC, SPA and potential Ramsar areas.

54 Meteorological data more recent than 1993-1997 should be used and different This has been undertaken and is addressed in Chapter 15. 15.3 scenarios should be modelled in relation to the National Air Quality Strategy.

55 Impact of air quality from emissions related to construction traffic should be This has been undertaken and is addressed in Chapter 15. 15.2 – assessed. The ES should support decisions with quantified predictions of the 15.5 number of construction vehicles required for the proposal, and an illustration of the construction routes and access points.

56 Proposals for dust suppression measures should be included These are included in Chapter 15. 15.6

57 Baseline noise monitoring should include properties immediately adjacent to This has been undertaken and is addressed in Chapter 16 16.5 and surrounding the airport and should be done at several locations determined by identifying the most sensitive receptors, including any relevant consented proposed developments. Separate baseline measurements for day, evening, night and weekends.

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58 Sites that are important for their bird populations should be considered as This has been undertaken and is addressed in Chapter 11. 11.5 sensitive receptors.

59 Sensitive receptors should include representative residential areas under the This has been undertaken and is addressed in Chapter 16 16.6 flight paths in surrounding conurbations, such as schools, hospitals, places of worship and retirement homes and residential properties where it is difficult to design effective mitigation strategies. Relevant sites should be treated as receptors. The impacts from ground based activities should be assessed using measurement index(s): LAeq, LA90, LA10, and LAmax.

60 Modelling should be done of different scenarios to predict sound levels to the Detailed modelling of potential noise levels has been undertaken 16.2 height of the aircraft given at the project fight path, The nature of the flight, type using a bespoke model calibrated to take into account as many of of aircraft, predicted speed of the aircraft, time of the flight, number of fights in a the mentioned parameters as possible. This is addressed in given time period should be considered. Chapter 16.

61 The assessment should be according to PPG24 and noise contour maps This has been undertaken and is addressed in Chapter 16. 16.5 produced illustrating the noise level. Forecast noise levels should use measurement indices used on the baseline assessment.

62 An assessment should be undertaken in accordance with tBS5228 and the This has been undertaken and is addressed in Chapter 16. 16.2 Department of Environment Advisory Leaflet AL72, Noise Control on Building Sites (1976) and WHO Guidelines fro Community Noise. Impacts on learning potential and health should be considered.

63 The proposal should meet the requirements of the European Noise Directive. LAA is below the applicable threshold for the European Noise N/A Directive and as such Lden and Lnight assessments are not considered appropriate.

64 An assessment should be made of likely significant impacts to important bird This has been undertaken and is addressed in Chapter 11. 11.5 populations and species in relation to disturbance from noise e.g. changes in roosting and feeding patterns and considering the timescale of the impacts.

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No Technical Requirement Comment Ref This has been undertaken and is addressed in Chapter 17. 65 An evaluation should be undertaken of employment data, employable 17.3 population, unemployable figures, number of people currently employed by the airport, employment catchment area, and service industry provision in the area. 17.4 This has been undertaken and is addressed in Chapter 17. 66 Prediction should be made of the number of jobs to be directly created by the 17.4 proposals during the construction, and operational stages, including an estimation of the number of indirect employment opportunities created. This has been undertaken and is addressed in Chapter 17. 67 The EIA should assess whether there are sufficient local employment resources 17.4 to meet the needs of the development and the likelihood of demand for supporting services with potential positive and negative effects

68 The appraisal should make reference to relevant national and regional policies, This has been undertaken and is addressed in Chapter 18. 18.3 – including traffic and local sustainable development priorities, and sustainable 18.4 transport provisions such as green travel plans for staff.

69 The appraisal should assess the sustainability of the proposals as a whole These issues are addressed throughout the report in the All scheme, not just detail the sustainable elements of the proposals. It should appropriate chapters, and are summarised in Chapter 18. address: emission of green house gases, contributions to and the maintenance of biodiversity, use of renewable and non-renewable resources, contribution to the economic well being of the community, effects on critical resources, waste generated by the project.

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70 A risk assessment should be undertaken in relation to the exclusion zone around As required under the conditions of the Nuclear Installation Act N/A the power station, and any restrictions. Full consultation should occur with the 1965 (as amended), staff at Dungeness nuclear power station have management at the power station, the Health and Safety Executive and the CAA undertaken a risk assessment of their facilities as part of the regarding this issue. This work could be undertaken separately to the EIA and is licensing process. Understandably, this risk assessment is required under separate legislation. A summary with the relevant legislation confidential as it contains security related information but it has would be useful. been thoroughly reviewed by the Health and Safety Executive (HSE) and accepted by the Nuclear Installations Inspectorate. A meeting was held between Dungeness and Lydd Airport staff to discuss the proposed airport expansion and LAA provided Dungeness with data on proposed fleetmixes and flightpaths so they could update their risk assessment. If the proposed expansion at Lydd is granted permission then the risk assessment will be reviewed again to ensure that there is no change to the predicted environmental risk The planning process will provide a suitable forum in which Dungeness can comment on the development proposals. Supplementary information on the risk of a crash has been produced by LAA within the planning package.

71 Inclusion of an impact assessment to identify, describe and evaluate the effects A cumulative impact assessment is included as Chapter 18 to 18.4 that are likely to result from the project in combination with other projects and address this issue. activities that are being, have been or will be carried out. For example: combined effects of loss of habitat, reduced air quality, increased nitrogen deposition, disturbance from noise upon the ecological integrity of the internationally designated sites.

73 The assessment needs to be related to likely traffic levels generated Predicted traffic levels generated has been included within the 14.3 Traffic Chapter 14

74 Proposed new or improved access arrangements should be identified New and improved access arrangements have been identified and 14.5 the level of commitment involved.

75 Impacts to local and wider sub region should be assessed The local and wider subregion have been considered 14.5

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No Technical Requirement Comment Ref

76 Impacts on existing public transport provision should be assessed along with the This has been included within the predicted impacts, and this is 14.5 implications for necessary substantial upgrading further referred to in the Travel Plan.

77 Traffic and Transport title should be extended to be ‘Transportation’ and include The assessment has included consideration of rail, bus and coach,. 14.2 all modes of transport, including rail. Policies in emerging Kent and Medway Reference has been made to the Kent and Medway Adopted Structure Plan should also be taken into account, in particular Policy TP25 Structure Plan 2006, and in particular Policy TP25: Lydd Airport. This is also further referred to in the Transport Assessment document which is supplementary to the ES.

78 Assessment should also consider the potential impact of additional traffic on The potential impact of additional traffic on junction 10 of the M20 14.5 junction 10 of the M20. has been considered in section Year 1 Operating Conditions of Predicted Impacts.

79 Impacts to important C roads should also be assessed This has been addressed and a Signage Strategy is in place for 14.6 nearby C roads and unclassified roads.

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Modelling Scenarios

1.2.8 The following impact scenarios have been assessed in this ES:

• Baseline Environment – (Existing Conditions) - This represents the environmental conditions present with existing passenger levels (approximately 3000 passengers) as of 2005/2006 and provides a baseline against which the impacts of the proposed development can be evaluated.

• Baseline Environment (Future Assessment Conditions Scenario) - This represents the impacts at the 300,000 passengers per annum level with no runway extension and are considered the ”no project” or “do nothing” scenario, since the airport is permitted to grow to such levels with its existing facilities. The scenario is currently expected to be reached in 2009.

Predicted Impacts: Construction Works

• Existing Conditions Scenario - This represents the environmental impacts that may arise during the construction of the runway extension when compared to the existing conditions, whilst this typically is not affected by passenger numbers this differs for a few areas such as Traffic and Transport. The scenario is currently proposed for 4 months prior to operating.

• Future Assessment Conditions Scenario– This represents the environmental impacts that could arise during the construction of the runway extension, were it to take place once the 300,000 passengers per annum Future Assessment Conditions had been reached. The scenario is currently proposed for 4 months prior to operating.

Predicted Impacts: Operational Impacts

• Existing Conditions Scenario– This represents the environmental impacts that may arise during the operation of the runway extension at the limiting capacity of the existing airport facilities (i.e. 300,000 passengers per annum) when compared to the conditions that are present today. This limiting capacity is currently expected to be reached in 2009.

• Future Assessment Conditions Scenario – This represents the environmental impacts that could arise during the operation of the runway extension at the limiting capacity of the existing airport facilities (i.e. 300,000 passengers per annum) given that this limiting capacity can be reached without the proposed development in place. Again, this scenario is currently proposed for 2009.

Mitigation has also been considered in terms of construction and operation for both existing and future assessment conditions scenarios.

The EIA

1.2.9 The ultimate purpose of the EIA is to provide a mechanism for minimising potentially adverse impacts and to provide the regulators with appropriate levels of information for decision-making, in a transparent and robust manner. As such the Environmental Statement (ES) report is used to present the relevant environmental information by means of the following documents:

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• Non-Technical Summary

• Main Report

• Figures

• Appendices

1.2.10 Further information on the approach to the EIA is included in Chapter 2.

1.3 Stakeholder Consultation

1.3.1 Consultation is a key part of assessing the environmental impacts of a project and in ensuring that project benefits are maximised. Throughout the EIA process the Proposed Development team has been in regular contact with key stakeholders, including local residents and the general public, through the use of regular (and often public) meetings as well as a newsletter to keep stakeholders informed (See Appendix 1.3) and the formal request for Scoping Opinions undertaken at the outset of the work. In addition, the EIA process has involved extensive liaison between LAA and its various sub-consultants and the Regulatory Authorities throughout.

1.3.2 A series of public consultation meetings have been held with the local community to present the proposed development and obtain their views on the proposal. These have been held both within the airport itself and within the surrounding villages and have been advertised in the local paper. These meetings are part of the Stakeholder Consultation Strategy (Appendix 1.4) which was produced to ensure that the local communities and key stakeholders have an opportunity to input into the development plans for the airport – See Appendix 1.4 for a copy of the strategy and Appendix 1.5 for a copy of the key issues arising during the consultation.

1.3.3 The table below outlines the details regarding the date, location and number of attendees at the Public consultation meetings:

Date Location Number of Attendees Jan 05 London Ashford Airport (Lydd) N/A Mar/05 London Ashford Airport (Lydd) N/A Mar 05 Greatstone-on-Sea N/A Apr 05 London Ashford Airport (Lydd) N/A June 05 New Romney Assembly Rooms N/A June 05 Dymchurch Assembly Rooms N/A July 05 Hythe Town Hall N/A July 05 Dymchurch Assembly Rooms N/A Aug 05 London Ashford Airport (Lydd) N/A

05.04.05 New Romney Assembly Rooms 80+ 12.04.05 Lydd Community Hall 60 19.04.06 London Ashford Airport (Lydd) 120 26.04.06 Hythe Town Hall 50+

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27.04.06 London Ashford Airport (Lydd) 130 10.05.06 Folkestone South Kent College Main Hall 5 17.05.06 London Ashford Airport (Lydd) 130 24.05.06 Holiday Inn Central on Canterbury Road 7 31.05.06 Rye Town Hall 40 10.10.06 London Ashford Airport (Lydd) 110+

1.3.4 The Lydd Airport Consultative Committee see Appendix 1.6 meets regularly at the airport to discuss the airport operations, and includes representatives of the following organisations:

• British Energy (Dungeness);

• Kent County Council;

• Lydd Action Against Airport (LAAG);

• London Ashford Airport (Lydd);

• Lydd NR Greatstone Residents Association;

• Lydd and Hythe Ranges;

• Lydd Town Council;

• New Romney Town Council; and

• Shepway District Council.

1.4 Permitted Development Rights

1.4.1 In addition to the works proposed to be undertaken under this planning application, the airport has the ability to undertake certain development projects under its Permitted Development Rights in accordance with the Town and Country Planning (General Permitted Development Order) 1995 No 418 Part 18 Aviation. In particular LAA can carry out, either on their operational land or within 8km of their operational land, works intended to improve any of the following:

• The provision of air traffic control services;

• The navigation of aircraft using the airport; or

• The monitoring of the movement of aircraft using the airport.

1.5 Contents of the Environmental Statement

1.5.1 The ES is set out as follows:

• Chapter 1: Introduction

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• Chapter 2: EIA Methodology

• Chapter 3: Lydd Airport

• Chapter 4: Project Description

• Chapter 5: Planning Policy Framework

• Chapter 6: Ground Conditions

• Chapter 7: Water Resources and Flood Risk

• Chapter 8: Solid Waste Management

• Chapter 9: Land Use

• Chapter 10: Ecology

• Chapter 11: Bird Conservation and Hazard Management

• Chapter 12: Landscape and Visual Amenity

• Chapter 13: Cultural Heritage and Historic Environment

• Chapter 14: Traffic and Transport

• Chapter 15: Air Quality

• Chapter 16: Noise and Vibration

• Chapter 17: Socio-Economic

• Chapter 18: Cumulative Effects

• Chapter 19: Summary Tables 1.5.2 The sections addressing each of the environmental issues within the Main Report are generally structured as follows:

• Introduction

• Legislative Drivers

• Assessment Methodology

• Baseline Environment

• Predicted Impacts

• Mitigation

• Residual Effects

• Summary

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1.5.3 To assist in the reading of this ES, a Glossary of Terms and Abbreviations used in this report is provided at the front of the ES and references to information and data are cited as footnotes. Appendices are included in Volume II of the report.

1.6 Environmental Impact Assessment Team

1.6.1 The EIA has been undertaken, co-ordinated and managed by PB, an international engineering and environmental company, with additional specialist input provided by the following:

• Steer Davies Gleeve (traffic impact assessment);

• Peter Fischer Design Ltd / Dave Huskinsson Associates (landscape and visual impact assessment);

• MC3D (photomontages);

• Mills Whipp (cultural heritage and historic environment);

• Ecoline (general ecological baseline and protected species surveying);

• Humphries Rowell (amphibian and invertebrate surveys);

• Paul James (over-wintering birds and breeding birds surveys);

• Joyce Pitt (botanical surveys for higher and lower plants);

• John Ball (watercourse surveys); and

• Aviation Wildlife Management (AWM – specialist avian advice).

1.7 Availability of the ES

1.7.1 The ES will be available from a number of sources including the LAA website, as well as:

• Shepway District Council Offices;

• Lydd Town Council Offices;

• Lydd Public Library/Hall;

• New Romney Town Council Offices;

• New Romney Public Library; and

• London Ashford Airport.

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1.8 Further Details

1.8.1 For further details on the project please contact the following:

Zaher Deir Managing Director London Ashford Airport Lydd, Kent. TN29 9QL Tel: 01797 322400 [email protected]

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CHAPTER 2

EIA METHODOLOGY

CHAPTER 2 LAA

EIA METHODOLOGY RUNWAY EXTENSION ES

2 EIA METHODOLOGY

2.1 Overview

2.1.1 The EIA process is designed to enable good decision-making based on the best possible information about the environmental and social implications of a proposed development. It involves the compilation, evaluation and presentation of all the significant environmental effects of the proposed development in order to assist the appropriate authority to consider and determine the planning application.

2.1.2 The EIA for the Proposed Development has been conducted in accordance with the latest Government Regulations and good practice guidance, including:

• Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999; • Circular 02/99 Environmental Impact Assessment (Office of the Deputy Prime Minister (ODPM)), 1999; • Preparation of Environmental Statements for Planning Projects that require Environmental Assessment. A Good Practice Guide (Department of the Environment), 1995; • Environmental Impact Assessment: A Guide to Procedures (Office of the Deputy Prime Minister (ODPM) 2000; and • Scoping Guidelines for the Environmental Impact Assessment (EIA) of projects. Environment Agency, 2002. 2.1.3 This section outlines the overall approach taken for the EIA. Specific methodologies for each specialist environmental issue are explained in the relevant sections of the ES. The EIA process for the proposed project has involved a number of steps, as illustrated in Flow Chart 2.1 below, and discussed in greater detail in Section 1.2.

Preparation Stage Collation / collection of data

Scoping (which impacts and issues should be considered) and Consultation

Description of the project/development action and alternatives

Description of the environmental baseline

Identification of key impacts

Assessment Stage Consultation Prediction of impacts

Evaluation and assessment of significance of impacts

Identification of mitigating measures and

monitoring requirements

Presentation Stage Submission of findings in the ES and submission to LA with planning application

Flow Chart 2.1 Environmental Impact Process1

1 Modified from J Glasson, R Therivel & A Chadwick “Introduction to Environmental Impact Assessment” 2nd Edition, 1999 (6)

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2.2 Project Planning

2.2.1 Effective project planning is essential to clearly define and communicate the goals of the EIA and determine how these goals are to be reached. The key questions that must be answered are:

• What are the likely issues requiring assessment?

• What existing information is available concerning these issues? and

• What information is subsequently absent and must be obtained? 2.2.2 These questions were answered primarily through the scoping process, which included a series of site visits to allow the PB project team to familiarise themselves with the site layout, meetings with key project stakeholders (including SDC, English Nature (now known as Natural England), EA, RSPB and the IDB) and initial document, literature and legislation reviews.

2.2.3 The consultation process allowed the EIA team to determine the full nature of the Proposed Development, identify the issues the regulatory bodies considered to be of greatest concern, discuss the level and nature of information the regulators wished to see presented and obtain copies of any relevant information they possessed. The scoping report and scoping opinion are provided in Appendices 1.1 and 1.2.

2.2.4 In addition, the document and literature reviews allowed the clarification and collation of the baseline information which already existed, identified that information which required updating or improving, and that information that was absent and would require original collection. The legislation and planning policy review was essential in determining which information would be required in order to assess regulatory compliance.

2.3 Baseline Environment

2.3.1 An environmental impact involves a change in the environment, resulting from a designated action and the impact assessment methodology is described in Section 2.4. In order to identify such a change, it is essential to have as complete as is practicable an understanding of the nature of the existing environment, prior to its interaction with the proposed development. This translates into the need to characterise the existing environmental baseline including establishing prevailing conditions for a range of environmental media, such as air, water, soil, groundwater, flora, fauna, noise and the human environment.

2.3.2 For the current project, this has been achieved through two main elements:

• Undertaking of bespoke monitoring studies to collect required supplementary data (primary sources); and

• Detailed review of secondary sources (i.e. existing documentation and literature). 2.3.3 Both the existing sources and bespoke studies were analysed and integrated into one coherent description of baseline characteristics to facilitate the modelling of potential changes in the environment relating to the proposed development.

2.3.4 The assessment has been structured as described in Chapter 1.2.8 and the baseline scenario the applicant considers most appropriate for the ES is the Future Assessment Conditions Baseline scenario based on the airport being able to reach 300,000 passengers per annum with no planning permission required. Given the

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investment in the airport in the last few years, the Future Assessment Conditions Baseline is considered to be a realistic and appropriate "future baseline" against which to gauge the impacts of the Proposed Development. This Future Assessment Conditions Baseline is thus used for the assessment and the derivation of mitigation measures. Accordingly the mitigation measures which the airport is proposing as part of the application are based on the impact of the Proposed Development proposals against the Future Assessment Conditions Baseline.

2.3.5 It will also be noted that the ES does in all instances also assess the effect of the Proposed Development against a "Current Conditions" baseline (which takes the baseline as the current conditions at the site rather than reasonable future conditions). It also therefore sets out mitigation measures which would be appropriate if the assessment were against a Current Conditions baseline rather than a Future Assessment Conditions Baseline. However, the applicant considers that the Council should be basing its determination of the application based on the Future Assessment Conditions Baseline and the mitigation measures derived therefrom as the most appropriate way of undertaking the EIA of the Proposed Development. Although it may not be inappropriate to examine the Proposed Development proposals against the Current Conditions baseline, the applicant considers the Future Assessment Conditions Baseline to be a more appropriate assessment basis and this approach is therefore commended to the Council and is consistent with a number of the requests raised in the ES Scoping Opinion.

2.4 Predicted Impacts

2.4.1 Virtually all human activity imposes some disturbance to aspects of the environment because of physical impacts on natural systems or due to interactions with other human activities and human systems. Often such impacts are slight or temporary and have an effect that may be regarded as insignificant.

2.4.2 The approach adopted to assess the significant impacts of the Proposed Development on the existing environment and defining mitigation measures, is based on the premise that certain potential impacts can be avoided through the careful choice of location, technology and materials. Extensive mitigation has also been incorporated into the project design in order to minimise the likelihood and extent of impacts to the environment, however some environmental impacts may be unavoidable.

2.4.3 Impacts are defined as changes in the environment that result from an event that interacts with it. They can be either positive or negative and are described in terms of the following:

• Likelihood of the impact occurring;

• Frequency of impact occurrence;

• Extent or the spatial extent of the impact;

• Duration of the impact;

• Magnitude of size of the impact in relation to set standards;

• Type of impact, whether the impact is beneficial (positive) or adverse (negative); and

• Significance – overall importance of the impact.

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2.4.4 This ES has sought to predict the occurrence and significance of potential impacts associated with the proposed development and to describe the mitigation measures which could be used to avoid, reduce, remedy or compensate for the potential impact. The terminology used to describe the scope and type of impacts upon each receptor is defined in each chapter of this ES. The impact assessment scenarios modelled are described in Section 1.2.8.

2.5 Mitigation

2.5.1 Where potential significant impacts have been identified, mitigation measures are proposed to reduce the frequency, likelihood or extent of the impact. Residual effects are those that remain following mitigation. The identification, assessment, and presentation of mitigation measures occur within each specialist topic and are summarised in Chapter 19 Summary Tables of this ES.

2.5.2 Where considered appropriate, the ES also includes recommendations for monitoring during the construction and operational phases of the Project to be implemented as part of the project Environmental Management Plan (EMP). Whilst mitigation and monitoring have not been separated within the main text, they have been considered in terms of construction and operational mitigation for both existing and future assessment conditions scenarios. In addition to this, they have been separated within the summary tables (the final chapter of this document), for easy reference.

2.6 Cumulative Impacts

2.6.1 The EIA has also considered cumulative impacts which can be defined as “impacts that result from incremental changes caused by other past, present or reasonably foreseeable future actions together with the project”. Cumulative impacts may include both the combined effect of individual impacts from the proposed development on receptors; and incremental impacts caused by separate developments within a defined study area including the proposed development.

2.6.2 The first type of cumulative effects is addressed within the individual chapters of the ES dealing with specific environmental issues. More information on the second type of cumulative impacts is provided in Chapter 18 of this ES. No additional mitigation is considered to be required over and above that stated in the ES to mitigate for cumulative impacts.

2.6.3 No additional mitigation is considered to be required over and above that stated in the ES to mitigate for cumulative impacts.

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CHAPTER 7 LAA

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7 WATER RESOURCES AND FLOOD RISK

7.1 Introduction

7.1.1 This Chapter assesses the potential impacts of the proposed runway extension to (and from) the water environment. As such, it covers issues of:

• Surface water and groundwater quantity and quality;

• Flood risk assessment;

• Water use and consumption; and

• Sewage generation, treatment and disposal. 7.1.2 The scenarios modelled in this chapter are as described in Chapter 1.

7.1.3 This Chapter should be read alongside Chapter 10 (Ecology and Nature Conservation) regarding potential indirect impacts to the nature conservation value of the Marsh and adjacent sites arising through changes to water quality / quantity.

7.2 Legislative Drivers

7.2.1 The following key legislation and policies have been reviewed as part of this assessment:

• The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003, which brings into law the provisions of 2000/60/EC Water Framework Directive (primarily water management at river basin district level and the implementation of River Basin Management Plans);

• The Water Resources Act 1991, which makes it an offence to cause or permit pollution of controlled waters;

• PPG 25 Development and Flood Risk1, which aims to increase communication between land-use planning, land management and the Building Regulations. This guidance explains how flood risk should be considered at all stages of the planning and development process in order to reduce future damage to property and requires the planning system to ensure that new development is safe and not exposed unnecessarily to flooding; and

• PPS 23 Planning and Pollution Control.

1 Whilst PPG 25 is still the current guidance, account has also been taken of the requirements of the draft PPS 25 during these works.

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7.3 Assessment Methodology

7.3.1 This assessment has been undertaken with regard to both the methodologies outlined in ‘Environmental Impact Assessment: A Guide to Procedures’ (DETR 2000) and the requirements of PPS 23 ‘Planning and Pollution Control’ and PPG 25 ‘Development and Flood Risk’. In addition, the comments provided by SDC and their consultees on the Project Scoping Report1 have been taken into account wherever feasible.

7.3.2 Initial data on existing conditions has been collected through a desk study of the area, including a review of the following information:

• Data held by the EA on water quality targets, river chemistry and flood risk;

• Accompanying report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

• Data from the Landmark “Envirocheck” database on discharge consents and pollution incidents to controlled waters (within a 1km radius of the site) and abstraction licences (within a 2km radius); and

• Findings of the ecological impact assessment. 7.3.3 Additional information has been obtained from the following sources:

• EA Pollution Prevention Guidance Notes;

• National Groundwater and Contaminated Land Centre Report NC/99/73, 2001;

• Planning Policy Statement (PPS) 23 Planning and Pollution Control (2004);

• Planning Policy Guidance (PPG) 25 Development and Flood Risk (2001);

• Sustainable Urban Drainage System: Best Practice Manual (CIRIA/ C523);

• The EA General Quality Assessment (GQA) scheme for the assessment of surface water quality. 7.3.4 The desk study was followed by a series of sites visits by specialist hydrologists, ecologists and drainage engineers and an ongoing dialogue has been maintained with the Regulatory Authorities (including the EA and the local IDB) throughout the EIA process.

7.4 Baseline Environment (Existing Conditions Scenario)

Surface Waters and Drainage

7.4.1 LAA lies adjacent to Denge Marsh, a flat area of historic marshland which is now drained to the sea by a series of interconnected tide locked drainage ditches controlled by the local Internal Drainage Board (IDB). The key watercourses near the site are:

• The Dengemarsh Sewer, which is classified as a main river and is controlled by the EA. It is the main watercourse on the site and runs approximately north – south adjacent to the site’s western boundary. As a main river, any work on the

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watercourse or within 8m of the bank requires Land Drainage Consent from the EA; and

• The Mockmill Sewer, which runs west-east adjacent to the northern boundary of the site, before turning at 90O down the site’s western boundary and joining the Dengemarsh Sewer. 7.4.2 Several other tributaries also drain into these sewers and there are a number of other drains across the site which are not confluent. The Jury’s Gut Sewer (see 7.4.12) is ultimately connected to the site via these lateral drains.

7.4.3 Water levels within the marsh ditches are controlled by the IDB via a series of sluices and retained at approximately 0.5m AOD during the summer and 1.4m AOD during the winter, rising to approximately 2m AOD during times of flood. A number of control sluices lie within the application site boundary, including the sluice on the Mockmill Sewer.

7.4.4 The majority of the site has no piped drainage system and under an agreement with the EA, stormwaters are allowed to drain directly to soft verges and natural soakaways.

7.4.5 Runoff from the terminal area and carpark is drained by a positive piped system through a single stage interceptor to an outfall in the Dengemarsh Sewer (see 7.4.12). There are three oil separator tanks included within this system, one of 750 gallons located in the car park; one of 3,500 gallons by the fuel farm; and one of 3,000 gallons by the main hangar. These separator tanks are inspected regularly and emptied by tanker on a quarterly basis.

7.4.6 Runoff from the apron is collected and discharged to a newly constructed pollution interception basin and separate attenuation basin. The pollution basin has an impermeable liner and reedbeds for pollution treatment and is also equipped with sluice valves to enable any spill of hazardous materials to be contained and removed before it enters the surrounding drainage system. From the basins the water enters the Dengemarsh Sewer at “greenfield” runoff rates under an agreement with the EA.

7.4.7 LAA is currently in the process of backfilling several drains and standing waterbodies located in close proximity to and east of the runway to meet CAA requirements.

7.4.8 Four surface water abstractions are located within 2km of LAA, as shown in Table 7.1 below.

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Table 7.1 Licenced Surface Water Abstractions within 2km of LAA

Operator Description Direction Distance from Abstraction terminal Norman Dengemarsh South west 654m General agriculture: Balcomb & Sewer and spray irrigation- direct Son associated unclassified ditches Norman Dengemarsh South west 704m General agriculture: Balcomb & Sewer spray irrigation- direct Son Lydd Golf Club Lydd Golf Club- North 1036m Spray irrigation and Driving tributaries of Range Ltd Dengemarsh Sewer A E Wrout & Private ditches, West 1565m General agriculture: Son watercourses and spray irrigation- direct petty sewers Note: Mockmill Sewer is not included in the Table as there are no licenced abstractions from it.

7.4.9 Surface water quality is monitored by the EA at two sites close to LAA, namely the Jury’s Gut sewer (to the west of LAA) and the Littlestone sewer (to the north east). The location of these sites is shown in Figure 7.1.

7.4.10 Monitoring data indicates that water quality in both sewers is generally poor, with both recording only a river quality target level of 5 in the last two decades (1 indicates good water quality, 6 poor water quality). As a result the sewers are considered to be ecologically poor, with the only species present likely to be those adapted to low levels of dissolved oxygen.

7.4.11 A recent assessment of the Romney Marsh / Dengemarsh Sewer and Jury’s Gut Sewer showed that both are at significant risk of failing their objectives under the Water Framework Directive. This is due to modifications to physical structure as a result of land-use changes and in the case of the Jury’s Gut, the risks of invasive (non-local plant species) entering the water.

Standing Surface Waters

7.4.12 Standing waterbodies are prevalent throughout the area, as shown in Figure 7.1. There is a water-body of approximately 100m2 present immediately to the east of the runway and a further series of ponds present on the golf course to the north west of the site. The closest large water-body to LAA is Greatstone Lake / Lade Pit, approximately 1km to the east, whilst the Arc Pit / Dungeness Gravel Pit, New Diggings, and Burrows Pits are located between 1.5 and 2.5km to the south. All these waterbodies are monitored by the Environment Agency. To the west of these pits are smaller waterbodies, mostly formed by new excavations. Whilst each of these lakes has also been assessed against the objectives of the Water Framework Directive, none appear to be at risk of failing these objectives.

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Groundwaters

7.4.13 As discussed in Chapter 6 (Ground Conditions), whilst local soils are classified as of high leaching potential, the site is only underlain by a minor aquifer of variable permeability contained within the unconsolidated deposits. There are 6 licensed groundwater abstractions within 2km of LAA, as shown in Table 7.2 below. Of these the most sensitive is the private potable water supply at Denge Marsh (some 700m distant), with the nearest public water supply located some 2km from the site.

Table 7.2 Licenced Groundwater Abstractions within 2km of LAA

Operator Description Direction Distance from Abstraction Terminal Folkestone & Wells at South 683m Potable water supply- Dover Water Denge Marsh direct Services Ltd Lydd Golf Club and Sand pit, North west 1201m Spray irrigation- direct Driving Range Ltd marine alluvial sands Hall Aggregates Lydd East 1698m Sand and gravel (SE) Ltd washing Folkestone and Denge Marsh South 1943m Public water supply Dover Water Services Ltd. Folkestone and Well No. 26 at South 1948m Public water supply: Dover Water Denge Marsh potable water supply- Services Ltd. direct RMC aggregates Beach shingle North east 1998m Extractive: process (Southern) Ltd in Lydd water

Recorded Pollution Incidents

7.4.14 There have been only 2 minor pollution incidents to controlled waters recorded from within the vicinity of LAA (and none in recent years) involving a release of fire water/foam near the terminal building on 9th April 1996 and a release of gas oil from the hangar on 27 August 1996. Recent improvements in airport management and investment in improved drainage (including the development of the new attenuation pond and interceptors) should help minimise the risk of such incidences in the future.

7.4.15 Whilst the local climatic conditions mean that LAA does not need to use antifreeze for its current (or proposed) operations, it does, however, use a number of hazardous materials that could potentially cause pollution of surface waters if they were not properly controlled. These include the following:

• A fuel farm with two bunded 54,000l tanks, which contain AVGAS and Jet A-1;

• Two mobile re-filling stations of 9,000l and 14,000l, which are filled from the fuel farm (under controlled conditions with spill response procedures);

• Oil stored in 1 litre containers in the fire department;

• A 1,000 litre tank of foam in the fire department;

• Below-ground oil separator tanks;

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• Waste oil tanks;

• Engine oil, paint spray cans, solvents and hydraulic oil present in small amounts in the aircraft maintenance hanger; and

• Sewage held in a cesspit at the southern end of the car park. 7.4.16 Current LAA management practices have been designed to ensure that all such materials are handled, and eventually disposed of, in a responsible manner.

Water and Sewage

7.4.17 The Airport is provided with a piped water supply which has the capacity to support up to 300 000 passengers movements per annum. As such, this is considered more than adequate to meet the demands of current passenger movements which consists of some 45m3 of water per week,

7.4.18 Recent investment in upgrading the existing sewage treatment and disposal system (including replacement of old sewage pipelines) means that the current cesspit-based sewage system is also considered adequate to meet current needs. At present some 45m3 of sewage are generated per week, and this is removed by two 25m3 tanker visits a week, which remove any effluent generated and transport it to an appropriate licenced treatment and disposal facility.

Consented Discharges

7.4.19 There are currently two discharge consents within 1km of the site, both held by LAA, and both into a tributary of the Dengemarsh sewer, namely:

• a trade effluent consent (site drainage from the Bravo Apron is treated in the attenuation pond) located some 600m north west of the existing terminal building; and

• a historic trade discharge consent (process water) located approximately 200m north west of the existing terminal building. 7.4.20 The process water consent is held by LAA for the discharge of treated sewage effluent from airport operations (consent number P.9062/K/CA/00) and has limitations attached to it as outlined in Table 7.3.

Table 7.3 Historical Effluent Discharge Limits from the old LAA Sewage Treatement Works (STW) Description Limit Description Limit Sewage volume 54 m3 / day Nitrogen 3 Mg/Lt Rate of 2 litre per sec Phosphate 1 Mg/Lt discharge BOD 10 Mg/Lt Iron 2 Ug/Lt Suspended 10 Mg/Lt Lead 30 Ug/Lt solids pH 6 – 9 Copper 20 Ug/Lt

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Flood Risk and Coastal Defence

7.4.21 Lydd and the surrounding area is a flat landscape and parts of Romney Marsh are 2m lower than the highest spring tides. The Environment Agency Map identified the whole of Lydd as being within the coastal flooding area for a 1 in 1000 year tide. The site is therefore identified as being within the ‘at risk’ area. This flood risk is affected by coastal sediment movement and is therefore managed in the area through the use of both offshore sediment recharge and longshore drift control (see Figure 7.2 and Table 7.4 below). For further details please refer to the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

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Table 7.4 Shoreline Flood Defence Management Units Flood Defence Description Lydd Ranges This runs from Jury’s gap to Dungeness Power Station. The foreshore is an exposed shingle storm ridge, with a narrow inter-tidal zone, which declines towards the east. The storm ridge protects a very extensive low-lying area from inundation, but a number of over-toppings do occur under a combination of extremely high tidal levels and strong wave action and this can result in serious flooding landwards of the Green Wall. Breaching of this ridge would have an impact in terms of flooding in both the adjacent units to the west and those of New Romney and Greatstone-on-Sea to the east. The Jury’s Gap location is a particularly vulnerable section. Long shore drift in this unit is predominantly in an easterly direction. Artificial beach feeding occurs at Jury’s Gap and at the Dengemarsh outfall. The ancient secondary defence line of the Green Wall runs at a shallow angle inland from the coast towards the foreland and this artificial gravel ridge is intercepted at Jury’s Gap due to changing coastal configuration. The eastern section is undefended, although following storms the beach banks are re-profiled. The preferred policy option for this retreating unit is ‘hold the line’ through continued recharge and maintenance. The present standard of service of the defences (over-topping/active breach) is 1:25. Dungeness Power Dungeness Power Stations are located on a narrow foreshore with an Station eroding shoreline. The coast is retreating, and the long shore drift is dominantly in an easterly direction. At present, the natural storm beach is supplemented by beach recharge. The preferred policy option here is hold the line, seen as the only option during the life and decommissioning of the plant. The opportunity for significant landward realignment of the coastline even following the completion of the earlier stages of decommissioning is restricted however due to the need for a safe store approach to the long- term decommissioning of the Power Stations. It is legally required that the present standard of service here is 1:10,000. Dungeness to This is a historically accreting shoreline, with drift in a south westerly and Littlestone on Sea southerly direction. The present storm ridge backs a wide sand and mud foreshore, increasing rapidly from a very narrow zone at the Dungeness to 1.2km at Greatstone-on-Sea and declining again towards Littlestone-on- Sea. The present day shingle backshore thus has a series of ridges which tend to absorb any waves that overtop the present day beach crest. The sand dunes at Greatstone-on-Sea are also an important flood defence. At Romney Sands, groynes have been constructed to reduce the long shore transport of shingle. The crest of the bank is at approximately 6.5mOD, which is insufficient to prevent overtopping during extreme events. Flooding and partial breaching have occurred at Greatstone-on-sea in the recent past on several occasions, flooding the car park and several adjoining properties. The preferred policy option here is ‘do nothing’ due to natural accretion. However, continued monitoring of beach levels is required for protection against breaching. If the natural accretion of Dungeness foreland ceased, and erosion started, the do nothing option would change to hold the line. From the power station to Greatstone-on-Sea there are 1:100 defences present. From Greatstone-on-Sea sand dunes to Romney Sands the service is 1:15.

7.5 Baseline Environment (Future Assessment Conditions Scenario)

7.5.1 No significant changes are considered to the natural water resources in and around the Airport under the Future Assessment Conditions Scenario, and nor are any changes expected to the risk of flooding.

7.5.2 With regards to water and sewage requirements, the piped water supply is considered adequate to meet the demands of up to 300 000 passengers movements per annum,

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and ongoing upgrades to the sewage treatment and disposal system will also allow this to meet the demands of 300 000 passengers. Proposed rates of water consumption and sewage generation (the two are considered directly proportional) for the Future Assessment Conditions Scenario are shown in Table 7.5 below. The current two tanker visits a week to remove effluent and transport it to an appropriate treatment and disposal facility are expected to increase to approximately 8 tanker visits a week, an issue discussed further in Chapter 14 Traffic and Transport of this ES

7.5.3 The existing water supply is adequate to meet the demands of current passenger movements, and recent investment in maintaining and improving the existing sewage treatment and disposal system (e.g. the old sewage pipelines being replaced) has meant that the current cesspit system is also considered adequate. Currently there are two tanker visits a week to remove effluent and transport it from this cesspit to an appropriate licenced treatment and disposal facility (See Table 7.5).

7.5.4 No other significant impacts to surface and groundwater resources have been identified at this stage from existing operations.

Table 7.5 Existing Water & Sewage Volumes Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or sewage Tanker Visits per generated) per Week* week (m3) 3,000 68 44 2

7.5.5 Up to 300,000 passenger movements can be accommodated within the existing terminal building and the existing water supply is adequate to meet their demands without modifications. Sewage treatment and disposal will continue to be managed by maintaining and improving the existing system.

7.5.6 Proposed rates of water consumption and sewage generation (the two are considered directly proportional) for 300,000 passengers per annum are shown in Table 7.7 below. The current two tanker visits a week to remove effluent and transport it to an appropriate treatment and disposal facility is, however, expected to increase to approximately 8 tanker visits a week at 300,000 passengers (See Table 7.6). This is discussed further in Chapter 14 Traffic and Transport of this ES.

Table 7.6 Predicted Water & Sewage Volumes at 300,000 Passengers per annum Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or sewage Tanker Visits per generated) per Week* week (m3) 300,000 180 181 8

7.5.7 The increase of passenger numbers will require additional car-parking spaces which will be accommodated by converting 2 of the existing stands on the Bravo Apron. The drainage from this area will be collected and discharged to the pollution interception basin and separate attenuation basin. Any hazardous spills will be contained and removed before it enters the surrounding drainage system (See Section 7.4.7).

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7.5.8 The increased number of aircraft movements to 300,000 passengers per annum has the potential to increase levels of aircraft related pollutants discharged to surface watercourses during periods of heavy rain, whilst the increased use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

7.6.1 The extension of Runway 21 by 294m, as well as 150m of clear area, will require the infill and abandonment of approximately 1013m of drains (See Figure 4.1 and 4.2). This will have a number of impacts:

• Removal of any in stream and riparian flora, fauna and habitat;

• Reduction of storage capacity for drainage and surface waters; and

• Disruption of the natural hydrology of the immediate area. 7.6.2 The impact on the in stream and riparian ecology has been assessed and described in detail in the Ecology chapter of this ES (Chapter 10 Ecology and Nature Conservation).

7.6.3 To compensate for the loss of storage capacity, approximately 1256m of new ‘replacement’ drains will be developed around the runway area. These areas will connect to the existing drainage features and have been designed in consultation with the EA and the IDB. The replacement drains will replicate the abandoned drains in width and depth to ensure storage volumes of surface water is greater or equal to those abandoned and will ensure adequate storage of runoff volumes from the runway extension during peak rainfall ‘events’.

7.6.4 The replacement of the surface drainage features will require careful management to ensure drainage regimes are maintained at the site. Drainage regimes, especially seasonal variations possible over the construction period will be incorporated in the Construction Environmental Management Plan (CEMP).

7.6.5 The construction of these replacement sewers will also generate a number of impacts:

• Generation of some 1884m3 of spoil material;

• Potential erosion of the new banks and bed as the channel hydraulics’ and sediment patterns achieve a state of settlement or equilibrium;

• Sedimentation of the watercourses downstream of the new drains as a result of the earthworks and potential erosion of the new drains which may cause disruption to any downstream flora and fauna (See Chapter 10 Ecology and Nature Conservation); and

• Ongoing maintenance commitments to maintain the new drains.

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7.6.6 Spoil piles located near a watercourse can affect local drainage through surface water runoff collecting material and depositing this material downstream and construction works can also affect local water quality through dewatering works and the discharge of site drainage. Prior to the commencement of construction works, the Contractor will be required to prepare a CEMP to minimise such impacts and to include drainage plans to control runoff, erosion and sedimentation (see mitigation). This CEMP will also be used to prevent the storage of fuels, oils and lubricants or the use of the contractor’s compound to contaminate surface water and groundwater through leaks and spills. Overall impacts are therefore expected to be of only minor adverse significance.

7.6.7 Construction works will require a quantity of water for such uses as consumption by work force, dust suppression and use in machinery and plants. Water required for such works will be obtained primarily from the piped water supply, with additional supply from mobile water bowers during specific activities, if necessary. Impacts from water usage are therefore expected to be a minor adverse impact.

Future Assessment Conditions Scenario

7.6.8 Predicted construction impacts for this scenario are as described for the ‘existing conditions scenario’ above.

7.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

7.7.1 The increased number of aircraft movements to 300,000 passengers per annum has the potential to increase levels of aircraft related pollutants discharged to surface watercourses during periods of heavy rain, whilst the increased use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.7.2 The proposed runway extension is not expected to significantly affect the operational activities of the airport, and whilst it will increase the amount of hardstanding present, the proposed drainage system has been developed in consultation with the IDB and EA to ensure that no significant impact will arise to surface or groundwater resources over and above those outlined for the 300,000 passengers without the runway extension.

7.7.3 Aircraft related pollutants and sediments will be collected by the oil separators and silt traps respectively which are an integral design of the runway extension (see Figure 4.2) . These services will be maintained regularly by LAA and the material disposed of at an appropriate facility. The use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.7.4 The entire LAA site is within a coastal flooding area (see Figure 7.2) and will be potentially exposed to a 1 in 200 year tide level of 5.47m Above Ordnance Datum

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(AOD). At such a level, the potential impact of flooding is considered significant however the overall increase in the length of drains provided will attenuate surface flows and impacts are expected to be of only minor adverse significance. Further details are provided in the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

7.7.5 Levels of water consumption and associated sewage generation will not increase as result of the runway extension as described in Future Assessment Conditions scenario (see paragraph 7.5.3)

7.7.6 Overall, the impacts of the runway extension on drainage are likely to be minor given the appropriate management of the replacement sewers is undertaken to ensure they retain their functional capacity for storage.

Future Assessment Conditions Scenario

7.7.7 Predicted Impacts arising from the operation of this scenario are expected to be similar to those described under the ”existing conditions” above, a part from the fact no sewer will be replaced under this scenario.

7.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

7.8.1 The loss of storage capacity by the abandonment of the existing drains will be mitigated by the development of new ‘replacement’ drains, which will ensure the existing storage capacity is retained and increased to accommodate the increase in impervious surface as a result of the runway extension.

7.8.2 Spoil material generated by the construction of these drains is approximately 1884m3 which will be disposed of by infilling the sewers to be abandoned with the surplus spread onsite in the clear areas.

7.8.3 Appropriate stormwater management measures will be designed and installed by the contractor prior to commencement of works to prevent erosion of any exposed soils/substrates and to prevent sediment laden or contaminated water draining offsite into adjacent controlled waters. Such measures may include diversion channels around the site for discharge into treatment/detention ponds and will be developed in consultation with the Local Authority, EA and the IDB.

7.8.4 Specific mitigation measures to avoid contamination of the receiving environment during construction will be detailed in a CEMP and will include, as appropriate:

• Fuel/oil tanks and chemical storage tanks/areas to be provided with locks and placed on compacted areas, within bunds that have a capacity equal to 110% of the storage capacity of the largest tank, to prevent spilled materials from leaking offsite. All valves and couplings to be located within the bunded area;

• Oil interceptors will be provided in any drainage system downstream of possible oil/fuel pollution sources. The oil interceptors will be emptied and cleaned regularly to prevent the release of oils and grease into the stormwater drainage system. Waste materials will be disposed of at an appropriate facility. Any surface water contaminated by hydrocarbons which are used during the

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construction phase will be passed through these oil/grit interceptor(s) prior to discharge;

• Measures will be taken to ensure that no leachate or any surface water that has the potential to be contaminated to enter directly or indirectly any watercourse, underground strata or adjoining land;

• Water inflows to excavated areas will be minimised by the use of lining materials, good house keeping techniques and by the control of drainage and construction materials in order to prevent the contamination of groundwater;

• Site personnel will be made aware of the potential impact on ground and surface waters associated with certain aspects of the construction works to minimise the incidence of accidental impacts;

• Refuelling of construction vehicles and equipment will be restricted to a designated area with properly designed fuel tanks and bunds and appropriate operating procedures;

• All channels permanent and temporary and any temporary attenuation ponds will be maintained to prevent flooding and overflowing and protected where necessary against erosion;

• All temporary hardstanding areas and exposed surfaces or storage areas will be designed to discharge to attenuation ponds. They will not discharge to watercourses or flow offsite in an uncontrolled manner;

• Portable chemical toilets and sewage holding tanks will be placed onsite to accommodate sewage generated by the construction workforce. A licensed contractor will be responsible for appropriate disposal and maintenance;

• Handling and storage of any potentially contaminating material will only occur in designated areas to prevent discharge to watercourses, the drainage system, or offsite;

• No washdown areas will be located near watercourses, or open drains and washdown waters will be collected and directed to appropriate treatment; and

• A spill management plan will be in place at all times.

Future Assessment Conditions Scenario

Construction mitigation measures are as described for the ‘existing conditions scenario’ above.

7.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

7.9.1 The drains within the airport boundary are owned and will be maintained by LAA. Drains outside the airport boundary are owned by IDB which undertakes annual maintenance of these drains to ensure they maintain their drainage capacity and efficiency. Maintenance of LAA’s drains will be undertaken in consultation with the IDB to ensure consistency of the maintenance regime in providing surface water

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storage throughout the system. LAA will ensure these sewers are monitored to ensure they remain stable as erosion of the banks and beds has the potential to cause obstructions to drainage, reduced storage volumes and may cause localised flooding if the banks are breeched.

7.9.2 The proposed drainage has been designed to ensure an increased overall length of drains to attenuate any additional surface flows that could arise as a result of the proposed runway extension and hence to minimise the risk of flooding. In addition a detailed Flood Risk Assessment has been undertaken for the entire airport (in consultation with the EA) which recommends the types of construction materials to be used in any developments at the airport to reduce the risk of flood-related impacts. Further details are provided in the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

7.9.3 Whilst the increase in the number of aircraft movements will result in the increased risk of contaminants entering watercourses, an Environmental Management Plan (EMP) will be produced to minimise such risks and appropriate spill prevention procedures will be detailed in the “Lydd Airport Aerodrome Manual & Emergency Orders”.

Future Assessment Conditions Scenario

7.9.4 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

7.10 Residual Effects

Existing Conditions Scenario

7.10.1 With the implementation of the mitigation measures detailed above the construction and operation of the runway extension is expected to have no more than a minor adverse impact on the surface and groundwater resources of the area.

Future Assessment Conditions Scenario

7.10.2 Residual impacts are expected to be as described for the “existing conditions scenario” above.

7.11 Summary

7.11.1 LAA lies adjacent to Denge Marsh and is drained to the sea by a series of interconnected tide-locked drainage ditches which are controlled by the Internal Drainage Board (IDB). The Environment Agency Flood Map identifies the whole of Lydd as being within the coastal flooding area for a 1 in 1000 year tide. The site is therefore identified as being within the ‘at risk’ area.

7.11.2 The majority of the site has no piped drainage system and under an agreement with the EA, uncontaminated storm-waters are allowed to drain directly to soft verges and natural soakaways. A new attenuation pond, with reedbed treatment and interceptors, has recently been developed to improve control of runoff from the main apron.

7.11.3 The runway extension is located to the north of the existing runway and will affect a number of drains. These drains will be backfilled and new drains constructed around

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the proposed runway extension. Whilst groundwater levels are high in this area, there are no abstractions in close proximity that are likely to be affected.

7.11.4 The current water supply and sewage disposal is adequate for the increase to 300,000 passengers.

7.11.5 A Construction Environmental Management Plan (CEMP) will be developed together with an operational Environmental Management Plan (EMP) and Spill Response Plan to minimise risks of accidental pollution of watercourses.

7.11.6 The runway extension will create additional storage volume due to the increased length of new ditches and overall. However, it is expected that the extension will have no more than a minor impact on surface and groundwater resources. No significant impacts on or arising from flood risk are envisaged.

7.11.7 For the majority of impacts, no significant difference in magnitude is expected between those impacts anticipated to arise when compared to the “existing conditions” and those arising compared to the “future assessment conditions” scenario. The exception is the magnitude of the increased volume of water consumed or sewage produced with the proposed terminal development, which is considerably less when compared to the latter scenario.

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3 LYDD AIRPORT

3.1 Introduction

3.1.1 London Ashford Airport (LAA) at Lydd (previously known as Lydd Airport) has been an operational airport for over 50 years and has provided a key service to regional passengers and in promoting regional tourism within Kent throughout this time.

3.1.2 Opened to the public in 1956, Lydd was the first post-war airport to be developed in England when Silver City Airways started to operate a short-haul car transporting service across the channel to France (primarily to le Touquet). In the early years over 130,000 cars and half a million passengers flew with the company out of Lydd, and at its peak the airport had over 250,000 passengers passing through its doors each year, with Silver City Airways operating a 50-strong fleet, including Douglas Dakotas, de Havilland Doves and Herons and Bristol Freighters.

3.1.3 In 1962, the airport was taken over by British United Airways and by 1965 an average of 400 cars and 1,300 passengers passed though the airport each day, as well as car manufacturers and dealers who used it to export their products to the Continent. Passenger numbers declined in the 1970s however, as travellers transferred their allegiances to the cross-channel hovercraft and roll-on/roll-off car ferries from Dover and Folkestone, and the premium cost of air-freight became prohibitive. As a result, the last Bristol freighter flew from Lydd in October 1970 and the last car was exported in 1971 (see www.lyddair.com/history).

3.1.4 Despite this, the airport has maintained its capability to provide both scheduled and private services, and retains its license to operate 24hrs a day 7 days a week. The current operating hours are 0900-1900 7 days a week in both winter and summer. The only restrictions on schedules or the number of flights is the capacity of the existing terminal building. The increasing emphasis on the need to alleviate pressures on runway capacities in the south-east means that LAA now represents a regional airport with a prime opportunity to offer inter-regional services.

3.1.5 In the last three years, approximately £20 million has been invested in the upgrade of the airport to support this vision, including the development of new Air Traffic Control and Instrument Landing Service facilities, as well as the creation of a new apron parking area, fire and rescue services and the creation of a new business executive lounge. These works, undertaken under the airports Permitted Development Rights, have already resulted in a significant increase in general aviation activity, with a corresponding increase in direct employment from 8 (in 2003) to 68 (today), as well as indirect employment created through ancillary services.

3.2 Airport Location and Setting

3.2.1 The airport is located on the Dungeness Peninsula in Kent some 2km to the east of the town of Lydd. Other towns in the area include New Romney (approximately 2km to the north), Rye (approximately 13km to the north west) and the coastal settlements of Greatstone-on-Sea (approx 1km north east), St. Marys Bay (6km north east), Littlestone-on-Sea (approx. 3km north east), Lydd-on-Sea (approx 2km south east) and Dungeness (approx 4km south east). The location of these towns is shown in Figure 3.1.

3.2.2 The Dungeness power stations restricted flying area is located approximately 3.5km to the south of the airport and prohibits all aerial activities for a 1.5 nautical mile radius around the facility to a height of 2,000 feet . The location of the Dungeness Exclusion

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Zone is shown in Figure 3.3. This restriction represents an amendment from the original limit which was agreed after consultation between LAA and the power station, but results in a basic requirement for all General Aviation departing south from the 21 runway designation (the appropriate runway for an approach from the north) to turn left towards the coast.

3.2.3 Two other restricted flying areas are also located near LAA, namely the Lydd military firing range restricted area (located approximately 2.3km to the west of the airport) and the Hythe firing range restricted area (located approximately 10km to the north east). These have restrictions to a height of 4,000 feet and 3,200 feet from the surface respectively. However, since all of the restricted flying areas have been in existence for a long time, the airport, military and the Power Station have all cooperated closely on this issue over the years to ensure that all can operate without any significant restrictions. The flightpaths and the location of the restricted areas are shown in Figures 3.3 - 3.5.

3.2.4 The airport is located some 25km from Junction 10 of the M20 and has good links to London, Ashford and other towns in the South East. The airport access road is reached via the B2075 (Romney Road), and the A259 near Brenzett. The A259 which connects the airport to Hastings and Rye in the west and Hythe, Folkestone and Dover in the east. The airport is located approximately 28 km from Ashford. Further information on access to the airport is included in Chapter 14.

3.2.5 The airport is located on an area of low lying flat land (approximately 3.5m above sea level) which is a mixture of a freehold land in LAA ownership/control and leasehold from Shepway District Council. Further details on the landuse in and around the airport are described in Chapter 9.

3.2.6 Dungeness, at the southerly tip of the Romney Marshes, is the largest shingle foreland in Europe and parts of it, as well as a number of other sites in the area, are designated for their features of both nature conservation and geological interest, as discussed further in Chapters 6 and 10.

3.3 Key Airport Facilities

3.3.1 The existing airport covers an area of approximately 132 ha, within which are found such key assets as the terminal building, hangars, runways, aprons and the air traffic control tower. Each of these is described in more detail below, and is shown in Figure 3.2.

The Terminal Buildings and Hangars

3.3.2 The existing 8m high terminal building covers an area of approximately 2,500m2 and has a handling capacity of up to 300,000 passengers per annum. The building was originally constructed in 1954 as a steel- and block-work structure, and has been refurbished several times, most recently in 2004. It contains a range of offices and immigration and customs facilities, as well as a bar and restaurant (also used for local functions), pilot training school and flying club. As part of the recent investment programme a new business executive lounge has been created, used primarily by FAL Aviation.

3.3.3 There are two maintenance hangars at the Airport, a recently reclad main hangar of approximately 2,664 m2 and a smaller hangar of approximately 441m2. Both of these are used by Sky-Sure Engineering (a wholly owned subsidiary of LAA) to service single and multi-engine piston aircraft.

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The Runways and Aprons

3.3.4 LAA currently has one operational runway which may be approached from either direction. The runway designations are 03 for an approach from the Southerly direction and 21 from the North. The designations are related to the indicated magnetic heading associated with the approach. These are described in more detail in Chapter 4. A previously used cross-runway has recently been taken out of service and the construction materials reclaimed to construct the new main apron area.

3.3.5 A “Clear Area” is located 150m on either side of the existing runway centrelines and is required to be free of obstacles in accordance with the CAA Safety Regulations Guidance. This is designed to ensure that if an aircraft comes off the runway it has additional level ground for it to stop on and to enable emergency vehicles to reach it more swiftly.

3.3.6 A new Aeronautical Ground Lighting (AGL) system has recently been installed at the airport, powered from an electrical sub-station located to the south of the terminal. On Runway 21 the AGL lights are located along the edge of and at the end of the runway. Additional approach lighting extends some 430m from the threshold and consists of two light crossbars (of 22.5m and 30m width) located at distances of 150m and 300m respectively from the threshold. The lights themselves are spaced some 2.7m apart on the cross bars. Runway 03 also has edge and threshold lighting, with approach lighting extending some 427m from the threshold, but this only has one cross bar at 305m. Blue edge lighting is present along the taxiway. The lights are high intensity white bulbs, but are angled at 4.5 degrees and are only on full power during poor visibility (such as fog) and are at a significantly reduced intensity of 1-3% of their full strength during the night.

3.3.7 The main apron contains stands for aircrafts (up to the size of 737) and lies perpendicular to, and to the west of, runways 21/03. This is used for all ground handling activities including fuelling and pre-flight checks. There is also a light aircraft apron near to the existing terminal building which also accommodates the needs of the executive aircraft interacting with the VIP terminal.

Air Traffic Control

3.3.8 The Airport Traffic Control (ATC) Tower is located to the north of the hangar across the main apron. It operates an Instrument Landing System (ILS) which became operational in June 2006. The ILS enables qualified pilots to use the signals transmitted from the system to make a correct and safe approach in poor visibility conditions. An ILS consists of two independent subsystems, one providing lateral guidance (the Localiser), the other, vertical guidance (the Glidepath) to aircraft approaching a runway, in this case Lydd’s Runway 21.

3.3.9 It is a prerequisite of most commercial and business jet air transport operations that an airport offers an ILS based approach to ensure that safe commercial operations can continue during marginal or poor weather conditions.

3.3.10 The ILS localiser approach is at 5 degrees westerly offset starting 900m from an imaginary extended centreline of the runway in the 21 direction due to the need to avoid the Hythe firing range. The location of the ILS paths is shown in Figures 3.4 and 3.5.

3.3.11 During busy periods aircraft will be directed to the “hold” which is 4-8 nautical miles inland from LAA and will be held at 3,200 feet. The aircraft will orbit until a safe approach has been confirmed by the ATC Tower, however given the low traffic densities predicted for the immediate future, use of the hold area will be minimal.

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3.3.12 In addition to the ILS, the airport also uses a number of other navigational and landing aids including the following:

• a VHF Omnidirectional Radio (VOR) which sends out radial signals on each of the 360 degrees to allow a pilot to fly to or from the airport along a set track;

• Distance Measuring Equipment (DME) which works alongside the VOR to provide information on range;

• A Non-Directional Beacon (NDB). This is an older type of radio aid, retained principally as back-up, which radiates a non-directional signal to which an aircraft receiver can be tuned in to get a bearing. The NDB is a much earlier development than the VOR and offers no precise track guidance or selection. Its low frequency (200 - 1750 kHz) makes it prone to interference in bad weather;

• Runway Precision Approach Path Indicators (PAPI) units. A two-colour light system using sealed units that give a bi-coloured beam, white in the upper part, red in the lower. The units are visible for up to 4.5 nautical miles from the threshold. The view of the lights alters depending on if the pilot is too high / correct / too low. This visual indication is of great assistance in delivering the aircraft to the touchdown point of the runway.

3.4 Ancillary Facilities

3.4.1 These assets are supported by a range of ancillary facilities, including car and coach parking areas, fire-fighting services and a fuel farm, as well as utilities such as drainage, sewerage and power supplies.

Parking Areas

3.4.2 Whilst the existing car park provides some space for some 143 vehicles, the reallocation of additional hardstanding areas means that this can be increased to 860 spaces, which is more than sufficient for the 300,000 passenger scenario (where 510 spaces would be needed). Further detail is provided in Chapter 14 Traffic and Transport.

Fire-fighting services

3.4.3 The fire department is located to the southwest of the main terminal building and has four vehicles (a pickup, a range rover, two fire engines) and a crew of twelve. It operates a mutual support agreement with the Kent Fire Brigade and the power stations.

Fuel Storage

3.4.4 The Airport’s fuel farm is located within a fenced off and bunded area adjacent to the access road, with access to the apron via a gate to the north east of the hangar. The farm contains two 54,000 litres tanks, which contain AVGAS and Jet A-1 fuels and are refilled approximately every 4-6 weeks. Aircraft are re-filled using two mobile re-filling stations, holding 9,000 and 14,000 litres respectively. Spill kits are located at both the fuel farm and at the fire station, and the airport’s emergency response procedure requires the local fire department and the Environment Agency to be contacted if more than 5m2 of fuel is spilt. The airport has had no pollution incidents in recent years, the last occurrences being two pollution incidents to controlled waters in 1996 (see

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Chapter 7 Water Resources).

Utilities

3.4.5 Power is supplied to the airport through underground power lines that enter the site to the southwest and connect into a 225Kva transformer located to the south of the fire department. In accordance with CAA requirements, there is a backup system consisting of a new 250kVA generator. The power supply to the transformer is 11kV.

3.4.6 The land around the airport is drained by a series of interconnected tide locked drainage ditches (locally referred to as sewers), the largest of which are the 'Dengemarsh Sewer', the Mockmill Sewer and the Paine Field Sewer. Water levels in these main sewers are controlled by the Internal Drainage Board (IDB) via a series of sluices, although there are a number of drains to the east of the existing runway which are the responsibility of the airport. Further details on these are provided in Chapter 7 and the locations of the “sewers” are shown in Figure 7.1.

3.4.7 Given the age and location of the airport, the majority of the site has no piped drainage system and under an agreement with the EA, uncontaminated stormwaters are allowed to drain directly to soft verges and natural soakaways. Run-off from the operational runways and taxiways, which may have a higher contaminant loading, is drained over the edge of the pavement to open channels that are culverted within the runway-graded strip and ultimately discharge under licence into the local sewers (ditches).

3.4.8 Run-off from the newly resurfaced apron is collected and discharged to a newly constructed pollution interception basin and separate attenuation basin. The pollution basin has an impermeable liner and reedbeds for pollution treatment and is also equipped with sluice valves to enable any spill of hazardous materials to be contained and removed before it enters the surrounding drainage system. From the basins, the water enters the Dengemarsh Sewer at 'green field' run-off rates in accordance with the discharge consent issued by the EA.

3.4.9 Runoff from the terminal area and car park is drained by a positive piped system through a single stage interceptor to an outfall in the Dengemarsh Sewer. There are three oil separator tanks included within this system, located in the car park (next to the fire department), by the fuel farm and by the main hangar and of 750, 3,500 and 3,000 gallons respectively. The tanks are inspected regularly and emptied by tanker on a quarterly basis and disposed of at a licensed facility.

3.4.10 There is currently no public sewer connection to the airport or onsite sewage treatment plant, and foul sewage from the terminal building is drained to a storage tank located to the southern end of the car park. This is emptied by tanker twice a week, with up to 8,000 gallons removed per visit for offsite treatment at a licenced facility.

3.4.11 Further details on drainage and sewerage are provided in Chapter 7 Water Resources.

3.5 Current and Currently Permitted Operations

3.5.1 The facilities at LAA have historically supported and can currently accommodate up to 300,000 passengers per annum, with no restrictions to timing or number of flights.

3.5.2 LAA recorded approximately 22,400 fixed-wing aircraft movements (henceforth simply referred to as aircraft movements) and 1,200 helicopter movements in 2005. Of the

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aircraft movements, some 408 were derived from passenger flights (378 scheduled flights and 30 charter flights) and in total some 2,817 paying passengers passed through the airport, the majority via the LyddAir1 17-seater Trislander daily service2 to Le Touquet.

3.5.3 As outlined in Chapter 1, at this time LAA was a visual approach airport only, but the recent investment, particularly the introduction of the ILS, has resulted in the airport being increasingly attractive to airline companies, so passenger numbers in 2006 are expected to be significantly higher.

3.5.4 Of the other flights, the vast majority were single engine private flights (see Figure 3.3 for existing circuit pattern) some 21,000 including many undertaken for pilot training3 but others included 30 local cargo movements (generally night flights to the Channel Islands), local coastguard and military flights, as well as use by business and private jets.

3.5.5 Tables 3.1 and 3.2 below show the breakdown of aircraft types, activities and annual movements at the airport recorded in 2005 (figures are rounded to the nearest 100 movements).

Table 3.1 Breakdown of current GA movements at LAA Aircraft type Activity Average Total Annual Daily Movements4 Movements Single engine Training/private <57 20,575 Multi piston Training/private/commercial 4 1,460 (non-passenger) Small executive Commercial/business 1 365 jets TOTAL <62 22,400

Table 3.2 Current annual helicopter activity at LAA Indicative Helicopter Type Use Average Total5 Annual Daily Movements Movements R22, R44, H269, H369, Hu50 Training <3 1000 S06, A109, SK76, AS50, AS55 Business <1 100 GAZL, LYNX, CH47, PUMA Military <1 100 TOTAL <5 1200

3.5.6 As described earlier, steps are now in place to increase passenger use of the airport to the currently permitted level of 300,000 passengers per annum through a combination of increasing the number of scheduled and chartered services offered by current airlines and attracting new airlines to the airport5. Table 3.3 below provides an indicative fleetmix and number of movements per day and per annum that could be expected to cater for 300,000 passengers per annum without the proposed runway extension. General Aviation is also likely to increase and the effect of this has been assessed.

1 LyddAir is a UK Civil Aviation Authority (CAA) certified air carrier based at the airport and authorised to perform both scheduled and charter flights to domestic and international locations 2 out at 09:30, returning at 17:00 3 as offered by the Lydd Aero Club (tenants of LAA), a CAA registered training facility since 2001 4 Throughout the tables in this Chapter “total daily movements” includes both incoming and outgoing flights, split equally. 5 The ES has included General Aviation as well as the proposed increase in passenger numbers.

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Table 3.3 Predicted Passenger Aircraft Fleetmix and Daily and Annual Aircraft Movements for 300,000 Passengers per annum (without Runway Extension)

Aircraft Passenger Average Expected Expected Expected Expected Type Capacity number of total5 daily daily annual annual passengers movements passengers movements carried per passengers flight

BAE146 100 78 4 312 1460 113880

Dash 8 50 40 2 80 700 29200

ATR42-500 48 40 6 240 2190 87600

Saab 340 33 25 8 200 2920 73000

TOTAL - - 20 832 7270 303680

3.5.7 In addition, LAA is hoping to encourage a Heli-Charter to be based at the airport. This would approximately double the number of training helicopters using the facilities. Military use (by helicopters) of the airport is also projected to continue.

3.6 Future Developments at the Airport

3.6.1 Under its Permitted Development rights LAA can undertake a number of other activities on land within its ownership to ensure the safe operation of the airport. This includes work such as the implementation of the ILS, clearing of obstructions within the Clear and Graded Area and relocation of the existing DME. Given the potential for future growth, LAA may also need to undertake improvements to a number of the ancillary services present, and whilst the majority of these would also be expected to be sanctioned under their Permitted Development rights, others may require further planning applications to be submitted. However, even where permitted operations do not require planning permission, LAA is committed to continuing to liaise with key stakeholders, including SDC and Natural England, on these issues and to keep them informed of their operations.

3.6.2 One such issue that can be managed under LAA’s Permitted Development rights, is proposals for increased airport parking.. It has been calculated that some 510 car- parking spaces will be required in total to support 300,000 passengers per annum (including at least 25 disabled spaces), and these would be made up of 400 long stay spaces, 40 short stay and 70 staff spaces. As there are only 223 car-parking spaces available it is proposed that a further 287 spaces will be provided through the short- medium term reallocation of two of the existing stands on Bravo Apron to parking (under Permitted rights), so that no further land-take would be required to meet this need. Further information on this issue is provided in Chapter 14.

3.6.3 The other major development that is currently being considered, however, is the development of the new terminal building to accommodate up to 500,000 passengers per annum. This is the subject of a separate planning application. The long-term business plan of LAA is to increase passenger capacity to 2,000,000 passengers per annum, although this is discussed only as part of the Masterplan lodged with the Department of Transport, Although no planning application is being submitted for 2,000,000 passengers at this stage, Chapter 18 (Cumulative Impacts) looks at the impact of both the proposed increase to 500,000 and a potential scenario of 2,000,000 passengers per annum.

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3.7 Non-Normal Operations

3.7.1 The 2005 “Lydd Airport Aerodrome Manual & Emergency Orders” outlines the hierarchy for operational and safety management at LAA and the roles and responsibilities of key staff in the event of an accident, emergency or other non- normal operation occurring.

3.7.2 The Managing Director has overall responsibility for aviation safety at LAA. The Airport Operations Manager (AOM) is responsible for maintaining a safe and efficient operating environment. The Senior Air Traffic Control Officer (SATCO) has various responsibilities, including the competence of controllers, training, and taking a lead role in the formulation and implementation of the unit’s safety management systems and the Senior Airport Fire Officer (SAFO) is responsible for ensuring the airport Rescue and Fire Fighting Services (RFFS) meets or exceeds the requirements of the Airport Improvement Plan (AIP) and CAP 168 (CAA policy on Licensing of Aerodromes).

3.7.3 In addition, key responsibilities are assigned to the following airport committees:

• The Aviation Safety Committee, which deals with airside safety issues, and comprises of Air Traffic Control, RFFS and representatives from aircraft operators at LAA;

• The Emergency Planning Committee, which covers emergency planning issues, and comprises of Kent Fire and Rescue Service, Kent Police, Kent Ambulance Services HM Coastguard, Air Traffic Control (ATC), RFFS, Kent County Emergency Planning Department and Aerodrome Management;

• The Safety Review and Pre-Planning Committee, which looks after the Safety Management System and is chaired by the Managing Director of LAA; and

• The Airport Consultative Committee which meets regularly to discuss issues relating to the airport and the local community and includes representatives of British Energy (Dungeness); Hythe Ranges; Kent County Council; Lydd Airport Action Group (LAAG); Lydd Airport; Lydd NR Greatstone Residents Association; Lydd Ranges; Lydd Town Council; New Romney Town Council; and Shepway District Council, amongst others. 3.7.4 In the event of an accident, the Duty Manager (one of the named management personnel) will take the lead role in decision making immediately. Responsibilities would include liaising with ATC / Air Accidents Investigation Branch (AAIB) with regard to the movement of any wreckage, taking the lead role on infringement of the aerodrome’s surfaces and specific tasks in relation to securing specific buildings for use after an accident.

3.7.5 The SAFO is responsible for ensuring that all vehicles equipment and media used meet requirements of UK CAA, International Civil Aviation Organisation (ICAO) and other relevant regulatory bodies as well as for keeping records for vehicles, equipment and media in compliance with CAP 168. The SAFP is also the named person for aviation fuel control at airport and ensuring that the procedures for the receiving, storage, delivery and quality control of aviation fuel dispensed at LAA, as contained in the Lydd Airport Aviation Fuel Document, are followed.

3.7.6 The emergency orders outlined in the Lydd Airport Aerodrome Manual cover a range of issues, including aircraft accidents and fires amongst other incidents. The emergency response plans are considered a “living document” and will continue to be developed and upgraded as the airport develops and its use grows.

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3.7.7 Planned future versions of the manual will also include formal procedures for responding to the environmental side of non normal operations at LAA, and an Environmental Management Plan (EMP) for the airport is also to be developed. The EMP itself will incorporate the mitigation outlined within this ES as it relates to the best practice controls and processes required to deal with any environmental issues that may result from non normal operations. As such, it will include, but not be restricted to, actions regarding the following:

• spills on the ground e.g. from the oil separators or the fuel farm;

• spills going into a watercourse;

• fire water disposal;

• impacts of a plane crash;

• sewage and cesspit leaks;

• management of the clear and graded area;

• fuel dumping of aircraft;

• fuelling procedures to prevent accidents;

• Protection from tanker or aircraft spills;

• Location and checking of spill kits;

• Wildlife management plans (including the Lydd Airport Bird Control Manual);

• Communications (e.g. contacting the EA in the event of a spill);

• protection of wildlife and habitats; and

• Management Responsibilities, Reporting Structure and Monitoring Procedures.

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CHAPTER 4

PROJECT DESCRIPTION

CHAPTER 4 LAA

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4 PROJECT DESCRIPTION

4.1 The Existing Runway

4.1.1 LAA currently has one operational runway which may be approached from either direction. The runway designations are 03 for an approach from the Southerly direction and 21 from the North. The designations are related to the indicated magnetic heading associated with the approach. The runway surface measures 1505m x 32 m. A secondary cross-runway was taken out of service some years ago, and part of this now forms the Bravo apron.

4.1.2 The choice of which threshold a pilot uses for taking off or landing is dependent upon a number of factors, the most important factor usually being that of wind direction. At Lydd the prevailing wind is from the south westerly direction and this favours the use of Runway 21 approximately 70% of the time as aircraft ordinarily take-off or land into the prevailing wind.

4.1.3 Under the CAA Aerodrome Reference Codes (see Table 4.1 below), the current runway length of between 1200m and 1800m means that the aerodrome is designated as a category “3C” facility. As such it is licensed for aircraft with wingspans of 24-36m (i.e. up to the size of B737-700s and A319s), which could use LAA to fly to most European destinations, although the largest planes would require an extended runway length of 1,768m and 1,722 m respectively to allow them to take off with full payloads.

Table 4.1 CAA Aerodrome Reference Codes Code element 1 Code element 2 Code Aeroplane reference Code Wing span Outer main gear number field length Letter wheel spana 1 Less than 800m A Up to but not including Up to but not including 15m 4.5m 2 800m up to but not B 15m up to but not including 4.5m up to but not including 1200m 24m including 6m 3 1200m up to but not C 24m up to but not 6m up to but not including 1800m including 36m including 9m 4 1800m and over D 36m up to but not including 9m up to but not 52m including 14m E 52m up to but not including 9m up to but not 65m including 14m F 65m up to but not including 14m up to but not 80m including 16m Source: CAA CAP 168 and International Civil Aviation Organisation (ICAO) Annex 14 a Distance between the outside edges of the main gear wheels

4.1.4 In addition to runway length, pavement bearing strength is also important in determining the maximum aircraft weight (and hence payload) that an airfield can accept. The CAA issues runways with a Pavement Classification Number (PCN), whilst aircraft are given an Aircraft Classification Number (ACN) and provided that the ACN is less or equal to the PCN, the aircraft can operate without any weight restrictions.

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4.1.5 The existing runways were resurfaced in 2005 and now consist of approximately 50mm of bituminous and 190mm of asphalt surfacing over a 150mm cement-bound base and a 550mm granular sub-base. This structure means that the pavements have been given a PCN value of 45, allowing planes such as the B737-700 and Airbus A319 (which have typical ACN's of 42 and 44 respectively when operating at maximum take-off weight) to operate out of the airport without any weight restrictions.

4.1.6 Details of the runway lighting and drainage are provided in Sections 3.3.6 and 3.4 respectively.

4.2 The Proposed Runway Extension

4.2.1 The proposed runway extension would involve the construction of approximately 294m of additional pavement to the northern end of the existing runway, resulting in a total runway length of 1799m with a further 150m starter extension beyond the threshold of Runway 21, See Figure 4.1 and 4.2. The runway width would, however, be retained at 32m and as the starter extension is not recognised by the CAA as part of the runway, the airport will remain a CAA Category 3C operation overall.

4.2.2 As the proposed extension is being undertaken to extend the runway at threshold 21, a Runway End Safety Area (RESA) is also required to comply with CAA recommendations. This will run some 300m from the end of the threshold and will be twice the width of the proposed runway (64m). This will provide a clear and graded area in the event of an aeroplane undershooting or overrunning the runway.

4.2.3 Construction of the runway extension is expected to take approximately 4 months to complete, at an estimated capital cost of £2 million and will involve the following works:

• Excavation of top soil to a depth of approximately 750mm;

• Backfill with 300mm of material reclaimed from the disused cross-runway & crushed & compacted onsite; and

• Cover with 250mm of coarse grade Road Base Asphalt and 200mm of fine grade Marshal Asphalt, with the aggregate size and layer thickness reducing up to the wearing course. 4.2.4 A number of drains will need to be realigned as part of these works and the proposed construction methodology for the drains is as follows:

• The new sections of drains will be constructed first;

• The junctions between the new drains and the old drains will be formed by stone filled gabions; and

• The old drains will be backfilled with 250mm layers of spoil and each layer will be compacted before the next layer is added. 4.2.5 The total landtake required for the construction of the runway extension is 13.38 ha made up of 1.04ha for the runway extension, 9.00 ha for the Clear Area, 0.58ha for the Starter Extension and 2.23 ha for the RESA area (See Figure 4.3a and 4.3b). During the construction works, approximately 300m of the existing runway from the

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edge of Threshold 21 will be taken out of service to create the required worker safety clearances, leaving a reduced runway length during working hours.

4.2.6 Some 19,100m3 of spoil will be generated by the runway excavation works and a further 365m3 from the excavation of the new drains. None of this is expected to contain contaminated material, so it is proposed that it will all be spread out within the Clear Area and grassed over, with no spoil taken offsite. Further information on potential impacts associated with spoil excavation and disposal works is provided in Chapter 6 Ground Conditions of this ES.

4.2.7 Approximately 10,000m3 of construction material will be required for the runway extension, starter extension and temporary access road (see below). Based on a typical HGV capacity of 20m3 this will create approximately 500 HGV movements and the potential impact of which is assessed within Chapter 14 Traffic and Transport.

4.2.8 It is envisaged that the haul route for the runway extension will be similar to that used for the apron construction in 2005, when an asphalt plant was set up onsite and bulky construction materials delivered to Ashford by rail before onward transport to site by road. HGV movements will use the A2070 from Junction 10 of the M20 until it intersects with the A259 and then south on the B2075 until the junction with the airport access road for deliveries. All material will be stockpiled in order to minimise HGV movements to a couple of weeks. The low level stockpiling (up to 2m) will be located within the construction compound in the vicinity of the main apron to the north of the existing terminal (See Figure 4.3a and 4.3b). During construction HGVs will access the works via a fenced off roadway placed around the edge of the new apron. The vehicles will use the parallel taxiway and then travel along a temporary access road to the end of the Starter Extension. The road will be comprised of crushed stone laid on a geotextile membrane and will be removed after use.

4.2.9 Drainage proposals for the scheme have been agreed with the EA and the IDB based on estimated peak runoff rates of approximately 637 litres per second (based on a 5 minute duration storm with a return period of 1 in 5 years and rain intensity of 90.9mm per hour). The length of old drains to be abandoned is 1,013m and the length of new drain to be constructed is 1,256m. The average depth of the new drains is 2m and the width is 0.75m. The runway has been designed with slopes falling at a gradient of 1.5% away from the centre line to the new drains which will surround both the runway and Starter Extension as shown on Figures 4.1 and 4.2. Silt traps and interceptors to capture any oil, aviation fuel and (if necessary) fire fighting foam will also be provided.

4.2.10 The existing runway lights at threshold 21 will be relocated from the end of the runway to sites within the Starter Extension and the RESA. The runway lighting at threshold 03 will not be affected by the proposed development.

4.2.11 It is anticipated that 40 construction staff will be required throughout the construction period. The construction working hours are anticipated to be 07.30-19.30 Monday – Friday and 07.30 – 15.30 on Saturday. There will be no works outside these periods without the written approval from SDC.

4.3 Operational Implications of the Runway Extension

4.3.1 The proposed runway extension will not affect either the size of the aircraft or the numbers of flights or passengers that the airport can accommodate, nor will it alter the flightpaths available for aircraft landing or taking off from LAA. It will, however, enable the larger B737-700 and A319 aircraft to take off with full payloads, and as such will enable LAA to support operations flying to destinations further afield than can

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currently be accommodated, and will also encourage the development of a slightly modified fleetmix, as shown in Table 4.2 below, to achieve the 300 000 passengers per annum target.

Table 4.2: Predicted Fleetmix and Aircraft Movements for 300,000 Passengers (with Project)

Aircraft Passenger Average Expected Expected Expected Expected Type Capacity number of daily daily annual annual passengers movements passengers movements passengers carried per flight

B737 160 136 2 272 700 99280

A319, 140 112 2 224 700 81760

BAE146 100 78 2 156 700 56940

Dash 8 50 40 2 80 700 29200

ATR42-500 48 0 0 0 0 0

Saab 340 33 25 4 100 1460 36500

TOTAL - - 12 832 3630 303680

4.3.2 Based on 300,000 passengers per annum with the runway extension there will be 12 aircraft movements per day (defined as either an aircraft landing or take-off), compared to the 20 movements per day expected without the runway extension (see Table 3.4) i.e. the works are expected to result in a net reduction of 8 movements per day at the 300,000 passenger level. Whilst there is likely to be some seasonal variation in passenger numbers this will be determined by the business plans of the airline operators using the airport and so a ‘busiest’ period cannot be determined at this stage, (for example peak traffic for business purposes will differ in timing from peak traffic for long or short term vacation periods).

4.3.3 Whilst proposals for the increased use of the airport by larger aircraft (with or without the runway extension) would typically see an increase in takeoff from Runway 03, the development of the starter extension will also provide the larger aircraft with an extra stretch of asphalt on Runway 21 prior to take off, and as such they are likely to preferentially use this runway. (Runway 21 will also be preferred for landings as it is the only one with an ILS at present). As a result, the 70:30 ratio of use for the 21/03 runways is expected to be retained, with Runway 03 likely to become used primarily by smaller aircraft for takeoff.

4.3.4 Larger aircraft and jets using Runway 21 will still be required to turn right shortly after take-off to avoid the Dungeness and Lydd Ranges restricted airspace. Smaller aircraft (General Aviation) using the runway could turn left on condition that they maintain clearance from the Dungeness restricted airspace.

4.3.5 The design period for the proposed runway extension is anticipated to be in the order of 50 years although the regular maintenance that will be undertaken in accordance with CAA requirements to ensure the safety of both aircraft and users is likely to

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extend this. At the eventual point when decommissioning is required it would be undertaken in accordance with best practice approaches in use at that time, and this aspect is therefore not discussed further in this ES.

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4.4 Project Need

The National and Regional Need

4.4.1 The UK Government recognises that the national economy, and its current favourable global position are, in part, dependent upon maintaining long term, sustainable growth in the UK airport capacity. The Government’s Aviation White Paper (The Future of Air Transport, December 2003), which sets out a strategic framework for the development of airport capacity in the UK to 2030, states that there has been a five fold increase in air travel in the past 30 years and projects an increased demand of 2 to 3 times current levels by 2030. It also states that failure to meet capacity could have serious national and regional consequences, and encourages the development of small regional airports to meet this need, as discussed further below.

4.4.2 In the South East, passenger numbers are increasing and were over 125.5 million in 2004 at Heathrow, Gatwick, Stansted and Luton alone. Currently 80% of air travellers using the main London airports are from the South East and more than half the UK demand in 2030 is forecast to be for airports in the South East1.

4.4.3 This growth has serious implications for the movement of air traffic, as the London Terminal Manoeuvring Area (TMA) is one of the busiest airspaces in the world. Heathrow and Gatwick are both currently approaching runway capacity limits while Stansted and Luton are increasingly affected by the congestion in the airspace.

4.4.4 As a result of this demand, the Government states in the White Paper that it “wishes to encourage the growth of regional airports in order to support regional economic development, provide passengers with greater choice, and reduce pressures on more over-crowded airports in the South East”. In addition, some of the White Paper’s principal conclusions about new runway capacity in the South East include:

• There is an urgent need for additional runway capacity;

• First priority is to make best use of the existing runways;

• There is scope for other existing South East airports to help meet local demand, and their further development is supported in principle; and

• No alternative locations for new airports will be supported. 4.4.5 The advantages and disadvantages of alternative regional airport locations are shown in Table 4.3 and 4.4 below.

4.4.6 The White Paper also recognises the important part that small airports have to play in the future provision of airport capacity in the South East and considers that LAA “could play a valuable role in meeting local demand and could contribute to regional economic development. In principle, we would support their development, subject to relevant environmental constraints.” The South East’s Regional Transport Strategy mirrors this statement, by recognising that “there is scope for other existing South East airports, to help meet local demand, and their further development is supported in principle, subject to relevant environmental considerations”.

1 Department of Transport (2003):The Future of Air Transport.

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4.4.7 The severe congestion experienced in the South East usually results in delays for flights entering and leaving the UK. In particular, aircraft leaving the region’s four main airports (Heathrow, Luton, Stansted and Gatwick) have to traverse the London TMA Holding Stacks to reach the cruise levels, with associated implications for both journey times and overall safety. LAA is outside the Holding Stack Areas and therefore has clear skies between the runway and cruise levels. Table 4.5 illustrates the major towns surrounding LAA within which approximately 1.3 million people live. The location of LAA in Kent may significantly reduce journey times for local residents wishing to fly without having to travel to airports north of London such as Stansted and Luton.

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Table 4.3 - Tier 1 London Airport Expansion Options

Airport Current Status Advantages Disadvantages Heathrow Has recently expressed an It is the busiest airport in the UK and Europe’s premier Air Quality – The site already has degraded air quality due to the high levels interest in building a third international gateway of aircraft movement therefore the addition of another runway would only runway and a 6th terminal, increase emissions and reduce the current air quality levels. which would almost double its The Governments White Paper “The Aviation White Paper carrying capacity as part of its - The Future of Air Transport,” published in December Space – It has been pointed out that in order to build this runway extension overall airport expansion 2003, supports Heathrow as the main International Hub in there is the possibility that 700 homes will have to be demolished. the UK. program Noise – Due to the density populated area it is expected that approximately In 2000, 117mppa (million There are well-established transportation links (railway 150,000 people will be affected by the new flight path. passengers per annum) flew line direct to Central London and the M25 and M4) to the from airports in the South East airport. over half of this traffic flew from Heathrow Airport Gatwick In 2003 Gatwick Airport was The second runway would enable some flights to be Space – If the proposal had gone ahead, 470 homes and some listed proposing two new runways removed from Heathrow and ease the congested air buildings would have been demolished which would increase the routes above Heathrow passenger numbers by almost Legal – Unlike at other airports where the Government is considering options four times current levels There are well-established transportation links (railway for runways, at Gatwick there is a legally-binding agreement which the then line direct to Central London and it is on the M23) to the British Airports Authority signed with West Sussex County Council in 1979. Gatwick Airport is the busiest airport This meant that BAA could not construct a second runway at Gatwick before single runway airport in the 2019 and it also prevents BAA from using the standby runway when the main world; handling 29.5 mppa of runway is operational the 117 million passengers

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Airport Current Status Advantages Disadvantages Stansted As part of the White Paper the The White Paper supports the runway expansion at Noise – Areas that would be affected by increased noise levels are government produced in 2003, Stansted claiming that the first expansion to the South Bardfields, Eastons, Takeley, Dunmow, Hatfield, Sheering and Roding, all of it was proposed that a second East’s capacity should be at Stansted around 2011/2012 which have a reasonable population size runway should be built at Stansted Airport There are well-established transportation links (railway Air Quality – There in an area around Stansted Airport is built up and would line direct to Central London and the M11, M25, A14) to be greatly affected by the degradation of air quality the airport Ecological – The 1000 year old Hatfield Forest in close proximity to the airport and the proposed new rail line to support the airport would be routed through or under the Forest Cultural Heritage – If the runway was to be built it would mean the destruction of approximately 200 homes, two or three Scheduled Ancient Monuments and between 29 and 64 Grade II listed buildings Land Take – Massive landtake would be required as thousands of new houses to accommodate airport workers as a result of the relocation from the Stansted area Luton Consultation over the The White Paper suggests that there would be sufficient Topography – The proposed expansion could result safety issues as it is expansion of Luton Airport is demand to justify expansion of Luton to the full potential of located within a valley being undertaken although it is a single runway (approximately 30mppa) in the period up believed that the construction to 2030 even with two new runways at other South East Infrastructure - The local infrastructure would be unable to cope with of two runways are being airports increased levels of movement considered The Luton/Dunstable area is identified in Regional Archaeology - The area is sensitive as not only is there a number of grade Planning Guidance as a Priority Area for Economic two listed buildings in close proximity but also towns of historic value such as Regeneration and, along with Bedford, is designated as a Hitchin and Great Offley Growth Area in the Communities Plan. The continued expansion of Luton Airport has the potential to play a key role in delivering employment-led growth in this area

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Table 4.4 - Tier 2 Regional Airport Expansion Options –(South East):-

Airport Current Status Advantages Disadvantages Biggin Hill The Biggin Hill Master Plan envisages The airport has 1,800m / 6,000ft runway that is Cannot expand the runway as it is situated on a hill, hemmed in by “limited growth” and “small scale long enough to accommodate business jets housing and roads development” but also includes the including Global Express, Airbus A319CJ and introduction of some scheduled flights and Boeing Business Jets (BBJ) Airspace congested and they have to pay NATS 100k per annum to extended operating hours suggests a dofor radar operations due to close proximity close proximity with strategy for modest scale growth of future No runway slots are needed London City airport operations at Biggin Hill Airport, to Prime location just 12 miles from Central Hours are limited to 0730 – 2100 weekdays and 0900 - 2000 at 500,000 passengers a year.. The Airport’s London and within easy reach of the motorway weekends and on Public Holidays operations are governed by it’s lease network conditions with the London Borough of Ecology – Four ancient woodland sites would be directly affected Bromley setting out restrictions on noise, (approximately 65ha) and there is potential for indirect effects. Woodland operating hours, aircraft size etc.This is Trust view expansion as unsustainable and there is potential for significant despite the fact that their attempt to impacts on the green belt and adjacent conservation areas reinterpret the existing lease so as to Noise and safety – DoT believe that major impacts will occur to the local permit scheduled flights was rejected by a community (a large population lives in close proximity to the airport) through judge last year (2004)in 2004. They intend the increase of noise and airspace congestion to re-negotiate the legal terms of operations with Bromley the Council who currently ban individual passengers from buying a ticket on flights from Biggin Hill [we have not checked this] Cambridge Cambridge Council agreed relocation in European commercial services would be Commercial – The airport operators are concerned whether the airport is 2002 due to importance of operator supported by a strong local business base and commercially viable as the complexities of relocation were underestimated (Marshall’s) to town’s economic viability good access to a wider area via the M11 and expansion was met with considerable local opposition The overall effect on the local road network would be positive with infrastructure being provided to give more direct access to the A45 and M11

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Airport Current Status Advantages Disadvantages Farnborough There have been talks on extending the No runway slots - exclusive to corporate Safety – The eastern approach to Farnborough, within what would be the runway to increase the commercial activity aircraft safety zone, is within a residential area. The situation is exacerbated by the fact that the runway is lower than Farnborough thus bringing aircraft in close Good transfer infrastructure – road, rail and proximity to the housing helicopter to central London There are well-established transportation links (railway line direct to Central London and the roads) to the airport Manston There is concern as to the financial Manston has a single runway of 2,7520 Distance – The airport is situated in a remote location away from likely liability/stability of the company. In July metres, the fifth longest in the UK and it has sources of passengers (three quarters of its catchment area is water). It is (Kent 2004, auditors warned of "fundamental infrastructure in place subject to a section 106 agreement with the Thanet District Council which International uncertainties" over its future, following severely affects its capacity although this agreement is currently being Airport) losses of £17m for the 12 months to March reviewed. The airport has no night flights, there are limitations on large 2004, against £12.8m the previous aircraft usage due to noise abatement (approaches over Ramsgate and yearManston has not been fully operational Herne Bay) and problems with taxiways since PlaneStation, which owned EUjet and also ran the airport, filed for voluntary The Runway often suffers from strong crosswinds and is more prone to fog administration on 26 July 2005 than Lydd Thanet is away from likely sources of passengers which together the noise impact on Ramsgate is also predicted to be a problem The new owners Infratil in February 2006 announced the return of passenger Much of the airport's infrastructure is in need of replacement e.g. radar, services with a limited service lighting, fuel farm control tower and parts of the terminal building. Manston has not been fully operational since PlaneStation, which also ran the airport, filed for voluntary administration The new owners Infratil in February 2006 announced the return of passenger services with a limited service Manston has not been fully operational since PlaneStation, which also ran the airport, filed for voluntary administration. The new owners Infratil in February 2006 announced the return of passenger services with a limited service Shoreham Physical limitations of the site at Shoreham The airport benefits from direct access from Space – There is lack of space for a new runway extension as there are a preclude consideration of the development the main A27 and a main line rail station is number of residential development within the vicinity of the airport on a significant scale within easy reach

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Airport Current Status Advantages Disadvantages Cliffe The planning application was rejected due Supports regeneration in the Thames Gateway Ecology – RSPB are concerned that the airport expansion will completely to concerns on the surface proposals and area destroy a number of wildlife sites and indirectly effect the following: not bird strike issue including surrounding area and other inevitable knock-on effects: Thames Estuary SPA, Thames Estuary Ramsar, South Thames Estuary SSSI, RSPB Northward Hill Nature Reserve Southend The planning application went to The airport would create economic Land Use – Approximately half of the land in the airport is designated green consultation in April 2005 [we are checking development in the East Thames Gateway belt, including part of the site of the new multi-modal interchange the current status of this] area Land Take – Land for the runway extension would require the demolition of Planning permission has been given for a No changes to existing flightpaths are a listed church and is also affected by the railway, roads and a number of new passenger terminal and multi-modal proposed other adjacent properties situated adjacent to the runway transport interchange No major additional areas of land are required Noise – With a high proportion of residential properties in the surrounding Further extensions to the passenger area, noise levels are expected to be high as a result of the increase in terminal building can be added, subject to 24 hour operation is a possibility activity planning consent being granted, as Hoping to open an airport railway station demand grows Good weather record

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Table 4.5 Population Figures for the Major Towns surrounding LAA Major Towns Population Ashford 105,900 Brighton & Hove 133,600 Canterbury 139,500 Dover 105,400 Eastbourne 91,400 Hastings 63,500 Lewes 92,900 Maidstone 141,500 Royal Tunbridge Wells 104,600 Folkestone 98,200 Tonbridge & Malling 105,600 Crowborough & Hailsham 140,800 Total Population 1,322,900 Source: National Statistics at http://www.statistics.gov.uk/default.asp 2003

4.4.8 The Government’s wider objectives of sustainable communities need to be reflected in airport growth, as the Government recognises the importance of airports for the development of regional and local economies. There is a need for local regeneration in the area surrounding LAA; Lydd town is referred to as a Rural Priority Area (RPA) and an Enterprise Zone within RPG9, and the need to create new jobs and enterprise. The Kent and Medway Structure Plan2 recognises the social and economic benefits associated with expanding air services and that regional airports can promote regeneration, whilst ensuring that environmental and community interests must be safeguarded. It has the following views on LAA:

‘The airport at Lydd plays an important part in serving local business needs and providing opportunities for recreational flying. Enhancement of the airport’s existing facilities would improve the airport’s ability to cater for general aviation and passenger traffic and capture scheduled and charter business. The operator’s own masterplanning study for the airport envisages growth of capacity to approximately 2,000,000 passengers per annum by 2014. The immediate proximity of international environmental designations to Lydd Airport pose a specific test for the nature and degree of any expansion including the relationship between the need for/acceptability of a runway extension at Lydd and the attainment of a significantly higher passenger capacity and throughput. Development proposals will be assessed against the common set of assessment criteria to be applied to both Manston and Lydd, including harm to internationally or nationally designated environmental areas’.

4.4.9 Kent County Council does consider LAA both in its current state and in the future to be very important to the future of East Kent and to the growth plans for Ashford. The Kent and Medway Structure Plan (Adopted July 2006) through Policy TP25 supports the expansion and further development at Lydd3. Kent County Council also supports development at LAA through Policy S32 of the Local Transport Plan and have made reference to include specific support for LAAs expansion proposal (see Appendix 5.1). For further information on the planning policies refer to Chapter 5.

3 Kent and Medway Structure Adopted Plan: Adopted Policies and Key Diagram July 2006

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The Local Need

4.4.10 LAA is recognised in the first paragraph of the Shepway Adopted Local Plan (2006) as a key part of Shepway’s strategic position between the UK and mainland Europe, providing a gateway to continental Europe. Kent’s role as a gateway to Europe is also an integral part of Kent’s Economic Development and Regeneration Framework.

4.4.11 The employment chapter of the Local Plan looks to retain Shepway’s competitiveness, by further improving and exploiting “the advantages offered by links to domestic and international markets”. The proposed development at LAA supports this view, by further developing the links to these markets. LAA is referred to specifically within the Plan’s Employment Objectives, where it is stated that development at LAA will be encouraged for aviation purposes, in order that employment opportunities may be expanded on Romney Marsh.

4.4.12 Within the transport chapter of the Local Plan, LAA is specifically referred to, where the airport is recognised as an important facility for the District with the potential for improvement and expansion. LAA is again recognised as an important source of employment for the local area. There is a specific policy to LAA in the form of Policy TR14.

The Economic Advantages of LAA

4.4.13 LAA is located on the Dungeness peninsula, approximately 50 miles southeast of central London. This has 4 major advantages over other regional airports in the south east, namely:

• As the runway lies across the peninsula, noise nuisance is relatively low;

• Local sea and land breezes lift local fog, providing a very good weather record;

• The airport is positioned under the core of the major U.K air traffic flow, (which goes to the southeast) producing significant airspace advantages; and

• Engine emissions are mostly out to sea, which provides further environmental advantages. 4.4.14 In addition, the uncongested airspace around the airport means that aircraft are able to reach optimum fuel burn cruising altitude more quickly at LAA than at other airports in the south east, whilst residents in the area will also benefit from a reduction in surface journeys if they do not have to travel north to the other London airports in the region.

4.4.15 Such residents provide a strong regional market for the airport, with in excess of 1.1 million citizens located within a 1 hour’s drive time and the wider London market of more than 13 million also easily accessible. The airport is located some 20minutes drive from both the M20 motorway and Ashford International station, and on completion of the Channel Tunnel Rail Link central London will be within one hour of LAA.

4.4.16 Further information on economic benefits arising as a result of the proposed airport expansion is included in chapter 17.

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4.5 Alternatives

4.5.1 As part of the design process a number of alternatives have been reviewed and assessed for their suitability for the proposed runway expansion at LAA.

4.5.2 Of these, the “Future Assessment Conditions” scenario allows for the growth of up to 300,000 passengers per annum (i.e. the maximum that the existing terminal can accommodate), using the existing runway length of 1505m, which is capable of supporting Boeing 737-700’s and Airbus 320’s (although without a full payload). Impacts of the “Future Assessment Conditions” scenario are addressed throughout this ES.

4.5.3 The option of extending the runway to the south was considered but was discounted as restrictions caused by the existing operational railway line that runs from the Dungeness Power Stations to Ashford would prevent sufficient land being available at the end of the extended runway for safe operation. An extension to the south would also result in aircraft flying directly over the Lydd Firing Range, which is not permissible.

4.5.4 The option of converting the existing runway into a parallel taxiway and construction of a new parallel or near parallel runway beside the taxiway was considered but has been discarded as it would result in unacceptable direct habitat loss from either the adjacent SSSI to the west or the SAC to the east.

4.5.5 The cross runway could be reopened and extended to the west but this is not considered feasible as the prevailing cross wind direct is not considered operationally effective.

4.6 Summary

4.6.1 The current proposal is to construct a runway extension of approximately 294m of additional pavement to the northern end of the existing runway, resulting in a total runway length of 1799m. A further 150m starter extension beyond Threshold 21 is also proposed. Whilst a number of drains will be affected by the proposed runway extension, new sections of drains will be constructed and overall there will be an increase in the total length of drains as a result of the proposed development.

4.6.2 Construction of the runway extension is expected to take approximately 4 months to complete, at an estimated capital cost of £2 million. The increased length of runway will enable larger aircraft such as the B737-700 and A319 to take off with full payloads enabling LAA to support operations flying to destinations further afield than can currently be accommodated.

4.6.3 Following an assessment of alternatives, the proposed project is considered to be the most economically and environmentally viable and the construction and operation of the runway extension will directly contribute to meeting some key objectives of both national and regional development plans.

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CHAPTER 5

PLANNING POLICY FRAMEWORK

CHAPTER 5 LAA

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5 PLANNING POLICY FRAMEWORK

5.1 Introduction

5.1.1 The purpose of this chapter is to set out the relevant national, regional, county and local planning policies and guidance that will have implications for the future growth of London Ashford Airport (LAA). The implications of the project in supporting or detracting from each of the relevant national, regional, county and local planning policies and guidance listed below is highlighted. Policies and guidance relating to specific areas such as air quality are dealt with in the specialist chapters. A summary of planning policy relevant to the proposed development at LAA is shown in Figure 5.1 below.

NATIONAL GUIDANCE White Paper on Aviation (2003) Civil Aviation Bill (2005)

Central Government Planning Policy PPS1 (2005) PPG4 (1992) PPS7 (2004) PPS9 (2006) PPG13 (2001) PPG15 (1994) PPG16 (1990) PPG21 (1992) PPS23 (2004) PPG24 (1994) PPG25 (2001)

REGIONAL GUIDANCE RPG9 (2001) (including replacement Chapter 9 (RTS, 2004)

LOCAL POLICY Kent and Medway Structure Adopted AND GUIDANCE Plan (2006)

Kent County Council Local Transport Plan 2001-2006

Kent Prospects – Economic Development and Regeneration Framework to 2006

Ashford’s Future (2005)

Shepway District Local Plan Adopted (2006)

Figure 5.1 Summary of planning policy relevant to the proposed development at LAA

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5.2 Planning History

5.2.1 In 1992 a planning application was submitted to Shepway District Council for an extension of 296 metres to the existing runway. The application was called in and determined by the Secretary of State for the Environment, subsequently it was granted planning permission subject to ten planning conditions. These planning conditions relate primarily to the operational requirements for the airport in terms of aircraft movements and operational hours. The existing planning permission was not implemented at that time due to economic conditions, however with the recent investment at the airport, the current application which this ES accompanies will be submitted.

5.3 National Guidance

White Paper on Aviation (2003)

5.3.1 In December 2003, the Government published its White Paper ‘The Future of Air Transport’, which provides a clear, national, strategic framework for the development of air travel over the next 30 years. The White Paper is clearly of the opinion that airports are contributors to the development of local and regional economies, stating that they “attract business and generate employment and open up wider markets. They can provide an important impetus to regeneration and a focus for new commercial and industrial development.”

5.3.2 In particular, the Government believes that airports:

• provide convenient access to international markets through the availability of flights for business travel, so attracting inward investment to a region; and

• facilitate the world-wide rapid delivery and logistics requirements of modern businesses - an important factor in assuring the future competitiveness of both the UK and regional economies. 5.3.3 These ideas relating to LAA are discussed further in Chapter 17.

5.3.4 The White Paper makes a commitment to do more to reduce and mitigate the environmental impacts associated with air travel and development. As a result the Government has stated that “the amount and location of future airport capacity must properly reflect environmental concerns”; and provide the following principles to provide a framework to manage the local environmental impact of aviation:

• we will respect targets on air and water quality which have been agreed to protect human health and the wider environment;

• we will require that airport developments are consistent with existing arrangements for the control of the noise impacts of aviation; and

• we will work constructively with our European and, where appropriate, international colleagues to develop further procedures and regimes for managing noise, including night noise. 5.3.5 Local controls should operate within these principles to manage the environmental impact of aviation and airport development so that:

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• noise impacts are limited, and where possible reduced over time;

• local air quality is maintained within legal limits across all relevant pollutants in order to protect human health and the wider environment;

• loss of landscape and built heritage is avoided wherever possible, and otherwise minimised and mitigated to the greatest extent possible;

• all relevant water quality and other mandatory environmental standards are met;

• surface access to airports is designed to help limit local environmental impacts; and

• impacts on biodiversity, such as disturbance of habitats and species, are minimised. 5.3.6 This ES outlines the measures and mitigation that will be incorporated in order to comply with the local controls as outlined above.

5.3.7 The White Paper also makes specific reference to LAA, where it states that LAA could “play a valuable role in meeting local demand and could contribute to regional economic development. In principle, we would support their development, subject to relevant environmental considerations”.

5.3.8 The White Paper also addresses the threat of climate change through the reduction of CO2 emissions. It states that significant damaging climate change has an environmental limit that should not be breached and therefore there is a need to keep the UK on a path to 60% cuts in CO2 emissions by 2050. The reduction in CO2 alongside the continuation to decouple economic growth from energy use and pollution is equally important consideration. The Paper sees a priority in reducing CO2 emissions by strengthening the contribution of energy efficiency and renewable technology and by signalling to British manufacturers to be ahead of the industry by developing green technologies so that they can play a larger part in the world’s future prosperity. The Paper also addresses the use of a carbon emission trading scheme to provide clear incentives for investment in energy efficiency and cleaner technologies at the lowest cost.

Civil Aviation Act (2006)

5.3.9 The Civil Aviation Act receive Royal Assent on 8 November 2006. The Act implements the important ‘Future of Air Transport’ White Paper commitments to sustainable aviation and protection of passenger interests. Under the Act, measures have been brought in to tackle aircraft noise, with airports given powers to enforce noise amelioration measures beyond airport boundaries and an ability to take economic measures to reflect aircraft straying from routes designed to minimise noise; and the Act makes explicit the powers of airports to set charges which reflect local emissions from aircraft with the Secretary of State now having the power to direct airports to levy such charges.

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Central Government Planning Policy

5.3.10 Central Government planning policy advice is issued in the form of Planning Policy Guidance Notes (PPG) or Planning Policy Statements (PPS). PPS are gradually replacing the PPG notes.

5.3.11 These explain statutory provisions for planning and provide guidance to Local Authorities and others on planning policy and the operation of the planning system.

5.3.12 The following are relevant to this project:

• PPS1 Delivering Sustainable Development (2005)

• PPG4 Industrial, Commercial Development and Small Firms (1992)

• PPS7 Sustainable Development in Rural Areas (2004)

• PPS9 Biodiversity and Geological Conservation (2006)

• PPG13 Transport (2001)

• PPG15 Planning and the Historic Environment (1994)

• PPG16 Archaeology and Planning (1990)

• PPG21 Tourism (1992)

• PPS23 Planning and Pollution Control (2004)

• PPG24 Planning and Noise (1994)

• PPG25 Development and Flood Risk (2001) 5.3.13 Although local policy for Shepway, Kent and the South East will ultimately determine and influence the proposed development at LAA, it is beneficial to determine how far the proposals support or detract from relevant national policies. Each relevant policy will now be discussed.

PPS1 Delivering Sustainable Development (2005)

5.3.14 Published in 2005 this PPS replaces PPG1 (General Policies and Principles published in 1997). The policies set out in PPS1 need to be considered in plan- making at all levels and may also apply to individual planning applications. Overall the PPS promotes:

• Social cohesion and inclusion;

• Protection and enhancement of the environment;

• Prudent use of natural resources;

• Sustainable economic development; and

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• Integration of sustainable development in development plans. 5.3.15 Sustainability objectives have been considered in the runway design and this is discussed in Chapter 4 Project Description.

PPG 4 Industrial, Commercial Development and Small Firms (1992)

5.3.16 This policy refers to one of the Government’s key aims of encouraging “informed continued economic development in a way which is compatible with environmental objectives”. This PPG takes a positive approach to the location of new business developments and assisting small firms through the planning system. The main message is that economic growth and a high-quality environment have to be pursued together.

5.3.17 The locational demands of industry should be a key consideration in drawing up plans. Development plans should weigh the importance of industrial and commercial development with that of maintaining and improving environmental quality. The advice covers mixed uses, conservation and heritage, re-use of urban land and other matters.

5.3.18 The proposed development at LAA will attract inward investment, as discussed in Chapter 17 (Socio-Economic) of this ES.

5.3.19 The importance of reducing greenhouse gas emissions is also outlined, with suggestions of reducing the need to travel and encouraging development in areas that can be served by more energy efficient modes of transport.

5.3.20 The proposed development at LAA, as with any airport development, are not compatible with the objective of reducing greenhouse gas emissions, and this is discussed further in Chapter 15 (Air Quality).

PPS7 Sustainable Development in Rural Areas (2004)

5.3.21 This has replaced PPG7 (The Countryside - Environmental Quality and Economic and Social Development). It sets out the Government's planning policies for rural areas, which Local Authorities should have regard to when preparing local development documents, and when taking planning decisions. The Government's objectives relevant to this proposal are:

• To raise the quality of life and the environment in rural areas;

• To promote more sustainable patterns of development; and

• Promoting the development of the English regions by improving their economic performance so that all are able to reach their full potential. 5.3.22 The proposed development at LAA supports the economic objectives of PPS7, the results of which are outlined in Chapter 17 (Socio-Economic) of this ES.

5.3.23 PPS7 recommends application of the following key principles are recommended to ensure sustainable development is at the core of land use planning:

• “Decisions should be based on sustainable development principles;

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• Accessibility should be a key consideration in all development decisions;

• New building development in the open countryside away from existing settlements, or outside areas allocated for development in development plans, should be strictly controlled;

• Priority should be given to the re-use of previously-developed ('brownfield') sites in preference to the development of greenfield sites; and

• All development in rural areas should be well designed and inclusive, in keeping and scale with its location, and sensitive to the character of the countryside and local distinctiveness”. 5.3.24 The proposed development will result in greenfield land being lost. However the proposals are compatible with the accessibility and location principles as outlined above.

PPS9 Biodiversity and Geological Conservation (2006)

5.3.25 PPS9 sets out planning policies on protection of biodiversity and geological conservation through the planning system. These policies complement, but do not replace or override, other national planning policies and should be read in conjunction with other relevant statements of national planning policy. This has replaced PPG9 on Nature Conservation. The Governments planning objectives are as follows:

• “to promote sustainable development by ensuring that biological and geological diversity are conserved and enhanced as an integral part of social, environmental and economic development, so that policies and decisions about the development and use of land integrate biodiversity and geological diversity with other considerations;

• to conserve, enhance and restore the diversity of England’s wildlife and geology by sustaining, and where possible improving, the quality and extent of natural habitat and geological and geomorphological sites; the natural physical processes on which they depend; and the populations of naturally occurring species which they support;

• to contribute to rural renewal and urban renaissance by:

• enhancing biodiversity in green spaces and among developments so that they are used by wildlife and valued by people, recognising that healthy functional ecosystems can contribute to a better quality of life and to people’s sense of well-being; and

• ensuring that developments take account of the role and value of biodiversity in supporting economic diversification and contributing to a high quality environment.” 5.3.26 This ES takes all the objectives outlined above into consideration and proposes mitigation measures where the proposed development detracts from the objectives outlined above. These issues are discussed in detail in Chapter 10 (Ecology and Nature Conservation).

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PPG13 Transport (2001)

5.3.27 There is specific guidance with respect to airports in PPG13, which is reproduced in its entirety below:

With regards to airports, local planning authorities will need to consider:

(i) The growth of regional airports: many are at a point where the introduction of new services is becoming increasingly attractive and where higher utilisation, and thus economies of scale, may be achieved. The New Deal for Transport encourages regional airport growth to cater for local demand where it is consistent with sustainable development; and

(ii) The role of small airports and airfields in serving business, recreational, training and emergency services needs. As demand for commercial air transport grows, this General Aviation (GA) may find access to larger airports increasingly restricted. GA operators will therefore have to look to smaller airfields to provide facilities. In formulating their plan policies and proposals, and in determining planning applications, local authorities should take account of the economic, environmental, and social impacts of GA on local and regional economies’.

5.3.28 The proposed development at LAA is directly compatible with the guidance outlined above by proposing expansion to meet demand and by retaining its role as a GA operator through the Lydd Aero Club (pilot training school and flying club).

PPG15 Planning and the Historic Environment (1994)

5.3.29 This PPG lays out Government policies for the identification and protection of historic buildings, conservation areas and other elements of the historic environment. It explains the role of the planning system in their protection.

5.3.30 The frequently close link between controls over ‘listed’ buildings and conservation areas and development control decisions means that development and conservation generally need to be considered together. Part One of the PPG deals with those aspects of conservation policy which interact most directly with the planning system. These include matters of economic prosperity, visual impact, building alterations, traffic and affect on the character of conservation areas.

5.3.31 Part Two addresses the identification and recording of the historic environment including listing procedures, upkeep and repairs and church buildings

5.3.32 The proposed developments comply with PPG15, as outlined in Chapter 13 Cultural Heritage and Historic Environment.

PPG16 Archaeology and Planning (1990)

5.3.33 This PPG sets out the Government’s policy on archaeological remains on land and how they should be preserved or recorded both in an urban setting and in the countryside.

5.3.34 It gives advice on the handling of archaeological remains and discoveries through the development plan and development control systems, including the weight to be given to them in planning decisions and planning conditions.

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5.3.35 An explanation is given of the importance of archaeology and of procedures in the event of archaeological remains being discovered during development

5.3.36 The proposed developments comply with PPG16, as outlined in Chapter 13 Cultural Heritage and Historic Environment.

PPG21 Tourism (1992)

5.3.37 This PPG outlines the economic significance of tourism and its economic impact. It explains how to deal with the topic in development plans and development control.

5.3.38 It discusses the impact of tourism, the nature of tourist activity and likely future trends, while showing what the planning system can do to cope with it. The use of planning powers to both regulate and facilitate tourism development is also dealt with, as is the role of regional tourist boards.

5.3.39 Locational factors in tourism development are discussed with emphasis on designated areas, historic towns and cities, seaside resorts and the countryside. Environmental factors, design problems and outdoor advertisements are also considered.

5.3.40 Chapter 17 Socio Economic of this ES discusses the impacts and influences that the proposed development will have on tourism.

PPS 23- Planning and Pollution Control (2004)

5.3.41 The policies in this statement and the advice in the accompanying Annexes (Annex 1: Pollution Control, Air and Water Quality and Annex 2: Development on Land Affected by Contamination) should be taken into account by Regional Planning Bodies (RPBs) and Local Planning Authorities (LPAs) in preparing Regional Spatial Strategies (RSSs) and Local Development Documents (LDDs) - referred to in this Statement as "development plans".

5.3.42 They are also material to decisions on individual planning applications. Where these policies are not reflected adequately in local development documents, or taken into account in relevant development control decisions, the Secretary of State may use his powers of direction to seek changes to the documents or may intervene in the consideration of planning applications.

5.3.43 This PPS and its associated annexes carry equal weight. A third Annex on Planning and Light Pollution will be prepared for public consultation in due course.

5.3.44 Advice is given on the interaction between planning development control and pollution control legislation, to avoid duplication and conflict of interest. It is intended to complement the new pollution control framework under the Pollution Prevention and Control Act 1999 and the PPC Regulations 2000 (as amended), but there is still some relevant advice to this proposal. This is as follows:

• any consideration of the quality of land, air or water and potential impacts arising from development, possibly leading to impacts on health, is capable of being a material planning consideration, in so far as it arises or may arise from or may affect any land use;

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• the planning system plays a key role in determining the location of development which may give rise to pollution, either directly or indirectly, and in ensuring that other uses and developments are not, as far as possible, affected by major existing or potential sources of pollution. 5.3.45 Planning authorities should have sufficient information on which to base their development control decisions. Where pollution issues are likely to arise, developers should discuss their proposals with both the planning and pollution control authorities, and with other authorities with a legitimate interest. The proposals have been discussed at a number of meetings with the EA, IDB and other consultees and agreements in principle reached regarding discharge consents, as detailed further in Section 7.

5.3.46 The CO2 contribution from any individual development is often only a small fraction of the total emissions for an area. However, promoters of major developments can be asked by the Local Planning Authorities (LPAs) for an energy statement and data on the expected CO2 emissions generated by the new development. LPAs should also consider how the climate may change over the lifetime of developments.

5.3.47 By their nature, airport developments need mechanisms and controls to curb and reduce any negative pollution impacts. The effects of the proposed development on land, air and water are discussed in detail in the relevant chapters of this ES.

PPG 24- Planning and Noise (1994)

5.3.48 This PPG guides Local Authorities in England on the use of their planning powers to minimise the adverse impact of noise. It outlines the considerations to be taken into account in determining planning applications both for noise-sensitive developments and for those activities which generate noise.

5.3.49 It explains the concept of noise exposure categories for residential development and recommends appropriate levels for exposure to different sources of noise.

5.3.50 It also advises on the use of conditions to minimise the impact of noise. Six annexes contain noise exposure categories for dwellings, explain noise levels, give detailed guidance on the assessment of noise from different sources, gives examples of planning conditions, specify noise limits, and advise on insulation of buildings against external noise.

5.3.51 The proposed development has been developed with this principle in mind. Further information on noise is provided in Chapter 16 Noise and Vibration.

PPG 25- Development and Flood Risk (2001)

5.3.52 This PPG explains how flood risk should be considered at all stages of the planning and development process in order to reduce future damage to property, summarising the responsibilities of various parties involved. It states that the planning system should ensure that new development is safe and not exposed unnecessarily to flooding. It has these principles:

• The susceptibility of land to flooding is a material planning consideration;

• Planning authorities should apply the precautionary principle to flood risk; and

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• Planning policies and decisions should recognise that the consideration of flood risk and its management needs to be applied on a whole-catchment basis and not be restricted to floodplains. 5.3.53 Flood risk should be considered on a catchment-wide basis and where necessary across administrative boundaries, assuming the use of floodplains for their natural purpose rather than for inappropriate development.

5.3.54 The PPG says that susceptibility of land to flooding is a material planning consideration that the Environment Agency has the lead role in providing advice on flood issues, and that developers should fund flood defences, where they are required because of the development.

5.3.55 It introduces a risk-based search sequence giving priority to sites at lower risk and establishes a minimum standard of defence for new development that takes account of the likely impact of climate change.

5.3.56 It aims to increase communication between land-use planning, land management and the Building Regulations.

5.3.57 This PPG will be superseded by PPS 25 (Development and Flood Risk) when final approval has been granted. The proposals stated within this ES have been considered in light of this emerging PPS.

5.3.58 In summary, the PPS advises that a strategic approach should be adopted in keeping with the Government’s aims to ensure that new development is sustainable. The thrust of the guidance in PPS 25 enshrines the concepts introduced in PPG 25. However, notably it introduces:

• The concept of classification of the vulnerability of development to flood risk;

• The need to conform to the requirements of the ‘Exception Test’ in circumstances where it is deemed necessary to locate new development in ‘high risk’ zones; and

• It identifies the need to apply the Strategic Flood Risk Assessment to decisions taken at all levels of planning, i.e. the need for assessment at the RSS.

5.3.59 Additionally, PPS 25 introduces the concept of Flood Risk Reduction, particularly in circumstances where development has been sanctioned on the basis of the ‘Exception Test’. The Flood zones are also re-classified as ‘Low Probability’, ‘Medium Probability’ and ‘High Probability’.

5.3.60 Details of the flood risk assessment are discussed in Chapter 7 (Water Resources and Flood Risk) which considers the proposed development in relation to PPG 25.

5.4 Regional Guidance

5.4.1 At present, strategic planning takes the form of Regional Planning Guidance (RPG), issued by the Secretary of State. This provides the framework for the preparation, by Local Authorities, of statutory development plans. RPG itself does not have statutory force; however, the Secretary of State has formal powers to intervene in the development plans process if plans have insufficient regard to RPG.

5.4.2 RPG generally covers those issues which need to be considered on a wider geographical basis than that of individual development plans. It sets out a broad

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development framework for the region over a period of 20 years or more and identifies the scale and distribution of provision for new housing and priorities for the environment, transport, infrastructure, economic development, agriculture, minerals and waste treatment and disposal.

5.4.3 RPG9 covers the areas of the Government Offices for the South East, London and part of Eastern Region.

Regional Planning Guidance for the South East (RPG 9), 2001 (Government Office for the South East)

5.4.4 RPG9 will eventually be replaced by the South East Plan, which has not yet been formally adopted and is still subject to change, and as a result the policies found in RPG9 are discussed below as they form the current relevant policy for South East England. However, details regarding the South East Plan are detailed further in paragraph 5.4.16.

5.4.5 The vision of RPG9 is of “encouraging economic success throughout the Region, ensuring a higher quality of environment with management of natural resources, opportunity and equity for the Region’s population, and a more sustainable pattern of development. The focus is on enabling urban renaissance, promoting regeneration and renewal, concentrating development in urban areas, promoting a prosperous and multi-purpose countryside and promoting wider choice in travel options, thereby reducing the reliance on the private car”.

Key Development Principles

5.4.6 The main relevant principles (which reflect national policy), that should govern the continuing development of the Region include:

• Greenfield development (namely, on previously undeveloped land) should normally take place only after other alternatives have been considered, and should have regard to the full social, environmental and transport costs of location; 5.4.7 This ES deals with the social, environmental and transport issues surrounding the Greenfield aspects of the proposed development.

• Economic opportunities should be increased by raising skills levels and reducing the disparities between different parts of the Region. In particular, by positive investment strategies for the Thames Gateway and Priority Areas for Economic Regeneration to improve the performance of poorer parts of the Region and by managing the localised impacts of development in economically buoyant areas; 5.4.8 Lydd is classified as a Priority Area, and the proposed development at LAA will create new economic opportunities for the region.

• There should be continued protection and enhancement of the Region’s biodiversity, internationally and nationally important nature conservation areas, and enhancement of its landscape and built and historic heritage; 5.4.9 Chapter 10 Ecology and Nature Conservation, Chapter 12 Landscape and Visual Amenity and Chapter 13 Cultural Heritage and Historic Environment of this ES

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discuss mitigation measures with the purpose of mitigating any adverse impacts upon important areas.

Rural Areas

5.4.10 Despite its environmental quality, rural areas in the South East are subject to strong development pressures. Rural areas also contain significant areas of deprivation. There is a need to create new jobs and enterprise within many rural areas, particularly those areas identified as Rural Priority Areas (RPAs). At the same time, there is a greater awareness of the need to protect and improve the rural environment. Policy Q7 below refers specifically to RPAs.

5.4.11 Policy Q7. A multi-purpose countryside should be secured and where necessary investment and renewal in rural areas should be encouraged. The quality and character of the rural environment should be maintained and enhanced, while securing necessary change to meet the economic and social needs of local people and visitors. Special consideration should be given to the economic and social needs of the Rural Priority Areas.

• Lydd is an Enterprise Grant Zone and a Rural Priority Area, which means it has a particular need to create new jobs and enterprise. The development of the airport will create a significant number of new employment opportunities, as outlined in Chapter 17 Socio-Economic, and is considered to be supportive of this Policy in this respect.

Environment

5.4.12 According to this guidance, ‘a high quality environment is essential to the future prosperity of the South East. The effective protection of the environment and prudent use of natural resources are fundamental aspects of the vision for this Region which is highly urbanised and subject to development pressures. This chapter encourages regional partners in planning positively for the care and management of the Region’s environment’. Policies E1, E2, and E7 are relevant to the proposed development at LAA and implications of these are discussed in the relevant Chapters of this ES.

5.4.13 Policy E1. Priority should be given to protecting areas designated at international or national level either for their intrinsic nature conservation value, their landscape quality or their cultural importance.

• The implications of the proposed development on designated areas are discussed in Chapter 10 Ecology and Nature Conservation, Chapter 12 Landscape and Visual Amenity and Chapter 13 Cultural Heritage and Historic Environment. 5.4.14 Policy E2. The Region’s biodiversity should be maintained and enhanced with positive action to achieve the targets set in national and local biodiversity action plans through planning decisions and other measures.

• Measures to maintain and enhance local biodiversity are discussed in Chapter 10 Ecology and Nature Conservation. It is pointed out in RPG9 that the presence of a protected species is material in considering development proposals.

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5.4.15 Policy E7. Local Authorities should work with the Environment Agency and others to play a positive part in pollution control and encourage measures to improve air quality.

• The Environment Agency has been consulted with respect to discharge licences. Consideration of pollution effects are discussed in Chapter 15 Air Quality of this ES.

Regional Spatial Strategy (RSS): The Draft South-East Plan, March 2006

5.4.16 The South-East Plan will, upon adoption replace RPG9 for the south-east and it sets out a vision for the future of the region through to 2026. It is not considered a minor amendment to RPG9 but is a replacement to the guidance and the strategy is based on a wholly updated evidence base. It was submitted to the Government on the 31 March 2006 and will be examined in public between 28 November 2006 and 30 March 2007 with adoption scheduled for February 2008. The status of the plan is far enough advanced to be considered a material consideration in planning policy and development control.

Key Development principles

5.4.17 One of the key cross-cutting spatial strategies for the region is the reduction of intra- regional disparities. Policy CC9 ‘Addressing Intra-Regional Disparities’ states that:

“Local Authorities and other national, regional and local partners in the public, private and voluntary sector should align policies and programmes to reduce the overall extent of, and as a result the significant spatial disparities in, socio-economic depravation across the region. Specifically they should focus funding and initiatives to address the extensive regeneration needs of the following sub-regions – East Kent & Ashford; Kent Thames Gateway; South Hampshire; Sussex Coast; and the Isle of Wight Special Policy Area.”

5.4.18 Lydd Airport falls within the East Kent & Ashford sub-region. The significant investment and employment opportunities that the proposed development will bring can clearly play an important role in aiding the economic regeneration of the area and reducing disparities with the rest of the wider south-east.

5.4.19 The Plan also seeks to ensure improvements to the character of the environment and the quality of life. Policy CC12 ‘Character of the Environment and Quality of Life’ states that:

“Actions and decisions associated with development and the use of land should actively encourage the conservation, and where appropriate the enhancement of the character, distinctiveness, and sense of place of settlements and landscapes throughout the region. Opportunities for creating a high quality environment should be sought, based on a shared vision that places emphasis on good design, innovation, sustainability and achieving a high quality of life.”

5.4.20 The Proposed Development will be of a high quality in terms of its design and appreciation for the environment and any adverse impacts will be mitigated by measures set out in the chapters of this statement. The Proposed Development will also aid the enhancement of local living standards through the creation of sustainable economic growth.

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Countryside and landscape management

5.4.21 Whilst retention of the landscape quality is important the need to support local economies is also paramount. As the airport does not lie within a specially designated landscape, policy C3 ‘Landscape and Countryside Management’ applies. It state states that positive and high quality management of the region’s open countryside should be encouraged in order to enhance its distinctiveness, enable habitat and landscape conservation and “support local economies and social well-being of communities through small scale development proposals to meet local needs”.

5.4.22 There is clear support for development that supports local economies but it must also be remembered that the potential economic significance of the airport development extends well beyond the immediate local area.

Sustainable natural resource management

5.4.23 The plan seeks to ensure that ‘the quality of the environment is maintained and enhanced for future generations while enabling continued sustainable growth and development’. Crucial to this is improving biodiversity and enhancing habitats. Policy NRM4 ‘Conservation and Improvement of Bio-diversity’ states that:

“local authorities and other bodies shall avoid a net loss of biodiversity, and actively pursue a net gain across the region by i) providing the highest level of protection for nationally and internationally designated sites....iii) ensuring that unavoidable damage to wildlife interest is minimised through mitigation, that any damage is compensated for, and that such measures are monitored, iv) ensuring appropriate access to areas of wildlife importance, identifying areas of opportunity for biodiversity improvement and setting targets reflecting those in NRM2”

5.4.24 Lydd Airport lies within a nationally and internationally important site of special scientific interest and there are targets for the improvement and extension of various types of habitat. Measures to maintain and enhance local biodiversity are discussed in chapter 10.

5.4.25 Air quality is seen as being important, primarily for the protection of human health but also in restricting adverse impacts on wildlife and vegetation. Policy NRM7 ‘Air Quality’ states that local authorities should seek a reduction of the number of days with medium and high air pollution by 2026 by reducing the impact of transport, supporting the use of cleaner fuels, mitigating the impact of development, reducing the exposure to poor air quality through design and encouraging the use of best practice during construction to reduce the levels of dust and other pollutants.

5.4.26 The Environment Agency has been consulted with respect to discharge licenses and air quality has been dealt with in chapter 15 of this statement.

5.4.27 Noise can reduce quality of life and policy NRM8 ‘Noise’ seeks to secure measures to address and reduce noise pollution at regional and local levels. This will be done through requiring sound attenuation measures in major transport schemes.

5.4.28 The development has been designed with sound attenuation in mind and further information is given in chapter 16 of this statement.

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Replacement Chapter 9- Regional Transport Strategy (RTS), 2004 (Government Office for the South East)

5.4.29 The revised RTS should play a full part in delivering the overall strategy of RPG9, including its spatial and environmental policies and key development principles. It aims to fully utilise existing capacity before justifying investment in additional capacity.

5.4.30 The vision of the RTS is ‘a high quality transport system to act as a catalyst for continued economic growth and provide for an improved quality of life for all in a sustainable and socially inclusive manner: a regional transport system which progressively reaches the standards of the best in North West Europe’, with the overarching vision for the need to bring about an urban renaissance.

5.4.31 Policy T6 relates directly to airports, and is reproduced below:

• Policy T6. Airports Relevant regional strategies, development plans and Local Transport Plans should include policies and proposals that: • support the development of Gatwick and Heathrow Airports within levels of growth agreed prior to the publication of the Aviation White Paper, though these will need to be reassessed in the light of the framework established by the White Paper; and

• take account of airport operator master plans produced in accordance with the Aviation White Paper. Airport Surface Access Strategies should set out ways of achieving a modal shift in favour of public transport. 5.4.32 The RTS lists the main conclusions relevant to the south east of the “Future of Air Transport” White Paper. Therefore, the view of the RTS is that ‘there is scope for other existing south east airports, to help meet local demand, and their further development is supported in principle, subject to relevant environmental considerations’. It is highlighted that airports have become major transport interchanges and traffic generators, and ‘magnets’ for development. Accordingly, ‘they should be treated as regional hubs in their own right in addition to their role as gateways… As such it is also vital to ensure multimodal access to airports; the development of connecting coach services will be of major importance, particularly in the period before new rail routes such as Crossrail can be implemented’.

5.4.33 It is noted that the Section D4 ‘Communications and Transport’, which is part of the South East Plan (currently in the consultation phase), does not support development at LAA. Representations have been made by Kent County Council to the Government to include LAA in this strategy. The Section D4 ‘Communications and Transport’ outlines the potential of Southampton Airport and Kent International Airport (Manston) and states that other airports in the region are not considered to have strategic potential.

5.4.34 The Proposed Development at LAA supports the RTS in that it provides facilities to meet local aviation demand, and supports Kent’s role as a gateway to Europe.

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5.5

5.5 Local Policies and Guidance

Kent and Medway Structure Adopted Plan (July 2006)

5.5.1 The Kent and Medway Structure Adopted Plan was recently published in July 2006.

Key Themes

5.5.2 The role of the Structure Plan is to provide the strategic planning framework which will guide decisions on development, transport and environmental matters in Kent and Medway over the next 20 years. This Plan covers the period 2001-2021. It will shape the scale, location and form of private and public investment in Kent over that period and in doing so must interpret national and regional policies as they apply to Kent and Medway. Some key themes of this Plan relevant to the proposed development at LAA are listed below.

Nurturing Kent and Medway's Environment and Resources:

• Protecting the countryside, minimising greenfield development and making the most of opportunities for re-using previously developed land, especially within existing towns and other substantial communities;

• Anticipating and reducing the impact of future climate change including stronger protection and management of areas of potential flood risk, reducing demand for energy and moving towards renewable energy sources;

• Protecting and enhancing Kent's land, air and water environments;

• Ensuring that development does not create unacceptable levels of pollution and that development that would be sensitive to pollution is protected from it;

• Conserving and enhancing Kent's natural habitats and biodiversity;

• Promoting sensitive and comprehensive approaches to the assessment and protection of the countryside, that reflect its character and biodiversity as well as its natural beauty;

• Conserving and enhancing Kent's historic environment; and

• Using and managing water and other natural resources wisely, including the safeguarding of viable mineral reserves from sterilisation. 5.5.3 The proposed development at LAA, like any airport expansion, or indeed any development, does have implications on the environment. The role of this ES is to address these issues and offer mitigation measures to minimise any significant adverse impacts.

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Fostering Prosperity and Well Being:

• Increasing economic opportunity and reducing economic disparities within Kent, by working towards regeneration and improved economic performance in North Kent, the coastal towns of East Kent and the former East Kent coalfield;

• Pursuing targeted economic development, including support for high value added activities and skills development, business clusters and knowledge based industries to boost the competitiveness of the Kent economy and existing businesses;

• Securing employment led growth and development, especially within the areas in North and East Kent which require regeneration;

• Helping existing businesses to grow and provide new jobs;

• Providing for sustainable growth in the economically successful parts of Kent, whilst addressing the pockets of deprivation which occur within them;

• Sustaining and improving the economic health and vitality of Kent's rural communities and helping the rural economy to diversify;

• Making the most of the role of Thames Gateway as a national and regional priority for economic growth, regeneration and infrastructure investment and recognising in this respect the pivotal role of the main urban areas of North Kent and Medway; and

• Promoting Ashford as a regional growth point whilst ensuring that the economy of East Kent in particular also benefits. 5.5.4 The proposed development at LAA offers positive economic opportunities to Shepway, Kent and the South East, through job creation and attracting business to the local area, which will encourage regeneration. These points are discussed in more detail in Chapter 17 (Socio-Economic).

Enhancing choice, opportunity and accessibility:

• Ensuring that decisions on development and transport make it easy for people to reach local services and jobs and provide a choice of transport for people and goods. 5.5.5 The proposed development at LAA will improve access and transport within Shepway District, and in addition will feed in with the local public transport network Ashford.

Key Policies

Chapter 2 The Spatial Strategy for Kent and Medway

5.5.6 Both Lydd and New Romney are identified as Rural Service Centres. The spatial strategy involves concentrating necessary rural development at such centres. These centres have been identified on the basis of not only their size but also the range of day to day services and facilities that they support. They have an important role to

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play because they provide community facilities as well as jobs and hence reduce the need to travel to urban areas. The following policies are relevant to the proposed developments at LAA:

• Policy SS1: Spatial Priorities for Development and Investment in Kent

• Strategic policy in Kent will be focused upon the promotion of development and investment in North Kent, Ashford and East Kent (including Shepway)

• Policy SS6: Development at rural service centres and other rural settlements

• Other than at Strategic Development Locations identified by this Plan, development at, but outside the built confines of rural settlements, should be small scale and identified in a Local Development Document or be supported by a special local justification. This may include the expansion of an established business. 5.5.7 The Proposed Development at LAA will bring increased development and investment to Shepway, and is supported in the Kent and Medway Structure Plan and Shepway Local Plan, as discussed later in this Chapter.

• Policy SS7: Development in the countryside

• Non residential development in rural Kent other than at rural settlements should:

i be demonstrated to be necessary to agriculture, forestry, the winning of minerals or other land uses for which a rural location is essential; or

ii be the re-use, adaptation or redevelopment of an existing rural building or institution, where the change is acceptable on environmental, traffic and other planning grounds; or

iii provide a public facility for which a rural location is justified; or

IV allow for the business diversification of an existing farm in accordance with Policy FP7.

5.5.8 As LAA is currently operating as an airport, the expansion in any other location would be neither feasible nor suitable.

Chapter 3 Kent and Medway Area Based Policies

5.5.9 Shepway suffers the highest levels of deprivation of the districts in the channel corridor. Some rural wards suffer higher than average levels of deprivation, made worse, in the case of Romney Marsh, by their remoteness. It is stated that measures to stimulate the rural economy and strengthen the role of the service centres at New Romney and Lydd should be pursued.

• Policy CC3: Shepway

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• Proposals to strengthen the rural economy of Romney Marsh should be concentrated at New Romney and/or Lydd. Elsewhere, protection of the environment and countryside will be foremost. Proposals to retain and strengthen the current uses at Lydd Airport should be pursued.

5.5.10 The proposed improvement to the facilities at LAA is directly supportive of this policy and should strengthen the local economy. This is discussed further in Chapter 17 Socio-Economic.

Chapter 4 Protecting Our Natural Environment

5.5.11 Policies E1 and E3 seek protection of Kent’s countryside and landscape character with E5 seeking protection for Special Landscape Areas (SLA).

• Policy E1: Protecting Kent’s Countryside

• Kent's countryside will be protected for its own sake. Development in the countryside should seek to maintain or enhance it. Development which will adversely affect the countryside will not be permitted unless there is an overriding need for it which outweighs the requirement to protect the countryside.

• Policy E3: Protection and Enhancement of Landscape Character

• Kent's landscape and wildlife habitats will be conserved and enhanced. Development will not be permitted if it would lead to the loss of features or habitats which are of landscape, historic, wildlife or geological importance, or are of an unspoilt quality free from urban intrusion unless there is a need for development which outweighs these countryside considerations.

• Where a need for development in the countryside is justified important features and characteristics will be retained. Proposals will be required to reflect the need for conservation, reinforcement, restoration or creation of countryside character and provide for the appropriate management of important features and the wider landscape. 5.5.12 The proposed development at LAA will comply with Policies E1 and E3 through inclusion of approaches to address these issues throughout the planning design of the project

5.5.13 Dungeness SLA is identified within Policy The primary objective in Special Landscape Areas is the long term protection and enhancement of the quality of the landscape whilst having regard to their economic and social well being. Development that may negatively impact upon these features will be strictly controlled as the Policy E5 below indicates. Dungeness is not affected directly by the proposed development at LAA as it falls outside of the boundaries of LAA, however it is situated close by to the airport and the potential impact upon the SLA is assessed in Chapter 12 Landscape and Visual Amenity.

• Policy E5: Special Landscape Areas

• Special Landscape Areas are defined as follows and indicated on the Key Diagram. Detailed boundaries of the SLAs will be reviewed and defined in local plans/development documents.

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• North Downs

• Greensand Ridge

• High Weald

• Eastern Low Weald

• Western Low Weald

• Old Romney Shoreline

• North Kent Marshes

• Sandwich Bay/Pegwell Bay

• Dungeness

• Blean Woods

• The primary objective in Special Landscape Areas will be the long term protection and enhancement of the quality of the landscape whilst having regard to their economic and social well being.

5.5.14 Policies E6 to E8 seek protection for wildlife assets whether important on a European Scale or locally.

• Policy E6: International and National Wildlife Designations

• Development will not be permitted where it would directly, indirectly or cumulatively, materially harm the scientific or nature conservation interests of any of the following categories of sites:

• a European site;

• a proposed European site;

• a Ramsar site;

• a Site of Special Scientific Interest; and

• a National Nature Reserve.

• Policy E7: County and Local Wildlife Designations

• Development which would materially harm the scientific or nature conservation interests, either directly, indirectly or cumulatively, of Local Nature Reserves, County Wildlife Sites identified in Local Development Documents and Regionally Important Geological/ Geomorphological Sites, will not be permitted unless there is a need which outweighs the local nature conservation or geological/geomorphological interest and adverse impacts can be adequately compensated.

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• Policy E8: Protection and Enhancement of Biodiversity

• Important wildlife habitats and species will be protected, maintained and enhanced, especially through long term management and habitat creation schemes, particularly where they have been identified as national and county priorities in the UK and Kent Biodiversity Action Plan(s), or where they are protected under wildlife legislation. This will be secured by: (i) Ensuring that site evaluation is undertaken to establish the nature conservation value of proposed development sites;

(ii) Identifying, safeguarding and managing existing and potential land for nature conservation as part of development proposals, particularly where a connected series of sites can be achieved; and

(iii) Local planning authorities identifying locations and proposals for habitat and species management, restoration and creation.

• Development likely to have an adverse effect, directly, indirectly or cumulatively, on important habitats or species will not be permitted unless:

• there is an overriding need for the development that outweighs the nature conservation interest; and

• loss of an important nature conservation resource can be adequately compensated and lesser impacts mitigated. 5.5.15 The proposed development at LAA will have a potential impact on a SSSI, and this is discussed in Chapter 10 Ecology and Nature Conservation.

5.5.16 The proposed development will have a potential impact on the geomorphology within the site. This is discussed in Chapter 6 Ground Conditions.

Chapter 5 Promoting Quality of Life in Town and Country 5.5.17 Policy QL1 seeks to promote high quality design that protects the character of the locality and has regard to scale, layout pattern and character of local areas. All development should be well-designed and of high quality.

5.5.18 The proposed development at LAA will not affect this policy.

Chapter 6 Fostering Prosperity

5.5.19 It is stated that ‘the main potential for future economic development in Kent lies in the regeneration of urban areas and strategic sites close to the centres of population. However the strategy recognises that not all investment should be directed to the towns and that rural communities also need new economic investment.

• Policy FP6: Development of employment uses in rural areas

• No provision for business development will be made elsewhere in rural Kent except where it:

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• involves the re-use, adaptation or redevelopment of an existing building, as covered by Policy SS7( ii ) ; or

• is required for the expansion of an established business and/or for the processing, storage, distribution or promotion and research concerning produce from Kent agriculture, horticulture or forestry; and (i) good access can be provided to the primary road network and bus or rail services; and

(ii) there is no overriding environmental objection.

5.5.20 The proposed development at LAA is part of the expansion of the airport as a business and will improve access to Kent as a whole. The potential impacts associated with the proposed development are dealt with in this ES.

Chapter 8 Promoting Quality, Choice and Accessibility in the Transport Network

5.5.21 With regards to aviation, the Plan recognises that while there are social and economic benefits associated with expanding air services and while regional airports can promote regeneration, environmental and community interests must be safeguarded. It has the following views on LAA:

5.5.22 ‘The airport at Lydd plays an important part in serving local business needs and providing opportunities for recreational flying. Enhancement of the airport’s existing facilities would improve the airport’s ability to cater for general aviation and passenger traffic and capture scheduled and charter business. The operator’s own masterplanning study for the airport envisages growth of capacity to approximately 2,000,000 passengers per annum by 2014. The immediate proximity of international environmental designations to Lydd Airport pose a specific test for the nature and degree of any expansion including the relationship between the need for/acceptability of a runway extension at Lydd and the attainment of a significantly higher passenger capacity and throughput. Development proposals will be assessed against the common set of assessment criteria to be applied to both Manston and Lydd, including harm to internationally or nationally designated environmental areas’.

5.5.23 Chapter 10 (Ecology and Nature Conservation) of this ES assesses the impacts that the proposed development will have on the surrounding internationally designated sites and local communities.

5.5.24 The Government’s wider objectives of sustainable communities need to be reflected in airport growth, as the Government recognises the importance of airports for the development of regional and local economies. There is a need for local regeneration in the area surrounding LAA; Lydd town is referred to as a Rural Priority Area (RPA) and an Enterprise Zone within RPG9, and the need to create new jobs and enterprise. Kent County Council supports the proposed expansion at Lydd – See Appendix 5.1 for further details.

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Policy TP25 of the Kent and Medway Structure Plan is dedicated to LAA:

• Policy TP25: Lydd Airport

• The expansion of aviation at Lydd Airport will be supported. Proposals related to the development of the airport will be assessed for acceptability against the following criteria:

• Development being directly related to the operation of the airport unless otherwise forming part of a proposal in a Local Development Document; and

• no material harm on internationally or nationally designated environmental areas; and

• no significant detrimental impact on locally designated environmental areas; and

• no significant adverse impact on the amenity of local communities which cannot be satisfactorily mitigated; and

• appropriate measures being secured to mitigate and where appropriate compensate for, the impact of development including noise control, air pollution, light pollution, water pollution, sewerage disposal, landscape, species and habitat management; and

• the requirements for surface access being adequately accommodated within the capacity of the existing or committed local transport network; and

• measures being identified and secured to improve access by public transport modes. Chapter 9 Climate Change and Managing Our Natural Resources

5.5.25 Climate change and natural resource management is also seen as an important issue within Kent.

• Policy NR4: Pollution Impacts

• The quality of Kent’s environment will be conserved and enhanced. This will include the visual, ecological, geological, historic and water environments, good air quality and levels of tranquillity and light intrusion.

• Development should be planned and designed to avoid, or adequately mitigate, pollution impacts. Proposals likely to have adverse implications for pollution should be the subject of a pollution impact assessment.

• In assessing proposals local authorities will take into account: (i) Impact on prevailing background pollution levels; (ii) The cumulative impacts of proposals on pollution levels; (ii) The ability to mitigate adverse pollution impacts; and

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(iii) The extent and potential extremes of any impacts on air quality, water resources

• Development which would result in, or significantly contribute to, unacceptable levels of pollution, will not be permitted.

5.5.26 The pollution impact of the proposed development is discussed in Chapters 10 Ecology and Nature Conservation, 6 Ground Conditions, 13 Cultural Heritage and Historic Environment and 7 Water Resources and Flood Risk of this ES.

• Policy NR7: Water Quality

• Development will not be permitted where it would give rise to an unacceptable impact on the quality or yield of Kent's watercourses, coastal waters and/or ground water resources.

5.5.27 The potential impact on water quality from the proposed development is assessed in Chapter 7 Water Resources and Flood Risk of this ES.

• Policy NR9: Development and Flood Risk

• Development will be planned to avoid the risk of flooding and will not be permitted: (i) if it would be subject to an unacceptable risk of flooding or where it would increase the risk of flooding elsewhere or require the construction of new defences; (ii) Where it would prejudice the capacity and integrity of flood plains or planned flood protection or coastal defence measures; (iii) Where it will hinder the implementation of future flood protection or coastal defence measures; and (iv) If it would adversely affect the ability of the land to drain. • Where development is necessary in areas at risk of flooding it should be designed and controlled to mitigate the impact of flood risk. Local Development Documents will include policies to: • ensure that a risk based sequential approach, reflecting degrees of flood risk, is adopted in guiding specified categories of development away from flood risk areas; and • secure the provision and maintenance of appropriate drainage systems in new developments to alleviate flood risk.

• ensure that proposals for development are accompanied by flood risk assessments appropriate to the scale and nature of the development and the risk.

5.5.28 The proposed development is located within a flood risk area Category 3. The potential impacts of the proposed development are assessed in Section 7 Water Resources and Flood Risk of this ES.

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Chapter 10 Managing our waste and mineral resources

5.5.29 The Structure Plan Strategy for Waste aims to:

• Promote an integrated approach to waste management;

• Provide for the necessary facilities to manage Kent’s waste in a sustainable way;

• Reduce the overall amount of waste produced;

• Allow some flexibility to cope with variations in the pace of waste reduction;

• Promote the best practical environmental options when disposing of waste; and

• Promote the reuse, recycling and recovery of waste. 5.5.30 Under Policy WM3, “Development proposals will be required to demonstrate they are able to make a contribution to reducing growth in the volume of waste generated in Kent and Medway”. LAA will encourage recycling wherever possible during its operations.

5.5.31 The construction of the Proposed Development at LAA will require some quantities of aggregate materials. The Structure Plan outlines how the use of aggregates “can have a major impact on land use and transportation.” Policy WM7 outlines the Structure Plan’s approach:

5.5.32 Policy WM7: Construction related spoil - In order to minimise the environmental impact of construction projects which require significant quantities of construction aggregates or give rise to significant amounts of surplus spoil, a scheme for the transport and routing of such materials, together with proposals for the disposal or reuse of surplus spoil, will be designed into the project itself.

5.5.33 Construction impacts as a result of the proposed development are assessed in Chapters 6 Ground Conditions and 14 Traffic and Transport of this ES.

Kent County Council’s Local Transport Plan 2001- 2006

5.5.34 The following is expressed with regard to Lydd Airport:

‘Although Lydd Airport currently operates on a more regional scale, it is a valuable contributor to cross-Channel traffic and the County Council supports its current plans to expand its air traffic. Lydd is well situated in terms of the corridors used by aircraft approaching the UK from the continent, but the airport is in a relatively isolated location and the surrounding area, including Dungeness, is of high nature conservation value. In 1999, Lydd carried some 6,000 scheduled passengers and 250 tonnes of freight, but the operators see the future involving feeding continental hub airports and/or holiday charter flights’. • Policy S32: The County Council will: • Generally support the expansion of aviation at Manston and Lydd Airports, subject to the environmental, traffic and employment implications.

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5.5.35 The Proposed Development at LAA supports Policy S32 through this ES, which investigates the environmental, traffic and employment implications.

5.5.36 Policy UKG 5 of the draft Kent Local Transport Plan 2006 – 2001 states that "KCC will support the sustainable development of Kent's airports". Paragraph 9.180 of Chapter 9 of the draft plan states that "Lydd Airport in Shepway provides an important aviation facility and has the potential for improvement and expansion for both passenger and cargo services" with paragraph 9.186 continuing "Lydd Airport plays an important aviation role, serving local business needs and providing the opportunity for recreational flying.

5.5.37 The airport's sole operator, LyddAir, offers scheduled flights to Le Touquet, France. The airfield has considerable potential for development and expansion, subject to environmental and transport implications. Any improvements will be aimed at enhancing the airport's ability to cater for general aviation and passenger traffic, and capture a larger share of the scheduled and charter flight market. The site is located relatively close to Folkestone and Ashford, including Ashford International Station. Despite strong competition in the cross-channel market, Lydd Airport continues to perform relatively well.

Kent Prospects- An Economic Development and Regeneration Framework to Kent 2006

5.5.38 This framework promotes the Kent Prospects current aspirations; however this has been more recently updated and strengthened by the draft Kent Prospects (Consultation draft March 2006).

5.5.39 It is acknowledged that ‘better access increases the influence of London and the city’s commuter pull for higher paid jobs, but also Kent’s airports contribute the generation of economic impacts.

5.5.40 The framework’s view is that:

‘”A priority of the framework is ‘Raise Kent’s global European profile as an International gateway”.

5.5.41 The framework acknowledges that there are significant economic problems in East Kent and the coastal towns, which includes a low skills base, poor external image, limited interest and a limited supply of business premises and facilities for small and medium sized firms and potential investors. These factors result in the area having some of the south east’s highest concentrations of deprivation. However, the area also has what is described by the framework as a “string of pearls” which includes the coast towns, the airports, Canterbury, historical and cultural centre and high quality environment.

5.5.42 As such, the framework has identified this priority “secure resources and attract investment which supports urban renaissance, develops key assets, and improves access to learning business and job opportunities”. The investigation of skills and job opportunities linked to Manston and Lydd airports, as well as Kent’s ports, are identified as a task for addressing the skills shortage in the sub-region.

5.5.43 The increase in Global Trade is identified as putting increasing pressure on the Country’s ports and airports. The framework sets out the unique role that Kent has to

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help address this increasing pressure. The ports, Eurotunnel and two main airports, Lydd and Manston, provide a range of business and job opportunities for local communities, as such the framework has identified this priority:

“Promote investment, business and job opportunities at Kent’s cross channel ports, main airports and international rail stations”

5.5.44 Promoting Kent as a Gateway location in its position between London and mainland Europe.

Ashford’s Future (2005)

5.5.45 A capacity study was undertaken for Ashford to identify what matters to the town’s quality of life. The results of the study are presented in Ashford’s Future1, which was published in 2005 by a partnership that was led by Ashford Borough Council. The document also includes a strategy for the future of Ashford.

5.5.46 The strategy highlights the importance of improving the regional rail network and to improve access to Europe. Improvements to international access is considered very important, this includes access to airports:

“it is considered that the town’s regional accessibility will need to be reinforced through improvements in the regional network … as well as improved links to Lydd airport.”

Shepway District Adopted Structure Plan (2006)

5.5.47 Shepway District Council adopted the Local Plan in July 2006. It contains planning policies which will be significant material considerations in the determination of planning applications. The Local Plan is based on the following principles of relevance to this proposal:

• The district has a diverse and attractive natural environment which deserves protection;

• The Council is committed to applying the principles of sustainable development; and

• The area suffers from problems of slow growth in the local economy, relatively high levels of unemployment and low wage levels. The District faces major structural imbalances in its economy which has lead to it being granted Assisted Area Status, being partly identified as a Rural Development Area and receiving funding from the Single Regeneration Budget. 5.5.48 Relevant general aims of the Local Plan review are as follows:

• To move towards more sustainable patterns of development;

• To concentrate new development in or adjoining the main urban areas wherever possible;

1 Ashford Borough Council (2005) Achieving sustainable growth - Ashford's future

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• To improve peoples employment opportunities and support the local economy;

• To protect the countryside from inappropriate development and to safeguard areas with particular importance for landscape and nature conservation; and

• To enhance peoples1 quality of life through meeting economic and social needs in a way that ensures the protection and enhancement of the environment and of resources for leisure, arts, recreation and sporting activities. 5.5.49 The Proposed Development at LAA supports the general aims of the Shepway Local Plan in that they will provide more employment opportunities. LAA is acknowledged in the first paragraph of the Plan, in the context of it being a gateway to continental Europe (along with the port of Folkestone and the Channel Tunnel). Through careful planning and the adoption of mitigation advice offered in this ES, significant adverse effects upon landscape and nature conservation will be minimised.

Sustainable Development

5.5.50 Under this principle, the Council believes that the ‘Polluter Pays’ rule should be applied to unavoidable environmental pollution or harmful effects on important environmental resources. ‘Meeting people’s needs’ includes tackling problems of deprivation and social exclusion through enabling good access to high quality services and community facilities, adequate employment and housing opportunities and well designed local environments. There is a recognised need to revitalise and broaden the local economy, stimulate employment opportunities and encourage industrial and commercial development. The necessary reduction in the need to travel is also an objective.

5.5.51 Policy SD1 is reproduced in its entirety below, as the entire policy is relevant to the proposed development at LAA.

• Policy SD1 All development proposals should take account of the broad aim of sustainable development - ensuring that development contributes towards ensuring a better quality of life for everyone, now and for generations to come. This involves meeting economic and social objectives and helping people meet their personal aspirations through accommodating the district’s need for commercial and industrial development, new homes and other land uses and improving quality of life for all members of society whilst respecting the following environmental criteria: a) Shape new development patterns in a way which reduces the need to travel, especially by car, and increases the attractiveness of walking, cycling and public transport; b) Preserve and enhance built and cultural heritage including Listed Buildings and their settings, conservation areas, sites and settings of nationally and locally important ancient monuments and archaeological sites, historic parks and gardens and, historic landscapes; c) Protect and enhance areas of countryside that are of special quality, particularly the Kent Downs Area of Outstanding Natural Beauty, Special Landscape Areas, Local Landscape Areas, Heritage Coast and undeveloped coast, ancient woodlands and, the best and most versatile agricultural land. Sustain the character and diversity of the wider countryside in general;

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d) Protect and enhance designated or proposed sites of international, national, countywide and local wildlife importance and plant or animal life protected by law. Maintain the District’s overall stock of nature conservation resources; e) Locate new development within or around existing built-up areas, especially on previously developed land, in preference to ‘greenfield’ sites; f) Maintain and improve the character and vitality of the built environment, promote a high quality of design and ensure that development density is appropriate to its location; g) Encourage energy efficiency and conservation, re-use and recycling of materials and, the sensitive development of renewable energy resources; h) Maintain and enhance water, soil and air quality; i) Maintain and enhance the provision of recreational open space, amenity land and tree and hedgerow cover; j) Prevent negative impacts on coastal protection, flood defence, land drainage and groundwater resources; and k) Safeguard and enhance the amenity of residents.

• Development proposals that would significantly conflict with one or more of environmental criteria a)- k) above will only be permitted where it can be shown that: i. there is an overriding economic or social need; ii. negative impacts are minimised as far as possible; and iii. measures will be taken to compensate for the adverse environmental effect. Where possible, compensatory measures should, as a minimum, ensure that no net environmental loss occurs.

5.5.52 The proposed development at LAA does have potential impacts which are assessed in this ES and mitigation measures are recommended for adverse impacts. However on a positive note, the proposed development will provide a basis for more jobs for the region.

Employment

5.5.53 The Plan outlines aims and objectives with the purpose of Shepway remaining competitive, by further improving and exploiting “the advantages offered by links to domestic and international markets”. The proposed development supports this view, by further developing the links to these markets. However the Plan also stresses that “employment developments must minimise impacts on local amenity and environment generally, and are developed in a co-ordinated manner to maximise their employment potential”. This ES discusses such impacts on local communities and the environment and proposed mitigation measures to minimise and any adverse impacts.

5.5.54 LAA is referred to specifically within the Plan’s Employment Objectives, where it is stated that development at LAA will be encouraged for aviation purposes, in order that employment opportunities may be expanded on Romney Marsh.

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Tourism

5.5.55 The tourism section of the Local Plan outlines the broad aim of maximising the economic, environmental and social benefits that tourism has to provide for the District.

5.5.56 The proposed development at LAA will have positive impacts for Shepway’s tourism industry, as discussed further in Chapter 17 Socio-Economic.

5.5.57 It is noted in Policy TM3 that hotel developments will be acceptable at LAA, subject to detailed design matters. None are planned under this application or the foreseeable future.

Transport

5.5.58 The Local Plan outlines aims which stress the need for developing a sustainable transport system that protects the general environment and amenity of residential areas, whilst providing an integrated transport network which can also limit the quantity of traffic on the Districts roads by encouraging alternative means of transport to the private motor car.

5.5.59 The objectives propose:

• “To ensure that new development is well related to the existing and proposed transport network especially public transport services;

• To minimise the adverse traffic impacts of development upon local communities; and

• To achieve a level of public car parking facilities compatible with sustainability aims.” 5.5.60 The Proposed Development at LAA will further develop Shepway’s transport network. However there will be adverse impacts from the increased traffic, and mitigation measures are recommended in Chapter 14 Traffic and Transport of this ES.

5.5.61 Where any new development takes place, it is stated that “developers will be expected to make provision for facilities which will allow and encourage public transport use, such as bus stopping facilities and turning areas linked to convenient pedestrian routes. Other development should also take account of the need for linkages with existing public transport routes wherever possible”. The proposed development at LAA complies with this by proposing a Travel Plan which will be implemented in consultation with the appropriate authorities.

5.5.62 There is text and policy within the Local Plan that specifically recognises LAA as an important facility for the District with the potential for improvement and expansion and as an important source of employment for the local area. The Local Plan therefore outlines that the County Council supports development that strengthens the airport function. A copy of the KCC Letter is included in Appendix 5.1.

5.5.63 Policy TR14 of the Local Plan is specific to LAA:

• Policy TR14 The District Planning Authority will permit proposals for the expansion of facilities at Lydd Airport directly related to the commercial and

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recreational flying use provided there would be no significant impact upon the internationally important wildlife communities in the Lydd/Dungeness area. Regard will also be given to the likely effect of proposals on other special features in the area, particularly the power station. 5.5.64 The mitigation measures recommended in Chapter 10 Ecology and Nature Conservation will minimise potential of significant adverse impacts on the internationally important wildlife areas in the surrounding area to LAA. No other special features are expected to be significantly affected by the Proposed Development.

Countryside

5.5.65 Much of the Local Plan’s countryside policy is relevant to the proposed development at LAA. The aims of the countryside section of Local Plan are reproduced in their entirety below:

“The broad countryside aims of the Plan are:- 1. To maintain and enhance the distinct character, functioning and quality of the countryside, (including rural towns and villages) and, conserve important natural resources; and

2. To encourage economic activity and viable communities in rural areas where this is compatible with environmental aims and objectives. 5.5.66 The Proposed Development at LAA will encourage the economic viability of Shepway, although there are environmental issues associated with this. The purpose of this ES is to address these issues and to propose mitigation measures to minimise any significant adverse impacts.

5.5.67 Policy CO1 identifies the broad principles against which development proposals in the countryside will be assessed.

• Policy CO1 The District Planning Authority will protect the countryside for its own sake. Subject to other Plan policies, development in the countryside will be permitted where proposals:

a) maintain or enhance features of landscape, wildlife, historic, geological and agricultural importance, and the particular quality and character of the countryside;

b) demonstrate that they cannot be practicably located within an existing settlement and essentially require a countryside location;

c) are of a high standard of design and, sympathetic in scale and appearance to their setting;

d) are acceptable in highway and infrastructure terms; and

e) preserve or enhance the amenity, character and functioning of rural towns and villages.

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• Development proposals that would significantly conflict with one or more of criteria a - e above will only be permitted where it can be shown that:

• there is an overriding social or economic need; • negative impacts are minimised as far as possible; and • measures will be taken to compensate for the adverse environmental effect. Where possible compensatory measures should, as a minimum, ensure that no net environmental loss occurs.

5.5.68 The proposed development at LAA will impact on Policy (a) of CO1, and this ES recommends mitigation measures to minimise potential significant adverse impacts. The proposals are going to be located to the north of the existing runway and therefore comply with point (b). The proposals are of a high standard of design, in compliance with point (c). They will enhance local infrastructure with respect to point (d). Although the proposed development may have a negative effect upon the amenity, character and functioning of local settlements, the fact that Lydd is a RPA (Rural Priority Area) and in need of regeneration display the social and economic need for the developments. In addition, this ES looks to minimise significant adverse impacts as far as possible and compensate for adverse environmental effects through the mitigation measures proposed.

5.5.69 Romney Marsh is identified as a Local Landscape Area. Policy CO5 states that “where possible, proposals should protect or enhance the landscape character and functioning of Local Landscape Areas. The District Planning Authority will not permit development proposals that are inconsistent with this objective unless the need to secure economic and social well-being outweighs the need to protect the area’s local landscape importance”.

5.5.70 The following Policies relate to sites designated for their wildlife and conservation values.

• Policy CO8 The District Planning Authority will refuse planning permission for development which would significantly effect the integrity of internationally designated or potential sites, i.e. Special Protection Areas, candidate Special Areas of Conservation or Ramsar sites unless:

• the proposal is directly connected with or necessary to site management for nature conservation, or; • there is no alternative solution and there are overriding public considerations.

• Where development is exceptionally permitted, impacts should be minimised and full compensation for remaining adverse effects provided. Where a site is host to a priority habitat and/or species, overriding considerations must be for reasons of human health or safety or, benefits of the proposal must be of primary importance to the environment.

5.5.71 The Proposed Development at LAA has been subject to extensive studies into potential adverse impacts during the EIA process and this ES recommends mitigation measures.

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• Policy CO9 The District Planning Authority will not permit development in or near Sites of Special Scientific Interest or the National Nature Reserves, which would adversely affect their wildlife or scientific interest unless;

i. there is an exceptional need for the development which overrides the national or regional value of the designation; and ii. measures will be taken to minimise impacts and fully compensate for remaining adverse effects.

5.5.72 The Proposed Development complies with Policy CO9.

• Policy CO10 The District Planning Authority will not permit development in or near Wildlife Sites or (proposed) Local Nature Reserves where such development would be detrimental to the nature conservation and / or scientific interest unless;

(i) it can be shown that there is an exceptional need for the development which overrides the value of the local nature conservation resource; and

(ii) measures will be taken to minimise impacts and fully compensate for remaining adverse effects.

5.5.73 The Proposed Development complies with Policy CO10.

• Policy CO11 The District Planning Authority will not give permission for development if it is likely to endanger plant or animal life (or its habitat) protected under law and/or identified as a UK Biodiversity Action Plan priority species or cause the loss of or damage to habitats and landscape features of importance for nature conservation, unless;

• there is an exceptional need for development which outweighs these nature conservation considerations; and

• measures will be taken to minimise impacts and fully compensate for remaining adverse affects.

5.5.74 The implications of Policy CO11 are discussed in Chapter 10 Ecology and Nature Conservation.

5.5.75 The use of planning conditions / obligations is summarised in Policy CO12.

• Policy CO12 The District Planning Authority will consider the use of conditions and/or seek to enter into planning obligations to ensure that development proposals protect and enhance important nature conservation resources, including provision for future management. In assessing proposals for development on sites of 0.5 hectares or more, the District Planning Authority will seek to retain features of nature conservation interest by establishing agreements between developers and appropriate conservation groups which could include the donation of land together with sufficient funds to ensure future management and creation of new features of nature conservation value.

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5.5.76 Policy CO13 discusses the aquatic environment:

• Policy CO13 Development proposals likely to have a harmful effect on the freshwater environment, including water courses, natural ponds, canals and sewers and adjoining banks, will only be permitted where harmful impact will be minimal, and where benefit in the form of increased access and / or water based recreation outweigh the negative effects. In such cases, measures should be taken to minimise impacts and fully compensate for remaining adverse effects.

5.5.77 The implications of Policy CO13 are discussed in Chapter 7 Water Resources and Flood Risk.

• Policy CO14 The District Planning Authority will give long term protection to Dungeness by giving priority to considerations related to its international importance for physiography, flora and fauna over other planning considerations.

5.5.78 The conflict between development and the countryside is discussed in the last section of the countryside chapter of the Local Plan. It is stated that ‘it is an objective of the District Council to encourage appropriate employment opportunities in rural Shepway’. The Parishes of Brenzett, Brookland, Ivychurch, Lydd, Newchurch, New Romney, Old Romney, St Mary in the Marsh, Burmarsh, Dymchurch and Snargate are part of the Kent Rural Development Area and therefore suffer from high unemployment and low levels of social and community facility provision.

5.6 Summary

5.6.1 In terms of policy there is general support for the development of LAA. It is recognised at National, Regional, County and District level as an important asset that could create a significant contribution to the economic growth of Shepway and Kent as a whole. The potential to assist with the economic regeneration of the Romney Marsh area and as a catalyst for growth and economic prosperity is clearly supported. As with many developments of this nature that are important not only at a local scale, but also regionally and nationally, there is a balance to be struck between various competing issues.

5.6.2 The importance of the natural environment is recognised throughout policy as is the welfare of the human population and its prosperity. Any expansion of LAA will have regard to these various issues and seek to achieve a sustainable balance.

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6 GROUND CONDITIONS

6.1 Introduction

6.1.1 This section of the report describes the existing geology, soils, hydrogeology and geomorphology of the proposed project site and outlines the current and potential environmental impacts of the proposed development on these resources. Where potentially significant impacts have been identified, mitigation is proposed to reduce the severity of such impacts to an acceptable level.

6.2 Legislative Drivers

6.2.1 A significant amount of national and international legislation and guidance is available with regard to ground conditions and particular account has been made of the following during this assessment:

Planning and Construction:

• Construction (Design and Management) Regulations 1994;

• Planning Act 1990 – Section 55;

• Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999;

• Planning (Hazardous Substances) Act 1990;

• Health and Safety at Work etc. Act (1974);

• Management of Health and Safety at Work Regulations 1999;

• Control of Substances Hazardous to Health Regulations 2002; and

• Construction (Health, Safety and Welfare) Regulations 1996.

Land Contamination

• Environment Act 1995 – Section 571;

• Environmental Protection Act, 1990, Part IIA2 and Circular (01 1 2006);

• Contaminated Land (England) Regulations 20063; and

• Planning Policy Statement (PPS) 234.

1 Environment Act 1995 – Section 57 2 Environmental Protection Act 1990, Part IIA 3 Contaminated Land (England) Regulations 2000 4 Planning Policy Statement 23

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6.2.2 Guidance from the Environment Agency5 has also been taken into account when assessing the potential for risk from potential contamination to the nearby Sites of Special Scientific Interest (see Chapter 10 Ecology and Nature Conservation for details of those designated for conservation purposes and Appendix 10.3.)

6.3 Assessment Methodology

Overall approach

6.3.1 The assessment has been based primarily on a review of published documents, supplemented by a site visit undertaken by PB geologists and a limited series of intrusive surveys, commissioned primarily for geotechnical purposes. Whilst no detailed site-specific geomorphological or land contamination assessments have been undertaken at this stage, should planning permission be granted a number of such studies are proposed as part of the construction environmental management works. A definition of terms used in the study is included in Appendix 6.1.

6.3.2 Key references for the study have included the following:

• Institute of Geological Sciences (IGS) geological – Hastings and Dungeness6;

• Soil Survey of England and Wales – Sheet 6 South East England;

• Hydrogeological map of England and Wales, Scale 1:625,0001;

• Long, A.J., Plater, A.J. and Waller, M.P. (2004). The location of the coastal geomorphological interest features at Dungeness, Kent. University of Durham for English Nature (now known as Natural England);

• Long A.J., Plater A.J., Waller M.P., Roberts H., Laidler P.D., Stupples P. and Schofield E. (2004). The Depositional and Landscape Histories of Dungeness Foreland and the Port of Rye: Understanding Past Environments and Coastal Change. University of Durham;

• Geotechnical, Lydd Airport California Bearing Ratio Testing Report 27 October 2003;

• Parsons Brinckerhoff Ltd, Lydd Airport Infiltration Testing Photographs, 17 March 2004; and

• Envirocheck Landmark Information Group Service (2005) Datasheet – Report on Lydd Airport.

5 Biological Test Methods for Assessing Contaminated Land: Stage 2 a demonstration of the use of framework for the ecological risk assessment of land contamination (EA:P5-069/TR1) 6 Institute of Geological Sciences (IGS), Hastings and Dungeness, Sheet 320/321 Solid and Drift Edition, 1:50,000 series

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Significance Criteria

Potential Effect Criteria Significant Land that is internationally designated – Permanent impact

Land that is nationally designated – Permanent impact

Major Land that is internationally designated – temporary impact. Impact affecting regionally important resource (e.g. groundwater) or leading to offsite contamination Land that is nationally designated – temporary impact. Impact Moderate affecting locally important groundwater resources. Contamination on-site No affect on designated site. No offsite impacts on groundwater. Minor Minor local protection for soil contamination Negligible No impact detected

6.4 Baseline Environment (Existing Conditions Scenario)

Soils

6.4.1 The proposed runway extension would be located on the sands and gravels of the Dungeness and Romney Marsh depositional complex, a large coastal barrier and the third largest area of coastal lowland in the UK. The marshland soils of the complex are typically characterised by a lower sequence of sands and silts overlain by an extensive peat deposit (formed between 3000 and 6000 years ago).

6.4.2 The local soils are dominated by those of the Sandwich and Romney groups7 as shown on Figure 6.1. The Sandwich group soils are mainly deep, well-drained calcareous and non-calcareous sandy soils, typically sparsely vegetated, unstable and at risk of wind erosion, although also often with locally extensive water logged hollows present amongst the associated shingle bars and spits. The Romney soils facies are described as deep, stoneless permeable calcareous coarse and fine silty soils.

6.4.3 These soils are classified as soils of high leaching potential8.

Geology

6.4.4 The Romney Marshes, adjacent to LAA, have been formed through a combination of natural sedimentation processes behind large shingle promontories and man-made reclamation of the area for agricultural development9. As a result, the natural drift deposits of the site are primarily made up of Holocene coastal and river sequences of shingles, sand and silts overlain by peat deposits.

6.4.5 The shingle deposits of the promontories are composed primarily of flint pebbles derived by marine erosion of the Cretaceous chalk and Tertiary deposits of the headlands to the west, and typically consist of pebbles ranging from 2 to 200mm in diameter. Through the coastal process of longshore drift the prevailing southwest wind has historically caused this shingle to travel eastwards along the coast where it has been deposited as fringing beaches along the coastline or cuspate forelands. The shingle in the fringing beaches is typically found to be aligned in sub-parallel ridges of

7 Soil Survey of England and Wales. Sheet 6 South East England 8 Hydrogeological map of England and Wales, Scale 1:625,000 9 Long, A.J., Plater, A.J. and Waller, M.P. (2004). The location of the coastal geomorphological interest features at Dungeness, Kent. University of Durham for English Nature;

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differing ages, the oldest ridges generally being the furthest from the present shoreline, as discussed further in 6.4.9 below.

6.4.6 The proposed site itself is located on an area of such Storm Gravel Beach Deposits, with isolated occurrences of Marine Alluvium Sand and underlying Lower Cretaceous solid geology deposits (8,10). The solid and drift geology of the site is shown in Figure 6.2. The CBR testing Results sheets indicated that the surrounding area near the existing terminal (see Figure 6.4) is coarse shingle with only two of the six test sites indicating yellow-brown mottled grey sandy clay.

6.4.7 In addition to creating a habitat for a wide variety of flora and fauna (see Chapter 10- Ecology), the shingle structures present are geomorphologically important in their own right, as described further below.

Geomorphology

6.4.8 The proposed runway extension is located within the Dungeness SSSI which is designated as an area of international importance for coastal geomorphology. It is also designated a SAC due to the annual line drift vegetation that the geomorphology supports, the impacts of which are considered in Chapter 10 Ecology and Nature Conservation. The proposed runway extension is located approximately 60m from the existing North Lade SSSI (see Figure 6.4). This area is of significant geological importance and has been designated a SSSI because of the structural deposition of natural shingle deposits. An extension to the existing SSSI has been proposed by Natural England which may extend to the airport site including the location of the proposed runway extension (Figure 6.4). Whilst this figure is only indicative the proposals have been included within the assessment in accordance with best practice.

6.4.9 The important geomorphological features of the two SSSI’s comprise a series of buried shingle ridges and troughs (with a general south-east to north-west trend) with associated sediments including fringing marsh and peat deposits. The ridges are generally well preserved and the successive shingle areas provide historic transition points between the shingle barrier and the estuarine and marsh sediments, the layout of which reflects the local history of storms and coastline changes. The two sites are considered to be of national geomorphological importance for this aspect (8, 9).

6.4.10 Within the marsh sediment itself, the lower bands of sands, silts, silty sand and silty clay generally retain their intact (laminated nature), whilst the upper (mottled) facies show evidence of significant post-depositional alteration by human activity (e.g. ploughing). Recent palaeoenvironmental reconstruction studies indicate that the marshland sediments interfingering with the gravel ridges in the Dengemarsh region were in place by at least AD 700-900, whilst the laminated sediments were deposited by following a series of storms during and sometime after the 13th Century(9).

Groundwaters

6.4.11 The sands and gravels throughout the area will provide limited groundwater supplies of uncertain quality and with the risk of saline contamination in coastal areas. The site is therefore considered to be underlain by a minor “Concealed” aquifer of variable permeability (see Figure 6.3), which runs through these unconsolidated deposits, but is considered to be of limited potential for licensed abstractions (see Chapter 7: Water Resources and Flood Risk). Details of surface waters are also included in Chapter 7: Water Resources and Flood Risk.

10 Long A.J., Plater A.J., Waller M.P., Roberts H., Laidler P.D., Stupples P. and Schofield E. 2004. The Depositional and Landscape Histories of Dungeness Foreland and the Port of Rye: Understanding Past Environments and Coastal Change. University of Durham.

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6.4.12 A summary of the geology and hydrogeology of the site is provided in Table 6.1 below.

Table 6.1 Summary of Geology and Hydrogeology of the Site Formation Flow Aquifer Description Estimated Mechanism Classification Thickness (m)

Alluvium Silts, clays and peat deposits. Fine grained and organic sediments Intergranular Minor Aquifer (Unknown deposition in low energy waters thickness) protected by gravel barriers. 1st Terrace River Gravels River gravels of inter-locking ridges and hollows related to wave energy Intergranular Minor Aquifer (Unknown and storm strength. thickness) Marine Alluvium Channel sands developed during Intergranular Minor Aquifer (Unknown barrier and foreland formation. thickness)

Mining and Contaminated Land

6.4.13 There is no evidence of mining in the vicinity of the airport (7) although there are a number of existing and historic gravel extractions in the area, as discussed further in Chapter 9 Land Use.

6.4.14 Information on the potential for significant land contamination at the site has been obtained through a review of historical maps from the site, a review of existing and historic discharge consents, interviews with key site staff and a walkover survey of the site. No intrusive investigations have been undertaken at this stage. The historical site development is described in Table 6.2 below.

Table 6.2 Historical maps of LAA and Surrounding Areas to 1km radius Maps Reviewed Site Features (publication dates) 1871, 1877, 1899, The grading of the site appears to be flat, with surface deposits of 1897, 1907, 1908, shingle to the southeast of the site. The Lydd railway line appears 1938 and 1940 beyond the south boundary of the site in 1899. The basic footprint of current day buildings appears. No details of 1961-62 airport infrastructure shown. `Basic building footprint of current activities. A tank is shown adjacent 1977-78 & 1982 to the current administration building. An old sewage plant and filter bed are also shown. Basic building footprint of current activities shown as indicated in 1989 1977-78. The old sewage plant and filter bed have been removed as well as the tank. Basic building footprint of current activities shown as indicated in 1992 1977-78. Basic building footprint of current activities shown as indicated in 1994 1977-78. Shingle outcrops shown around the southeast corner of the runway intersection. The airport is shown as the current building footprint. The airport tank 1999 farm is shown along the entrance road. Water pumping station & reservoir and gravel pits are located to the southwest of the map.

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6.4.15 The historical review has indicated that no unexpected significant potential sources of contamination are likely to exist on the site, although, as with any active airport, the presence of such operational areas as maintenance hangars, fire-fighting and fuel storage facilities and sewage treatment plants is likely to have resulted in some local contamination. No contamination associated with the location of the proposed runway extension itself has been identified, although a full ground investigation will be undertaken prior to any construction works commencing.

6.5 Baseline Environment (Future Assessment Conditions Scenario)

6.5.1 The Baseline Environment under this scenario is expected to be as under the existing conditions scenario. The exception is that proposals to combine the 8 existing SSSIs into a single SSSI called the Dungeness, Romney Marsh and Rye Bay SSSI may have been implemented. This will not, however have any physical effect on the conditions present nor will it represent a greater level of protection for the currently designated sites.

6.6 Potential Impacts (Construction Works)

Existing Conditions Scenario

6.6.1 The proposed runway extension will result in the permanent landtake of approximately 2.17ha from the edge of the Dungeness SSSI. Whilst this will not affect any of the habitats for which the SSSI has been designated, primarily the vegetated shingles and the loss represents only some 0.07% of the total 3252ha of the SSSI, the “international” importance and ‘very high’ sensitivity of the site means that the overall impact significance is considered to be moderate adverse.

6.6.2 The proposed runway extension is located approximately 60m from the existing North Lade SSSI (see Figure 6.4). This area is of significant geological importance and has been designated a SSSI because of the structural deposition of natural shingle deposits.

6.6.3 An extension to the existing SSSI has been proposed by Natural England which may extend to the airport site including the location of the proposed runway extension (Figure 6.4). Whilst this figure is only indicative the proposals have been included within the assessment in accordance with best practice.

6.6.4 The proposed construction works will result in the generation of approximately 19,500m3 of spoil. The excavations will be to a maximum depth of 750mm and there are no important aquifers located below the proposed site location. Therefore impacts on either availability or quality of groundwaters are expected to be negligible.

6.6.5 From a review of historic information there is no evidence of any especially contaminative activities on the site of the proposed runway and the spoil is expected to be clean in nature. Further investigations will be undertaken to confirm this prior to construction commencing. In addition, as the spoil will be disposed of onsite, impacts relating to spoil generation and disposal are expected to be of only minor adverse significance.

6.6.6 In addition, and given that a Construction Environmental Management Plan (CEMP) will be produced for the proposed development to ensure that the risk of accidental spillages from plant during construction work is controlled (see mitigation below), impacts arising through localised contamination of soils are expected to be of only very minor adverse significance.

6.6.7 Overall, therefore no effects to local residents, workers or ecology are expected as a

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result of impacts to ground conditions and/or hydrogeology during the construction phase of this development and impacts on the geological resources themselves are considered to be moderate adverse.

Future Assessment Conditions Scenario

6.6.8 Predicted construction impacts arising from operation of runway operation under this scenario are expected to be the same as described under the “existing conditions scenario” above.

6.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

6.7.1 The operation of the runway extension (and associated drainage – see Chapter 7 Water Resources and Flood Risk) is not expected to result in any adverse impacts to the soil, geology or hydrogeology of the site. There will be no onsite disposal of waste (see Chapter 8) and existing airport infrastructure will be upgraded as required to minimise risks arising as a result of spills to either soils or controlled waters.

6.7.2 In addition, and given that LAA intend to develop an Environmental Management System for the airport (see mitigation below) will mean that no significant impacts from airport operations are expected. Any use of potentially hazardous materials will be undertaken in accordance with UK legislation and in consultation with the appropriate regulatory authorities to ensure that no significant impacts occur.

Future Assessment Conditions Scenario

6.7.3 Predicted operational impacts arising from runway operation under this scenario is as described under the “existing conditions scenario” above.

6.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

6.8.1 The main impact to be mitigated from the proposed development is the potential impact on the existing buried geomorphology. To minimise the severity of this impact, LAA is proposing to work with Natural England to undertake a targeted site investigation of the geomorphologically important area of the proposed runway extension site prior to construction to ensure that further information concerning the importance of the local geomorphology can be obtained and recorded.

6.8.2 The proposed survey will include the following:

• An assessment of existing geomorphic information present on the extent and nature of the local soils with reference to the evolution of the areas during the last 2000 years;

• A surface topographic survey of the site;

• Sampling of soils by hand coring on a 25m grid throughout the study area. A detailed description of sediments encountered at each site will be completed and will include grain size, composition, depths etc., using a semi-quantitative method adopted by researchers of coastal deposits;

• Drilling of a deep borehole to determine the ancient sedimentary record of site

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evolution in an area where ridges of gravel deposits at the surface with troughs (swales) in-filled with finer grained sediment may be present. This very distinctive geomorphology marks the landward limit of gravel deposition into the back- barrier marshland sediment, The exact location of this borehole will be decided following completion of the hand coring; and

• Optically-stimulated luminescence (OSL) dating of sediments obtained from two levels within the deep borehole to provide a chronology of back-barrier sediment in-filling of the marshland during historical times. 6.8.3 Should planning permission be granted, an approach to pre-commencement site investigations will also be agreed with the regulatory authorities, targeted to those areas where contamination could be most likely encountered, and undertaken to assess the extent of any contamination present. Should any such material be encountered, it will be analysed for the presence of hazardous materials and a remediation strategy developed in accordance with current regulatory requirements and submitted for approval to the regulatory authorities, to be carried out before construction works commence. I

6.8.4 A site specific Health and Safety and Environmental Plan will be developed prior to commencement of site works in accordance with the requirement of the CDM Regulations, 199411. The work will also be undertaken in compliance with the requirements of the following regulations: the Health and Safety at Work Act12, the Management of Health and Safety at Work Regulations13, the Control of Substances Hazardous to Health Regulations14 and the Construction (Health, Safety and Welfare) Regulations15. Under CDM, a works method statement and risk tables will be produced to assess and reduce possible hazards and risks to site users during construction works.

6.8.5 A Construction Environmental Management Plan (CEMP) will be prepared for the proposed development to minimise potential significant impacts upon the underlying geology and soils. General mitigation measures that would be included within the CEMP include the following:

• All works to be properly barriered off and adequate signage installed to indicate appropriate Personal Protective Equipment (PPE) required (and to be worn at all times);

• All health and safety equipment to be available onsite, including spill kits fire extinguishers etc.16 (12);

• All fuel storage to be properly stored i.e. bunded where the bund would contain 110% of fuel stored17;

• In addition to the site investigation should any contaminated ‘hot-spots’ be identified by the on-site contractors, work in that area will cease until the material present has been sampled and analysed and an appropriate and agreed remediation strategy developed;

• Should any contaminated areas be identified, a remediation approach would be agreed with the regulatory authorities before the commencement of any

11 Construction (Design and Management) Regulations 1994 12 Health and Safety at work etc. Act (1974) 13 Management of Health and Safety at Work Regulations (1999) 14 Control of Substances Hazardous to Health Regulations (1999) 15 Construction (Health, Safety and Welfare) Regulations (1996) 16 Department for Environment Food & Rural Affairs, Assessment of Risks to Human Health from Land Contamination CLR 8,9 & 10 (2002) 17 Department for Environment Food & Rural Affairs, Guidance note for the Control of Pollution (Oil Storage) (England) Regulations 2000

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remediation works. Should off-site removal be required any material would be disposed of at a suitably licensed facility;.

• Any excavated material will be placed on hardstanding, covered and placed away from any watercourses (17);

• All clean material arising from construction works will be spread evenly within the application boundary over the clear and graded area before grassing the runway surrounds; and

• If significant dust is generated all areas will be damped down.

Future Assessment Conditions Scenario

6.8.6 Construction mitigation measures under this scenario is as described under the “existing conditions scenario” above.

6.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

6.9.1 Given the limited potential impacts of the proposed operational facility on local ground conditions, no specific operational mitigation is proposed at this stage, over and above the development of a Environmental Management System (EMS) for the airport (to follow the ISO 14000 series approach). The development of such an EMS will help ensure that the risk of accidental spillages is minimised, and that any use of potentially hazardous materials is undertaken in accordance with UK legislation and following consultation with the appropriate regulatory authorities.

Future Assessment Conditions Scenario

6.9.2 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

6.10 Residual Effects

Existing Conditions Scenario

6.10.1 The proposed runway extension will result in the permanent landtake of approximately 2.12ha from the edge of the Dungeness SSSI. The runway will primarily affect the vegetated shingles and the loss represents only some 0.066% of the total 3252ha of the SSSI, the ’international’ importance and ‘very high’ sensitivity of the site means that the overall impact is considered to be moderately adverse.

Future Assessment Conditions Scenario

6.10.2 Residual impacts are expected to be as described for the “existing conditions scenario” above.

6.11 Summary

6.11.1 Baseline conditions for the site have been established from a desk study and walkover of the area. The site is underlain by alluvium, terrace gravels and marine alluvium which are geomorphologically important. The walkover has indicated that whilst, as with any active airport, there are some potential sources of historic

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contamination onsite. None are expected in the area of the proposed runway extension, although this will be confirmed through an intrusive investigation before construction commences.

6.11.2 Mitigation of the potential impact on the geomorphology will be undertaken through a targeted site investigation of the area of the proposed runway extension, to ensure that the historical value of the site is recorded.

6.11.3 Excavation of spoil will be undertaken with care and material will be properly handled and reused onsite as appropriate. As mentioned above, a pre-construction site investigation will be undertaken and, should any areas of contamination be encountered, a remediation strategy will be developed for approval, to be carried out prior to the commencement of development in accordance with UK legislative requirements.

6.11.4 No significant differences are expected between those impacts predicted under the “existing conditions” and “future assessment” scenarios.

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7 WATER RESOURCES AND FLOOD RISK

7.1 Introduction

7.1.1 This Chapter assesses the potential impacts of the proposed runway extension to (and from) the water environment. As such, it covers issues of:

• Surface water and groundwater quantity and quality;

• Flood risk assessment;

• Water use and consumption; and

• Sewage generation, treatment and disposal. 7.1.2 The scenarios modelled in this chapter are as described in Chapter 1.

7.1.3 This Chapter should be read alongside Chapter 10 (Ecology and Nature Conservation) regarding potential indirect impacts to the nature conservation value of the Marsh and adjacent sites arising through changes to water quality / quantity.

7.2 Legislative Drivers

7.2.1 The following key legislation and policies have been reviewed as part of this assessment:

• The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003, which brings into law the provisions of 2000/60/EC Water Framework Directive (primarily water management at river basin district level and the implementation of River Basin Management Plans);

• The Water Resources Act 1991, which makes it an offence to cause or permit pollution of controlled waters;

• PPG 25 Development and Flood Risk1, which aims to increase communication between land-use planning, land management and the Building Regulations. This guidance explains how flood risk should be considered at all stages of the planning and development process in order to reduce future damage to property and requires the planning system to ensure that new development is safe and not exposed unnecessarily to flooding; and

• PPS 23 Planning and Pollution Control.

1 Whilst PPG 25 is still the current guidance, account has also been taken of the requirements of the draft PPS 25 during these works.

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7.3 Assessment Methodology

7.3.1 This assessment has been undertaken with regard to both the methodologies outlined in ‘Environmental Impact Assessment: A Guide to Procedures’ (DETR 2000) and the requirements of PPS 23 ‘Planning and Pollution Control’ and PPG 25 ‘Development and Flood Risk’. In addition, the comments provided by SDC and their consultees on the Project Scoping Report1 have been taken into account wherever feasible.

7.3.2 Initial data on existing conditions has been collected through a desk study of the area, including a review of the following information:

• Data held by the EA on water quality targets, river chemistry and flood risk;

• Accompanying report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

• Data from the Landmark “Envirocheck” database on discharge consents and pollution incidents to controlled waters (within a 1km radius of the site) and abstraction licences (within a 2km radius); and

• Findings of the ecological impact assessment. 7.3.3 Additional information has been obtained from the following sources:

• EA Pollution Prevention Guidance Notes;

• National Groundwater and Contaminated Land Centre Report NC/99/73, 2001;

• Planning Policy Statement (PPS) 23 Planning and Pollution Control (2004);

• Planning Policy Guidance (PPG) 25 Development and Flood Risk (2001);

• Sustainable Urban Drainage System: Best Practice Manual (CIRIA/ C523);

• The EA General Quality Assessment (GQA) scheme for the assessment of surface water quality. 7.3.4 The desk study was followed by a series of sites visits by specialist hydrologists, ecologists and drainage engineers and an ongoing dialogue has been maintained with the Regulatory Authorities (including the EA and the local IDB) throughout the EIA process.

7.4 Baseline Environment (Existing Conditions Scenario)

Surface Waters and Drainage

7.4.1 LAA lies adjacent to Denge Marsh, a flat area of historic marshland which is now drained to the sea by a series of interconnected tide locked drainage ditches controlled by the local Internal Drainage Board (IDB). The key watercourses near the site are:

• The Dengemarsh Sewer, which is classified as a main river and is controlled by the EA. It is the main watercourse on the site and runs approximately north – south adjacent to the site’s western boundary. As a main river, any work on the

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watercourse or within 8m of the bank requires Land Drainage Consent from the EA; and

• The Mockmill Sewer, which runs west-east adjacent to the northern boundary of the site, before turning at 90O down the site’s western boundary and joining the Dengemarsh Sewer. 7.4.2 Several other tributaries also drain into these sewers and there are a number of other drains across the site which are not confluent. The Jury’s Gut Sewer (see 7.4.12) is ultimately connected to the site via these lateral drains.

7.4.3 Water levels within the marsh ditches are controlled by the IDB via a series of sluices and retained at approximately 0.5m AOD during the summer and 1.4m AOD during the winter, rising to approximately 2m AOD during times of flood. A number of control sluices lie within the application site boundary, including the sluice on the Mockmill Sewer.

7.4.4 The majority of the site has no piped drainage system and under an agreement with the EA, stormwaters are allowed to drain directly to soft verges and natural soakaways.

7.4.5 Runoff from the terminal area and carpark is drained by a positive piped system through a single stage interceptor to an outfall in the Dengemarsh Sewer (see 7.4.12). There are three oil separator tanks included within this system, one of 750 gallons located in the car park; one of 3,500 gallons by the fuel farm; and one of 3,000 gallons by the main hangar. These separator tanks are inspected regularly and emptied by tanker on a quarterly basis.

7.4.6 Runoff from the apron is collected and discharged to a newly constructed pollution interception basin and separate attenuation basin. The pollution basin has an impermeable liner and reedbeds for pollution treatment and is also equipped with sluice valves to enable any spill of hazardous materials to be contained and removed before it enters the surrounding drainage system. From the basins the water enters the Dengemarsh Sewer at “greenfield” runoff rates under an agreement with the EA.

7.4.7 LAA is currently in the process of backfilling several drains and standing waterbodies located in close proximity to and east of the runway to meet CAA requirements.

7.4.8 Four surface water abstractions are located within 2km of LAA, as shown in Table 7.1 below.

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Table 7.1 Licenced Surface Water Abstractions within 2km of LAA

Operator Description Direction Distance from Abstraction terminal Norman Dengemarsh South west 654m General agriculture: Balcomb & Sewer and spray irrigation- direct Son associated unclassified ditches Norman Dengemarsh South west 704m General agriculture: Balcomb & Sewer spray irrigation- direct Son Lydd Golf Club Lydd Golf Club- North 1036m Spray irrigation and Driving tributaries of Range Ltd Dengemarsh Sewer A E Wrout & Private ditches, West 1565m General agriculture: Son watercourses and spray irrigation- direct petty sewers Note: Mockmill Sewer is not included in the Table as there are no licenced abstractions from it.

7.4.9 Surface water quality is monitored by the EA at two sites close to LAA, namely the Jury’s Gut sewer (to the west of LAA) and the Littlestone sewer (to the north east). The location of these sites is shown in Figure 7.1.

7.4.10 Monitoring data indicates that water quality in both sewers is generally poor, with both recording only a river quality target level of 5 in the last two decades (1 indicates good water quality, 6 poor water quality). As a result the sewers are considered to be ecologically poor, with the only species present likely to be those adapted to low levels of dissolved oxygen.

7.4.11 A recent assessment of the Romney Marsh / Dengemarsh Sewer and Jury’s Gut Sewer showed that both are at significant risk of failing their objectives under the Water Framework Directive. This is due to modifications to physical structure as a result of land-use changes and in the case of the Jury’s Gut, the risks of invasive (non-local plant species) entering the water.

Standing Surface Waters

7.4.12 Standing waterbodies are prevalent throughout the area, as shown in Figure 7.1. There is a water-body of approximately 100m2 present immediately to the east of the runway and a further series of ponds present on the golf course to the north west of the site. The closest large water-body to LAA is Greatstone Lake / Lade Pit, approximately 1km to the east, whilst the Arc Pit / Dungeness Gravel Pit, New Diggings, and Burrows Pits are located between 1.5 and 2.5km to the south. All these waterbodies are monitored by the Environment Agency. To the west of these pits are smaller waterbodies, mostly formed by new excavations. Whilst each of these lakes has also been assessed against the objectives of the Water Framework Directive, none appear to be at risk of failing these objectives.

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Groundwaters

7.4.13 As discussed in Chapter 6 (Ground Conditions), whilst local soils are classified as of high leaching potential, the site is only underlain by a minor aquifer of variable permeability contained within the unconsolidated deposits. There are 6 licensed groundwater abstractions within 2km of LAA, as shown in Table 7.2 below. Of these the most sensitive is the private potable water supply at Denge Marsh (some 700m distant), with the nearest public water supply located some 2km from the site.

Table 7.2 Licenced Groundwater Abstractions within 2km of LAA

Operator Description Direction Distance from Abstraction Terminal Folkestone & Wells at South 683m Potable water supply- Dover Water Denge Marsh direct Services Ltd Lydd Golf Club and Sand pit, North west 1201m Spray irrigation- direct Driving Range Ltd marine alluvial sands Hall Aggregates Lydd East 1698m Sand and gravel (SE) Ltd washing Folkestone and Denge Marsh South 1943m Public water supply Dover Water Services Ltd. Folkestone and Well No. 26 at South 1948m Public water supply: Dover Water Denge Marsh potable water supply- Services Ltd. direct RMC aggregates Beach shingle North east 1998m Extractive: process (Southern) Ltd in Lydd water

Recorded Pollution Incidents

7.4.14 There have been only 2 minor pollution incidents to controlled waters recorded from within the vicinity of LAA (and none in recent years) involving a release of fire water/foam near the terminal building on 9th April 1996 and a release of gas oil from the hangar on 27 August 1996. Recent improvements in airport management and investment in improved drainage (including the development of the new attenuation pond and interceptors) should help minimise the risk of such incidences in the future.

7.4.15 Whilst the local climatic conditions mean that LAA does not need to use antifreeze for its current (or proposed) operations, it does, however, use a number of hazardous materials that could potentially cause pollution of surface waters if they were not properly controlled. These include the following:

• A fuel farm with two bunded 54,000l tanks, which contain AVGAS and Jet A-1;

• Two mobile re-filling stations of 9,000l and 14,000l, which are filled from the fuel farm (under controlled conditions with spill response procedures);

• Oil stored in 1 litre containers in the fire department;

• A 1,000 litre tank of foam in the fire department;

• Below-ground oil separator tanks;

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• Waste oil tanks;

• Engine oil, paint spray cans, solvents and hydraulic oil present in small amounts in the aircraft maintenance hanger; and

• Sewage held in a cesspit at the southern end of the car park. 7.4.16 Current LAA management practices have been designed to ensure that all such materials are handled, and eventually disposed of, in a responsible manner.

Water and Sewage

7.4.17 The Airport is provided with a piped water supply which has the capacity to support up to 300 000 passengers movements per annum. As such, this is considered more than adequate to meet the demands of current passenger movements which consists of some 45m3 of water per week,

7.4.18 Recent investment in upgrading the existing sewage treatment and disposal system (including replacement of old sewage pipelines) means that the current cesspit-based sewage system is also considered adequate to meet current needs. At present some 45m3 of sewage are generated per week, and this is removed by two 25m3 tanker visits a week, which remove any effluent generated and transport it to an appropriate licenced treatment and disposal facility.

Consented Discharges

7.4.19 There are currently two discharge consents within 1km of the site, both held by LAA, and both into a tributary of the Dengemarsh sewer, namely:

• a trade effluent consent (site drainage from the Bravo Apron is treated in the attenuation pond) located some 600m north west of the existing terminal building; and

• a historic trade discharge consent (process water) located approximately 200m north west of the existing terminal building. 7.4.20 The process water consent is held by LAA for the discharge of treated sewage effluent from airport operations (consent number P.9062/K/CA/00) and has limitations attached to it as outlined in Table 7.3.

Table 7.3 Historical Effluent Discharge Limits from the old LAA Sewage Treatement Works (STW) Description Limit Description Limit Sewage volume 54 m3 / day Nitrogen 3 Mg/Lt Rate of 2 litre per sec Phosphate 1 Mg/Lt discharge BOD 10 Mg/Lt Iron 2 Ug/Lt Suspended 10 Mg/Lt Lead 30 Ug/Lt solids pH 6 – 9 Copper 20 Ug/Lt

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Flood Risk and Coastal Defence

7.4.21 Lydd and the surrounding area is a flat landscape and parts of Romney Marsh are 2m lower than the highest spring tides. The Environment Agency Map identified the whole of Lydd as being within the coastal flooding area for a 1 in 1000 year tide. The site is therefore identified as being within the ‘at risk’ area. This flood risk is affected by coastal sediment movement and is therefore managed in the area through the use of both offshore sediment recharge and longshore drift control (see Figure 7.2 and Table 7.4 below). For further details please refer to the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

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Table 7.4 Shoreline Flood Defence Management Units Flood Defence Description Lydd Ranges This runs from Jury’s gap to Dungeness Power Station. The foreshore is an exposed shingle storm ridge, with a narrow inter-tidal zone, which declines towards the east. The storm ridge protects a very extensive low-lying area from inundation, but a number of over-toppings do occur under a combination of extremely high tidal levels and strong wave action and this can result in serious flooding landwards of the Green Wall. Breaching of this ridge would have an impact in terms of flooding in both the adjacent units to the west and those of New Romney and Greatstone-on-Sea to the east. The Jury’s Gap location is a particularly vulnerable section. Long shore drift in this unit is predominantly in an easterly direction. Artificial beach feeding occurs at Jury’s Gap and at the Dengemarsh outfall. The ancient secondary defence line of the Green Wall runs at a shallow angle inland from the coast towards the foreland and this artificial gravel ridge is intercepted at Jury’s Gap due to changing coastal configuration. The eastern section is undefended, although following storms the beach banks are re-profiled. The preferred policy option for this retreating unit is ‘hold the line’ through continued recharge and maintenance. The present standard of service of the defences (over-topping/active breach) is 1:25. Dungeness Power Dungeness Power Stations are located on a narrow foreshore with an Station eroding shoreline. The coast is retreating, and the long shore drift is dominantly in an easterly direction. At present, the natural storm beach is supplemented by beach recharge. The preferred policy option here is hold the line, seen as the only option during the life and decommissioning of the plant. The opportunity for significant landward realignment of the coastline even following the completion of the earlier stages of decommissioning is restricted however due to the need for a safe store approach to the long- term decommissioning of the Power Stations. It is legally required that the present standard of service here is 1:10,000. Dungeness to This is a historically accreting shoreline, with drift in a south westerly and Littlestone on Sea southerly direction. The present storm ridge backs a wide sand and mud foreshore, increasing rapidly from a very narrow zone at the Dungeness to 1.2km at Greatstone-on-Sea and declining again towards Littlestone-on- Sea. The present day shingle backshore thus has a series of ridges which tend to absorb any waves that overtop the present day beach crest. The sand dunes at Greatstone-on-Sea are also an important flood defence. At Romney Sands, groynes have been constructed to reduce the long shore transport of shingle. The crest of the bank is at approximately 6.5mOD, which is insufficient to prevent overtopping during extreme events. Flooding and partial breaching have occurred at Greatstone-on-sea in the recent past on several occasions, flooding the car park and several adjoining properties. The preferred policy option here is ‘do nothing’ due to natural accretion. However, continued monitoring of beach levels is required for protection against breaching. If the natural accretion of Dungeness foreland ceased, and erosion started, the do nothing option would change to hold the line. From the power station to Greatstone-on-Sea there are 1:100 defences present. From Greatstone-on-Sea sand dunes to Romney Sands the service is 1:15.

7.5 Baseline Environment (Future Assessment Conditions Scenario)

7.5.1 No significant changes are considered to the natural water resources in and around the Airport under the Future Assessment Conditions Scenario, and nor are any changes expected to the risk of flooding.

7.5.2 With regards to water and sewage requirements, the piped water supply is considered adequate to meet the demands of up to 300 000 passengers movements per annum,

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and ongoing upgrades to the sewage treatment and disposal system will also allow this to meet the demands of 300 000 passengers. Proposed rates of water consumption and sewage generation (the two are considered directly proportional) for the Future Assessment Conditions Scenario are shown in Table 7.5 below. The current two tanker visits a week to remove effluent and transport it to an appropriate treatment and disposal facility are expected to increase to approximately 8 tanker visits a week, an issue discussed further in Chapter 14 Traffic and Transport of this ES

7.5.3 The existing water supply is adequate to meet the demands of current passenger movements, and recent investment in maintaining and improving the existing sewage treatment and disposal system (e.g. the old sewage pipelines being replaced) has meant that the current cesspit system is also considered adequate. Currently there are two tanker visits a week to remove effluent and transport it from this cesspit to an appropriate licenced treatment and disposal facility (See Table 7.5).

7.5.4 No other significant impacts to surface and groundwater resources have been identified at this stage from existing operations.

Table 7.5 Existing Water & Sewage Volumes Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or sewage Tanker Visits per generated) per Week* week (m3) 3,000 68 44 2

7.5.5 Up to 300,000 passenger movements can be accommodated within the existing terminal building and the existing water supply is adequate to meet their demands without modifications. Sewage treatment and disposal will continue to be managed by maintaining and improving the existing system.

7.5.6 Proposed rates of water consumption and sewage generation (the two are considered directly proportional) for 300,000 passengers per annum are shown in Table 7.7 below. The current two tanker visits a week to remove effluent and transport it to an appropriate treatment and disposal facility is, however, expected to increase to approximately 8 tanker visits a week at 300,000 passengers (See Table 7.6). This is discussed further in Chapter 14 Traffic and Transport of this ES.

Table 7.6 Predicted Water & Sewage Volumes at 300,000 Passengers per annum Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or sewage Tanker Visits per generated) per Week* week (m3) 300,000 180 181 8

7.5.7 The increase of passenger numbers will require additional car-parking spaces which will be accommodated by converting 2 of the existing stands on the Bravo Apron. The drainage from this area will be collected and discharged to the pollution interception basin and separate attenuation basin. Any hazardous spills will be contained and removed before it enters the surrounding drainage system (See Section 7.4.7).

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7.5.8 The increased number of aircraft movements to 300,000 passengers per annum has the potential to increase levels of aircraft related pollutants discharged to surface watercourses during periods of heavy rain, whilst the increased use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

7.6.1 The extension of Runway 21 by 294m, as well as 150m of clear area, will require the infill and abandonment of approximately 1013m of drains (See Figure 4.1 and 4.2). This will have a number of impacts:

• Removal of any in stream and riparian flora, fauna and habitat;

• Reduction of storage capacity for drainage and surface waters; and

• Disruption of the natural hydrology of the immediate area. 7.6.2 The impact on the in stream and riparian ecology has been assessed and described in detail in the Ecology chapter of this ES (Chapter 10 Ecology and Nature Conservation).

7.6.3 To compensate for the loss of storage capacity, approximately 1256m of new ‘replacement’ drains will be developed around the runway area. These areas will connect to the existing drainage features and have been designed in consultation with the EA and the IDB. The replacement drains will replicate the abandoned drains in width and depth to ensure storage volumes of surface water is greater or equal to those abandoned and will ensure adequate storage of runoff volumes from the runway extension during peak rainfall ‘events’.

7.6.4 The replacement of the surface drainage features will require careful management to ensure drainage regimes are maintained at the site. Drainage regimes, especially seasonal variations possible over the construction period will be incorporated in the Construction Environmental Management Plan (CEMP).

7.6.5 The construction of these replacement sewers will also generate a number of impacts:

• Generation of some 1884m3 of spoil material;

• Potential erosion of the new banks and bed as the channel hydraulics’ and sediment patterns achieve a state of settlement or equilibrium;

• Sedimentation of the watercourses downstream of the new drains as a result of the earthworks and potential erosion of the new drains which may cause disruption to any downstream flora and fauna (See Chapter 10 Ecology and Nature Conservation); and

• Ongoing maintenance commitments to maintain the new drains.

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7.6.6 Spoil piles located near a watercourse can affect local drainage through surface water runoff collecting material and depositing this material downstream and construction works can also affect local water quality through dewatering works and the discharge of site drainage. Prior to the commencement of construction works, the Contractor will be required to prepare a CEMP to minimise such impacts and to include drainage plans to control runoff, erosion and sedimentation (see mitigation). This CEMP will also be used to prevent the storage of fuels, oils and lubricants or the use of the contractor’s compound to contaminate surface water and groundwater through leaks and spills. Overall impacts are therefore expected to be of only minor adverse significance.

7.6.7 Construction works will require a quantity of water for such uses as consumption by work force, dust suppression and use in machinery and plants. Water required for such works will be obtained primarily from the piped water supply, with additional supply from mobile water bowers during specific activities, if necessary. Impacts from water usage are therefore expected to be a minor adverse impact.

Future Assessment Conditions Scenario

7.6.8 Predicted construction impacts for this scenario are as described for the ‘existing conditions scenario’ above.

7.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

7.7.1 The increased number of aircraft movements to 300,000 passengers per annum has the potential to increase levels of aircraft related pollutants discharged to surface watercourses during periods of heavy rain, whilst the increased use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.7.2 The proposed runway extension is not expected to significantly affect the operational activities of the airport, and whilst it will increase the amount of hardstanding present, the proposed drainage system has been developed in consultation with the IDB and EA to ensure that no significant impact will arise to surface or groundwater resources over and above those outlined for the 300,000 passengers without the runway extension.

7.7.3 Aircraft related pollutants and sediments will be collected by the oil separators and silt traps respectively which are an integral design of the runway extension (see Figure 4.2) . These services will be maintained regularly by LAA and the material disposed of at an appropriate facility. The use and storage of potentially contaminating substances within or near the existing terminal building could also lead to leaks and spills that could affect local water quality. The recent development of the attenuation and reedbed treatment pond, with its pollution interceptors and the airports ongoing commitments to improving site drainage, as well as improved environmental management planning, means that such impacts are only expected to be of minor adverse significance.

7.7.4 The entire LAA site is within a coastal flooding area (see Figure 7.2) and will be potentially exposed to a 1 in 200 year tide level of 5.47m Above Ordnance Datum

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(AOD). At such a level, the potential impact of flooding is considered significant however the overall increase in the length of drains provided will attenuate surface flows and impacts are expected to be of only minor adverse significance. Further details are provided in the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

7.7.5 Levels of water consumption and associated sewage generation will not increase as result of the runway extension as described in Future Assessment Conditions scenario (see paragraph 7.5.3)

7.7.6 Overall, the impacts of the runway extension on drainage are likely to be minor given the appropriate management of the replacement sewers is undertaken to ensure they retain their functional capacity for storage.

Future Assessment Conditions Scenario

7.7.7 Predicted Impacts arising from the operation of this scenario are expected to be similar to those described under the ”existing conditions” above, a part from the fact no sewer will be replaced under this scenario.

7.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

7.8.1 The loss of storage capacity by the abandonment of the existing drains will be mitigated by the development of new ‘replacement’ drains, which will ensure the existing storage capacity is retained and increased to accommodate the increase in impervious surface as a result of the runway extension.

7.8.2 Spoil material generated by the construction of these drains is approximately 1884m3 which will be disposed of by infilling the sewers to be abandoned with the surplus spread onsite in the clear areas.

7.8.3 Appropriate stormwater management measures will be designed and installed by the contractor prior to commencement of works to prevent erosion of any exposed soils/substrates and to prevent sediment laden or contaminated water draining offsite into adjacent controlled waters. Such measures may include diversion channels around the site for discharge into treatment/detention ponds and will be developed in consultation with the Local Authority, EA and the IDB.

7.8.4 Specific mitigation measures to avoid contamination of the receiving environment during construction will be detailed in a CEMP and will include, as appropriate:

• Fuel/oil tanks and chemical storage tanks/areas to be provided with locks and placed on compacted areas, within bunds that have a capacity equal to 110% of the storage capacity of the largest tank, to prevent spilled materials from leaking offsite. All valves and couplings to be located within the bunded area;

• Oil interceptors will be provided in any drainage system downstream of possible oil/fuel pollution sources. The oil interceptors will be emptied and cleaned regularly to prevent the release of oils and grease into the stormwater drainage system. Waste materials will be disposed of at an appropriate facility. Any surface water contaminated by hydrocarbons which are used during the

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construction phase will be passed through these oil/grit interceptor(s) prior to discharge;

• Measures will be taken to ensure that no leachate or any surface water that has the potential to be contaminated to enter directly or indirectly any watercourse, underground strata or adjoining land;

• Water inflows to excavated areas will be minimised by the use of lining materials, good house keeping techniques and by the control of drainage and construction materials in order to prevent the contamination of groundwater;

• Site personnel will be made aware of the potential impact on ground and surface waters associated with certain aspects of the construction works to minimise the incidence of accidental impacts;

• Refuelling of construction vehicles and equipment will be restricted to a designated area with properly designed fuel tanks and bunds and appropriate operating procedures;

• All channels permanent and temporary and any temporary attenuation ponds will be maintained to prevent flooding and overflowing and protected where necessary against erosion;

• All temporary hardstanding areas and exposed surfaces or storage areas will be designed to discharge to attenuation ponds. They will not discharge to watercourses or flow offsite in an uncontrolled manner;

• Portable chemical toilets and sewage holding tanks will be placed onsite to accommodate sewage generated by the construction workforce. A licensed contractor will be responsible for appropriate disposal and maintenance;

• Handling and storage of any potentially contaminating material will only occur in designated areas to prevent discharge to watercourses, the drainage system, or offsite;

• No washdown areas will be located near watercourses, or open drains and washdown waters will be collected and directed to appropriate treatment; and

• A spill management plan will be in place at all times.

Future Assessment Conditions Scenario

Construction mitigation measures are as described for the ‘existing conditions scenario’ above.

7.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

7.9.1 The drains within the airport boundary are owned and will be maintained by LAA. Drains outside the airport boundary are owned by IDB which undertakes annual maintenance of these drains to ensure they maintain their drainage capacity and efficiency. Maintenance of LAA’s drains will be undertaken in consultation with the IDB to ensure consistency of the maintenance regime in providing surface water

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storage throughout the system. LAA will ensure these sewers are monitored to ensure they remain stable as erosion of the banks and beds has the potential to cause obstructions to drainage, reduced storage volumes and may cause localised flooding if the banks are breeched.

7.9.2 The proposed drainage has been designed to ensure an increased overall length of drains to attenuate any additional surface flows that could arise as a result of the proposed runway extension and hence to minimise the risk of flooding. In addition a detailed Flood Risk Assessment has been undertaken for the entire airport (in consultation with the EA) which recommends the types of construction materials to be used in any developments at the airport to reduce the risk of flood-related impacts. Further details are provided in the separate report “Flood Risk Assessment Report, For the Proposed Runway Extension, 2006 by BSF Consulting Engineers”.

7.9.3 Whilst the increase in the number of aircraft movements will result in the increased risk of contaminants entering watercourses, an Environmental Management Plan (EMP) will be produced to minimise such risks and appropriate spill prevention procedures will be detailed in the “Lydd Airport Aerodrome Manual & Emergency Orders”.

Future Assessment Conditions Scenario

7.9.4 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

7.10 Residual Effects

Existing Conditions Scenario

7.10.1 With the implementation of the mitigation measures detailed above the construction and operation of the runway extension is expected to have no more than a minor adverse impact on the surface and groundwater resources of the area.

Future Assessment Conditions Scenario

7.10.2 Residual impacts are expected to be as described for the “existing conditions scenario” above.

7.11 Summary

7.11.1 LAA lies adjacent to Denge Marsh and is drained to the sea by a series of interconnected tide-locked drainage ditches which are controlled by the Internal Drainage Board (IDB). The Environment Agency Flood Map identifies the whole of Lydd as being within the coastal flooding area for a 1 in 1000 year tide. The site is therefore identified as being within the ‘at risk’ area.

7.11.2 The majority of the site has no piped drainage system and under an agreement with the EA, uncontaminated storm-waters are allowed to drain directly to soft verges and natural soakaways. A new attenuation pond, with reedbed treatment and interceptors, has recently been developed to improve control of runoff from the main apron.

7.11.3 The runway extension is located to the north of the existing runway and will affect a number of drains. These drains will be backfilled and new drains constructed around

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the proposed runway extension. Whilst groundwater levels are high in this area, there are no abstractions in close proximity that are likely to be affected.

7.11.4 The current water supply and sewage disposal is adequate for the increase to 300,000 passengers.

7.11.5 A Construction Environmental Management Plan (CEMP) will be developed together with an operational Environmental Management Plan (EMP) and Spill Response Plan to minimise risks of accidental pollution of watercourses.

7.11.6 The runway extension will create additional storage volume due to the increased length of new ditches and overall. However, it is expected that the extension will have no more than a minor impact on surface and groundwater resources. No significant impacts on or arising from flood risk are envisaged.

7.11.7 For the majority of impacts, no significant difference in magnitude is expected between those impacts anticipated to arise when compared to the “existing conditions” and those arising compared to the “future assessment conditions” scenario. The exception is the magnitude of the increased volume of water consumed or sewage produced with the proposed terminal development, which is considerably less when compared to the latter scenario.

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CHAPTER 8

SOLID WASTE MANAGEMENT

CHAPTER 8 LAA

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8 SOLID WASTE MANAGEMENT

8.1 Introduction

8.1.1 Waste management is arguably one of the most challenging environmental issues of our times. The UK is fast running out of landfill capacity and new legislation will significantly affect the way waste is managed. This chapter reviews the solid wastes arisings that are expected to be generated during the construction and operation of the proposed runway extension at LAA and discusses options for their disposal given the available facilities in the region.

8.1.2 The scenarios modelled in this chapter are as described in Chapter 1.

8.2 Legislative Drivers

National Context

8.2.1 Section 44A of the Environmental Protection Act 1990 (as amended) required the preparation of a National Waste Strategy for England which was published in 2000. Preparation of the Strategy ratifies Article 7 of the 1991 EU Framework Directive on Waste, and includes policies for meeting the following objectives:

• Ensuring that waste is recovered or disposed of without endangering human health or using processes or methods which could harm the environment (including giving rise to noise or odour nuisance);

• Establishing an integrated and adequate network of waste disposal installations. This network should also aim to help the EU meet its objective of becoming self- sufficient in waste disposal, and that waste is disposed of in the nearest appropriate installation;

• Encouraging the prevention or reduction of waste through the development of clean technologies, the technical development and market of products with the least impact on the waste stream, and the development of techniques for the final disposal of dangerous substances in waste for recovery; and

• Encouraging recovery, reuse, reclamation, recycling, etc and the use of waste as a source of energy. 8.2.2 It also outlines how each sector can contribute to achieving the aims of the Strategy, and targets to limit Industrial and Commercial waste, in an effort to reduce the amount of these wastes landfilled to 85% of their 1998 levels.

8.2.3 Since the publication of the Waste Strategy 2000, both municipal and business waste are growing at a rate slower than GDP; with municipal waste increases slowing from 3.5% per year in 2000 to 1.5% per year today. There have also been reductions in the relative amounts of some key waste being landfilled - municipal waste has decreased from 82% to 72% and industrial and commercial waste from 50% to 44% over this period.

8.2.4 A substantial range of new policy instruments has also been introduced, including the landfill tax escalator, the Landfill Allowance Trading Scheme (LATS), the aggregates levy, regulations to implement a number of EU directives on waste in specific sectors

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(including packaging and vehicles) and a new planning policy statement (PPS10) covering waste.

8.2.5 In February 2006, the Government published a consultation document which sets out the progress made since 2000 in meeting its objectives and implementing its policies with respect to waste, which includes proposals for a revised strategy and the policies for implementing it. In revising the Strategy the Government wishes to build on the progress that has been made to ensure that we meet Landfill Directive targets and other European commitments. However, a shift in emphasis is also required for the future as follows:

• Putting greater focus on waste prevention and embedding this in the wider Sustainable Consumption and Production (SCP) agenda alongside other environmental impacts;

• Seeing waste as a resource and extending a recycling and re-use culture beyond the home to workplaces, shopping and leisure activities;

• Highlighting sustainable waste management in the non municipal sectors (over ten times the size of household waste including commercial, industrial, construction, demolition, mining and quarry wastes which have varying characteristics) with greater integration of planning and procurement between municipal and some non-municipal waste; and

• Securing technologically efficient investment in the treatment of waste in each part of the chain. Previous relatively cheap landfill ‘solutions’ are not an option and the step-change in investment that has already begun will need to gather pace.

Regional Context

8.2.6 The South East England Regional Assembly (SEERA) published a Regional Waste Management Strategy (Proposed alterations to Regional Planning Guidance, South East – Regional Waste Management Strategy) in March 2004 and proposed a radical change in the way waste is managed in the South East.

8.2.7 The South East Region is one of the most pressed regions for waste management capacity. Much of it is designated as protected, for example, through AONB and SSSI status or green belt designation. The creation of the South Downs and New Forest areas as National Parks will exacerbate this situation.

8.2.8 The South East’s waste includes approximately 4.1 million tonnes of municipal solid waste (collected by local authorities), of which almost 80% is landfilled and only 19% is recycled; approximately 8 million tonnes of industrial and commercial waste, of which half is landfilled; approximately 13 million tonnes of construction and demolition waste, only a third of which is recycled as aggregates or soil, and approximately five million tonnes of agricultural waste. The total waste managed in the South East is estimated to rise to nearly 35 million tonnes by the year 2025. The Strategy addresses all of the main waste streams that are currently subject to regulation – municipal, commercial and industrial, and construction and demolition waste.

8.2.9 There are currently significant inter-regional movements of waste including imports from London but also exports to neighbouring regions. In particular, there are exports of municipal waste from Kent to landfill in the East of England and large quantities of commercial and industrial waste from Hampshire, Kent and Surrey.

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8.2.10 There are at present extensive and significant movements of waste between waste planning authority areas. The patterns of movement are particularly complex for commercial and industrial waste, with two-way movements between most areas reflecting waste being transported to the nearest site (proximity), although a high degree of self-sufficiency is achieved in Oxfordshire and Kent.

8.2.11 Previous regional guidance on waste planning (which covered London and parts of the East of England) proposed self-sufficiency in the disposal of non-inert waste at the county level as a means of encouraging responsibility for waste management, development of waste management facilities and reducing transport. The county level will often provide an appropriate level for sub-regional planning for all waste streams and management methods, particularly as waste local plans and frameworks will form the basis of more local planning for the provision of waste management and processing facilities.

8.2.12 However, the approach will need to evolve and change to reflect the dynamic nature of waste, cross-border movements and the factors that drive this including the commercial market and contracts, proximity and Sustainability Appraisal and, in particular, a move towards greater resource recovery and management.

8.2.13 The following targets for recovery and diversion from landfill were established:

• Commercial and Industrial Waste – through an assumption that diversion required by the target in the Waste Strategy 2000 (85% of waste landfill in 1998 to be landfilled in 2005 will continue over the lifetime of the Strategy); and

• Construction and Demolition Waste – through applying the target for reducing landfilling of commercial and industrial waste to 2005 and continuing to divert construction and demolition material from landfill disposal beyond that date. 8.2.14 The targets are particularly challenging as waste is currently increasing annually and has increased since the Landfill Directive and Waste Strategy 2000 targets were set. This implies that increasing proportions of waste will be diverted from landfill through recycling, composting and other recovery and diversion. Recovery includes recycling, composting and other methods of recovering materials and, in certain circumstances, energy from waste.

Local Context

8.2.15 The Kent Waste Local Plan 1998 to 2011 contains detailed land-use policies and proposals in relation to waste management and waste disposal in a given area. The Kent Waste Local Plan sets a county-wide strategy for waste disposal, including the identification of specific site opportunities for waste management and disposal facilities. The Waste Local Plan aims to promote waste minimisation, recycling, as well as minimise the distance waste is transported from its generation source. The proposed application will need to demonstrate that the development is in reasonable compliance with these objectives.

Business Context

8.2.16 Commercial and industrial waste generation and management have a direct financial impact on businesses and the cost of disposal is set to increase. It therefore makes good sense to reduce waste generation in the first place and to get as much value out of materials as possible. Landfill tax increases will also affect the costs of disposal of

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commercial and industrial waste, encouraging recovery. In addition, many materials are now banned from landfill and alternative management is required. Alternatives to landfill need to be identified for these materials.

8.2.17 The Government has two key measures in place to support the diversion of commercial and industrial waste from landfill. The Landfill Tax is aimed at increasing the costs of disposal to landfill and making other management routes more commercially attractive. The tax is currently £21 per tonne (from 1st April 2006) for active wastes and £2 per tonne for inert wastes. The tax is on a £3 per tonne per year escalator to a maximum of £35 per tonne in the medium term. The Aggregates Levy is intended to reflect the environmental costs of quarrying and to increase the attractiveness of secondary aggregates produced from inert mineral wastes and construction and demolition wastes. The tax is currently set at a level of £1.60 per tonne.

8.2.18 Given the relative size of the commercial and industrial waste stream and the ability to separate materials at source, there are greater potential benefits through increasing recycling rates in this sector. The significant increase in landfill tax will provide further encouragement to businesses and industry, including construction, to minimise waste and improve recycling.

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8.2.19 There is a raft of legislation affecting the management of wastes arising from the construction and operation of the airport, the key ones are within Table 8.1 below.

Table 8.1 Summary of Key Legislation Primary Act Secondary Legislation Remit Prohibition on unauthorised or Environmental Waste Management harmful depositing, treatment, or Protection Act S 33 Licensing Regulations disposal of waste (e.g. facilities to 1990 Part II 1994 (as amended) be licensed; and certain activities onsite to be registered exempt) Environmental Protection (Duty of Duty of Care in respects to waste S 34 Care) Regulations 1991 (e.g. use of transfer notes) (as amended)

Hazardous Waste Specifies arrangements for the (England) Regulations management of hazardous waste 2005 and (e.g. producer registration and use S 62 List of Wastes of prescribed consignment notes) (England) Regulations and ratifies the European waste 2005 catalogue into UK law Controlled Waste Control of (Registration of Carriers Requires carriers of waste to be Pollution and Seizure of Vehicles) registered with the Environment (Amendment) Regulations 1991 (as Agency Act 1989 amended) European Transfrontier Shipment Supervision and control of waste Communities of Waste Regulations shipments between Member States Act 1972 1994 into and out of the EU Collection, transport, storage, handling, processing, and use or disposal of animal by-products (e.g. Animal By Products catering waste); and placing on the Regulations 2005 market, export and transit of animal by-products and certain products derived from them Ratifies the EU landfill directive (i.e. Pollution Landfill (England and banning of certain wastes to landfill, Prevention & Wales) Regulations and introducing acceptance Control Act 2002 (as amended) procedures which apply to 1999 producers and operators) Pollution Prevention and Ratifies the EU IPPC directive (i.e. Control (England & certain activities will require a permit

Wales) Regulations from the environment agency or 2000 (as amended) local authority)

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8.3 Baseline Environment (Existing Conditions Scenario)

8.3.1 The generic waste streams currently generated by LAA are shown in Table 8.2 below.

Table 8.2 Generic waste streams from LAA Hazardous Wastes General Wastes

Maintenance activity wastes (oily rags, Aircraft cabin waste (newspapers, magazines, waste oil, waste fuel, tyres) foodstuffs) Waste oil from the waste oil tank (being Food wastes (general food wastes, raw meat refurbished at the time of the site visit) and fish, aluminium cans, glass, plastic) Material from occasional spills (oily water Customs waste (seized contraband goods) mixtures and emulsion, contaminated adsorbent material) Feminine hygiene waste and other waste considered to be clinical Cleaning wastes (containers of cleaning chemicals) Landscape wastes (grass cuttings and excavated soil)

Aqueous Film Forming Foam (AFFF) (waste water from fire fighting appliances)

Electrical waste (information technology and communications equipment)

Office Waste (paper, plastic etc).

8.3.2 The existing level of operations means that only a small amount of waste is currently generated at the airport (approximately 2000 kg per annum), and this is regularly collected and disposed of by licensed contractors at an approved and fully regulated facility nearby. There are a number of such licenced waste management facilities in the Kent and East Sussex area, with the nearest to the airport being the Allen’s Bank site located at the former Pioneer Aggregate Quarry opposite the Golf Club on the north east side of the B2075. This site is currently operated by Bromley Landfill Limited, Ashford and is licensed for the disposal of clean inert waste (EU Category No. 170504) including uncontaminated soil and stones, and would therefore be available for general inert construction wastes.

8.3.3 Sewage from the airport is also tankered off-site for treatment as described further in Chapter 7: Water Resources and Flood Risk.

8.4 Baseline Environment (Future Assessment Conditions Scenario)

8.4.1 Data from other UK airports (see Table 8.3) indicates that an average passenger trip generates some 0.32kg of waste, (by extrapolation, 300,000 passengers per annum are expected to generate approximately 96,000 kg of waste per annum, less than 0.24% of the annual waste produced by a major local centre such as Ashford. Such levels are considered to be well within the capacity of the local waste disposal facilities and impacts arising are expected to be of only minor adverse significance.

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Table 8.3 Indicative Waste Production Statistics for UK Airports1 Airport Waste to landfill per Percentage of waste recycled out of passenger (kg) total waste arising (1997/1998) (1997/1998) Heathrow 0.32 17.0 % Gatwick 0.36 13.7 % Stansted 0.44 5.7 % Glasgow 0.31 3.1 % Edinburgh 0.19 7.2 %

8.4.2 Waste types will be as outlined in Table 8.2. 8.4.3 The proposed development will produce an increase in sewage which will be disposed of offsite (refer to Chapter 7: Water Resources for more detail).

8.5 Predicted Impacts (Construction Works)

Existing Conditions Scenario.

8.5.1 The impacts of 300,000 passengers are detailed above and the resultant impacts arising are expected to be of only minor adverse significance. Therefore this section will focus on the impacts as a result of construction of the runway extension

8.5.2 The construction waste types likely to be generated are:

• Soil (topsoil and subsoil) excavated from the proposed runway extension site (approximately 19,100 m3) and the drainage ditches (approximately 400 m3)will be reused within the application site;

• Aggregate used for temporary access roads (approximately 10,000 m3);

• General waste (office, catering waste etc.);

• Building materials (cement, concrete, bricks etc.);

• Packaging waste (wood, metal, plastic etc.);

• Hazardous waste (oils, oil filters, oily rags, chemical/oil containers, batteries, expended sand blast etc.);

• Paint waste (paint, tins, buckets etc.); and

• Electrical waste (cables, cable drums, cable trays etc.). 8.5.3 Construction wastes such as cement, concrete, bricks, tiles and ceramics with low contents of metals, plastic, organics, wood, chemicals, rubber are typically classed as inert wastes. Disposal of up to 50% of such materials can generally be avoided by careful management, for example the use of small scale processing plant located close to the source or destination of the material. Such approaches will be used during the proposed construction works and impacts arising are expected to be of

1 Sources: Commission for Integrated Transport, A comparative study of the environmental effects of rail and short-haul air travel. Ref: http://www.cfit.gov.uk/docs/2001/racomp/racomp/a3.htm)

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only minor adverse significance.

8.5.4 The Landfill Directive (as implemented by the 2002 Landfill Regulations) requires pre- treatment of hazardous waste prior to landfilling and has resulted in a significant reduction in the number of sites for disposal of such wastes. This in turn has affected disposal prices and transport costs meaning that the most economical options for dealing with such wastes generally involves an element of treatment and subsequent re-use onsite. Levels of hazardous wastes arising are not expected to be significant.

8.5.5 Spoil generated during construction works will be stockpiled and reused on site wherever possible. Stockpiled materials exposed to wind action will be damped down and no significant effects are expected to result.

Future Assessment Conditions Scenario

8.5.6 Predicted impacts arising from construction of the facilty under this scenario are expected to be the same as described in the ‘existing conditions scenario’ above .

8.6 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

8.7.1 The increase of passenger levels to 300,000 passengers per annum is expected to result in the same waste types as outlined in Section 8.4. Volumes of waste will increase to approximately 96,000 kg of waste per annum, which represents a 48 fold increase over the existing conditions. Despite this increase, it will still represent less than 0.24% of the current annual waste production of a major local area such as Ashford, and is therefore considered to only result in an impact of minor significance on the operation of the existing waste disposal facilities within the County )including the permitted and proposed waste to energy plants).

8.7.2 Traffic implications associated with increased waste disposal movements are addressed in Chapter 14.

Future Assessment Conditions Scenario

8.7.3 Predicted waste streams and traffic implications under this scenario are expected to remain the same as the ‘existing conditions scenario’ above.

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8.7 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

8.7.1 A CEMP will be produced prior to construction which will involve measures to control waste production such as a Site Waste Management Plan. This will be prepared using the Department of Trade and Industry (DTI) voluntary code of practice2. The Plan will minimise waste at source during the construction works through the accurate assessment of the potential for “waste” material re-use and recycling both on and off site.

8.7.2 Adopting a site management approach based around an effective SWMP will facilitate:

• Better control of risks relating to the materials and waste on site;

• Dealing with queries from stakeholders regarding waste arisings more efficiently;

• Compliance with legislation;

• Management of materials supply, storage and handling in an appropriate manner; and

• Better management of waste for recovery or disposal. 8.7.3 The excavation and potential reuse of soil as part of the construction phase is classified as a Waste Management Activity and is covered under an exemption in Paragraph 19A, Schedule 3, to the Waste Management Licensing Regulations 1994 (as amended). An application to register the Paragraph 19A exemption will be made to the Environment Agency for the reuse of these materials as part of the development.

8.7.4 Any importation of secondary aggregates for use as part of construction activities (e.g. temporary road) will be reviewed in the context of the Waste & Resources Action Plan (WRAP) Quality Protocol3. This provides purchasers with a quality-managed product to common aggregate standards, which increases confidence in performance and provides a clear audit trail for those responsible for ensuring compliance with Waste Management Legislation, whilst allowing producers to demonstrate that their product has been fully recovered and is no longer a waste.

Future Assessment Conditions Scenario

Proposed mitigation for construction impacts under this scenario is as described in the ‘existing conditions scenario’ above.

2 Guidance for Construction Contractors and Clients on Site Waste Management Plans (SWMPs), published by the DTI in July 2004 (http://www.dti.gov.uk/construction/sustain/site_waste_management.pdf) 3 WRAP Quality Protocol - http://www.aggregain.org.uk/quality/quality_protocols/index.html

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8.8 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenarios

8.8.1 The majority of waste is likely to be produced by airline passengers at the airport and any waste prevention and minimisation programmes will need to be targeted at these airlines. It is a long term commitment of LAA to produce a Waste Management Strategy which will be developed as part of the Environmental Management Systems (EMS) for the airport.. This strategy will identify how individual waste streams are managed, collected, and disposed of airside and landside. For example companies using bins provided by LAA for use in airside or landside areas will be required to make annual declarations of what they are disposing of into those bins. This process will be audited periodically to ensure that waste materials are being placed into the most appropriate bin. The Strategy will focus on the top levels of the Waste Hierarchy (i.e. Reduce, Reuse, and Recycle) before other options are employed (e.g. disposal to landfill). To the extent practicable selected waste management sites should be chosen using the proximity principle. The following paragraphs identify some specifics that will need to be considered as part of this strategy both landside and airside at the airport.

Aircraft Waste Arisings

8.8.2 The main components of aircraft waste will be newspapers and magazines left by passengers; plastic packaging from food and drinks and cabin waste comprising un- segregated food waste and other packaging materials.

8.8.3 Whilst only a limited number of aircraft waste surveys have been carried out to date, a recent study calculated an average composition profile for aircraft waste based on data from Bristol, Manchester and Leeds/Bradford airports4. The figure below represents the typical composition of waste arising from aircraft based on these findings.

4 Proposed development at Stansted Airport Environmental statement volume 15 Waste Management, August 2001, Entec UK Ltd

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Figure 8.1 Average Composition of Aircraft Waste from UK Airports

Paper Glass 40% Cans (Fe & Al) 47% Plastics Card Textiles 1% 6% 2% 2% Re-usable items 1% Residual waste 1%

8.8.4 There is often a very short turnaround time (< 30 minutes) from when passengers disembark an aircraft to the next set of passengers boarding the plane. This leaves on-board cleaners very little time to collect waste, let alone segregate material streams on the aircraft. Therefore a waste management contract needs to be developed which incorporates waste re-use, recycling and recovery as part of the waste collection protocol.

8.8.5 Figure 8.1 shows the largest percentage of aircraft waste is paper, future waste management protocols will include recycling containers for collection of waste newspapers and magazines at aircraft stands for use by the cleaning contractors.

8.8.6 Food waste needs to be managed and disposed of in accordance with the Importation of Animal Products and Poultry Products Order 1980 (as amended) or the Animal by Products Regulations 2005, as appropriate. An assessment of the implications of managing and disposing of such waste and imported food (e.g. that seized by customs) will be undertaken and arrangements put in place for its segregation airside and appropriate disposal.

Airport Lounges and Restaurants

8.8.7 Food waste needs to be managed and disposed of in accordance with the Animal by Products Regulations 2005. For instance, raw meat and fish cannot be disposed of to landfill and must be placed in a separately marked bin and sent to an approved outlet (e.g. incinerator or alkaline hydrolysis plant). Cooked meat and fish and bakery products can however be sent to landfill and in some instances be fed to livestock. An assessment of the implications of managing and disposing of food waste will be undertaken and arrangements put in place for its segregation and appropriate disposal. Segregated waste bins will be introduced allowing separate collection of cans, glass and paper.

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Maintenance Activities

8.8.8 Higher volumes of air traffic at the site in the future will undoubtedly lead to an increase in maintenance and the associated waste streams. These are potentially likely to be hazardous wastes, which would require special arrangements for disposal and are not necessarily suitable for recycling. Particular attention will be given to the appropriate management of rubber from aeroplane tyres and oils (and oily contaminated materials – for example, absorbent materials used to clean up leaks and spillages).

Aircraft Re-Fuelling Operations

8.8.9 After a large plane has been refuelled, a small portion of the fuel is drained from the truck tanks using a syringe and tested for water content. This fuel cannot be poured back inside the tank, and the management practices will incorporate containers to collect and store this fuel so that it can be safely disposed of offsite.

Future Assessment Conditions Scenarios

8.8.10 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

8.9 Residual Effects

Existing Conditions Scenario

8.9.1 Residual effects of the construction of the proposed runway extension will be to increase the volume of waste leaving the LAA site. The increase in the volume of waste produced will have a residual effect on the capacity of waste receiving centres, the number of waste collection journeys to and from the airport site and the increased demand on waste disposal sites. It is considered that for the 300,000 passenger scenario, once the proposed waste management systems have been put in place, impacts are expected to be of only minor adverse significance.

Future Assessment Conditions Scenarios

8.9.2 Residual effects are expected to be as described for the “existing conditions scenario” above.

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8.10 Summary

8.10.1 The current operation produces a number of forms of waste. The volume of waste is expected to increase with the expansion of the airport and the construction of the runway extension.

8.10.2 The following mitigation measures will be implemented to reduce the volumes of waste produced in accordance with the targets set by SEERA’s Waste Management Strategy:

• Preparation and implementation of a Site Waste Management Plan to an approved Code of Practice prior and during the construction phase;

• Reuse of soil during the construction phase will be regulated in accordance with an exemption under the Waste Management Licensing Regulations 1994 (as amended);

• Adoption of standardised protocols for importing and exporting secondary aggregates during the construction phase; and

• Development and implementation of an airport wide Waste Management Strategy which identifies how individual operational streams are managed, collected and disposed of airside and landside. The Strategy will focus on the top levels of the Waste Hierarchy (i.e. Reduce, Reuse, and Recycle) before other options are employed (e.g. disposal to landfill). 8.10.3 Whilst the magnitude of any impact arising from the proposed development is greater when compared to the “existing conditions” scenario as opposed to the “future assessment conditions” scenario, in neither case are the waste volumes generated by either the construction or operation of the new facility considered a significant impact.

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9 LAND USE

9.1 Introduction

9.1.1 This Chapter describes the existing land-uses in and around the airport and assesses the potential impacts associated with the proposed new runway extension by comparison to a) the Baseline (Existing Conditions) and b) Future Assessment Condition (300,000 passengers) scenarios. The work has included both site visits and desk studies and focuses on land within an radius of approximately 1km centred on GR 064213 (1:25 000 Ordnance Survey Explorer Map Number 1251). It includes a brief assessment of impacts on the footpaths and wider environs of the area, including the towns of Lydd, New Romney and the coastal settlements to the east.

9.1.2 The scenarios modelled in this chapter are as described in Chapter 1.

9.1.3 As described in Chapter 4, it is proposed that the runway extension will be built on land to the north of the existing runway. This location is shown in Figures 4.1 and 4.2.

9.1.4 The remainder of this Chapter is structured as follows:

• Policy and Legislation: identifies the relevant policy and legislation at national, regional and local levels;

• Methodology used to identify the parameters of the study and defining the terms used;

• Baseline conditions relating to current land use;

• Impacts of the proposed development against both Baseline and Future Assessment Condition scenarios; and

• Mitigation measures recommended. 9.1.5 Impacts on geology are detailed in Chapter 6: Ground Conditions, water in Chapter 7: Water Resources and landscape in Chapter 12: Landscape and Visual Amenity.

9.2 Legislative Drivers

9.2.1 The recently issued Planning Policy Statement 72 (PPS 7) promotes sustainable patterns of development and highlights that development should focus on re-use of previously developed land (brownfield), near to local service centres where employment, housing and other services can be provided. Development on greenfield land is discouraged, and development in rural areas “should be well designed and inclusive with its location and sensitive to the character of the countryside and local distinctiveness”.

9.2.2 PPS 7 highlights that “the presence of the best and most versatile agricultural land defined as land in grades 1, 2 and 3a of the Agricultural Land Classification (ALC)3, should be taken into account alongside other sustainability considerations”. This latter

1 Ordnance Survey: 125 Explorer Map, Romney Marsh, 1:25 000, 2004 2 Office of the Deputy Prime Minister (ODPM): Planning Policy Statement 7, Sustainable Development in Rural Areas, HMSO 2004 3 Department of the Environment, Food and Rural Affairs (DEFRA): Agricultural Land Classification of England and Wales: Revised Guidelines and Criteria for Grading the Quality of Agricultural Land Defra Publications

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includes inter alia biodiversity, the quality and character of landscape, amenity value, accessibility to infrastructure etc. PPS 7 continues “Little weight in agricultural terms should be given to the loss of agricultural land in grades 3b, 4 and 5 except in areas where particular agricultural practices themselves may contribute in some special way to the quality and character of the environment”.

9.2.3 The ALC provides a general indication of land quality in all areas on a scale ranging from 1 (best) to 5 (lowest), based upon the long term physical limitations of land for agricultural use. The classification is compiled in the light of the interactions of climate, site, slope and soil characteristics from which is calculated the agricultural capability of the soil as outlined in Table 9.14. Grade 3 is subdivided into two. In accordance with current UK best practice, all local soils are considered as a default 3a category, unless indications to the contrary are available.

Table 9.1 Agricultural Land Classification Criteria Grade Level Type

With no or very minor limitations to agricultural use 1 Excellent giving rise to high and consistent yields Very good with minor limitations affecting crop yield, 2 Very good cultivations or harvesting, although some difficulties may arise from demanding crops Moderate/high yields with a narrow range of crops or 3a Good to Moderate moderate yield with wide range of crops Moderate yields of narrow range of crops and lower 3b Moderate yields of wide range of crops Severe limitations as to crops and yields, suited to grass 4 Poor and some low and variable yields of cerreals – includes droughty arable land Very severe limitations, suited to permanent pasture or 5 Very Poor grazing

9.3 Assessment Methodology

9.3.1 The assessment has been made with reference to the Department of the Environment’s “Preparation of Environmental Statements for Planning Projects that Require Environmental Assessment – A Good Practice Guide5 which indicates that the best quality of agricultural land should be protected from development and that in some poorer areas non-prime land may have local importance for maintaining a viable agricultural economy. Where appropriate, guidance in other manuals, such as the Design Manual for Roads and Bridges (DMRB) Volume 11, Part 6 – Land Use6, has also been taken into account.

4 Finch H J S , Samuel, A M and Lane, G P F: Lockhart & Wiseman's Crop Husbandry including Grassland, Woodhead Publishing, 2002 5 Environment, Department of (DoE), Preparation of Environmental Statements for Planning Projects that require environmental assessment – A Good Practice Guide, HMSO 1995 6 Design Manual for Roads and Bridges (DRMB) Vol 11 Part 6 – Land Use, The Highways Agency, 1993

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9.3.2 The land-use assessments have paid particular attention to:

• Land take;

• Local ALC;

• Local Site Designations; and

• The impacts of major works for access, and severance.

Assessment Criteria

9.3.3 Land use for the purpose of this assessment is defined as the use and management of any land directly or indirectly affected by the proposed development.

9.3.4 Whilst there are no published “standard” criteria for land use assessments, significance levels for potential effects have been drawn up based upon practical experience and guidance from such bodies as the Institute of Ecology and Environmental Management (IEEM)7 and the Institute of Environmental Management and Assessment (IEMA)8. Significance is therefore seen as an interaction of both the sensitivity of the potential receptor (e.g. international, national, regional, local importance) and the magnitude and scale of change.

9.3.5 The assessment has been carried out as a three stage process using these criteria as outlined in Tables 9.2, 9.3 and 9.4.

Table 9.2 Criteria to Assess Sensitivity of Receptor Magnitude Criteria

Areas of land use of national or international importance e.g Significant designated sites and neighbouring land uses, highly sensitive to the type of development proposed. Land uses that are of regional, or county importance, especially Major neighbouring land highly sensitive to the type of development proposed.

Moderate Areas of land of local importance, especially neighbouring land highly sensitive to the type of development proposed.

Minor Land uses of greater than local importance, although not particularly sensitive to type of development proposed.

Negligible Areas of land of no more than very local significance or not sensitive to the type of development proposed.

7 Institute of Ecology and Environmental Management (2006) Guidelines for Ecological Impact Assessment in the United Kingdom (version 7 July 2006). http://www.ieem.org.uk/ecia/index.html 8 Institute of Environmental Management and Assessment (2004). Guidelines for Environmental Impact Assessment. IEMA, Lincoln.

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Table 9.3 Criteria to Assess Magnitude and Scale of Change on Land Use Magnitude Criteria

Existing land use will be unable to continue as a direct or indirect Significant consequence of the development or a beneficial new land use that could not otherwise occur will be facilitated.

Major Where existing land use can continue but changes in land take, extent, profitability, enjoyment, etc. is likely to be noticed by the user.

Minor Small changes not materially affecting the continuation of existing use. Negligible No predicted change.

Table 9.4 Assessment of Significance of Potential Effects on Land Use Potential Effect Criteria

Significant A land use of at least national importance which will be unable to continue or will be facilitated as a direct result of the development process. At a minimum a noticeable change in land use of at least regional Major importance; or unable to continue as a result of the development process. A noticeable change in locally significant land use, which may be Moderate unable to continue; or a small change in nationally important land use. Minor Small changes with no more than local effects Change will be negligible and/or land use not sensitive to this type Negligible of development process.

9.4 Baseline Environment (Existing Conditions Scenario)

Existing Land Use Overview

9.4.1 The proposed runway extension will be built on predominantly arable farmland, with some minor loss of drainage ditches, on land to the north of the existing runway as outlined in Table 9.5 below.

Table 9.5 Percentage Land-take of Footprint Type % Landtake of Footprint Existing Hardstanding 0% Improved Grassland 100% Current SSSI 16.21% Current SSSI affected 0.07% Proposed SSSI 83.78% Proposed SSSI affected 0.19%

9.4.2 A desktop study has been undertaken to identify existing land uses in the area which has included a review of:

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• Local plans for the study area, primarily the Shepway Local Adopted Plan (2006) and Kent and Medway Structure Adopted Plan (2006) and Kent County Council, Mineral Waste Development Framework9;

• Aerial and ground photographs;

• Ordnance Survey mapping1 ALC4, Kent Land Usage10; and

• A review of the Countryside Character Initiative reports11. 9.4.3 To comprehensively assess the baseline conditions of land use at LAA, a site visit to the airport and surrounding areas to survey the land use took place on 19th August 2005 with a visual update in October 2006. A detailed study area of approximately 1km was defined as a generically accepted area for EIA purposes. Land use definitions were developed as shown in Table 9.6 and the area in Figure 9.1.

Table 9.6 Land Use Definitions Land Use Definition Existing airport Land currently owned by LAA. land Farms & Property identified as part of a farm holding with land used for Agriculture agricultural purposes e.g. the growing of crops or grazing of animals. Land used for tourism and recreational purposes e.g. golf courses; Leisure/Tourism caravans; holiday lets; hotels; bed and breakfast, etc. Land used for the pursuit of industrial work e.g. factories. This includes Industrial aggregate gravel extraction and landfill Property used for residential purposes, including farm houses of former Residential farms. Military Land occupied or used by the Ministry of Defence. Designated areas e.g. Proposed Ramsar site, Special Area of Designated Conservation (SAC), Site of Special Scientific Interest (SSSI) – Areas/Nature including proposed extensions,. This includes a number of waterbodies Reserves and woodland. Dismantled Former railway line. railway Access and Access tracks and Public Rights of Way. Rights of Way

9.4.4 Most of the land (approximately 75%) in an arc around LAA from the southwest to the northeast is made up of freehold farm/agricultural holdings with the remainder including a mix of residential properties, tourism businesses (e.g. the golf course complex) and some mineral extraction of sands and gravel. The mainly residential areas of the towns of Lydd and New Romney lie to the west and north of the airport respectively with the coastal settlements of Littlestone-on-Sea, Greatstone-on-Sea, Lydd-on-Sea and their associated developments to the east.

9.4.5 Figure 6.1 shows the local soil conditions in the area. The soil is free draining and ranges from a loamy/clay typical of the coastal flats in the west and northwest to sand

9 Kent County Council, Mineral Waste Development Framework, Section 1 – List of Existing Permitted Construction Aggregate Sites With Reserves Remaining To Be Worked website 10 Kent County Council, Kent Landscape Information System, available at www.kent.gov.uk/klis/home 11 Countryside Agency, Character Area 123, Romney Marshes, www.countryside.gov.uk/Images/JCA123_tcm2- 21573.pdf, 2006

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dune type soils in the east and south east (including the Dungeness shingle bank to the south-east). Further to the north lie the former Medieval salt workings of Romney Salts. A full description of these soils is given in Chapter 6: Ground Conditions.

9.4.6 The land to the north of Lydd Town is described by the Countryside Agency as “high quality agricultural land of extensive arable fields and some traditional open wet pasture land grazed by cattle and sheep”.

9.4.7 Romney Marsh itself is an area of reclaimed open marshland bounded to the south and east by the English Channel and to the north and west by old sea cliffs on the Wealden and Lower Greensand beds. It is characterised by a flat, open agricultural landscape, with distinctive drainage dykes, marshes and forms Countryside Agency Countryside Character Area 123. Kent County Council refers to the Romney Marsh area as mixed farmland, and it is designated as a local landscape area by Shepway District Council under policy CO5 of the Local Plan 2006, as well as within the Kent and Medway Structure Adopted Plan SPG1 (July 2006). Denge Marsh, which lies to the west of the site has the landscape action 'Conserve and Restore/Reinforce' ascribed to it.

9.4.8 The Marshes are interspersed with narrow, straight roads and isolated settlements with distinctive churches, which add to the overall sense of remoteness and the open landscape character. The area’s high nature conservation value is concentrated on the wet grazing marshes, dykes, mudflats and the less extensive but distinctive sand dunes and shingle ridges of Dungeness to the south east of the site, as described further in Chapter 10 Ecology and Nature Conservation.

9.4.9 Outside the detailed 1km study area the predominant land uses consist of tourism/leisure (along the coast) and residential (the numerous towns and villages in the area). The military have a firing range training ground approximately 2km to the south west of the airport.

Existing Land Use: LAA & the Surrounding Area

9.4.10 The existing land uses surrounding the airport are detailed below and illustrated in Figure 9.1.

Airport Land

9.4.11 Within the airport boundary much of the land is taken up with the existing terminal building, car park, apron, runway and hangar, as well as ancillary facilities such as the fire department, air traffic control tower and fuel farm. A small range of commercial, business and recreational activities also operate out of the airport, including FAL Aviation – Business Executive management; Lydd Air; Sky-Sure Engineering and the Lydd Aero Club. Details of these have been provided earlier in the ES.

9.4.12 The Airport has recently purchased a parcel of 15.5ha of farmland to the northwest of the existing terminal area and holds options on two further parcels of land to the North and Northeast of the airport comprising 11.3ha and 18.2ha respectively, which are currently still in agricultural use.

Residential

9.4.13 The majority of the properties in the area and along the coastal ribbon development comprise a mixture of bungalows and semi-detached dwellings, whilst in Lydd, the residential area includes the historic centre surrounded by newer housing developments. Impacts upon residential land uses as a result of construction and

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operation of the proposed runway extension are, against ‘existing conditions’ and ‘future assessment’ scenarios, addressed throughout this document, rather than as a stand-alone issue in this section.

Farming/Agriculture

9.4.14 The land immediately surrounding the airport is graded 3 to 4 as shown on Figure 9.2, where it can be clearly seen that there is a “finger” of grade 3a loamy clay soil on a north / south axis between the grade 4 and non-agricultural land of sand dune and shallow lime-rich soils to the west and the Dungeness Shingle Bank to the east. Some good quality land (Grades 1 and 2) is present on the opposite side of the B2075 Romney Road.

9.4.15 The farms immediately surrounding the airport include Belgar, Forty Acre, Footway and Whitehall Farms. Whilst still agricultural holdings, these farms have generally started to diversify into the leisure/tourist industries through the introduction of B&B’s, caravans for rent and farmgate sales of fresh produce. Fields are also rented out in some cases to other farmers for the grazing of sheep and horses on an ad hoc basis.

9.4.16 Due to the flatness of the topography crops tend to suffer from wind damage. Thus local farming systems are centred on typical three year rotation built around wheat, oilseed rape, early potatoes with set aside and grazing.

Leisure/Tourism

9.4.17 Holiday/caravan parks are found along the coast and include the Romney Sands Holiday Village through which runs the Romney, Hythe & Dymchurch Miniature Railway, the smallest public railway in the world.

9.4.18 The beaches, which form part of the proposed Ramsar site, are a mixture of sand and shingle with a storm beach running along the coast on which are found beach huts. Hotel and bed and breakfast accommodation is also available on farms and in private houses as well as in Lydd and New Romney.

9.4.19 A small motorbike racing circuit is present on Belgar Farm which is only occasionally used and is found to the north west of the airport. Some recreational facilities, particularly a go-karting circuit, are found on the edge of Lydd next to Lydd Military Camp.

9.4.20 Lydd Golf Club is found adjacent to the airport boundary to the north/northwest. The golf course was a former turf production business, but today the Club comprises of a club house with a bar and restaurant available for function hire, a golf professional shop, an 18 hole golf course and a driving range. Planning permission has been recently granted for a 76 bedroom hotel and ancillary facilities.

9.4.21 There are no roads within the Airport lands, other than the airport access road itself, which leads off the B2075 Romney Road. The study area is bounded by the Lydd- New Romney Road and the coast road from New Romney through Greatstone on Sea and Lydd on Sea to Dungeness and Dungeness Road from Dungeness to Lydd. Access to the fields surrounding the runway is by way of tracks, but these are not public rights of way.

9.4.22 Public rights of way outside the airport boundary include a public footpath running from Footway Farm through Belgar Farm to New Romney and from New Romney to Greatstone on Sea. In addition, there are several public footpaths crossing the shingle bank to the south east which connect to public rights of way to Lydd and through Boulderwall Farm and the RSPB Reserve as shown in Figure 9.1. The area is

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not registered for open access under the Countryside and Rights of Way Act 2000, as it is not mountain, moorland, downland or registered common land.

9.4.23 A dismantled railway line bisects the area on a north/south axis to the east between the airport and the coast taking a sweeping curve north-westwards round the southern end of the runway. The surviving section of the New Romney branch line serves the Dungeness Nuclear power station. Sections of the railway line act as access points to the fields to the north and east of the airport runway. The northern section to the north of the runway is not a public right of way but the most southerly section forms part of a footpath network crossing the foreland from Lade.

Commercial and Industrial

9.4.24 There is little visible industry in the area other than the Dungeness Nuclear Power Station located on Dungeness Foreland and some isolated pockets identified on the edge of Lydd.

9.4.25 The site lies on a series of shingle sand banks on which there are two mineral extraction facilities currently operational, one at Denge Quarry and the other at Scotney Court Quarry, as well as outstanding planning and exploration areas. Many of the former gravel pits have been used for the creation of open waterbodies some of which are included as part of the proposed Ramsar site. Site designations are discussed further in Chapters 10 Ecology and Nature Conservation and 11 Bird Conservation and Hazard Management.

9.4.26 The former Pioneer Aggregate Quarry known as Allen’s Bank in the vicinity of Whitehall Farm on the north east side of the B2075 and opposite the Golf Club is currently under remediation by Bromley Landfill Limited, Ashford. The lakes at TR 058 228 are currently being infilled with waste designated as “clean inert waste” under EU Category No. 170504. This is defined as soil and stones other than those mentioned in 170503 (where 170503 is soil and stones containing dangerous substances). The process is due to be completed in approximately 18 months time with all the water “drained” leaving only two small dew ponds. The resulting land use will be used only for grazing and will therefore be classified as Grade 5 under the ALC.

Conservation and Natural Resources

9.4.27 Potential impacts to designated sites of Ecological importance are addressed in Chapters 10 and 11. Potential impacts to designated sites of geological interest are addressed in Chapter 6: Ground Conditions. Potential impacts to water resources in the area are addressed in Chapter 7: Water Resources and Flood Risk. Ditches of historical interest are discussed in Chapter 13 Cultural Heritage and Historic Environment. Impacts on these land-uses are therefore not discussed further within this Chapter.

Military

9.4.28 The Lydd Ranges are present on the south eastern edge of Lydd, and include a mixture of training buildings, offices and storage facilities. A second MOD firing range is located some 15km to the north-east from LAA in Hythe (Hythe Firing Range). These two ranges are some of the UK’s oldest and have been used for nearly 200 years.

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9.5 Baseline Environment (Future Assessment Conditions Scenario)

9.5.1 Under the “Future Assessment Conditions” scenario, the airport will continue to grow to up to 300,000 passengers per annum, The land use baseline is the same as that described in the ‘existing conditions’ scenario above.

9.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

9.6.1 Construction of the runway extension will result in land-take of approximately 12,356m2 for the runway extension and 5,583m2 for the starter extension. The volume of spoil to be removed will be approximately 19,142m3 and the impacts on soil and the underlying geomorphology are assessed in Chapter 6 Ground Conditions.

9.6.2 The agricultural land classification of the affected land is rated as 3-4 - Moderate to Poor as shown on Figure 9.2 and is not the category of best or most versatile agricultural land and therefore on a national/regional level the effect would be negligible.

9.6.3 A temporary construction compound will be located on the existing hardstanding of the bravo apron and upon completion this area will revert back to its original use. Access for the main construction works will be via the existing airport access road and then along a temporary access road to the northern end of the runway. HGVs during construction will access the northern end of the runway via a fenced off roadway placed around the edge of the Bravo apron. The vehicles will use the parallel taxiway and then travel along a temporary access road. The road will consist of crushed stone laid on a geotextile membrane and will be removed after use.

Ditches

9.6.4 The runway extension will truncate the existing drainage pattern and impact upon the major water courses of Dengemarsh, Mockmill and Paine Field Sewers and some minor ditches will also be affected. Affected ditches will be blocked and re-routed around the extension in such a manner as to maintain and enhance their ecological integrity as discussed in Chapter 10 Ecology and Nature Conservation.

9.6.5 Whilst the main sewers form part of the historic drainage pattern of the marshes (see Chapter 13), and are an important component of the local water management system (see Chapter 7), given that the length of the old drains to be abandoned is 1,013m and the length of new drain to be constructed is 1,256m, the overall change in drainage capacity (and its location) is not expected to have a significant impact on landuse.

Future Assessment Scenario

9.6.6 Predicted impacts arising from construction of the runway extension under this scenario are expected to be the same as described under the ‘existing conditions scenario’ above.

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9.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

9.7.1 Areas of agricultural land around the airport create a buffer zone from development and direct operational impacts arising as a result of increased passenger, aircraft and road traffic activity will be primarily limited to impacts on areas used for recreational, conservation or agricultural purposes, although some residential areas may also experience changes in local ambience. Such impacts are discussed elsewhere in this document, primarily Chapters 12 Landscape and Visual Amenity, 15 Air Quality and 16 Noise and Vibration.

9.7.2 The proposed operation of the runway may also have an indirect impact on land management practices in the area, especially through the development of agreements with local farming and conservation practices to control the risk of birdstrike. This is discussed further in Chapter 11 Bird Conservation and Hazard Management.

9.7.3 Additional car-parking for 300,000 passengers will be located on existing hardstanding within the airport boundary (see Figure 4.4) and no impact on external landuse is, therefore, envisaged.

Future Assessment Conditions Scenario

9.7.4 Predicted impacts under this scenario are expected to be the same as described under the ‘existing conditions scenario’ above.

9.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

9.8.1 Mitigation of the impacts from construction of the proposed runway extension will be primarily through the development of a Construction Environmental Management Plan (as outlined elsewhere in this ES). This will include access to farm land in the surrounding area of the airport maintained so that no restrictions occur.

9.8.2 Any clean soil excavated during the construction works will be stored onsite on hardstanding and covered with high density polythene for subsequent re-use. Any potentially contaminated material will be either remediated onsite and kept separate from clean material or transported to an appropriate disposal facility, as described in Chapter 6 Ground Conditions. Mitigation will be provided for impacts on local geomorphology as described in Chapter 6 Ground Conditions.

Future Assessment Scenario

9.8.3 Proposed mitigation for construction impacts under this scenario is as described under the ‘existing conditions scenario’ above.

9.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

9.9.1 The airport will work closely with local landowners and in consultation with the Local Authorities to develop a strategy to modify existing land use practices to encourage

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activities which will not interfere with the planned airport operations, as described further in Chapter 11 Bird Conservation and Hazard Management.

9.9.2 No further mitigation for operational impacts is proposed at this stage.

Future Assessment Scenario

9.9.3 Proposed mitigation for operational impacts under this scenario is as described under the ‘existing conditions scenario’ above.

9.10 Residual Effects

Existing Conditions Scenario

9.10.1 The proposed runway extension will result in the permanent loss of Grade 3 and 4 land. The scale of impact is considered minor due to the availability of better quality agricultural land in the surrounding area.

9.10.2 Residual effects on surrounding land-uses (over and above those discussed in the other Chapters of this ES) are expected to be limited to impacts on local land-use management practices, as described in 9.10.1 above. Any such change in the surrounding land-uses will be developed in consultation with landowners, Local Authorities and other concerned parties and overall impacts are expected to be minor.

9.10.3 Amenity impacts on other users (e.g. recreational users) are discussed elsewhere in this ES.

Future Assessment Conditions Scenario

9.10.4 Residual impacts are expected to be as described for the ‘existing conditions scenario’ above.

9.11 Summary

9.11.1 Whilst LAA is located in an area with a number of internationally important geological, ecological and landscape designations (See Chapters 6 Ground Conditions, 10 Ecology and Nature Conservation and 12 Landscape and Visual Amenity), the proposed runway extension will be built on Grade 3 and 4 agricultural land and the impact is considered minor due to better quality land in the surrounding area being present.

9.11.2 Impacts of increased passenger numbers will result in an indirect impact on farming practices and recreational users in the surrounding area as a result of proposed bird hazard control measures, the impacts of which are addressed in Chapter 11 Bird Conservation and Hazard Management.

9.11.3 Overall, the impacts of the proposed runway extension will be the same (by comparison) for both the Existing Conditions and Future Assessment Conditions scenarios.

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CHAPTER 10

ECOLOGY AND NATURE CONSERVATION

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10 ECOLOGY AND NATURE CONSERVATION

10.1 Introduction

10.1.1 This Chapter describes the existing ecological and conservation value of the airport and its surrounding areas, and assesses the magnitude, significance and probability of any ecological impacts that could arise as a result of the proposed runway extension. The Chapter focuses on impacts to flora and non-avian fauna – impacts on, or derived from, interactions with birds are addressed in Chapter 11 Bird Hazard and Nature Conservation.

10.1.2 The Dungeness area in general is known to support a range of habitats and species of nature conservation importance and particular care has therefore been taken throughout the design and development of the proposed scheme to minimise potentially adverse impacts wherever possible using the hierarchy of impact avoidance as the preferred solution followed progressively by impact mitigation and impact compensation.

10.1.3 Additionally, the approach taken to evaluating the ecological conditions of the area has included both desk studies and detailed field investigations, the latter having been developed following consultation with a range of key stakeholders including Natural England and the RSPB. Further details on these are provided in Section 10.3.

10.1.4 The scenarios modelled in this chapter are as described in Chapter 1.

10.2 Legislation Drivers

10.2.1 Whilst Chapter 5 (Planning Policy Framework) discusses the local planning background against which the proposed development will be considered, including relevant nature conservation plans and policies, the following legislation, policy and guidance documents have been used to underpin the ecological impact assessment reported in this Chapter:

• Habitats and Species Directive (92/43/EEC) 1992;

• (Wild) Birds Directive (79/409/EEC) 1979;

• Ramsar Convention on Wetlands of International Importance, 1971;

• Bern Convention (on the Conservation of European Wildlife & Natural Habitats; and on the Conservation of Migratory Species of Wild Animals) 1979;

• Conservation (Natural Habitats and c.) Regulations 1994;

• Wildlife and Countryside Act 1981 (and subsequent amendments);

• Countryside and Rights of Way Act 2000;

• Protection of Badgers Act 1992;

• National Parks and Access to the Countryside Act 1949;

• The UK Biodiversity Action Plan (UKBAP) 1994;

• Kent Biodiversity Action Plan (Kent BAP) 1997;

• Planning Policy Statement 9: Biodiversity and Geological Conservation;

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• Kent & Medway Structure Adopted Plan 2006; and

• Shepway District Local Adopted Plan 2006.

10.3 Assessment Methodology

General Approach

10.3.1 An initial desk-based ecological appraisal of the site was undertaken by RPS Consultants in 2002 1. Since then, further information on the ecological resources of the area has since been collected on a year-on-year basis through a combination of field survey and consultation and the results of these studies are included within this ES. The baseline conditions used for this impact assessment represent an assimilation of all information collected to date.

Study Area

10.3.2 Given the diversity of daily or seasonal movements demonstrated by different types of ecological receptors, a number of different study areas have been used for this assessment to ensure that the range of potential impacts that could arise from the proposed runway extension have been assessed in a comprehensive and robust manner. These study areas are shown in Table 10.1 below and Figures 10.2 – 10.6. Further details on the studies themselves are summarised within the remainder of this section, and included in full within the Ecology Appendices.

Table 10.1 Study Areas Used for this Assessment Study Area Surveys undertaken Survey Lead Dates Surveyor Within 5km of the Review of existing data on designated sites 2004-05 PB site boundary Review of existing data on bats and bird feeding 2004-05 PB areas and roosts Within 2km of the Review of existing data held by KBRC and others 2004-05 PB site boundary on badgers, great crested newts, otters and other protected species Watercourse Survey July 2005 J Ball General surveys of breeding and overwintering 2004-2005 P James birds (see Chapter 11) 2005-2006 Within 500m of CBC Surveys of breeding birds (see Chapter 11) 2004-2005 P James the airport boundary. 2005-2006 Extended Phase 1 Habitat Survey June 2005 I Tanner Within the airport Botanical Surveys for Higher and Lower Plants June - Aug J Pitt boundary 2005 Protected Species Survey ( Define) July 2005 I Tanner Invertebrate Survey July - Sep A Godfrey 2005 Amphibian Survey May - June HRA 2004

1 RPS (2002) Ecology Designations at Dungeness: Background Information. RPS (2003) Preliminary Assessment of the Effects of the Proposed Expansion of Lydd Airport on Sites of European Nature Conservation Importance. December 2006 Page 145 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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Study Area Surveys undertaken Survey Lead Dates Surveyor Within the Great crested newt surveys – watercourses and April - May PB application terrestrial habitats 2006 boundary Fish – presence/absence April/May PB 2006 Aquatic Mammal Surveys June - Aug PB 2005 Feb - April 2006

Desk Study and Consultation

10.3.3 Existing ecological data relating to the site and its surroundings was obtained through consultations with the following organisations:

• East Kent Badger Group;

• Natural England;(formerly known as English Nature);

• Environment Agency (EA);

• Kent and Medway Biological Records Centre (KMBRC);

• Kent Bat Group;

• Kent County Council (KCC);

• Kent Mammal Group;

• Kent Reptile and Amphibian Group;

• Kent Wildlife Trust (KWT);

• Romney Marsh Countryside Project; and

• Royal Society for the Protection of Birds (RSPB).

Field Surveys

Extended Phase 1 Habitat Assessment

10.3.4 An extended Phase 1 Habitat Survey was undertaken in June 2005 of land within the airport boundary and readily accessible within the surrounding area. The work was carried out in accordance with standard Joint Nature Conservation Committee (JNCC) Phase 1 survey methodology 2 and was complimented by analysis of aerial photographs of the site to produce a detailed habitat map (Figure 10.2) and associated Target Notes (refer to Figure 10.3).

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Higher and Lower Plant Surveys

10.3.5 Areas identified during the Extended Phase 1 Survey as being of potentially greater ecological interest were then targeted for more detailed botanical surveys undertaken in June, July and August 2005 3. These included the:

• ditches located to the south-east of the runway which provide potential habitat for uncommon species such as divided sedge, yellow vetch and marsh mallow;

• vegetated shingle to the south and east of the runway which could support interesting ecological assemblages including Cladonia lichens; and

• open ponds across the eastern part of the site. 10.3.6 In addition, more detailed surveys were undertaken in the Summer 2005 of habitats within a 200m radius of the main pond (“Pond A”) and along a transect line through the eastern part of the site to record both the higher plant species and the diversity of lichen communities present, as well as the presence of any bryophytes 4. The main pond is located approximately 60m to the east of the main runway – See Target Notes TN29-32 on Figure 10.3.

Watercourse Surveys

10.3.7 Drainage ditches on and around the airport were surveyed during August 2005 for both ecological and hydrological importance5. Further surveys were undertaken in February-April 2006 6 7, which focussed particularly on the ditches to the north and east of the site. Specific surveys were undertaken for water vole, water shrew and great crested newts (following standard methodologies as discussed below) and the drains to the north were also subject to netting to assess the presence or absence of fish. Observations were also made of any other species present, including invertebrates such as medicinal leech (see below).

Invertebrate Surveys

10.3.8 A series of terrestrial and aquatic invertebrate surveys were undertaken between May and September 20058. Survey methodologies included pond sampling, malaise trapping, sweep netting, pitfall traps, water traps, direct searching and moth trapping. A specific survey for medicinal leech was undertaken in the main pond under Natural England licence.

10.3.9 During surveys of drains to the north of the runway in April 2006, opportunistic surveys for invertebrates were also undertaken.

Reptile Surveys

10.3.10 Reptile surveys were undertaken in July 2005 9, following standard survey methodologies such as those detailed by Natural England, Froglife, and Herptofauna Groups of Britain and Ireland (HGBI) 10 11 12(including refuge searches and direct

3 Pitts, J. (2005) Botanical Survey Report and Report on the Lichens of the Main Study Area, Lydd Airport. 4 Pitts, J. (2005) Botanical Survey Report and Report on the Lichens of the Main Study Area, Lydd Airport. 5 Ball, J (2005) Watercourse Survey at Lydd Airport, Kent. 6 Addendum to John Ball’s Report February 2006. 7 Summary of KF/SR/JRW April Surveys of drains to the north of the runway. 8 Godfrey, A (20050 Invertebrate survey of Lydd Airport, Kent. 9 Ecoline (2005) Protected species survey report, LAA Lydd Airport Expansion Programme. 10 English Nature (1998) Species Conservation Handbook (Herps). December 2006 Page 147 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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observation), to determine the reptile species presence/absence on the site.

10.3.11 The refuge search methodology entailed the creation of artificial reptile refugia from pieces of corrugated tin (1 x 0.5 metre), placed in sheltered but open areas, especially on south-facing slopes to provide ideal basking spots and refugia for reptiles. These refuges were checked periodically, during suitable conditions, for basking reptiles.

10.3.12 It is acknowledged that July is not the optimum time for reptile surveys, and whilst a number of individuals from several species were recorded on the site, these may not fully represent the total numbers of species and individuals present on the site. As a result a precautionary approach has been taken to assessing the severity of any impacts to this group, and the proposed mitigation has been developed accordingly.

Amphibian Surveys

10.3.13 The Dungeness area is known to support an extensive meta-population of great crested newts and Natural England have undertaken detailed monitoring of a number of waterbodies near the proposed project since 1994 13.

10.3.14 To supplement these data, waterbodies within the footprint of the development were assessed for their potential to support amphibians, and the following monitoring surveys were conducted by licensed surveyors to establish the presence or absence of key species, particularly great crested newts (Appendix 10.2):

• 2004: survey of 15 ponds and waterbodies within the airport boundary (15) between May and June14 using a combination of visual observations, bottle- trapping, egg-searching and torch-surveying 15 16 17;

• 2005: Incidental observations and opportunistic torch surveys in July18; and

• 2006: detailed surveys of ditches to the north of the runway between early March and late May based on a combination of egg-searching, netting and torch- surveying. Bottle-trapping was not undertaken in this instance following the confirmation of water shrew as being present in the drainage ditches. 10.3.15 It should be noted that the first of the 2004 great crested newt surveys were undertaken in May of that year, before it was realised that the site’s particular climatic conditions mean that newt activity at this site can start as early as the end of January and peak in the ponds in mid to late March (although not in 2006). Lower numbers of newts and the lack of eggs or juveniles in some ponds may reflect this, and indeed in that year some of the ephemeral ponds were known to have dried up prior to completion of the final survey. Further surveys have provided additional data regarding the abundance of this species, and a precautionary approach has been taken to assessing the severity of any impacts to this group, and mitigation delivered accordingly.

11 Froglife (1999) Reptile survey: An Introduction to Planning, Conducting and Interpreting Surveys for Snake and Lizard Conservation (Froglife Advice Note 10). 12 Herpetofauna Groups of Britain and Ireland: Advisory Notes for Amphibian and Reptile Groups. 13 English Nature Great Crested Newt Survey Data for the Dungeness Area. 14 As these surveys were undertaken rather late in the year for great crested newt in the Dungeness Area the results were primarily used to look for presence, rather than demonstrate absence. 15 English Nature (1998) Species Conservation Handbook (Herps). 16 English Nature (2001) Great Crested Newt Mitigation Guidelines. 17 Froglife (2001) Great Crested Newt Conservation Handbook 18 Ibid. December 2006 Page 148 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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Fish surveys

10.3.16 Whilst none of the waterbodies near the airport are considered to be of particular conservation value for the fish populations they support, opportunistic fish netting surveys of the four main drains around the site were undertaken as part of the ditch surveys.

Aquatic Mammal Surveys

10.3.17 Mammal surveys for water vole, water shrew and otter were undertaken in July and August 2005 across the existing airport site, with particular attention paid to the main pond 19 20 and these were supplemented by further detailed surveys of the ditches to the north and east of the runway undertaken in April 2006. In addition to direct observation of individual animals, searches were undertaken along banks and in patches of marginal aquatic vegetation for field signs, including burrow entrances, latrines, tracks and feeding remains (water voles) and characteristic places of rest, droppings, scent marks, tracks, trails and feeding remains (otters).

10.3.18 Surveys were undertaken following best practice guidance, as detailed by Natural England, EA, JNCC and relevant documents such as the Water Vole Conservation Handbook21. Species-specific approaches included the following:

• Water voles: Sherman traps were placed along the ditches in 2005 and 2006; and

• Water shrews: Baited tubes were placed in suitable bankside vegetation and checked for characteristic droppings 20. Eight tubes were put out near the main pond in 2005, and a further sixty tubes were put out around the ditches to the north of the existing runway in April 2006) 20 (see survey location maps in Appendix 10.2). 10.3.19 Whilst the use of overnight traps for water voles in 2006 did not allow the voles to become accustomed to the presence of the traps, the use of other complimentary methods to detect the presence of this species (i.e. burrows, runs, feeding remains and latrines) means that the overall presence / absence data generated is considered robust.

10.3.20 In addition to the above, a general assessment of the suitability of local habitats for aquatic mammals was made including considerations of the diversity and abundance of foraging resources; availability of suitable burrow or holt sites throughout the year, availability of refuges from predators and the presence / absence of different predators, particularly mink 20.

Other Mammal Surveys

22 10.3.21 A badger survey was undertaken in June 2005 , to search for signs of activity including setts, latrines, snuffle holes, tracks and hairs. Further searches were made to the north of the runway in April 2006.

Bat surveys across the site were undertaken in July and August 200523 using a Bat Box III detector and (where relevant) a high-powered torch. These included both a

19 English Nature (1998) Species Conservation Handbook (Herps). 20 Parson Brinckerhoff Ltd. (2005) Lydd Pond A: Aquatic Mammal Survey. 21 Strachan, R (1998) Water Vole Conservation Handbook. English Nature. Environment Agency and WildCru. 22 Tanner, I. (2005) Phase 1 Habitat Survey of Lydd Airport Site 23 Ecoline (2005) Protected species survey report, LAA Lydd Airport Expansion Programme. December 2006 Page 149 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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bat foraging/activity survey (which focussed on the key potential areas of willow scrub, trees, and the ditch networks) and a detailed visual inspection and two emergence surveys of the terminal building. The bat activity survey was limited to specific locations at specific times and should be considered to be limited to a presence / absence survey.

Study Limitations

10.3.22 In addition to the specific limitations outlined above, it should be noted that whilst every effort has been made to undertake the ecological surveys at the appropriate time of year (appropriately qualified experts have been used in all cases), seasonal trends and inherent variations in ecosystem dynamics mean that some species of flora and fauna may not have been recorded. In addition the following specific points relating to the surveys should be noted, and have been taken into account during the impact assessment. There is also little guidance on methods for assessing the effect of climate change on the distribution of species and habitats, but these have been considered where possible in this assessment.

10.3.23 Whilst there is little guidance on methods for assessing the effect of climate change on the distribution of species and habitats, these have been considered where possible in this assessment.

Assessment Criteria

10.3.24 The ecological assessment has been carried out using a three-step process, based on the Institute of Ecology and Environmental Management’s (IEEM) draft Guidelines for Ecological Impact Assessment (2005)24, of measuring receptor importance/sensitivity, impact magnitude and residual impact significance. Impacts have also been considered in terms of the objectives and targets set out in UKBAP 25 and Kent BAP 26.

10.3.25 The first step in the impact assessment process has been to classify the importance and/or sensitivity of the various ecological receptors using the approach set out in Table 10.2.

Table 10.2 Importance/Sensitivity of the Receptor Receptor Examples Importance/ Sensitivity International An internationally designated site or candidate site (SPA, pSPA, SAC, = ‘Very high’ cSAC, pSAC, Ramsar site, Biogenetic Reserve). A viable area of a habitat type listed in Annex I of the Habitats Directive, or smaller areas of such habitat which are essential to maintain the viability of a larger whole. Any regularly occurring population of an internationally important species, that is threatened or rare in the UK (i.e. it is listed as occurring in 15 or fewer 10km squares in the UK). A regularly occurring, nationally significant population of any internationally important species. National = A nationally designated site (SSSI, NNR, Marine Nature Reserve, etc.), or a ‘High’ discrete area which the country conservation agency has determined meets

24 Institute of Ecology and Environmental Management (IEEM) (2005) Draft Guidelines for Ecological Impact Assessment. 25 UK Biodiversity Action Plan http://www.ukbap.org.uk/default/aspx 26 Biodiversity Action for Kent’s Wildlife http://www.kentbap.org.uk December 2006 Page 150 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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Receptor Examples Importance/ Sensitivity the published selection criteria for national designation (e.g. SSSI selection guidelines) irrespective of whether or not it has yet been notified. A viable area of a priority habitat identified in the UKBAP, or smaller areas of such habitat which are essential to maintain the viability of a larger whole (this could include networks of ancient and/or species-rich hedges or even small groups of ancient trees). Any regularly occurring population of a nationally important species (for example, identified as a priority species in the UKBAP, or a species of principal importance for biodiversity under Section 74 of the CRoW Act (2000) that is threatened or rare in the region or county. County/ County/Unitary Authority designated sites and other sites that the Unitary designating authority has determined meet the published ecological Authority = selection criteria for designation (including SINCs, Local Nature Reserves ‘Medium’ and Wildlife Trust sites). Semi-natural woodland greater than 0.5 ha which is considered to be in ‘good condition’. A viable area of habitat identified as a priority in the County/ Unitary Authority BAP. A regularly occurring, locally significant population of a species identified as important on a regional or County/Unitary Authority basis (but not identified as priority species in the UKBAP). Any regularly occurring population of a nationally important species (UKBAP, Section 74, Red Data Book, etc.) that is not threatened or rare in the region. Local = Semi-natural woodland greater than 0.25 ha. ‘Low’ Areas of habitat or populations/communities of species considered to appreciably enrich the habitat resource within the context of the parish or neighbourhood, e.g. species-rich hedgerows, ponds, etc. A regularly occurring, locally significant population of a County/Unitary Authority important species during a critical phase of its life cycle. Negligible No site designation; species and habitats that are common and widespread and of very limited nature conservation value.

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10.3.26 Impact magnitude has then been assessed for the airport site a four-point scale as detailed in Table 10.3.

Table 10.3 Magnitude of Change (Impact) Large • Loss of over 50% of a site, feature, habitat or population. • Adverse change to all of a site, feature, habitat or population. • For beneficial effects, an impact equivalent in nature conservation terms to a gain of >50% of a site, feature, habitat or population. Medium • Loss affecting 20-50% of a site, feature, habitat or population. • Adverse change to over 50% of a site, feature, habitat or population. • For beneficial effects, an impact equivalent in nature conservation terms to a gain of 20-50% of a site, feature, habitat or population. Small • Loss affecting 5-19% of a site area, feature, habitat or population. • Adverse change to 20-50% of a site, feature, habitat or population. • For beneficial effects, an impact equivalent in nature conservation terms to a gain of 5-19% of a site, feature, habitat or population. Negligible • Loss affecting up to 5% of a site area, feature, habitat or population. • Adverse change to less than 20% of a site, feature, habitat or population. • For beneficial effects an impact equivalent in nature conservation terms to a gain of up to 5% of a site, feature, habitat or population.

10.3.27 Impact magnitude is based on assuming that best site practice is followed during construction. Consideration of the magnitude of impact does not take account of any recommendations for specific mitigation, compensation or avoidance measures that might subsequently be described.

10.3.28 The relationship between impact magnitude and the importance or sensitivity of the receptor is then used to derive a measure of impact significance as shown on Table 10.4 and applied in Table 10.5.

Table 10.4 Significance of Impact Magnitude of Impact Sensitivity Large Medium Small Negligible Very high (International) Substantial Substantial Moderate Negligible High (National) Substantial Moderate Moderate Negligible Medium (County/unitary Moderate Moderate Slight Negligible authority) Low (Local) Moderate Slight Slight Negligible Negligible Slight Negligible Negligible Negligible

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10.3.29 Mitigation, avoidance or compensation measures have been developed wherever an adverse significant impact has been identified, with priority given to the mitigation of impacts on protected species or habitats. Any residual effects that cannot be mitigated, avoided or compensated for have subsequently been identified. Potential enhancement of wildlife habitats has also been considered where appropriate.

10.3.30 It should be noted that a separate “Statement to Inform” is also being produced to specifically assist the competent authorities to determine whether there will be an adverse effect on the integrity of the SAC or SPA.

10.4 Baseline Environment (Existing Conditions Scenario)

Overview

10.4.1 As described in Chapter 1, LAA is situated within the Romney Marshes, some 2km to the east of the town of Lydd, and 2km to the west of Greatstone-on-Sea in the Shepway District of Kent. The Romney Marshes are an area of reclaimed open marshland, bounded to the south and east by the English Channel, and to the north and west by old sea cliffs.

10.4.2 The Dungeness Peninsular, located at the southerly tip of the Romney Marshes, is the largest shingle foreland in Europe and much of the area is notified, designated or proposed for designation under a range of national and international nature conservation legislation. This includes areas designated as National Nature Reserve (NNR), Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC), and Special Protection Area (SPA) as well as a proposed Ramsar site. Further details on each of the designated sites are provided below.

10.4.3 The SSSI includes almost the whole of the Dungeness Peninsular to the south east of the airport and Denge Marsh (excluding active gravel workings, residential areas and the power stations) and the SAC covers a similar area, with the additional exclusion of the lakes in the flooded former gravel pits. The SPA comprises those lakes, the natural wetland in the Open Pits area and areas of immediately adjacent land. The site boundaries for these areas are shown in Figure 10.1.

10.4.4 Natural England are currently reviewing the SSSI and SPA boundaries, as well as those of the proposed Ramsar site (see the Natural England Leaflet – The Romney Marshes and Rye Bay: A Review of the area’s nature conservation designations 27) and as it is proposed that the SPA and SSSI sites will be extended in the near future to reflect changes in local bird populations, both existing and proposed ecological designations have been taken into account in the impact assessment sections.

10.4.5 The NNR comprises the RSPB reserve, part of the beach on the eastern side of Dungeness owned by Shepway District Council, and parcels of other land at the south east tip of Dungeness, and to the rear of residential properties at Greatstone- on-Sea, Lade and Lydd-on-Sea.

10.4.6 Natural England’s Natural Area profile for Romney Marsh describes the international nature conservation importance of the Dungeness shingle. The area hosts a complex pattern of vegetation, most notably the prostrate broom and blackthorn scrub, holly wood and distinctive forms of lichen-rich acidic heath. As well as these dry plant communities, the wetlands of the Open Pits and natural shingle hollows contain fen, swamp and wet scrub vegetation. Saltmarsh is also present in the pits close to the

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southern shore, saltmarsh. The area is considered botanically rich and supports an abundance of invertebrates, including several rare and scare species, as well as a sizeable population of great crested newts.

10.4.7 Certain species present in the area are afforded particular protection under the Wildlife and Countryside Act 1981 (as amended); including the following:

• Sussex emerald moth, associated with shingle vegetation;

• Great crested newt, found in the wetland areas;

• Lizard orchid, found on local sand dunes;

• Medicinal leech which occurs in grazing marshes, ponds, gravel pits and margins; and

• Water voles. 10.4.8 All wild birds are also protected, as are several mammal species. Further information on protected species is included later in this Chapter. Details of the legislative protection and planning policy relating to these species are included in Appendix 10.1.

10.4.9 Although much of the coastal and flood plain grazing marshes is now arable land, substantial blocks of pasture remain and the brackish influence means that many saltmarsh plants are still present here. The aquatic and bankside flora of the drains and sewers (the local name for the larger channels) and the associated invertebrate fauna are very rich. The area is also important for birds, both in the breeding season and in winter, although large parts are now more heavily grazed and drier than is ideal.

10.4.10 Important features and species present on the grazing marshes include the following:

• breeding waterfowl (notably redshank and lapwing.);

• wintering waterfowl (including Bewick’s swan, lapwing and golden plover, and birds of prey such as hen harrier);

• rare and scarce plants including saltmarsh goosefoot, slender hare’s-ear, divided sedge and Borrer’s saltmarsh grass;

• diverse aquatic and bankside plant communities including scarce species (short- leaved pondweed, marsh mallow, greater water-parsnip and rootless duckweed); and

• many rare and scarce invertebrates (including medicinal leech, marsh mallow moth, great silver diving beetle, hairy dragonfly and Sussex emerald moth). Internationally Designated Sites28

10.4.11 There are two internationally designated areas of nature conservation importance located within and in the vicinity of LAA, namely:

• The Dungeness SAC, located immediately east of the existing runway; and

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• The Dungeness to Pett Level SPA, located approximately 750m east and 500m south of the existing runway and which may be extended in the near future to reflect recent changes in local bird populations.

10.4.12 In addition, several areas in the vicinity of the site are currently considered to constitute a possible wetland of international importance under the Ramsar Convention, to be termed the ‘Dungeness to Pett Level potential Ramsar site’ should the designation be approved. 10.4.13 The locations of these designated sites are shown in Figures 10.1. The site citations are included within Appendix 10.3.

Nationally Designated Sites

10.4.14 In addition to the above, six sites of national importance are located near the airport site, namely:

• Dungeness SSSI, located immediately east of the existing runway;

• North Lade SSSI, located immediately adjacent to the north west boundary of the airport and area of land within 500m to the east of the existing terminal building;

• Walland Marsh SSSI, located approximately 7km to the south west of the airport boundary;

• Cheyne Court SSSI, located approximately 7km to the west of the airport boundary;

• Romney Warren SSSI, located approximately 4.5km to the north east of the airport; and

• Dungeness RSPB Nature Reserve and Important Bird Area, located immediately adjacent to the south eastern airport boundary. 10.4.15 Natural England are proposing re-designations of the SSSIs to reflect the whole nature of the Dungeness geomorphological system and the habitats and species it supports. The proposals have been subject to consultation since July 2006.

10.4.16 The airport lies with Natural England’s Romney Marsh Natural Area, a non-statutory designation reflecting the area’s characteristic association of wildlife and natural features, defined as a biogeographic zone within a nationwide context.

10.4.17 The locations of these sites are shown in Figure 10.1. A summary of the site designations is included within Appendix 10.3.

Locally Designated Sites

10.4.18 There are two locally designated sites in the vicinity of the airport site:

• Tourney Road, Roadside Nature Reserve (RNR), located approximately 2km to the south west of the airport boundary; and

• Lydd Common and Pastures Site of Nature Conservation Interest (SNCI), located approximately 800m to the west of the airport boundary. 10.4.19 The locations of these designated sites are shown in Figure 10.1. A summary of the site designations is included within Appendix 10.3. December 2006 Page 155 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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Higher Plants

10.4.20 Whilst much of the land directly outside of the airport boundary to the west, north and north-east (including the golf course) supports highly modified agricultural land or amenity grassland, within (and to the east and south of) the boundary a more diverse and ecologically valuable range of habitats are present (see Appendix 10.2A and associated target notes).

10.4.21 The managed semi-improved grassland adjacent to the airport runway, taxiway and the temporary surfacing (gravel) adjacent to the Bravo Apron are limited in their diversity and many of the adjacent vegetated shingle areas are dominated by primary successional scrubs of scotch broom, common gorse and bramble, with elder scrub where the coarser shingle has allowed soils to collect. Areas of barer shingle in the south east, however, support rarer species and the older shingle ridges support calcifugous grasslands, with sheep’s fescue, common bent and sheep’s sorrel, whilst pockets of red fescue and sea thrift are found on the more distant historic cliffs.

10.4.22 A series of pools, fens and sallow carrs (known as the Open Pits) with marshy areas and ditches are present within the shingle beach system to the east of the airport boundary and support scarce species such as marsh fern, marsh cinquefoil, great fen-sedge and common cottongrass. A drainage ditch system is also present within and around the airport perimeter.

10.4.23 During the field surveys twelve notable higher plant species were recorded within the survey area (and mainly to the east of the runway) including brown sedge, divided sedge, common sedge, sea mouse ear, common dodder, early marsh orchid, southern marsh orchid, Oenanthe lachenalii, creeping willow, shepherds cress, marsh speedwell, and spring vetch. Details of the status of these species are provided in Appendix 10.4.

10.4.24 There are a series of open ponds to the east of the runway. Of these the main pond is shallow with very gently sloping margins and pebble and gravel banks which extend above the waterline. The water appeared to be of good quality and clarity. Marginal and emergent vegetation includes bulrush, purple loosestrife, common water- plantain, club-rush species, water mint, water dock and sallow. Organic mud covered 70% of the submerged pebble and gravel substrate. The pond water levels were noted to have reduced significantly (to less that half its normal size) by September, becoming several shallow unconnected pools.

10.4.25 The managed ditch network across and around the site includes a variety of sizes and structures of watercourse which drain the surrounding land. Whilst some drain sections are ecologically richer than others all those surveyed are considered to have ecological interest. The ditches are subject to regular management by the Internal Drainage Board (IDB), which is undertaken yearly between July and October whereby all the vegetation is cut (leaving 8-10cm of growth) and the ditches dredged.

10.4.26 The main sewer (Dengemarsh Sewer) within the airport boundary is a natural stream or brook although heavily engineered by artificial deepening and possibly widening in places (6). Typical of a sewer structure it has a broadly trapezoidal cross section although in places it has a more natural profile created from weathering and erosion of the earth banks. The three large drains to the north of the existing runway are of similar form to the Dengemarsh Sewer. Other smaller ditches/sewers within the airport boundary, although original streams with natural winding courses, have been subject to engineering and some sewers are completely artificial. Typical dicotyledon herbs are present on the banksides of these ditches with dense reed in channel. When surveyed the majority of the larger channels were often completely choked by vegetation. Submerged channel vegetation was usually absent in the narrower reed-

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shaded sewers compared with the larger drains 29.

10.4.27 No invasive or injurious weeds such as Japanese knotweed, Himalayan balsam or giant hogweed were found within the site or adjacent areas.

Lower Plants

10.4.28 From historic records it is known that three main types of lower plants are present in and around the airport site, namely slime moulds, lichens and bryophytes. Of these, whilst three red list threatened species of slime moulds (Myxomycetes) have been recorded in the area, none were recorded during the surveys.

10.4.29 The Dungeness Peninsular is known to support an extremely important lichen flora and some 148 species have been recorded on all substrates, of which three are rare. A specific lichen survey undertaken for this study indicated that within the airport lichens are primarily restricted to areas of undisturbed shingle or bare areas within the vegetated shingle, although a limited and unremarkable flora was also present on well-lit sallow scrub branches in the vicinity of the ponds. Extremely little lichen interest was present elsewhere, including the disturbed shingle 30.

10.4.30 Nine species of lichen of special interest were however recorded in the areas surveyed 29 (as presented in Appendix 10.2B): Peltigera membranacea, Cladonia ciliata, Cladonia cervicornis, Cladonia crispate var cetrariformis, Cladonia subulata, Cladonia uncialis ssp biuncialis, Pseudoevernia furfuracea, Fuscidea cyathoides, and Lecanora conpallens. Details of their status and location are provided in Appendix 10.4.

10.4.31 One bryophyte species of note was recorded within the areas surveyed (5) (as presented in Appendix 10.2B): an aquatic moss Drepanocladus aduncus, found within the marshy and semi-aquatic areas to the south of the main pond, and which has a restricted (local) distribution in Kent.

Invertebrates

10.4.32 In addition to its flora, the Dungeness area is also renowned for its invertebrate fauna and the Dungeness to Petts Level SSSI has been widely surveyed. Species data for the area is included in Appendix 10.5, which includes a summary of notable and protected invertebrate species’ status and legislative protection

10.4.33 Single small juveniles of medicinal leech, a UK protected species, were encountered from two sample locations around the main pond during the surveys in July 2005 29 indicating that the species breeds here. Medicinal leeches were also found whilst netting for amphibians and fish in two ditches to the north of the runway.

10.4.34 A range of other aquatic invertebrates was also recorded from the main pond and whilst the overall species list was less diverse than expected, with numbers of some aquatic groups (such as molluscs and water beetles) especially poorly represented, the area is known to support several rare or uncommon invertebrate species. These include the small red-eyed damselfly (not previously recorded in Dungeness and a recent addition to the British list), three scarce Orthoptera, a Nationally Scarce soldierfly, a rare wasp that parasitizes soldierflies, a bee-wolf (formerly regarded as very rare but now considered widespread) and the UKBAP and Kent BAP Priority Species carder bee.

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10.4.35 A summary of notable and protected species’ status and legislative protection is included in Appendix 10.5.

Fish

10.4.36 Fish surveys in the area have been confined to some electrofishing within the RSPB reserve, to the south of the airport site. This recorded bream, eel, perch, pike, roach, rudd, stickleback (3-and 9-spined) and tench and such species are likely to be present within other waterbodies in the area.

10.4.37 Two stickleback were caught whilst netting in the drainage ditches to the north of the runway (the Mockmill and Paine Field Sewers) and it is likely that such fish are also present within the other main drain (Dengemarsh Sewer) and a ponded area of the ditch within two culverts linked to these slightly to the east.

Reptiles

10.4.38 Common lizards were recorded from 11 locations within the airport site 31 (locations provided in Appendix 10.2C) near ditches, permanent grassland and tree cover. This species appeared to be absent from the areas of open or lightly vegetated shingle.

10.4.39 Grass snakes were recorded from 3 locations across the site 30 (locations provided in Appendix 10.2C). Records included sightings of a sub-adult and an adult female grass snake, in grassland at the north of the site, and the discovery of a sub-adult slough in the south of the site. No grass snakes were sighted during surveys of the main pond. The results indicate that grass snakes appear to occur throughout the area, although at relatively low densities. This species is known to prefer rough grassland areas and is less likely to occur in short vegetation. It is likely that the species ranges along the ditch network but no sightings have been made during the many visits to the site and no snakes were located under the refuges placed along the banks of the drains to confirm this assumption.

10.4.40 Common lizard and grass snake are protected under UK legislation (as detailed in Appendix 10.5).

Amphibians

10.4.41 Three notable amphibian species have been recorded within the airport site, namely great crested newt, smooth newt and marsh frog 32 33. A summary of their status and legislative protection is included in Appendix 10.5.

10.4.42 Small numbers of great crested newts were recorded in waterbodies to the east of the runway in 2004 32 and a further 10 great crested newt adults were recorded within the main pond (pond number 4) with smaller numbers within waterbodies 8 and 11 in 2005. Smooth newt was also recorded from eight of the waterbodies. (The locations of these are shown in Figure 10.4).

10.4.43 Natural England’s survey results also record a breeding population of great crested newts in the main pond and they have also been found within ditches/waterbodies further north and east of the runway. Overall, it is considered that the main pond is likely to provide one of three key breeding habitats for great crested newts within the vicinity of the airport and it is likely that the newts will also use the terrestrial shingle

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habitat surrounding the pond.

10.4.44 Great crested newts may also be present within other areas of suitable standing water and associated terrestrial habitats within 500m of the main pond. Ponds within the golf course to the west of the site have been identified as having a high potential for great crested newts 34 and these waterbodies lie within 500m of the main pond.

10.4.45 The three ditches (including the Dengemarsh Sewer) located directly to the north of the runway are considered to represent poor great crested newt habitat however and no signs of the presence of this species were identified there during the surveys undertaken in July 2005 or 2006 (in fact fish were recorded in them in March 2006).

10.4.46 Drainage ditches to the west of the runway are also considered to represent poor great crested newt habitat however no surveys have been undertaken of these waterbodies to date.

Mammals

10.4.47 Substantial evidence of water vole activity was found in the ditches to the north of the runway 35 including burrows, latrines and feeding stations, and 3 water voles were seen entering the water along the Mockmill Sewer to the north-west of the existing runway (see Appendix 10.2D), although none were trapped.

10.4.48 Brown rat was also recorded along the three ditches to the north of runway, and to the south of the site and bank vole was recorded on several occasions in the south of the site. Although brown rat and bank vole populations are known to out-compete water voles, substantial evidence of both brown rat and water vole activity were noted along the same stretches of ditches to the north of the runway.

10.4.49 Evidence of water shrew (primarily characteristic droppings collected in the baited tubes) was recorded in the vicinity of the main pond and presence of this species was also recorded along two ditches to the north of the runway 34 (see Appendix 10.2D). Shrew droppings were also recorded along another ditch to the north of the runway but due to the lack of aquatic invertebrate evidence meant that it is unconfirmed as to whether they were water shrew.

10.4.50 Adult otter tracks were noted in the vicinity of the main pond (which is expected to provide relatively good foraging potential with prey including newts, frogs, grass snakes and waterfowl) and otters are likely to be present throughout the site although no sightings have been made to date.

10.4.51 Whilst a number of bat species have been recorded within the LAA area (see Figure 10.5), only very low levels of bat activity were recorded across the site, with common pipistrelle bats recorded on two separate occasions, once foraging along the ditches to the north of the runway and once on a flyby along the edge of the runway. No evidence of foraging was noted within areas of willow scrub or the trees on site. No evidence of roosting bats was found in any of the buildings on site and overall it is considered that the very flat, open landscape provides poor foraging conditions for bats with little shelter against adverse weather conditions. Indeed, during the surveys it was apparent that relatively light breezes were sufficient to displace flying invertebrates potentially reducing the likelihood of bats feeding in such areas.

10.4.52 Other mammals recorded during the 2005 surveys include a hare population that ranges across the site; wood mouse in the south of the site and pygmy shrew in the south-east quadrant of the site. Field signs of brown rat, mink, rabbit, mouse and fox

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were also noted in the vicinity of the main pond.

10.4.53 Surveys for badger across the site did not reveal the presence of any setts, latrines, paw prints, or hairs to indicate the presence of this species.

Birds

10.4.54 Results of the bird surveys undertaken for this ES are presented in Chapter 11 Bird Conservation and Hazard Management.

Assessment of Nature Conservation Importance

General Overview

10.4.55 An important feature of the study area is the wide range of different habitats that are present within the airport boundary, including vegetated shingle; bare shingle; semi- improved rough grassland; pools, swamps and marshy areas associated with dense scrub; and ditch / drainage system. These areas provide habitat for a large number of species, notably diverse assemblages of birds and invertebrates, amphibians, reptiles, and aquatic mammals.

10.4.56 A number of protected and notable species are known to be present on site. Great crested newt, medicinal leech, and otter, for example, are protected under the Wildlife & Countryside Act (1981, and amendments) (WCA) and under the EC Habitats Directive (as enacted in the UK under the Conservation (Natural Habitats &c.) Regulations, 1994) and are also listed as Priority Species in the UKBAP and Kent BAP.

10.4.57 Great crested newts breed in the main pond on site and are likely to hibernate and forage in suitable habitats within a radius of up to 500m from the pond (although the majority will be within 250m). The adjacent Dungeness SAC and SSSI are known to support populations of great crested newt.

10.4.58 Medicinal leech and otter are known to use the main pond and drainage ditches to the north of the runway; and are likely to use the network of ditches throughout the site. Common lizards and grass snakes are also protected under the WCA and are known to occur over much of the study area and this is likely to represent a locally important population of these species.

10.4.59 UKBAP Priority Species of invertebrate, the carder bee, was recorded during the invertebrate surveys, as well as three scarce Orthoptera, a RDB3 water beetle, a Nationally Scarce soldierfly, and a rare wasp. The site overall supports a very diverse invertebrate fauna and this is again likely to be due to the variety of habitats present.

Assessment of Nature Conservation Value

10.4.60 In order to undertake a meaningful assessment of nature conservation importance, the ecological resources of the airport site and the surrounding area have been classified into readily identifiable ecological units based on the results of the extensive survey work carried out over the last few years.

10.4.61 The most important of these ecological units is the area of unmodified shingle habitats, which lie within and adjacent to the airport site; the beaches; and the brackish and freshwater pools designated as Dungeness SSSI and SAC; and being considered as a potential Ramsar site. This ecological unit is therefore considered to December 2006 Page 160 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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be of ‘international’ importance.

10.4.62 The various ecological units and features are listed in Table 10.5 along with the importance / sensitivity category assigned to each one.

Table 10.5 Summary Assessment of Nature Conservation Importance Receptor Importance Sensitivity Dungeness SAC International Very high Dungeness to Pett Level SPA International Very high Dungeness SSSI National High Vegetated shingle National / County High / Medium Bare shingle County / Local Medium / Low Semi-improved rough grassland Negligible / Local Negligible / Low Pools, swamps and marshy areas County Medium associated with dense scrub Remaining areas of bare ground, hard Negligible Negligible standing, and buildings Invertebrates (particularly medicinal leech) International / Very high / High National Amphibians (particularly great crested International / Very high / High newts) National Bats International / Very high / High National Aquatic Mammals (particularly otter and International / Very high / High / water shrew) National / County Medium Reptiles County Medium

10.4.63 As shown in the table above, the airport site comprises several habitats and species of very high nature conservation importance: notably the SAC with vegetated shingle supporting a number of highly specialised plants, invertebrates (including medicinal leech) and great crested newts. Other protected species found on site include otter, water vole, water shrew, reptiles and bats. The surrounding areas also support a diversity of habitats and species, including other designated sites such as the Dungeness to Pett Level SPA: notable for its international bird interest.

10.4.64 Ongoing habitat management practices would include maintenance of the cut and graded area, management of the ditches to ensure their efficient operation and use of the main pond as the emergency fire water supply. Natural England is also implementing a programme of scrub clearance works within the eastern section of the airport site, which is being undertaken in an attempt to restore the site to a more natural coastal condition as it was back in the 1970’s. The IDB also undertakes regular clearing of the sewers around the airport, with vegetation cut on a twice yearly basis.

10.4.65 The lichen communities, bryophytes and higher plants of the local shingle communities are characteristic of nutrient-poor habitats and as such are considered sensitive to the effects of nitrogen enrichment Calculation of critical loads for habitats similar to those at Lydd have shown that annual deposition levels of more than 10-15 and 5-10 kg Nitrogen ha-1 year-1 for shingle banks and mosses respectively have the potential to adversely affect the sensitive ecosystems present (APIS data 2000) and specific air quality objectives have also been developed for sulphur dioxide and

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oxides of nitrogen (NOx) for the protection of vegetation and ecosystems36 37. For –3 38 NOx the objective is 15.7ppb or 30 μg NOx (as NO2) m annual mean for all vegetation types (25). Existing levels of nitrogen deposition in the Lydd area have been calculated at approximately 15.3kg Nitrogen ha-1 year-1 (APIS, 2000 data) and as such it appears that terrestrial nitrogen deposition levels may already exceed the critical load values for both shingle and moss habitats.

10.4.66 Nitrogen deposition can also lead to eutrophication of local freshwater systems resulting in increased growth of algae and phytoplankton at the expense of more notable macrophytic botanical communities. Aquatic fauna are also sensitive to changes in water quality, both as a result of potential acidification, increased turbidity and eutrophication, and care must be taken to avoid impacts to protected invertebrates (such as the medicinal leech) and/or fauna further up the food chain (such as otters).

10.5 Baseline Environment (Future Assessment Conditions Scenario)

10.5.1 To make a valid assessment of the potential ecological impacts of a proposed development, it is important to consider the ecosystem changes that could occur in its absence. For many projects, such changes would primarily be driven by natural ecological succession, but in this instance, they will arise from the ongoing management strategy of the operational airport including the growth of the airport to 300,000 passengers per annum under its current operating licence.

10.5.2 Additional air emissions associated with increased aircraft use and road traffic have the potential to add to the levels of nitrogen deposition (and associated changes to soil acidification and freshwater eutrophication), although modelling of potential emissions associated with the permitted 300,000 passenger scenario, indicate that the significance of any such change in air quality is predicted to be negligible (see Chapter 15 Air Quality). Similarly, impacts on the sensitive habitats and species present and the integrity of the Dungeness SAC and SSSI are also considered to be of no more than minor significance.

10.5.3 Increased activity and noise levels can lead to increased disturbance impacts to sensitive species both near the airport and in the vicinity of the associated transport corridors (air and land) – See Chapter 16 Noise and Vibration for further details. Any such disturbance impacts upon the Dungeness SAC and SSSI are expected to be minimal as they are designated primarily for their exceptional plant communities and great crested newt population and geomorphology respectively. However, the Dungeness to Pett Level SPA, which is designated for its ornithological interest, lies within 500m of the airport site and is more sensitive to such disturbance, especially as the Dungeness Road, which may experience an increase in local traffic, passes through the SPA to the south east of the airport. The potential impacts upon this site and the birds associated with the SPA are discussed further in Chapter 11 Bird Conservation and Hazard Management of this ES. Other nature conservation sites including the North Lade, Walland Marsh and Cheyne Court SSSIs are unlikely to be affected during operation of the proposed development and any effect on these sites is considered to be negligible. Effects of noise and vibration on non-avian fauna are poorly understood at both the individual and the population level, but whilst excessive noise levels are believed to result in physiological and/or behavioural effects, studies indicate that, in general, animals appear to habituate to prolonged exposure to noise, and as such no significant, long term impacts are expected to occur to terrestrial fauna in the area.

36 These are broadly equivalent to the critical levels set by United Nations Economic Commission for Europe (UNECE) and the World Health Organisation (WHO) 37 English Nature Scoping Opinion, letter to Shepway District Council dated October 4th 2005 38 This is more stringent than the human health standard for nitrogen dioxide over the same averaging period which is 40 μg –3 NO2 m . Defra Review of National Air Quality Strategy http://www.defra.gov.uk/environment/airquality/consult/naqs/ December 2006 Page 162 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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10.5.4 The aquatic communities associated with the Dungeness SAC and SSSI can be particularly sensitive to pollution, and elevated levels of ammonia, nitrogen deposition and phosphate deposition can accelerate freshwater acidification and eutrophication processes. Such impacts can in turn promote excessive plant growth and algal blooms (cyanobacteria), which can be toxic to fauna, especially if the dissolved oxygen content of the water is significantly reduced. Whilst nitrogen deposition from additional air emissions has the potential to promote this process, modelling of emissions associated with the 300,000 passenger scenario (as described above) indicated that such impacts are expected to be of no more than minor significance.

10.5.5 The increased numbers of aircraft, support vehicles/plant and road vehicles using the airport site as the airport grows under its currently permitted scenario could also see an increase the risk of accidental spillages of toxic chemicals such as fire fighting chemicals, detergents oil, fuel and other chemicals, but these will be controlled through the development of a site Environmental Management System, and mitigated impacts are expected to be of only minor significance.

10.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

10.6.1 A number of potential impacts have been identified that may arise from the proposed construction works, including direct habitat loss, the potential for contamination and siltation (primarily of watercourses) and disturbance effects and incidental mortality. Each of these is addressed further below.

Direct Habitat Loss

Designated Sites

10.6.2 Permanent habitat loss will arise through the construction of the new runway pavement and starter extension, the management of the clear and graded area and the realignment of the drainage ditches. Temporary habitat loss could arise from the construction and use of the haul road, the stockpiling of soils and the use of the construction compound.

10.6.3 Habitats that would be affected would be primarily semi-improved (rough) grassland (4.5 ha) and arable grassland (13.6 ha) as well as approximately 1020m in length of standing/running water and marginal vegetation. The arable and semi-improved grassland habitats and the habitats associated with the managed drainage ditches are considered to be of only local importance and generally low sensitivity and the ecological impact is generally considered low.

10.6.4 The works will not result in any direct habitat loss to the SPA or on Walland Marsh and Cheyne Court SSSIs. The landtake will, however, involve the loss of some 2.17ha from the very edge of the Dungeness SAC and existing SSSI. Whilst this will not affect any of the habitats or species for which the SAC or SSSI have been designated, primarily the vegetated shingles and great crested newts (see below), and the loss represents only 0.07% of the total 2916 ha of the SAC and only some 0.07% of the total 3252 ha of the existing SSSI, the ’international’ importance and ‘very high’ sensitivity of the site means that the overall impact significance is considered to be moderate.. In addition, the protected nature of the site necessitates an Appropriate Assessment under Regulation 48 (2) of the Conservation (Natural Habitats, & C.) Regulations (1994).

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10.6.5 The landtake will involve the loss of some 11.21ha from the proposed SSSI which represents only some 0.19% of the total 5661 ha of the proposed SSSI however it is considered a moderate impact due to the sensitivity.

Flora

10.6.6 Approximately 1020m of the ditches to the north of the existing runway would be relocated as part of the works, see Figure 4.1 and 4.2. The ditches to be affected are regularly disturbed by channel dredging and bank side strimming and no notable species were recorded there. Given the generally low botanical interest and sensitivity of both the ditches and the improved grassland habitats affected, impact on habitats and flora is therefore considered to be slight.

Invertebrates

10.6.7 A number of uncommon invertebrates have been recorded in the main pond and associated ditches. Medicinal leeches were also found whilst netting for amphibians and fish in two ditches to the north of the runway. The partial infill of these ditches will decrease availability of primary habitat for such species and will require mitigation.

10.6.8 The unmitigated loss of vegetation within 1m of the ditch waterline (especially any great willowherb, the roots of which are the preferred laying habitat for medicinal leech) would have an adverse impact on the conservation status of this species.

10.6.9 Given the above, the unmitigated removal of the aquatic and terrestrial habitats to the north of the existing runway, would be considered to have a moderate impact on invertebrate communities.

Reptiles and amphibians

10.6.10 The proposed development would encroach on areas of rough grassland known to support common lizard and grass snake and the drainage ditches to be affected are also considered suitable for grass snake. However, other areas of similar habitat in the vicinity would remain unaffected and should provide sufficient basking and scrub cover for these species. Overall therefore, despite the risk of accidental mortalilty during construction works, the potential impact upon reptiles is considered to be of negligible significance.

10.6.11 The proposed works will not directly affect any of the waterbodies which are known to support great crested newt breeding populations, although they will involve the loss of aquatic and terrestrial habitats within 500m of these ponds. Such losses, whilst they could lead to reduced availability of foraging opportunities and suitable refugia for hibernating newts, are considered unlikely to have a significant impact on the local great crested newt population given the extensive areas of suitable aquatic and terrestrial habitats present elsewhere in the vicinity, especially in the east of the site. Only a slight impact is therefore envisaged upon the population of great crested newts within the airport site and within the SAC as a whole.

Mammals

10.6.12 Otter presence has been noted around the main pond and the animals are likely to use the drainage system throughout the area on at least a transient basis. However no holts were recorded within the study area and the affected ditches are unlikely to contain the larger fish favoured by this species (coarse fish, salmonoids and eels). The limited loss and/or modification of these ditches and associated terrestrial December 2006 Page 164 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 10 LAA

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habitats is therefore unlikely to impact significantly upon available foraging habitat for otters and although construction works may restrict their movements through the drainage network (they do not favour crossing open territory) the overall effect upon this species is predicted to be of negligible magnitude and a negligible impact is therefore predicted for this species overall.

10.6.13 The limited loss and/or modification of the ditches and associated terrestrial habitat will have an adverse impact on the water shrew population using these sites. However such impacts are likely to be of small magnitude as suitable sections of drainage ditch habitat will remain in adjacent areas and the impact is therefore considered to be of only slight significance.

10.6.14 Water voles are also known to inhabit the affected drainage ditches and whilst the limited loss and/or modification of the ditches and associated terrestrial habitats is again likely to be of small magnitude, the high conservation value of this species means that the resulting (unmitigated) impact is considered to be of moderate significance.

Impacts due to Contamination / Siltation of Watercourses

10.6.15 During construction works there is potential for accidental pollution to affect ecological receptors on or in the vicinity of the site from a range of sources including contaminated water, oil and fuel used by site plant; materials used in runway construction and infilling of the ditches and run-off from stockpiled soil and construction materials. Further assessment of the potential for changes in water quality is addressed in Chapter 7 Water Resources and Flood Risk of this ES.

Designated Sites

10.6.16 The aquatic nature of many of the habitats within the Dungeness SAC and SSSI means that they are sensitive to any such contamination, with the level of impact influenced by the local hydrological regime. Potential impacts upon the SAC and SSSI through contamination and siltation are therefore considered to be of moderate adverse significance. Given the distance from the site, impacts on other designated sites, including the SPA and the North Lade, Walland Marsh and Cheyne Court SSSIs, are considered to be negligible.

Flora

10.6.17 Pollution of watercourses can cause long-term damage to the productivity and diversity of aquatic vegetation, leading to longer-term changes in vegetative composition with knock-on impacts on invertebrate populations and further along the food chain. However, good working practices will be used throughout the construction period and whilst there will be some temporary impact on water quality during the work on the drainage ditches, it is not envisaged that soils or construction materials would be deposited in adjacent waterbodies in sufficient quantities or over a prolonged enough period of time to result in a significant impact on the aquatic vegetation present. Likewise, any in-stream works that cause liberation of sediment into the water column, including metals and pollutants bound in the sediment that could be remobilised by the works, would be limited and therefore are unlikely to cause significant impact on the aquatic ecosystems. Potential siltation impacts are therefore considered to be of negligible significance.

10.6.18 Many of the terrestrial habitats around the site also support higher and lower plants of high conservation value and any limited contamination of such habitats would be considered to be a moderate impact.

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Invertebrates

10.6.19 Medicinal leeches present in the drainage ditches would be sensitive to changes in water quality or habitat changes arising from chemical contamination and/or siltation, with the main pond considered particularly sensitive. Amphibians also provide a primary food source for medicinal leeches within the Dungeness area and the leeches would therefore also be susceptible to any reduction in newt populations, triggered by contamination. Any impact on aquatic invertebrate communities is considered likely to be of moderate adverse significance given the high conservation status of a small number of species associated with the habitats present.

Reptiles and Amphibians

10.6.20 Common lizard and grass snake populations could be adversely impacted on by any spills or releases that affected prey availability (particularly amphibians and invertebrates) or led to the bioaccumulation of contaminants in prey. However the use of good construction practices means that the likelihood of such impacts is considered low and overall impacts are considered to be of no more than slight adverse significance.

10.6.21 Great crested newts and other amphibians would be highly susceptible to any pollution events within the aquatic ecosystems, as contaminants may not only be ingested directly or via their prey, but can also be absorbed through their skins or eggs, the latter which are also particularly sensitive to smothering arising from siltation. As any short term impacts on the newt sub-population within the airport site could lead to longer term impacts on the newt meta-population within the SAC as a whole, any such impact arising would be considered to be of substantial significance.

Mammals

10.6.22 Otters could be susceptible to the pollution impacts should contaminants be ingested directly or via bioaccumulation within their prey and being large carnivores they are also vulnerable to changes in food availability as a result of changes in water quality including increased siltation. Pollutants such as oil or petrol may also reduce waterproofing of otter fur affecting their thermoregulation. Whilst it is unlikely that otters would come into contact with any pollutants, any impact arising from chemical contamination would be considered to be of moderate significance.

10.6.23 Water shrews are susceptible to ingestion of pollutants directly or via invertebrate prey and are also particularly sensitive to changes in aquatic invertebrate availability, which can be affected by increased siltation. Any risk of impacts on water quality is therefore considered to be of moderate significance for this species.

10.6.24 Water voles are similarly susceptible to pollutants entering the drainage ditches, which could be ingested directly or via their food plants and risks of impacts on water quality would be considered to be of slight significance for this species.

Air Quality Effects

10.6.25 There is potential for dust emitted during construction (from stockpiled material, for example) to be carried elsewhere on or off site via aerial transmission. Increased vehicular emissions from construction plant and vehicle movements could also have the potential to affect ecological receptors. These types of indirect impacts are temporary in nature. The potential for changes in air quality are addressed fully in Chapter 15 Air Quality of this ES.

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Designated Sites

10.6.26 In significant quantities, dust can cause smothering of sensitive vegetation and the deposition over time can cause potential habitat loss. Whilst it is likely that dust generated as part of the construction works could reach Dungeness SAC and SSSI, in areas located adjacent to and immediately downwind of the site, the proposed development is unlikely to involve the release of dust in sufficient quantities or over sufficient timescales (as it is considered a temporary impact) to result in a significant impact on the SAC and SSSI hence a negligible effect is predicted.

10.6.27 No significant effect on the SPA is envisaged and a negligible effect is predicted upon other nature conservation sites including the North Lade, Walland Marsh and Cheyne Court SSSIs, which are considered unlikely to be affected by the works.

Flora

10.6.28 As discussed above, significant quantities of dust can cause smothering of sensitive vegetation and the deposition over time can cause potential habitat loss. As lichens uptake substances directly from the atmosphere and lack protective cuticles, they are particularly sensitive to environmental stress, especially concerning atmospheric pollution. However, the proposed construction works is unlikely to involve the release of airborne pollutants, including dust, in sufficient quantities or over sufficient timescales (as it is considered a temporary impact) to result in a significant impact.

Fauna

10.6.29 Any dust settlement within the aquatic systems could lead to vegetative smothering and reduced food availability. Aquatic species such as great crested newts could also be affected by a reduction in availability of vegetative cover and plants suitable for egg-laying within the breeding ponds, as well as reduced availability of suitable refugia in terrestrial vegetation throughout the hibernation period. Invertebrates, including the medicinal leech, would also be sensitive to changes in water quality due to dust settlement and its potentially smothering effect. However, the proposed development is unlikely to involve the release of large quantities of dust over an extended timescale and overall a negligible effect on fauna is predicted.

Disturbance

10.6.30 Construction activities are likely to cause general disturbance to ecological receptors in the area. Increased noise, vibration and lighting levels may arise during construction, including increased vehicular movements along the access road and runway. The resulting indirect impacts would be temporary in nature. The potential for changes in noise and vibration levels are addressed fully in Chapter 16 Noise and Vibration and visual effects in Chapter 12 Landscape and Visual Amenity of this ES.

Designated Sites

10.6.31 Noise and artificial light could cause disturbance to sensitive fauna and bird species associated with the Dungeness SAC and SSSI located within and adjacent to (and immediately downwind of) the proposed development. There is also potential for visual and physical intrusion to cause disturbance to the habitats and fauna of the adjacent SAC, including access by construction workers to the areas adjacent to the existing runway. Potential impacts upon the SAC and SSSI are therefore considered to be of moderate significance.

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10.6.32 No significant effect on the SPA is envisaged due to the distance from the site. A negligible effect is also predicted upon other nature conservation sites including the North Lade, Walland Marsh and Cheyne Court SSSIs, which are considered unlikely to be affected by the works.

Flora

10.6.33 Habitat disturbance may be experienced in areas outside the footprint of the development, due to access by construction workers, plant and storage of materials. The installation of cabling and drainage may also increase disturbance to habitats.

10.6.34 Vegetated shingle is a habitat of particular sensitivity to disturbance and is slow to recover. Disturbance to any areas of vegetated shingle would therefore be considered of moderate significance. However, as the majority of the proposed works would be undertaken in currently disturbed areas, such as managed grassland/arable, the potential disturbance to habitats and flora from the proposed works is considered to be slight.

Fauna

10.6.35 General impacts may include increased noise, vibration and lighting levels resulting from the works, with potential to adversely impact faunal populations in the area. Most of the faunal species known to inhabit the area however, are considered to be relatively tolerant to human disturbance as evidenced by their co-existence with an operational airport and are considered likely to habituate to the form of temporary disturbance.

10.6.36 Some species are more sensitive to physical disturbance and great crested newts are considered especially vulnerable to injury and/or death at times when they are migrating to or from the breeding ponds/waterbodies and in the period immediately after hibernation. Whilst any such impact is considered likely to be significant in the context of it being a cumulative impact to habitat loss, it appears unlikely that the works to the north of the runway would disturb great crested newts.

10.6.37 Overall, the potential effect of disturbance on fauna is considered to be moderate adverse in significance.

10.6.38 Future Assessment Conditions Scenario

10.6.39 Predicted impacts arising from construction of the facility under this scenario are expected to be the same as described under the “existing conditions scenario” above.

10.7 Predicted Impacts (Operational impacts)

Existing Conditions Scenario

10.7.1 Whilst the proposed development would not result in any change in aircraft passenger capacity over and above that already permitted for the site a number of impacts may arise from the extended runway length. These impacts on non-avian ecology include impacts arising through changes to water quality and disturbance effects from lighting, both of which are discussed below. Predicted impacts from the increase in passenger numbers are discussed in section 10.5 (Baseline Environment - Future Assessment Conditions Scenario). Impacts on birds are addressed in Chapter 11.

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Water Quality and Drainage Effects

10.7.2 The proposed development would increase the area of hardstanding and the effect of this increase in impermeable surface area on the hydrological conditions of the site may in turn have an effect upon ecological receptors. The potential for changes in water and drainage conditions due to a change in surface and groundwater flows and quality are addressed fully in Chapter 7 Water Quality and Flood Risk of this ES.

10.7.3 Whilst any changes in surface and groundwater flow could also affect vegetation communities within the SAC and SSSI which are dependent on certain ground conditions (such as water content and pH), it is unlikely that significant changes in surface water and groundwater flow would arise from the proposed development and therefore this potential impact is considered to be of negligible significance.

10.7.4 Other nature conservation sites including the SPA and North Lade, Walland Marsh and Cheyne Court SSSIs are also unlikely to be affected by the operation of the proposed development and the overall effect of changes in water quality and drainage upon the integrity of designated sites within and in the vicinity of the airport site is considered to be of negligible significance.

10.7.5 Modifications to the existing site drainage system would involve a limited loss of bankside and aquatic habitats although the drainage channels are heavily managed at present and so the habitats and species are considered relatively resilient to disturbance. Changes in water depth and flow regime are often critical for freshwater ecosystems. Overall, the potential effect on habitats and flora is considered to be slight adverse in significance.

Lighting Effects

10.7.6 The proposed airport development would involve the relocation of the existing lighting installations to the northern end of the runway. Additional to the landing lights, lighting associated with aircraft and road vehicles may also have a potential effect on ecological receptors due to the increase in road and air traffic associated with the operational site

10.7.7 No significant impact upon the integrity of the designated sites of nature conservation interest in the area is likely to arise from the increased level of lighting. The existing runway operates approach lighting to the north of the site, in the vicinity of the SAC, and the proposed lighting will be located approximately 300m further north from the SAC and its sensitive habitats and species. Overall a negligible change or even slight beneficial effect will be experienced by the habitats and species of the SAC.

10.7.8 The erection of lighting installations at a new location within the airport site does have the potential to disturb wildlife in the immediate area as increased artificial light may disrupt biological rhythms of species and interfere with the behaviour of nocturnal animals.

10.7.9 In particular nocturnal mammals, such as badgers and otters, may be disturbed by the presence of bright illumination, whilst studies into the effects of lighting on bats reveal that depending on the light source/type of light this may have either an adverse or positive effect on the foraging behaviour of different bat species. However, given the very low intensity of the lighting at night, and the low sensitivity of the areas to be affected, the impact is considered negligible.

10.7.10 Future Assessment Conditions Scenario

10.7.11 Predicted impacts under this scenario are expected to be the same as described under sections 10.7.2-9 the “existing conditions scenario” above, although levels of

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habituation to disturbance will be higher and the magnitude of potential impacts arising from any of the changes outlined above will be less.

10.8 Proposed Mitigation (Construction impacts)

Existing Conditions Scenario

10.8.1 The proposed development has been designed in such a way as to minimise habitat loss and disturbance to ecological receptors in the area. The following section describes the proposed mitigation being planned for the works.

10.8.2 Generic mitigation measures will be implemented during construction to prevent and/or minimise potential impacts upon habitats and species in the area. In particular a works method statement will be developed within the Construction Environmental Management Plan (CEMP) to illustrate how impacts on ecology will be managed in accordance with best practice guidance, including pollution-prevention procedures and EA guidelines regarding working in proximity to watercourses, to reduce the risk of contamination. Examples of measures to be included within the CEMP include the following:

• Protection of important habitats from accidental leaks or spills of oil or other petroleum-based products is extremely important. All fuels, oils and other potentially contaminating materials will be stored in securely bunded areas;

• Dust suppression measures will be implemented throughout the site;

• Equipment, construction materials and waste will be stored only on hardstanding areas and covered with sheeting;

• Areas outside the footprint will be fenced off to prevent unauthorised access by site plant or personnel or incorrect storage, for example of spoil;

• Vehicle movement will be confined to existing roads and access tracks. Any access over vegetation and soils will be limited to dedicated access tracks used only by vehicles with wide tyres to minimise damage;

• The soil will be stripped, handled, stored, and managed appropriately, for re-use on site wherever possible; and

• Phasing of works will take into account the various species’ periods of particular vulnerability, for example vegetation clearance should only be done outside the bird nesting season (see bird-specific measures below). 10.8.3 Mitigation measures implemented during construction to prevent and/or minimise potential adverse effects associated with the temporary changes in air quality; water quality and drainage; and noise and vibration are discussed in the other sections of the ES.

Habitat-specific Measures

10.8.4 The extent and duration of work within and adjacent to the waterbodies / drainage ditches will be minimised to reduce the severity of impacts resulting from silt disturbance upon the aquatic and terrestrial habitats.

10.8.5 The loss of some 1020m of ditch habitats will be partially mitigated through the

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provision of over 1250m of new drainage ditches (and thus wetland habitats). The recreation of aquatic and terrestrial habitats will therefore benefit a variety of species allowing areas of habitat suitable for species including great crested newt, medicinal leech and otter to be provided without necessitating large areas of open water.

10.8.6 Although the primary aim of the drainage ditches is to provide a functional drainage system for the site, the works will be sympathetic to the local ecological conditions and aim to enhance and recreate existing habitats, maintaining natural bank conditions were possible, using natural materials for bank protection as required.

10.8.7 Drainage ditches to be lost, or those to be retained but which may need some modifications, would be strimmed prior to commencement, so that vegetation is at ground level and to allow any animals present to seek refuge elsewhere. In addition, following any species-specific measures (see below) the drains will be carefully drained down and any animals present allowed to disperse naturally where possible over a period of several days.

10.8.8 Restoration and appropriate management of aquatic and bankside vegetation will be undertaken to maximise the ecological interest of the drainage ditches and appropriate planting of divided sedge and other species of botanic interest will be undertaken with advice from Natural England. Species such as yellow flag iris and great willowherb will also be planted on Natural England’s recommendations to provide suitable resources for species such as water vole and medicinal leech. Habitat enhancement measures will also be considered, such as the provision of artificial holts and good riparian habitat for the benefit of otters and appropriate management of bankside vegetation to encourage use by water voles. In places bare earth patches will be provided within south-facing banks to benefit invertebrate species.

Species-specific Measures

Medicinal Leech

10.8.9 Medicinal leech surveys of the drainage ditches to the north of the runway would be undertaken in advance of any works commencing. The results of these surveys would inform an appropriate mitigation strategy which could involve a translocation exercise to an appropriate receptor site, most likely the main pond. A mitigation strategy would be devised in consultation with Natural England and other specialists with detailed knowledge of this species. Surveys and any translocation activities would be carried out following best practice guidance and under DEFRA licence by a Natural England licensed surveyor, with a clear justification of the reasons for removing the waterbodies.

Reptiles

10.8.10 Many of the most valuable areas and features for reptiles on site would not be affected by construction. However, reptiles are likely to be present throughout the site and measures to avoid their incidental mortality will need to be employed. It is not considered necessary to relocate individuals, as the areas to be impacted by the works would be subject to targeted habitat management to reduce the overall suitability of these areas for reptiles. For example, grass would be kept short and scrub covered removed to discourage use by reptiles. Considerable tracts of suitable habitat in the vicinity are available for any displaced reptiles. Works in areas of suitable hibernating reptile habitat would be undertaken during the summer months, when reptiles are active rather than during the hibernation period.

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Great Crested Newt

A further series of great crested newt surveys have been undertaken of the drainage ditches to the north of the runway. Whilst no great crested newts were found during these surveys, additional field surveys would be undertaken just prior to any work commencing to confirm the results. In addition, and as part of its biodiversity action plan, LAA are committed to developing a long term newt management strategy in agreement with Natural England to ensure that should any future works be required (e.g. translocation works, terrestrial habitat management, creation of replacement habitat etc) the approach to any such work has been agreed in advance.

Water Vole

10.8.11 Specific water vole mitigation to exclude animals from the working area is required, given the presence of the species in the drainage ditches to be directly impacted. The mitigation strategy will follow best practice guidance (19) and be agreed in advance with the EA and Natural England prior to any works commencing, and may include a trapping, removal and release exercise. The loss of water vole habitat in the long term will be mitigated for by the creation of new drainage ditches around the runway. However more suitable habitat within adjoining ditches exists and further surveys will be undertaken to establish the presence of water vole in the wider area. These adjoining ditches would benefit from enhancement to encourage water voles to move away from the areas to be lost.

Other Aquatic Mammals

10.8.12 No evidence of otter activity or presence was recorded along the drainage ditches that are to be affected to the north of the existing runway. The loss of potential otter foraging habitat and corridor network would be replaced in the long term by the creation of new drainage ditches connecting with the existing drains across the site.

10.8.13 The loss of water shrew habitat in the long-term will be replaced by the creation of new drainage ditches around the proposed runway extension. Water shrews are not restricted to aquatic bank side habitats and are also known to live in terrestrial habitats such as woodland, hedgerow and grassland and are known to disperse to distances of approximately 160m. It is likely however that they would be present in the well vegetated banks along the drainage ditches (which provides them with protection from predators) due to the lack of other suitable habitat as arable habitat surrounds the ditches. Suitable habitat within adjoining ditches would benefit from enhancement to encourage water shrews to move away from the areas to be lost and it is possible that further surveys will need to be undertaken to establish the presence of water shrew in the wider area and if such ditches are suitable for relocating any water shrews trapped (under licence). A detailed mitigation strategy will be devised with the EA and Natural England prior to any construction works, possibly involving an intensive trapping effort.

10.8.14 Where drainage ditches are being retained, but modifications required, the loss of marginal and bankside vegetation will be minimised and the use of hard engineering structures along the banks avoided. Current maintenance is undertaken outside of the water shrew-breeding season (which is April-September).

Future Assessment Conditions Scenario

10.8.15 Proposed mitigation for construction impacts under this scenario is as described under the “existing conditions scenario” above.

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10.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

10.9.1 As part of the long-term management of the site, a biodiversity action plan will be developed for the airport in discussion with Natural England as part of the proposed EMS for the airport. This will endeavour to maximise the ecological benefits of the airport (whilst not compromising safety), using complimentary habitat management initiatives to provide nature conservation benefits. The plan will include both habitat and species specific actions and will include, but not be limited to, the issues outlined below.

10.9.2 To reduce the risk of siltation and contamination of watercourses during operation, vegetated ditch banks will be enhanced, following advice from Natural England and additional buffer zones planted, such as reedbeds/wetlands, to act as filters to retain silt and potential contaminants, such as petroleum products while they degrade.

10.9.3 In order to attract invertebrate species which have a requirement for bare earth to burrow into to make breeding tunnels, a number of ‘bee banks’ will be created on suitable earth bunds. These ‘bee banks’ are south-facing areas of bare earth that are kept weed-free and protected from any chemical treatment. This enables solitary bee and wasp species to create tunnels for breeding in the exposed earth. It is hoped that the ‘bee banks’ will benefit many species of wasp and bee.

10.9.4 Measures would be implemented to protect the reptiles and small mammals from any future mortality associated with the operational airport for example, by the use of small ramps in interception trenches to allow animals to escape. Appropriate habitat management of certain areas of the site would also aim to increase the habitat suitability for reptiles away from the operational areas of the site, to reduce the risk of disturbance and accidental mortality.

10.9.5 Measures to avoid the incidental mortality of great crested newts will be employed in the vicinity of the ditches where they are present. Any activities likely to kill or injure great crested newts, or to damage or destroy their habitat (in particular, site clearance and earth works), would be carried out under DEFRA licence in agreement with Natural England and at the time of year when the majority of newts will be in the pond (i.e. April/May).

10.9.6 Although the management of the drainage ditches by the IDB does not appear to have a detrimental effect on the water vole populations to date, habitat management of the waterbodies and drainage ditches in the vicinity of the site will be undertaken in agreement with Natural England and EA, using appropriate management such as the following:

• Maintain buffer strips >5m wide on either side of the watercourse from the top of the bank;

• Grade the banks of the watercourses within the buffer zones in certain sections to create wet shelves with gently sloping margins that may support a wide variety of plants ranging from those which prefer being partially submerged at all times, to those which prefer dry conditions all or most of the time (currently the ditch banks are very steep-sided). Ditch management should ideally be done during the winter, on short stretches at a time in rotation, leaving gaps of 20-30m between sections. Work upstream to allow seeds and invertebrates to return to disturbed areas downstream. Work from one bank, as far back as possible from the water’s edge to minimise compaction of vegetation and burrows. If possible, store any excavated material overnight on the bank to allow invertebrates and

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amphibians to return to the water (at least 2m from the waterway to prevent the material washing back into the waterway);

• Strim/cut the bankside vegetation on rotation to approximately 15cm in height. Cut alternate and opposite strips of waterway banksides (each 30-50m long) in alternate years. Where possible, leave a fringe of uncut vegetation at the waters edge (particularly as no winter cover). Dispose of cuttings away from the buffer strip to prevent smothering of bankside vegetation. If possible, cut in late autumn to avoid disturbing water voles whilst breeding;

• If bank reinforcement is necessary to prevent erosion and collapse, ‘soft’ reinforcement techniques will be used which stabilise banks but also allow water voles to burrow and promote potential food growth; and

• All areas subject to habitat management programmes will be monitored in the long term to ensure continued effective management.

Ecological Monitoring and Long-term Management

10.9.7 Given the significant ecological constraints associated with much of the site and its surroundings, a formal environmental management framework (to include a Biodiversity Action Plan) will be established as part of the proposed EMS to ensure a continual input to all ongoing and future phases of the airport. This would ensure that potential impacts on valuable habitats and species continue to be either avoided or effectively mitigated and would also allow for the continued input of positive biodiversity enhancement measures throughout the life span of the airport.

10.9.8 A system of ecological survey, monitoring, supervision and advice has already been set in place, and this would continue to be undertaken in full consultation with the relevant consultees. Specialist ecological input and advice will be provided throughout the development process to ensure that legal obligations and best practice requirements are met.

10.9.9 LAA will seek to promote conservation on the airport site where there is no conflict with aviation safety and security. Biodiversity management and monitoring will ensure that following the airport’s development there will not be any significant net loss in biodiversity and where possible it will aim to enhance existing habitats and create new habitat that will contribute to increasing the overall biodiversity both on site and in its immediate vicinity, without any increased risk to aviation safety.

Future Assessment Conditions Scenario

10.9.10 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

10.10 Residual Effects

Existing Conditions Scenario

10.10.1 With the appropriate mitigation measures implemented, there will be few significant adverse effects as a result of the proposed development. Residual effects will be limited to the loss of bankside and in-stream habitat associated with ditches to the north of the runway; loss of arable and semi-improved grassland habitat to the north of the runway; and temporary disturbance to species using these habitats.

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Future Assessment Conditions Scenario

10.10.2 Residual impacts are expected to be as described for the ‘existing conditions scenario’ above

10.11 Summary

10.11.1 Ecological features in the area of the proposed airport development are considered to be of very high value for ecology and nature conservation, due to the presence of vegetated shingle (within SAC and SSSI designation); great crested newts and medicinal leech; other ecological features to be affected are evaluated as being of lower value (local to negligible). Long-term effects on key ecological features are, however, not expected to be of significant adverse impact, particularly once the mitigation measures included within this Chapter have been implemented.

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11 BIRD CONSERVATION AND HAZARD MANAGEMENT

11.1 Introduction

11.1.1 Given the international importance of the sites around LAA for both over-wintering and breeding bird populations, and public concerns over the potential for bird-related hazards to affect the operational functioning of the airport, bird conservation and bird hazard management are two interconnected areas that must be thoroughly understood within the context of any application for planning consent.

11.1.2 This chapter of the ES therefore deals solely with these two issues, and describes the results of both the ornithological assessment commissioned for the EIA and the bird hazard risk assessment carried out for the proposed development scenarios. The bird hazard risk assessment is currently being developed in consultation with RSPB. The assessment also includes an evaluation of potential indirect impacts that could affect important bird populations as a result of the bird hazard management control measures proposed.

11.1.3 The scenarios modelled in this chapter are as described in Chapter 1.

11.2 Legislative Drivers:

11.2.1 Whilst Chapter 5 (Planning Policy Framework) discusses the local planning background against which the proposed development will be considered, including relevant nature conservation plans and policies, the following legislation, policy and guidance documents have been used to underpin the ecological impact assessment reported in this Chapter:

• Habitats and Species Directive (92/43/EEC) 1992;

• (Wild) Birds Directive (79/409/EEC) 1979;

• Ramsar Convention on Wetlands of International Importance, 1971;

• Bern Convention (on the Conservation of European Wildlife & Natural Habitats; and on the Conservation of Migratory Species of Wild Animals) 1979;

• Conservation (Natural Habitats and c.) Regulations 1994;

• Wildlife and Countryside Act 1981 (and subsequent amendments);

• Countryside and Rights of Way Act 2000;

• National Parks and Access to the Countryside Act 1949;

• The UK Biodiversity Action Plan (UKBAP) 1994;

• Kent Biodiversity Action Plan (Kent BAP) 1997;

• Planning Policy Statement 9: Biodiversity and Geological Conservation;

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• Kent & Medway Structure Adopted Plan 2006; and

• Shepway District Local Adopted Plan 2006.

11.3 Assessment Methodology:

Ornithological Studies

11.3.1 The key objectives of this study have been as follows:

• to establish the geographical scope and methodology for desk and field surveys which would provide robust information on which to base an impact assessment;

• to carry out a desk study of bird conservation sites, other important habitats and bird species distribution;

• to carry out further confirmatory field survey studies on wintering and breeding bird activity;

• based on the above, to evaluate the importance of the LAA site and its environs for birdlife;

• to assess the potential impacts of the proposed development (and any required bird hazard mitigation works) on the conservation value of the area for birdlife; and

• to recommend mitigation measures as necessary. Study Area

11.3.2 Whilst the direct footprint of the proposed development is small and restricted to land within the airport boundary; indirect impacts arising from disturbance can affect larger areas, and following consultation with RSPB and Natural England detailed ornithological studies have therefore been undertaken for a 500m area around the airport, as shown in Figure 11.1.

11.3.3 In addition, and as the proposed project could affect long-term air traffic movements, interactions with birdlife over a much larger area have also been assessed , and following further consultation with Natural England and the RSPB, a wider survey of sites within 2 miles of the airport (including the Denge Marsh area) has also been surveyed, with particular regard to species of particular conservation importance and/or bird strike risk. This extended study area is shown in Figure 11.2.

11.3.4 In certain cases existing data has been used to compliment the field surveys (eg where data are available from the annual Wetland Bird Surveys - WeBS – counts) and although it is acknowledged that not all local species will be recorded in these surveys, they do provide some data on annual trends, allowing some of the field work to be more confirmatory in nature. The surveys themselves are described in more detail later in this Section.

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Key Sites of Ornithological Interest within the Study Areas

11.3.5 As outlined in Chapter 10 Ecology and Nature Conservation and Section 11.3 below, the area surrounding the airport is protected under a range of UK and international designations, many of which relate to the conservation of bird species that breed or over-winter on the inland wetlands, grazing-marsh, arable land, shingle-beaches, gravel pits, sand dunes and saltmarsh present. The key designated sites of ornithological importance located near LAA that have been assessed in this study are shown in Figure 11.3 and outlined in Table 11.1 below.

Table 11.1 Key Designated Sites of Ornithological Importance in the Study Area Name Ornithological interest The Romney Marsh Natural Area, Numerous breeding and wintering birds, especially incorporating the Dungeness SSSI, on the gravel pits and in the RSPB Reserve. The Dungeness RSPB Nature Reserve, area is also an important landfall for nocturnal Lade Pits, Dungeness Bird migrants, especially warblers, chats and thrushes. Observatory & Dungeness to Pett The Lade Pits provide significant habitat to waders, Levels SPA geese and waterfowl The Romney and Lade Sands & An important area for overwintering waders Romney Warren SSSIs (especially sanderling) and waterfowl (including great crested grebe and red throated diver) Cheyne Court SSSI Important roosting grounds for Bewick’s swan and also used by a range of waterfowl, including white fronted goose, bittern, wigeon, gadwall, shoveller, golden plover, gargany Walland Marsh SSSI Important feeding area for Bewick’s Swan and also used by significant populations of redshank, lapwing, yellow wagtail, meadow pipit, water rail, tufted duck, reed warbler, sedge warbler, wigeon, teal, golden plover, snipe, mute swan, hen harrier and ruff. Up to 30,710 non breeding waterfowl have been recorded here (1997/98) Rye Harbour SSSI Important for breeding terns, and gulls as well as passage migrants such as whimbrel

Key Species of Ornithological Interest within the Study Areas

11.3.6 The most common bird species present in the area (and which account for over 80% of all the records from the RSPB Reserve) include such species as starling, tufted duck, sand martin, teal, wigeon, pochard, swallow, shoveler, herring gull, black- headed gull, lapwing, greylag goose and golden plover. Of these, the larger birds and medium-sized flocking species are considered to be of particular concern for birdstike risk, whilst others, especially the smaller passerines, have not been shown to cause damage to commercial turbine engines to date and as such are considered generally low risk and low priority species for bird hazard management.

11.3.7 As outlined further in Section 11.3.24 there is a clear relationship between bird weight and numbers struck and the risk that an aircraft will be damaged. Thus, species which are larger than 100g, or occur in flocks (e.g. gulls, lapwings, corvids, pigeons, starlings, etc), are most likely to cause damage to aircraft, and thus have the potential to cause accidents. Recent studies have helped define a "priority group" of bird species which fit either or both these categories and these are the main target of any preventive measures. At Lydd these include the following:

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• Gulls;

• Grassland plovers and coastal waders;

• Raptors;

• Waterfowl;

• Gamebirds;

• Corvids;

• Starlings; and

• Pigeons.

11.3.8 The bird-strike risk assessment has therefore focussed on all of these groups, with the potential for impacts on conservation objectives assessed in more detail for the first four. Ornithological Desk Studies

11.3.9 Initial desk studies carried out for this assessment identified nine survey areas which have been the subject of regular Wetland Bird Survey (WeBS) reports, as shown in Figure 11.3. Data from these sites have been reviewed, alongside that from other sources, including the various summaries produced by the RSPB in relation to the Dungeness Nature Reserve.

Field surveys – Wintering Birds

11.3.10 A series of overwintering bird studies were carried out over the winters of 2004/5 and 2005/6 to verify the data available from the desk studies and assess the importance of some of the non-WeBS surveyed areas for wintering wildfowl, waders and gulls. Although the 2004/05 survey was confined to three visits, (16th and 21st February and 5th March 2005), six further visits were made to the study area from October through to March in 2005/06 (18th October, 8th November and 6th December 2005 and 17th January, 14th February and 14th March 2006), and further overwintering studies are being undertaken in 2006-07. Visits were timed to coincide with high tide when coastal species may move to the study area to roost.

11.3.11 Counts of concentrations of wildfowl, waders and gulls were made from vantage points using a telescope mounted on a tripod. The study was undertaken by Paul James, an experienced bird surveyor with good knowledge of the local area.

11.3.12 Whilst the data collected by these studies cannot be considered as fully comprehensive, given the limited duration and high ecological value of the area, by using it to ground truth the data obtained from the other surveys, it is believed that a robust enough understanding has been developed to ensure that, should the developments be allowed to proceed, appropriate mitigation can be developed to allow the airport and the bird conservation areas to co-exist.

Field Surveys – Breeding Birds

11.3.13 The aims of this study were to determine the pattern and distribution of breeding birds within the agreed study area and to identify important non-designated breeding sites. Surveys were carried out in spring/summer 2005 and 2006, again by Paul James.

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11.3.14 In 2005, four visits were made to the study area (on 22 April, 18 May, 7 June and 6 July). On each visit, following an initial walk-over assessment of the breeding bird communities present within the study area as a whole, a more detailed survey was undertaken, where breeding sites were noted. The survey was carried out based on the BTO’s Common Birds Census mapping method, in which a series of visits are made to a study area and contacts with birds (by sight or sound) are recorded on a large scale map 1 2. Standard codes for species and activities are used when registering birds on the visit map (see Figure 11.1).

11.3.15 A total of ten mapping visits were made to the site between late March and early July 2006 on 31 March, 28 April, 5 May, 12 May, 19 May, 8 June, 16 June, 23 June, 29 June and 6 July. Each visit was spaced fairly even throughout the season, started before 9 a.m. and was carried out in good weather, in accordance with CBC recommendations. Cold, windy or wet days were avoided since the activity and detectability of the birds are much reduced. During the visits the location and movements of the birds present in the study area were marked on the visit maps, taking care to ensure that each individual was recorded only once. Again the standard CBC codes for species and activities (Marchant 1983) were used when registering birds on the maps.

Bird Conservation

11.3.16 The conservation impact assessment has been undertaken using a methodology based on that of the Environmental Impact Assessment Regulations 1999 and on the Institute of Ecology and Environmental Management (IEEM) guidelines (2006) and Institute of Environmental Management Assessment (IEMA) guidelines (2004). This incorporates the assessment of the local environmental sensitivity with the magnitude of the impacts likely to occur, to determine the overall significance of the impact.

11.3.17 Negative effects are defined as effects that are detrimental to the nature conservation value of any component of the ecosystem and anything that might reduce that component's viability at the site. Positive effects are defined as those that increase conservation value and which improve a component's viability. Effects can be further defined as direct (those that are causally linked to the development without any intermediary factor) or indirect (those involving at least one intermediary process), and have been considered through both the construction and operational phases of the proposed development. The criteria used for the determination of significance of the ecological effects are summarised in Tables 11.2 and 11.3 below.

Table 11.2 Determination of the Ecological Sensitivity of the Site.

SENSITIVITY DEFINITION

Cited interest of Special Protection Areas (SPAs,) Special Areas of Conservation (SACs) and Sites of Special Scientific Interest (SSSIs). VERY HIGH Cited means mentioned in the citation text for the site as a species for which the site is designated (SPAs/SACs) or notified (SSSIs).

1 Bibby CJ, Burgess ND & Hill DA 2000. Bird Census Techniques. Academic Press. 2 Marchant J 1983. BTO Common Birds Census Instructions. Maund & Irvine, Tring

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SENSITIVITY DEFINITION

Other species that contribute to the integrity of an SPA or SSSI. Local population of more than 1% of the national population of a species. HIGH Ecologically sensitive species, e.g. large birds of prey or rare birds (<300 breeding pairs in the UK).

Regionally important population of a species, either because of population size or distributional context. EU Birds Directive Annex 1, EU Habitats Directive priority habitat/species MEDIUM and/or Wildlife & Countryside Act Schedule 1 species (if not covered above). UK Biodiversity Action Plan (BAP) priority species (if not covered above).

Any other species of conservation interest, e.g. species listed on the Birds LOW of Conservation Concern not covered above.

Table 11.3 Determination of the Magnitude of Ecological Effects

MAGNITUDE DEFINITION

Total loss or very major alteration to key elements/ features of the baseline conditions such that post development character/ composition/ VERY HIGH attributes will be fundamentally changed and may be lost from the site altogether. >80% of population/habitat lost. Major alteration to key elements/ features of the baseline (pre- development) conditions such that post development HIGH character/composition/attributes will be fundamentally changed.20-80% of population/habitat lost.

Loss or alteration to one or more key elements/features of the baseline MEDIUM conditions such that post development character/ composition/ attributes of baseline will be partially changed.5-20% of population/habitat lost. Minor shift away from baseline conditions. Change arising from the loss/ alteration will be discernible but underlying character/ composition/ LOW attributes of baseline condition will be similar to pre-development circumstances/patterns.1-5% of population/habitat lost. Very slight change from baseline condition. Change barely NEGLIGIBLE distinguishable, approximating to the "no change" situation.<1% of population/habitat lost.

11.3.18 The combined assessment of the magnitude of an effect and the sensitivity of the site (or any component of the ecosystem) has been used to determine whether or not an impact is significant with respect to the EIA Regulations. These two criteria have been cross-tabulated to assess the overall significance of that effect (Table 11.4).

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Table 11.4 Impact Significance Matrix

SENSITIVITY

VERY HIGH HIGH MEDIUM LOW

VERY HIGH Very high Very high High Moderate

HIGH Very high Very high Moderate Low

MEDIUM Very high High Low Very low MAGNITUDE

LOW Moderate Low Low Very low

NEGLIGIBLE Low Very low Very low Very low

11.3.19 The significance of each combination is shown in each cell. Cells with low and very low significance would be deemed as not significant under the EIA Regulations. The interpretation of these significance categories is as follows:

• Very low and low are not normally of concern, though normal design care should be exercised to minimise impacts;

• Medium represents a potentially significant impact that requires careful individual assessment. Such an impact could warrant planning refusal, but it may be of a scale that can be resolved by revised design or appropriate mitigation; and

• Very high and high represent a highly significant impact on bird populations and would warrant refusal of a planning proposal if significant additional mitigation is not provided. Bird Hazard Risk Assessment

11.3.20 The results of desk and field surveys described above have been used to inform a bird hazard risk assessment study of the airport, undertaken by Airport Wildlife Management (AWM). This study is currently being finalised with the RSPB but includes:

• A review of the Civil Aviation Authority (CAA) 3 4 risk assessment methodology on bird hazard to aircraft in general;

• Assessment of the bird hazard at LAA from historical data;

• Site visits and refinement of the risk assessment 5 with reference to the historical birdstrike records 6 and to take account of aircraft types likely to be operated under the proposed development at LAA; and

3 Civil Aviation Authority. 1998. The Management of Safety. Consultative Version 0.1. September 1998. CAA Safety Regulation Group. 4 Civil Aviation Authority. 1998. CAP680. Aerodrome Bird Control. CAA London.

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• Recommendation of mitigation measures appropriate to the scale of operations and specifically designed for the conditions at LAA. CAA Risk Assessment Methodology

11.3.21 The procedures applied are described in ‘The Management of Safety’ (1998), 7, a constantly evolving document produced by CAA Safety Regulation Group (SRG) in consultation with industry as guidance to aerodrome operators and air traffic service units on the development of safety management systems. It should be noted that for the purposes of such assessments, the CAA SRG define hazard as a ‘physical situation, often following some initiating event, that can lead to an accident’.

11.3.22 Risk management is an essential part of safety management, and risk assessment is the process by which risks are evaluated and, where necessary, policies for their mitigation determined, using the following approach:

• Identification of all possible hazards;

• Critical review of possible hazards and subsequent re-definition as necessary;

• Hazard severity assignment for each of the hazards identified;

• Estimation of probability of each hazard arising;

• Risk tolerability determination in which severity and probability of hazards are combined; and

• Risk reduction as required by action to mitigate the severity or likelihood of occurrence. Hazard Identification

11.3.23 The potential hazard of birds to aircraft has been assessed in terms of general groups, as outlined in Section 11.3.7. This assessment provides an indication of those species that are likely to visit the airport to determine tolerability and the need for mitigation action.

11.3.24 Approximately 1600 bird strikes on UK-registered civil aircraft are reported to the CAA annually (out of some tens of thousands of flights undertaken annually) and whilst the majority of these cause little or no damage, those causing aircraft losses are generally similar in nature i.e. they involved common aircraft types, standard aerodrome activities and modest numbers of the species that commonly frequent airfields. Where bird strikes have had catastrophic results this has been primarily because of chance factors such as ingestion of birds into one or more engines causing a sufficient loss of power for the aircraft to crash or the pilot to lose control.

11.3.25 Whilst even single, relatively small birds have the proven potential to cause accidents, there are clear relationships between bird weight and numbers struck and the risk that the aircraft will be damaged as shown in Table 11.5.

5 Milsom, T P. 1990. The Use of Birdstrike Statistics to Monitor the Hazard and Evaluate Risk on UK Civil Aerodromes. Birdstrike Committee Europe 20, Helsinki. Working Paper 30, pages 303-320. 6 Thorpe, J. 1996. Fatalities and Destroyed Civil aircraft due to Bird strikes 1912-1995. Birdstrike Committee Europe 23, London. Working Paper 1, Pages 17-31. 7 Civil Aviation Authority. 1998. The Management of Safety. Consultative Version 0.1. September 1998. CAA Safety Regulation Group.

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Table 11.5 Relationship between bird weight / numbers and risk Bird weight % damaging strikes (% causing engine damage) <100g (small) 2.7 (0.7) 101-1000g (medium) 12.0 (3.96) >1000g (large) 22.7 (4.97) No of birds struck % damaging strikes (% causing engine damage) 1 8.12 (2.1) 1-10 14.6 (4.6) 11-100 40.3 (22.6)

11.3.26 As described earlier, species which are larger than 100g, or occur in flocks (e.g. gulls, lapwings, corvids, pigeons, starlings, etc), are most likely to cause damage to aircraft, and have the potential to cause accidents. Further information on those species of particular concern at LAA is provided in Baseline Environment: Key species of Birdstrike and Conservation Importance paragraphs.

Hazard Severity

11.3.27 Whilst there is no fixed formula for degrees of hazard, a four level system and definitions are used as shown in Table 11.6. Applying these criteria to the potential results of birdstrikes with “priority groups” of birds, it is apparent that the hazard severity for birdstrikes includes all levels up to and including ‘catastrophic’.

Table 11.6: Hazard Severity Definitions Classification Results: one or more of the following Catastrophic Loss of aircraft Multiple fatalities Hazardous Large reduction in safety margins Physical distress or workload such that flight crew cannot be relied upon to perform their tasks accurately or completely Serious injury or death of a relatively small proportion of occupants Major Significant reduction in safety margins Reduction in ability of flight crew to cope with adverse operating condition as a result of increase in workload or as a result of conditions impairing their efficiency Injury to occupants Minor Nuisance Operating limitations Emergency procedures

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Hazard Probability

11.3.28 The following definitions originate from Joint Airworthiness Requirement 25, which quantifies probability in terms of flight hours. However, CAA SRG considers that the definitions are equally valid for aircraft movements and bird strikes at an aerodrome.

Table 11.7: Hazard Probability Definitions Classification Qualitative & quantitative definitions Extremely Improbable Should virtually never occur in the whole life of the fleet. <10-9 per movement Extremely Remote Unlikely to occur when considering several systems of the same type but, nevertheless, has to be considered as being possible. 10-7 to 10- 9 per movement Remote Unlikely to occur during total operational life of each system but may occur several times when considering several systems of the same type. 10-5 to 10-7 per movement Reasonably Probable May occur once during total operational life of a single system. 10-3 to 10-5 Frequent May occur once or several times during operational life. 1 to 10-3 per movement

11.3.29 The exceptionally high safety standards imposed on civil air transport both by regulation and by public demand means that all accidents from all causes are required to occur at a frequency of less than 1 x 10-7. Individual hazards are therefore required in turn to pose a considerably lower risk, in the order of 1 x 10-9, although, given the very low frequency with which accidents occur in civil aviation, it is difficult to quantify risks from individual causes, such as bird strikes.

11.3.30 The indications are that the risk of a major bird strike accident is probably below 1 in 10-7 for UK civil aerodromes as a whole (i.e. “remote”), although individual airports will have different hazard levels because of local conditions, and as insufficient aircraft movements have been accrued and most airports have not suffered a major accident caused by birds, precise levels for each airport are difficult to quantify. However, a precautionary approach to bird strike mitigation encourages the use of bird hazard management practices, no matter what the expected hazard probability.

Risk Assessment

11.3.31 The risk level for an airport is determined by combining the severity and probability of the hazard to determine its tolerability and whether it must be reduced. Numerical values (e.g. 1-4) are assigned for the severity and probabilities as defined above, with higher numbers for greater hazards and severity and combined to arrive at a numerical value that can be compared with pre-determined and agreed safety values. Whilst insufficient data may be available to determine quantitative risk assessments for an individual aerodrome, this is not considered a serious problem because the next stage, assessing tolerability (see below), tends to ‘smooth out’ the numerical boundaries between hazard and probability levels.

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Risk Tolerability

11.3.32 When the risk has been determined, the score can then be used to determine whether the risk is acceptable, at a level that requires on-going review, or is unacceptable and must be reduced to a lower category. This way of looking at hazard, probability and tolerability can be expressed as a matrix as shown in Table 11.8 below:

Table 11.8 Risk Tolerability Matrix CATASTROPHIC Review Unacceptable Unacceptable Unacceptable Unacceptable HAZARDOUS Review Review Unacceptable Unacceptable Unacceptable MAJOR Acceptable Review Review Review Review MINOR Acceptable Acceptable Acceptable Acceptable Review EXTREMELY EXTREMELY REMOTE REASONABLY FREQUENT IMPROBABLE REMOTE PROBABLE

11.3.33 When the bird strike hazard is considered in the above terms, it can be seen that, in principle, effective mitigation measures are always required to reduce it to a lower category, because of the possibility of a catastrophic accident.

Risk Reduction

11.3.34 An ‘unacceptable’ risk assessment must be reduced and where it falls between ‘acceptable’ and unacceptable, it should be reduced to a level As Low As Reasonably Possible (ALARP principle). Mitigating action may be aimed at reducing the severity of the hazard, its probability, or both. To reduce the hazard of birds on aerodromes, the approach is to reduce the probability of birdstrikes by avoiding the presence of birds in the vicinity of aircraft, by one means or another.

11.4 Baseline Environment (Existing Conditions Scenario)

Key Sites of Ornithological Importance

11.4.1 For non-ornithological ecological information please see Chapter 10 (Ecology and Nature Conservation).

Internationally Designated Sites

11.4.2 The Dungeness to Pett Level SPA lies approximately 500m east and 200m south of the airports southern boundary and extends southwards to within 1km of the Dungeness Nuclear Power Station, within the Romney Marsh Natural Area. The site is designated primarily for its ornithological interest and supports populations of European importance for breeding common tern (Sterna hirundo), little tern (Sterna albifrons), Mediterranean gull (Larus melanocephalus) and overwintering Bewick’s swan (Cygnus columbianus), as well as internationally important populations of overwintering shoveler (Anas clypeata).

11.4.3 The site also supports nationally important populations of gadwall (Anas stropera), pochard (Aythya farina), little grebe (Tachybaptus ruficollis), cormorant (Phalacrocrax carbo), coot (Fulica atra), smew (Mergellus albellus), little stint (Calidris minuta) and ruff (Philomachus pugnax) and it is considered to be of local importance for its

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populations of marsh harrier, hen harrier, merlin, peregrine, short-eared owl, aquatic warbler, spotted crake and sandwich tern.

11.4.4 There are current proposals to extend the site boundaries in the near future to reflect recent changes in local bird populations. In particular, the creation of a new wetland at Cheyne Court means that many Bewick’s swans tend to roost there or at the nearby farm reservoirs, rather than at Dungeness, and in recent years they have only used the gravel pits in the existing SPA when Cheyne Court has been dry in autumn. The swans in particular also tend to feed on the arable fields on Walland Marsh (see below) and it is because they may now both feed and roost outside of the SPA for much of the time that consideration is currently being given to changing the SPA boundary.

11.4.5 Since its initial designation, a number of other species also meet the thresholds of the SPA selection guidelines. These include wintering red-throated diver, bittern, hen harrier, golden plover, breeding bittern and sandwich tern, as well as the total assemblage of more than 20,000 wintering waterfowl, as shown in Table 11.9.

Table 11.9 Dungeness to Pett Level: Species satisfying over-wintering thresholds for European and international importance based on WeBS data 1998/9 – 2002/3 Species Peak Counts SPA value Red-throated diver 189 3.8% GB population Great Crested Grebe 824 5.2% GB population Cormorant 246 1.1% GB population Bittern 3 3.0% GB population Bewick’s Swan 147 1.8% GB population European White-fronted Goose 430 7.4% GB population Wigeon 3,107 0.8% GB but >2,000 indivs Gadwall 216 1.3% GB population Shoveler 495 1.2% International population Golden Plover 4,177 1.7% GB population Lapwing 12,106 0.6% GB but >2,000 indivs Sanderling 251 1.2% GB population Waterbird assemblage 33,800 + >20,000 indivs -

11.4.6 Despite having only a few years of consolidated (non-WeBS) data, Natural England further advises that the presence of several other species in the area also qualifies the site for international designation. These are:

• Bittern: Between 1997-2002 at least 4 individuals and possibly as many as 9, have been recorded over-wintering in the areas around Dungeness/Lade, Cheyne Court, and Rye Harbour/Pett Level/Icklesham. These represent at least 4% of the GB wintering population of this Annex I species.

• Hen harrier: Up to 17 individuals (2003/4) have been recorded roosting and the requirement for the “regular occurrence” of over 8 birds has been met. The

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mean of the three available peak winter counts is 13 individuals, representing 1.7% of the GB wintering population.

• Mute swan: Between 346 and 714 individuals have been recorded in the last three seasons and both the GB 1% threshold (375 individuals) and the international importance threshold for Ramsar qualification (380) have been exceeded by the 2002/3 and 2003/4 counts. The three year peak mean of 487 individuals represents 1.3% of the GB biogeographic population.

• Whimbrel: On passage whimbrel roost at Rye Harbour and the five year peak mean (1997-2001) of 298 birds (representing 6.0% of the GB passage population) use the SPA (including the proposed extensions) for feeding. The threshold for national importance is 50 individuals. 11.4.7 The area (which also includes the SSSI - see below) has been proposed as a Potential Ramsar Site as it supports over 20,000 waterfowl, over 1% of the NW and Central European non-breeding population of shoveler, and a significant population of wintering mute swans. It is also designated as an Important Bird Area (IBA) primarily for the breeding terns and wintering waterfowl it supports. The IBA includes areas of inland wetlands, grazing-marsh and arable land, and the two shingle- beaches at Dungeness and Rye Harbour. The Dungeness RSPB Reserve, described in more detail below, is also included within the SPA.

Nationally Designated Sites

11.4.8 In addition to the internationally designated sites, six sites of national importance are located near the LAA site, namely the Romney Marsh Natural Area, the Dungeness RSPB Nature Reserve and the Dungeness, North Lade, Walland Marsh and Cheyne Court SSSIs. The locations of these are shown in Figure 10.1 and the site citations are provided in Appendix 10.3.

11.4.9 The Romney Marshes Natural Area embraces the vast shingle beaches and flat marshland between Hythe in Kent and Pett in Sussex. The Natural Area is notable for the extent of its wetland habitats ranging from the large shingle expanse of Dungeness to the drainage ditches and small ponds of the surrounding farmland. These varied habitats contain a highly diverse and in some cases highly specialised flora and fauna. The Natural Area contains National Nature Reserves (NNR), Local Nature Reserves (LNR), Sites of Special Scientific Interest (SSSI), a Special Area of Conservation (SAC), a Special Protection Area (SPA), a proposed Ramsar site (internationally important wetland) and many Sites of Nature Conservation Interest (SNCI).

11.4.10 The Dungeness RSPB Nature Reserve to the south of the airport forms part of the Dungeness to Pett Levels SPA (it is also designated as a NNR, SSSI, Nature Conservation Review (NCR) site, and Geological Conservation Review (GCR) site and is part of the large shingle foreland which extends from Romney Marsh to the sea immediately west of the nuclear power station at the Dungeness peninsula. The reserve supports internationally important numbers of wintering shoveler and nationally important numbers of wintering Berwick’s swan, white fronted goose, wigeon, gadwall, pochard, ruff, little grebe, smew, coot and cormorant, as well as nationally important numbers of breeding gargany, gadwall, pochard and water rail.

11.4.11 In addition to the national and international interest, approximately 60 species of birds breed in the Reserve each year (including around 750 pairs of waterfowl and waders) and overall, some 121 bird species have been recorded there (see Appendix 11 for

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details). These have included some 64 amber listed (nationally declining) and 17 red listed (nationally threatened) species. As described in Section 11.3.6, the most common species, which account for over 80% of all records from the reserve, are starling, tufted duck, sand martin, teal, wigeon, pochard, swallow, shoveler, herring gull, black-headed gull, lapwing, greylag goose and golden plover.

11.4.12 The islands in the flooded gravel pits within the reserve have supported internationally important breeding seabird colonies in the past and common tern and Mediterranean gull colonies have been particularly valued. Numbers of breeding seabirds (common tern, sandwich tern, Mediterranean gull, and black headed gull) have declined since the 1980’s but the RSPB’s management objective is to restore numbers to their former levels by annual vegetation and soil clearance to leave freshly exposed shingle, as well as through control of predators (including mink and herring gulls and lesser black backed gulls on Burrow’s Pit). In conjunction with the Rye Harbour LNR, the area still supports the largest colony of breeding terns in Kent (primarily common and sandwich terns Sterna hirundo and S. paradisaea), with internationally significant numbers present.

11.4.13 In addition to the gravel pits with their low islands and the natural shingle wetlands, further breeding bird assemblages are associated with areas of sand dune and saltmarsh. The area is also an important landfall for nocturnal migrants, especially warblers, chats and thrushes and the movement of diurnal migrants following the coastline can often be seen. The Lade Pits provide significant habitat to waders, geese and waterfowl whilst the nearby beach at Lade Sands holds nationally and internationally important numbers of wintering great crested grebe and sanderling (Calidris alba) respectively.

11.4.14 The 1946 ha Walland Marsh SSSI is located approximately 7km west of the airport and includes most of the few remaining areas of unimproved and permanent grassland on the reclaimed local silty and peaty soils of the Walland Marsh and The Dowels. These long-established grazing marshes together with the adjoining pasture and arable land are intersected by a network of integrated field dykes and larger waterways with slow moving, nutrient-rich and sometimes brackish waters. The site is particularly noted for the botanical diversity of the dykes and the rich invertebrate fauna, but is also of interest for it’s breeding and wintering birds which include internationally important numbers of Bewick’s swan and nationally important numbers of white-fronted goose, wigeon, gadwall, garganey, shoveler, golden plover, lapwing and ruff, with up to 30,710 non breeding waterfowl recorded (1997/98).

11.4.15 The 69ha Cheyne Court SSSI is located approximately 6km west of the airport and south east of Walland Marsh. The site supports internationally important numbers of wintering Bewick’s swans, European white-fronted geese, wigeon, gadwall, shoveler, bittern and golden plover.

11.4.16 The Romney Warren SSSI is important for feeding waders and supports nationally important numbers of wintering sanderling.

11.4.17 The North Lade SSSI is designated for it geomorphological rather than ornithological value.

11.4.18 The Dungeness SSSI is of importance for the variety ofe birds which breed and overwinter. Several breeding and wintering species are present in number of national importance, whilst numbers of wintering sanderling Calidris alba reach internationally important numbers.

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Wetland Bird Survey (WeBS) Desk Study Data

11.4.19 The Wetland Bird Survey (WeBS) is the monitoring scheme for non-breeding wildfowl/waterfowl in the UK which aims to provide the principal data for the conservation of their populations and wetland habitats. The data collected is used to assess the size of waterbird populations, determine trends in numbers and distribution and assess the importance of individual sites for waterbirds, in line with the requirements of international conservation Conventions and Directives.

11.4.20 Continuing a tradition begun in 1947, volunteer counters participate in synchronised monthly counts at wetlands of all habitat types, mainly during the winter period. Within the vicinity of LAA there are nine main sites covered by WeBS, the locations of which are shown in Figure 11.3. These nine sites are shown in Table 11.10 overleaf.

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Table 11.10 Summarised WeBS data for the LAA Area Site Key Findings Dungeness Burrowes Pit (with its four main island groups) provides nesting and roosting sites for a variety of bird species, whilst the many other lakes on the RSPB reserve (including the New Excavations and, more recently, an area of shallow water on Dengemarsh) provide ideal habitat for a variety of ducks and Reserve waders, and should eventually (once reedbeds have become established) provide nesting habitat for species such as bittern, marsh harrier and (22791) bearded tit. Overall, the many artificial wetlands that have been created have, with RSPB protection and management, become increasingly important for nationally important populations of wildfowl. The seabird colony has by contrast reduced in size since the 1980s, but habitat suitable for the return of larger populations of seabirds is being maintained. The WeBS counts for the winters 1999/2000 – 2003/2004 (see Appendix 11.1 and 11.2) confirm that the Dungeness RSPB Reserve supports a very wide variety of waterbirds. More numerous species (five-year winter mean peaks & five-year winter peak counts in parentheses) include little grebe (25, 43), great crested grebe (30, 41), cormorant (209, 288), greylag goose (128, 409), wigeon (1605, 1955), gadwall (121, 156), teal (841, 1611), mallard (348, 55), pintail (95, 162), shoveler (355, 494), pochard (301, 532), tufted duck (334, 535), goldeneye (23, 26), smew (23, 33), ruddy duck (180, 263), and coot (667, 765). Autumn numbers of cormorant (332, 625), shoveler (284, 378) and pochard (722, 862) are of national importance as are the winter numbers of shoveler and smew. The fields at Dengemarsh hold a regular herd of mute swans (56, 83) and are sometimes joined by Bewick’s swan (15, 25) and whooper swan (7, 10). Waders are also a feature of this area including golden plover (520, 1500), lapwing (1227, 3200) and ruff (22, 55), the latter being of national importance. Bittern is now recorded annually, mainly in winter. Most records relate to singles, but two and three have been recorded on several dates and five in January 2003. Birds of prey regularly hunt over the reserve including hen harrier, marsh harrier, peregrine and merlin. Some 60 species of birds are reported to breed on the reserve each year, including approximately 750 pairs of wildfowl and waders. These include cormorant, gadwall, shoveler, pochard, grey partridge, oystercatcher, lapwing, avocet, redshank, black-headed gull, common gull, herring gull, lesser black-backed gull, common tern, yellow wagtail, wheatear, bearded tit, linnet, reed bunting, yellowhammer and corn bunting. Long Pits The Long Pits, which comprise two ancient gravel diggings, lie to the east of the Dungeness RSPB Reserve and are numerically the least important (22793) site in the area covered by WeBS (see Appendix 11.2). Species typical of the site include little grebe, mallard, tufted duck, moorhen and coot though numbers, except for coot (40, 50), rarely reach double figures. A bittern was recorded in March 2004.

Lade Pit Lade Pit is a large flooded gravel pit situated to the east of Lydd Airport and just inland of the coastal development between Lydd-on-Sea and (22796) Greatstone-on-Sea. The WeBS counts for the site (see Appendix 11.2) confirm that a wide variety of waterbirds are present in winter including great crested grebe (12, 16), Canada goose (40, 60), mallard (119, 150), pochard (125, 200), tufted duck (117, 130), goldeneye (8, 12), smew (10, 24), ruddy duck (20, 43) and coot (120, 270). Numbers of smew are of national importance. Uncommon species such as divers, the rarer grebes, long- tailed duck and goosander are sometimes recorded. Lade Sands At low tide a large expanse of sandy mudflats is exposed along the eastern shore of the Dungeness Peninsular, providing an attractive food source for (22403) large numbers of gulls (Dungeness Bird Observatory recorded 90,000 in 2000) and waders. The more numerous species recorded by WeBS (see Appendix 11.2) include oystercatcher (460, 832), grey plover (56, 74), knot (303, 350), sanderling (221, 330), dunlin (739, 1200), curlew (158, 349) and redshank (83, 152). Winter numbers of sanderling are of national importance. Offshore there are large mid-winter gatherings of red-throated diver (187, 800) and great crested grebe (824, 1600), both of which are of national importance.

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Site Key Findings Brett Pits The Bretts Pits, which lie to the west of the Dungeness RSPB Reserve and south of Lydd, hold a variety of waterbirds though the numbers are (22794) generally small. Typical species recorded by WeBS (see Appendix 11.2) include great crested grebe (4, 6), cormorant (17, 31), mallard (8, 13), pochard (14, 17), tufted duck (9, 17) and coot (55, 93). Fieldwork over the course of the 2005/06 winter suggests that the pits may now be less attractive to wildfowl, probably due to disturbance by water sports. The fields to the east of the pits, which form part of Dengemarsh, hold a regular herd of mute swans (53, 93). These are often joined by whooper swans (5, 10), a once rare winter visitor which has become regular since 1996, and occasional herds of Bewick’s swans (7, 30). The fields also hold flocks of lapwing (333, 500), golden plover (108, 200) and a few ruff (5, 15). Whitehalls The reed-fringed Whitehalls Gravel Pits lie just to the north of Lydd adjacent to the B2075. The WeBS counts (see Appendix 11.2) show that the site Gravel Pits holds generally small numbers of waterbirds including typical species such as wigeon (143, 180), mallard (30, 73), pochard (23, 43), tufted duck (17, (22797) 40) and coot (57, 77). A herd of mute swans (50, 75) frequents the fields adjacent to the pits while variable numbers of golden plover (140, 200), lapwing (317, 500) and curlew (23, 44) are also present in the winter. Lydd West The Lydd West Gravel Pits are three small pits which lie just to the northwest of Lydd. The more numerous species recorded by the WeBS counts Gravel Pits (see Appendix 11.2) include little grebe (9), wigeon (316), mallard (43), tufted duck (24), pochard (20) and coot (83) though a wide variety of other (22796) wildfowl occurs such as shelduck (6), shoveler (8), goldeneye (2) and smew (2). The fields to the north of the pits hold a regular herd of mute swans (32) and flocks of Canada geese (30) and greylag geese (87). Scotney Pit Scotney Pit is a large maturing gravel pit that straddles the border of Kent and East Sussex alongside the Lydd-Rye road. The surrounding areas are (22792) largely pasture, with some flooded pools adjacent to the road at the eastern end. As with other pits in the area, Scotney attracts a variety of waterbirds in the winter. Typical species recorded by WeBS (see Appendix 11.2) include great crested grebe (13, 19), cormorant (38, 90), mute swan (33, 110), white-fronted goose (227, 355), greylag goose (473, 570), Canada goose (86, 177), wigeon (794, 1100), mallard (85, 139), shoveler (41, 70), pochard (310, 500), tufted duck (99, 175), coot (544, 652), golden plover (700, 2000) and lapwing (1090, 2000). More unusual species are often recorded. These include divers, black-necked and Slavonian grebes, tundra bean goose, scaup, smew and little stint. Scotney Pit is the only regular wintering site for white-fronted geese in East Sussex and is of national importance for this species. Another important feature of the area is the presence of a hen harrier roost which held a minimum of 11 different birds in mid-February 2004 (Sussex Bird Report 2004). Walland Walland Marsh covers a very large area extending north from the Kent-East Sussex border to a line between New Romney in the east and Appledore Marsh in the west, though only a small part is covered by WeBS (see Appendix 11.2). This area, which has been sympathetically managed for nature (22381) conservation, attracts very large numbers of waterbirds including mute swan (136, 189), Bewick’s swan (124, 220), white-fronted goose (229, 450), greylag goose (126, 160), wigeon (2110, 3200), gadwall (83, 110), teal (870, 1800), mallard (232, 500), pintail (114, 135), shoveler (250, 520), coot (185, 270), golden plover (2060, 5000), lapwing (7400, 17500), ruff (13, 32) and snipe (74, 160). Spring numbers of ruff (14, 32) are of national importance as are the winter numbers of Bewick’s swan, white-fronted goose and ruff. The network of drainage ditches that dissect Walland Marsh are likely to hold significant populations of reed and sedge warblers and reed buntings while other breeding species include yellow wagtail, tree sparrow and corn bunting, all of which have shown significant recent national declines.

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Wintering Bird Surveys 2004/05 and 2005/06

11.4.21 Areas of particular ornithological interest recorded during the wintering bird surveys are presented in Table 11.11 below with further discussion on individual species of note in the area included in Section 11.4.21.

Table 11.11 – Areas of ornithological interest recorded during the wintering bird surveys SITE Field Survey Data: Winter 2004/05 and 2005/06 Dengemarsh (arable fields 2005/06: Variable numbers of lapwing and golden plover and a fairly to S of Lydd to Dungeness regular herd of up to 43 mute swans. Two Bewick’s swans noted with a Rd & S to Manor Farm herd of mute swans near Cockle Bridge in the November count. Bretts Pits Used for water sports so very few birds observed. Lydd West Gravel Pits (TR 2004/05: One smew (16 Feb). The Dungeness gravel pits as a whole 035212) are of national importance for this species regularly supporting a wintering population of up to 40 birds. A flock of 300 wigeon was noted (northwest of Lydd in the grazing on the banks of one of the pits while in the fields to the north of vicinity of Dering Farm) the pits there was a herd of 17 mute swans. 2005/06: Small numbers of wildfowl and waders, including a flock of up to 250 wigeon which grazed on the gently sloping banks of the pit. The fields to the north of the pits were often frequented by a herd of up to 70 mute swans and sometimes by smaller flocks of Canada and greylag geese. Whitehalls Gravel Pits (TR 2004/05: small numbers of wintering wildfowl (54 wigeon, 3 teal, 2 049221) opposite airport tufted duck and 18 pochard) on 21 Feb. Fields to the west of the pit approach road (05:06 refers held a herd of 29 mute swans. to TR 051221) (pit appears to be being filled in) 2005/06: Small numbers of wintering wildfowl, especially pochard and wigeon. Fields to the west of the pit (towards birds kitchen) used by a herd of up to 39 mute swans. Fields adjacent to and 2005/06: a regular herd of up to 70 mute swans and variable numbers immediately S of the airport of lapwing and golden plover. approach road Northern end of the airport 2004/05: held a notable flock of 25 tree sparrows and 7 corn buntings in the vicinity of Northlade on 21 Feb. (both red listed species of high conservation concern). Also (TR 067222) 13 red-legged partridges and 10 stock doves. A marsh harrier was seen on 7 Mar and a hen harrier at New Romney on 18 May. Gravel pit to the north of 2004/05: 20 gadwall, 7 tufted duck and 4 goldeneye on 7 Mar. Lade Pit (TR 077222) Fields to the northwest of 2004/05: herd of over 100 Bewick’s swans on 16 and 21 Feb; sites Swamp Farm (TR 033235) which hold 70 or more birds are considered to be of national importance for this amber listed species. 2005/06: only Bewick’s swans recorded at the site were 21 in December 2005 which were associating with mute swans to the south of swamp farm. The latter site also held two whooper swans in January and February 2006.

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SITE Field Survey Data: Winter 2004/05 and 2005/06 Areas of permanent sheep 2004/05: Mixed flocks of black-headed and common gulls and lapwing. pasture throughout the Counts on 21 Feb included 21 black-headed and 54 common gulls in study area TR 0420 and 27 black-headed and 119 common gulls in TR 0321 while on 7 Mar there were 15 lapwing in TR 0624, 153 lapwing in TR 0623, and 89 lapwing, 82 black-headed gulls and 30 common gulls in TR 0523. 2005/06: Mixed flocks of black-headed and common gulls with lapwing, golden plover and the occasional ruff, as above. Lade Sands (22403) 2004/05: supports a wide variety of shorebirds including nationally between Dungeness and important numbers of sanderling. species were recorded (7 Mar) Littlestone-on-Sea included oystercatcher, ringed plover, grey plover, knot, sanderling, dunlin, bar-tailed godwit, curlew, redshank and turnstone.

11.4.22 Overall the winter surveys of 2004/05 and 2005/06 demonstrate that in addition to the designated conservation sites and WeBS survey sites there are a number of other sites of ornithological interest within a two mile radius of Lydd Airport. There are also large parts of the study area, especially extending northwards from the airport towards New Romney, that appear more or less devoid of birds in the winter months.

11.4.23 By far the most important ornithological features observed were the wintering herd of over 100 Bewick’s swans which in the early part of 2005 were to be found in the vicinity of Swan Farm, Denge Lane. The absence of counts of this magnitude in the study area over the winter of 2005/06 may be attributable to birds now using the recently created wetland habitat on Walland Marsh where up to 138 were noted in January 2006. The presence of several large herds of mute swans within the study area was also notable. Given that the number of swans recorded varied considerably from month to month and from site to site, it would appear that the birds move widely throughout the area occupying several different roosting sites.

11.4.24 Numbers of grassland plovers (primarily golden plover and lapwing) recorded varied considerably from month to month, with peak numbers recorded in the early part of the winter followed by a marked decline later. This may have arisen as a result of the onset of harsh weather when the fields become frozen causing the birds to leave the area and seek alternative feeding areas. Another notable feature of the October 2005 survey was the large number of herring gulls recorded roosting on the fields to the west of Greatstone-on-Sea at Romney Salts.

Breeding Birds Surveys

11.4.25 Areas of particular ornithological interest recorded during the breeding bird surveys are presented in Table 11.12 below and Figure 11.1. Further discussion on individual species of note in is included in Appendix 11.5 and 11.6. (Numbers in brackets refer to breeding pairs).

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Table 11.12 – Areas of ornithological interest recorded during the breeding bird surveys Site Field Survey Data: Spring / Summer 2005 A 15.5 ha pocket of arable land to Coot (1), skylark (2), yellow wagtail (1), reed warbler (3), sedge the south of the access road with warbler (2), reed bunting (1) and corn bunting (1). A pair of reed-fringed drainage dykes kestrels from a nearby nest box used this area for hunting. Sheep pasture & reed-choked Moorhen (1), skylark (3), yellow wagtail (1), reed warbler (1), drainage ditches between the linnet (1), reed bunting (2) and corn bunting (1 pair). Small airport and golf course post-breeding flocks of starlings were also present Small tongue of land beyond the As above including skylark, yellow wagtail, reed bunting and northern end of the runway corn bunting. surrounded by arable land Area enclosed by the perimeter Rough grassland adjacent to the runways holds good numbers fence of the airport. of skylarks and a few meadow pipits and is used for hunting by a pair of barn owls that reported to be nesting in a nest box by the terminal building. Pairs of stock doves were noted using the aircraft hangar adjacent to the airport buildings and also the ruined buildings at Northlade. A tree sparrow in the latter area on 6th July was suggestive of local breeding. Main pond adjacent to the runway Only a single singing reed warbler on 18 May. Single hobby, turtle dove and cuckoo were noted in the vicinity. Site Field Survey Data: 2006 A – Area enclosed by the perimeter The rough grassland adjacent to the runways holds good fence of the airport (surveyed in numbers of skylarks and a few meadow pipits and a pair of barn 2005) owls as in 2005. The drainage ditches support reed and sedge warblers and reed buntings while the various gravel pits are attractive to small numbers of waterbirds including little grebe, tufted duck and coot. The buildings at Northlade support nesting stock dove and tree sparrow and a roosting barn owl. B – Area to the west of the airport The large arable field adjacent to the airport car park held some (partly surveyed in 2005, extended yellow wagtail, reed bunting and corn bunting. The drainage in 2006) ditch which runs between this field and the approach road to the airport contains open water and supports the following waterbirds: mute swan, mallard, tufted duck, coot and reed and sedge warblers in areas of reeds. Tree sparrows (one pair) nested in the fuel storage building along the approach road in 2006. More arable land and drainage ditches present south of the railway line support the same species described above. C – The area between the airport This area has sheep pasture with and drainage ditches heavily and the golf course (surveyed in choked with reeds. Few birds are supported though forage on 2005) the sheep pasture attracts post-breeding flocks of starlings. D – Golf course (surveyed in 2005) The golf course has benefited from the construction of several reed fringed lakes. Waterbirds are present in the open water (mute swan, mallard, moorhen and coot) while the reeds hold good numbers of reed warblers and a few pairs of reed buntings. Skylarks utilise the rough grass beside the fairways. E – Large arable fields beyond the Those fields planted with oil seed rape are especially attractive northern perimeter fence towards to breeding birds including good numbers of yellow wagtail, reed New Romney and Lade Pit (partly bunting and corn bunting. The drainage ditches in this area are surveyed in 2005). reed choked with little open water and support few birds. The roof of the disused portable toilet block at TR 065226 held a nesting pair of tree sparrows.

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Site Field Survey Data: Spring / Summer 2005 F – Shingle areas east and south This areas holds few birds except whitethroats which favour each from the perimeter fence (not areas of bramble and other low scrub. surveyed in 2005) G – Disused flooded gravel pits These waterbodies are attractive to breeding waterbirds between the railway line and including greylag and Canada goose, mute swan, tufted duck, Boulderwall Farm, some within the moorhen and coot. Areas of reeds attract good numbers of RSPB reserve (not surveyed in reed and sedge warblers and reed buntings. Two pairs of 2005) oystercatchers were also present in this area in 2006.

Key Species of Birdstrike and Conservation Importance

Gulls and Terns

11.4.26 Given its coastal location, gulls are inevitably numerous in the region around LAA, and will be a significant element of the birdstrike hazard. There are known winter roosts at the Lydd gravel pit and on the coast at Littlestone, Lydd, Dungeness and Rye, with some 90,000 gulls (Dungeness Bird Observatory, 2000). There There are also a number of nesting colonies of black-headed and herring gulls around the Denge Peninsula so that, as with many coastal aerodromes, the gull hazard will continue year-round. Daily movements are likely to be concentrated along the coasts and, for black-headed gulls especially, on a broad front from colonies and roosts to inland feeding areas. Further information on the abundance of gulls and Terns at LAA is provided in Table 11.13.

Table 11.13: Abundance of Gulls and Terns near LAA Species Status Comments Common tern International Summer visitor (April to August) and passage migrant. importance Breeding occurs during this time on shingle beaches, (breeding) around lakes, ponds, estuaries and coastlines particularly on the Burrowes Pit islands and formerly on the ARC and Water Tower pits. Has declined recently. The peak breeding count is 350 pairs in 1982, 1986 and 1988 (approximately 2% of the national population, some 14,000 pairs (JNCC, 2000)) compared with the 2000-2004 breeding five-year mean of just 49 pairs. Little tern International Summer visitor (April to September) to the British Isles. (breeding) Breeds along coastal sand or shingle beaches during this time. Feeding on small fish and invertebrates. They are in an unfavourable conservation status and historically numbers throughout Europe have declined. Greatest threat in the UK is considered to be from human disturbance particularly in the south-east due to high human population levels. The Dungeness SPA supports 35 breeding pairs (JNCC, 2000), or 1.5% of the national population of 2,400 pairs. Sandwich tern International Summer visitor and passage migrant. Formerly nested on importance the Burrowes Pit islands. Nesting was first noted in 1978 (breeding) with seven pairs, the colony then increased to a peak of 350 pairs in 1985 and 1986. Last nested in 1997. Common breeder historically.

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Species Status Comments Mediterranean International Mainly summer visitor. Has bred. Until the 1950s this was gull importance a very rare bird in the UK, but today it is widespread in (breeding) winter with a small resident breeding population along the south east coast, particularly Kent. This population is understood to represent the north-western limit of its global range, it is on the RSPB amber list. It prefers coastal areas, particularly near lakes, lagoons and marshes The first successful breeding attempt in 1979 was also the first breeding record for Kent. Breeding then occurred annually on the RSPB reserve until 1997 except for 1980 and 1995, with a maximum of six pairs in 1992. The UK breeding population is thought to be approximately 100 pairs. Has increased as a non- breeding summer visitor with a peak count of 43 in June 2003. Black headed Local Common resident. A declining breeding species – the gull populations not colony that nests on the islands of the Burrowes Pit within of particular the RSPB reserve has dwindled to just a handful of pairs. conservation Formerly bred on the open shingle of the ARC Pit. The status highest breeding counts are 1150 pairs in 1979 and 1100 pairs in 1980 compared with the 2000-2004 breeding five- year mean of just 75 pairs. Common breeder historically. Common Gull Local Common resident. Breeds annually in small numbers on populations not Burrowes Pit, New Excavations and Dengemarsh and of particular formerly bred on the Water Tower Pits. The best year conservation was 1996 with 13 pairs compared with the 2000-2004 status breeding five-year mean of 11 pairs. Dungeness is the only site where this species breeds in England. Herring gull Local Common resident. Breeds annually on Burrowes and populations not ARC Pit with a peak of 129 pairs in 1997 compared with of particular the 2000-2004 breeding five-year mean of 70 pairs. The conservation peak counts are 30,000 in February 2000 at Lade Sands status and 8,000 in February 2001 on Burrow’s Pit.

Grassland Plovers and Coastal Waders

11.4.27 The grazing marsh and gravel pit habitats of the Peninsula provide ideal wintering habitats for lapwing and golden plover and the area is likely to experience “weather movements” causing mass influxes in response to hard winter weather further north. Given the peninsula’s location relative to coastal and cross channel migration routes, influxes of a number of wader species on passage may be expected in autumn and spring, especially in poor weather and especially on the runway. These species present a significant element of the bird strike hazard. Further information on the abundance of grassland plovers and coastal waders at LAA is provided in Table 11.14.

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Table 11.14: Abundance of Grassland Plovers and Coastal Waders at LAA Species Status Comments Golden International Regular winter visitor plover importance Lapwing European Common resident. Breeds annually – 47 pairs recorded in 2004 importance on the RSPB reserve with 47 pairs. The 2000-2004 breeding five-year mean is 44 pairs. Peak counts of 5000 in December 1997 and 4800 in November 1997 compared with 17,500 at Walland Marsh in February 2000. Ruff National Passage migrant and declining winter visitor. Often present in importance winter in the Dengemarsh area with peak counts of 113 in (wintering) December 1997 and 101 in December 1978 though numbers have declined in recent years. The 1999-2003 five-year winter mean is 40. Little stint National Winter visitor importance Sanderling Local populations Passage migrant and winter visitor. The peak count at Lade not of particular Sands in recent years is 330 in March 2000. The 1999/2000 – conservation 2003/04 five-year peak mean for this site of 221 is of national status importance. Whimbrel International Rye harbour (passage) importance Oystercatch National Resident. Breeds annually with a peak count on the RSPB er importance reserve of 30 pairs in 2001 and a 2000-2004 breeding five-year mean of 26 pairs. At Lade Sands the peak count in recent years is 832 in November 1999 compared with the 1999/2000 – 2003/2004 winter five-year peak mean of 460. Little Ringed Local populations Scarce breeding summer visitor and passage migrant. A pair Plover not of particular bred successfully on the RSPB reserve in 2003. conservation status Avocet National Passage migrant and rare breeder. Colonisation as a breeding importance species on the RSPB reserve commenced in 1999, with a maximum of four pairs in both 2003 and 2004. The peak counts at this site are 74 in June 1980 and 70 in December 1982. Snipe National Fairly common winter visitor. At Walland Marsh the peak WeBS importance counts for the period 1999/2000 – 2003/2004 are 200 in October 2001 and 160 in December 2000. The autumn and winter five- year peak means are 113 and 74 respectively. Redshank National Resident. Breeds annually in small numbers mainly in the importance Denge Marsh area with a maximum of 14 pairs in 1998 and 2000. The 2000-2004 breeding five-year mean is 12 pairs.

Raptors

11.4.28 The involvement of diurnal raptors and owls in UK bird strikes appears to be increasing, perhaps as a consequence of ecological pressures (shortages of permanent rough grassland) “forcing” them to hunt on airfields, but in some cases local population increases are implicated (particularly with buzzards in recent years). Even the barn owl and kestrel, the most common raptors involved in bird strikes, are sufficiently large to cause engine damage. Further information on the abundance of raptors at LAA is provided in Table 11.15.

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Table 11.15: Abundance of Raptors at LAA Common Con. Status Comments Name Hen International Winter visitor. At least 11 different birds were present at a harrier Importance roost near Scotney Pit in February 2005. Hunting birds may be encountered anywhere on the Dungeness peninsular during the day. Marsh National Resident. Numbers on the RSPB reserve have increased harrier Importance in recent years, in line with the national trend, with peak counts of seven in September 1999, ten in August 2003 and six in November 2004. Merlin National Local but no specific information Importance Peregrine National Occasional Importance Kestrel European Recorded in 2005 surveys as breeding. Importance Short- European Occasional eared owl Importance Long- Local populations Scarce resident. A pair probably bred on the RSPB eared Owl not of particular reserve in 2003. conservation status Barn Owl European A pair probably bred on the RSPB reserve in 2002 and Importance 2003 where up to two birds were recorded over the winters of 2003/04 and 2004/05. These may be the pair reported to breeding in the owl nest box by the terminal building at Lydd Airport in 2005.

Waterfowl

11.4.29 The flooded gravel pits, marshes, drains and grazing marshes of the area around the airport provide ideal habitat for waterfowl and the regular occurrence of over 20,000 overwintering waterfowl and up to 750 breeding pairs of waterfowl and waders in the RSPB reserve makes the area of international importance for many species.

11.4.30 Over-wintering species present include Bewick’s swans, shoveler, pochard and smew. These species are both of conservation importance and significant bird strike hazards.

11.4.31 Further information on the abundance of and birdstrike risks associated with waterfowl at LAA is provided in Table 11.16 overleaf.

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Table 11.16: Abundance of Waterfowl at LAA Common Con. Status Comments Name Overwintering (Breeding) Bewick’s International Winter visitor arriving in mid-October from their breeding grounds in Siberia. Their favoured habitats are shallow swan Importance freshwater lakes, marshes or slow-moving rivers adjacent to extensive grassland liable to flooding, however recently an increase in foraging on agricultural land has been recorded. This maybe due to the swans continued threat by a loss of suitable habitat and man’s activities, indeed, historically numbers throughout Europe have declined. The Dungeness SPA has a population of around 179 (maximum counts have reached 284) or 2.5% of the UK wintering population (JNCC 2000), which is approximately 7,200. The once regular flock, which used arable fields on Walland Marsh by day and roosted on the ARC pit, appears now to be using recently created wetland habitat on Walland Marsh as its main roost site. Mute swan International Resident. The Dungeness peninsula holds a number of large herds of this species. Over the period 1999/2000 – Importance 2003/2004 the peak WeBS site counts were 189 on Walland Marsh in February 2002, 171 at Scotney Pit in May 2001, 164 on the RSPB reserve in July 2001, and 75 at Whitehalls Gravel Pits in January 2002. Whooper Local populations not Scarce winter visitor. Once a rare visitor, a regular wintering herd has become established in the Dengemarsh area since Swan of particular 1996. A maximum of 11 birds was seen in February 2004. conservation status White fronted National Importance Winter visitor. In some years this species can form quite large flocks whereas in others it can be scarce. The peak c goose reserve, Scotney Pit and Walland Marsh are 500 in January 1982, 355 in March 2002 and 450 in February 2002 respectively Greylag Local populations not Common introduced resident. The peak WeBS counts for the RSPB reserve, Scotney Pit and Walland Marsh are 415 in Goose of particular September 2001, 570 in December 2003, and 160 in February 2002 respectively compared with the equivalent winter five- conservation status year peak means of 128, 473 and 126. Shoveler International Resident surface feeding ducks. Approximately 1,300 birds are resident and breed in Britain, predominantly in central and Importance south eastern England. In winter, the population increases to approximately 10,000 birds with many of the resident birds moving south, being replaced by an influx of continental birds from further north. Shovelers are ground nesting birds of lowland marshes and rough grassland adjacent shallow water. Historically numbers have been declining, however breeding numbers on the RSPB reserve increased. The peak counts for this site are 755 in October 2001. The UK is thought to be home to more than 20% of the NW European population. The peak count for Walland Marsh is 520 in February 2002 and the 1999/2000 – 2003/2004 winter five-year peak mean of 250 is also of national importance. Wigeon National Importance Common, mainly winter visitor. The maximum counts on the RSPB reserve are 6100 in December 1996 and 4500 in January 1997 compared with a five-year peak mean for the period 1999/2000 – 2003/2004 of 1605. At Walland Marsh the peak count is 3200 in January 2000 and the winter five-year peak mean is 2110.

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Common Con. Status Comments Name Overwintering (Breeding) Gadwall National Importance Resident and increasing breeder. 34 pairs in 2003 is the maximum for this species on the RSPB reserve. The 2000-2004 breeding five-year mean is 24 pairs. The peak counts for the RSPB reserve are 260 in November 1995 and 223 in (National Breeding) December 1999 compared with a winter five-year peak mean for the period 1999/2000 – 2003/2004 of 121. Teal Local populations not Common, mainly winter visitor. The maximum WeBS counts on the RSPB reserve in the period 1999/2000 – 2003/2004 of particular are 1611 in November 2000 and 1232 in January 2003 compared with a five-year winter peak mean for the same period of conservation status 841. At Walland Marsh the peak count is 1800 in February 2002 and the winter five-year peak mean is 870. Pochard National Importance Common resident. Breeds in increasing numbers on the RSPB reserve with 23 pairs recorded in both 2003 and 2004. The 2000-2004 breeding five-year mean is 17 pairs. The peak counts for this site are 1000 in November 1974 and 955 in (National Breeding) October 1991. The 1999/2000 – 2003/2004 autumn five-year peak mean of 722 is of national importance. Smew National Importance Winter visitor. The peak count for this species on the RSPB reserve is 58 in both December 1995 and December 1996. The 1999/2000 – 2003/2004 five-year peak mean of 23 is of national importance. The Dungeness area as a whole is (National Breeding) probably the main wintering site for this species in Britain. Goldeneye Local populations not Fairly common winter visitor. The peak WeBS counts for the RSPB reserve and Lade Pit are 26 in January 2000 and 12 in of particular March 2000 respectively. The 1999/2000 – 2003/2004 five-year peak means are 23 and eight respectively. conservation status Tufted Duck Local populations not Common resident. The peak WeBS counts for Lade Pit, the RSPB reserve and Scotney Pit are 130 in November 2000, of particular 535 in November 2003, and 175 in December 2003 respectively compared with the equivalent winter five-year peak conservation status means of 117, 334 and 99. Gargany National Importance Summer visitor and rare breeder. The maximum counts on the RSPB reserve are 20 in August 1982 and 16 in August (Breeding) 1981. Breeding has only been proven once at this site (in 1991) but pairs have been present in most years and breeding may occasionally take place. Great Crested Local populations not Common resident Grebe of particular conservation status Little grebe National Importance Common resident (National Breeding)

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Common Con. Status Comments Name Overwintering (Breeding) Coot National Importance Common resident (National Breeding) Cormorant National Importance Common resident. Breeding first occurred in 1994 with 20 pairs on Burrowes Pit. ARC pit was colonised in 1997, the total population has since increased to a maximum of 107 pairs in 2004. The 2000-2004 breeding 5-year mean is 76 pairs. (National Breeding) Roosts occur on the islands of Burrowes and ARC Pits with peak counts of 870 in August 2004 and 625 in August 2001. The 1999 – 2003 autumn five-year peak mean for the RSPB reserve of 332 is nationally important. Bittern Local populations of Scarce, mainly winter visitor, but has occurred in all months. Numbers in winter have increased considerably in recent conservation status years on the RSPB reserve. Most records relate to singles, but twos and threes have been recorded on several dates and five in January 2003. Water rail Local populations of Resident. Peak numbers occur in winter when the small breeding population (maximum 12 pairs in 2003) is supplemented conservation status by immigrants. The peak counts on the RSPB reserve are 40 in November 1975 and 20 in April 1969. Note: bittern (3) red-throated diver (189), spotted crake also nationally imp. Bewick Swans Roost at Cheyne Court & nearby farm reservoirs feeding Walland Marsh

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Gamebirds

11.4.32 This is a high-risk group and numbers at Lydd are higher than at most UK airports because of local game rearing and shooting practices. The main hazard identified at present involves pheasants, but grey and red-legged partridges are also present and constitute a significant hazard. Grey partridge (Perdix perdix) is of particular conservation value, and whilst the breeding population on the RSPB reserve declined in the 1970s it has since stabilised with a 2000-2004 breeding five year mean of six pairs.

Corvids

11.4.33 There are relatively few stands of trees on the peninsula suitable for rookeries, but there is a rookery in Lydd village within 2 miles of the airport, sufficiently close to cause year- round influxes, but especially in early summer when young rooks fledge. Rooks, carrion crows and jackdaws congregate around feeding troughs and sheep in the pastures at Forty Acre Farm and on the golf course. Territory-holding carrion crows are a permanent presence on the airfield in daylight hours.

Starlings

11.4.34 With a history of causing birdstrike accidents, the starling is the smallest species regarded as a significant risk to air safety in the UK. Several flocks in the order of 300- 500 birds, consisting largely of juveniles, have been observed in pasture fields in close proximity to the airport. Historically, much larger flocks have been recorded in the area, numbers up to 100,000 on the RSPB reserve in 1999.

Pigeons

11.4.35 There is a small population of feral pigeons in the hangar (regularly shot to control numbers) and wood pigeons and stock doves are numerous in the local area. Stock doves were regularly seen in groups of 10 around Northlade. However, despite numerous pigeon food plants in the grass, pigeons are reported not to be a problem on the airfield. Turtle Dove (Streptopelia turtur) is of particular conservation value but is a scarce and declining summer visitor. Three pairs were confirming breeding on the RSPB reserve in 1999 and single pairs in 2000 and 2001. Single pairs probably bred in both 2002 and 2003.

Non Bird-strike Species

11.4.36 Abundance of non-bird strike species recorded within the area is shown in Table 11.17 below.

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Table 11.17: Other Bird Species Recorded Yellow Wagtail Summer visitor and passage migrant. Breeds annually on the RSPB reserve with a peak of 38 pairs in 1997 compared with the 2000-2004 breeding five-year mean of six pairs. Fieldwork in 2005 indicates that Walland Marsh is also likely to hold a significant breeding population of this declining species. Wheatear Summer visitor and passage migrant. Breeding has declined considerably on the RSPB reserve from a peak of 70 pairs in 1953. The 2000-2004 five- year mean is just six pairs. Cetti’s Warbler Increasing passage migrant, winter visitor and rare breeder. First recorded in 1975 and then almost annually until 1985 but not again until 1994. Breeding was first attempted on the RSPB reserve in 1998 and then in 2003, with two pairs in 2004. Marsh Warbler Rare summer visitor. A pair bred successfully on the RSPB reserve in 1999. Bearded Tit Resident, passage migrant and winter visitor. Breeding first occurred at Hookers Pit in 1981 with one pair present though there was no further breeding until 1992 when four pairs were present. Breeding has occurred in every year since with between one and five pairs. The highest counts are 38 in October 1992 and 32 in January 1992. Tree Sparrow Scarce resident. The highest recent counts on the RSPB reserve, where a pair probably bred in 2003, are 40 in November 2003 and 30 in September 2000. Fieldwork in 2005 in the vicinity of Lydd Airport produced a number of records of this species. A flock of 25 was seen at Northlade on 21 February, a total of ten birds at three sites on 7 March, and a flock of 60+ at Lydd West Gravel Pits on 15 November. A pair was seen near Old Romney on 22 April and a single bird at Northlade on 6 July. The likelihood is that the Walland Marsh area continues to hold reasonable numbers of this declining species. Linnet Mainly passage migrant and common breeder. A peak breeding count of 250 pairs on the RSPB reserve in 1977 has been followed by a subsequent decline with an estimated 81 pairs in 2004. Reed Bunting Resident, passage migrant and winter visitor. Increasing numbers breed on the RSPB reserve with a peak of 137 territorial males reached in 2004. The 2000-2004 breeding five-year mean is 103 pairs. The network of drainage ditches on Walland Marsh is also likely to hold significant numbers of this nationally declining species. Yellowhammer Scarce resident. Breeding numbers on the RSPB reserve have declined significantly from a peak of 25 pairs in 1985, 1990 and 1991 to just one pair in 2004. The 2000-2004 breeding five-year mean is four pairs. Corn Bunting Scarce resident and winter visitor. Breeding occurs annually on the RSPB reserve in small numbers, the peak count is nine pairs in 1997. The 2000- 2004 breeding five-year mean is three pairs. The maximum count is 500 in both December 1988 and December 1996 but typically fewer than 20 birds were present in the winter months during 2000-2005. Fieldwork on Walland Marsh in 2005 suggests that this area supports a significant breeding population of this declining species.

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Additional data from the Wintering Bird and Breeding Bird Surveys

11.4.37 The winter surveys recorded a total of some 76 bird species, including 35 amber species of medium conservation concern and 10 red species of high conservation concern. Whilst the results indicate that the airport itself and its immediate environs do not constitute an important area for over wintering birds, the larger area continues to be of significant national and international importance, and a number of species may have flightpaths in the vicinity of the airport (see Section 11.4.38 and 11.5.3).

11.4.38 In 2005, the breeding bird surveys recorded some 58 bird species, of which 14 were amber listed and 10 red listed. The data indicates that the airport and its immediate environs is of ornithological value for a number of species including breeding populations of skylark (red), yellow wagtail (amber), reed bunting (red) and corn bunting (red), all of which have declined rapidly in recent years as a results of changes in agricultural practice. The presence of yellow wagtail was considered to be of particular significance given that the species has declined by 27% in the UK since 1994. Britain holds almost the entire population of the distinctive race flavissima of this species, so population changes in the UK are of special significance.

11.4.39 The 2006 breeding bird surveys covered a larger area than the 2005 survey. The total number of bird species found was 62 (4 higher than the 2005 survey), of which 9 are red-listed, 25 are amber-listed and 28 are green-listed. 19 new bird species were recorded, including the red-listed Yellowhammer and a further 13 amber-listed species and 5 green-listed species, all not recorded in 2005. However, 15 species recorded in 2005 were not found in the 2006 survey. Overall, a significant increase in the number of amber-listed species in 2006 has occurred and there have been both losses and gains in diversity in the green-listed species group. The red list has seen little change between 2005 and 2006. The airport and its immediate environs are of very high ornithological value, supporting breeding populations of a significant number of red-listed and amber-listed species.

11.4.40 Species recorded during the winter and breeding bird surveys are shown in Tables 11.18. 11.19 and 11.20 below, with raw data from the surveys provided as Appendices 11.3 to 11.6.

Table 11.18 Species recorded in the winter survey 2004/05 Red listed Amber listed Green listed Skylark Cormorant Lapwing Little grebe Collared dove Song thrush Mute swan Knot Great crested Pied wagtail grebe Starling Bewick’s swan Dunlin Grey heron Robin House sparrow Whooper swan Bar-tailed Canada goose Wren godwit Tree sparrow Greylag goose Curlew Mallard Blackbird Reed bunting White-fronted Little egret Tufted duck Chiffchaff goose Corn bunting Wigeon Black-headed Smew Long-tailed tit gull Hen harrier Gadwall Common gull Ruddy duck Blue tit

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Red listed Amber listed Green listed Teal Herring gull Red-legged Great tit Grey partridge partridge Linnet Pochard Lesser black- Pheasant Magpie backed gull Goldeneye Stock dove Moorhen Jackdaw Shelduck Green Coot Rook woodpecker Shoveler Meadow pipit Golden plover Carrion crow Turnstone Dunnock Sanderling Chaffinch Green Stonechat Great black- Greenfinch sandpiper backed gull Snipe Mistle thrush Feral rock dove Goldfinch Oystercatcher Fieldfare Woodpigeon Ringed plover Redwing Sparrowhawk Grey plover Kestrel Ruff Marsh harrier Redshank

Table 11.19 List of species recorded in the breeding survey 2005 Red listed Amber listed Green listed Corn bunting Cormorant Blackbird Little grebe Hen Harrier Cuckoo Blue tit Long-tailed tit House sparrow Dunnock Carrion crow Magpie Linnet Green woodpecker Chaffinch Mallard Reed bunting Kestrel Chiffchaff Moorhen Sky Lark Meadow pipit Collared dove Pheasant Song thrush Mistle thrush Coot Pied wagtail Starling Mute swan Feral rock dove Red-legged partridge Tree sparrow Oystercatcher Goldfinch Reed warbler Turtle dove Stock dove Great crested grebe Robin Stonechat Great tit Rook Swallow Greenfinch Sedge warbler Whimbrel Grey heron Swift Yellow wagtail Hobby Tufted duck Jackdaw Whitethroat Jay Woodpigeon Lesser whitethroat Wren

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Table 11.20 List of species recorded in the breeding survey 2006 Red listed Amber listed Green listed Corn bunting Barn Owl Blackbird Mallard Hen Harrier Black-headed gull Canada goose Moorhen House sparrow Common gull Carrion crow Northern Wheatear Linnet Cormorant Cetti’s warbler Pheasant Reed bunting Cuckoo Chaffinch Pied wagtail Sky Lark Dunnock Chiffchaff Red-legged partridge Starling Eurasian Curlew Collared dove Reed warbler Tree sparrow Gadwall Common tern Sedge warbler Yellowhammer Green sandpiper Coot Sparrowhawk Green woodpecker Goldfinch Swift Greylag goose Greenfinch Tufted duck Herring gull Grey heron Whitethroat Honey-buzzard Little grebe Woodpigeon Kestrel Magpie Wren Meadow pipit Mistle thrush Mute swan Northern Lapwing Oystercatcher Peregrine falcon Stock dove Swallow Teal Willow warbler Yellow wagtail

11.4.41 Overall the studies have shown that the Dungeness peninsula is of considerable ornithological importance for both its wintering wildfowl and waders and its breeding bird communities. Many of the species that occur in the area are of red (high) and amber (medium) conservation concern, with at least 10 species occurring in numbers representing nationally important populations (red-throated diver, great crested grebe, cormorant, Bewick’s swan, white-fronted goose, shoveler, pochard, smew, sanderling and ruff). Many of these bird populations are highly mobile and will move regularly between different feeding and roosting areas, presenting a different type of bird-strike hazard than that found from more territorial species. As an example, the annual presence of a herd of over 100 Bewick’s swans that flies frequently between its water roosts and farmland feeding sites is of particular note in this regard. . Other swan and geese species are also likely to commute regularly between feeding sites and roosts

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although no specific sightings of such movements have yet been collected in the LLA’s vicinity.

Summary

Bird Conservation

11.4.42 It is clear that the study site is very important for wintering birds’ populations, being adjacent to internationally and nationally designated bird conservation sites. The field studies conducted over two winters (2004/05 and 2005/06) recorded a total of 76 species including 35 amber species of medium conservation concern and 10 red species of high conservation concern. There are a number of non-designated sites of ornithological interest within a two mile radius of Lydd Airport. Equally, there are large parts of the study area, especially extending north from the airport towards New Romney, that are more or less devoid of birds in the winter months, especially in harsh weather. The most important single ornithological feature of the area is the wintering herd of over 100 Bewick’s swans, which are mobile throughout the study area in the winter period. The sensitivity of the wintering bird population as determined by this study is therefore considered to be very high.

11.4.43 The airfield and its environs is also important for breeding birds and some 62 species were identified in the 2006 surveys, including 9 red-listed and 25 amber-listed which were breeding. Of particular note were the breeding populations of skylark (red), yellow wagtail (amber), reed bunting (red) and corn bunting (red). It is concluded that the sensitivity of the breeding bird population as determined by this study is very high.

Birdstrike Hazard

11.4.44 Aerodrome bird strike rates within the UK generally vary in the range 1.5 – 15 strikes per 10,000 aircraft movements and airports with efficient bird hazard control programmes generally manage to achieve rates at the low end of the scale (1.5 – 3.5 strikes per 10,000 aircraft movements). Whilst total reported bird strike numbers at an aerodrome increase proportionately to aircraft movement rates, the statistical relationship is not linear and birdstrike rates per aircraft movement actually show an inverse relationship with growth in aircraft movements as bird hazard management practices at an airport improve.

11.4.45 Relatively few birdstrikes from LAA have been recorded in the CAA birdstrike database to date, with only 16 recorded in the period 1990-2005, none of which were considered serious. The birdstrike records were made up as follows:

• 5 strikes with gulls (including one go-round and one aborted takeoff);

• 4 with pheasants;

• 4 with lapwings (all in the 1990-93 period);

• 2 with pigeon/woodpigeon; and

• 1 with a rook.

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11.4.46 LAA currently uses a combination of four bird scaring techniques to manage birdstrike hazard, namely the use of Digiscare (digitised bird distress calls); arm flapping; pistol firing of exploding projectiles; and airborne simulated distressed birds. These appear to be performing a satisfactory function at present and the CAA birdstrike database includes only 16 birdstrikes for the airportfrom the period 1990-20058, none of which were considered serious. The existing control measures also do not seem to have had an adverse impact on the conservation value of the area.

11.4.47 Whilst the numbers of birdstrikes recorded are too low to compare in any meaningful way with a “typical” UK aerodrome, the overall pattern of strikes is as might be anticipated for an airport of this nature located near the coast, with gulls and plovers figuring prominently. A disproportionate number of pheasants’ strikes were however recorded, because of local game rearing practices.

11.4.48 There have been no reported incidents with wildfowl at LAA to date, but this may be partly a consequence of the relatively low numbers of aircraft movements. Whilst it is likely that there will be a relatively higher than average risk of waterfowl strikes compared to most UK airports, it should be noted that a number of UK airports have significantly higher background risk levels. Examples of such airports are Belfast and Liverpool as they are located near tidal estuaries and thus attract large numbers of waterbirds.

11.4.49 The flocks of swans and geese that fly frequently between their water roosts and farmland feeding sites are considered to represent a “very low incidence/high hazard” birdstrike scenario due to the size and tight formations favoured by these species. Similar situations are found at the City of Derry Airport (both Bewick and Whooper swans in particular) and Glasgow Airport (Whooper swans), and whilst specific hazard management techniques are required to deal with such bird flightpath risks, once mitigated (see proposed mitigation later in this Chapter) such impacts are not considered to present an unacceptable risk.

11.5 Baseline Environment (Future Assessment Conditions Scenario)

11.5.1 Given that the airport has operated successfully alongside local bird conservation throughout its history (including at its previous peak of 250,000 ppa), its operation at the 300,000 passengers per annum capacity (the Future Assessment Conditions scenario) is not expected to significantly alter the composition or abundance of populations of bird species in the general area around the airport.

11.5.2 In particular, whilst increased numbers of aircraft flights may lead to limited incidences of birdstrike, these will be very carefully managed as part of the normal airport operations (outlined below) and no changes would be expected at the population level. The local distribution of some bird populations could also be affected indirectly in the areas immediately adjacent to the airport as a result of either bird control methods (including scaring and local changes to habitat and/or landuse) or through increased noise and visual disturbance arising from the air traffic movements themselves.

11.5.3 However, existing evidence regarding the potential effect of such disturbance impacts on local populations is inconclusive, and as many of the species observed during the surveys appeared habituated to living in an active airport environment no major

8 Made up of 5 strikes with gulls, 4 with pheasants; 4 with lapwings, 2 with pigeons and1 with a rook.

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changes are expected. Any local population redistributions that did occur may arise anyway as a result of other changes to landuses in the area (as has recently occurred with the overwintering populations of Bewick Swans taking up residence in Cheyne Court), and the ongoing activities by the RSPB to further improve local habitat suitability for key species will play a role in this.

Birdstrike Hazard

11.5.4 As part of their ongoing plans to achieve the Future Assessment Conditions scenario, LAA propose to introduce a bird control programme targeted to achieving a birdstrike rate of less than 3.0 per 10,000 movements. This would result in 13 bird strikes per annum for 300 000 passengers per annnum. Since, however, on average only about 10% of reported UK birdstrikes cause aircraft damage, and only around 1% cause engine damage9, this would mean that potentially significant birdstikes would only be expected about once every ten years under this scenario. This is considered to be an acceptable risk for an airport of this nature, and given the size of bird populations present, is not expected to have any impact on the bird conservation status of the area.

11.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

11.6.1 Impacts associated with the construction of the Runway Extension will primarily be restricted to direct impacts from habitat loss. Impacts associated with noise, vibration air quality, traffic and other construction activities are addressed elsewhere in the relevant chapters of this environmental statement.

Direct impacts from habitat loss

11.6.2 The proposed development will result in a change of use from semi-improved grassland and arable land to hardstanding and the adjacent ditch system would also be affected. The grassland area supports breeding skylarks (red listed) and meadow pipits (amber listed), and some potential nesting sites would be lost. However, in the context of surrounding land, the amount of nesting habitat lost to development would be very small. The magnitude of the impact is considered to be negligible. Therefore the impact of the runway footprint on breeding birds is predicted to be low.

11.6.3 Certain stretches of the drains will also be lost, although the impact of this on bird species is considered negligible and overall impacts are considered low.

Birdstrike Hazard

11.6.4 No changes to birdstrike hazard are expected to arise from construction works.

9 (indeed only around 0.5% cause serious engine damage leading to shut-down or loss of power in one engine, whilst rates of significant damage to more than one engine cannot be calculated with any accuracy as there have been none in the UK for 20+ years, but are certainly less than 0.0001% of all birdstrikes, and probably less than 0.00005%.)

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Future Assessment Conditions Scenario

11.6.5 Predicted impacts arising from construction of the facility under this scenario are expected to be the same as described under the “existing conditions scenario” above.

11.7 Predicted Impacts (Operational impacts)

Existing Conditions Scenario

Bird Conservation

11.7.1 As outlined in the Baseline Environment (Future Assessment Conditions Scenario (11.5)) the proposed development could have the following impacts on wintering and breeding birds:

• Direct impacts from mortality (birdstrike) of birds in the vicinity of the airport arising from increased air traffic movement;

• Direct or indirect impacts on bird flightpaths and overflight through birdstrike / disturbance / discouragement;

• Indirect impacts on breeding and wintering birds from increased disturbance (including that of birdstrike mitigation and increased air traffic movements);

• Indirect impacts on bird conservation measures through changed habitat management inside the airport;

• Indirect impacts on bird conservation measures through changed landuse outside the airport; and

• Indirect impacts on future bird conservation measures in the area through safeguarding;

11.7.2 Each of these is discussed in more detail below.

Bird overflight

11.7.3 Historically bird overflight over the airport has been discouraged and this practice will continue with the planned airport growth. Overflying wildfowl pose the greatest danger to air traffic, and whilst recent bird surveys show that neither swans nor geese regularly cross the airfield, other large species such as gulls have been recorded around the runway.

11.7.4 As part of the ongoing operations, the flightpaths used by such species, numbers and timings will continue to be recorded, and whilst it is difficult for the airport to implement direct action to prevent such overflights (eg neither pyrotechnics nor shooting are considered necessary or effective in such instances) should large numbers of such species be observed to be flying over the airport to concentrate at feeding sites nearby, disturbance and/or habitat management measures will be implemented to reduce the frequency of such events. Such measures would be non-lethal and would

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only take place after negotiation and agreement with the relevant landowner or tenant, as well as discussion with the conservation authorities.

11.7.5 Overall, therefore, impacts arising through overflight are considered to be of moderate significance.

Indirect impacts from disturbance

11.7.6 Increased activity at the airport will without doubt increase disturbance levels in the area and the increasing air traffic movements and altered fleetmix will affect the existing noise profile of the airport. Whilst this has the potential to impact upon the distribution of wintering birds beyond the airfield, studies at airports such as Coventry, Derry and Glasgow, appear to demonstrate that wintering bird populations quickly habituate to aircraft noise impacts and populations are not affected or deterred from the area in the longer term. The magnitude of this impact is therefore considered to be low and the overall significance of the impact is predicted to be moderate.

11.7.7 With regards breeding birds, there are very few UK research studies on the impact of aircraft noise (or other disturbance) on the breeding success of birds. However, it is evident that at most UK airports, birds such as skylark continue to breed successfully on the airfield grassland, despite noise from jet aircraft and providing appropriate mitigation is applied, it is expected that the LAA airfield and its environs will continue to provide breeding habitat for the species surveyed.

11.7.8 Most of those studies that are available have been carried out on birds by the United States (U.S.) government, owing to the proximity of many US military bases to nature reserves. In a study of Herring Gulls near John F Kennedy International Airport10 it was found that when super sonic aircraft flew over the colony considerable numbers of nesting gulls flew from their nests, eggs were broken and at the end of the incubation period mean clutch sizes were found to be lower. However, when subsonic aircraft were responsible for the overflights, no effects on nesting gulls were noted.

11.7.9 Similarly, behavioural responses of wading birds to aircraft flyovers at various altitudes have been observed at a nesting colony in southern Florida, where a combination of helicopters and fixed wing aircraft were used in attempts to simulate regular airport traffic11. In all of the tests, no bird that left its nest failed to return within five minutes and more significantly, in 90% of the tests the birds showed little or no reaction to the aircraft flying overhead.

11.7.10 The magnitude of this impact is therefore considered to be low and the overall significance of impact of increased disturbance on breeding birds is predicted to be moderate.

Indirect impacts from changes to airport habitat management

11.7.11 Proposals for changes to airport habitat management include the discontinuing of the current long grass policy, the netting over of standing waterbodies and the control of scrub. Such changes are unlikely to have a significant impact on the local populations of over-wintering birds, and are also not expected to significantly affect

10 Burger J 1981. Behavioural responses of Herring Gulls (Larus Argentatus) to aircraft noise. Environmental Pollution (Ser A) 24:177-184 11 Kushlan JA. Effects of helicopter censuses on wading bird colonies. J Wildlife Management 43:756-760. 1979.

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local breeding bird populations as the habitats to be affected are common throughout the area local to the airport. Impacts are therefore expected to be of low magnitude and moderate significance for both over-wintering and breeding birds.

11.7.12 Whilst birds use the small local waterbodies in the immediate area, netting of the ponds is not expected to have an adverse impact on the aviation fauna. This area is not important for either wintering or breeding birds, and the magnitude of the impact on wintering and breeding birds is considered to be negligible. The overall significance of this impact is therefore considered to be low.

Indirect Impacts from changes to local land uses

11.7.13 Proposals for changes to neighbouring land uses to discourage birdstrike species will primarily include proposals for reduced game bird rearing and agreements over management of arable lands. Such changes are unlikely to have a significant impact on local populations of over-wintering birds, and are also not expected to significantly affect local breeding bird populations as the habitats to be affected are common throughout the wider area. Impacts are therefore expected to be of low magnitude and moderate significance for both over-wintering and breeding birds.

11.7.14 An important concern is the potential impact of ‘safeguarding’ around LAA, whereby habitats around the airport which are likely to attract bird strike hazard species are discouraged (see Figure 11.4). Whilst the development proposals brought forward by LAA by themselves should not significantly affect the designated or important non- designated ornithological habitat sites or important bird populations there is the potential for safeguarding to compromise the future development of such sites as RSPB reserves. Such an impact would be considered significant and LAA propose to work together with the CAA, RSPB and Natural England to ensure that the use of safeguarding to reduce bird strike risks is not at the expense of present or future bird habitat provision.

Impacts to Bird Conservation arising as a result of safeguarding measures

11.7.15 The safeguarding agreement has yet to be finalised but it is likely to include management methods and agreements such as the change in farming methods on certain land, the phasing out of game bird breeding in the area and the careful planning of soft landscaping, in particular the planting of trees. Following its successful implementation the measures will have a low to moderate impact on the local bird conservation status. If the measures are managed and monitored successfully, these potential impacts can be reduced significantly.

11.7.16 Appropriate mitigation for such impacts is included in Section 11.9 below.

Birdstrike Hazard

11.7.17 With 300 000 passengers pa passing through the terminal building, and the proposed bird control programme in place (targeted to achieving a birdstrike rate of less than 3.0 per 10,000 movements) the airport would expect to see some 13 birdstrikes per annum. Given the size of the over-wintering bird populations present, the magnitude of this impact is considered to be low and the overall significance of this impact is expected to be moderate.

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11.7.18 Where the impact impinges on populations of breeding birds present at the airport, impacts would be greater should any of the more uncommon species, such as the raptors, be affected. However given the proposed birdstrike mitigation to discourage such species from nesting at the airport, the risk of such impacts will be reduced and the magnitude of any such impacts is considered to be low. Overall impact severity is therefore considered to be moderate. Mitigation requirements for these impacts which should be addressed through the planning process are however included within the following section.

Future Assessment Conditions Scenario

11.7.19 Operational impacts on bird conservation arising through the use of the runway and the facility (300,000 passengers per annum) are expected to be no different from those described in the baseline environment (future assessment conditions) scenario. Additionally as the bird control programme will already be in place, existing bird populations should be habituated to the operational airport and given the size of the over-wintering bird populations present, no significant impacts are expected.

11.7.20 With the proposed mitigation in place, the airport development and associated air traffic movements are expected to result in a minor increase, from 12 birdstrikes per annum for the “Future Assessments Conditions” scenario (300,000 passengers without the runway extension) to 13 for the “Year 1 Operating Conditions” scenario (300,000 passengers with the runway extension.

11.7.21 This is entirely a consequence of the slightly increased overall aircraft movement rates projected for the runway extension if the forecasted aircraft movement numbers and fleet composition were met. However, in terms of passenger safety, the overall reduction in the number of aircraft carrying passengers if the runway extension were to be built would result in an expected 40% reduction in birdstrike frequency to commercial passenger-carrying flights and a proportionate reduction in the risk of birdstrike-related damage to these commercial flights.

11.7.22 Overall, given the size of the over-wintering bird populations present, the magnitude of this impact is considered to be negligible and the overall significance of this impact is expected to be low.

11.7.23 Where the impact impinges on populations of breeding birds present at the airport, impacts would be greater should any of the more uncommon species, such as the raptors, be affected. However given the proposed birdstrike mitigation to discourage such species from nesting at the airport, the risk of such impacts will be reduced and the magnitude of any such impacts is considered to be low. Overall impact severity is therefore considered to be moderate.

11.7.24 Mitigation requirements for these impacts which should be addressed through the planning process are however included within the following section.

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11.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

11.8.1 No significant impacts are expected from construction works, and no specific mitigation is proposed other than to avoid disturbance to nesting birds during the works. The exceptions are that in order to mitigate for small areas of lost skylark and meadow pipit breeding habitat, LAA will put aside a larger area of land on or near the airfield to be managed specifically to provide appropriate nesting conditions for these species. Where drains are to be removed, longer stretches, with better management are proposed The implementation of mitigation to minimise disturbance is outlined in other Chapters.

Future Assessment Conditions Scenario

11.8.2 Proposed mitigation for construction impacts under this scenario is as described under the “existing conditions scenario” above.

11.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

Birdstrike Hazard

11.9.1 As discussed the bird populations present at LAA do clearly provide a significant potential risk of birdstrike and it is therefore essential that these impacts are mitigated by appropriate management techniques. Whilst a more detailed risk assessment for bird hazard is currently being finalised to ‘fine tune’ the control mitigation measures required for LAA’s development proposals (See Section 11.3.20 above). The following recommendations form a general approach to managing the issue in the light of the general ornithological sensitivity of the area.

11.9.2 Given the need to reduce the bird strike rate to less than 3.0 per 10,000 movements to ensure the continued operation of the airport, a number of mitigation measures are being proposed by LAA, namely:

• Improved resourcing and structuring of the Bird Hazard Control Team;

• Careful management of habitats within the airport boundary;

• Active dispersal of birds from airfield by mobile patrols using appropriate use of bird scarers, trapping and other manual techniques; and

• Agreements with local landowners, stakeholders and Local Planning Authorities regarding appropriate land uses around the airport boundaries and under the aircraft flightpaths to form a safeguarding system.

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11.9.3 Each of these is discussed further below and will be further detailed in the Bird Control Plan which is being developed (following discussion with the nature conservation organisations). This document will help ensure that both the long term conservation objectives and the aircraft are managed in an effective manner.

Improved Resourcing of the Bird Hazard Control Team

11.9.4 The LAA expansion proposals will require the upgrading of the current bird control services, which are carried out by the Airport Fire Service team. There are broadly three levels of organisation for bird dispersal personnel in use at UK civil airports, namely:

a Use of non-specialist personnel, with or without bird control training, drawn from staff dedicated to other tasks (e.g. airport fire service, operations, ATC) on an "on call" (if available) basis - the "multi-function unit" option. This generally gives rather poor results and is unable to provide the flexible response that variation in the bird hazard level demands.

b Use of a semi-dedicated unit comprised of a smaller number of trained staff from a staff pool as above but dedicated to and available full-time for bird control duties on individual shifts. If carefully managed this can overcome many of the previous shortcomings if suitable staffing are available to ensure sufficient resources to perform the bird control task properly at times.

c Use of small dedicated, trained teams of personnel dedicated almost entirely to bird control task (other duties such as surface and lighting inspection are compatible) - specialist "Bird Control Units” or “Airfield Safety Units." This has gained ground slowly over recent years, with small to medium-sized airports leading the way, driven by the realisation that at times safety was being compromised by their inability to divert manpower to the bird control task as and when it was required. With careful selection, training and management of staff, combined with adequate resources and effective habitat management, this option consistently gives the best results, although costs can be significant. 11.9.5 As part of the proposed mitigation for the development, LAA will commit to remove the bird hazard control task from the Fire Service and will continue to upgrade the resources available to the bird hazard control team to ensure that the exemplary level of bird hazard risk management that will be required at this site can be met.

11.9.6 Other mitigation measures will include the introduction of a tiered system of responsibility for bird hazard control with continuous surveillance throughout operating hours of the airfield and its surrounding airspace by trained Bird Control Operatives. Warnings will also be passed to Air Traffic Control from the Bird Control Team (BCT) of hazardous numbers and movements of birds that cannot be immediately dispersed.

Habitat Management within the Airport

11.9.7 A number of key habitats within the airport can be managed to minimise the risk of birdstrike, whilst enhance their conservation potential to other species, as described below. In addition, potential birdstrike species such as raptors that are currently encouraged to breed at the airport would be encouraged to move elsewhere through the setting up of alternative nesting sites (in conjunction with RSPB and Natural England) to discourage their presence within the airport perimeter.

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Grassland

11.9.8 A traditional Long Grass Policy (LGP) is in force at LAA, which aims to deny birds access to the invertebrate populations that are typically present beneath regularly mown grassland. Soil conditions at the airport are considered inappropriate for the maintenance of a “classic” high quality long grass sward (as described in CAP680), but as the substrate also does not support the numbers of invertebrates that occur on most airfields, denying birds access to the soil is less critical. LAA will therefore seek an agreement with the CAA that the “standard” LGP should not be applied here and instead an appropriate habitat management regime will be agreed with Natural England and the RSPB.

Open Water

11.9.9 The presence of open ponds, streams or ditches on a civil airport is not advisable from a birdstrike hazard perspective, particularly in an area with high waterfowl populations. There is a very clear correlation between waterfowl strikes and the presence of open water habitats on aerodromes and the main species involved have been mallard and grey herons, both species which will regularly use even the smallest ponds and the narrowest drains that may be present. Active bird dispersal is not sufficiently effective against these species to reduce the hazard to an acceptable level and the only recommended mitigation measures are passive bird exclusion systems, primarily netting systems. LAA therefore propose to install such netting over the drains and any open ponds on the airport, and whilst this will exclude the birds, it is not expected to have an adverse effect on any of the other valuable wildlife using these resources, such as the great crested newts and invertebrates.

Scrub

11.9.10 Whilst the extensive scrub on the eastern side of the airfield is not a habitat used by common flocking airfield species like gulls, lapwings, corvids and starlings it does offers cover for game birds. In the short term, LAA propose to control the scrub to maintain a buffer zone of open ground between it and the runway, although eventually, with the expansion of the Airport’s operations, it may become necessary to remove it altogether. Any such works will be done in consultation with the RSPB and Natural England.

Habitat Management around the Airport

11.9.11 Local land uses can have a significant effect on the level of birdstrike hazard present in and around an airport. Land uses around the airport are described in Chapter 9 Land Use and LAA is actively seeking to develop management agreements with local landowners with regards to the following land uses, as described further below:

• Arable farming;

• Game bird rearing;

• Sheep and other livestock farming;

• Gravel extraction;

• Solid waste management; and

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• Management for conservation.

Arable farming

11.9.12 Ploughing, drilling and harvesting can all have a major influence on local bird populations, particularly when they occur in fields beneath runway approaches or directly adjacent to the airfield boundary. Ploughing in particular can have a short- term (but potentially very dramatic) effect in attracting large numbers of birds that feed on exposed soil invertebrates, including gulls, corvids, starlings and lapwings. Mitigation involves negotiating the timing and location of such activities with the landowner as well as the short-term deployment of personnel to disperse bird concentrations.

11.9.13 The type of crop grown also has consequences for the birdstrike hazard. Root crops are only significantly attractive for a short period after crop lifting, whilst cereal crops (wheat and barley) may attract granivorous species for a short time after harvesting, as well as providing a feeding habitat for invertebrate feeders such as gulls and grassland plovers until the crop reaches around 150mm tall. Ripening crops may attract corvids and pigeons for a short while, as do any stubbles left after harvesting. Oilseed rape may attract significant numbers of woodpigeons throughout the winter months and this crop is best discouraged in close proximity to aerodromes. LAA will draw up a programme to manage such risks in conjunction with local farmers/land owners.

Game Bird Rearing and Shooting

11.9.14 At present, large numbers of game birds are reared, released and shot in very close proximity to the airport and these birds are supported by game bird feeding stations and strategically planted “game crops” around the airport. As game birds of all species are an extremely high-risk group and have a history of destroying even large turbine engines, this currently represents a significant local birdstrike hazard at LAA. Habitat management and “scaring” measures are not sufficient to contain the hazard and at the very minimum, a local agreement to relocate release pens, feeders, game crops and shooting “beats” further away from the airport boundary is being sought. This agreement will be undertaken with the affected landowners and can be enforced by LAA using its powers under the Air Navigation Order 2005.

Appropriate use of Bird Hazard Safeguarding Options

11.9.15 LAA has a long-established safeguarding consultation system with Rother and Shepway Councils. LAA are in the process of reviewing this safeguarding approach in the context of both the updated ODPM, DfT and National Assembly of Wales Joint Circular 1/2003 (10 February 2003) on safeguarding and the findings of this ES. The new approach will ensure that a balance is met between recognising the importance of the ornithological wetland habitat around the airport and the need to minimise birdstrike hazard something that has successfully been achieved at several other UK airports which have been able to combine development with maintenance and expansion of wetland habitat in the near vicinity of the airfield.

Conclusion/Summary

11.9.16 Whilst it is acknowledged that LAA is located in an area supporting significant bird populations, by benchmarking LAA against other airports in areas with comparable or

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higher local bird populations, it is concluded that the birdstrike risk at LAA can be contained within levels comparable with other UK airports.

11.9.17 Although it is inevitable that the number of bird strikes occurring at LAA will rise proportionately with aircraft movements, it has repeatedly been shown that the risk of each aircraft movement suffering a bird strike (i.e. the bird strike rate corrected for aircraft movements) can be reduced as an airport grows provided that the necessary resources are dedicated to bird hazard mitigation.

11.9.18 LAA’s situation with respect to the disposition of local bird populations is significantly better than that of many other UK aerodromes (e.g. Liverpool – Mersey Estuary, Dundee-Tay Estuary, Warton – Ribble Estuary, RAF Kinloss – Burghead Bay) and although additional measures will be required to achieve the required standard for the airport’s planned expansion, the birdstrike hazard at LAA can be contained within levels comparable to these other UK airports without extraordinary measures and without measurable impact on local bird populations beyond the immediate airport environs.

Bird Conservation

Wintering Birds

11.9.19 As discussed above overall impacts on wintering bird populations as a result of the proposed runway extension of are expected to be of only low-moderate significance. Whilst no mandatory mitigation would normally be required for an impact of this severity, LAA propose to enter into a voluntary agreement with Natural England and RSPB to develop a long-term approach to management of the airport and its environs to ensure that the ornithological value of the area is retained (and where possible enhanced) as a result of the re-development of a functional civilian airport at Lydd.

11.9.20 In addition and given the paucity of data available on the issue, LAA propose to fund a research study to further assess the potential for disturbance impacts of increased air traffic movements on wintering birds, as although developments at other UK airports appear to have proceeded without serious impacts on the presence and distribution of birds, very little long-term empirical research has been undertaken to date on this issue. Monitoring undertaken as part of this assessment would be linked to a series of management ‘trigger levels’, which would be agreed in advance with Natural England and RSPB to ensure that, should any significant adverse impacts be identified, controls on airport activity or additional mitigation would be brought to bear.

Breeding Birds

11.9.21 As discussed, overall impacts on breeding birds as a result of the proposed development is predicted to be of only low-moderate significance. Whilst no mandatory mitigation would normally be required for an impact of this severity, given the ecological sensitivity of the area LAA proposes to work with Natural England and RSPB to develop a Biodiversity Action Plan (which will be developed as part of the proposed EMS), in order that those species not constituting a birdstrike hazard are able to continue breeding within and around the airfield. An ongoing monitoring programme will be undertaken as part of this action plan and will be used to refine it if needed to optimise the areas of ornithological interest.

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Proposed Monitoring

11.9.22 As part of a bird hazard control programme, a regular monitoring programme of hazards and effectiveness of control will be maintained. The results of this will be used to manage appropriate change in conjunction with the airfield biodiversity plan.

11.9.23 As described above, a series of further wintering bird monitoring surveys will also be undertaken by the airport, using, as a minimum, the same methodology as the field survey undertaken in 2005/06 with the study outcome compared to the 2005/06 baseline. These will take place annually for a minimum of ten years and any negative change in the wintering populations will be addressed through a management review with a pre-agreed mitigation strategy.

11.9.24 For the breeding birds, a monitoring programme to the same methodology as the field survey undertaken in 2006, will also be undertaken (or financed) by the airport for a minimum of ten years, with the study outcome compared to the 2006 baseline. Any negative change in the breeding bird populations will be addressed through a management review with a pre-agreed mitigation strategy.

Future Assessment Conditions Scenario

11.9.25 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above.

11.10 Residual Effects

Existing Conditions Scenario

11.10.1 The main issue for consideration here will be the impacts of the bird hazard control programme on wintering and breeding birds in and around LAA and it is essential that the bird hazard control and ecological stewardship programmes are harnessed for mutual benefit. In particular:

• The biodiversity action plan for the site will take account of bird hazard control requirements. This will include providing nesting sites for potential bird strike species away from the airfield;

• Bird control methods will be developed which deter hazard species but do not affect or disturb non-hazardous species; and

• Where hazard control methods are implemented which reduce breeding or wintering sites, these will be compensated for offsite. 11.10.2 Whilst no bird hazard control programme can reduce the risk of birdstrike to zero, as long as the appropriate bird hazard mitigation controls outlined above are applied, birdstrike hazard impacts at LAA will be minimised to nationally acceptable levels, without compromising the ornithological value of the site and its surrounding areas.

11.10.3 The proposed development is not expected to have any residual effect on the important wintering bird populations, which are likely to habituate themselves to noise disturbance (in the same manner that they have to the existing operational airport). The proposed research programme would monitor for any negative impact on the

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wintering birds and if any were demonstrated then airport activities or mitigation alternatives would be reviewed.

11.10.4 The proposed development is also considered unlikely to have any residual effect on the important breeding bird populations and if proposed mitigations outlined above are applied then the airfield and its environs should continue to provide good breeding bird habitat. Local populations would continue to be monitored and if any negative impacts were demonstrated airport activities or mitigation alternatives would be reviewed.

11.10.5 As discussed above, an important concern is the potential impact of ‘safeguarding’ around LAA, whereby habitats around the airport which are likely to attract birdstrike hazard species are discouraged. It is clear that the development proposals brought forward by LAA by itself should not significantly affect the designated or important non-designated ornithological habitat sites or important bird populations, nor compromise the future development of such sites as RSPB reserves. LAA proposes to work together with the CAA, RSPB and Natural England to ensure that the use of safeguarding to reduce bird strike risks is not at the expense of present or future bird habitat provision.

Future Assessment Conditions Scenario

11.10.6 Residual impacts are expected to be as described for the “existing conditions scenario” above.

11.11 Summary

11.11.1 Significant populations of wintering and breeding birds are supported by the habitats around Lydd airport and the wider area. There are a number of sites of ornithological interest within a 2 mile radius of Lydd Airport, which include birds that are red or amber listed and thus are of conservation importance. Surveys of wintering and breeding birds found relatively large populations of several species of birdstrike importance that inhabit areas in close proximity to the airfield and flightpaths.

11.11.2 The proposed runway extension is situated in an area of high ornithological value and the sensitivity of the wintering and breeding bird population is considered to be very high. The significance of the direct impacts from habitat loss is considered to be low. The direct impact of the runway extension on over-wintering birds is also considered to be low, but for breeding birds is considered to be moderate. Indirect impacts from disturbance, changes to airport habitat management, and changes to local land uses are all predicted to be moderate. The overall impacts on both wintering and breeding bird populations as a result of the runway extension are predicted to have low- moderate impacts.

11.11.3 The difference between the projected birdstrike numbers with or without a runway extension (with 300,000 passengers) is negligible. When benchmarking LAA against other airports with comparable bird populations, the predicted number of birdstrikes for the proposed runway extension are thus not considered to present an unacceptable risk. Proposed mitigation to reduce the birdstrike rate includes improved resourcing of the Bird Hazard Control Team, appropriate use of bird hazard safeguarding options, habitat management within and around the airport and the use

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of manual techniques. It is likely that as the airport grows, the birdstrike rate can be reduced provided necessary resources are dedicated to bird hazard mitigation.

11.11.4 Proposed mitigation for bird conservation include a research study funded by LAA to assess disturbance impacts on wintering birds and an airfield biodiversity action plan for breeding birds. As part of a bird hazard control programme, regular monitoring of hazard control effectiveness will be in place and field surveys of breeding and wintering birds will continue for a minimum of 10 years. Residual effects of the bird hazard control programme are likely to be negligible with the implementation of the proposed mitigation measures. LAA proposes to work closely with the CAA, RSPB and Natural England to ensure that safeguarding the airport against birdstrike risk is not at the expense of bird habitat provision.

11.11.5 Whilst the potential impacts predicted under the “existing conditions” and “future assessment” scenarios are broadly similar in nature, the magnitude of any impacts resulting from the proposed development will be greater in the latter scenario.

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CHAPTER 12

LANDSCAPE AND VISUAL AMENITY

CHAPTER 12 LAA

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12 LANDSCAPE AND VISUAL AMENITY

12.1 Introduction

12.1.1 The purpose of this assessment of the landscape and visual effects is to determine the magnitude and significance of any impacts likely to be associated with the proposed runway extension of London Ashford Airport (LAA) at Lydd, by comparison with a) the baseline (existing conditions) and b) future assessment condition (300,000 passengers) scenarios.

12.1.2 The scenarios modelled in this chapter as as described in Chapter 1, and full details of the proposed scheme are provided in Chapter 4. In summary, the proposed runway extension (and approach lighting) would involve the construction of approximately 295m of asphalt to the north of the existing runway, resulting in a total length of 1799m with a further 150m starter extension but maintaining a width of 32m (as illustrated in Figure 4.3).

12.1.3 The landscape resource and visibility baseline conditions of the site and its surrounds have been thoroughly investigated, through a combination of desk studies and field surveys. David Huskisson Associates (a firm of Chartered Landscape Architects registered with The Landscape Institute) carried out initial desk studies and prepared much of the baseline element of this assessment in 2005. Peter Fischer Landscape Design Limited (a firm of Chartered Landscape Architects also registered with The Landscape Institute) carried out field surveys in spring 2006, provided additions to the baseline element of this assessment and assessed the magnitude and significance of the impacts both on the landscape resource and human receptors.

12.2 Legislative Drivers

12.2.1 The following legislation, policy and guidance documents have been used to inform this impact assessment:

• Kent and Medway Structure Adopted Plan;

• Shepway District Adopted Local Plan;

• Guidelines for Landscape and Visual Impact Assessment – 1st Edition 1995;and

• Guidelines for Landscape and Visual Impact Assessment – 2nd Edition 2002.

12.3 Assessment Methodology

Identification of Effects

12.3.1 Effects on landscape character and visual amenity can arise for many reasons, for example perceived changes to:

• The scale, grain and pattern of the landscape, for example by alien or engineered landform or out of context planting;

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• Deterioration or erosion of the rural landscape by the urbanising effects of traffic, hard surfacing, structures and built development, lighting and signs and associated loss of tranquillity; and

• Intervisibility between surrounding locations and the proposals. 12.3.2 Generally, whilst changes that impinge upon features of recognised higher quality such as a Conservation Area or a statutorily protected landscape such as an Area of Outstanding Natural Beauty may be most serious, unprotected features may also be locally highly valued and thus should also considered to be of importance and worthy of safeguarding wherever possible.

General

12.3.3 The assessment methodology adopted follows the Guidelines for Landscape and Visual Impact Assessment prepared by The Landscape Institute with the Institute of Environmental Management and Assessment, drawing from both the first and second editions dated 1995 and 2002 respectively.

12.3.4 Landscape and visual effects are independent but related subject areas and are assessed separately. In simple terms landscape effects comprise changes in fabric, character and quality of the landscape whereas visual effects relate to the appearance of these changes and their impact on those viewing the changes.

12.3.5 The two principal criteria determining the significance of landscape and visual effects are the magnitude of effect and the sensitivity of the landscape or person experiencing visual effects, sometimes termed landscape or visual receptors. The sensitivity of the landscape is defined as being the extent to which a landscape can accept change of a particular type and scale without unacceptable adverse effects on its character. The sensitivity of visual receptors will depend on the location and context of the viewpoint, the expectations and occupation or activity of the receptor and the importance of the view. The duration of effects will also affect their significance. Temporary effects will generally be less significant than long term or permanent effects.

12.3.6 The method for ranking the sensitivity and magnitude of change criteria and their significance are indicated in Tables 12.1, 12.2 and 12.3.

12.3.7 The visual assessment is based on Winter Views at Day 1 as these represent the “worse case”. Effects can be positive (beneficial), negative (adverse) or neutral (as explained further below.

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Table 12.1 Ranking of Sensitivity and Magnitude of Change Criteria for Landscape Receptors LANDSCAPE RECEPTOR RANKING MAGNITUDE OF CHANGE SENSITIVITY For example, important components or High Notable change in characteristics particularly distinctive character over an extensive area ranging to susceptible to relatively small changes. very intensive change over a more Usually all National Parks / AONB’s and limited area. sometimes areas with County / District notations and some Conservation Areas and settings of some Listed Buildings. For example, an area of moderately Moderate changes in localised area. valued characteristics reasonably tolerant of changes, occasionally parts of AONB’s, usually County / District notations and some Conservation Areas and settings of some Listed Buildings Medium and with some detractors.

For example, a relatively unimportant Virtually imperceptible change in any

area, the nature of which is potentially components. tolerant of substantial change and probably has significant detractors.

Low

Table 12.2 Ranking of Sensitivity and Magnitude of Change Criteria for Visual Receptors VISUAL RECEPTOR SENSITIVITY RANKING MAGNITUDE OF CHANGE For example, some residential High For example, the majority of viewers properties and most rural public rights affected and/or major change(s) in of way, views from moving vehicles, view of high visual quality and/or where view can be considered to be a proposed development dominates primary feature the view

For example, some residential For example, many viewers affected properties, recreational facilities, some but by moderate change(s) in view rural and semi rural public rights of way, of ordinary visual quality or clearly views from commercial premises or visible changes that are subordinate from moving vehicles, where view is Medium to other elements in the view occasional For example, industrial premises, some For example, few viewers affected or residential properties, urban public minor change(s) in view of poor rights of way, views from moving visual quality or proposals for only a vehicles or where view is small amount of change in viewer’s

glimpsed/infrequent natural cone of vision

Low

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Table 12.3 Thresholds for the Significance of Landscape and Visual Effects

Landscape or Visual Sensitivity Magnitude of Change Low Medium High High Moderate Significance Substantial Substantial Significance Significance Medium Slight to Moderate Moderate Moderate / Substantial Significance Significance Significance Low Slight Significance Slight Significance Slight / Moderate Significance No / Negligible Change No / Negligible No / Negligible Negligible / Slight Significance Significance Significance

Methodology: Impacts on Landscape Character

12.3.8 The general character of the landscape of the site and its surroundings was surveyed and an assessment made as to how the proposed development would impact on the scale, structure and texture of the landscape. The impacts were evaluated in terms of there degrees of magnitude - high, medium and low - depending on the degree of change caused to key elements of the landscape that give it its particular character.

12.3.9 Impacts of new development on the intrinsic landscape character of an area can be neutral, beneficial or adverse. In the case of a neutral impact, the landscape character of the site and its surroundings is neither enhanced nor harmed. A beneficial impact will result from the enhancement or improvement of the landscape resource (this could be through additional planting, more appropriate replacement planting, habitat extension or creation or improved management of the existing resource). An adverse impact occurs when significant elements of the existing landscape resource are lost and adequate compensatory provision is not possible, resulting in an erosion of the landscape character of the site and its surroundings.

Methodology: Assessment of Visual Impacts

12.3.10 With regard to the visual effects on human receptors, a Zone of Visual Influence (ZVI) (see Figure 12.1) was identified, an area from which some part of the proposed development (including lighting) might be visible, and the degree of unmitigated impact was assessed. The zone may consist of separated areas due to the landform of the site and its surroundings. The extent and degree of these impacts is set out in detail in Section 12.5 of this chapter. A comparison assessment of the mitigated visual impact was then made based on appropriate and feasible mitigation works. Finally the relative significance of these impacts was assessed.

12.3.11 The baseline situation against which the visual impact assessment of the proposed development has been carried out takes into account all existing buildings, buildings under construction and extant planning permissions in the vicinity of the site.

Methodology: The Zone of Visual Influence

12.3.12 The ZVI is the overall extent of land or buildings from which it may be possible to see some part of the proposed development, including lighting. The zone may consist of separated areas due to the landform of the site and its surroundings.

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Methodology: Human Receptors

12.3.13 Anyone with a view from within the ZVI is a “receptor”. Receptors are graded in order of sensitivity according to the extent of time they may have a view of the proposed development. In descending order of sensitivity, these are generally agreed to be:

• The occupants of residential dwelling or institutions;

• Users of public rights of way and public recreational open space;

• Road users (drivers, cyclists, pedestrians and passengers in private and public transport); and

• Workers in their place of work (offices, shops, factories, farmland etc), shoppers and users of indoor recreation facilities or private restricted access outdoor recreation facilities. 12.3.14 The degree (or magnitude) of visual impact has been assessed in three levels of impact - high, medium and low and has been related to the visual impact of existing site conditions the proposed development would replace. Whilst Section 12.5 and Table 12.4 provides descriptions of the extent and significance of views from particular areas surrounding the site, on the ZVI (Figure 12.1) plan the impacts have been simplified to give a summarised indication of extent only in graphic form.

12.3.15 Assessment of the degree of impact is based on the extent to which the proposed development is visible in the viewer's natural cone of vision, whilst assessment of the significance of the impact is based on both the extent to which the visible development changes the character of the view (magnitude of change) and on the duration or regularity of the receptor’s experience of the view (receptor sensitivity). Other matters taken into consideration when considering the significance of the impact include the extent of existing screening and whether this or other features in the overall view draw the eye or act as a focus. The significance of the impact is assessed in three levels of impact – substantial, moderate and slight (see Table 12.3).

12.3.16 A ZVI must to a degree be generalised as it is impossible to determine with absolute accuracy every particular point from which the proposed development is visible. At times foreground buildings, vegetation or other forms of screening may hide the proposed development from view. In addition, the possibility of views from upper-floor windows of private property has been assessed without being able to gain access. It is therefore necessary to assess on an area basis locations from which the visibility of the proposed development will have a particular degree (or magnitude) of impact, although according to the viewer’s precise location within that area, the proposed development may or may not actually be visible depending on the extent of intervening landform, buildings, fences or vegetation.

12.3.17 Where views of the proposed development would fill a large part of the receptor’s (viewer’s) cone of vision and the proposed development would dominate the view, we have assessed such areas as being subject to a high visual impact.

12.3.18 Where the proposed development would be distinctly visible but would not dominate other elements in the view, such as foreground buildings, vegetation or other skyline elements, then we have assessed this as a medium visual impact.

12.3.19 There will be many other viewpoints from which the proposed development may be visible as a background element or seen above or between foreground buildings or

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vegetation in such a way that, although visible, only constitutes one small element in the receptor’s overall cone of vision. Views such as this we have assessed as being of low visual impact.

12.3.20 Visual impacts may be neutral, beneficial or adverse. A neutral impact will neither enhance nor detract from the receptor’s view although the composition of the view may have changed. A beneficial impact will enhance the receptor’s view, although again the composition of the view may have changed. (This is most likely when derelict or unsightly land and buildings is being replaced with new development and/or materials more appropriate or sympathetic to the surroundings.) An adverse impact is one that detracts from the receptor’s view. (This most usually occurs where the scale of new development becomes a dominating element in the view, particularly where open or attractive vistas become obstructed or foreshortened.)

Study Area

12.3.21 An initial desk study led to the decision to drive all rural roads and all roads on the edges of built up areas and walk selected public footpaths within a 3km radius of the site to check its visibility. Locally elevated areas within that radius were also checked (e.g. sand dunes, overbridges).

12.4 Baseline Environment (Existing Conditions)

Site Description

12.4.1 The application site comprises an area at the northern extremity of the existing LAA, and an area of flat farmland immediately to the north of the airport boundary that together totals approximately 13.38ha in extent. The area of the site within the airport boundary consists of a mixture of short mown and rough grass. The farmland consists of arable and grazing land divided up by several drainage ditches. A small part of the farmland within the proposed site forms the northern extremity of the Dungeness Shingle SSSI although its classification within the SSSI appears anomalous as it is clearly part of enclosed farmland. There are no hedges or trees within the site.

12.4.2 LAA lies in the southernmost part of Kent in a low lying coastal area known as the Romney Marshes. Refer to Figure 3.1. The settlements of Greatstone-on-Sea, Lade and Lydd-on-Sea lie approximately 1km to the east of the proposed runway extension, with New Romney lying approximately 2km to the north and Lydd approximately 2km to the south west. To the south of the site lies the shingle promontory of Dungeness Point, which juts into the English Channel at a distance of approximately 5.5km from the site.

Site Surroundings

12.4.3 The site is just over 1km inland from the coast. To the north east of the proposed site, flat open farmland stretches for approximately 800m until it reaches the residential edge of Greatstone-on-Sea, the boundary marked by the route of the Romney Hythe & Dymchurch Railway (Area A, see Figure 12.1).

12.4.4 To the east of the proposed site, flat open farmland gives way to flooded former gravel workings within approximately 400m. Beyond this lies the residential edge of Greatstone-on-Sea and Lade sitting on a shallow shingle platform approximately 2m above the farmland and the flooded gravel workings. A school and a scout hut at the

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west end of Baldwin Road are the nearest publicly accessible buildings to the site at a distance of approximately 530m (Area B, see Figure 12.1).

12.4.5 To the south east of the site flat open farmland gives way to more flooded former gravel workings and the shallow shingle ridges of the Dungeness Shingle SSSI within 400-600m (Areas C & D, see Figure 12.1). The experimental concrete sound “Mirrors”, dating from the early 1930s are a visual feature of this area sitting on the western edge of the old gravel workings approx 750m from the site. Public access on the shingle is possible to within approx 800m of the site. The residential edge of Greatstone-on-Sea continues south on the slightly raised shingle platform mentioned above, merging with Lade and Lydd-on-Sea and becoming steadily more distant from the site. To the south the shingle extends for approx 5km to the Dungeness Power Station complex, crossed by the railway line serving the power station, the Dungeness Road and a number of public footpaths. 2km to the south of the site an old water tower and above-ground storage tank are a visual feature of the shingle. To the south east, sandwiched between the shingle and Lydd-on-Sea, is an operating gravel pit also within approx 2km of the site.

12.4.6 LAA itself lies to the south and south west together with some flat open farmland at the southern end of Denge Marsh (Area E, see Figure 12.1). The existing runway runs south west from the edge of the site of the proposed runway extension for a distance of approximately 1500m. The main group of airport buildings are approx.1km to the south west on the west side of the existing runway. The main terminal building comprises one and two storey elements with flat roofs and horizontal lines finished in predominantly white painted render. The two-storey element is approximately 5.5m in height. The two adjacent aircraft hangars are a visual feature of this area. Made of pale grey or blue corrugated sheeting and with grey shallow pitched roofs, the newer and larger of the two is approximately 10m in height to the ridge and the older smaller one approximately 9m in height to the ridge. There are two high mast lighting columns (approx 30m high) associated with the hardstanding next to the hangars.

12.4.7 There are large areas of hard standing associated with the terminal building and hangars, which provide for both aircraft and car parking. The operating runway is aligned south west to north east, with associated taxiways and is surrounded by flat open grassland with levels generally ranging from 2 to 4m AOD. Other infrastructure within the airport includes fuel storage facilities and several small service buildings and fenced compounds.

12.4.8 Beyond the airport to the south west there is extensive flat open farmland on Denge Marsh, and the small town of Lydd.

12.4.9 To the west, north west and north of the site stretches open relatively flat farmland except for the Lydd Golf Course to the west, that has been created as a links style course with undulating landform, its nearest edge being c.550m from the site (Areas F and G, see Figure 12.1). About 2km to the north the farmland abuts the edge of New Romney but otherwise stretches for several kilometres. The B2075 passes c.1.5km to the west of the site. A number of public footpaths cross this area although all are more than a kilometre from the site. Unlike the largely treeless farmland to the north east and south west of the site, this area has pockets of tree planting around farmsteads, one or two rows of trees planted for shelter and sporadic scrub willow along some of the ditches or sewers that compartment the farmland.

12.4.10 Photographs were taken from a number of publicly accessible locations that represent a range of typical views that are possible of the site for the runway extension. These are shown on Plates 12.1 – 12.12 with the extent of the runway extension site including the approach lighting indicated on them. These viewpoints, which have been

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agreed with Shepway District Council as required in the scoping report, are as follows:

Plate 12.1 (View 1) Looking south west from dune tops at the back of Greatstone-on-Sea public car park.

Plate 12.2 (View 2) Looking west from the west end of Baldwin Road, Greatstone-on-Sea.

Plate 12.3 (View 3) Looking north west from the shingle platform at the back of the caravan park in Greatstone-on-Sea at a point opposite the causeway to “The Mirrors”.

Plate 12.4 (View 4) Looking north west across the Dungeness shingle ridges from the west end of Taylor Road, Lydd-on-Sea.

Plate 12.5 (View 5) Looking north west from “The Mirrors” information plaques

Plate 12.6 (View 6) Looking north from the northern extremity of the Dungeness shingle where it gives way to farmland

Plate 12.7 (View 7) Looking north east from the airport access road at the western corner of Lydd Airport.

Plate 12.8 (View 8) Looking east from the public footpath that skirts the north west corner of Lydd Golf Course.

Plate 12.9 (View 9) Looking south east from the public footpath between New Romney and Belgar Farm.

Plate 12.10 (View 10) Looking south east from the B2075 Romney Road at its junction with Caldecot Lane.

Plate 12.11 (View 11) Looking south west from the eastern part of Church Lane on the southern edge of New Romney.

Plate 12.12 (View 12) Looking south west from the west end of Baldwin Road, Greatstone-on-Sea at a twin-engined aircraft landing at Lydd Airport.

Geology, Topography and Drainage

12.4.11 The Romney Marshes owe their present day appearance to the natural process of sediment deposition behind large shingle promontories and to the reclamation, in stages, of the area for agricultural use.

12.4.12 The area is underlain by the Lower Cretaceous Hastings Beds. Above these are the Holocene coastal and river deposits and top shingle. The latter are the shoreface and storm beach surface deposits, with some thin acid soils between the stones, which characterise the Dungeness headland. A series of long, domed corrugations of grey- yellow shingle run inland marking the edges of fossil shorelines. Inland, nearer to Lydd in the area known as Denge Marsh, the ploughed farmland and pasture become increasingly soil based strewn with the rounded flints.

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12.4.13 The area is drained by an extensive and irregular network of drainage ditches and sewers, such as Dengemarsh, Mockmill and Paine Field Sewers, which ultimately outfall into the sea. There are also a number of areas of open water resulting from the flooding of past gravel extraction pits.

Vegetation

12.4.14 Tree cover is extremely sparse in the area and is generally limited to pockets of land around farmsteads and sporadic scrub willow along some of the sewers and ditches to the west and north of the site. There are typically no hedges. Scrub vegetation such as blackthorn, bramble, broom and the smaller woodsage grows on the ridges of shingle. Willow scrub in pits or around old gravel extraction sites is locally significant, particularly in the vicinity of “The Mirrors” to the south east of the site. The woody scrub within the airport boundary to the east of the existing runway which currently screens much of the airport from the west is being removed this year as part of a Natural England programme to restore shingle habitats.

12.4.15 The most strikingly characteristic plant is sea kale and its bright green summer foliage contrasts strongly with the grey and buffs of the shingle. Areas of open water and many of the ditches are fringed with reeds and other marginal plants all of which contribute to the “marshland” character of the area.

12.4.16 Surrounding agricultural land is a mix of sheep pasture, amenity turf production and mixed arable, with a significant amount of vegetables of varying kinds.

12.4.17 The Lydd Golf Club is a links style course with a characteristic mix of managed grassland of varying height.

Landscape Character

12.4.18 The site lies within the “Romney Marshes” Character Area No.123 as described in the Countryside Agency publication Countryside Character – Volume 7: South East and London 1999. This describes the key characteristics of the area as a flat open and agricultural landscape with distinctive drainage dykes, marshes, shingle coastal promontories and open skies. These characteristics contrast with the distant inland backdrop of well-wooded rising ground approx 12-14km to the north and west.

12.4.19 Within Kent a number of more detailed Landscape Character Assessments have been carried out over recent years and these have now been consolidated and edited into a countywide study called The Landscape Assessment of Kent October 2004. This assessment indicates that the site lies in the “Dungeness Shingle” landscape character area.

12.4.20 To the north, east and west of the Dungeness Shingle lie the “Brookland Farms”, “The Romney Coast” and “Walland Marsh Farmlands” landscape character areas respectively. The open seascape of the English Channel lies immediately to the south and east of the Dungeness shingle.

12.4.21 The dominant landscape elements of the Dungeness Shingle landscape character area are the flat landform, with the micro-relief of shingle ridges, and the exposed coastal location with associated constant winds and extremes of climate. The wind- sculptured shapes of the woody scrub reflect the exposed nature of the area.

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12.4.22 Vast areas of disturbed shingle, security fencing and flooded mineral workings/gravel extraction mark the centre of the character area. The site itself lies on the transition from the exposed shingle to grassland and agriculture on thin soils.

12.4.23 The great open expanses of shingle and farmland together with the almost constant noise of the wind create a sense of isolation and remoteness heightened by the distant views of the power station and transmission lines to the south. However, the noise from the military firing ranges and aircraft operating from LAA precludes a true sense of “tranquillity” in the area. Gravel workings, both past and present, military uses and expanding holiday resorts create a visual clutter along the coast which detracts from the openness and remoteness.

12.4.24 Apart from the power station and the 1904 and 1960 lighthouses at Dungeness Point, other significant skyline features in the vicinity of the site are the water tower at the south east corner of the airport, the experimental 1930s concrete sound “Mirrors” to the east of the site and the church towers of Lydd and New Romney. Intervisiblity in the open landscape is theoretically good although in practice is often hampered by frequent mists and haze and the considerable distances between features in the open landscape.

Sensitivity

12.4.25 Dungeness is the largest shingle foreland in Europe and is a unique and highly valued landscape. The Kent and Medway Structure Plan (adopted 2006) identifies Dungeness as a Special Landscape Area (SLA). SLAs are of strategic importance, recognised as being of a landscape quality and sufficient in scale to be of scenic significance in the county context. Structure Plan Policy ENV4 gives priority to the conservation and enhancement of the landscape in SLAs and provides for their long- term protection. The boundary of the SLA is defined in the Shepway District Local Plan (adopted 2006). The SLA lies approximately 200m to the south of the proposed runway extension.

12.4.26 The Local Plan Review also identifies areas, which are of particular local landscape value and/or act as green buffers within or adjoining urban areas, contributing to local environmental quality and identity. Much of Romney Marsh is identified as a Local Landscape Area (LLA). Most of the open land immediately surrounding LAA to the west, north and east falls within the LLA. This includes most of the proposed runway extension site which lies largely within the southern edge of the LLA.

12.4.27 The stretch of coastline from Greatstone-on-Sea to Dungeness has been designated in the Local Plan Review as Undeveloped Coast. This designation relates to significant areas of coast, which are dynamic and vulnerable to coastal processes and often specifically identified for their nature conservation importance.

12.4.28 The sensitivity of the Dungeness Shingle area is considered to be high using the scale in Table 12.1. This is due to the high visibility over the dominant landform, and the many unique features. The cluster of defence installations, the power station, the sound “Mirrors”, the old water tower and holiday properties on the spit, specialised coastal and shingle-based vegetation, all contribute to a very strong sense of place. The landscape is highly valued as demonstrated by the various designations described above.

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12.5 Baseline Environment (Future Assessment Conditions Scenario)

12.5.1 The baseline environment under this scenario is the same as described under the ‘existing conditions scenario’ above. The only difference from a rise to 300,000 passengers per annum will be an increased visibility of aircraft on the existing runway seen from the east (once Natural England removes the scrub vegetation within the airport boundary).

12.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

12.6.2 Landscape Effects

12.6.3 Construction of the runway extension and installation of approach lights and all necessary associated drainage and services, together with the cutting and grading of areas to either side and at the end of the runway extension to comply with safety requirements, will result in the permanent incorporation of approximately 9.92ha of farmland into the airport boundary.

12.6.4 The part of the site within the existing airport boundary (approximately 3.46ha) will not change from its current land use or appearance when the work is complete except for the area of land that will be covered by part of the new runway extension itself. However, during construction parts of this area will be used for temporary haul roads and low level stockpiling of materials (up to 2m) whilst construction works progresses. Similarly, parts of the farmland being incorporated into the airport will also be used for temporary haul roads and the low level stockpiling of materials whilst construction works progresses. Until final seeding of the proposed grass areas has established the ground surface will be either bare soil or spoil heaps of soil or aggregates.

12.6.5 The construction of the runway extension will result in the loss of approximately 9.92ha of farmland on the edge of, and just within, a Local Landscape Area designated primarily because of its characteristic hedgeless and largely treeless mixed farmland compartmented by drainage ditches. The designation does, however, include other visually quite different landscape uses such as the nearby Lydd Golf Course and is immediately adjacent to the large area of managed grassland within the existing airport to which the changed use of the site would be an addition.

12.6.6 Whilst in local or district terms this change to the landscape of the site can be said to be of moderate significance, in terms of county or regional impact it is of negligible significance.

12.6.7 Visual Effects

12.6.8 The most likely visual impacts on receptors during construction will be the presence of temporary fencing, haul road surfaces and stockpiles of materials and the movement of earthmoving and runway laying machinery on the site as well as bare soil surfaces. Visually the bare soil would be no different from newly ploughed or tilled arable land, particularly at the distances at which it would be seen and can be discounted. The presence of construction related fencing, haul roads, materials stockpiles, equipment and machinery will be temporary and transient according to the work being carried out. Given the considerable distances from which the great majority of receptors will have sight of these intrusions, given the modest size and extent of these intrusions within these views and given their temporary and transient nature, their impacts can be considered of negligible significance.

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Future Assessment Conditions

12.6.9 Construction impacts under this scenario are predicted to be as for the ‘existing conditions scenario’ above.

12.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

12.7.1 The “existing conditions scenario” would result in most of the area proposed for the runway extension continuing in agricultural management as is currently the case, whilst that part of the proposed site within the existing airport limits would continue to be maintained in a short grass regime in accordance with safety requirements.

12.7.2 Within the airport boundary, existing management work would continue, including works associated with the cut and graded area to either side of the existing runway and most notably Natural England’s planned scrub removal from parts of the Dungeness Shingle SSSI and SAC which are within the airport to the east of the existing runway.

12.7.3 Although the condition of the airport and adjacent farmland would therefore be expected to remain generally in their existing form as current management practices are anticipated to continue, the scrub removal will result in increased visibility of aircraft on the existing runway seen from the east and south east.

12.7.4 As it is anticipated that there will be no changes to current management or farming practices, there will be no changes to the landscape resource or landscape character of this area.

12.7.5 As with the effects on the landscape itself, the fact that no changes are anticipated to current management or farming practices, means that there will be no change in its visual appearance and therefore no change in its effect on visual receptors.

12.7.6 However, removal of scrub vegetation by Natural England elsewhere within the airport boundary will result in aircraft on the existing runway becoming more visible from the publicly accessible parts of the Dungeness Shingle SSSI and SAC. Given the size of aircraft currently operating from the airport, the transience of their presence on the runway, the fact that the airport exists, the distance that receptors would be from the runway and the resulting receptor sensitivity and magnitude of change, the significance of this visual impact would be slight and neutral.

Landscape Effects

12.7.1 Although some of the area will be hardstanding for the runway extension itself, the effect of the changes to the site once it is operational will primarily be the conversion of approximately 9.92ha of mixed grazing but predominantly arable farmland to amenity grassland managed as a short grass regime for safety reasons.

12.7.7 As with the landscape effect during construction, whilst in local or district terms this change to the landscape of the site can be said to be of moderate significance, in terms of county or regional impact it is of negligible significance.

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Visual Effects

12.7.8 The (ZVI) (see Figure 12.1) from which some part of the proposed site may be seen extends approximately 1km to the north east and south west and approximately 2km to the north west and south east.

12.7.9 The attached table of receptors (Table 12.4) sets out on an area by area basis, starting in the north east and working clockwise around the compass, definable areas of receptors within the (ZVI). The table then briefly describes each group of receptors, lists the distance from the nearest and furthest parts of the area to the nearest edge of the site, describes the extent of views possible from each area and then sets out the receptor sensitivity and magnitude of change. Finally it summarises the significance of the unmitigated visual impact and whether it is neutral, beneficial or adverse.

12.7.10 Additional information explaining the context of the various views to an extent which cannot be accommodated in the table is set out in the paragraphs below. The plans and views referred to below or in Table 12.4 can be found on Plates 12.1 – 12.12.

12.7.11 The open flatness of the site and its surroundings means that there is a relatively large area, most of it either farmland or the airport itself, from which the runway would be visible. However, the flatness of the site and the acuteness of the angle at which the viewer sees it means that the site is generally only visible as a thin horizontal sliver as just one small part of the overall view in which the foreground or skyline elements or the sky itself draw the eye. The limited visibility of the northern end of the existing runway in View 2 (Plate 12.2) demonstrates this effectively.

12.7.12 As can be seen from the Table of Receptors (Table 12.4) the great majority of receptors have views of the site from a distance of 500m or more. The only receptors within 500m of the site would be farm workers working on the farmland, maintenance and some other airport operatives “airside” on the airport itself and visitors to the small motorcycle circuit to the north west of the site accessed through Belgar Farm.

12.7.13 As a consequence, both the receptor sensitivity and the magnitude of change are generally low and the significance of the unmitigated impact is slight. This is principally due to distance, the fact that views are infrequent or transient and that the site forms only a small part of the viewer’s natural cone of vision, resulting in only small and subtle changes to the view. The only exceptions are some views from the shingle platform at the edge of Greatstone-on-Sea and the shingle ridges to the east and south of the sound “Mirrors” where the receptor sensitivity is considered to be medium. Only in the closest of these views (from the western end of Baldwin Road in Greatstone-on-Sea (View 2, Plate 12.2)) is the magnitude of change considered medium resulting in a significance of unmitigated visual impact that is consequently moderate.

12.7.14 The airport, generally seen as a background feature of little visual significance, is already a familiar part of the overall character of the area, particularly for those that live and work in the vicinity. Although some visible change in the view would be evident to some receptors as set out in Table 12.4, the fact that the runway extension results in what at a distance is a relatively subtle change in the balance of maintained grassland to farmland in the overall view, means that the significance of the change can be considered neutral in all cases.

12.7.15 With regard to the visibility of aircraft in the sky approaching and landing or taking off at the airport, View 12, (Plate 12.12), taken from the same location as View 2 (Plate 12.2), shows how small a twin-engined six-seater aircraft appears when coming in to land at a distance of approx.1km from the viewer. Twelve movements per day of

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larger aircraft would result from the runway extension and 300,000 passengers per year. Four of these movements would be by the largest proposed aircraft, Boeing 737s or Airbus A319s. These aircraft would be more visible than the aircraft in the photograph, however, for the great majority of receptors at 500m or more from the runway, they will still only form a subordinate and transient element in the overall view. The magnitude of change in the view compared with the aircraft in the photograph would be medium. As most of the receptor sensitivities are low, this would result in a significance of unmitigated impact that is slight to moderate and, in the few cases where receptor sensitivities are medium, in a significance of unmitigated impact that is moderate. For the reasons given in Sections 12.7.12-14 above, the significance of these impacts can be considered neutral.

12.7.16 With regard to lighting impacts, whilst the existing runway lights at the threshold 21 will be relocated from the end of the runway to sites within the starter extension and RESA, the total extent of lighting will not change and the considerable distance means that no significant impacts are anticipated. 12.7.17 Impacts arising through traffic disturbance or other effects on local ambience are dealt with elsewhere in this document.

Future Assessment Conditions Scenario 12.7.18 Predicted Impacts arising from the operational impacts of the facility under this scenario are expected to be the same as described under the “existing conditions scenario” above. 12.7.19 It is anticipated that, with regard to impacts on landscape and visual amenity as a result of the construction phase of the proposed terminal building, there would be no difference between the baseline and future assessment condition scenarios. As such no mitigation measures are proposed here.

12.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

12.8.1 Often, where visual impacts of a proposed development occur, screening with landform and/or planting is commonly introduced to reduce the visibility of the development. This is only appropriate, however, where such landform or planting contributes appropriately to the landscape structure and character of the area. In this instance, the area is characterised by the flatness of the airport and surrounding farmland and the compartmentation of the landscape by drainage ditches and water courses, not by hedges. It is a large open landscape in which small changes in level are imperceptible.

12.8.2 Planting of trees and hedges is inappropriate in this context. Minimisation of visual impact is achieved by the fortuitousness of distance between the site and the great majority of receptors, the flatness of the site and its surroundings and the visual similarity of short mown grass on the airport and grazing land or low vegetable crops on adjacent farmland which, at a distance, become almost indistinguishable in terms of both colour and texture.

12.8.3 In the event that the surplus soil (approximately 19,500m3) generated from excavations to construct the runway extension is spread evenly within the application boundary (over the clear and graded areas) before grassing the runway surrounds, clear and graded areas would be filled to a depth of 0.24m above the level of the runway extension; all associated edges would have a shallow transitional slope of 5%. Seen at a distance of 500m or more by all but a small number of transient farm or

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airport workers, this change in level will be imperceptible. It will therefore have no effect on the significance of the unmitigated impacts, and is not deemed necessary during the construction phase.

Future Assessment Conditions Scenario

12.8.4 Construction mitigation measures for this scenario are as proposed for the ‘existing conditions scenario’ above.

12.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

12.9.1 As the great majority of receptors have views of the site from a distance of 500m or more, and the fact that the runway extension results in what at a distance is a relatively subtle change in the balance of maintained grassland to farmland in the overall view, leads to no proposed operational mitigation measures. Future Assessment Conditions Scenario

12.9.2 Operational mitigation measures are as proposed for the ‘existing conditions scenario’ above.

12.10 Residual Effects

Existing Conditions Scenario

12.10.1 As the mitigation measures that are appropriate would be of only marginal effect, and in any event, would not affect the significance of the unmitigated visual impacts, there are no residual effects to report for this scenario.

Future Assessment Conditions Scenario

12.10.2 Residual effects are as described above for the ‘existing conditions scenario’.

12.11 Summary

12.11.1 The proposed site is located at the point of transition between the Dungeness Shingle, which is identified as a Special Landscape Area (SLA), and the Romney Marshes area of flat open farmland, much of which lies within an area designated a Local Landscape Area (LLA). The proposed site lies outside the SLA and has no impact upon it in terms of landscape character. The site just sits on the edge of the LLA and the impact of the proposed runway on the landscape character of this area is considered to be slight and neutral.

12.11.2 The table of impacts on visual receptors (Table 12.4) indicates that in almost all cases the significance of the unmitigated impact on those with a view of the proposed runway extension will be slight and neutral. In only a small number of instances, the impact is considered greater, being moderate and neutral. The degree of significance of these unmitigated impacts is due principally to distance, the fact that many views are infrequent or transient and that for many the changes caused by the proposed development will form only a small part of the viewer’s natural cone of vision.

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12.11.3 The construction of the runway extension will enable larger aircraft to use the airport. The small number of daily movements of larger aircraft would result in visual impacts that are generally slight to moderate but neutral.

12.11.4 There are no appropriate mitigation works that would significantly reduce the impacts on either the landscape character of the area or the visual impacts on human receptors. Therefore no residual effects are anticipated as a result of the unmitigated impacts assessed.

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Table 12.4 Visual Impact on Receptors by Area

Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA A

Area of open flat farmland compartmented 0-c.980m Runway extension and landing lights seen almost end-on. Views Low Low Slight, neutral by drainage ditches by farm workers when working on the land. Presence infrequent and transient.

Glimpse views at an angle from moving train. Site forms only a Romney Hythe and Dymchurch railway c.700-980m small part of the overall view. Views are generally infrequent and Low Low Slight, neutral Line transient.

Residential development on the south side Views of runway extension and landing lights will vary according of Dunes Road, Greatstone-on-Sea c.750-950m to vegetation/fencing at end of gardens. Views more likely from Low Low Slight, neutral those dwellings with upper floor windows. At this distance landing light posts unlikely to be visible but lights may spill some light in dull/dusk/evening light. Site forms only a small part of the overall view. AREA B

Area of open flat farmland compartmented 0-c.780m Runway extension and landing lights seen side-on. Views by Low Low Slight, neutral by drainage ditches farm workers when working on the land. Presence infrequent and transient.

Fenced private land with “keep out” signs but unofficial access to Flooded former gravel workings with c.250-875m walk the margins appears commonplace. Glimpse views through Low Low Slight, neutral vegetated margins scrub vegetation in places.

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA B (contd)

Publicly accessible shingle platform raised c.500-1000m Clear if distant views of site for walkers on edge of shingle Medium to Medium to Moderate to by up to 2m above adjacent farmland and platform (Views 2 and 3, Plates 12.2 and 12.3). Views from low low slight, neutral gravel workings with a school, caravan park caravan park and residential development will vary according to and residential development along its boundary vegetation and fencing. Views most likely from upper eastern edge floor windows. Views possible from edge of school site but unlikely from school building.

The most elevated views available of the site, but site only partly Small area of sand dune tops at back of Medium Low Slight, neutral c.950-1030m visible between foreground buildings (View 1, Plate 12.1). Greatstone-on-Sea public car park Viewers limited to some walkers and holidaymakers who are more likely to be looking seawards.

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA C

Flooded former gravel workings with “The c.750-1350m Controlled access to parts of area to view “The Mirrors” but no Medium Low Slight, neutral Mirrors” sitting within scrub vegetation on general access. Glimpses of small parts of proposed site through western margin foreground of scrub vegetation. ”The Mirrors” themselves draw the eye (View 5, Plate 12.5).

Glimpses of site through scrub vegetation around “The Mirrors” Shingle ridges and shingle platform up to in the middle ground. “The Mirrors” themselves draw the eye. 2m above adjacent shingle ridges with c.1000-2000m Views from residential development are oblique and will vary Low Low to Slight to residential development along its eastern according to boundary vegetation and fencing (View 4, Plate negligible negligible, edge 12.4). Views most likely from upper floor windows. Site forms neutral only a small part of the overall view.

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA D

Some flat open farmland compartmented 0-c.850m Oblique views of runway extension. Views by farm workers when Low Low Slight, neutral with drainage ditches working on the land. Presence infrequent and transient.

Some fenced off areas of the shingle ridges Limited access. Only likely receptors are ecologists visiting the which are part of the Dungeness SSSI and c.250-850m SSSI/SAC. Presence infrequent and transient. Oblique views of Low Low Slight, neutral SAC runway extension only likely once scrub clearance by Natural England carried out.

Clear if distant and oblique views of site for walkers who get this Publicly accessible part of the shingle c.850-1000m far (numbers likely to be limited) (View 6, Plate 12.6). Medium Low Slight, neutral ridges which are part of the Dungeness SSSI and SAC

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA E

Some flat open farmland to west of airport c.150-950m Oblique views of runway extension. Views by farm workers when Low Low Slight, neutral compartmented with drainage ditches working on the land. Presence infrequent and transient.

“Airside” part of Lydd Airport Oblique views of runway extension dominated by visibility of 0-c.1600m existing runway. Views by airport staff carrying out maintenance Low Low Slight, neutral and by aircraft crew and passengers. Presence infrequent and transient.

AREA E (Contd)

Access road to Lydd Airport and the main c.1000m Oblique glimpse views over foreground of rough grass and Low Low Slight, neutral terminal and hangars hardstanding for airport workers, visitors (View 7, Plate 12.7) and passengers. Views from buildings themselves are limited.

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA F

Area of open flat farmland compartmented 0-c.1000m Runway extension seen side-on. Views by farm workers working Low Low Slight, neutral by drainage ditches. on the land. Presence infrequent and transient.

Small motorcycle circuit within farmland Runway extension seen side-on. Views by visitors to circuit. accessed via Belgar Farm. c.350-500m Presence infrequent and transient. Low Low Slight, neutral

Lydd Golf Course Oblique views of runway extension from parts of the golf course. c.550-1400m Visibility dictated by undulations in golf course topography (View Medium to Low Slight, neutral 8, Plate 12.8). Presence regular or infrequent and transient. Site low forms only small part of overall view. AREA G

Area of generally flat farmland with some c.450-2150m Distant views from parts of area. Some views screened by Low Low Slight, neutral minor undulations, compartmented by intervening scrub vegetation. Views by farm workers when drainage ditches. Some sporadic scrub working on the land. Presence infrequent and transient. planting on ditch edges, some trees around farm buildings. Small number of farmsteads within the area. There may be views possible from one or two of the farmsteads, most likely from upper floor windows (e.g. Belgar Farm) but site Medium Low Slight, neutral forms only small part of overall view.

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Location Distances Descriptions of View Receptor Magnitude Significance of Sensitivity of Change Unmitigated (to nearest Impact edge of site) AREA G (Contd)

Public footpath across parts of this area of c.1050-1825m Runway extension may just be visible from parts of this footpath Medium Low Slight, neutral farmland for walkers heading south (View 9, Plate 12.9). Presence infrequent and transient.

For drivers it is unlikely that the runway extension would be B2075 Romney Road and a small number c.1500-2100m visible but for passengers it may just be possible (View 10, Plate Low Low Slight, neutral of dwellings on the east side of the road 12.10). Views would be infrequent and transient. For residents there may be glimpses of part(s) of the runway extension depending on boundary fencing and vegetation. Few upper floor windows in these dwellings.

Pedestrians on this lane may have glimpse views between barns Eastern part of Church Lane on southern and sporadic hedgerow vegetation (View 11, Plate 12.11). Site forms only a small part of the overall view. edge of New Romney c.1380-1730m Low Low Slight, neutral

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CHAPTER 13

CULTURAL HERITAGE AND HISTORIC ENVIRONMENT

CHAPTER 13

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13 CULTURAL HERITAGE AND HISTORIC ENVIRONMENT

13.1 Introduction

13.1.1 This chapter assesses the impacts of the proposed runway extension on the historic environment. The historic environment is considered in three sections - Archaeology, Historic Landscape and Historic Buildings.

13.1.2 An outline of the planning policy context is provided followed by sections describing the assessment methodology, baseline conditions and potential impacts resulting from the development. The need for mitigation measures are also considered and any residual effects described.

13.1.3 The scenarios modelled in this chapter are as described in Chapter 1.

13.1.4 Reference should be made to the Archaeological Gazetteer (see Appendix 13.1) for further details, and the following documents have been adhered to:

• Institute of Field Archaeologists - Code of Conduct;

• Institute of Field Archaeologists 1999 - Standard and Guidance for Archaeological Desk-based Assessments;

• English Heritage 1991 - Management of Archaeological Projects; and

• Association of County Archaeological Officer's 1993 - Briefs and Specifications for Archaeological Assessment and Field Evaluations 13.1.5 The work of the Romney Research Trust has also been reviewed for the compilation of this report.

13.2 Legislative Drivers

National Planning Policy

13.2.1 Planning Policy Guidance 16 (PPG16) – Archaeology and Planning - outlines government guidance on the role of the Local Planning Authority in safeguarding the archaeological resource through the development control process. It sets out the Secretary of State’s policy on archaeological remains and provides a number of recommendations many of which have been integrated into local development plans.

13.2.2 Planning Policy Guidance 15 (PPG15) – Planning and the Historic Environment - considers the impact of development on existing buildings, and on the character of areas that are recognised for their landscape or townscape value. The protection of the historic environment needs to be considered within the context of sustainable development. The District Council will ensure that the impact of proposals for new development on the historic environment is fully considered. The Government 'lists' buildings as being of special architectural interest. These buildings are subject to special planning controls over their demolition, including partial demolition, alteration or extension in any manner, which affects their special character.

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13.2.3 With regard to the landscape it states that:

"The physical survivals of our past are to be valued and protected for their own sake, as a central part of our cultural heritage and our sense of national identity…. Their presence adds to the quality of our lives, by enhancing the familiar and cherished local distinctiveness which is so important an aspect of the character and appearance of our towns, villages and countryside.

In the countryside the detailed patterns of fields and farms, hedgerows and walls, and of hamlets and villages, are among the most highly valued aspects of our environment. The whole of the landscape, to varying degrees…is an archaeological and historical artefact…much of its value lies in its complexity, regional diversity and local distinctiveness" 1

13.2.4 This planning guidance is adopted within the Shepway Local Plan through Structure Plan Policies ENV 5 (SSSI’s), ENV13 (Rural Lanes), ENV18 (Archaeology), ENV19 (Listed Buildings).

13.2.5 It should be noted that PPG 15 is shortly to be combined with PPG16 as a revised Planning Policy Statement (PPS) 15 Historic Environment.

Regional Planning Policy

Regional Planning Guidance (RPG)

13.2.6 The Department of Employment, Training and Rehabilitation (DETR) Government Office for the South East refers to their policy with regard to archaeology and built heritage in Regional Planning Guidance RPG9 through Policy E1. This policy states that “Priority should be given to protecting areas designated at international or national level either for their intrinsic nature conservation value, their landscape quality or their cultural importance.” The South East Plan will, upon adoption, replace RPG9 for the south-east and it sets out a vision for the future of the region through to 2026 focusing on housing, transport, economy and environment. The policy is presented in full within Chapter 5.

Kent and Medway Structure Plan 2003 SPG1: Landscape Character

13.2.7 Policy SPG1 offers Supplementary Planning Guidance (SPG) to supplement the policies and proposals of development plans. It "elaborates policies so that they can be better understood and effectively applied". SPG1 supplements draft policies E3 - E5 which was adopted in 2005.

13.2.8 Policy E5: Special Landscape Areas (SLAs) will "provide long term protection and enhancement of the quality of the landscape whilst having regard to their economic and social well being. SLAs are not national designations but have been identified in earlier Structure Plans because of their strategic landscape importance and significance in a countywide context". The Old Romney Shoreline and Dungeness are designated SLAs in Policy E5.

1 Kent and Medway Structure Adopted Plan (2006) Supplementary Planning Guidance SPG1: Landscape Character (July 2006)

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Kent Regional Planning Policy

13.2.9 Kent County Council's Regional Planning Policy QL8 refers to archaeological sites. It states that:

“The archaeological and historic integrity of scheduled ancient monuments and other important archaeological sites, together with their settings, will be protected and, where possible, enhanced.

Where important or potentially important archaeological remains may exist, developers will be required to arrange for archaeological assessment and/or field evaluation to be carried out in advance of the determination of planning applications.

Where the case for development affecting an archaeological site is accepted, the archaeological remains should be preserved in situ. Where preservation in situ is not possible or justified, appropriate provision for preservation by record will be required.”

13.2.10 The SPG on archaeology provides further guidance to Policy QL8: Archaeological Sites' and represents a 'link' between the Kent and Medway Structure Plan and the Extensive Urban Archaeological Survey undertaken by Kent County Council. The guidance is concerned with the impact of development on archaeological remains within towns rather than sites in the surrounding countryside. Although SPG3 applies to Lydd it does not apply to the surrounding countryside including London Ashford Airport (LAA).

Local Planning Policy

Shepway District Adopted Local Plan (July 2006)

13.2.11 Local Plan policies regarding archaeology and cultural heritage are referred to by the following policies:

• ENV5: Development which would materially harm the scientific or wildlife interests of Ramsar Sites, designated or potential Special Protection Areas, and Special Areas of Conservation, National Nature Reserves and Sites of Special Scientific Interest, will normally be refused.

• ENV13: Rural lanes which are of landscape, amenity, nature conservation, historic or archaeological importance will be protected from changes which would damage their character and enhanced.

• ENV18: In the control of development and through policies and proposals in local plans:

i The archaeological and historic integrity of scheduled ancient monuments and other important archaeological sites and historic landscapes, together with their settings will be protected and where possible enhanced. Development that would adversely affect them will normally be refused.

ii Development may be permitted where this would provide the best reasonable means of conserving the character, appearance, fabric,

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integrity and setting of the ancient monument, archaeological site or historic landscape.

iii Where the case for development which would affect an archaeological site is accepted by the Local Planning Authority, preservation in situ of archaeological remains will normally be sought. Where this is not possible or justified, appropriate provision for investigation and recording will be required.

iv Prospective developers will be requested to arrange for an archaeological field evaluation to be carried out in advance of determination of planning applications where it is indicated that important or potentially important archaeological remains may exist.

• ENV19: In the control of development and through policies and proposals in local plans:

i Listed buildings will be preserved and their architectural and historic integrity and the character of their settings will be protected and enhanced;

ii Changes of use will be permitted where these would provide the best reasonable best means of conserving the character, appearance, fabric, integrity and setting of listed buildings; and

iii In the case of demolition/substantial demolition (which will only be permitted exceptionally and where there is a strong justification) or where alterations would lead to the destruction of part of the fabric of a listed building, appropriate arrangements may be required for investigation and recording by an approved building recorded or archaeologist. 13.3 Assessment Methodology

13.3.1 The purpose of this assessment is to collate relevant historical and archaeological data, to gain information about the known or potential archaeological and cultural heritage resources within the assessment area; to provide information on the extent, character, date, integrity, state of preservation and relative quality of archaeological deposits within the assessment area, taking into account all known previous land uses; and assess the potential impact of the proposed development on any archaeological remains, whether known or postulated.

13.3.2 Consideration has been given to potential construction impacts upon the historic environment and the extent and nature of proposed mitigation measures that could be employed.

13.3.3 Determination of the current baseline for the historic environment has been achieved through the analysis of known archaeological and historical landscape features and buildings within a 3km wide study area centred on National Grid Reference (NGR) TR 606500 121750. Information relating to sites outside the study area have been referenced where it provides insights or parallels to the wider historical, cultural or archaeological context.

13.3.4 Kent County Council's Sites and Monuments Record (SMR) and the National Monuments Record (NMR) have been consulted for a 3km (linear) square study area centred on TR 606500 121750 (Figure 13.1). Shepway District Council and the

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NMR's listed buildings data have been consulted for a 2km (linear) square study area with the same centre. Where relevant, data has also been drawn from a wider area based on the 'Romney Marsh and Western River Valleys Archaeological Gazetteer compiled by Alan Tyler (November 2004) and the South Foreland to Beachy Head Shoreline Management Plan (Draft January 2005). The Kent County Council’s Archaeological Department have also been consulted regarding the general scope of the report. The chief cartographic sources have been used and a selection of these are below2 3 4 5. Printed primary and secondary sources for the history of the area have been employed, and the research pursued into the manuscript collections of the London Library and the Centre for Kentish Studies (Maidstone).

13.3.5 Historic landscape characterisation data was drawn from the Kent and Medway Adopted Structure Plan 2006 – SPG1: Landscape Character July 2006, and Kent and Sussex Biodiversity Action Plan (BAP) – Appendix D: Shoreline Management Plan.

13.3.6 Historic Landscape Characterisation (HLC) has been carried out over the area of the Dungeness Foreland including Denge Marsh and the Lydd/Holmstone Beach shingle ridge. LAA lies at the centre of this area.

13.3.7 The assessment has been achieved through the identification and interpretation of HLC attributes which have been grouped into HLC types/areas within the current landscape of the study area. An analysis of the key features within each of the HLC character areas has been made in order to assess (where relevant) time-depth, past landscape change and land use, landscape rarity and survival, chronology and process of land enclosure and present and future landuse including, where relevant:

• Current land use;

• Past land use;

• Field morphology;

• Boundary types; and

• Distribution and types of surface deposits.

13.3.8 Distribution and type of resources (water, mineral, pasture)

• Place names and earliest references;

• Settlement types and patterns;

• Communication types and patterns;

• Historic mapping;

• Geological, soil, hydrological and topographical mapping;

• Selected historic mapping; and

• Aerial photographs.

2 www.liv.ac.uk/geography/Romney Marsh 3 www.durham.ac.uk/geography/Romney Marsh 4 www.rmcp.co.uk/canal 5 Sortie Number: RAF/CPE/UK/1752, Date: 21/09/1946, Sortie Number: RAF/58/2778, Date: 1/05/1959 Sortie Number: OS/73182, Date: 16/05/1973, Film No: MAL/79030, Date: 6/08/1979 Sortie Number: OS/88125, Date: 22/05/198

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13.3.9 The assessment of the historic environment within the study area involved the collection and analysis of additional information regarding the spatial pattern of the landscape in the adjacent area, the topography of the area and the underlying drift geology of the site and its immediate vicinity.

Significance Criteria

13.3.10 The significance criteria used to determine the magnitude of potential impacts on the historic environment are based on the value and importance of the resources and the extent of the development impact on them. A five level scale of Archaeological Significance Criteria is used and each level is defined within Table 13.1 below.

Table 13.1 - Archaeological Significance Criteria

Significance Indicative Criteria

No detectable impact. Archaeological resource unaffected by development. Negligible No mitigation required.

Area of development impact is < 5% of area of archaeological resource characterised by low information retrieval levels and/or poor condition of Minor (not resource. Such deposits may include widespread homogeneous soils or significant) more complex stratigraphy that is badly fragmented e.g. Denge Marsh deposits. Limited mitigation is required e.g. sampling of marsh deposits through borehole investigation.

Area of development impact is 5-10% of area of archaeological resource characterised by low information retrieval levels and/or poor condition of Medium/ resource. Such deposits may include widespread homogeneous soils or Moderate (not more complex stratigraphy that is badly fragmented e.g. Denge Marsh significant) deposits. Limited mitigation is required e.g. archaeological watching brief. The integrity of the archaeological resource would be unaffected by this procedure.

Area of development impact is >10% of area of archaeological resource characterised by low information retrieval levels and/or poor condition of resource or an archaeological resource characterised by a high information retrieval potential suffers development impact effects - in this situation the size of area is irrelevant. Such deposits may include more complex High Significant stratigraphy e.g. structural or ritualistic deposits. Mitigation is required and (significant) this would be achieved through archaeological excavation within the footprint of disturbance. PPG16 and Local Plan policies require mitigation through redesign to reduce impact and allow preservation in situ or preservation by record through archaeological excavations. Archaeological data retrieval would provide a positive input to research aims and objectives.

Areas of potentially significant archaeology, archaeological priority areas or Scheduled Ancient Monuments and their settings that would be severely affected by the development. PPG16 and Local Plan policies require Critical mitigation through redesign to reduce impact and allow preservation in situ (significant) or preservation by record through extensive archaeological excavations. Archaeological data retrieval would provide a positive input to research aims and objectives.

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13.4 Baseline Environment (Existing Conditions)

13.4.1 The baseline conditions data has been divided into three sections: archaeology, historic landscape and historic buildings.

Archaeology

Prehistoric

13.4.2 In the archaeological databases, there are no entries predating the Bronze Age for the study area. Finds distribution patterns indicate Bronze Age occupation west of Lydd where the Romney Marsh Archaeological Gazetteer lists two possible ring ditches (Gaz. nos. 12 & 13) and a hoard of 5 bronze axes and 8 bronze ingots. These were retrieved from Pioneer Quarry approximately 1.2 km west of the subject site (Gaz. nos. 14 & 15). The bronze axes' typology indicates a date of c. 1800 – 1600 BC. Unfortunately because their stratigraphic context was destroyed it is not known if they were buried on land or as a result of a wrecked ship. Under such circumstances their location cannot be used to imply a more accurate position for the past shoreline.

13.4.3 Evidence for Bronze Age activity on Lydd Beach was observed on the shingle ridges close to Caldicott Farm when several possibly Bronze Age (2000 - 650 BC) hearths, some with associated worked flint, were identified (Gaz. Ref. TR 02 SE 69 – KE17660). Also, further south along the shingle ridge a group of Early Bronze Age axes was discovered about 1km south of Caldicott Farm (NGR: TR 0466 2194).

13.4.4 There is only sparse evidence for Iron Age activity in the vicinity of the study area. At Bretts Lydd quarry, several kilometres west of the subject site, excavations in 1998 recorded Iron Age pottery, briquetage, fired clay and a timber feature. Within the study area, however, there are no entries of Iron Age date within the archaeological databases.

Roman

13.4.5 In the Roman period Romney Marsh was 'locationally marginal and its hinterland lacked major centres of consumption or villa-based estates' 6. It appears to have been an extensive saltmarsh protected by the shingle barrier. At this time the site's location is likely to have been offshore east of the Lydd Beach shingle.

13.4.6 On the marsh itself only small-scale settlement occurred which was probably associated with grazing and salt production. The salt marshes behind the gravel barrier in the vicinity of Lydd may have been utilised in this way and further evidence of salt production was recorded at Bretts Quarry west of Lydd. Within the study area, however, the database does not list any Roman entries and the study area is likely to have been off-shore at this time.

Saxon

13.4.7 Archaeological evidence for Saxon activity in the vicinity of the study area indicates that the dry ground along Lydd Beach was occupied. A Saxon Charter of the 8th century refers to a grant of rights and land at 'Hylde'. This gives Lydd its present name - 'hlid' is an Old English word meaning slope 7. The settlement at Lydd

6 Long A. (et al) 2002 Romney Marsh: The Changing Landscape - Romney Marsh Coastal and Landscape Change through the Ages, Oxford University School of Archaeology 2002 Monograph No. 56 7 Cameron K. 1969 English Place Names

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originated in the Saxon period is further supported by All Saints' church which has 8th or 9th century masonry walls at the western end of the knave. Although there is no evidence for the early formation of Denge Marsh at this time, the route to Romney along the Lydd Beach gravel barrier may have been established, as a coin dated AD 978-1016 was discovered there in 2001 (Saxon no.105).

13.4.8 Evidence for Saxon activity on the foreshore was recorded during gravel extraction at Denge West Quarry in 1994-5. The remains of two whales were discovered which had been stranded on the foreshore in the 10th century and cut marks on the bones indicate that the local population butchered them for whale-meat. Also, at Denge West (North) Quarry three fragments of wood were found which showed evidence of wood-working and may represent activity in the inter-tidal zone, possibly predating the 8th to 10th century (Gaz. Ref. TR 02 SE 61- KE15737).

Medieval

13.4.9 At the beginning of the second millennium AD Denge Marsh, on which the subject site is situated, started to develop behind the evolving Dungeness shingle foreland. The foreland is now represented by a series of shingle ridges which can be seen running roughly north-west to south-east along the eastern side of the main runway. At about this time the River Rother was diverted into its new estuary at New Romney.

13.4.10 Romney Marsh in general was reclaimed relatively early compared to other coastal marshland areas and suggests this may be due to the presence of wealthy monasteries in Kent who possessed marshland holdings. These provided agricultural diversity for the estates initially as seasonal pasture, and later through the opportunity they provided for raising new revenue through improvement (reclamation).'

13.4.11 Such an estate is mentioned at Lydd with Ad Hlidum, Bleccing, Bishops Wick and Denge Marsh mentioned in the boundary clause. Lydd itself is mentioned in a Charter of Henry II extending the privileges of the Cinque Ports to the archbishops men of Lydd and Dengemarsh. At this time Dengemarsh Manor was a member of the Wye estate granted by William I to Battle Abbey. Battle Abbey leased pasture land to tenant farmers throughout the 14th century. Manorial records of 1556 give land rental details of the manor from Jack’s Court (Gaz. Ref. TR 02 SE 9 – KE3766), a moated house on the north-eastern side of the study area, and to the fields east and south. Dengemarsh Sewer bounded the manor to the north-west but may have originated as early as the late 8th century.

13.4.12 Salt was produced on an industrial scale on the saltmarshes between Dungeness headland and the Romney inlet at Belgar north of the subject site. Medieval salt workings are recorded 0.5km south of New Romney just north of the study area (NMR unique identifier 462815/6). They are represented by a large flat mound with linear extensions.

Post-Medieval

13.4.13 Sheep farming dominated the landuse on Romney Marsh throughout the post- medieval period until WWII when government food production policy led to an increase in ploughed land. The shift from pastoral landuse to mixed agriculture resulted in the break up of the large fields and an increase in mechanisation and labour. The ploughing also destroyed much of the evidence for medieval drainage and the saltmarsh creeks 8. Evidence from the Lydd Quarry excavations also

8 Romney Marsh Research Trust

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indicates that it truncated floor surfaces and hearths belonging to the medieval farmsteads to the west of Lydd.

Historic Landscape Characterisation

Background

13.4.14 Romney Marsh is identified as a Character Area by the Countryside Agency and is designated a local landscape by Shepway District Council 9. Also within the Kent and Medway Structure Plan SPG1 1 . Denge Marsh has the landscape action 'Conserve and Restore / Reinforce' ascribed to it. The Old Romney Shoreline and Dungeness are designated SLA in Policy E5 of the Draft SPG. The area immediately south and east of Lydd Airport is designated as Dungeness SSSI and land to the north is designated Lade SSSI.

Landscape Character Types (Kent & Medway SPG11)

Irregular Enclosures

13.4.15 Kent County Council's Landscape characterisation defines areas of 'Irregular Enclosures' on Denge Marsh around the north and west of the airport (Figure 13.2). The field patterns are defined mainly by drains orientated roughly parallel with the NW-SE shingle ridges of the Dungeness Foreland. There are two larger drains, Dengemarsh Sewer and Mockmill Petty Sewer, the former of which has a natural irregular course draining southwards. Smaller drains define the enclosures some of which have been further divided into smaller arable plots and ploughed fields since farming reforms during and after WWII involving the introduction of arable cultivation.

13.4.16 In terms of time depth, some elements of these enclosures - the drains - may be ancient and have been created soon after the early medieval development of Denge Marsh itself. This reclamation and occupation occurred behind the land and sea walls and on the well drained gravel ridges around Lydd. Small farmsteads of timber- framed buildings with straw or reed thatched roofs were situated adjacent to trackways which followed the gravel ridges and artificial ditch systems were established which incorporated the existing tidal and stream channels (8).

13.4.17 Such a ditch system was observed close to Caldicott Farm approximately 1km north- west of the site (Gaz. ref. TR 02 SE70 - KE17661). A series of ditches dating from the 11th to the 14th century was recorded which may represent the remnants of an early field system established along the edge of the principle shingle ridge. Other ditches form a broadly rectilinear pattern that extended into the western lower-lying half of the site adjacent to the Romney Road (now the B2075) which may already have been established at this time. Further evidence for early landuse was retrieved at Denge West, just south of the site, where part of what may be a medieval building was revealed during gravel extraction (Gaz. Ref. TR 02 SE 60 – KE15736). A dark finds rich layer, shingle floor, post holes and 2 ditches were observed while pottery from the site dates from the 13th to 15th century.

13.4.18 It is likely that a similar pattern of landuse evolved on Denge Marsh. Following the 12th century reclamation the farming economy in the vicinity of Lydd appears to have been based on a mixed agricultural regime. This continued until the 14th century when there was a decrease in the number of farmsteads reflecting a general trend of

9 The National and Kent and Sussex Biodiversity Action Plan - Appendix D: Thematic Studies - Shoreline Management Plan (Draft January 2005)

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depopulation on the marsh. Although the arrival of bubonic plague in 1348 accelerated the process, the depopulation continued throughout the 15th and mid 16th centuries. Holdings were engrossed and land formerly worked from two or three farmsteads was cultivated from only one. A system of larger fields was created possibly as a result of the depopulation and an increase in pastoralism.

13.4.19 Later in the 18th and 19th centuries further influences on the character of the landscape were posed by the Enclosure Acts. However, Kent County Council's SPG suggests that they 'did not affect Kent and field systems tend to maintain their medieval origins. The reasons for this are unclear but may be attributed to pastoral traditions and the custom of gravelkind or to the complexities of Kent's peninsular geology'. Nonetheless most of the remaining larger landowners lived in upland villages while their livestock was maintained by ‘lookers’ who operated from small dwellings - ‘Lookers Huts’ – spread across Romney Marsh. The sites of many of these huts are listed in the area surrounding Lydd including examples at Caldicott Farm, dating after 1830, and two other 19th century huts on the north side of Lydd (Gaz. refs. 1801-1900 nos. 384, 422 & 423). East of Lydd, on Denge Marsh, the sites of 2 Lookers Huts are known, one of which lay just to the west of the runway (Figure 13.3) (Gaz. refs. 1801-1900 nos. 427 & 429).

Dungeness Shingle

13.4.20 Shingle occupies the area to the south-east of LAA which is to the rear of the urban coastline. Within this landscape type there are three areas of 'Active and disused Gravel & Clay workings' and the Dungeness NNR. Since its deposition in the medieval period the shingle has survived in a predominantly natural state and has not been farmed although the eastern coast has been developed and Dungeness nuclear power station was built on the south coast. Because of its rarity this area is ascribed SSSI status and is referred to as Dungeness SSSI.

Parliamentary Enclosures

13.4.21 Small regular fields with straight boundaries of a parliamentary type of enclosure are defined adjacent to the east and north of Lydd town (Figure 13.3). This field pattern is likely to have originated after the post-medieval enclosures, perhaps of the common fields around Lydd and is characterised by more regular field patterns.

Historic Buildings

Listed Buildings

13.4.22 Only one listed building is recorded on Shepway District Council’s database within the 2km square (linear) study area centred on LAA. Jack's Court, also referred to as Jacques Court, is described as a Grade II listed building comprising of an 18th century, L-shaped farmhouse of 2 storeys (Gaz. ref. 8). The site was originally occupied by a medieval moated house and much of its moat still survives. It is situated on the north-eastern side of Lydd approximately 1.5km south-west of the runway extension.

Military Buildings and Structures

Napoleonic Defences

13.4.23 In the late 18th and early 19th centuries the threat of invasion from France was such that a defensive system was built along the south-eastern coast of Britain from Suffolk

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to Sussex. Romney Marsh was a flat vulnerable section of the coast at the centre of this defensive system.

13.4.24 Initially in 1798 Lade Fort was built at Lade approximately 2km east of LAA on the coast. One of the first representations of it is on the Ordnance Survey map of 1801 (Figure 13.2). It is a Scheduled Ancient Monument (SAM No. 264) and lies in an Archaeologically Sensitive Area (9). The proposed runway extension should not affect its setting as Lade Fort is separated by 2km of shingle ridges.

13.4.25 The fort is linked to a system of Napoleonic Martello Towers and the Royal Military Canal; both built in 1804 although the canal was not completed until 1806. The Martello Towers were spread along the coast line and in association with the Royal Military Canal formed a defensive system around the whole of Romney Marsh. The canal stretches for approximately 28 miles following the cliff from Hythe in the north- east to Cliff End in the south-west, several kilometres west of LAA. Although Martello Tower Nos. 10, 25 and 28 are considered notable 'Archaeologically Sensitive Areas' and tower numbers 5, 23 and 24 are Scheduled Ancient Monuments (9) neither they nor their immediate settings will be affected by the runway extension.

Greatstone listening devices

13.4.26 Due to its flat topography and location, Romney Marsh was at the forefront of the defence of Britain and in the 1930’s the RAF built an Anti-Aircraft-Detection Installation approximately 900m southeast of the site. It still survives and consists of 3 mirror-like bowls of reinforced concrete to which microphones were attached (Gaz. ref. 6). Each bowl is a Scheduled Ancient Monument – numbered: Kent 378a – c. They are situated amongst shingle ridges and a flooded pit. The proposed runway extension is not considered to directly affect the setting of the Scheduled Ancient Monuments as the two are separated by an expanse of shingle ridges.

WWII

Romney Marsh Advanced Landing Ground

13.4.27 An Advanced Landing Ground was established on Romney Marsh during WWII. Such airfields are defined as temporary and consisting of a natural earth or grass surface reinforced with wire mesh. They were in use during the build-up to D-Day. The list of UK Airfields in the SE of England locates the Romney Marsh airfield, constructed in 1943, at co-ordinates N 50 58 and E 00 52 - this is at approximately National Grid Reference TR 016 236. This location is in the vicinity of Hawthorn Corner which lies approximately 4km north-west of Lydd. Its current use is listed as 'agriculture'. The airfield was occupied by RAF Group 11 Fighter ALG and is now designated as 'extinct'. A list of RAF bases in Kent indicates that RAF Squadrons 174, 175 and 245 were based there.

Pill boxes

13.4.28 During WWII, Dungeness was protected by a series of pillboxes spread across Denge Marsh in the vicinity of LAA (Gaz. refs. 20 - 22). Further pillboxes were located to protect the coast guard station and on the beaches at Lydd-on-Sea. The pill boxes are not listed.

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Railway - New Romney Branch Line

13.4.29 In 1884 a three mile stretch of railway, the New Romney Branch Line, was opened from Lydd to New Romney. It connected the earlier (1851) line from Ashford to Hastings with Lydd Town, Dungeness and New Romney via a junction at Appledore. The branch line was originally authorised in 1866 to run from Appledore to New Romney with a further branch to Dungeness in anticipation of the future development of a port at Dungeness which did not materialise. Later in the 1870's, the idea of building a harbour at Dungeness was again receiving support, including that from Sir Edward Watkin, Chairman of South Eastern Railway. The opportunity of eventually creating a rail / ferry link from London to France and the abundance of shingle for track ballast, the excavation of which could have formed the harbour, proved almost irresistible. As a result the independent Lydd Railway Company obtained powers to build the line from Appledore to Dungeness on April 8th 1881. It was designed to be a standard gauge single track line from Appledore to Lydd with a terminus near the lighthouse at Dungeness. It was opened 7th December 1881.

13.4.30 On July 24th the following year the company was authorised to extend the branch line from a junction just south of Lydd (TR 061 206) to New Romney (Gaz. ref. 7). This branch was opened on 19th June 1884. A further line was also soon opened from Lydd Station to the artillery ranges at Holmstone.

13.4.31 During the inter-war years many summer bungalows were erected between Dungeness and New Romney causing the New Romney branch to be re-sited nearer the coast by the newly formed (1923) Southern Railway. Two new halts were provided at Greatstone-on-Sea and Lydd-on-Sea while the line terminated at New Romney. Lydd Station was renamed Lydd Town to avoid confusion. The line was brought into use on the 4th July 1937 as part of the original line from Lydd to New Romney was closed. Meanwhile the Romney, Hythe and Dymchurch Light Railway had built their line from Hythe to New Romney in 1927 under the Light Railway Act and then extended it along the coast to Dungeness10.

13.4.32 Passenger trains ceased to call at Dungeness in 1953 and the New Romney branch was closed to passengers in March 1967 but remains as a siding to mile post 74 to serve the nuclear power station. General goods traffic continued to be handled at Lydd Town until October 1971. Since then the line has been used to move locally excavated aggregate at Amey Roadstone Corporation's private sidings near Lydd. These movements ceased in 1980. The only regular traffic now remaining is nuclear waste from Dungeness Power Station.

13.4.33 At the Lydd Town station the main building, up platform and goods shed survive but the down platform, signal box and sidings have been demolished. Dungeness station has been removed and both lines lifted at the later Romney junction.

Aviation - History of the Car Freight Service at Lydd Airport

13.4.34 Romney Marsh was the location of early aviation operations, the Royal Flying Corps having airfields at Dering Dome, Lydd in 1914 and St Mary's Bay (then Jesson) in 1917 and aviators visited the marsh to built and test aircraft.

13.4.35 The original car freight airport was called Silver City and was located above the cliff at on the western side of Romney Marsh. Silver City relocated to Lydd in 1954

10 Harding P. A. 2004 The Romney Branch Line Peter A. Harding

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becoming Ferryfield Airport until 1978, the first new post-war airport in the UK. Two runways were built 'with their lengths tailored to the low sector lengths required'.

13.4.36 The site at Lydd was chosen for three reasons.

• Location close to the English Channel - Le Touquet was the closest airport in France, being only 37 nautical miles away with Silver City Airways able to transport holidaymakers and their vehicles to the Continent in less than 20 minutes; and

• The airport's location on a peninsula offered 'beneficial noise characteristics'. 13.4.37 In the early years over 130,000 cars and half a million passengers flew with Silver City Airways out of Lydd. In 1962, however, it was taken over by British United Airways and by 1965 on average 400 cars and 1,300 passengers passed though the airport each day11. It was also used by car manufacturers and dealers to export their products to the Continent.

13.4.38 With the advent of the Hovercraft and roll-on/roll-off ferries from Dover and Folkestone in the early 1970's, the premium cost of air freight became prohibitive. The last Bristol freighter flew from Lydd in October 1970 and the last car in 197112.

13.4.39 The runways were not suitable for modern aircraft which have high performance wings able to support a 'wide range of missions’. Therefore, with the removal of the Car Ferry Market, Lydd was unable to handle modern aircraft on longer journeys. In addition, there was a lack of demand for a pure inter-regional service in these days.

Built History of LAA

13.4.40 When the airport was first built, a 'car portal' type design was used consisting of single storey concrete buildings. The main hangar was built shortly afterwards. An additional administration block was added in the mid 1960's to the north-west of the main airport buildings and in the late 1970's a Plessey Watchman radar was installed.

13.4.41 A redesign of the terminal building took place in 1986/7 to provide a duty free facility and two gates from a central departure lounge. The administration block was converted to 'operate as an executive terminal'. In 2004, some non-core buildings north-east of the terminal were demolished and the tarmac apron reinstated while the fire station was demolished and relocated to a temporary building to the south-west of the terminal. This phase of redevelopment also included the resurfacing of the main runway and the removal of runway 14/32.

13.4.42 There are no buildings of historical interest at airport. The block of concrete buildings comprising the Biggles Bar, admin buildings and aviation club were built in 1953/4.

13.5 Baseline Environment (Future Assessment Conditions Scenario)

13.5.1 The future assessment conditions scenario is the same as described under the “existing conditions scenario” above.

11 Carpenter E. 1996 Romney Marsh A Second Selection - Britain in Old Photographs Sutton Publishing Ltd 12 www.lyddair.com/history

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13.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

13.6.1 The runway extension will require approximately 750mm of excavation within the footprint of the runway extension. Further excavations will be needed for the runway drainage and the cabling for the runway lighting.

13.6.2 Minor effects are anticipated during the construction of the runway extension. No known archaeological remains or monuments will be affected by these works, however there will be some limited impact to the historic landscape's key cultural attributes as the pattern of drains and the sluice at the junction of Paine Field Sewer and Mockmill Sewer would be affected. These drains may have medieval origins.

13.6.3 A construction formation level at an approximate depth of 750mm below the marsh surface will truncate the upper portion of the marsh depositional sequence. However given the extent of the Denge Marsh deposits as a palaeoenvironmental and geomorphological resource, compared with the limited volume of the truncation resulting from the proposed runway extension, the implications of the construction works are considered to be minor adverse.

Future Assessment Conditions Scenario

13.6.4 Impacts will be as described for the existing conditions scenario above.

13.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

13.7.1 The operational impacts of the runway extension upon the Historic Environment will be limited to visual aspects only. These were assessed and photographed during a site visit in August 2005. At the request of Kent County Council, observations were made from vantage points on top of the Neolithic Ridge located at the western edge of Romney Marsh. They were situated at Cliff Farm (south of Stone in Oxney), Bilsington Monument and Lympne church. The observations indicated that:

• Visibility and the scale of the proposed development within the landscape as viewed from the top of the ancient cliff line would not greatly affect the appreciation of the historic landscape;

• Dungeness Power Station dominates the views even though it lies in the background;

• Lydd town is screened by trees as is the existing airport; and

• The existing airport is not visible from the cliff top but blends into the landscape. 13.7.2 No other operational impacts are expected.

Future Assessment Conditions Scenario 13.7.3 Predicted impacts arising from operation of the facility under this scenario are expected to be the same as described under the “existing conditions scenario” above.

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13.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

13.8.1 The requirement for a programme of archaeological works will be discussed with the local authority under the provisions of PPG 16 and Local Plan Policy. Such works would involve the maintenance of an archaeological watching brief during earthmoving works and a programme of environmental soil sampling to investigate palaeoenvironmental and marsh formation deposits (see Chapter 6). These works will form part of the CEMP which will be prepared to minimise potential significant impacts upon any unknown archaeological remains.

Future Assessment Conditions Scenario

13.8.2 Proposed mitigation for construction impacts under this scenario are as described under the ‘existing conditions scenario’ above.

13.9 Proposed Mitigation (Operation Impacts)

Existing Conditions Scenario

13.9.1 No mitigation measures are considered necessary for the operational impacts of the proposed development.

Future Assessment Conditions Scenario

13.9.2 No mitigation measures are considered necessary for the operational impacts of this scenario.

13.10 Residual Effects

Existing Conditions Scenario

13.10.1 All construction impacts can be mitigated through a combination of an archaeological watching brief and soil sampling. When this has been completed a positive contribution to the research programme for the formation processes and palaeoenvironmental character of Denge Marsh will have been achieved. The residual effect will be negligible.

13.10.2 The residual effect on the historic landscape will be minor with some disruption to the field drainage pattern within the footprint of the proposed runway extension. With regard to the Built Heritage, the proposed runway extension would be located some distance from both Jack's Court (listed building) and the WWII Listening Devices (scheduled ancient monuments). It will lies approximately 1km to the east of Jack's Court (Gaz. refs. 8 & 9) and will not have an impact upon its setting. It is also not considered to directly affect the setting of the WWII Listening Devices (Gaz. Ref. 6) which lie 900m to the southeast across an expanse of shingle ridges.

Future Assessment Conditions Scenario

13.10.3 Residual Impacts are expected to be as described for the ”existing conditions scenario” above.

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13.11 Summary

13.11.1 An assessment of the potential impacts of the proposed runway extension on the historic environment has been undertaken. The key focus has been to provide a clear and concise description of the baseline conditions for archaeology, the historic landscape and built heritage within the study area. The potential impacts of the proposed development have been assessed and mitigation measures recommended.

13.11.2 During this assessment the Institute of Field Archaeologists' Code of Conduct and guidance papers have been adhered to.

13.11.3 The results of the assessment indicate that:

• There will be damage to a portion of the marsh depositional sequence as a result of the foundations. Given however, the extent of the Denge Marsh deposits as a palaeoenvironmental and geomorphological resource, the implications of the construction works are considered to be minor;

• Historic landscape - a small section of the drains and the sluice at the junction of Paine Field Sewer and Mockmill Sewer would be truncated by the construction of the proposed runway extension. This impact is considered to be minor adverse; and

• Built heritage - the construction of the proposed runway extension will not impact upon any historic buildings. It will not affect the setting of the WWII listening devices – Scheduled Ancient Monuments Nos. Kent 378a – c (Gaz. ref. 6) or the medieval Grade II Listed Building at Jack's Court (Gaz. refs. 8 & 9). 13.11.4 A programme of archaeological works may be undertaken required under the provisions of PPG16 and Local Plan Policy. Such works would involve the maintenance of an archaeological watching brief during earthmoving works and a programme of environmental soil sampling to investigate palaeoenvironmental and marsh formation deposits.

13.11.5 Overall, for the majority of impacts, no significant difference in magnitude is expected between those impacts anticipated to arise when compared to the “existing conditions” and those arising compared to the “future assessment conditions” scenario.

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CHAPTER 14

TRAFFIC AND TRANSPORT

CHAPTER 14 LAA

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14 TRAFFIC AND TRANSPORT

14.1 Introduction

14.1.1 This chapter assesses the transport impacts associated with the Future Assessment Conditions scenario for the extension to the runway at LAA. It summarises the key findings of the Transport Assessment (TA) prepared and submitted as a separate supporting document to the Planning Application.

14.1.2 The scenarios modelled are as described in Chapter 1.

14.1.3 The implications on transportation policy are assessed in Chapter 5 Planning Policy Framework. The chapter describes the methods used to assess the impacts of the proposed development, the baseline conditions existing at and in the vicinity of the Site, the potential direct and indirect transport impacts arising from the predicted trip generation associated with the development and the impact these trips will have on the different transport modes. Proposed mitigation measures required to prevent, reduce or offset any identified impacts have also been described.

14.2 Legislative Drivers

14.2.1 The proposed runway extension at LAA will serve to develop the airport as an important regional airport for the South East of England in line with the District and County transport policies. The Government’s integrated transport policy also identifies the need for additional air capacity in the area.

14.2.2 The Kent Local Transport Plan and the Shepway District Council Local Plan recognise that London Ashford airport is an important transport facility for the district and that there is potential for expansion. The Councils support development that strengthens the airport function. The Kent and Medway Adopted Structure Plan (2006) considers LAA in TP25, with particular scope to include surface access being adequately accommodated within the capacity of the existing or committed local transport network; and with measures being identified and secured to improve access by public transport modes. Further information is included within the TA.

14.3 Assessment Methodology

14.3.1 The TA has been undertaken using current best practice methodologies. Best practice is based on the brief guidance set out in PPG13, the IHT Guidelines, the IEMA Guidelines for the Environmental Assessment of Road Traffic and the National Best Practice Guide for TAs that has recently been published.

14.3.2 The assumptions used in the assessment have also been set out in this section in terms of mode split and trip distribution.

Data Collection

14.3.3 Site visits have been undertaken to determine the baseline environment. Surveys have been carried out to identify traffic flows, pedestrian activity, car park usage, retail activity and servicing requirements.

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14.3.4 Table 14.1 below summaries the survey programme carried out and data sources used to inform the analysis. It highlights the type of data collected and how it has been used in the TA.

Table 14.1 Survey Data & Data Sources Survey Date Description Used For Automatic Counts Automated Traffic Counts January Assessing impact of along surrounding (ATCs) 2005 additional traffic roads Monthly Annual Average Daily Average traffic flows by Factoring January 2004/05 Traffic (AADT) Data month along A259 Counts to August Manual Classified January Counts of traffic at Used for Junction Junction Turning Counts 2005 Hammonds Corner & Impact Assessment Brenzett January Speed surveys of traffic Contribution to noise Speed Surveys 2005 along A259 assessments Details of all flights Leeds-Bradford International Summer To produce a flight arriving and departing Airport Flight Timetable 2005 profile for Lydd airport South East Area Passenger (CAA) Survey Data 2003 Passenger Survey Data Distribution, Mode Split and Group Size Transport Assessment London Manston Airport June to accompany planning Mode Split Transport Assessment 2004 application for Manston assumptions Airport expansion

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14.3.5 The methods and assumptions used to assess the impacts of the airport expansion are detailed below in Table 14.2.

Table 14.2 Methods and Assumptions Used Issue Method Using Civil Aviation Authority (CAA) Passenger Catchment & Distribution passenger survey data for Kent & East Sussex Using Leeds Bradford flight profile of annual, weekly and daily flights to identify the peak Trip Generation period. This profile is then applied to 300,000 passengers per annum Combination of CAA survey data and London Mode Split Manston Airport Transport Assessment Existing Conditions servicing levels applied Servicing to forecast waste production and delivery numbers The airport has developed a likely fleet mix for the flights it will handle for each scenario. Passenger levels per flight This has been used to identify the number of passengers per flight. Using CAA passenger survey data on trip Car Park Occupancy duration, the car parking requirements for each scenario has been calculated. Proposed developments in the area have also been included in our impact analysis. Cumulative Impacts These are the Lydd Hotel application and the decommissioning of Dungeness ‘A’ reactor.

14.3.6 The data collected from Leeds Bradford airport shows that August is the busiest month of the year with Monday being the busiest day of the week. All traffic assessments have therefore been based on August baseline traffic flows.

Trip Generation and Distribution1

14.3.7 The likely distribution of the additional traffic on the local road network has been estimated using CAA passenger survey data relating to the home origins of air passengers. Figure 14.1 shows the passengers by district in Kent & East Sussex. The highest proportions live in Sevenoaks, Brighton, Canterbury, Medway and Eastbourne.

14.3.8 In addition, a drive time catchment has been calculated to determine the likely distances that passengers will travel in order to get to the airport. The 60-minute catchment has a total population of approx 778,178, with 322,558 households. The 90-minute catchment has approx 3,497,855 with 1,446,945 households. This is shown in Figure 14.2

14.3.9 The results of the survey have been used to distribute the traffic generated by the airport expansion on the surrounding road network. Figure 14.3 shows this likely spread of trips.

1 Further details can be found in Chapter 7 of the Traffic Assessment (TA)

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14.3.10 The impacts of the increased passenger movements on the surrounding highway network have been assessed for the main routes to and from the airport. Our studies have assumed that no additional traffic will be generated along the other minor roads near to the site through improved signage.

Passenger Mode Split

14.3.11 The following table shows the mode split for passengers that has been used for this analysis. The method of car travel has been differentiated by whether the car is parked on-site or whether the passengers are picked up/dropped off at the airport. This affects the numbers of trips generated and the car park occupancy.

Table 14.3 Air Passenger Trip Mode Split Mode Percentage of Trips Private Car (Using Long-Stay Parking) 42% Private Car (Drop-off/Pick-up) 28% Bus 10% Rail 0% Taxi 20%

14.3.12 The car occupancy level is key to identifying the actual number of vehicle trips being generated. The CAA data for the south east provides information on the group size of all south east passengers. This provided the basis for the car occupancy assumption. The data showed that the average group size was 3.3 people.

14.3.13 This mode split is based on existing survey data for similar airports as stated in Table 14.1 and CAA passenger survey information. Improvements to the local public transport network may reduce the reliance on the private car.

Staff Mode Split

14.3.14 The employees have been broken down into general office employees and shift employees. General office employees are assumed to work regular office hours of between 09:00 and 17:00.

14.3.15 Shift employees work throughout the day in order to handle flights arriving and departing outside regular opening hours. The shifts are assumed to be as follows:

08:00 – 16:00

16:00 – 00:00

00:00 – 08:00

14.3.16 This shift system enables the changeover of shifts between forecast flight arrivals and departures.

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Table 14.4 General Employee Mode Split Mode of Travel Percentage of Employees Car Driver 85% Car Passenger 5% Bus 10%

Table 14.5 Shift Employee Mode Split Mode of Travel Percentage of Employees Car Driver 90% Car Passenger 5% Bus 5%

14.4 Baseline Environment (Existing Conditions)

Road Network

14.4.1 The airport is located on the south coast of Kent, approximately 15 miles (25km) south of Junction 10 of the M20. This provides good links to London and beyond as well as other areas of the South East.

14.4.2 The airport access road is reached via the B2075 (Romney Road), nearly three kilometres south of the junction with the A259 (Hammonds Corner). The A259 east of Brenzett was ‘detrunked’ in September 2003, with the A2070 becoming the trunk road linking to Ashford and the M20.

14.4.3 The B2075 is accessed from the west (Hastings and Rye) and east (Folkestone and Dover) via the A259. The route from the north (Ashford and M20) is via the A2070 and A259 (from Brenzett).

14.4.4 The B2075 continues south to Lydd. Jurys Gap Road connects Lydd to Camber further west and Rye. It is not anticipated that airport traffic will use this route.

14.4.5 Improvements are scheduled for Junction 10 of the M20 commenced in September 2006. The works involve widening the slip roads and over-bridges at the junction to increase traffic capacity. Further plans are also being developed for an additional motorway junction to the southeast of Ashford – Junction 10a.

14.4.6 Average Annual Daily Traffic flows (AADT) have been calculated from survey data for various points on the road network, See Table 14.6. The survey locations are shown in Figure 14.4. The flows have been factored up from survey data to reflect the average August flows as this is the busiest period of the year.

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14.4.7 Table 14.6 7-Day 18hr AADT Flows

Site 2005 1 - A259 Lydd Rd 8411 3 - A259 Straight La 6061 5 - B2075 Romney Rd 7166 6 - A259 New Romney 11036 7 - A259 Dymchurch 11219 8 - B2075 Lydd 3141 9 - A2070 11864

Junction Assessment (Hammonds Corner)

14.4.8 A junction assessment was undertaken2 using the existing 2005 traffic data from KCC, with results shown in Table 14.7. The data factored to August levels was used in order to establish the current conditions at the busiest time of year. For the purpose of the analysis, the maximum Ratio to Flow Capacity (RFC) and the maximum queue length have been taken to represent over the peak hour periods.

Table 14.7 A259/B2075 Junction Assessment – 2005 August Data AM PEAK PM PEAK Maximum Maximum Maximum Maximum RFC Queue (no of Queue (no of RFC cars) cars) B2075 – A259 0.732 4.6 0.701 4.3 Westbound

B2075 – A259 0.849 5.9 0.858 6.4 Eastbound

A259 West to B2075 0.615 2.3 0.481 1.6 Southbound

14.4.9 The results show that the junction is currently operating at or near capacity much of the time, particularly for traffic travelling from the B2075 to the A259 eastbound. A junction is generally considered to operate efficiently if the ratio of flow to capacity (RFC, a measure of stress) is less than 85%. The maximum queue length at the junction was 6.4 vehicles on the B2075 Romney Road arm, for vehicles waiting to turn right towards New Romney. Vehicles travelling eastbound from the B2075 to the A259 towards New Romney are already operating above the recommended 85% level of stress. The 2005 baseline flows are shown in Figure 14.5.

14.4.10 Plates 14.1 and 14.2 show photographs of the Hammonds Corner junction. Plate 14.1 shows that a right hand turning lane is only provided right at the junction onto the B2075 itself rather than on the approach. There is evidence that left-turning traffic from the B2075 drive onto the verge to pass around queuing traffic.

14.4.11 Onsite observations suggest that queuing is already a problem at the junction, even during off-peak times.

2 Using PICADY software

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14.4.12 The junction currently has unusual line-markings for left-turning traffic with a give-way line at a right angle to the right-turning line. This is shown in Plate 14.2.

Junction Assessment (Brenzett)

14.4.13 The junction at Brenzett is a roundabout linking the A2070, the A259 Lydd Road and the B2080. Morning and evening peak hour flows at the junction are shown in Figure 14.7.

14.4.14 The baseline conditions at this junction are relatively good, with little congestion during daytime hours. The busiest arms are the north and south links of the A2070 to Ashford and the A259 to Rye. Further details of the assessment of this junction are included within the Future Operating Conditions section below.

Road Traffic Accidents

14.4.15 Road traffic accident data was collected for the road network around the airport for the period September 1999 to August 2004. In total, 95 road traffic accidents were recorded along these roads in the five year period. This included three fatal accidents and 18 serious accidents. These are mainly clustered around the road junctions at Hammonds Corner and Brenzett. On average there were nineteen accidents per year over the survey period.

Public Transport

Local Bus Network

14.4.16 LAA is served by direct bus services that connect with rail services from Ashford International Station.

14.4.17 The nearest bus stop to the airport is along the B2075 at the entrance to the airport access road. The northbound stop has a small shelter although neither stop has information about services and in general the facilities are poor.

14.4.18 From the bus stop it is approx 1 km to the airport terminal building. The stop is served by Stagecoach bus service 711 and Kent Coach Company services 11, 11A and 11B.

14.4.19 Kent Coach Company operates bus services between Ashford and Lydd with some services travelling via the village of Appledore. The frequencies are shown in Table 14.8. The journey from Lydd to Ashford takes approximately 60 minutes.

Table 14.8 Bus Services Serving Lydd Route From/To Monday-Friday Saturday Sunday Every 90 11/11A/11B Ashford to Lydd Hourly No Service Minutes Folkestone – 12 New Romney - Hourly Hourly Every 2 Hours Lydd Dover – 711 Folkestone – Hourly Hourly Every 2 Hours Rye – Hastings

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Local Rail Network

14.4.20 The airport is located approx 25 kilometres south of Ashford International rail station and 12 kilometres southeast of Appledore rail station. There is a single-track rail link between Appledore and the village of Lydd but this is currently disused by passenger services. There is currently no realistic prospect of this branch being reopened.

14.4.21 Southern Railway operates services from Ashford International rail station to Appledore. before continuing on to Rye and Hastings with some going further to Lewes and Brighton. Appledore is the nearest rail station to the airport and the journey time from Ashford to Appledore is 14 minutes. Therefore passengers travelling to LAA by rail must travel by train to Ashford or Appledore and continue their journey by bus or taxi. The station is currently unmanned so passengers wishing to continue their journey are advised to continue by rail to Rye station where there is a taxi rank available.

14.4.22 Table 14.9 shows the daily frequencies of rail services between Ashford and London, which has been operated since April 2006 by the Integrated Kent Franchise (IKF). This covers services currently operated by South East Trains. Improvements to the frequencies and the travel time are expected as a result of the forthcoming high speed rail connection to London St. Pancras as part of the Channel Tunnel Rail Link. This is (scheduled for completion in 2007, which could see the travel time between London St Pancras and Ashford International reduced to approximately 40-minutes.

Table 14.9 Southeastern Rail Service Frequencies between London and Ashford

London to Ashford Ashford to London

Time Mon-Fri Sat Sun Total Mon-Fri Sat Sun Total (hour)

05:00 2 1 0 3 2 1 0 3

06:00 5 3 0 8 8 3 1 12

07:00 6 5 0 11 7 4 3 14

08:00 6 5 4 15 6 5 3 14

09:00 7 7 4 18 4 6 3 13

10:00 8 8 4 20 5 6 3 14

11:00 8 8 4 20 6 6 3 15

12:00 7 8 4 19 6 6 3 15

13:00 8 8 4 20 6 7 3 16

14:00 9 8 4 21 6 6 3 15

15:00 9 8 4 21 9 6 3 18

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London to Ashford Ashford to London

Time Mon-Fri Sat Sun Total Mon-Fri Sat Sun Total (hour)

16:00 10 8 4 22 6 6 3 15

17:00 12 8 4 24 4 9 3 16

18:00 8 7 4 19 3 2 3 8

19:00 7 5 4 16 5 3 3 11

20:00 6 4 4 14 3 3 3 9

21:00 5 4 4 13 2 3 4 9

22:00 4 4 3 11 2 1 0 3

23:00 4 4 1 9 0 0 0 0

Total 131 113 60 304 90 83 47 220

Coach Transport

14.4.23 Coaches are permitted to use the airport by prior arrangement and can park in the main car park adjacent to the terminal building. Coach transport to the airport is currently very low with one coach per month during the winter months and one per week during the summer.

Taxi Services

14.4.24 There is no official taxi rank at the airport. Taxis drop-off and pick-up passengers on an ad hoc basis in front of the terminal building.

Car Parking

14.4.25 The car park at LAA is situated adjacent to the main terminal building and is free of charge for daily passengers and visitors. For vehicles parked overnight there is a £3 parking charge.

14.4.26 The number of available parking spaces at LAA is currently 223 regular spaces and 4 disabled spaces. The car park does not currently operate at full capacity.

14.5 Baseline Environment (Future Assessment Conditions Scenario)

14.5.1 The ‘Future Assessment Conditions’ scenario relates to levels of traffic expected in and around the airport assuming that passenger movements have reached the limit of current capacity of 300,000 passengers per annum without the runway extension.

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Trip Generation

14.5.2 The trips have been broken down into staff and passenger trips along with additional service vehicle movements.

14.5.3 The trip profiles are based on the proposed flight timetable and arrival and departure patterns and have been used to derive the peak hours for flows into and out of the airport. Full details of these profiles can be found in the accompanying Transport Assessment documents.

Passenger Trip Generation

Table 14.11 Passenger Car Trips – ‘300,000 Passengers per annum No Extension’ Hour Inbound Car Trips Outbound Car Trips

00:00 – 06:00 18 17

06:00 – 12:00 75 56

12:00 – 18:00 84 86

18:00 – 00:00 42 60 TOTAL 219 219

14.5.4 A total of 438 one-way car trips per weekday are predicted to be generated by the air passengers at a level of 300,000 passengers per annum as shown in Table 14.11 above.

14.5.5 The peak hour for traffic into the airport for this scenario is between 09:00 and 10:00 when a total of 20 car trips are forecast entering the car airport. This is also the peak hour for outbound car trips from the airport. 10% of all car trips into and out of the site are forecast to occur between 09:00 and 10:00. Further details of the trip profile are included in the accompanying Transport Assessment document.

Staff Trip Generation

14.5.6 Table 14.12 shows the levels of car trips generated by staff by hour. Detailed analysis in the Transport Assessment show the peak inbound flows are forecast between 07:00 and 08:00 with 35 staff car trips entering the airport. The peak outbound flows are between 16:00 and 17:00 when 40 staff car trips are forecast to leave the car park.

Table 14.12 Daily Staff Car Trips – ‘300,000 Passengers per annum No Extension’ Hour Inbound Outbound 00:00 - 06:00 9 26 06:00 – 12:00 72 31 12:00 – 18:00 68 95 18:00 – 00:00 16 14 TOTAL 165 165

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Servicing and Delivery Trips

14.5.7 A total of four refuse collections per week have been assumed once the airport reaches 300,000 passenger movements per annum. In addition, it has been assumed that five sewage/waste water collections will be made per week at the airport.

Public Transport Trips

14.5.8 As shown in the mode split breakdowns earlier in the chapter, there is forecast to be limited use of public transport as current provision is limited.

Bus Trips

14.5.9 The level of bus trips generated per weekday is forecast to be as follows:

Table 14.10 Bus Passenger Trips – ‘300,000 Passengers per annum No Extension’ Hour Inbound Outbound 00:00 – 06:00 4 6 06:00 – 12:00 29 10 12:00 – 18:00 26 28 18:00 – 00:00 5 21 TOTAL 64 64

14.5.10 The mode split has been applied to the overall 24-hour profile. However, with the current bus timetable, the bus trips between 7pm and 7am would not be served by local services.

14.5.11 The increased bus passengers suggests that additional services for buses to stop at the airport rather than on the B2075 are required.

14.5.12 The increased bus passengers suggests that additional bus facilities should be provided for the airport such as additional services and the capacity for buses to call at the airport itself rather than stopping on the B2075. The potential for this is discussed further in the accompanying Travel Plan document. The increase in bus patronage is expected irrespective of the runway extension.

Taxi Trips

14.5.13 The following table details the level of taxi trips forecast to be generated by the additional passenger movements.

Table 14.11 Taxi Passenger Trips – ‘300,000 Passengers per annum No Extension’ Hour Inbound Outbound 00:00 – 06:00 4 4 06:00 – 12:00 19 19 12:00 – 18:00 25 25 18:00 – 00:00 16 16

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TOTAL 64 64

14.5.14 The peak hours for taxi passenger trips are 09:00-10:00 and 17:00-18:00.

14.5.15 A total of 64 inbound and outbound taxi trips are forecast. The additional trips suggest additional taxi rank facilities are required for the airport.

Car Parking

14.5.16 The average length of trip has been obtained using the CAA passenger survey data 2003 (See Table 14.1). This has allowed the car park occupancy to be modelled over a month.

14.5.17 Table 14.15 details the duration breakdown used for this analysis.

Table 14.12 Trip Duration Profile Length of Trip Percentage of Trips 0-1 day 14% 2 days 11% 3 days 15% 4-6 days 13% 7 days 25% 8-14 days 17% 15 or more days 4%

14.5.18 The above assumptions have been used to forecast the car park occupancy over a month to calculate the total parking capacity needed.

Table 14.13 Car Park Capacity Type of Space Total Long-Stay 400 Short-Stay 40 Staff 70 TOTAL 510

14.5.19 A total of 510 spaces are required for the additional passenger movements planned. 25 of these spaces will be for disabled users and situated close to the terminal building. There are ample carparking spaces available within the airport through the reallocation of existing hardstanding which will be undertaken as part of the airports permitted rights.

Average Annual Daily Traffic

14.5.20 The table below details the forecast change in AADT levels at various points on the road network and the current traffic and anticipated traffic flows in 2009 assuming that the airport is operating at 300,000 passengers per annum and that other background growth has occurred.

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Table 14.14 7-Day 18hr AADT – ‘300,000 Passengers per annum No Extension’ Future Assessment Site Baseline Traffic (2005) Conditions (No Extension 2009) 1 – A259 Lydd Rd 8411 9285

3 – A259 Straight La 6061 6488

5 – B2075 Romney Rd 7166 8488

6 – A259 New Romney 11036 12194

7 – A259 Dymchurch 11219 12370

8 – B2075 Lydd 3141 3320

9 – A2070 11864 12842

Junction Assessment

14.5.21 Traffic flow increases are most likely to present capacity problems at road junctions. Based on an assessment of increases in turning volumes at junction on airport approach roads, the operation of the A259/B2075 junction has been assessed. The growth in traffic experienced at Hammonds Corner will not be a result of the planning application associated with this Transport Assessment. The level of growth experienced in this location would be expected to occur in any case as airport passenger numbers increase to 300,000 per annum. This total could be achieved irrespective of permission being granted for the runway extension.

14.5.22 Traffic flows generated by the Future Assessment Conditions scenario will not increase traffic by more than 5% at any junction.

14.5.23 The A259/B2075 Hammonds Corner junction has been assessed using PICADY software for priority junctions. The results of the junction assessment for 300,000 passengers per annum and no runway extension scenario are shown in Error! Reference source not found..

Table 14.15 A259/B2075 Junction Assessment – ‘300,000 Passengers per annum No Extension’ AM PEAK (08:00-09:00) PM PEAK (17:00-18:00) Maximum Maximum Maximum Maximum RFC Queue (no of Queue (no of RFC cars) cars) B2075 – A259 0.991 15.6 0.958 14.5 Westbound

B2075 – A259 1.039 18.5 1.015 18.9 Eastbound

A259 West to B2075 0.755 4.9 0.569 2.3 Southbound

14.5.24 The additional passenger movements and associated staff growth lead to most arms of the junction functioning in excess of 85% of capacity under the Future Assessment Conditions scenario.

14.5.25 The forecast total flows at the junction are shown in Figure 14.6.

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14.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

14.6.1 The construction period for the runway extension is scheduled to last for approximately 4 months. The majority of HGVs will be generated by the construction of a temporary access road to the construction site. It has therefore been assumed that most of the HGV movements will be generated in the first month of construction. In making this assumption, assessment is made of the worst-case level of additional vehicle trips.

14.6.2 The construction is forecast to require 10,000 cubic metres of aggregate. This will be transported to the site by HGVs with a capacity of 20 cubic metres. This equates to 500 two-way vehicle trips.

14.6.3 The construction of the runway extension is forecast to be carried out in 2007. The construction traffic will follow a designated route into and out of the site. This will be via the A2070 from Ashford and is shown in Figure 14.8.

14.6.4 The proposed development will increase the percentage of HGV vehicles on some of the surrounding roads. This impact is set out in Table 14.19 below. The increase in HGV movements does not increase the percentage of HGV traffic to above 10% on any of the affected roads even when considering a ‘worst case’ scenario.

Table 14.16 Construction Traffic Impact Additional HGV Site Baseline % HGV Flows (per Overall % HGV weekday) 1 – A259 Lydd Rd 7.5% 50 8.1% 5 – B2075 Romney Rd 5.7% 50 6.5% 9 – A2070 7.8% 50 9.3%

Future Assessment Conditions Scenario

Impacts of this scenario will be as described for the Existing Conditions Scenario above.

14.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

14.7.1 The following section assesses any potential impacts the runway extension will have in terms of transport and the local road network. This assumes that passenger numbers will remain at 300,000 passengers per annum.

14.7.2 The runway extension will enable the larger B737-700 and A319 aircraft to take off with full payloads, and as such will enable LAA to support operations flying to destinations further afield than can currently be accommodated. The following section assesses the potential impacts.

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Passenger Trip Generation

14.7.3 The trip profiles will be based on a combination of the proposed flight timetable and arrival and departure patterns and have been used to derive the peak hours for flows into and out of the airport. Full details of these profiles can be found in Chapter 7 of the accompanying TA.

14.7.4 A total of 438 one-way car trips per weekday are predicted to be generated by 300,000 passengers per annum with the runway extension as shown in Table 14.16.

Table 14.16 Air Passenger Car Trips – ‘300,000 Passengers per annum with Runway Extension’ Hour Inbound Car Trips Outbound Car Trips

00:00 – 06:00 29 30

06:00 – 12:00 75 54

12:00 – 18:00 89 91

18:00 – 00:00 26 44 TOTAL 219 219

14.7.5 The peak hour for passenger trips into the airport is between 17:00 and 18:00 when a total of 31 car trips are forecast. This is also the peak hour for passenger car trips out of the site with 31 vehicles forecast to leave the site in this hour.

14.7.6 The impacts of this increase are dealt with through the junction assessments, which are dealt with in Section 14.7.23 onwards of this chapter.

Staff Trip Generation

14.7.7 Table 14.17 shows the levels of car trips generated by staff by hour. Detailed analysis in the Transport Assessment show the peak inbound flows are forecast between 07:00 and 08:00 with 35 staff car trips entering the airport. The peak outbound flows are between 16:00 and 17:00 when 40 staff car trips are forecast to leave the car park.

14.7.8 The impacts of this increase are dealt with through the junction assessments, which are dealt with in Section 14.7.23 onwards of this chapter.

Table 14.17 Daily Staff Car Trips – ‘300,000 Passengers per annum with Extension’ Hour Inbound Outbound 00:00 - 06:00 9 26 06:00 – 12:00 72 31 12:00 – 18:00 68 95 18:00 – 00:00 16 14 TOTAL 165 165

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Servicing and Delivery Trips

14.7.9 A total of four refuse collections per week have been assumed once the airport reaches 300,000 passenger movements per annum. In addition, it has been assumed that five sewage/waste water collections will be made per week at the airport.

14.7.10 The impacts of this increase are dealt with through the junction assessments, which are dealt with in Section 14.7.23 onwards of this chapter.

Public Transport Trips

14.7.11 As shown in the mode split breakdowns earlier in the chapter, there is forecast to be limited use of public transport as current provision is limited.

Bus Trips

14.7.12 The level of bus trips generated per weekday is forecast to be as follows:

Table 14.17 Bus Passenger Trips – ‘300,000 Passengers per annum with Runway Extension’ Hour Inbound Outbound 00:00 – 06:00 7 9 06:00 – 12:00 30 10 12:00 – 18:00 25 30 18:00 – 00:00 2 15 TOTAL 64 64

14.7.13 The mode split has been applied to the overall 24-hour profile. However, with the current bus timetable, the bus trips between 7pm and 7am would not be served by bus services.

14.7.14 The increased bus passengers suggests that additional bus services and the capacity for buses to stop at the airport rather than on the B2075 are required.

14.7.15 The potential to generate a bus-based patronage associated with the airport represents a benefit in sustainable transport terms, as it accords with PPG13 principles in terms of reducing the need to travel by car.

Taxi Trips

14.7.16 The following table details the level of taxi trips forecast to be generated by the additional passenger movements.

Table 14.18 Taxi Passenger Trips – ‘300,000 Passengers per annum with Runway Extension’ Hour Inbound Outbound 00:00 – 06:00 9 9 06:00 – 12:00 18 18 12:00 – 18:00 27 27

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18:00 – 00:00 10 10 TOTAL 64 64

14.7.17 The peak hours for taxi passenger trips are 09:00-10:00 and 17:00-18:00.

14.7.18 A total of 64 inbound and outbound taxi trips are forecast. The additional trips suggest additional taxi rank facilities are required for the airport as shown in Figure 4.2a.

14.7.19 The impacts of this increase are dealt with through the junction assessments, which are dealt with in section 14.7.20 onwards of this chapter

Car Parking

14.7.20 The average length of trip has been obtained using the CAA passenger survey data 2003 (See Table 14.1). This has allowed the car park occupancy to be modelled over a month. Table 14.15 details the duration breakdown used for this analysis.

Table 14.19 Trip Duration Profile Length of Trip Percentage of Trips 0-1 day 14% 2 days 11% 3 days 15% 4-6 days 13% 7 days 25% 8-14 days 17% 15 or more days 4%

14.7.21 The above assumptions have been used to forecast the car park occupancy over a month to calculate the total parking capacity needed.

Table 14.20 Car Park Capacity Type of Space Total Long-Stay 400 Short-Stay 40 Staff 70 TOTAL 510

14.7.22 A total of 510 spaces are required for the additional passenger movements planned. 25 of these spaces will be for disabled users and situated close to the terminal building. There are ample carparking spaces available within the airport through the reallocation of existing hardstanding which will be undertaken as part of the airports permitted rights. Since space is available for this level of parking, the impact is considered of negligible significance.

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Average Annual Daily Traffic

14.7.23 This section details the forecast change in AADT levels at various points on the road network. Table 14.21 below shows the percentage of total traffic that will be generated by the airport expansion to 300,000 passengers per annum and the provision of the runway extension under the Year 1 Operating Conditions. The survey locations are shown in Figure 14.4.

Table 14.21 7-Day 18hr AADT – Runway Extension % Increase % Increase Future Future of current of future Current Assessment Assessment and Future assessment Traffic Conditions Conditions Assessment conditions Site Levels (No (With Conditions with and (2005) Extension Extension (no with out 2009) 2009) extension) extension 2009 1 – A259 Lydd 10.3% 0% 8411 9285 9285 Rd

3 – A259 7% 0% 6061 6488 6488 Straight La

5 – B2075 18.4% 0% 7166 8488 8488 Romney Rd

6 – A259 New 10.4% 0% 11036 12194 12194 Romney

7 – A259 10.2% 0% 11219 12370 12370 Dymchurch

8 – B2075 5.6% 0% 3141 3320 3320 Lydd

9 – A2070 11864 12842 12842 8.2% 0%

14.7.24 It is important to note that the airport is able to expand to 300,000 passengers per annum under its existing layout (regardless of the runway extension being in place or the need for further planning permission) and so, in transportation terms, the most appropriate comparison is between columns 3 and 4 of the table, as summarised in column 6 above. It is evident that the proposed runway extension will not effect the anticipated traffic flows for 300,000 passengers. Figure 14.11 shows the location on the local road network where there is an increase above the baseline traffic flows of more than 5%. In no location is the increase 10% or above.

Junction Assessment

14.7.25 The effects of the runway extension trip generation have been assessed for the Hammonds Corner junction. The increased trips during the peak hour mean the queue lengths are increased when compared with the existing conditions scenario.

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Table 14.22 A259/B2075 Junction Assessment – ‘300,000 Passengers per annum With Runway Extension’ 2009 AM PEAK PM PEAK Maximum Maximum Maximum Maximum RFC Queue (no of Queue (no of RFC cars) cars) B2075 – A259 0.999 16.2 0.988 16.9 Westbound

B2075 – A259 1.046 18.9 1.037 21.1 Eastbound

A259 West to B2075 0.771 5.4 0.596 2.6 Southbound

14.7.26 The runway extension would add a marginal volume of traffic to the junction due to a more concentrated pattern of flight arrivals and departures. This would result in the junction operating in excess of capacity in both am and pm peak hours. The forecast flows are shown in Figure 14.7.

14.7.27 It should be noted that if a different flight profile were applied in order to reduce the numbers of passengers arriving and departing during the during the peak hours, the impact on the junction would be lessened. The assessment has been based on a worst case scenario in terms of both time of year and flight profile.

14.7.28 Some additional traffic to/from the airport passes through M20 junction 10 where works commenced on 11 September 2006 to improve the junction (Junction 10 Interim Works). The most significant increase in the peak hours would be a 1.2% increase on the eastbound off-slip (an additional 15 vehicles), which would not be material to the operation of the improved junction.

Future Assessment Conditions Scenario

14.7.29 Predicted impacts arising from this scenario are expected to be the same as described under the “existing conditions scenario above”.

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14.8 Proposed Mitigation (Construction Works)

Existing Conditions Scenario

14.8.1 An agreed route for construction vehicles will be set up in agreement with Shepway District Council and detailed within the CEMP in order to reduce the level of disruption on the surrounding road network. The operational hours of the construction site may be restricted in order to prevent additional HGVs during the peak periods of the day. The concentration of HGVs in the initial stages of the construction will reduce the longer term impacts on the road network.

Future Assessment Conditions Scenario

14.8.2 Proposed mitigation for construction impacts under this scenario is as described under the “existing conditions scenario” above.

14.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

Road Network

14.9.2 The airport access road is considered to be of adequate capacity to handle additional traffic. It has recently been resurfaced and improved in preparation for the increase in passengers.

14.9.3 It is proposed that the junction of the B2075 and the airport access road be improved. Although the junction has ample capacity for the additional traffic, it is proposed that a roundabout be constructed at the junction in order to improve safety along the B2075 and also provide additional capacity for any further expansion of the airport. The implementation of a roundabout will also help to slow traffic along the B2075 as it approaches Lydd. A preliminary design for the junction is shown in Figure 4.9.

14.9.4 At Hammonds Corner, it is recognised that the junction will in the near future become overloaded regardless of any changes to the scale of operation at LAA and there will be a capacity constraints in the Future Assessment Conditions scenario (i.e. regardless of the planning application being granted for the runway). The junction has been discussed with the highway authority who can see positive safety and capacity benefits from the replacement of the existing priority junction with a roundabout. LAA are committed to working with the relevant highway and planning authorities to identify and implement an agreed improvement to this junction and making an appropriate contribution to its funding.

14.9.5 As part of this assessment, initial investigations and analysis of a roundabout solution at Hammonds Corner has been undertaken. This shows clearly that a scheme of this type could offer benefit to this point in the network.

14.9.6 A roundabout at the junction will allow the traffic travelling to and from the airport, particularly in the direction of Ashford, to flow through the junction more effectively. A preliminary roundabout layout has been designed which is shown in Figure 14.9. It shows a standard roundabout layout with 30 metre flares from each direction in order to allow up to 6 vehicles to queue in two lanes. These results should be treated as a

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guide only as the exact layout of any future junction improvements would need to go through a detailed design process.

14.9.7 The effects of this improvement are demonstrated in the following tables. A junction assessment using ARCADY has been carried out to measure the performance of the junction at both the scenarios of 300,000 passengers per annum with and without a runway extension.

Table 14.23 A259/B2075 Roundabout Option Assessment – ‘300,000 Passengers per annum No Extension’ AM PEAK PM PEAK Maximum Maximum Maximum Maximum RFC Queue (no of Queue (no of RFC cars) cars) A259 Lydd 0.521 1.2 0.314 0.45 Road East

B2075 Romney 0.349 0.5 0.354 0.6 Road

A259 Lydd 0.384 0.6 0.490 1.0 Road West

Table 14.24 A259/B2075 Roundabout Option Assessment – ‘300,000 Passengers per annum with Runway Extension’ AM PEAK PM PEAK Maximum Maximum Maximum Maximum RFC Queue (no of Queue (no of RFC cars) cars) A259 Lydd 0.524 1.2 0.316 0.5 Road East

B2075 Romney 0.352 0.5 0.363 0.6 Road

A259 Lydd 0.388 0.7 0.498 1.0 Road West

14.9.8 It is clear that providing a roundabout layout would help to solve the issues and as stated previously LAA are committed to working with the relevant highway and planning authorities to identify and implement an agreed improvement to this junction.

Signage Strategy

14.9.9 To ensure that nearby ‘C’ and unclassified roads are not affected by the increased traffic, the airport will be clearly signposted from the Brenzett junction encouraging all traffic to travel to the airport via the A259 and the B2075.

14.9.10 At present a sign directs traffic from the west along the Camber road. This road has limited capacity through the villages of Camber and Lydd and will not be encouraged for airport traffic.

14.9.11 All travel information for passengers using LAA will identify the preferred route as well as suggesting public transport alternatives.

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Travel Plan

14.9.12 In order to mitigate the impacts of the airport growth on the local road network, an outline Travel Plan has been developed. This is submitted as part of the planning application.

14.9.13 The overall objective of the Travel Plan is to maximise the opportunity for staff and passengers to travel to the site by alternative modes to the private car.

14.9.14 A number of ‘sub-objectives’ have been identified to support the over-riding objective. These are:

• Improved bus stop facilities within the Airport complex;

• Designated routes to the airport clearly signposted;

• Car sharing database and promotion for employees;

• Taxi services promotion;

• Publicity campaigns highlighting available public transport; and

• Contribution towards enhanced local bus services via the airport.

14.9.15 LAA will nominate a Travel Plan co-ordinator who will be responsible for:

• Overseeing the timely implementation of Travel Plan measures;

• Facilitating effective communication links with key stakeholders including local authorities and the local community;

• Overseeing the Travel Plan monitoring programme; and

• Acting as a point of contact for all Travel Plan related issues.

14.9.16 A separate outline travel plan document is submitted with this application detailing the long-term plan for reducing the traffic impacts of the airport on the local area.

Future Assessment Conditions Scenario

14.9.17 Proposed mitigation for construction impacts under this scenario is as described under the “existing conditions scenario” above.

14.10 Residual Effects

Existing Conditions Scenario

14.10.1 The main residual effect of the proposed development is the increase in traffic flows. The main traffic increase will be along the B2075 as the majority of airport vehicles

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will use this road. However, the redesign of Hammonds Corner will allow the traffic to be accommodated comfortably even during the peak hours for vehicle movements.

14.10.2 There is likely to be a gradual increase in the levels of public transport trips generated by the airport. This would be dependent on the provision of improved public transport services in the area, particularly through improved bus services. The proposed provision of enhanced bus services will encourage a reduction in the number of car trips being generated. It will also provide a valuable additional bus service for local residents and airport staff.

Future Assessment Conditions Scenario

14.10.3 Residual impacts are expected to be as described for the “existing conditions scenario” above.

14.11 Summary

14.11.1 The key issue in this chapter is the comparison of the Future Assessment Conditions scenario (assuming 300,000 passengers per annum) with the operation of the runway extension at the same passenger numbers.

14.11.2 The impact of the runway extension means fewer flights per day and therefore consolidating flight movements which has an effect on flight arrival and departure patterns.

14.11.3 Providing an airport access junction will allow passengers and staff, safe and efficient access to the airport.

14.11.4 The principal difference between the two scenarios assessed is that an increase in the baseline level of traffic is expected for the Future Assessment Conditions Scenario, even without the proposed runway extension.

14.11.5 The runway extension would add a marginal volume of traffic to the junction due to a more concentrated pattern of flight arrivals and departures. This will lead to a marginal deterioration in junction performance at Hammonds Corner due to the implementation of the runway extension. The junction has been discussed with the highway authority who can see positive safety and capacity benefits from the replacement of the existing priority junction with a roundabout. LAA are committed to working with the relevant highway and planning authorities to identify and implement an agreed improvement to this junction and making an appropriate contribution to its funding.

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CHAPTER 15

AIR QUALITY

CHAPTER 15 LAA

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15 AIR QUALITY

15.1 Introduction

15.1.1 This chapter assesses the potential air quality impacts of the construction and operation of the proposed runway extension at LAA serving 300,000 passengers per annum. The assessment considers potential changes to local air quality in relation to the protection of human health and ecosystems, and the potential generation of nuisance dust and odours. Impacts of the scheme on greenhouse gas emissions are also considered.

15.1.2 The scenarios modelled are as described in Chapter 1 with specific years used as follows: baseline conditions (2005), future assessment conditions (2009) and year 1 operating conditions (2009).

Pollutants and Potential Impacts

15.1.3 The pollutants considered in this study were selected with reference to the UK National Air Quality Strategy1 2 (AQS), taking into consideration the principal types of emissions at airports. Table 15.1 provides basic information on the potential impacts of all pollutants included in the AQS and provides information on whether the pollutant requires assessment in relation to LAA.

15.1.4 The pollutants considered in detail in this assessment are:

• Nitrogen oxides (NOx, including nitric oxide (NO) and nitrogen dioxide (NO2)),

• Particulate matter with a diameter less than 10μm (PM10),

• Benzene (as a component of total non-methane volatile organic compounds, NMVOC),

• 1,3-Butadiene (as a component of total NMVOCs), 15.1.5 In addition to the AQS pollutants, the assessment also considers nuisance dust, defined as particles with diameters in the range 1 to 75μm.

1 Department of the Environment, Transport and the Regions (2000) in partnership with the Scottish Executive, the National Assembly for Wales, and the Department of the Environment for Northern Ireland. The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (Working together for Clean Air). 2 Department of the Environment, Transport and the Regions (2003) in partnership with the Scottish Executive, the National Assembly for Wales, and the Department of the Environment for Northern Ireland. The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: Addendum

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Table 15.1 Air Quality Strategy Pollutants: Sources and Effects Pollutant Main Sources Impacts Assess Comments Refuelling and fuel storage Fuel vapours; Benzene and operations are a potential Incomplete Carcinogenic YES 1,3 Butadiene source, as are road and combustion of fuel aircraft exhaust emissions. Vehicle and aircraft exhausts Reduces capacity of are potential sources. Incomplete CO blood to carry YES However, previous studies of combustion of fuel oxygen. major airports show that CO is not a significant concern1. Impaired lung NO formed during function; Oxides of combustion in air. Vehicle and aircraft exhausts acidification and YES nitrogen NO formed by are a significant source 2 eutrophication of oxidation of NO soils No man-made Eye, nose and sources. Formed No assessment required in throat irritation, O through chemical NO relation to local schemes due 3 chest infection; reactions in to lack of sources affects crop growth presence of sunlight. Industrial processes, especially mineral Affects the and ferrous metals. respiratory and Vehicle and aircraft exhausts PM Combustion cardiovascular YES 10 are a significant source processes. systems, asthma Chemical reactions and mortality. in air. Predominant source Constriction of is combustion of No significant changes to airways by sulphur-containing local sources of SO stimulating nerves 2 SO fossil fuels, NO anticipated; Vehicle and 2 in the lining of the principally coal and aircraft emissions of SO are nose, throat and 2 heavy oils. Some not significant. lungs industrial processes. Road traffic was Affects the main contributor synthesis of before general sale haemoglobin, of leaded petrol was kidneys, joints and No significant sources of lead Lead banned on 1 January NO reproductive associated with this project. 2000. Industry system. Can cause contributes to lead damage to the emissions but to a nervous system lesser extent. Eg see AEAT, 2001, Proposed development at Stansted Airport: Air Quality Assessment

15.1.6 An addendum to the AQS published in 2003 set objectives for an additional group of pollutants, polycyclic aromatic hydrocarbons (PaH), which are carcinogenic. The primary source of PaH in the UK is domestic coal and wood burning, and uncontrolled fires. Road transport contributes around 8% of UK emissions. Quantitative information on PaH emissions from road sources and background levels is, at present, limited. However, PaH in the atmosphere is primarily present in the particulate phase. Measures which reduce PM10 emissions from combustion sources will also contribute to reductions in PaH emissions. It is, therefore, considered that the impact of the scheme on PaH levels will be implicitly assessed in the local air quality assessment of PM10.

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15.2 Legislative Drivers

Human Health and Air Quality Drivers

15.2.1 Part IV of the Environment Act 1995 3 required the Government to develop a national air quality strategy containing standards and objectives, and measures in order to achieve these objectives. The AQS published in 1997 and subsequently revised in 2000 satisfies these requirements. The standards and objectives for air quality relating to human health and the protection of ecosystems are contained in the Air Quality Regulations4 5.

15.2.2 In addition, the requirements of the EU Air Quality Directive and subsequent Daughter Directives have been transcribed into UK law via the Air Quality Limit Values Regulations6 7 8 9.

15.2.3 The Air Quality Standards, on which Objectives and Limit Values are based, are set purely with regard to scientific and medical evidence on the effects of the particular pollutant on health and represent the minimum or zero risk levels. The associated Objectives and Limit Values take into account economic efficiency, practicability, technical feasibility and timescales. Table 15.2 contains details of the Air Quality Objectives and Limit Values relevant to the Proposed Development.

Table 15.2 Summary of UK Air Quality Objectives relevant to LAA Air Quality Assessment

Pollutant Objective Measured as To be Achieved by 16.25 μg/m3 Running annual mean 31/12/2003 Benzene 5 μg/m3 Running annual mean 31/12/2010

1,3-Butadiene 2.25 μg/m3 Running annual mean 31/12/2003

1 hr mean, not to be exceeded more 200 μg/m3 31/12/2005 Nitrogen Dioxide than 18 times per year 40 μg/m3 Annual mean 31/12/2005 Oxides of Nitrogen1 30 μg/m3 Annual mean2 31/12/2000

24 hr mean not to be exceeded more 50 μg/m3 31/12/2004 than 35 times per year

3 24 hr mean not to be exceeded more Particulates (PM ) 50 μg/m 3 31/12/2010 10 than 7 times per year 40 μg/m3 Annual mean 31/12/2004 20 μg/m3 Annual mean3 31/12/2010 Notes: 1. Expressed as NO2. 2. These objectives are for the protection of vegetation and ecosystems and apply to those parts of the UK which are more than 20km from a conurbation of more than 250,000 people; and greater than 5km distance from industrial sources regulated under Part A of the 1990 Environment Act, motorways and built-up areas of more than 5000 people. These objectives are currently provisional for the time being in England, Wales, Northern Ireland; Greater

3 Environment Act 1995. Part IV, Air Quality 4 Statutory Instrument No 928 (2000). The Air Quality Regulations (England), HMSO publications 5 Statutory Instrument No 3043 (2002). The Air Quality (England) (Amendment) Regulations. HMSO publications 6 Statutory Instrument No 2315 (2001). The Air Quality Limit Values Regulations, HMSO publications 7 Statutory Instrument No 3117 (2002). The Air Quality Limit Values (Amendment) Regulations, HMSO publications 8 Statutory Instrument No 2121 (2003). The Air Quality Limit Values Regulations, HMSO publications 9 Statutory Instrument No 2888 (2004). The Air Quality Limit Values (Amendment) (England) Regulations, HMSO Publications

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London has set different provisional objectives for particulates.

15.2.4 Following guidance from the Department for Environment, Farming and Rural Affairs (DEFRA), LAQM.TG(03)10, Objectives for the protection of human health apply to outdoor locations, excluding workplaces, where members of the public are likely to be exposed over the relevant averaging period associated with the objective.

15.2.5 For the assessment of annual mean and daily mean air quality objectives in relation to LAA, residential properties in the vicinity of the airport are, therefore, the nearest relevant receptors.

15.2.6 It is possible that members of the public will be present outside the airport terminal building for periods approaching one hour and, therefore, this should be considered a relevant receptor location for the assessment of hourly average concentrations. However, it is generally considered that the annual mean objective for nitrogen dioxide is more onerous than the hourly mean objective. Therefore, in this study, the landside of the terminal building is considered to be a relevant receptor location for annual mean nitrogen dioxide as a proxy for the assessment of hourly mean nitrogen dioxide.

Sensitive Ecosystems

15.2.7 The Air Quality Objective for annual mean nitrogen oxides, shown in Table 15.2, is designated for the protection of vegetation and ecosystems. The Air Quality Regulations state that it applies to locations which are more than 20km from a conurbation of more than 250,000 people and greater than 5km distance from industrial sources regulated under Part A of the 1990 Environment Protection Act, motorways and built-up areas of more than 5000 people. Dungeness Power Station, regulated under Part A of the 1990 Environment Act, lies within 5km of the southern section of the study area for this assessment.

15.2.8 The regulations also state that the locations selected for monitoring compliance with the objective should be representative of areas of 1000km2 and, therefore, the limit has no statutory basis in the assessment of micro-scale environments in the vicinity of roads, runways or other stationary and mobile sources of NOx. However, taking a precautionary approach, ambient air concentrations of NOx are assessed at sensitive vegetation sites over the entire study area.

15.2.9 The Habitats Directive11 12 13 requires that an assessment of the effects of a scheme on sensitive ecosystems is undertaken. The assessment must take into account the impact of the scheme on the features for which European protected sites e.g. Special Areas of Conservation (SACs), Special Protection Areas (SPAs) etc. were designated. In this assessment, the impact on sensitive ecosystems within Sites of Special Scientific Interest are also assessed.

15.2.10 There are no quantitative standards or objectives for assessing the deposition of nitrogen on ecosystems. Deposition is, therefore, assessed against location- and vegetation-specific critical loads i.e. the estimated exposure to deposition of a pollutant below which, according to present knowledge, significant harmful effects do not occur.

10 Local Air Quality Management Technical Guidance LAQM.TG(03) (2003) Department for the Environment, Food and Rural Affairs. 11 European Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora. 12 Statutory Instrument Number 2716 (1994) The Conservation (Natural Habitats, &c.) Regulations 1994. HMSO publications. 13 Statutory Instrument Number 192 (2000) The Conservation (Natural Habitats &c.) (Amendment) (England) Regulations 2000. HMSO publications

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Greenhouse Gases

15.2.11 The European Community ratified the Kyoto Protocol on 31 May 2002, committing the European Union to make legally binding cuts in emissions of six direct greenhouse gases. Different targets have been set for individual countries to enable the EU to meet its overall target of 8% cuts in emissions by 2008-2012 in relation to 1990 levels.

15.2.12 Under the Kyoto Protocol, the UK is required to reduce emissions by 12.5%. In addition, the UK Climate Change Program has set a national goal of reducing emissions by 20% by 2010 in relation to 1990 levels. However, there are no standards or objectives set for the control of greenhouse gases at the local level and therefore the potential impacts of LAA are assessed qualitatively.

Dust and Odours

15.2.13 Under Part III of the Environmental Protection Act (EPA) 1990, Local Authorities have regulatory powers to control Statutory Nuisance, which can include dust and odour emissions from construction activities. Statutory Nuisances are defined as:

• Any dust or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance; and

• Any accumulation or deposit which is prejudicial to health or a nuisance.

15.2.14 When a statutory nuisance is shown to exist, the Local Authority must serve a notice which will require the abatement of the nuisance or prohibiting or restricting its occurrence or reoccurrence, or the carrying out of such works and other steps necessary to reduce the effects of the nuisance.

15.2.15 Dust deposition may also impact on sensitive ecosystems by affecting photosynthesis, respiration and transpiration.

15.2.16 There are, however, no UK legislative standards or objectives relating to dust deposition, dust nuisance or odour nuisance and so the potential impacts of LAA cannot be quantitatively assessed. However, a qualitative assessment on potential impacts from dust and odours on air quality has been undertaken.

15.3 Assessment Methodology

Study Area

15.3.1 The study area, within which pollutant concentrations are assessed, is a 5km east- west 6km north-south rectangle enclosing the airport, as shown in Figure 15.1. The area includes the main settlements in the region namely Greatstone on Sea, New Romney and Lydd, together with isolated farm and rural properties such as Footway Farm, Forty Acre farm and Kemps Hill Farm.

15.3.2 As shown in Figures 15.3 and 15.4, the study area includes the locations of maximum air quality impacts for both residential and ecosystem receptors. Outside of the study area, the impacts will decrease with increasing distance from the airport and may be inferred from values at the extremes of the model domain. It should be noted that, as air quality impacts are assessed on a grid of receptors spaced 50m apart over the entire area, the receptors selected for inclusion in the tables and Figure 15.1 cover only a subset of all receptors assessed and were chosen to be representative of sensitive receptors (e.g. schools) and properties in the potentially most affected

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villages in the surrounding area.

Outline Approach for Construction Impacts

15.3.3 It is considered that the potential for dust to cause impacts is likely to be limited to approximately 200m from construction works that have dust generation potential.

15.3.4 In addition, construction traffic and plant have the potential to impact on human health and ecosystems via exhaust gas emissions.

Outline Approach for Operation Impacts

15.3.5 The approach taken to assess the air quality impacts of the operation of the runway extension is to compare, using computer dispersion modelling, current local air quality with that anticipated in the future if the runway extension is constructed and that anticipated if the extension is not constructed.

15.3.6 The scenarios modelled are as described in Section 15.1.

15.3.7 The modelling of local air quality impacts requires the identification and quantification of airport-related pollutant sources, and the estimation of background pollution levels. Background pollution levels are considered to arise from emission sources within the study area but not directly related to the airport (primarily traffic sources), and from the medium and long range transport of pollutants from outside the study area.

15.3.8 Background pollution concentrations are available from the UK National Air Quality Information Archive (NAQIA)14. The archive provides pollutant concentrations on a 1km grid for the UK for the year 2001 and also for compliance years relevant to individual pollutants. Factors and guidance are provided by NAQIA to estimate concentrations in other years. Background nitrogen deposition levels are available from the 5km mapped data provided by the Air Pollution Information System (APIS)15.

15.3.9 For the calculation of total pollutant concentrations, background concentrations relevant to 2005 are used in the assessment of current airport impacts and concentrations relevant to 2009 are used in the assessment of both scenarios examining the increase in passenger levels to 300,000 passengers per annum.

15.3.10 Emissions sources explicitly considered for this assessment include:

• Aircraft-related emissions

• Engine exhaust emissions in the landing and take-off cycle below 1000m (3200ft),

• Auxilliary Power Unit (APU) emissions,

• Fuel handling

• Brake wear and tear

• Airside vehicle emissions

• Exhaust emissions from aircraft support vehicles

14 UK National Air Quality Information Archive, www.airquality.co.uk 15 Air Pollution Information System , www.apis.ac.uk

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• Exhaust emissions from airport operational vehicles

• Landside vehicle emissions

• Exhaust emissions on public roads

• Exhaust emissions on airport approach road

• Exhaust emissions in airport car-park, including cold start emissions

• Tyre wear and tear

• Emissions from terminal heating boiler 15.3.11 The estimation of emissions from aircraft related emissions has been based on current and future operational data supplied by LAA as annual averages. The estimation of emissions from landside traffic emissions has been based on the assessment of traffic levels described in Chapter 14 of this ES. Pollutant emissions have been based on emission factor data contained in:

• ICAO databank16; FAA databank17

• AP4218

• NAEI19 15.3.12 Further details of the estimation of emissions and their spatial distribution are provided in Appendix 15.1.

15.3.13 Tables 15.3 to 15.5 show the estimated annual emissions of NOx, PM10 and NMVOCs for the modelling scenarios.

16 International Civil Aviation Organisation Engine Exhaust Data Bank 17 Federal Aviation Authority Aircraft Engine Emissions Database 18 US Environmental Protection Agency Compilation of air pollutant emission factors, AP-42 5th edition 19 UK National Air Emissions Inventory, www.naei.co.uk

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Table 15.3 Annual emissions of NOx in tonnes per year 300,000 300,000 passengers Current passengers With No Extension Extension Runway Take-off roll 0.19 3.97 7.32 Landing roll 0.05 0.54 4.05 In Air Climb-out 1.26 10.76 17.02 Approach 0.87 2.83 3.48 Taxi In and Out 0.03 1.21 0.93 Gate Shut down 0.04 3.17 1.18 APU <0.01 0.22 0.67 Airside support vehicles 3.73 10.69 9.48 Helicopter Take-off <0.01 0.02 0.02 Landing <0.01 0.01 0.01 Carpark Cold start 0.01 0.03 0.03 Finding space 0.02 0.05 0.05 Roads Main roads in study area 25.43 21.96 21.98 Boiler Fuel oil burner 0.28 0.28 0.28 Totals All sources 31.9 55.7 66.5 Aircraft engines1 2.4 22.5 34.0 Airport-related2 6.5 33.8 44.5 1. Direct emissions from aircraft engines during landing and take-off cycle 2. All sources except main roads in study area

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Table 15.4 Annual emissions of PM10 in tonnes per year 300,000 300,000 passengers Current passengers With No Extension Extension Runway Take-off roll <0.001 0.004 0.011 Landing roll <0.001 0.001 0.006 Brake and tyre wear 0.131 0.536 0.564 In Air Climb-out <0.001 0.011 0.022 Approach <0.001 0.002 0.007 Taxi In and Out <0.001 0.001 0.002 Gate Shut down <0.001 0.002 0.002 APU 0.000 0.000 <0.001 Airside support vehicles 0.128 0.620 0.521 Helicopter Take-off <0.001 <0.001 <0.001 Landing <0.001 <0.001 <0.001 Carpark Cold start 0.001 0.003 0.003 Finding space 0.001 0.001 0.001 Roads Main roads in study area 0.88 0.70 0.70 Brake and tyre wear 0.33 0.39 0.39 Boiler Fuel oil burner 0.041 0.041 0.041 Totals All sources 1.5 2.3 2.3 Aircraft engines1 0.13 0.56 0.61 2 Airport-related 0.30 1.22 1.18 1. Direct emissions from aircraft engines, tyres and brakes during landing and take-off cycle 2. All sources except main roads in study area

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Table 15.5 Annual emissions of NMVOC in tonnes per year 300,000 300,000 passengers Current passengers With No Extension Extension Runway Take-off roll 0.42 0.45 0.51 Landing roll 0.44 0.58 0.92 In Air Climb-out 4.94 5.01 5.55 Approach 4.43 4.62 4.97 Taxi In and Out 0.56 1.87 2.41 Gate Shut down 0.65 2.53 3.41 APU <0.01 0.02 0.03 Airside support vehicles 0.32 0.97 0.85 Refuelling 0.03 0.52 0.67 Helicopter Take-off 0.01 0.02 0.02 Landing <0.01 0.02 0.02 Carpark Cold start 0.05 0.24 0.24 Finding space <0.01 <0.01 <0.01 Roads Main roads in study area 3.03 2.64 2.64 Boiler Fuel oil burner <0.01 <0.01 <0.01 Totals All sources 14.9 19.5 22.3 Aircraft engines1 11.5 15.1 17.8 Airport-related2 11.9 16.9 19.6 1. Direct emissions from aircraft engines during landing and take-off cycle 2. All sources except main roads in study area

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Dispersion modelling

15.3.14 Dispersion modelling was undertaken using the ADMS model (version 3.3) ADMS is a new generation dispersion model that has been widely used in other airport air quality assessments including Heathrow and Stansted.

15.3.15 The dispersion modelling was undertaken using 5 years of hourly sequential meteorological data collected at Herstmonceaux between 1997 and 2001. Herstmonceaux (approximately 45km west of Lydd) is the station closest to Lydd that records the complete set of meteorological data required for dispersion modelling. A comparison of the wind roses from observations at LAA and Herstmonceaux shows a high degree of correlation, sufficient to justify the use of Herstmonceaux for dispersion modelling purposes. Wind roses for Herstmonceaux are shown in Figure 15.2. South-westerly winds are dominant, but there are also a significant percentage of north-easterly winds.

15.3.16 As described in 15.3.2, the dispersion model is used to predict pollutant concentrations and deposition on a grid of ground level receptors covering the entire study area, with a maximum resolution of 50m. The dispersion model results are presented graphically as concentrations or deposition contour plots, and in tabulated form at selected receptors. The receptors have been chosen to be representative of the most affected offsite properties, sensitive receptors e.g. schools, and to be representative of worst case sensitivities within the villages in the area e.g. Lydd, Greatstone, and New Romney.

15.3.17 Further details of the dispersion modelling are provided in Appendix 15.2.

Significance Criteria

15.3.18 The quantitative air quality assessment criteria used in this study are based on the air quality objectives or critical loads. There is no generally accepted guidance available on the significance of air quality impacts (see below) and the judgement of significance is usually based on the expertise of the air quality specialist and similar projects.

15.3.19 For this study, the assessment of significance will be made on a pollutant specific basis, which will take into account:

• the level of background concentration or deposition;

• the process contribution (PC) as a percentage of the relevant objective or criteria i.e. the contribution of LAA alone; and

• the predicted environment concentration (PEC) as a percentage of the relevant objective or criteria i.e. the total concentration in ambient air or deposition, taking into account the process contribution and the background concentrations/deposition. 15.3.20 For annual average measures, where the process contribution is less than 1% of the relevant standard, the significance of the impact of the process will be considered to be negligible whether background concentrations exceed the standard or not. Table 15.6 provides the full set of significance criteria.

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Table 15.6 Significance criteria Significance Factor Major Moderate Minor Negligible PEC ≤ 70% of limit PEC > 70% of limit and PC ≤ 50% of limit value and PC > (25% for non- PC ≤ 10% of limit 10% threshold pollutants) PC ≤ 1% of limit Local air quality value and PEC ≤ value Or or 70% PC > 50% PEC > 70% and PC ≤ 10%

15.4 Baseline Environment (Existing Conditions Scenario)

Overview

Background Pollutant Concentrations

15.4.1 Air quality in the South East of England is generally good, although pollution hot spots and high pollution episodes do occur. Pollution events fall into two main categories, summer ozone pollution episodes and winter nitrogen dioxide and particulate matter episodes.

15.4.2 The main sources of pollution in the region are road traffic and emissions arising from mainland Europe and other parts of the UK. There are relatively few major industrial sources of pollution in the region. These are primarily located within the Solent Area and in the East Thames Corridor and are, therefore, of low significance to air quality assessment for LAA.

15.4.3 Table 15.7 shows the background pollutant concentrations in the vicinity of LAA, extracted from the NAQIA. Concentrations of all pollutants relevant to LAQM are well within their respective statutory Air Quality Objectives for the protection of both human health and vegetation and ecosystems. Background concentrations of all pollutants are expected to decrease with time, primarily as a result of a tightening of emissions standards across all industrial and transport sectors.

Table 15.7 National Air Quality Archive Pollutant Concentrations at Lydd Airport 1-3 Pollutant NO NO PM CO Benzene SO X 2 10 Butadiene 2 Year μg/m3 μg/m3 μg/m3 mg/m3 μg/m3 μg/m3 μg/m3 2005 11.1 8.7 20.1 0.13 0.12 0.05 5.0 2009 9.7 7.8 18.6 0.10 0.11 0.04 5.0

Local Air Quality Management

15.4.4 The assessment study area lies within the boundaries of Shepway District Council (SDC). SDC have followed the phased approach required by the Government to review the levels and sources of pollution in their areas, and to assess likely future concentrations of the pollutants specified in the National Air Quality Strategy (NAQS) and Air Quality Regulations.

15.4.5 SDC has concluded that there are no areas of concern for local air quality in the District, and as such the Council have not declared any Air Quality Management

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Areas. The main source for locally generated air pollution is road traffic. The only major industrial site in the area is Dungeness Power Station which does not emit significant quantities of pollutants relevant to Local Air Quality Management.

Ecosystems

15.4.6 There are two internationally designated sites for the protection of habitats in the vicinity of the airport, namely Dungeness Special Area of Conservation (SAC) and Dungeness to Pett Level Special Protection Area (SPA). In addition, there are two nationally designated sites immediately adjacent to the airport, Northlade Site of Special Scientific Interest (SSSI) and Dungeness SSSI. Furthermore, an extension to the Northlade SSSI has been proposed, which includes the soft verges in the immediate vicinity of the runway and terminal building, within the airport boundary.

15.4.7 Data provided in the NAQIA indicate that NOx and SO2 levels are currently within the Objectives set for the protection of vegetation and ecosystems.

15.4.8 APIS provides information on critical loads for acidification and eutrophication. Acidification relates to the deposition of pollutants which may acidify soils and freshwaters; this includes species derived from NOx, SO2 and ammonia emissions, as well as a number of other minor pollutants. Eutrophication relates to nitrogen deposition including species derived from NOx and ammonia emissions. In the vicinity of the airport, APIS provides the following critical loads

• 4 keq/ha/yr for acidification; and

• 10-15 kgN/ha/yr for eutrophication of vegetation, on the nutrient-poor shingle banks. 15.4.9 Background deposition of acid is estimated in APIS to be approximately 1.6keq/ha/yr, well within the relevant critical load. Background deposition of nitrogen is, however, estimated to be 15.3kgN/ha/yr which exceeds the critical load by between 2% to 50%, indicating that the shingle banks in the region may experience greater nutrient deposition than can be tolerated. However, the deposition estimated by APIS is applicable to the year 2000, and may be reduced by 2% each year to take into account generally decreasing background levels of nitrogen dioxide. Table 15.8 shows the estimated nitrogen deposition for the future years. Nitrogen deposition is estimated to remain above the most conservative estimate of the critical load in the future, but within the upper estimate.

Table 15.8 APIS Background Nitrogen Deposition at Lydd Airport Pollutant Nitrogen Year kgN/ha/yr 2001 15.3 2005 13.8 2009 12.8

Dust

15.4.10 There are no quantitative data available on dust deposition rates in the vicinity of the airport. In the absence of large industrial processes or active mineral extraction, within 500m of the airport, capable of generating significant quantities of dust e.g. ferrous metal processes, cement making etc., it has been assumed that dust deposition levels are typical of a rural/coastal area and, as such, are not an area of concern. There is a landfill site to the west of the airport, close to the junction of the

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airport approach road and the B2075. Remediation works are currently being undertaken at the site, which have the potential to generate dust. However, these works should be completed within 18 months and are not expected, therefore, to impact on dust levels during the terminal construction.

Local Environmental Conditions

15.4.11 Table 15.9 shows the predicted increment to annual mean nitrogen dioxide, at selected receptors, resulting from the current operations of LAA and roads in the vicinity of the airport. The data shown in the table are the maximum over the 5 years of meteorological data used in the modelling. Total ambient pollutant concentrations (PEC) also shown and are predicted to be well within the Air Quality Objective for annual mean nitrogen dioxide at all locations.

15.4.12 A typical spatial distribution of pollutant concentrations is provided in Figure 15.3, which shows the predicted annual mean concentrations of nitrogen dioxide, modelled using meteorological data from 2001 and pollutant emissions estimated on the basis of current activity levels.

15.4.13 At the current levels of airport activities, the local contribution to ambient nitrogen dioxide levels is dominated by two sources: traffic on local roads, which carry predominantly non-airport related traffic; and airport activities in the vicinity of the existing terminal buildings, which include the idling of aircraft engines, airside vehicle emissions and the heating boiler. Ground level pollutant concentrations of NO2 resulting from aircraft landing and take-off (LTO) cycle emissions are negligible.

15.4.14 At off-airport receptors, the contribution to ambient air NO2 concentrations resulting from current airport activities is predicted to be of negligible to minor significance.

15.4.15 Table 15.9 shows that the contribution from local sources to annual mean ambient concentrations of PM10 is negligible at current activity levels, and that total pollutant concentrations are well within the statutory Air Quality Objective.

15.4.16 Table 15.10 shows the contribution from local sources to annual mean ambient concentrations of NMVOCs for which there are Air Quality Objectives, namely Benzene and 1-3 Butadiene, and their total ambient air concentrations. Total concentrations are well within the Air Quality Objectives, and the contribution from airport-related sources is negligible at current activity levels.

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Table 15.9 Ambient Air Pollutant Concentrations (μg/m3) resulting from current activities at LAA

Contribution from Local Sources Total Ambient Air Concentration μg/m3 μg/m3

Id Receptor NO2 PM10 NO2 PM10

Objective 40 40 40 40

1 Lydd 1.36 0.08 10.06 20.18

2 Lydd (School) 1.31 0.08 10.01 20.18

3 Greenhop Farm 0.99 0.06 9.69 20.16

4 Jack's Court 1.82 0.11 10.52 20.21

5 Lade 0.28 0.02 8.98 20.12

6 Greatstone on Sea 0.53 0.04 9.23 20.14

7 Greatstone on Sea (School) 0.58 0.04 9.28 20.14

8 Romney Sands 0.55 0.04 9.25 20.14

9 LittleStone on Sea 0.81 0.06 9.51 20.16

10 New Romney 2.36 0.15 11.06 20.25

11 Hammonds Corner 8.05 0.46 16.75 20.56

12 Calcott Farm 1.31 0.08 10.01 20.18

13 Belgar Farm 1.47 0.09 10.17 20.19

14 Lydd Golf Club 1.46 0.09 10.16 20.19

15 Forty Acre Farm 2.05 0.13 10.75 20.23

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Table 15.10 Ambient Air Pollutant Concentrations (μg/m3) resulting from current activities at LAA Contribution from Local Total Ambient Air Sources μg/m3 Concentration μg/m3 Id Receptor Benzene 1-3 Butadiene Benzene 1-3 Butadiene Objective 5 2.25 5 2.25 1 Lydd 0.009 0.004 0.129 0.054 2 Lydd (School) 0.008 0.004 0.128 0.054 3 Greenhop Farm 0.008 0.005 0.128 0.055 4 Jack's Court 0.011 0.005 0.131 0.055 5 Lade 0.003 0.002 0.123 0.052 6 Greatstone on Sea 0.005 0.004 0.125 0.054 7 Greatstone on Sea (School) 0.007 0.005 0.127 0.055 8 Romney Sands 0.004 0.002 0.124 0.052 9 LittleStone on Sea 0.005 0.002 0.125 0.052 10 New Romney 0.016 0.006 0.136 0.056 11 Hammonds Corner 0.038 0.012 0.158 0.062 12 Calcott Farm 0.008 0.003 0.128 0.053 13 Belgar Farm 0.009 0.004 0.129 0.054 14 Lydd Golf Club 0.010 0.004 0.130 0.054 15 Forty Acre Farm 0.014 0.006 0.134 0.056

15.4.17 Figures 15.4 and 15.5 show the typical predicted spatial distribution of the airport related contribution to annual mean deposition of nitrogen and total NOx, respectively, modelled using meteorological data from 2001. Table 15.11 shows the nitrogen oxides concentration and nitrogen deposition over the existing designated ecosystem sites. Since the ecosystem sites cover substantial areas, concentrations and deposition values are presented as the range over the sites, as illustrated by the range of concentration or deposition at the ecosystem receptors shown in Figures 15.4 and 15.5. Data for the Dungeness SSSI can be inferred from the results for the Dungeness SAC and Dungeness to Pett Level SPA.

15.4.18 The concentration of oxides of nitrogen is within the Air Quality Objective (30μg/m3) at all sites. Total nitrogen deposition exceeds the most conservative estimate of critical load for the sites, primarily as a result of the elevated background deposition levels alone.

15.4.19 Over the majority of the Dungeness SAC and Dungeness to Pett Level SPA, the contribution from airport-related sources represents a negligible impact. Over the majority of the existing Northlade SSSI and the area of the Dungeness SAC closest to the airport, the contribution from airport sources to nitrogen deposition is less than 10% of the critical load, but is judged to be a moderate impact as a result of the high background levels of deposition.

15.4.20 Within the airport boundary, over the proposed SSSI, maximum nitrogen deposition exceeds 1kgN/ha/yr in limited areas (10% of the critical load for vegetated shingle. However, there are no sensitive habitats (i.e. vegetated shingle) in these areas and the impact is, therefore, considered negligible.

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3 Table 15.11 Ambient Air Pollutant Concentrations of NOx (μg/m ) and Nitrogen Deposition (kgN/ha/yr) over the existing designated sites resulting from current activities at LAA.

Contribution from Local Total Ambient Air Sources Concentration/ Deposition N deposition N deposition 3 3 Id Receptor NOx (μg/m ) (kgN/ha/yr) NOx (μg/m ) (kgN/ha/yr) Objective/Critical Load 30 10-15 30 10-15 1 Northlade SSSI 1.09 - 7.11 0.09 - 0.57 12.19 – 18.21 13.89 - 14.37 2 Dungeness SAC 0.16 - 1.75 0.01 - 0.14 11.26 – 12.85 13.81 - 13.94 Dungeness to Pett Level 3 SPA 0.19 - 0.76 0.02 - 0.06 11.29 – 11.86 13.82 - 13.86

15.5 Baseline Environment – Future Assessment Conditions Scenario

15.5.1 Tables 15.3 to 15.5 show that airport related emissions of NOx, PM10, and NMVOC from LAA are predicted to increase to 34, 1.2 and 17 tonnes/year respectively with the increase in passenger levels to 300,000 passengers per annum without the runway extension. Current emission totals are 6.5, 0.30 and 12 tonnes/year respectively. Aircraft emissions of NOx increase from 2.4 to 22 tonnes/year with the increased passenger numbers. Aircraft emissions of PM10 and NMVOC also increase, but show lower percentage increases over current levels.

15.5.2 Table 15.12 shows the predicted increment to annual mean pollutant concentrations of nitrogen dioxide resulting from the operation of the airport at 300K ppa without the runway extension, and the total ambient concentrations, at selected receptors. The data shown in the table are the maximum over the 5 years of meteorological data used in the modelling.

15.5.3 Figure 15.6 shows a typical prediction of total predicted annual mean concentrations of nitrogen dioxide, modelled using meteorological data from 2001, for the 300,000 passengers per annum cases without the runway extension. As the number of passengers served by LAA increases, ambient air concentrations of NO2 in the study area become increasingly influenced by on-airport pollution sources. Ground level concentrations in the vicinity of the airport remain dominated by activities in the terminal gate area, although the impacts of aircraft LTO cycles increase in significance as the number of plane movements increases.

15.5.4 Total ambient pollutant concentrations are predicted to be well within the Air Quality Objectives for the protection of human health at all relevant receptor locations. At the landside of the airport terminal, the maximum annual mean concentration of NO2 is around 20μg/m3, well within the Objective and it is therefore concluded that concentrations are also likely to be within the hourly mean Objective.

15.5.5 With respect to current levels, NO2 concentrations show both increases and decreases with increased passenger movements, depending on the location of the receptor. Decreases result from a combination of decreasing background concentrations and decreasing vehicle emissions on local roads as a result of improvement in vehicle technology and increasingly stringent emissions standards. At receptors with a significant contribution from airport-related sources, the decrease in background concentrations is more that offset by the increase in airport emissions, resulting in an increase in concentrations. At the terminal building, there is a moderate increase in pollutant concentrations, but no predicted exceedence of the annual mean (and hence hourly mean) Objective.

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Table 15.12 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum without runway extension scenario. Contribution from Local Total Ambient Air Sources μg/m3 Concentration μg/m3

Id Receptor NO2 PM10 NO2 PM10 Objective 40 40 40 40 1 Lydd 1.92 0.12 9.72 18.72 2 Lydd (School) 1.55 0.10 9.35 18.70 3 Greenhop Farm 1.98 0.13 9.78 18.73 4 Jack's Court 2.03 0.13 9.83 18.73 5 Lade 0.68 0.05 8.48 18.65 6 Greatstone on Sea 1.12 0.08 8.92 18.68 Greatstone on Sea 7 1.53 0.11 9.33 18.71 (School) 8 Romney Sands 0.81 0.06 8.61 18.66 9 LittleStone on Sea 0.89 0.07 8.69 18.67 10 New Romney 2.16 0.15 9.96 18.75 11 Hammonds Corner 7.06 0.43 14.86 19.03 12 Calcott Farm 1.37 0.09 9.17 18.69 13 Belgar Farm 1.82 0.12 9.62 18.72 14 Lydd Golf Club 2.02 0.13 9.82 18.73 15 Forty Acre Farm 2.58 0.17 10.38 18.77

15.5.6 Table 15.12 shows the predicted annual mean concentrations of PM10 in the 300,00 passengers per annum without runway extension scenario. Annual mean pollutant concentrations of PM10 are within the statutory Air Quality Objective in all scenarios and, in comparison to the current pollution levels, have decreased to within the provisional Objective by the time of the opening of the runway extension.

15.5.7 Direct assessment of the Air Quality Objective for daily mean concentration of PM10 is not possible using the methodology used for this study. However, the number of 3 exceedences of the daily mean PM10 standard, 50μg/m , may be estimated using the methodology provided in Appendix 15.2. The maximum predicted number of exceedences with the operation of the runway extension, at relevant receptor locations, is 3, well within the Objective which allows 35 exceedences. The value is also within the provisional Objective, which allows 7 exceedences of the standard.

15.5.8 Reductions in total annual mean PM10 concentrations with respect to current levels are seen at all receptors. This is due to the anticipated decrease in background concentrations between 2005 and 2009 being greater than the increase in the contribution from airport-related sources.

15.5.9 Table 15.13 shows the predicted annual mean concentrations of Benzene and Butadiene in the 300K ppa without the runway extension scenario. Annual mean pollutant concentrations of NMVOCs are within the Air Quality Objective in all scenarios. With respect to current pollution levels, total ambient air concentrations of Benzene and Butadiene show both increases and decreases depending on the location dependent balance between the effects of increasing on-airport emissions, decreasing road traffic emissions and decreasing background concentrations.

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Table 15.13 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum without runway extension scenario Contribution from Local Total Ambient Air Sources μg/m3 Concentration μg/m3 Id Receptor Benzene 1-3 Butadiene Benzene 1-3 Butadiene Objective 5 2.25 5 2.25 1 Lydd 0.016 0.011 0.126 0.051 2 Lydd (School) 0.012 0.007 0.122 0.047 3 Greenhop Farm 0.019 0.014 0.129 0.054 4 Jack's Court 0.017 0.008 0.127 0.048 5 Lade 0.007 0.005 0.117 0.045 6 Greatstone on Sea 0.010 0.008 0.120 0.048 Greatstone on Sea 7 0.015 0.012 0.125 0.052 (School) 8 Romney Sands 0.007 0.005 0.117 0.045 9 LittleStone on Sea 0.006 0.003 0.116 0.043 10 New Romney 0.015 0.006 0.125 0.046 11 Hammonds Corner 0.034 0.011 0.144 0.051 12 Calcott Farm 0.009 0.004 0.119 0.044 13 Belgar Farm 0.014 0.008 0.124 0.048 14 Lydd Golf Club 0.017 0.010 0.127 0.050 15 Forty Acre Farm 0.026 0.013 0.136 0.053

15.5.10 Table 15.14 shows the predicted range of annual mean nitrogen oxide concentration and nitrogen deposition over the existing designated ecosystem sites for the 300,000 passenger per annum without runway extension scenario. Figure 15.7 shows the predicted airport related contribution to annual mean deposition of nitrogen, modelled using meteorological data from 2001, for the 300,000 passengers per annum without runway extension scenario. Figure 15.8 shows the total predicted annual mean concentrations of NOx.

3 Table 15.14 Ambient Air Pollutant Concentrations of NOx (μg/m ) and Nitrogen Deposition (kgN/ha/yr) over the existing designated sites for the 300,000 passengers per annum without runway scenario

Contribution from Local Total Ambient Air Sources Concentration/ Deposition N deposition N deposition 3 3 Id Receptor NOx (μg/m ) (kgN/ha/yr) NOx (μg/m ) (kgN/ha/yr) Objective/Critical Load 30 10-15 30 10-15 1 Northlade SSSI 1.81 - 25.99 0.14 - 2.08 11.51 - 35.69 12.94 - 14.88 2 Dungeness SAC 0.31 - 7.68 0.02 - 0.61 10.01 - 17.38 12.82 - 13.41 Dungeness to Pett Level 3 0.38 - 2.38 0.03 - 0.19 10.08 - 12.08 12.83 - 12.99 SPA

15.5.11

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15.5.12 Offsite, concentrations of NOx are within the Objective for the protection of vegetation over all sites, with the exception of the area of the existing Northlade SSSI closest to the airport terminal. Onsite, concentrations exceed the Objective over the region of the proposed SSSI in the vicinity of gate activities. However, there is no vegetated shingle in the exceedence areas. Furthermore, it should be noted that the Objective for the protection of vegetation does not apply in microscale environments such as the vicinity of the airport terminal.

15.5.13 Offsite, over the existing designated sites, nitrogen deposition is predicted to be above the most conservative estimate of the critical load, but within the upper limit. With the exception of the aforementioned area of existing Northlade SSSI closest to the terminal, predicted deposition levels for 300,000 passengers per annum without runway extension scenario are generally lower than current levels due to the anticipated decrease in background deposition levels being greater than the impact of the airport.

15.5.14 Onsite, over the proposed SSSI, there are locations within 20m of the edge of the runway where vegetated shingle is present and the airport contribution to nitrogen deposition exceeds 10% of the critical load. However, total deposition in these areas is predicted to be lower than current levels and the overall impact is, therefore, considered to be of moderate significance.

15.6 Potential Impacts (Construction Works)

Existing Conditions Scenario

15.6.1 Dust deposition impacts are likely to be limited to properties or ecosystems within 200m of construction activities with dust generation potential. Whilst there are no residential properties within 200m of proposed works, the Northlade SSSI and the Dungeness SSSI/SAC lie within 200m of the site. In addition, residential properties adjoining the airport access roads e.g. Forty Acre Farm, and farms along the B2075 to Hammonds Corner, could be impacted by dust on roads. The assessment of nuisance dust effects is based on the assumption that appropriate control measures would be applied during construction.

15.6.2 The potential for dust nuisance at properties and ecosystem sites will depend on a wide range of factors including prevailing meteorological conditions, the nature of materials and the type and duration of the activities.

15.6.3 The potential for dust generation and its transport to sensitive receptors is highest during dry, windy conditions. In general, construction activities associated with the greatest potential for dust generation are:

• Earthworks including excavation of topsoil, handling on site and deposition;

• Handling and storage of materials (including loading and unloading)

• Haulage roads and unsealed site surfaces (including vehicles travelling along them);

• Wind blow across disturbed site surfaces and materials; and

• Mechanical operations such as crushing, drilling, concrete mixing and cutting.

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15.6.4 It is currently anticipated that the scheme will not generate a significant surplus of excavated material during construction, and it is envisaged that the majority of material can be used on site with little requirement for offsite disposal.

15.6.5 The employment of Best Practicable Means (BPM) would minimise the risk of adverse effects from construction dust and should avoid causing Statutory Nuisance or damage to vegetation. Specific control measures for construction would be applied through the implementation of a Construction Environmental Management Plan (CEMP).

15.6.6 The site manager would have responsibility on a day to day basis for determining if either the nature of the activities on site or weather conditions would be likely to result in the transfer of dust off site. Were this to be the case, remedial action would be taken to minimise emissions, including the application of appropriate control measures, or if necessary, the temporary suspension of works. Examples of appropriate control measures are provided in Section 15.6.

15.6.7 Exhaust emissions from construction traffic and plant have the potential to create adverse impacts on local air quality. As for dust control, the employment of BPM, as outlined in Section 15.6, will minimise the risk of adverse impacts. Furthermore, due to the temporary nature of construction activities at any one location, it is considered unlikely that these effects will be significant.

Future Assessment Conditions Scenario

15.6.8 Impacts for the Future Assessment Conditions Scenario are as described under the “Existing conditions scenario” above.

15.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

15.7.1 Tables 15.3 - 15.5 show that airport related emissions of NOx are predicted to increase to 44 tonnes/year with the proposed runway extension. This is primarily due to an increase in aircraft emissions to 34 tonnes/year resulting from the use of larger planes on the extended runway. Furthermore, as the number of large planes increases, emissions from APUs increase, but the emissions from the idling of engines at the gate decreases. Emissions of PM10 and NMVOC also increase with the operation of the extended runway, but show much lower percentage increases than the “300 000 passengers p.a. without runway extension” scenario.

15.7.2 Table 15.15 shows the predicted increment to annual mean nitrogen dioxide concentrations, at selected receptors, resulting from the operation of the airport to 300,000 passengers per annum with the extended runway. The data shown in the table are the maximum over the 5 years of meteorological data used in the modelling.

15.7.3 Total ambient pollutant concentrations are predicted to be well within the Air Quality Objectives for the protection of human health at all relevant receptor locations. At the landside of the airport terminal, the maximum annual mean concentration of NO2 is around 20μg/m3, well within the Objective and it is therefore concluded that concentrations are also likely to be within the hourly mean Objective.

15.7.4 Figure 15.9 shows the total predicted annual mean concentration of nitrogen dioxide, modelled using meteorological data from 2001, and emissions for the 300,000 passengers per annum with runway extension scenario.

15.7.5 NOx concentrations increase with the operation of the runway extension as the number of large planes increases. Very small reductions in concentration are seen at

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receptors close to the terminal area, due to a decrease in emissions from aircraft support vehicles as a result of the more efficient use of support vehicles when servicing larger planes. The increases in concentration are of negligible to minor significance.

Table 15.15 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum with runway extension scenario

Contribution from Local Total Ambient Air Sources μg/m3 Concentration μg/m3

Id Receptor NO2 PM10 NO2 PM10 Objective 40 40 40 40 1 Lydd 1.95 0.12 9.75 18.72 2 Lydd (School) 1.58 0.10 9.38 18.70 3 Greenhop Farm 1.97 0.12 9.77 18.72 4 Jack's Court 2.11 0.13 9.91 18.73 5 Lade 0.75 0.05 8.55 18.65 6 Greatstone on Sea 1.66 0.09 9.46 18.69 Greatstone on Sea 7 2.48 0.13 10.28 18.73 (School) 8 Romney Sands 1.00 0.06 8.80 18.66 9 LittleStone on Sea 0.96 0.07 8.76 18.67 10 New Romney 2.22 0.15 10.02 18.75 11 Hammonds Corner 7.08 0.43 14.88 19.03 12 Calcott Farm 1.38 0.09 9.18 18.69 13 Belgar Farm 1.82 0.11 9.62 18.71 14 Lydd Golf Club 2.02 0.12 9.82 18.72 15 Forty Acre Farm 2.60 0.17 10.40 18.77

15.7.6 Table 15.15 shows the predicted annual mean concentrations of PM10 in the 300,000 passengers per annum with the runway extension scenario

15.7.7 Annual mean pollutant concentrations of PM10 are within the statutory Air Quality Objective in all scenarios and, in comparison to the current pollution levels, have decreased to within the provisional Objective by the time of the opening of the runway extension.

15.7.8 Table 15.16 shows the predicted annual mean concentrations of Benzene and Butadiene in the 300,000 passengers per annum with runway extension scenario. Annual mean pollutant concentrations of NMVOCs are within the Air Quality Objective in all scenarios.

15.7.9 With respect to current pollution levels, total ambient air concentrations of Benzene and Butadiene show both increases and decreases depending on the location dependent balance between the effects of increasing on-airport emissions, decreasing road traffic emissions and decreasing background concentrations.

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Table 15.16 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum with runway extension scenario

Contribution from Local Total Ambient Air Sources μg/m3 Concentration μg/m3 Id Receptor Benzene 1-3 Butadiene Benzene 1-3 Butadiene Objective 5 2.25 5 2.25 1 Lydd 0.019 0.014 0.129 0.054 2 Lydd (School) 0.013 0.008 0.123 0.048 3 Greenhop Farm 0.022 0.018 0.132 0.058 4 Jack's Court 0.018 0.010 0.128 0.050 5 Lade 0.008 0.007 0.118 0.047 6 Greatstone on Sea 0.013 0.011 0.123 0.051 Greatstone on Sea 7 (School) 0.019 0.017 0.129 0.057 8 Romney Sands 0.008 0.006 0.118 0.046 9 LittleStone on Sea 0.007 0.004 0.117 0.044 10 New Romney 0.016 0.007 0.126 0.047 11 Hammonds Corner 0.034 0.012 0.144 0.052 12 Calcott Farm 0.009 0.005 0.119 0.045 13 Belgar Farm 0.015 0.009 0.125 0.049 14 Lydd Golf Club 0.019 0.013 0.129 0.053 15 Forty Acre Farm 0.029 0.015 0.139 0.055

15.7.10 Figure 15.10 shows the predicted airport related contribution to annual mean deposition of nitrogen, modelled using meteorological data from 2001, for the 300,000 passengers per annum with runway extension scenario. Figure 15.11 shows the predicted annual mean concentration of NOx. Table 15.17 shows the range of nitrogen oxide concentration and nitrogen deposition over the existing designated ecosystem sites.

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3 Table 15.17 Ambient Air Pollutant Concentrations of NOx (μg/m ) and Nitrogen Deposition (kgN/ha/yr) over the existing designated sites for the 300,000 passengers per annum with runway extension scenario

Contribution from Local Total Ambient Air Sources Concentration/ Deposition N deposition N deposition 3 3 Id Receptor NOx (μg/m ) (kgN/ha/yr) NOx (μg/m ) (kgN/ha/yr) Objective/Critical Load 30 10-15 30 10-15 1 Northlade SSSI 2.10 - 22.68 0.17 - 1.81 11.80 - 32.38 12.97 - 14.61 2 Dungeness SAC 0.34 - 8.99 0.03 - 0.72 10.04 - 18.69 12.83 - 13.52 Dungeness to Pett Level 3 0.43 - 2.76 0.03 - 0.22 10.13 - 12.46 12.83 - 13.02 SPA

15.7.11 Offsite, concentrations of NOx are within the Objective for the protection of all vegetation over all sites, with the exception of the area of Northlade SSSI closest to the airport terminal. Onsite, concentrations exceed the Objective over the region of the proposed SSSI in the vicinity of gate activities, however, there is no vegetated shingle in the exceedence area.

15.7.12 Offsite, nitrogen deposition is predicted to be above the most conservative estimate of the critical load, but within the upper limit. The increase in deposition with the operation of the runway extension is negligible. Furthermore, the predicted deposition in both 300,000 passengers per annum scenarios is generally lower than current levels, with the exception of the aforementioned area of Northlade SSSI closest to the terminal.

15.7.13 Onsite, over the proposed SSSI, there are locations within 60m of the edge of the runway where the airport contribution to nitrogen deposition exceeds 10% of the critical load and vegetated shingle is present. However, further than 10m from the edge of the runway, total deposition in these areas is predicted to be lower than current levels and the overall impact is, therefore, considered to be of moderate significance.

Climate Change

15.7.14 Global aviation is now considered to be an increasingly significant source of greenhouse gases, primarily carbon dioxide and water vapour from engine exhausts. Aircraft emissions are considered particularly important as they emit gases and particles directly into the upper troposphere and lower stratosphere (where they can impact on atmospheric composition, including ozone concentrations) as well as having the potential to trigger the formation of condensation trails and increase cirrus cloud cover. As a result of such effects, emissions from aircraft may have a larger global warming impact than would be estimated from the quantities of greenhouse gases emitted directly. Whilst the quantification of such indirect effects is subject to considerable uncertainty, typically the direct impact of emissions may be multiplied by a factor of between 2 and 4 to estimate the overall effects including indirect impacts.

15.7.15 Based on predicted growth in passenger demand, emissions of greenhouse gases from UK aviation (including all domestic flights and international flights originating in the UK) are predicted to increase from 4.6 Mt carbon equivalent (CE) in 1990 and 8.8 MT CE in 2000 to between 10.3Mt CE and 11.4 Mt CE in 2010 and to between 15.7 Mt CE and 29.1 Mt CE in 2050 (Aviation and Global Warming, Department for Transport, January 2004). This increase contrasts with UK commitments under the Kyoto protocol to reduce overall emissions by 8% by 2008-2012 and the stated

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national goal of reducing overall emissions by 60% by 2050. If both the overall UK targets and projected increase in aviation emissions are achieved, aviation would account for up to 30% of UK emissions in 2050. (It should be noted that only emissions from domestic flights are currently included in Kyoto targets. There is no international convention that allows emissions from international flights to be attributed to national emission inventories.)

15.7.16 How emissions of greenhouse gases from aviation should be subject to additional controls is currently the subject of national and international debate. Additional control measures that are being considered include financial measures such as carbon taxes and emission trading as well as restrictions on aircraft movements.

15.7.17 In principle, methods developed by Netcen (Revision to the Method of Estimating Emissions from Aircraft in the UK Greenhouse Gas Inventory: Netcen, July 2004) can be used to develop reasonably rigorous estimates of greenhouse gas emissions from aircraft using LAA. However, greenhouse gas emissions estimates from LAA with and without a runway extension are difficult to make at this stage, as it is not clear which routes and exact fleet mixes will be commercially sustainable. Furthermore, such estimates should take into consideration how much air traffic is displaced from other airports in the south-east of England.

Roadside Concentrations of Pollutants

15.7.18 The dispersion modelling undertaken for this study used a receptor grid with 50m spacing. This implies that the predicted concentrations are generally applicable to non-roadside sites only. Therefore, roadside concentrations have been estimated using the Screening Methodology recommended in the Design Manual for Roads and Bridges20. Figures 15.12 and 15.13 show the predicted roadside concentrations of nitrogen dioxide and particulates for sample locations alongside the B2075 between Hammonds corner and the airport approach road and the A259 through New Romney respectively.

15.7.19 Figures 15.12 and 15.13 show that in all scenarios, concentrations at the roadside are well within the Air Quality Objectives.

Future Assessment Conditions Scenario

15.7.20 In general terms, air quality impacts arising from the proposed project show only minor changes from the proposed “future assessment scenario” conditions, as described in section 15.5. In particular, total ambient pollutant concentrations are predicted to be well within the Air Quality Objectives for the protection of human health at all relevant receptor locations under both scenarios.

15.7.21 NOx concentrations will increase slightly for the 300 000 passengers with the runway extension scenario compared to the future assessment conditions baseline, as the number of large planes will increase, but the differences inn nitrogen deposition between the two scenarios are negligible.

15.7.22 For all other parameters the differences will also be negligible. Thus, for example, the predicted number of exceedences of the Air Quality Objective for daily mean PM10 with the operation of the runway extension is unchanged from the without extension scenario (at relevant receptor locations, the maximum number of exceedences remains 3, well within the Objective which allows 35 exceedences and the provisional Objective, which allows 7 exceedences of the standard).Annual mean pollutant concentrations of PM10 are within the statutory Air Quality Objective in all scenarios and, in comparison to the current pollution levels,

20 Highways Agency, Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1 (as amended in February 2003).

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15.7.23 The current proposal to increase the runway length at LAA will not alter the number of aircraft movements beyond the already permitted 300,000 ppa, and impacts on climate change are considered negligible.

15.7.24 The differences between the two scenarios serving 300,000 passengers per annum, i.e. with and without the runway extension, Roadside Concentrations of Pollutants are also negligible.

15.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenarios

15.8.1 Good site management practices during the construction works will help to prevent the generation of airborne dust. It will be the responsibility of the nominated contractor and site manager to ensure through a CEMP that sufficient precautionary measures to limit dust generation are in fact taken.

15.8.2 To ensure that atmospheric dust, contaminants or dust deposits generated by the construction work do not exceed levels which could constitute a nuisance to local residents or damage to ecosystems, or site equipment, it is proposed that visual inspections of dust, odours and exhaust emissions be undertaken along airport approach roads and along the boundary of the construction works. A trained and competent person should carry out monitoring on a weekly basis. However, if dry windy weather prevails then the rate of monitoring should (initially) be increased to daily, and increased to 4 times per day, if levels remain high.

15.8.3 The mitigation measures described below should be implemented as necessary. If, despite the implementation of best practicable means of dust/odour mitigation, levels of dust soiling remain unacceptable, the site manager should ensure the cessation of dust generating construction activities.

15.8.4 In ecologically sensitive areas, it is important that working methods and operations pay due attention to the protection of the integrity of the adjacent SSSIs and SAC.

Site Clearance

15.8.5 The prolonged storage of debris on site, in temporary stockpiles should be avoided. Vehicles removing demolition or site clearance materials must have their loads effectively sheeted on all sides. Crushing of material for reuse, transportation or disposal should be undertaken as far away as possible from sensitive receptors. Burning of waste material should be avoided if possible. Excavation faces, when not being worked, should be sheeted.

Handling and Storage of Materials

15.8.6 The number of handling operations should be minimised, ensuring that dusty material is not moved or handled unnecessarily. Fine material should be delivered to site in bags. Drop height must be kept to a minimum.

15.8.7 Stockpiles should be located as far away as practicable from potential receptors, with slopes at angles less than the natural angle of repose of the material. Stockpiles should be sheeted, contained within wind barriers or potentially damped down. If long term stockpiles are required, consideration should be given to the use of chemical bonding agents.

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Site Roads and Haulage Routes

15.8.8 Hard-standing areas for vehicles entering, parking and leaving the site should be provided, with wheel washing facilities at access points. Site roads should be cleaned regularly, and damped down if necessary. Site vehicle movements should be kept to a minimum and, where possible, restricted to paved haulage routes. Vehicle speeds should be limited to 20 km/h or less on surfaced roads, and 10 km/h on unpaved surfaces. The idling of vehicles should be kept to a minimum.

15.8.9 If required, cleaning of public roads used for transport of materials should be undertaken.

Mechanical Operations

15.8.10 Static and mobile plant should be well maintained, regularly serviced and located as far away as practicable for sensitive receptors. Spillages should be minimised and removed promptly.

Future Assessment Conditions Scenario

15.8.11 Proposed mitigation for construction impacts under this scenario is as described under the “Future assessment conditions scenario” above.

15.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

15.9.1 Given the relatively low significance of the impacts of the operation of the runway extension with 300,000 passengers per annum, detailed mitigation measures are not currently warranted. However, the following measures will be implemented as part of a long term strategy to minimise the impacts of the airport expansion on air quality

• Commissioning of air quality monitoring to monitor the impacts of the development of the airport following construction of the runway extension.

• Development of an LAA air quality strategy, with particular emphasis placed on the reduction of emissions for ground activities:

• Reducing time spent on APU;

• Using low emission ground support equipment;

• Reducing time spent with aircraft and vehicle engines idling; and

• Increasing efficiency of use of aircraft support vehicles.

• Ensure aircraft operate in the most fuel efficient manner during LTO cycles by:

• Minimising the time of aircraft spent on hold on runways;

• Minimising the thrust used during take-off, climb-out and approach; and

• Minimising the time spent on reverse thrust during landing roll.

• Increased use of public transport by passengers and staff.

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• Minimising spillages and fugitive losses of VOCs from refuelling operations. Climate Change

15.9.2 Options for the mitigation of increased greenhouse gas emissions from aircraft are currently the subject of policy studies at international, European and national levels, with the Airport Operators Association in the UK favouring international emissions trading. Carbon offset schemes have been considered as a voluntary measure by some UK airports, and this might be considered at LAA if it can be shown that greenhouse gas emissions are likely to rise as a result of fleet mix alterations.

Future Assessment Conditions Scenario 15.9.3 Proposed mitigation for operational impacts under this scenario is as described under the “future assessment conditions scenario” above.

15.10 Residual Effects

Existing Conditions Scenario

15.10.1 With the implementation of the mitigation measures detailed above the construction and operation of the runway extension is expected to have no more than a minor adverse impact on the air quality for the sensitive ecosystems.

Future Assessment Conditions Scenario

15.10.2 Residual impacts are expected to be as described for the “existing conditions scenario” above.

15.11 Summary

Dust

15.11.1 There are sensitive receptors within 200m of the planned works and potential dust impacts could be significant at residential properties and sensitive ecosystems without the implementation of mitigation measures. However, it is concluded that, with the application of Best Practicable Means, adverse impacts due to construction dust or nuisance effects are unlikely to occur.

Local Air Quality

15.11.2 Pollution levels are currently within the Air Quality Objectives at all relevant receptor locations, and are predicted to remain within the Objectives with the expansion of the airport to 300,000 passengers per annum capacity, whether the runway extension is constructed or not.

15.11.3 The operation of the runway extension results in negligible to minor changes in NO2 in relation to both current air quality and future air quality in the vicinity of the airport serving 300,000 passengers per annum without the extension.

15.11.4 Changes in PM10 and NMVOC concentrations resulting from the increase in airport passenger numbers and the construction of the runway are negligible. PM10 levels are predicted to decrease from current levels, whether the runway is constructed or not. This is a result of generally decreasing background concentration levels.

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15.11.5 At roadside receptors, pollutant concentrations in future scenarios are lower than current levels. The impact of the proposed development is therefore a reduction in the rate of improvement of air quality with time.

Impacts on Sensitive Ecosystems

15.11.6 Over the existing and proposed designated sites, the concentrations of NOx are currently predicted to be within the Air Quality Objective for the protection of vegetation and ecosystems. Where vegetated shingle is present, concentrations are anticipated to remain within the Objectives in the future, whether the runway extension is constructed or not.

15.11.7 The operation of the runway extension results in negligible to minor changes in NOx over the existing designated conservation sites, in relation to both current and future air quality in the absence of the runway extension.

15.11.8 Background levels of nitrogen deposition exceed the most conservative estimate of the critical load over the existing designated sites in the vicinity of the airport, but are within the upper estimate. Onsite, over the existing and proposed designated sites, where vegetated shingle is present, deposition is predicted to remain within the upper estimate of the critical load in the future scenarios for airport expansion, whether the runway is constructed or not.

15.11.9 The local contribution to nitrogen deposition resulting from the airport sources following the expansion of the airport to 300,000 passengers per annum is generally less than 10% of the critical load, but is considered to be of moderate significance due to the elevated background deposition levels. However, the increase in nitrogen deposition resulting from the difference between the 300,000 passengers per annum without the runway and 300,000 passengers with the runway is negligible offsite.

Climate Change

15.11.10 The current proposal to increase the runway length at LAA will not alter the number of aircraft movements beyond the already permitted 300,000 ppa, but it would alter the aircraft fleet mix using the airport. In principle, methods developed by Netcen (Revision to the Method of Estimating Emissions from Aircraft in the UK Greenhouse Gas Inventory: Netcen, July 2004) can be used to develop reasonably rigorous estimates of greenhouse gas emissions from aircraft using LAA.

15.11.11 However, greenhouse gas emissions estimates from LAA with and without a runway extension are difficult to make at this stage, as it is not clear which routes and exact fleet mixes will be commercially sustainable. Furthermore, such estimates should take into consideration how much air traffic is displaced from other airports in the south-east of England.

15.11.12 Options for the mitigation of increased greenhouse gas emissions from aircraft are currently the subject of policy studies at international, European and national levels, with the Airport Operators Association in the UK favouring international emissions trading. Carbon offset schemes have been considered as a voluntary measure by some UK airports, and this might be considered at LAA if it can be shown that greenhouse gas emissions are likely to rise as a result of fleet mix alterations.

15.11.13 Overall, for the majority of impacts, no significant difference in magnitude is expected between those impacts anticipated to arise when compared to the “existing conditions” and those arising compared to the “future assessment conditions” scenario.

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CHAPTER 16

NOISE AND VIBRATION

CHAPTER 16 LAA

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16 NOISE AND VIBRATION

16.1 Introduction

16.1.1 This section of the Environmental Statement considers the implications of noise and vibration effects of the proposed runway extension at London Ashford Airport (Lydd), which would have the potential to generate an impact on the local noise climate both during the construction and operational phases of the development by comparison to the a) the Baseline (Existing Conditions) and b) Baseline Future Assessment Conditions (300,000 passengers) scenarios. The assessment identifies all significant pre- and post-development noise and vibration sources, and to quantify their potential effect on existing and future sensitive receptors.

16.1.2 The scenarios modelled in this chapter are as described in Chapter 1.

16.1.3 A glossary of Acoustics terminology is provided in Appendix 16.1.

16.2 Legislative Drivers

16.2.1 The following legislation and guidelines have been used in this assessment:

• BS4142: 1997 ‘Rating industrial noise affecting mixed residential and industrial areas’; • BS5228: 1997 (Various parts) ‘Noise and vibration control on construction and open sites’; • BS 7445: 1991 'Description and Measurement of Environmental Noise', Parts 1 to 3; • BS8233: 1999 ‘Sound Insulation & Noise Reduction for Buildings’; • Department for Environment, Food and Rural Affairs (DEFRA), 2005 ‘Update of Noise Levels for the Prediction of Noise on Construction and Open Sites’. • Department of the Environment (DoE), 1992, Advisory Leaflet 72; • Department of Transport; Calculation of Road Traffic Noise (CRTN) 1988, • Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 7; Traffic Noise and Vibration; • ISO 9613 ‘Acoustics – Attenuation of sound during propagation outdoors’; • Planning and Policy Guidance (PPG) 24: Planning and Noise; • World Health Organisation Environmental Health Criteria 12: Noise, 1980; and • World Health Organisation Guidelines for community noise, 2000.

16.3 Assessment Methodology

Overall Approach

16.3.1 The quantification and assessment of the potential noise and vibration impacts of the proposed development have been undertaken by a combination of site surveys, desktop studies, literature reviews, consultations and predictions. The main sources of noise and vibration are identified as follows:

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• Construction Operations;

• Airborne Aircraft;

• Ground operations;

• Increased Road Traffic Noise. 16.3.2 The following sections summarise the assessment methodologies and significance criteria adopted for each noise and vibration source identified, drawing from the list of legislative guidance provided above. The following tasks have also been undertaken to inform the assessment:

• The measurement of existing background noise levels surrounding the site;

• A review of published research into the effects of noise on wildlife. 16.3.3 It should be noted that baseline noise monitoring, and subsequent impact assessments, have been undertaken during the week and at weekends to purposefully include quiet times.

Construction Operations

16.3.4 BS 5228 'Noise and vibration control on construction and open sites' gives recommendations for basic methods of noise control relating to construction sites and other open sites where construction activities are carried out. It details the legislative background to noise control, along with the recommended procedures for effective liaison between developers, site operators and local authorities. Methods on how to minimise the impact of site noise on workers and local residents are also provided.

16.3.5 The magnitude and significance of the effect of construction noise depends upon a number of variables, including:

• The noise generated by plant or equipment used on site, generally expressed as sound power levels;

• The periods of time site plant is operational;

• The distance between the noise source and the receptor;

• The level of attenuation likely due to ground absorption, air absorption and barrier effects. 16.3.6 Construction noise limits are specific to each scheme, and are agreed in consultation with the Local Authority. These limits take many factors into account, including the nature of the works, the times and durations of the activities, and the sensitivities of the closest receptors. The limits are expressed as an average level for a period of time (usually averaged over the working day), and thus it is possible that peak levels are in excess of the average levels.

16.3.7 DoE Advisory Leaflet (AL) 72 gives advice as to maximum levels of construction site noise at residential locations during daytime hours. The leaflet states that the noise level outside the nearest occupied room should not exceed 70 dB(A) in rural, suburban and urban areas away from main road traffic and industrial noise. This increases to 75 dB(A) for urban areas near to main roads. Specific construction noise

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limits are site specific, and are agreed on an individual basis with the Local Authority. The 70 dB(A) value is used as the threshold of significance in this assessment.

16.3.8 Some construction activities can also be a source of ground-borne vibration, which can be a cause for concern at the nearest receptors. Typical activities include compaction, breaking and piling. The significance of the effect from any vibration activities is a function of the vibration source and the propagation path to the receptor; the greater the distance away, the lower the impact. In most cases, if the distance between the source and receiver is sufficient to meet noise criteria, the effect of ground-borne vibration will be minimal.

Airborne Aircraft

Daytime (07:00 – 23:00 hrs)

16.3.9 During takeoff, airborne aircraft noise is defined as the noise produced by an aircraft as it commences its takeoff run, until it has reached a point along its flight path that it does not contribute significantly to the noise climate of the surrounding area. During landing, the aircraft is considered airborne until it has completed landing, braking and has decelerated to taxiing speed.

16.3.10 In the UK, the standard measure for long term exposure to aircraft noise is the Equivalent Continuous Sound Level, LAeq, in dB(A). This represents the hypothetical steady sound that contains the same amount of sound energy as the fluctuating noise of aircraft activity over a defined time period.

16.3.11 In September 1990 the Department of Transport adopted the LAeq, 16hr (over the period 0700-2300 hours) to quantify aircraft noise. This replaced the Noise Number Index (or NNI) previously used 1. The Environmental Research and Consultancy Department (ERCD) of the CAA produces annual noise contours on behalf of the Department for Transport (DfT) for Heathrow, Gatwick and Stanstead, establishing the use of LAeq in best practice methodology.

16.3.12 The following LAeq,16hr levels are used:

• 57 dB(A) LAeq,16hr corresponds to the onset of low community annoyance;

• 63 dB(A) LAeq,16hr corresponds to moderate community annoyance; and

• 67 dB(A) LAeq,16hr corresponds to high community annoyance.

16.3.13 The lower limit of 57 dB(A) is in line with the guidance offered by PPG24: Planning and Noise. PPG24 sets out the Government’s policy on noise as it relates to planning in England. It outlines, amongst other issues, the considerations to be taken into account in determining planning applications for activities that will generate noise and advises on the use of conditions to minimise the impact of noise.

16.3.14 PPG24 states that for aircraft noise, daytime levels (07:00-23:00) should be expressed in terms of noise exposure contours in LAeq. Areas of exposed land are categorised into Noise Exposure Categories (NEC's). Under PPG24, categories C and D would not normally achieve planning permission, and therefore any new noise generating development would certainly have to satisfy at least category B, if not category A. The NEC table for daytime aircraft noise is presented in Table 16.1 (below):

1 Planning and Policy Guidance (PPG) 24: Planning and Noise

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Table 16.1: PPG24 – Noise levels corresponding to the daytime noise exposure categories (NEC’s) for new dwellings due to air traffic noise

Noise Exposure Category in LAeq,16hr dB Time of Day A B C D 07:00 – 23:00 < 57 57 – 66 66 – 72 > 72

16.3.15 Although specifically applicable to planning applications for new residential properties in areas impacted by existing noise sources, these NEC noise levels reference the 57dB(A) threshold, which is used as the threshold of significance in this assessment.

16.3.16 Noise contours have been generated using the Integrated Noise Model (INM) Software, version 6.1. The software is based upon a database of typical noise levels for numerous different aircraft. INM calculates and plots contours showing the equivalent continuous noise level (LAeq, 16hr) on the ground due to the movements of airborne aircraft, based on the information contained in the database, and data input to the model including:

• Number and types of aircraft anticipated for use;

• Number of movements of each of those aircraft during a typical day; and

• Anticipated flight paths for take off and landing.

16.3.17 The current and future anticipated fleetmixes and details of aircraft movements at the airport, have been obtained from LAA to inform the modelling process. Details of the aircraft used to generate the noise model are provided in Chapter 4 Project Description. The software allows for the substitution of equivalent aircraft in cases where the specific aircraft proposed for use at the airport is not contained within the software database. It should be noted that the approach and departure flight paths used in the model represent a typical scenario for most aircraft. They are not intended to represent the precise route all aircraft will follow, as this can depend on aircraft type, weight and payload, length of runway used, pilot experience, weather conditions, and other factors. INM accounts for some of this variability using nominal dispersion tracks either side of the selected flight paths. The rate of climb of each aircraft will also differ depending on these factors. INM used typical flight trajectories for each aircraft modelled.

16.3.18 Larger aircraft such as the Boeing 737 and the A319, will utilise an Instrument Landing System (ILS) approach path. This is a guidance system which tracks a steady Northerly descent into Lydd airport. Aircraft using the ILS will fly over the coastal villages of Littlestone-on-Sea, St Mary’s Bay, and Dymchurch. At greater height the ILS approach path lies over West Hythe and Lympne. Aircraft descend at an angle of 3.5 degrees. It is assumed for the purpose of the noise model that the ILS approach path is used by these larger aircraft at all times.

16.3.19 The runway at LAA subtends a 30 degree angle to magnetic North. The runway designation is 03/21; 03 when aircraft take off toward to the North (at a 30 degree angle) and 21 when aircraft take off toward the South (at a 210 angle to magnetic North). The prevailing wind direction is such that runway 21 is active approximately 70% of the time. This is assumed for the purpose of the noise model.

16.3.20 A small percentage of annual movements will be by rotary wing aircraft i.e. helicopters. The INM software is primarily for fixed winged aircraft, although it does allow for user defined data to be input into the model. Helicopters can take off from any point and depart in any direction, leading to difficulties in creating noise contours, because specific flightpaths can not be defined. It is likely that the relatively steep

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departure and landing paths of helicopters would cause any noise contours produced to remain within the airport boundary. Since it is not possible to define helicopter flightpaths to incorporate into the INM Software, noise from helicopters can not be assessed.

16.3.21 It is also appropriate to consider the instantaneous or peak noise level that would impact upon the noise sensitive receptors. Whilst the LAeq,16hour is the accepted noise metric of the CAA, in this case where relatively few aircraft movements are anticipated in one day, it is unlikely to give a representative indication of the noise level that would actually be heard on the ground. Hence consideration is given to the Sound Exposure Level (SEL) of an aircraft flyover event. This is defined as the sound pressure level which, if occurring over a period of one second, would contain the same amount of acoustic energy as the sound event in question. It is useful for events such as aircraft “fly-over’s” or train “pass-by’s” as it gives a closer indication of the magnitude of the instantaneous noise levels experienced during such events. The INM software contains a database of SEL levels for aircraft at different payloads, which is used to inform this assessment.

Night-time (23:00 – 07:00 hrs)

16.3.22 The current proposals do not include any formalised schedule for aircraft movements at night. However, LAA have a licence for 24 hour operations at Lydd airport, and as consideration may be given to some scheduled flights between 06.00 to 07.00 and 23.00 to 00.00, the significance criteria for night-time operations are included.

16.3.23 Research into equivalent night-time annoyance has not established a robust relationship between noise levels and the likelihood of sleep disturbance. However, guidance is available from the sources detailed below.

16.3.24 PPG241 offers equivalent night time levels for aircraft noise, again expressed in terms of noise exposure contours in LAeq. The NEC table for night time aircraft noise is presented in Table 16.2 (below):

Table 16.2: PPG24 – Noise levels corresponding to the night time noise exposure categories (NEC’s) for new dwellings due to air traffic noise

Noise Exposure Category in LAeq,8hr dB Time of Day A B C D 23:00 – 07:00 < 48 48 – 57 57 – 66 > 66

16.3.25 The WHO has produced Environmental Health Criteria 12: Noise, 1980 2, which details the effects of noise on many aspects of health, including annoyance and quality of sleep. It considers that daytime outdoor noise levels below 55 dB LAeq will prevent community annoyance. It also prescribes that a limit of 35 dB LAeq,8hr or less at night (internal) will help preserve the restorative properties of sleep.

16.3.26 A further WHO document, Guidelines for Community Noise (2000)3, provides newer guidelines with marginally lower limits. In this, sleep disturbance will be minimised for an in-bedroom level of less than 30 dB(A) Leq,8h. The attenuation offered by an open window is typically around 15 dB, so this corresponds to an outdoor level of 45 dB(A) when allowing for natural free ventilation to the bedroom.

2 WHO (1980) Environmental Health Criteria 12: Noise 3 WHO (2000), Guidelines for Community Noise

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16.3.27 In addition to these, a large-scale field study of aircraft noise events (ANE’s) and sleep disturbance was carried out for the DfT in 1991 and reported in December 1992 4 . It was broadly found that for outdoor night-time Lmax levels below 80 dB(A), ANEs are unlikely to cause disturbance to sleep. For individual ANE Lmax levels above 80 dB(A) the probability of minor arousal was approximately 1 in 30, and the probability of awakening was approximately 1 in 75.

16.3.28 For a small number of night-time flights, the most stringent criteria to be met is the Lmax levels at the nearest residential properties.

Ground Operations

16.3.29 The increase in passenger numbers and enhancement of fleetmix will lead to changes in ground operations, which has the potential to affect the noise climate in areas in close proximity to the airport. The topography of the surrounding land offers no natural screening as the area is very flat, from airport ground operations and nearby receptor locations.

16.3.30 Ground operations include the following:

• Taxiing aircraft;

• Engine testing, particularly of larger aircraft;

• Aircraft Auxiliary Power Units (APU) - this refers to a small engine or generator used to power an aircraft's primary systems when on the ground, often located at the tail of the larger aircraft such as the Boeing 737 or Airbus 319;

• Ground Power Units (GPU) - this is external to the aircraft, effectively allowing the aircraft to 'plug in' to this power source rather than run its APU; and

• Other ground vehicles. 16.3.31 Noise levels associated with the ground operations of the airport are predicted using the methodology of International Organization for Standardisation (ISO) 9613 "Acoustics – Attenuation of sound during propagation outdoors" to predict the likely noise levels generated by ground operations at the location of the nearest sensitive receptors 5.

16.3.32 The WHO document ‘Guidelines for Community Noise’, provides limit values for community noise in various specific environments. Noise levels below the limits are considered necessary to minimise any temporary or long-term deterioration in physical, psychological or social functioning associated with noise exposure3. PPG 24 quotes the general daytime outdoor noise level provided by this document, stating that outdoor noise levels of less than 55 dB(A) (LAeq) are required to prevent significant community annoyance1.

16.3.33 BS8233 provides assessment criteria and noise limits both inside and outside of buildings. It states a desirable outdoor steady noise limit of does not exceed 50 dB(A) and an upper limit of 55 dB(A). A threshold level significance of 50 dB(A) is used in this assessment, for ground operations6.

4 JB Ollerhead (et al) Report of a field study of aircraft noise and sleep disturbance, Department of Transport, 1992 5 ISO 9613 Acoustics (1993) Attenuation of sound during propagation outdoors 6 BS 8233, (1999) ‘Sound Reduction and Noise Reductions for Buildings’ BSI

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Increased Road Traffic Noise

16.3.34 Noise from increased levels of road traffic as a result of the proposed development has the potential to impact upon existing receptors. The DMRB states that an ‘overnight’ increase in traffic flow of 25% (all other factors staying equal, i.e. speed, etc) would produce an increase in traffic noise of 1 dB or less7. A change in noise levels of less than 1 dB would not be audible and is considered insignificant.

16.3.35 Over a long period, the smallest perceptible change in noise is 3 dB. Hence a change of greater than 3 dB represents a slight or marginal impact.

The Effects of Noise on Schools

16.3.36 A number of published research papers have investigated the possible detrimental effects of aircraft noise on children’s education. Whilst some of these imply that long term exposure to aircraft noise can directly lead to poorer reading and maths performance, others suggest that aircraft noise can indirectly affect school ability by affecting levels of annoyance, perceived stress and attention span 8 and yet others found no significant correlation between noise levels and reading ability after corrections for socioeconomic factors were taken into account 9.A further study of children living in the vicinity of Heathrow, Schipol and Barraja, specifically investigated the effects of noise in relation to impaired reading and “reading age” as well as their mental health. The results indicated that each 5dB increase was linked to children being up to two months behind in their reading age although the effects of long-term exposure to aircraft noise was not investigated 10 and other sources of distraction were not investigated.

16.3.37 Published evidence is inconclusive and the link between increased noise levels and a detrimental effect on learning has yet to be proven. It is nonetheless necessary to adopt a significance criterion against which the impact of any predicted increases in noise at the location of a school building can be assessed. For this purpose, an increase of 5dB in the equivalent continuous sound pressure level (LAeq) is adopted. This is based on the most objective evidence available at present, representing the possible onset of adverse learning effects.

Noise and Wildlife

16.3.38 The noise impact on birds is assessed in Chapter 11, Bird Conservation and Hazard Management.

7 Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 7; Traffic Noise and Vibration, Department of Transport. 8 Chronic aircraft noise exposure, stress responses, mental health and cognitive performance in school children. Professor Stephen Stansfield, Dr M Haines, R F Job, B Berglund, J Head, Department of Psychiatry, Barts and London Hospital, Queen Mary, University of London See letter also in:J Epidemiol Community Health. 2002 Feb;56(2):139-44. 9 Professor Stephen Stansfield, Dr M Haines, R F Job, B Berglund, J Head Multilevel modelling of aircraft noise on performance tests in schools around Heathrow Airport, 2001. 10 Aircraft and road traffic noise and children's cognition and health: a cross-national study. Stansfeld SA, Berglund B, Clark C, Lopez-Barrio I, Fischer P, Ohrstrom E, Haines MM, Head J, Hygge S, van Kamp I, Berry BF; RANCH study team

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16.4 Baseline Environment (Existing Conditions Scenario)

16.4.1 The existing noise climate in the areas surrounding LAA was determined by way of a baseline noise survey. Noise monitoring took place in a number of positions representing typical residential locations that could be impacted by the proposed development. Appendix 16.1 details in full the methodology and findings of the baseline noise assessment.

16.4.2 Two baseline noise surveys were undertaken. During February 2005, unattended monitoring took place in four locations relatively close to the airport, for continuous periods in excess of 48 hours. During March 2005, a series of attended ‘spot measurements’ took place in ten residential locations considered likely to be affected by the proposed development.

16.4.3 LAA experiences a seasonal variation in airport activity. The number of daily aircraft movements was comparatively few during the winter months when the noise monitoring took place.

16.4.4 Table 16.3 states the locations selected for the unattended monitoring and the spot measurements. These locations are shown on Figure 16.1. Positions were chosen to represent centres of population surrounding the airport in all directions. The proposed ILS approach path for larger aircraft was taken into consideration when selecting monitoring positions at increased distance from the airport. Following liaison with Shepway District Council, the locations of existing noise sensitive receptors were also considered.

Table 16.3: Monitoring locations Position Description Unattended Long Term Monitoring M1 Garden of 25 Oakham Drive, Lydd. M2 Homeleigh Farm, Dungeness Road. M3 40 Seaview Road, Greatstone. M4 ‘Owlers’, Church Lane, New Romney. Attended Spot Measurements P1 Robin Hood Lane, Lydd. P2 Homeleigh Farm, Dungeness Road. P3 Pleasance Road South, Lydd-on-Sea. P4 Corner of Williamson Road / Taylor Road. P5 Greatstone Primary School, Baldwin Road. P6 Dunes Road, Greatstone. P7 Coast Road, Littlestone on Sea. P8 Church Road, New Romney. P9 Coast Drive, St Mary's Bay. P10 Mill Road, Dymchurch.

16.4.5 Refer to the technical Appendix 16.1 for details of the monitoring methodology, including measurement periods, weather conditions during monitoring and the full set of measurement results.

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16.4.6 The following summary tables (16.4 and 16.5) show the range of LAeq,1hour and LA90,1hour values obtained at each unattended monitoring location, during the daytime and night-time. Values are rounded to the nearest whole decibel.

Table 16.4: Summary of daytime (0700-2300) levels during unattended monitoring Range of Levels (dB(A))

LAeq,1hour LA90,1hour M1 - Oakham Drive, Lydd 43-55 33-47 M2 - Homeleigh Farm 46-62 39-56 M3 - Seaview Road, Greatstone 38-59 32-43 M4 - Church Lane, New Romney 40-60 34-47

Table 16.5: Summary of night-time (2300-0700) levels during unattended monitoring Range of Levels (dB(A))

LAeq,1hour LA90,1hour M1 - Oakham Drive, Lydd 37-50 30-46 M2 - Homeleigh Farm 45-65 36-59 M3 - Seaview Road, Greatstone 38-48 36-41 M4 - Church Lane, New Romney 30-53 22-45

16.4.7 The lowest recorded background noise levels in Locations M1, M3 and M4 range from 32 to 34 dB(A) during the day. These are typically low values for a largely rural area. Slightly higher background levels were recorded at Location M2, where the lowest background noise level recorded was 39 dB(A). This is due to traffic on the Dungeness Road, and possible noise from the farm itself.

16.4.8 During the night, lowest recorded background noise levels were broadly similar to their respective daytime values in Locations M1, M2 and M3. However, Location M4 recorded a very low background noise level of 22 dB(A) during the night.

16.4.9 Table 16.6 provides a summary of the range of recorded LAeq,T and LA90,T during the daytime and night-time, at each spot measurement location.

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Table 16.6: Summary of the range of recorded LAeq,T and LA90,T during the daytime and night-time, at each spot measurement location

Range of Recorded Range of Recorded Position Daytime Levels Nighttime Levels

LAeq,10mins LA90,10mins LAeq,5mins LA90,5mins P1 52-67 40-48 33-53 31-43 P2 49-72 38-47 33-55 32-42 P3 45-54 40-45 45-49 41-45 P4 44-53 36-43 33-50 32-44 P5 44-51 38-45 35-56 32-46 P6 40-59 38-44 38-48 34-47 P7 49-59 43-54 43-57 41-56 P8 41-55 35-46 36-50 34-42 P9 49-53 47-50 46-49 42-45 P10 47-57 41-47 40-50 37-48

16.4.10 In order to provide a worst case assessment of potential noise impacts, the lowest recorded background noise levels have been used to inform the assessments that follow. In Lydd, Homeleigh Farm, Greatstone and New Romney (where both unattended and attended measurements took place) the lowest daytime background noise levels were obtained from the unattended monitoring, so these values have been used.

16.4.11 During the attended monitoring sessions, light aircraft were observed landing from Location P5 (Greatstone Primary School), but did not contribute considerably to the recorded level, and the noise from the aircraft was subjectively considered surprisingly inaudible. Of all monitoring positions, Location P6 (Dunes Road) was influenced the most by existing air traffic, as it is situated at the northern end of the runway, under the flight path of incoming aircraft. Up to four aircraft were observed to fly over Dunes Road during three of the ten-minute monitoring periods. Each aircraft was clearly audible for approximately 10 seconds. In Location P8 (Church Road, New Romney), aircraft were visible, but only just audible, during two of the ten-minute monitoring periods.

16.4.12 In addition, an INM computer noise model was created to show the impact of current airport activity using the flight paths and runway usage detailed in Chapter 4. The majority of current usage is from business and general aviation flights and the aircraft currently in use are small and do not lead to significant noise contours (see Figure 16.2).

16.4.13 The figure indicates that the significant noise contours remain close to the runway and do not significantly influence the existing noise climate, with only the 45dB(A) contour extending over any residential receptors. This concurs with the subjective impression and measured baseline noise levels; that existing airport activity does not contribute significantly to the baseline noise climate.

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16.5 Baseline Environment (Future Assessment Conditions Scenario)

Airborne Aircraft: Daytime

16.5.2 Information regarding the anticipated fleetmix and number of movements per day has been obtained directly from LAA and input into the INM modelling software. The flightpaths used have been assumed for the purposes of creating the noise model and are representative of the typical flightpaths that may be used. They are not intended to define the flightpaths that will be used by aircraft under this scenario, as these will vary depending on the aircraft, pilot, weather, payload and other factors.

16.5.3 All the proposed aircraft in the fleetmix for this scenario are of the type already using the airport on a regular basis. There are no additional larger aircraft (such as the Boeing 737) proposed for this scenario. As such the ILS approach system and associated flight path is not in use for this scenario.

16.5.4 Figure 16.3 shows the noise contours produced by the computer model for this scenario. Each contour links areas on the ground likely to experience the same noise level, due to the airborne plane activity, in increments of 3dB. Although it is standard practice to only show the 57dB(A), 63dB(A) and 67dB(A) contours (which correspond to low, medium and high community annoyance respectively), it is considered appropriate in this case to show noise contours down to 45dB(A). This gives an indication of the areas in which the existing background noise levels are likely to be affected by the proposed aircraft activity.

16.5.5 The figure shows that the 57dB(A) contour line does not extend over any noise sensitive receptors. This indicates that the noise levels are well below the onset of community annoyance at these locations.

16.5.6 The 51dB(A) contour line lies over Homeleigh Farm to the south and the majority of houses on Dunes Road. These receptors are directly in line with the airport runway, and would experience increased noise levels due to the number of aircraft using the runway. It is likely that all aircraft will fly over these properties regardless of origin or final destination.

16.5.7 The 45dB(A) contour gives as indication of those areas which may experience marginally elevated noise levels noise levels due to the operation of the airport under this scenario. Although there are no larger aircraft, the volume of smaller aircraft required to carry 300,000 passengers per annum leads to a considerable spread of the 45dB contour line. This contour line extends as far as Lydd-on-Sea (to the Southeast) and Dunes Road, Littlestone and St Mary’s Bay (to the North).

16.5.8 Greatstone Primary school lies on the 45dB(A) contour. This indicates a marginal increase in noise levels is likely at this location; however this will not lead to significant changes in continuous noise levels over the adopted significance criterion.

16.5.9 The actual spread of noise contours is dependant on flight path. As previously noted, the noise model is based on assumed flight paths which are subject to variation due to numerous factors. With the smaller aircraft proposed for this scenario, this variation is more likely as they are unlikely to be using the ILS approach system, and are more able to undertake tighter turns and manoeuvres. These modelled contours therefore represent the full spread of likely noise contours.

16.5.10 As there will not be any new aircraft introduced to the fleetmix, the subjective character of the noise produced will not change significantly. Moreover, the aircraft are unlikely to lead to instantaneous or peak noise levels in excess of those already

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experienced. There will however be a significant increase in the number of daily movements of smaller aircraft, without the runway extension.

Ground Operations

16.5.11 There will be no new aircraft introduced into the fleetmix for this scenario, but there will be an increase in the number of movements of smaller aircraft. As such the ground operations associated with this scenario will not include the introduction of larger aircraft carrying APU’s or requiring GPU’s. Hence the sources of ground noise are limited to smaller aircraft taxiing to and from the runway, and other vehicular movements.

16.5.12 Noise sensitive receptors likely to be affected by increased ground movements are those in close proximity to the runway and stand apron. Due to the distances involved (approximately 1000m in the worst case) it is not considered likely that this change in ground movements on the airfield will lead to significant increases in noise level at the location of the nearest sensitive receptors. Only the particularly noisy sources (such as the engines of larger aircraft like the Boeing 737) would cause an appreciable increase in noise levels at these distances.

Increased Road Traffic Noise

16.5.13 Traffic noise will change as traffic levels vary over time, which has the potential to impact existing receptors. The expected increases in traffic flow figures due to predicted airport traffic are compared to existing traffic flows. The significance of the noise from development traffic is assessed with reference to DMRB, which states that an ‘overnight’ increase in traffic flow of 25% (all other factors staying equal, i.e. speed, etc) would produce an increase in traffic noise of 1 dB or less. A change of less than 1 dB is considered to have a negligible impact. Over a long period, the smallest perceptible change in noise is 3 dB. Where an increase in traffic flow of less than 25% has been predicted, quantitative modelling is identified as being unnecessary as an increased impact from vehicle noise is extremely unlikely.

16.5.14 Table 16.7 shows the baseline traffic flows, and the predicted traffic increase due to the future assessment conditions scenario. The increase in traffic flow due to the proposed development is shown as a percentage of the baseline flow figure. Traffic flow figures are shown as AADT figures during daytime hours (defined by DMRB for noise purposes as the 18 hour period from 0600 hours to midnight). Refer to Chapter 14 Traffic and Transport for information regarding the traffic flow data, and the locations of the AADT Traffic counters.

Table 16.7: Existing and predicted traffic flows for the future assessment conditions scenario 7 day 18hr AADT 5 day 18hr AADT Additional Additional Operational Increase Operational Increase 2005 Traffic Total (%) 2005 Traffic Total (%) Site 1 8411 613 9024 7.3 8764 651 9415 7.4 Site 3 6061 144 6206 2.4 6316 153 6469 2.4 Site 5 7166 686 7851 9.6 7467 727 8194 9.7 Site 6 11036 72 11109 0.7 11500 77 11577 0.7 Site 7 11219 72 11291 0.6 11691 77 11767 0.7 Site 8 3141 36 3177 1.2 3393 38 3431 1.1 Site 9 11864 469 12333 4.0 12363 498 12860 4.0

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16.5.15 Increases in traffic flow due to the future assessment conditions scenario is not expected to increase by more than 25% at any of the AADT traffic count locations on public roads. According to DMRB quantitative modelling of this increase is not necessary, as an increased impact from vehicle noise (and therefore vibration) is unlikely.

16.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

16.6.1 Extension of the runway has the potential to lead to noise generated by items of plant machinery such as excavators, loaders, and HGVs. It is understood the runway extension will take around 4 months to complete, starting early in 2007.

16.6.2 Construction activity inevitably leads to temporary noise generation at locations in close proximity to the construction activities. However, due to the typical distances between the proposed site and the nearest receptors, the impact of construction activity on residents will be reduced.

16.6.3 Construction noise predictions can be made based on the methodology outlined in BS 5228: 1997 'Noise and vibration control on construction and open sites' 11 in conjunction with general information regarding proposed activities. In 2005, the Department for Environment, Food and Rural Affairs (DEFRA) published an Update of Noise Levels for the Prediction of Noise on Construction and Open Sites 12.. This has been used to supplement the database contained in BS 5228.

16.6.4 The nearest sensitive receptor to the construction site is Greatstone Primary School, at a distance of 500m. Table 16.8 shows the noise levels associated with typical construction activities, and predicts the likely noise contribution from each item at a distance of 500m. The estimated sound pressure levels shown are reasonable estimates based on propagation attenuation only and do not account for any screening or directivity effects.

Table 16.8: Example sound pressure levels of likely construction activities. Typical A-weighted Estimated Sound CONSTRUCTION ACTIVITY/ Sound Pressure Pressure Level at ASSOCIATED PLANT Level at 10m (dB(A)) 500m (dB(A)) Site Preparation Dozer 75 41 Tracked Excavator 78 44 Wheeled Backhoe Loader 68 34 Excavation Dozer 81 47 Tracked Excavator 79 45 Loading Lorry 80 46 Articulated Dump Truck 81 47 Rolling and Compaction Roller 79 45 Vibratory Plate 80 46

11 BS 5228: 1997 (Various parts) ‘Noise and vibration control on construction and open sites’, BSI 12 Update of Noise Levels for the Prediction of Noise on Construction and Open Sites, Department for Environment, Food and Rural Affairs (DEFRA), 2005.

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TOTAL 89 55

16.6.5 Construction site noise limits are agreed on a site-by-site basis between the appointed contractor and the Local Authority. However, the 70 dB(A) value suggested by AL72 13can be used to assess the likelihood of a noise impact based on the above predictions. The “Total” figure shown in Table 15.8.1 assumes that all plant will be operating simultaneously, and hence provides a worst case noise level. Considering the temporary and changing nature of the construction works and the large distances between the construction activities and Noise sensitive receptor locations (approximately 1km), it is likely that construction noise levels will be less than 55dB(A) at a distance of 500m, and therefore less at the noise sensitive receptor locations. Hence the impact of construction noise is not predicted to be significant.

16.6.6 Nonetheless, appropriate working practices would be adopted to minimise noise levels where practicable. Suggested noise mitigation measures for construction are described in the mitigation section.

16.6.7 Some construction activities can be a source of ground-borne vibration, which can be a cause for concern at the nearest receptors. Typical activities that would lead to vibration effects include compaction and breaking.

16.6.8 The impact at the nearest properties from any vibration activities is a function of the vibration source and the propagation path to the receptor; larger distances reduce the impact. Due to the large distances involved, construction vibration will not be discernible at the receptor locations. The impact of construction vibration will therefore be negligible.

16.6.9 It is envisaged that the haul route for the terminal development will be similar to the apron construction in 2005. Bulky construction materials were delivered to Ashford by rail and then transported to site by road. To deliver materials to site, HGVs will use the A2070 from the M20, and then follow the A259 and the B2075 to the airport access road. An increase in HGV activity or overall traffic flow of 25% will lead to a 1dB change in noise level, which is the smallest detectable change in noise level. Any increase below 25% will lead to an insignificant change in noise levels. It is assumed that the proposed construction traffic movements will not lead to an increase of traffic flow or HGV percentage in excess of 25% and hence will not lead to a significant impact.

16.6.10 All material will be stockpiled in order to minimise HGV movements. The proposed stockpiling will be located in the vicinity of the main apron to the north of the existing terminal. During construction, HGVs will access the works via fenced off roadway placed around the edge of the apron.

”Future Assessment Conditions Scenario

16.6.11 Construction impacts under this scenario are expected to be as for the Existing Conditions Scenario outlined above.

13 Department of Environment Advisory Leaflet (AL) 7

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16.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

Airborne Aircraft: Daytime (07:00 – 23:00hrs)

16.7.2 Information regarding the anticipated fleetmix and number of movements per day has been obtained directly from LAA, and input into the INM modelling software. The flightpaths used have been assumed for the purposes of creating the noise model, and are representative of the typical flight paths that may be used. They are not intended to define the flight paths that will be used by aircraft under this scenario, as these will vary depending on the aircraft, pilot, weather, payload, and other factors.

16.7.3 The fleetmix for this scenario contains additional larger aircraft; the Boeing 737 and the A319, totalling 4 movements per day. As such the ILS approach system and associated flight path is assumed for all large aircraft approaches. As a result of the prevailing wind direction at the airport, it is assumed that larger aircraft will take off towards the south 70% of the time, banking right over Lydd village.

16.7.4 Figure 16.4 shows the noise contours produced by the computer model for this scenario. Contours are shown in 3 dB increments down to 45dB(A), to give an indication of the areas in which the existing background noise levels are likely to be affected by the proposed aircraft activity.

16.7.5 The figure shows that the 57dB(A) contour line does not extend to any noise sensitive receptors. This indicates that the noise levels as a result of the scheme are well below the onset of community annoyance at these locations.

16.7.6 The 53dB(A) contour line, at its Northern extent, reaches the centre of Dunes Road. The 51dB(A) contour line extends to the South to Homeleigh Farm on Dungeness Road, and extends as far as Littlestone at its Northern end. Due to the path of the ILS approach, the 48dB(A) and 45dB(A) contour extends as far as St Mary’s Bay to the North.

16.7.7 The 45dB(A) contour line extends to Lydd village, due to the flight path of larger aircraft which take off in a Southerly direction and bank right. It also extends to Lydd on Sea due to the continued influence of the smaller aircraft, which are able to bank right after takeoff to avoid the Dungeness power station exclusion zone. This indicates that residents in these locations will experience marginally elevated noise levels.

16.7.8 Greatstone Primary school lies on the 45dB(A) contour. This indicates a marginal increase in noise levels is likely at this location; however this will not lead to significant changes in continuous noise levels over the adopted significance criterion.

16.7.9 Although the computer noise model indicates that there are no receptors within the 57dB(A) contour, this does not give a representative indication of the number of properties that would experience elevated noise levels and therefore experience an impact as a result of the proposed scheme. Due to the low number of large aircraft movements, the levels reduce considerably when corrected to a 16-hour average. It is therefore important to consider the instantaneous or peak noise levels, which will increase considerably.

16.7.10 The INM software contains a database of noise levels (expressed as SEL’s) for different aircraft at different payloads. It is possible to interrogate this database to provide an indication of the range of SEL’s that are expected at LAA.

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16.7.11 Table 16.9 shows the range of SEL’s at various altitudes for a Boeing 737-800 series. The overall weight of an aircraft directly affects the noise level it produces, particularly at takeoff, as more thrust is required to provide equivalent lift. Hence a heavier aircraft is generally noisier.

Table 16.9: Typical range of SEL’s for a Boeing 737-800 at various altitudes Altitude (ft) Typical Range of SEL’s (dB) 200 99 - 110 1000 88 - 104 2000 82 - 97 5000 75 - 92 10000 65 - 82

16.7.12 Larger aircraft which take off towards the South will turn right over Lydd village soon after becoming airborne, in order to avoid the military Danger Zone. Although the rate of climb depends on a number of factors and is not easy to predict, an aircraft passing over Lydd village will reach an approximate height of 1000 feet. It is evident from table 16.9 that the SEL of this event is likely to be between 88 and 104 dB(A).

16.7.13 It should be noted that the SEL represents a theoretical sound event, one second in duration, which contains the same amount of sound energy as a typical airplane fly- over. The actual maximum noise level at a given position will be less than the SEL value stated. There is inherent variation in the time it takes for an aircraft to fly over a given position, hence the use of the SEL to normalise different events for comparison. However for the purpose of providing indicative sound pressure levels, it is possible to assume the duration of a pass by and calculate the equivalent continuous sound pressure level for that period, to compare with existing background noise levels.

16.7.14 For an event of duration 20 seconds, the equivalent continuous sound pressure level at Lydd Village will be between 75 and 91 dB(A), for a departing aircraft.

16.7.15 Aircraft coming in to land (using the ILS approach) are likely to have less fuel on board and therefore be lighter. The SEL of a landing aircraft will be closer to the low end of the range of SEL’s given above. Using the assumed 3.5 degree angle of approach it is possible to infer the approximate height of an incoming aircraft over those monitoring positions used in the baseline noise assessment, which lie directly beneath the ILS approach. The pass-by duration of 20 seconds can again be assumed for the purpose of providing an indication of likely noise levels.

16.7.16 Table 16.10 gives the expected height of an aircraft using the ILS approach at various locations. The likely SEL is stated and corrected to a 20-second duration. This is then compared to the lowest recorded background noise levels in each location.

Table 16.10: Likely SEL of Boeing 737-800 using ILS approach Lowest Distance Height of Likely LAeq,20secs recorded Location to Airport Aircraft SEL of stated daytime (m) (ft) (dB(A)) SEL background level (dB(A)) Dunes Road 1250 225 98 85 38 Littlestone 3000 670 90 77 43

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St Mary’s Bay 6000 1350 86 73 47 Dymchurch 7500 1680 83 70 41

16.7.17 Inspection of the SEL values gives a clearer indication of the likely noise levels of the larger aircraft. Existing background levels are low in all areas surrounding the airport, and beneath the ILS approach path. Whilst the likely instantaneous noise levels are comparatively very high, these events will occur infrequently during a typical day.

16.7.18 When assessed against the recognised government criteria, the proposed runway extension will have no impact, because no properties lie within the 57dB(A) contour line. However, it should be recognised that the addition of large aircraft to the airport fleetmix, will lead to comparatively high noise levels for short periods of time.

Airborne Aircraft: Night-time (23:00 – 07:00hrs)

16.7.19 The LAA currently has a license to operate 24 hours a day and night-time movements have been assessed.

16.7.20 To provide an indication of the number of flight movements, during the night time period, that would cause the equivalent continuous sound pressure level to exceed the stated 48dB(A) criterion, a noise contour has been produced showing the worst case acceptable scenario, (see Figure 16.5) The contour shown is for 2 A319 aircraft arrivals from the North, and one A319 departure to the South. The following combinations of aircraft would also not exceed the 48dB(A) contour noise level at residential properties:

• South: One A319 either approaching or departing.

• North: Two A319 Approaching, OR, 1 A319 Departing, OR, 1 Boeing 737 either approaching or departing.

16.7.21 Significance criteria indicate that Lmax levels below 80 dB(A) are desirable to prevent sleep disturbance. The maximum level of an aircraft fly-over event can be comparable in magnitude to the stated SEL values. Hence a large aircraft movement during the hours of 23:00 – 07:00 has the potential to impact the identified residential receptors and cause sleep disturbance.

16.7.22 The baseline noise assessment shows that noise levels during the night hours are typically lower than during the day, in all monitoring locations. It is reasonable to assume that movements during the night hours will be minimal. For a small number of night-time flights, the most stringent criteria to be met is the Lmax levels at the nearest residential properties.

16.7.23 The investigation into aircraft SEL’s (presented above) indicates the instantaneous or peak noise levels are likely to exceed the 80 dB(A) maximum level significance criteria. This has the potential to cause sleep disturbance.

Ground Operations

16.7.24 The ground operations of the proposed larger aircraft, namely the Boeing 737 and A319, will give rise to the greatest instantaneous noise levels as aircraft are

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manoeuvred into parking positions. Such aircraft also introduce APU’s or GPU’s, which represent a continuous noise source at a much lower level.

16.7.25 These operations will not take place outside of the existing hardstanding areas (close to the terminal building), taxiways and runway. The closest residential receptors to these areas are farms on the outskirts of Lydd village (to the West) and the coastal community of Lydd-on-Sea and Greatstone-on-Sea (to the East). The typical distance between these receptors and the hardstand areas is 1000m. It is reasonable to assume that the movement of these larger aircraft will represent the dominant source of ground noise over such distances.

16.7.26 Whilst it was not possible to measure the noise levels from large aircraft directly, the typical sound pressure level of a large aircraft during taxi manoeuvres has been obtained from other published sources 14. At a distance of 50m, a HS125:800 twin engine jet aircraft generates a sound pressure level of 72 to 80 dB(A) depending on aircraft orientation. This equates to an equivalent level of 54dB at 1000m, not accounting for the effects of any screening or absorptive effects. Ground movement will occur for relatively short periods of time, as the aircraft moves between the runway and hardstanding area. Hence this does not represent a continuous noise source. The equivalent continuous sound pressure level of this source will be lower than 55dB over period of time greater than a few minutes.

16.7.27 This noise source does not lead to noise levels in excess of the WHO general daytime outdoor noise level criterion (as referenced in PPG24) 1, or the BS8233 outdoor steady noise limit 6. As such, the noise due to these operations is unlikely to be significant during the day.

16.7.28 Whilst there are no existing scheduled night flight movements at present, night-time movements could occur as part of the proposed development. Further, ground movement and engine testing may be required before 0700 or after 2300 hours for flights scheduled to fly during the day. During the night, WHO guidelines suggest that an external noise level of 45 dB(A) is required to prevent sleep disturbance 3. This refers to an equivalent continuous noise level averaged over the entire night-time period (2300 to 0700 hours). It is unlikely, due to the relatively short duration of ground movements, that this level will be exceeded when averaged over the whole eight hour period. However, instantaneous sound pressure levels at the nearest Noise Sensitive Receptors will exceed existing background noise levels, and therefore lead to increased noise levels albeit for short periods of time.

Increased Road Traffic Noise

16.7.29 As noted for the previous scenario, traffic noise will change as traffic levels vary over time, which has the potential to impact existing receptors. Again, the expected increases in traffic flow figures due to the increase in passenger movements are compared to baseline traffic flows, to provide an indication of the increase in traffic flow figures. The significance of the noise from development traffic is assessed with reference to DMRB [4], which states that an ‘overnight’ increase in traffic flow of 25% (all other factors staying equal, i.e. speed, etc) would produce an increase in traffic noise of 1 dB or less. A change of less than 1 dB is considered to have a negligible impact. Over a long period, the smallest perceptible change in noise is 3 dB. Where an increase in traffic flow of less than 25% has been predicted, quantitative modelling is identified as being unnecessary as an increased impact from vehicle noise is extremely unlikely.

14 Sharps Redmore Partnership (1999) Farnborough Aerodrome Environmental Statement, Technical Appendix IV: Noise.

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16.7.30 Table 16.11 shows the baseline predicted traffic flows and the predicted traffic increase for this scenario. The increase in traffic flow due to the airport operational traffic is shown as a percentage of the baseline flow figure. Traffic flow figures are shown as Annual AADT figures during daytime hours (defined by DMRB for noise purposes as the 18 hour period from 0600 hours to midnight) 7. Refer to Chapter 14 for information regarding the traffic flow data and the locations of the AADT Traffic counters. Table 16.11: Existing and predicted traffic flows, with runway extension 7 day 18hr AADT 5 day 18hr AADT Additional Additional Operational Increase Operational Increase 2005 Traffic Total (%) 2005 Traffic Total (%) Site 1 8411 606 9017 7.2 8764 622 9386 7.1 Site 3 6061 143 6204 2.4 6316 146 6462 2.3 Site 5 7166 677 7843 9.4 7467 695 8162 9.3 Site 6 11036 71 11107 0.611500 73 11573 0.6 Site 7 11219 71 11290 0.611691 73 11764 0.6 Site 8 3141 36 3177 1.1 3393 37 3430 1.1 Site 9 11864 463 12327 3.9 12363 476 12839 3.9

16.7.31 Once again, the calculated increases in traffic flow due to the development is not expected to increase by more than 25% at any of the AADT traffic count locations on public roads. According to DMRB, an increased impact from vehicle noise (and therefore vibration) is unlikely.

16.7.32 Whilst an average traffic impact is unlikely, it is important to consider the nature of the noise, which will be time variable rather than continuous. It is reasonable to assume that traffic movements away from the airport will lead to larger numbers of traffic movements in a relatively short time period, although traffic arriving may be more spread. In this scenario, the increased number of larger aircraft movements increases the frequency of occurrence of these events. This has the potential to lead to increased noise level and a change in the character of the noise climate, for short periods of time.

Future Assessment Conditions Scenario

16.7.33 Despite the change in the proposed fleetmix that could arise as a result of the project, no significant differences in noise climate are expected to arise as a result of the proposed project when compared to the future assessment conditions (as described in Section 16.5).

16.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

16.8.1 In order to minimise potential construction impacts, all construction activities will be carried out in accordance with the recommendations of BS 5228. In addition, the following mitigation measures will be implemented through the Construction Environmental Management Plan (CEMP):

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• Working hours will be agreed with the Local Authority and are specific to the construction site;

• The Contractor and Local Authority should be particularly aware that one of the nearest sensitive receptor to the proposed activity is a primary school and agree appropriate but practicable working noise limits;

• Specific method statements and risk assessments would be required for night working. In order to minimise the likelihood of noise complaints in such eventualities, the contractor would inform and agree the works in advance with the Environmental Health Officer, informing affected residents of the works to be carried out outside normal hours. Furthermore, the residents would be provided with a point of contact for any queries or complaints;

• All vehicles and mechanical plant used for construction will be fitted with effective exhaust silencers, and regularly maintained;

• Inherently quiet plant will be used where appropriate. All major compressors will be sound-reduced models fitted with properly lined and sealed acoustic covers which will be kept closed whenever the machines are in use and all ancillary pneumatic percussive tools will be fitted with mufflers or silencers of the type recommended by the manufacturers; and

• All ancillary plant such as generators, compressors and pumps will be positioned so as to cause minimum noise disturbance. If necessary, temporary acoustic barriers or enclosures will be provided.

Future Assessment Conditions Scenario

16.8.2 Proposed mitigation for construction impacts under this scenario is as described under the “existing conditions scenario” above.

16.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

16.9.1 LAA will implement the International Civil Aviation Organisation (ICAO) detailed guidelines for a ‘balanced approach’ to managing aircraft noise. The concept was introduced when the 33rd ICAO Assembly adopted Resolution A33/7, which included international guidance for the introduction of operating restrictions on an airport-by- airport basis. The Balanced Approach has since been incorporated into European Community Legislation as Directive EC/2002/30. Further details of the ‘balanced approach’ are provided in Appendix 16.2.

16.9.2 LAA will develop a Noise Management Plan to comply with the balanced approach requirement. This will need to balance the needs of the airport with the concerns of the local affected residents. The following mitigation measures are proposed at LAA, which incorporate some of the principles of the Balanced Approach:

• Using noise-abatement operating procedures: the airport operators will introduce a penalty system to fine pilots using excessive thrust when departing or arriving at LAA. The money from these fines will go into a community fund to benefit the local area;

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• Permanent noise monitoring: LAA will provide permanent external noise monitoring stations, in order to quantify and monitor noise levels close to the nearest affected sensitive receptors due to the airport operations. Appropriate monitoring positions will not be unduly influenced by other noise sources and will be agreed in consultation with the Local Authority;

• Land-use planning and management policies: this covers a wide range of options regarding the appropriate location for ground operations to take place, ensuring that nearby sensitive receptors are not subject to unnecessary amount of noise due to taxiing aircraft, engine testing, and other sources of ground noise. It is common practice in UK airports to define Noise Abatement Zones in which there are restrictions on ground activity. However, at LAA, there is a significant area of land between the hardstanding areas and the nearest sensitive receptors; and

• Communication: The airport will establish clear lines of communication with local residents, such that concerns regarding noise from airport operations can be addressed, in the first instance, directly to the airport.

Future Assessment Scenario

16.9.3 Proposed mitigation for operational impacts under this scenario is as described under the “existing conditions scenario” above

16.10 Residual Effects

Existing Conditions

16.10.1 With the implementation of the mitigation measures detailed above, the construction and operation of the proposed runway extension is expected to have no more than a minor adverse impact. Increases in airborne noise levels do not exceed the recognised CAA criterion for the Onset of Community Annoyance. However, movements during the nicght-time are likely to lead to some sleep disturbance in some individuals, which would be considered a moderate/major adverse impact.

Future Assessment Conditions

16.10.2 Residual impacts are expected to be as described above for the ‘existing conditions scenario’.

16.11 Summary

16.11.1 The potential noise and vibration effects of the proposed runway extension, in both construction and operational phases have been assessed. It considers two scenarios; expansion to 300,000 passengers per annum without and with the runway extension.

16.11.2 Construction activities have the potential to increase noise levels at the location of nearby sensitive receptors, however due to the temporary nature of this noise source, the potential impact is not significant. Furthermore there will be no vibration impact. The appointed contractor will follow the guidance of BS5228 to minimise construction noise impacts.

16.11.3 The future assessment conditions scenario of the proposed expansion to 300,000 passengers per annum without the runway extension, will lead to increases in noise

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level, but not above the Onset of Community Annoyance. There will be no large aircraft movements, but the frequency of small aircraft movements will increase.

16.11.4 Whilst the existing runway will allow aircraft such as the Boeing 737 with limited take of weight to use the airport, the proposed extension will allow 737s to take off with maximum weight. However, the number of proposed movements per day is small. This will lead to instantaneous or peak noise levels in excess of those already experienced, though for short periods of time.

16.11.5 Any large passenger aircraft movements occurring during the night have the potential to cause sleep disturbance due to the high maximum noise levels likely.

16.11.6 For both scenarios, the movement of aircraft on the ground has the potential to cause additional noise at receptor locations closest to the airport, as aircraft taxi into position after landing. However, due to the relatively large distances involved and the non- continuous nature of this noise source, this is not likely to lead to equivalent continuous noise levels in excess of WHO significance criteria.

16.11.7 For both scenarios, the predicted increase in road traffic will not cause noise or vibration levels to increase significantly, when averaged over the daytime hours. Traffic noise may increase for short periods of time as vehicles are likely to depart and arrive at the airport in groups, rather than a continuous flow.

16.11.8 LAA will develop a Noise Management Plan to comply with the balanced approach requirement. This will need to balance the needs of the airport with the concerns of the local affected residents. Proposed mitigation measures include the introduction of fines for pilots using excessive thrust, effective land use planning and management policies, and establishment of clear lines of communication with local residents. 16.11.9 No significant noise impacts are expected to arise from the proposed project when compared to the Future Assessment Conditions scenario.

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17 SOCIO-ECONOMIC ISSUES

17.1 Introduction

17.1.1 This chapter sets out the socio-economic context for the proposed development at London Ashford Airport (LAA), and assesses the impact that the three potential scenarios may have, both in the locality and more widely across the South East, by comparison to a) the Baseline (Existing Conditions) and b) Future Assessment Condition (300,000 passengers) scenarios, as described in Chapter 1. The Predicted Impacts assess the source, scope and extent of impacts arising from both the construction and operation of the proposed development.

17.1.2 Impacts have been assessed in terms of the effects on the local and regional population, employment and economy and tourism against both Baseline and Future Assessment Condition scenarios. Impacts on local communities arising from changes to noise, vibration, air quality, landscape, water quality and similar issues are dealt with in other chapters of this ES.

17.1.3 A series of public consultations have been undertaken to obtain further information on both baseline conditions and perceived impacts of concern, as well as to provide information to interested parties on the development proposals and their potential social and environmental impacts. The work undertaken for this consultation (which is ongoing) is described in Appendix 1.5 of this ES.

17.1.4 Whilst there is no specific legislation solely concerned with managing socio-economic impacts of a project of this nature, there are a number of key policies and guidance notes which are considered relevant. These policies are described in Chapter 5 Planning Policy Framework.

17.2 Assessment Methodology

17.2.1 A socio-economic baseline of the area has been established by means of a desk study and review of the public consultation data. The following stakeholders have been consulted and data sources used when compiling the baseline information:

• Annual Business Inquiry (1998-2000);

• Annual Employment Survey (1995-1997);

• Census 2001;

• East Sussex County Council;

• Hastings District Council;

• Kent County Council (Land Use and Transport Policy Unit, Strategic Planning Resources Division, Strategic Planning Analysis and Information Team);

• London Ashford Airport;

• National On-line Manpower Information System (NOMIS);

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• Office of National Statistics;

• Oxford Economic Forecasting (OEF);

• Rother District Council;

• Shepway District Council;

• South East England Development Agency (SEEDA);

• South East England Regional Assembly (SEERA);

• South East England Tourist Board (SEETB); and

• Tourism South East. 17.2.2 The subsequent analysis has paid particular reference to the following key indicators and themes:

1. Population and Profile: considering indicators relating to age, ethnicity and standard occupational group of the local population;

2. Employment and Economy: considering the local business structure and wider economic issues such as Gross Domestic Product (GDP), investment and economic forecasts; and

3. Tourism: considering tourism employment, domestic and foreign spending and tourism forecasts.

17.2.3 The initial baseline review has enabled the subsequent impact evaluation to be undertaken within the relevant social and economic context. Particular emphasis has been placed on the three elements described above, for each of which the following impacts have been considered:

• Direct impacts, including economic components such as construction employment created by the proposed development, and permanent direct employment generated. Social components include health and community needs;

• Indirect impacts, including economic components such as expenditure, employment and income resulting from multiplier effects, and social components such as the provision of enhanced transportation infrastructure and improvements to enhance the overall quality of life for local communities; and

• Induced impacts, arising for instance when direct employment at the airport contributes to induced employment through workers income and local expenditure.

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Employment

Construction Employment

17.2.4 Studies on similar developments in the UK, such as the Bristol Airport Economic Impact Study1 (2005) and the English Partnerships Best Practice research, advise that one construction job year is created per £52,000 of capital investment in a scheme (at 2001 costs), or about £53,500 in 2006 prices2. Construction employee years can be converted to permanent Full Time Equivalent (FTE) jobs using the standard ratio of ten years of construction employment per one full time equivalent job, an estimate derived from experience of regeneration works elsewhere in the UK.

Direct Employment

17.2.5 A commonly used ‘rule of thumb’ to estimate direct employee numbers at airports is 1,000 employees per million passengers. However, individual airports differ widely in numbers directly employed as a result of the size of airport, extent and diversity of services, type of operators attracted, and the physical capacity of each airport to accommodate jobs, and a number of studies have reached different conclusions concerning the effects of economies of scale and the volumes of schedules, charter and freight flights.

17.2.6 A recent Airport Council International (ACI)3 paper by York Aviation provides a set of criteria that are suitable to benchmark airports in terms of employment analysis, and classifies airports based on employment densities (on-site direct employees) as low, medium, high and very high. The criteria are outlined in Table 17.1 below.

1 BIA & SWRDA (2005) Bristol International Airport Economic Impact Study, Roger Tym & Partners 2 Using inflation rates from the Office of National Statistics 3 The Social and Economic Impact of Airports in Europe, 2004, York Aviation

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Table 17.1 Criteria for classification of airport density, adapted from ACI report Directly employed per Passenger Freight million passenger Criteria throughput density throughput Domestic traffic Charter traffic Low Low/medium 350-600 Low High utilisation density Non airlines based Limited development International traffic Scheduled traffic Medium/high Medium + No frills airlines 600-900 Low density international traffic Some airlines based Significant development International hub International traffic High Scheduled traffic High 900-1200 High density Major airline based Substantial development Inefficient/overmanned. often accommodate Very Low 1200+ Low airline headquarters high and maintenance facilities

17.2.7 For the purposes of this assessment, LAA would be classified as a ‘Low-Medium’ density airport, due to:

• economies of scale (there are higher employment ratios at small airports due to the fixed nature of some staffing);

• the likelihood of international and scheduled traffic associated with the proposed developments;

• the significance of the development associated with a runway extension; and

• comparison with other airports (e.g. Bristol, Stansted, Luton). 17.2.8 Using the ACI criteria, as a medium density airport, the number directly employed at LAA is estimated as 600 per million passenger throughput, and this figure will be used as a basis for this assessment. The Bristol Airport Economic Impact Study (2005) used the same criteria, as that airport employs 584 persons per million passengers.

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Indirect Employment

17.2.9 The multiplier effect is used to consider the additional employment effects that a development will have in addition to its direct impact. In order to calculate any indirect employment that may result from the proposed development, a multiplier was obtained from a regional average documented in Halcrow (2002)4, and applied to the number of predicted direct employees for each scenario. A value of 0.3 has been used in the Halcrow and related studies5.

17.2.10 This multiplier is not composite, as it does not factor in the effects of leakage, deadweight and displacement. The effects of leakage (which involves the dissipation of impact outside of the relevant target area), deadweight (which takes into account the counterfactual i.e. what would have happened anyway), and displacement (which assesses the extent to which the proposed activity either replaces current activities on site or moves them from elsewhere) are highly subjective particularly for airports. The Halcrow report, and other airport economic impact studies (e.g. BIA6) therefore do not use composite multipliers for employment forecasting.

Induced Employment

17.2.11 A multiplier of 0.3 has been applied for induced employment, again as recommended by the Halcrow report. A top down approach was used, which means that induced employment was calculated using the direct employment figure for each scenario, plus the number of indirect employees.

The Study Area

17.2.12 The main focus for the evaluation of potential socio-economic effects has been within the boundaries of Shepway District Council (SDC – henceforth referred to as “Shepway” in this Chapter), and data has been obtained via the 2001 Census for Shepway District (which included Folkestone, Hythe and Romney Marsh). Shepway itself is divided into the wards of Elham and Stelling Minnis; North Downs (West and East); Tolsford; Folkestone; Lympne and Stanford; Hythe; Dymchurch and St Mary’s; New Romney Town and Coast; and Lydd. Where possible, data relating to only Lydd has been specifically used in describing baseline conditions, although for many factors figures pertaining to the Shepway area have been extrapolated to describe the general status and conditions of Lydd.

17.2.13 Due to the sub-regional importance of this development, some key impacts have been evaluated at a greater scale, and for the purposes of this baseline, the Wider Environs area has incorporated the Kent Councils of Shepway District, Maidstone Borough, Dover District, Ashford Borough, Canterbury City and Tunbridge Wells Borough, and the East Sussex Councils of Rother District and Hastings Borough. Data from the 2001 Census specific to each of these Districts has been combined to create data specific to the wider environs. Any instances where data are unavailable for any Borough or District are footnoted.

4 DTLR (2002) South East and East of England Regional Air Services Study Stage Two: Appraisal Findings Report – Supporting Documentation. Airport Employment Forecasting, Halcrow Group Ltd 5ECOTEC (2001) The Local and Regional Economic Impacts of the Expansion of Regional Air Services" 6 BIA & SWRDA (2005) Bristol International Airport Economic Impact Study, Roger Tym & Partners

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17.2.14 It is important to remember that, in addition to these areas, the proposed development at LAA are likely to have socio-economic impacts across the whole South East region and such impacts have been mentioned in a qualitative manner where relevant.

17.3 Baseline Environment (Existing Conditions)

17.3.1 LAA is located within the Shepway District of Kent. Lydd, the closest settlement to LAA, is a small market town of approximately 5,800 people (2003) and provides a range of local services. The nearest major shopping centre is Rye, approximately 8 miles to the north west.

Regional Overview

Population and Profile

17.3.2 The 2001 Census establishes that the total population of Shepway is some 96,200 people. The population structure is illustrated in Figure 17.1 below, which illustrates that although there are similar numbers of children, there are significantly less 15 – 44 year olds when comparing the Study Area with the national average. This trend is then reversed for the older age groups, where there are a considerably higher proportion of people aged over 50.

Figure 17.1 Population Structure of Study Area Source: Census 2001

17.3.3 It is considered that the decline of lower age groups and rise in older persons in the area is a recent development. When comparing data for the Study Area between the 1991 and 2003, there has been an 11.4% decline in 16-24 year olds during this period, and a 9% decline in 25-34 year olds (see Figure 17.2), with a considerable rise in the number of older persons, the most significant being a 28.6% rise in the 45- 59 age band.

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17.3.4 There was an overall population increase of 5.6% during this time period. The majority of this rise (approximately 60%) is likely to be a result of in-migration, rather than natural population change (Shepway District Plan, 2002). Overall the figures indicate an emigration of younger people, potentially in search of jobs, and an immigration of more elderly people, including those of retirement age.

35 30 25 20 15 10 5 0 0-15 16-24 25-34 35-44 45-59 60-64 65+ % Change 1991 - 2003 % Change 1991 - -5 -10 -15 age group

Figure 17.2 Population Change by Age Group band in Study Area 1991-2003 Source: Office for National Statistics

17.3.5 The total population of the districts incorporated within the Wider Environs is 938,285, where there has slightly lower population growth between 1991 and 2003, at 5.1%. The 2001 Census has shown the ethnic profile of the Study Area and Wider Environs is predominantly White British (94.59% in the Study Area and 95.28% in the Wider Environs).

Housing

17.3.6 House prices in the Study Area are currently well below county, regional and national averages. Land Registry data for January to March 2006 reveal an average (mean) price of £182,902, with a total of 557 sales completed during this quarter. This compares with averages of £206,627 in Kent, £228,762 in the South East and £192,745 for England and Wales. However, the average house prices in the Study Area have more than doubled between 1998 and 2005, in line with national trends, as shown in Figure 17.3. This trend conforms with the decline in unemployment in the area over the same period.

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price number of sales

250000 1000 900 200000 800 700 150000 600 500 100000 400 300 Number of Sales Average price(£) 50000 200 100 0 0

r 8 0 1 3 4 0 0 ea 99 00 00 y 1 1999 2 20 2002 2 20 2005 Year

Figure 17.3 House prices in the Study Area, October 1998 to June 2005 Source: Land Registry, 2005

17.3.7 There is also a substantial stock of tourist accommodation in the Study Area, which is due to the Study Areas high reliance on the tourism industry. There are a total of 66 serviced accommodation establishments in the Folkestone, Hythe and Romney Marsh area alone, providing a total of 1,350 rooms7.

In terms of council housing stock, there are currently 218 Council and 64 Housing Association homes in the Lydd area, and 3,625 Council and 1,245 Housing Association homes in total in the Study Area8.

Education Services

17.3.8 There are a number of primary schools within the Study Area. Lydd Primary School is in close proximity to LAA (approximately 0.5 miles), with 320 pupils on the roll in 2003. Other nearby primary schools include Greatstone Primary School (approximately 2 miles), St Nicholas Primary School (approximately 3 miles), Brenzett Primary School, Brookland Primary School (approximately 5 miles) and Dymchurch Primary School (approximately 7 miles). The nearest secondary school (approximately 3 miles) is Southlands Community Comprehensive School in New Romney, with 1,190 pupils in 2003.

Health Services

17.3.9 There are doctor surgeries in Lydd, New Romney, Romney Marsh and other surrounding towns to LAA. The nearest emergency hospital for the area is the William Harvey hospital at Ashford (approximately 13 miles away). There are a number residential of care homes near LAA, including Manor House, The Regard Partnership (approximately 1 mile), Beakon, Memories, Palm Care (approximately 2 miles), Rosecroft Care, Communitas and Springwood Court (approximately 3 miles).

7 Discover Folkestone Visitor Centre 8 Land Registry, 2005.

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Economy

17.3.10 The Study Area has demonstrated slow economic growth trends since the end of the recession, similar to most other East coastal Districts, where GDP per capita in 2001 was £11,690, slightly above Kent’s average of £11,621. In comparison with the UK average of £12,548 and the South East average of £13,731, Shepway and Kent appear to be lagging behind the regional and national average. However, current predictions forecast Shepway’s output to have increased by 2.2% between 2001 and 2006, and by 3.1% between 2006 and 2011. This figure is slightly above the forecast for Kent, and slightly above UK forecasts (in the 2004 Budget, HM Treasury forecast UK GDP to grow by between 2.5% and 3% in 2006 and 2.25% and 2.75% in 20079.

17.3.11 The area is subject to the following initiatives to seek to improve local economic performance:

• Shepway was granted Intermediate Assisted Area Status in 1993, which it has retained from the period 2000 – 2006. Assisted Areas are defined by the UK government (Department of Trade and Industry) on the basis of economic decline, unemployment and other measures of deprivation, and Intermediate Status enables companies planning expansion, modernisation or rationalisation to receive grants towards their investments; and

• Lydd is small rural town eligible for potential SEEDA funding in their Market Town Programme. This offers grants for both major and smaller projects.

17.3.12 Ashford is currently part of a large investment and regeneration programme, outlined in Ashford’s Future (2005) and the Masterplan document, which outlines the expansion of Ashford to 2031. This will involve an investment of some £3 Billion by both the Public and Private Sectors, and the creation of 28,000 jobs. The vision for Ashford is that is will be come a strong, self-sustaining and growing town, recognised as a world-class exemplar location rich in resources with a technologically enabled, knowledge based learning economy.

17.3.13 The Masterplan sets out the key components necessary to make Ashford a successful and sustainable town, in particular how it can accommodate the required 31,000 homes and necessary infrastructure to support them. At present there are significant physical infrastructure constraints impacting upon development, however Ashford is well positioned to develop as an exemplary regional transport node linking road (M20, M2), rail (Channel Tunnel Rail Link international and domestic) and air (LAA and Kent International Airport).

Occupational Profile

17.3.14 Figure 17.4 displays the occupational profile of the Study Area and Wider Environs, and illustrates that both contain a higher proportion of employees in managerial and personal service jobs than the national average. However the Wider Environs has considerably less people in professional jobs than the rest of the South East and Great Britain. Although the Study Area has a larger amount of employees in managerial and professional roles, there are also considerably more employees in elementary roles.

9 Office for National Statistics

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20 18 16 14 Study Area 12 Wider Environs % 10 8 South East 6 Great Britain 4 2 0

l l a al s s e e ry ri na n e e ic a io o arial ic v hin t ge s i t ad rv r c a s e e fe d Tr S r S Ma men o ofess l le Man r ille nd E P Pr k na me a nd Secre S o to a s s nt e u a Per C & , Pl rativ s Associate s ce Sales Pro Administ

Figure 17.4 Occupational Groups (1995-2003) Source: Annual Employment Survey (1995-1997) (factored) / Annual Business Inquiry (1998-2003)10

Employment

17.3.15 Comparisons of employees by industry for 1995 and 2003 (Figure 17.4) show increasing numbers of people being employed within service industries and progressively less ‘blue collar’ workers in Primary Industries and Manufacturing, although 2003 saw significantly more people employed in the construction industry than previously. Indeed Construction, Tourism (distribution, hotels and restaurants) and Transport and Communications are the only sectors to have gained employees over the last decade, and within Shepway these sectors support a higher percentage of employees than regional and national averages (Table 17.2).

Table 17.2 Employee change in the Study Area, Wider Environs, the SE and UK (1995-2003) Source: Annual Employment Survey (1995-1997) (factored) / Annual Business Inquiry (1998-2003)11

Primary Manufacturing Construction Distribution, Transport and Banking, Public Other All Industries hotels and communications finance & administration, services Industries restaurants insurance, education & etc health

Study -33.3 -24.2 33.3 36.4 80 -9.3 -2.2 30.8 7.7 Area

Wider -31.1 -15.2 49 29.15 -6.7 7.18 8.1 37.4 7.6 Environs

SE -7 -9.5 50.5 24.3 21.1 32.7 10.1 39.4 n/a

UK -22.6 -19 26.5 18.5 14.6 26.1 20.3 24.9 13.1

10 Information for Rother and Hastings was not available for this analysis, and these councils are not included when collaborating data for the Wider Environs 11 Data for the Wider Environs in this instance includes data for the whole of East Sussex, plus data for Ashford, Canterbury, Dover, Maidstone, Shepway and Tunbridge Wells

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Other Services

Public Administration, Education & Health Study Area 1995 Study Area 2003 Banking, Finance & Insurance etc. Wider Environs 1995 Transport and Communications Wider Environs 2003

Distribution, Hotels and Restaurants

Construction

Manufacturing

Primary Industries

0 5 10 15 20 25 30 35 %

Figure 17.5 Comparative business structures of the Study Area and Wider Environs by proportion of employees (1995-2003) Source: Annual Employment Survey (factored) / Annual Business Inquiry12

17.3.16 The significance of the service sector within the Shepway Area is shown in Figure 17.5, which compares the local, regional and national changes in employees between 1995 and 2003:

• Employment in Transport and Communications has risen significantly here by 80% since 1995, although the Wider Environs has seen a 6.7% decline in this sector over the same period. This increase in employment in Shepway is likely to be due to the development of the Channel Tunnel at Folkestone and ongoing developments at Ashford;

• Tourism is also an important sector in Shepway, as reflected in the large proportion of employees in distribution, hotels and restaurants. There has been a 36.4% rise in the number of people employed in this sector, which is significant when compared to the 18% national average and may again be linked to trade from the Channel Tunnel. This is discussed further in Section 17.4.26 (Tourism); and

• Employment in Banking, Finance and Insurance is declining in Shepway, whereas it is increasing both regionally in the Wider Environs and nationally. 17.3.17 The rise in all employment for both the Shepway and the Wider Environs is relatively low at 7.7% and 7.6% respectively, when compared to the 11.4% regional rise and 13.1% national rise.

17.3.18 Both Shepway and the wider environs are characterised by a high percentage of small employers, with a smaller percentage of medium to large employers, as shown in Figure 17.6. Large employers in Shepway include the British Nuclear Group (Dungeness) and increasingly LAA itself, and such companies play a vital role in the local economy, both directly and indirectly as the supplier network, with which they work, is increasingly dependent upon their business (the multiplier effect).

12 Information for Rother and Hastings was not available for this analysis, and these councils are not included when collaborating data for the Wider Environs

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80 70 60 Study Area 50 Wider Environs % 40 South East 30 GB 20 10 0 1 to 4 5 to 10 11 to 24 25 to 99 100+ Firms by size band

Figure 17.6 Firms by Size Band Source: Annual Business Inquiry/NOMIS13

Unemployment

17.3.19 Unemployment levels in Shepway are higher than those in the wider environs (See Figure 17.7) and whilst the 2003-2004 levels of 6% are less than the peak of 12% recorded in 1994, there is still considerable capacity within the workforce for generation of future employment opportunities.

7

6

5

4

ed

y 3 lo p 2

1 % Unem 0 Study Area Wider Environs SE GB

Figure 17.7 Percentage unemployed in Study Area, Wider Environs, South East and Great Britain, 2003-2004 Source: NOMIS local area labour force survey (Mar 2003-Feb 2004)

13 Data for the Wider Environs in this instance includes data for the whole of East Sussex, plus data for Ashford, Canterbury, Dover, Maidstone, Shepway and Tunbridge Wells

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Deprivation Indicators

17.3.20 The UK Index of Multiple Deprivation (IMD), which incorporates data on different aspects of deprivation (such as disability, employment and income) to produce a combined measure, indicates that deprivation levels within the Shepway area are relatively high when compared with other South East local authority districts. Within the 2004 IMD ranks Shepway is currently ranked 131st of the 354 local authority districts in England (where 1st = the most deprived English district and 354th = the least deprived), and is ranked as the 10th most deprived of the 67 local authority districts in the South East. In particular, the data reveal that 14.6% of the population in Shepway is currently living in low-income households (defined as in receipt of means tested benefits), and only four other local authority districts in the South East have a higher proportion of residents in low-income households. This compares with a national average of 13.8% and a South East average of only 8.8%.

Local Industries

17.3.21 Shepway has suffered from a lack of local enterprise and economic investment over the years, although a number of schemes have been introduced in recent years to rectify the slow economic growth in the area. For instance, Romney Marsh has been identified as an Enterprise Gateway, where entrepreneurship is supported in disadvantaged groups and communities and local start-ups are assisted to grow and to improve competitiveness and productivity. In addition, the economic structure of Shepway is evolving to capitalise upon the advantages of changes in communications technology, the reduced trade barriers of the European single market and the location benefits the district enjoys of the Channel Tunnel. Key local industries include the following:

• Tourism The tourism industry is an important source of income for the Shepway area, as described earlier. Shepway has retained a buoyant tourist industry attracting tourists from the UK and abroad, helped by its reputation as one of the sunniest locations in Britain and the district also has a long coastline with extensive sandy beaches, Areas of Outstanding Natural Beauty (Kent Downs AONB, located north of LAA) and numerous short stay visitor attractions. It is important to note here that the tourism industry is likely to contain a large proportion of self-employed people, who are excluded from the ABI data and are on the whole very difficult to measure at a local level with any degree of accuracy and therefore any results previously discussed may be under-represented. The tourism industry is made up of jobs supported by visitor spending and can therefore also cover a wide range of industrial sectors, such as retail, transport and personal services, as well as those directly related to tourism, like hotels and catering.

• Nuclear Dungeness Nuclear Power Plant is situated approximately 3.5 miles from LAA, and is a significant local employer in Shepway. Dungeness A Nuclear Power Station is due to cease generating electricity on 31st December 2006 and in accordance with Government policy will begin to be decommissioned. This loss of employment is likely to have a significant impact on the Shepway District. There are approximately 475 employees at Dungeness A. At closure, this will go down to 255, with many taking early retirement. Post defuelling, this will drop further, and there will be opportunities for employees to transfer to ‘B’ station or

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into Tier 2 contractors who will be working on site. There will be no employees at Dungeness A by 2021. Dungeness B is due for decommissioning in 201814.

• Financial and Customer Services Shepway is already home to a variety of service companies, including Saga Group, Eurotunnel customer services, GE Frankona Re UK, and In-sure Ltd, who enjoy the benefits of a location close to London and continental Europe combined with the convenience of modern communications technology.

• Distribution and Logistics Shepway has a flourishing break-bulk distribution and logistics sector due to the removal of trade barriers within the EU and the increased local choice of transport modes for crossing the Channel. The logistics and distribution companies operating within the district, such as Norfolk Line and Laser Transport, cite Shepway's location and accessibility to UK and European markets as major benefits for their operations. This accessibility is a pivotal location requirement for companies who are seeking to establish responsive yet unified operational frameworks within northern Europe to maximise the advantages of the single market.

• Manufacturing Local manufacturing companies cover a range of sectors including health care products such as Carter Products and drink manufacturers such as Silver Springs Mineral Water Company. Sims Portex Ltd (of Hythe) have recently announced they will be relocating to Mexico, with the loss of 600 jobs.

• Construction The local construction industry suffered a recession through over- capacity after the completion of the Channel Tunnel but new large scale projects including the construction of the Channel Tunnel Rail Link and town centre developments have restored confidence.

• Primary Industries The traditional primary industries continue to benefit from the natural attributes and geographical location of the district. The extensive rural and coastal area supports an array of diverse industries providing employment opportunities in agriculture, forestry and fishing.

Aviation and the Economy

17.3.22 Aviation is a substantial contributor to the UK economy, contributing £10.2 billion to the UK GDP in 2002 (House of Commons, 2003). Oxford Economic Forecasting (OEF) published a report in 1999 (The Contribution of Aviation to the UK Economy), which provides the most comprehensive and up-to-date assessment of the economic benefits of aviation. In 1998, the UK aviation industry directly employed 180,000 people, and supported three times as many jobs through the supply chain, induced effects, and jobs depending upon inbound and outbound travellers (OEF, 1999), as shown in Table 17.3 below.

14 Dungeness A Nuclear Power Station Environmental Statement, 2005, British Nuclear Group

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Table 17.3 Breakdown of UK aviation industry employees, 1998

Number of jobs (1998) Direct Employment 180,000 Indirect Employment 200,000 Induced employment 94,000 Travel Agents 75,000 Total 549,000 Source: OEF (1999)

Tourism

17.3.23 Employment in the tourism industry is clearly dependent upon the aviation industry, and some two thirds of foreign tourists arrive in the UK by air (OEF, 1999). Aviation also assists in generating employment in other areas of the economy by facilitating direct foreign investment in the UK. Table 17.4 below compares spending by UK residents overseas and foreign visitors to the UK using monthly series data derived from the International Passenger Survey (IPS)(www.statistics.gov.uk/STATBASE).

Table 17.4 Visits and spending by UK residents abroad and overseas residents in the UK. UK resident expenditure Overseas Visitor Expenditure overseas (£ billion) in UK (£ billion) 30,184 13,048

17.3.24 In 2002, the number of people employed in tourism in the UK was just over 2 million (House of Commons, 2003). There has been a long-term trend of tourism jobs gradually increasing, the majority of which are employee jobs.

17.3.25 Spending by both domestic and foreign tourists was approximately £76 billion in 2002, which is spent predominantly on accommodation, eating out, shopping and travel within the UK, as shown in Figure 17.8 (House of Commons, 2003). Domestic tourism accounts for 83% of spending upon which the 2.2 million UK tourism jobs rely (Friends of the Earth (FOE), 2005).

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Figure 17.8 Overseas and domestic tourism spending by category, 2001 Source: House of Commons, 2003

17.3.26 The South East of England attracted over 16 million domestic visitors per annum, and nearly 4 million overseas visitors in 2004 (IPS15). The overseas trips were predominantly holiday visits, followed by visits to friends or relatives, then business trips, as shown in Table 17.5 below. Although there were more holiday visits, visits to friends and relatives resulted in higher spending.

Table 17.5 Number of trips to the South East of England by purpose of visit (2004) (IPS) Number of Trips (million) Spending (million) Holiday 1.08 £274 Visiting Friends and Relatives 1.40 £389 Business 0.99 £472 Other 0.46 £331 Total for South East England 3.95 £1,467

17.3.27 The highest number of visitors to the South East by nationality in 2004 were visitors from the United States, closely followed by visitors from France, as shown in Figure 17.9 below. Visits from the UK’s immediate neighbouring countries of France, Germany, the Netherlands and Belgium when combined, represent over one third of the overseas visitors to the region.

15 IPS International Passenger Survey, carried out by the Office of National Statistics. Available from http://www.industry.visitsoutheastengland.com/factsandfigures/overseastourismfacts/overseastourismfacts.aspx

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600

500

400

300

'000k visits 200

100

0

a A e in ds lic li a S c a n a um U n p Italy tr i ad S rla s lg n Fra Ca Germany he Au Be et N Irish Repub

Figure 17.9 Top overseas markets to the South East in 2004, ranked by visits (IPS)

17.3.28 The main purpose of tourist trips to Shepway in 2003 was holidays (68%), followed by visits to friends and family (19%) and business (13%). There were 408,000 staying trips in 2003, with domestic visitors making up 88% of trips, and overseas visitors making up 12%. These visits accounted for nearly £60 million being spent. There were over 3 million tourism day trips during the same period, which accounted for £83 million being spent. In total, £143.5 million was spent by all visitors, of which £133.8 million directly benefited local business, and £49 million was generated through indirect and induced spending, in terms of business turnover. This income into the local economy is estimated to have supported approximately 2,700 Full Time Equivalent Jobs and 3,670 Actual Jobs (Tourism South East (TSE), 2004).

17.3.29 Analysts forecast an increase of 3% for overseas visits in 2005 for the South East region, however domestic tourism is predicted to have a slower rate of economic growth due to the weakening housing market, fears over further interest rate rises and higher petrol costs (TSE, 2005).

17.3.30 There are a relatively large number of hotels, bed and breakfasts, guesthouses and holiday homes in Shepway. The area of Lydd and Romney Marsh attracts tourists due to its natural beauty and diversity of habitats, geomorphology and wildlife. The area has numerous designations including SPA, SAC, SSSI, RAMSAR, NNR and national Earth Heritage. There is an expanse of sandy beach that spreads along the coast. Other attractions around Lydd include go-karting, jet skiing, water skiing and speed boating, the Romney, Hythe and Dymchurch Steam Railway, Lydd Town Museum and the 18 hole golf course next to LAA. Future tourist attractions include the re-establishment of the Air Show at LAA which due to recommenced in 2006.

17.3.31 Research carried out within Shepway by Transmarche Tourism Research has provided a profile of visitors to Folkestone and Hythe. Results indicated that the majority of visitors were UK residents, who were predominantly on a day trip or holiday. Overseas visitors were mainly visiting to study a language. This was

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reflected in the age profile of visitors, with the majority of UK visitors aged over 65, whilst almost half of overseas visitors were under 35. Motivations for visiting Folkestone included the opportunity to visit France, whereas the main motivation for visiting Hythe were the beach facilities and peace and tranquillity of the area.

Employment Arising from LAA Operations

Direct employment

17.3.32 A variety of factors have significant influences on the levels of direct employment at airports. These include the following:

• Passenger number ratios (such as the mix of passenger traffic handled, e.g. scheduled/charter, business/leisure, inbound/outbound etc.);

• Capacity utilisation. This is particularly relevant at LAA as there are generally higher employment ratios at small airports due to the fixed nature of some staffing. A rise in passenger numbers will lower the employment ratio;

• The number of airlines and aircrew based at the airport;

• Maintenance activity and administrative functions; and

• The extent of local development opportunities and how far these opportunities are being exploited.

17.3.33 Airport companies themselves typically account for approximately 20% of direct employment, although this will vary with the extent of outsourcing16. The Regional Air Services Co-ordination Study (RASCO) study17 provides a breakdown of airport employment opportunities, where approximately 30% of employment is managerial and professional, 10-15% is manual, and the remainder made up of clerical/secretarial, other service and semi or unskilled manual workers. LAA currently employs some 68 staff directly, as presented in Table 17.6 below.

16 Regional Air Services Co-ordination Study (RASCO), DfT (2002) 17 ibid

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Table 17.6 Current Employment Levels at LAA

Current Employment Levels – March 2006 Executive Offices 6 Sales and Marketing 2 Fire Crew 12 Bird Control 1 Engineering 5 IT 2 ATC 8 ATC Engineering 1 HR 2 Accounts 5 Catering 9 Customer Services 3 Safety and Security 3 FAL 9 Totals 68

Indirect employment

17.3.34 LAA has a policy of using local goods and services wherever practical, which positively influences the amount of local indirect employment. Whilst the absolute extent of this influence is not easily quantifiable, using the approach outlined in section 17.2 and the standard multiplier of 0.3, the current operations are expected to produce 20 indirect jobs.

Induced Employment

17.3.35 Workers employed through LAA will also spend a proportion of their income in the local area, which will in turn support other jobs in the local economy, although the absolute extent to which this further expenditure reaches the local economy is difficult to quantify, depending upon where the workers live and where they spend their money. Additional money will also passed into the local economy through supply linkages as the airport and its users buy goods and services from other local businesses.

17.3.36 The induced employment expected as a result of existing operations, calculated as described above from the total direct and indirect employment forecasts times a multiplier of 0.3, is an extra 26 jobs.

17.3.37 A small proportion of income would also be spent on ‘at work’ expenditure on local goods and services such as food, leisure and some convenience goods. This would

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be captured by the local Shepway economy. There would be successive rounds of the multiplier effect resulting from this induced expenditure, working its way through the local economy.

17.4 Baseline Environment (Future Assessment Conditions Scenario)

17.4.1 Given the proposed timescales, regional socioeconomic conditions under this scenario are expected to be the same as those described under the ‘existing conditions scenario’.

17.4.2 Employment figures at LAA will however increase over time in line with the rise in passenger numbers. Using the ACI benchmark of 600 employees per million passengers for a medium density airport, a rise in passengers to 300,000 per annum is expected to result in an expected increase of 112 direct jobs above the ‘existing baseline scenario’, resulting in a total of 180 staff employed directly as LAA.

17.4.3 Similarly, with LAA’s policy of using local goods and services wherever practical, an increase to 300,000 passengers per annum is expected to create an additional 34 indirect jobs, resulting in a total of 54 indirect jobs.

17.4.4 The induced employment expected as a result of the future assessment conditions scenario (calculated from the total direct and indirect employment forecasts times a multiplier of 0.3) is an additional 44 jobs, resulting in a total of 70 jobs.

17.5 Potential Impacts (Construction Works)

Existing Conditions Scenario

Employment Impacts

17.5.2 The scale of construction employment is a function of the size and type of construction expenditure, which is dependant upon the overall value of the construction project; the extent to which materials, services and equipment can be and are likely to be sourced locally or further afield and the extent to which construction labour is sourced locally or further afield.

17.5.3 In the absence of a preferred scheme contractor, a series of assumptions have been made to estimate the likely levels of construction employment generated by the proposed development. These have included assumed construction costs of approximately £2 million for the runway extension. The English Partnerships figures that approximately £53,500 of construction expenditure supports one person-year of employment and that 10 person years of construction work are equivalent to one permanent job in the economy (as outlined in Section 17.2.4) have also been used.

17.5.4 Based on this ratio and the estimated construction costs of £2million, it is estimated that 37 gross person years of employment will be generated. Using a standard ratio of 10 person years of construction work being equivalent to one permanent job in the economy, this is equivalent to just under 4 FTE jobs created

Future Assessment Conditions Scenario

17.5.5 Predicted impacts from runway construction under this scenario are expected to be the same as described under the ‘existing conditions scenario’ above.

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17.6 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

Operational Based employment forecast

17.6.2 As discussed in Section 7.3, The proposed development will generate a number of direct, indirect and induced economic and social impacts, of which the key economic impact that can be quantitatively measured is the creation and support of employment as shown in the Table 17.7 below.

Table 17.7 Key Employment Types

Direct employment incorporating the on and off-site employment associated with LAA itself and the airlines and other companies that are based there. Indirect employment incorporates those in employment relating to suppliers to the airport, created by initial purchases and services required by LAA. There is a cumulative effect through the supply chain as initial suppliers make purchases from their suppliers and so on. Induced employment supported by the salaries and wages of those workers employed both directly at LAA and indirectly in the form of its suppliers. This employment income leads to expenditure in the local economy, which supports further rounds of income, expenditure and employment. 17.6.3 Using the calculations, outlined in Section 17.2 it is predicted that 300,000 passengers per annum would support

• a direct employment workforce of 180 persons (ie an increase of 112 jobs);

• an indirect employment workforce of 54 persons (ie an increase of 34 jobs); and

• an induced employment workforce of 70 persons (ie an increase of 44 jobs);

The combined amount of employment is therefore an increase of 190 jobs from the existing conditions baseline, which is a positive impact.

Implications of Employment Impacts

17.6.4 The increased demand in employment arising from the rise in passenger throughput to 300,000 per annum, should be met by the labour supply in Shepway and the Wider Environs, with the majority of employees expected to live locally. Furthermore, LAA has a commitment to preferentially employ at least 80% of its direct employees locally18.

17.6.5 The relationship between labour demand and supply is relies on a number of inter- relating factors and is difficult to quantify. A rise in employment demand will be met by supply if the local population is able to absorb the demand, for example by having high unemployment rates and a suitably qualified number of persons available. If there is not sufficient locally qualified resources available to absorb the demand, in- migration and/or increased competition for local labour supply will generally result,

18 See ECOTEC (2001) The Local and Regional Economic Impacts of the Expansion of Regional Air Services

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with often an associated rise in labour cost. A qualitative assessment of the factors that will influence the local labour supply in the area around LAA is as follows:

• The occupational profile outlined in the baseline indicates a high proportion of employees in managerial and personal services, and elementary roles. This job mix fits in well with the RASCO profile of direct airport employment outlined in Section 17.4.9. Those employed in construction in Shepway and Wider Environs is also growing, which should absorb the requirement for construction labour, if this labour demand is sourced locally. The low rise in overall employment levels means that the increased demand in labour will be welcomed. There are no reliable profiles for indirect and induced airport employment for comparison.

• Although unemployment rates are recovering from the last recession, they are still comparatively high in both Shepway and Wider Environs when compared to regional and national averages. This surplus of labour supply, coupled with the current low economic growth in the Study Area, indicates that the local area would be able to absorb the labour demand surrounding the expansion of LAA.

• The Dungeness Nuclear Power Plant has been a stable feature of the local economy for approximately 40 years, and the decommissioning of the plant will lead to employment loss that will significantly impact upon the local socio- economic climate. Dungeness A will cease generation at the end of 2006, with the 475 jobs being reduced to 255 by January 2007, and 0 by 2021. This will lead to a 1.4% reduction in total number of employee jobs in Shepway19. The employment demand from the proposed development at LAA will therefore provide employment opportunities for the rise in available labour supply associated with the decommissioning of Dungeness A. The above indicates that it is likely that the employable population in Shepway and Wider Environs will be able to absorb the labour demand. Although there is a current trend of decline of working age population residents, and a rise in older persons in Shepway, the high unemployment rate and pool of employable labour within commuting distance of LAA means that this is not likely to have a significant effect on labour supply.

17.6.6 In addition, with respect to the deprivation levels in the Study Area, the employment forecasts associated with the proposed development at LAA will have a positive impact on the Study Area by providing more jobs and by acting as a catalyst for further regeneration for the local economy. This may positively impact the IMD rank of Shepway.

17.6.7 A small proportion of income would be spent on ‘at work’ expenditure on local goods and services such as food, leisure and some convenience goods. This would be captured by the local Shepway economy. There would be successive rounds of the multiplier effect resulting from this induced expenditure, working its way through the local economy.

19 Dungeness A Nuclear Power Station Environmental Statement, 2005, British Nuclear Group

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Population

In-Migration

17.6.8 Whilst any in-migration resulting from the increased demand for labour will have some impact on the available local supporting services, such as schools, health services and other community facilities, it is considered unlikely that any in-migration will be concentrated in one small area and therefore there are not expected to be any significant impacts associated with this.

17.6.9 In-migration may create an increase in demand for housing. This may have some negative impacts to the lower income community as the housing market is likely to become more competitive as a result and there may be more competition for council accommodation. However, house and rental prices in the Study Area are currently much lower than the national average, and any rise in house prices will not be significant when compared to the national housing market. In addition, there is currently significant rapid expansion in housing in the Ashford area that is likely to able to absorb any demand for housing caused by in-migration.

Local Communities

17.6.10 There is a likelihood that communities in the area immediately surrounding LAA will experience at least some changes in ambience to their current rural lifestyle as a result of ‘shadow effects’ to the local noise, visual and other environments. These will arise through a combination of increased human activity and aircraft and traffic movements, as well as potential pressures of further development. Should this ambience be altered, there is a chance that the current population profile may change as retirees may be less attracted to the area. Potential impacts to ambience are dealt with in the other Chapters of this ES, and mitigation levels to reduce impacts to acceptable levels are proposed.

17.6.11 Whilst LAA’s 24 hour operational licence means that there is the potential for occasional night flight operations, a large-scale study into effects of night time Aircraft 20 Noise Events (ANEs) on sleep disturbance reported that for outdoor night time Lmax levels below 95 dB(A) the average person had a chance of awakening of less than 1 in 75, and levels below Lmax = 80 dBA ANEs are unlikely to cause disturbance to sleep. Such impacts are explored further in Chapter 16 Noise and Vibration.

Housing

17.6.12 House prices in the Study Area are low when compared with regional and national averages. Whilst in general increased airport operations have the potential to depress property values in direct proximity to the airport and under the flightpath, increased levels of employment and opportunities for travel may have the opposite effect. Longterm impacts to house pricing are therefore uncertain.21.

20 Department of Transport paper 1992 21 A specific impact contributing to changes in property values is a change in noise and ‘hedonic pricing’ (a method used to estimate economic benefits or costs). Research has estimated a change of 0.5-1% of house values per dB(A) Leq permanent change in noise. See DfT, Night flying restrictions at Heathrow, Gatwick and Stansted: Consultation on Restrictions to apply from October 2005 – Partial RIA. Annex E: Partial Regulatory Impact Assessment.

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Schools

17.6.13 The effect of noise on local schools is discussed further in Chapter 16 Noise and Vibration. Since it is expected that the majority of employees will be recruited from the local area, no significant levels of in-migration are expected and no significant additional pressure on school services are therefore predicted.

Tourism

17.6.14 No negative impacts are expected on recreational facilities in close proximity to LAA from the proposed development. Whilst the tranquil conditions of immediate sites such as the golf course and nature reserve may be affected by aircraft noise, the proposed development is likely to attract more people to the area and from this perspective the number of people using the amenities may rise.

17.6.15 “Tourism” is used to refer to all overseas travel to and from the UK whether for business or leisure purposes. Tourism is an important and growing sector in Shepway and Wider Environs, with a high percentage of employees when compared to other industries and national averages.

17.6.16 The substantive external impacts associated with tourism will predominantly arise from passengers using LAA as a destination, rather than an origin airport, as they are more likely to seek a higher proportion of overnight accommodation and other tourism services. Analysis of impacts from outbound and inbound passengers will therefore be considered separately.

Outbound Tourism Impacts

17.6.17 The expected growth in passenger numbers at LAA as a result of the proposed development will provide beneficial external economic impacts through expenditure in the South East and elsewhere within the UK, for instance on accommodation, retail, catering, business and entertainment. There is also likely to be a rise in demand for short stay accommodation in the area, for instance, by passengers wishing to stay in hotels overnight previous to their flights.

17.6.18 Although the holiday villages and caravan parks in Greatstone-on-Sea, Littlestone-on- Sea and New Romney may be adversely affected due to changes in local ambience, as the proposed development will also make these areas more accessible to inbound tourists (as well as bringing the opportunity of international travel closer to the residents of Kent and surrounding counties) the extent of any such impact is hard to quantify.

Inbound Tourism Impacts

17.6.19 The volume of visits and spend by overseas visitors to the UK is affected by a number of factors which may impact on different origin areas in different ways including changes in the economic activity and disposable income in the origin countries; the relative value of sterling against the origin country currencies; changes in the routes and opportunities to access the UK, together with the marketing and promotion of those opportunities in the origin countries; and political and health events such as war, terrorism incidents and disease outbreaks that can have significant, albeit short term, impacts on the willingness to travel.

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17.6.20 Whilst approximately 3,000 scheduled passengers per annum currently pass through LAA (CAA, 2005) using one route (to La Touquet), there are no other data available on tourism spending for passengers using LAA. A report by South West Tourism on the economic impact of tourism22 indicates that overseas visitors are currently worth approximately £242 each to the South West economy23and can be used to assume that inbound tourists are likely to be worth a similar amount to the economy surrounding LAA. A rise in passenger numbers associated with the proposed development at LAA could positively benefit the local economy by injecting direct foreign investment into the region through increased inbound tourism spending.

17.6.21 The proposed development at LAA will also benefit the tourism industry in the South East from a rise in inbound passengers demanding tourism facilities, which results in a rise in employment demand and a rise in incomes. It should be noted, however that the tourism market in the UK is expected to continue to decline in competitiveness when compared with overseas destinations due to the continuing decline in air fares and the rising cost of surface travel24. Any rise in the number of tourists visiting a region will require careful planning in order to ensure that the whole community can reap the benefits.

Other Socio-economic Impacts

Development

17.6.22 At present there are no significant direct off-site activities surrounding LAA. There are however, industrial units and warehouse premises in Romney Marsh, including Mountfield Road Industrial Estate, Harden Road Industrial Estate, Station Yard in Lydd, Kitewell Lane in Lydd and Dengemarsh Road Industrial Area.

17.6.23 Air intensive industries are defined as those that ship and receive a high proportion of goods by air freight, and those that are high intensity users of air transport. SEEDA publishes a directory of major companies, and this directory shows that 27% of all companies in Kent, and 35% in both East and West Sussex, are air intensive. These companies are likely to benefit from the proposed expansion at LAA. There is also the possibility that air intensive companies may relocate to near LAA, which would have a positive benefit on the local and regional economies.

17.6.24 In addition, research has shown that the local provision of air services is an important factor in relation to the siting of regional offices, as an international airport can influence location decisions by companies. The Common Options for Airport Regions (COFAR)25 report supports the view that airports play a major economic development role within their respective regions, pinpointing airports as ‘an essential competitive factor’ and a ‘tool for regional development’ (RASCO).

Future Assessment Conditions Scenario

17.6.25 Predicted employment numbers arising from the runway extension under this scenario are not expected to change from the baseline (Section 17.4), as passenger numbers remain the same at 300,000 per annum. Impacts for this scenario are the same as that described above in the ‘existing conditions scenario’.

22 Value of Tourism (2003) South East Tourism 23 Data taken from BIA Economic Impact Study (2005) BIA & SW RDA 24 The Impacts of Future Aviation Growth in the UK, Strategic Aviation Special Interest Group (SASIG) December 2000 25 Common Options for Airport Regions COFAR (2001) Airport City and Regional Embeddedness: Final Report

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17.7 Proposed Mitigation (Construction Works)

Existing Conditions Scenario

17.7.1 Employment impacts associated with construction are positive and therefore require no mitigation, although coordination is required with local regulators and tourist boards to ensure that the effectiveness of the positive impacts are not offset by temporary negative impacts to the local ambience (as addressed elsewhere in this ES.

Future Conditions Scenario

17.7.2 Proposed mitigation under this scenario is as described under the ‘existing conditions scenario’ above.

17.8 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

17.8.1 Employment impacts associated with operation are positive and therefore require no mitigation, although coordination is required with local regulators and tourist boards to ensure that the effectiveness of the positive impacts associated with any rise in tourism is not offset by negative impacts (including inward migration). Impacts to the local ambience are addressed elsewhere in this ES.

Future Conditions Scenario

17.8.2 Proposed mitigation under this scenario is as described under the ‘existing conditions scenario’ above.

17.9 Residual Effects

Existing Conditions Scenario

17.9.1 The construction jobs created as a result of the runway extension are considered to be a minor effect particularly as they do not, of themselves, raise the long term productive capacity of the regional economy.

17.9.2 Any expansion at LAA will enhance the attractiveness of the Shepway District and surrounding region as a location for inward investment.

Future Assessment Conditions Scenario

17.9.3 Residual effects are expected to be as described for the ‘existing conditions scenario’ above.

17.10 Summary

17.10.1 Shepway District has a population of just under 100,000 people, with a lower proportion of middle aged residents and a higher proportion of older residents when compared to the national average. This is a fairly recent development that has been attributed to in-migration of people of retirement age.

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17.10.2 The Study Area has had slow economic growth since the last recession, and has been granted Intermediate Assistance Area Status. Unemployment rates are higher than the South East average, and deprivation levels are high, with the Study Area ranked 10th out of the 67 in the South East in IMD data (2004).

17.10.3 Transport and communications, tourism and construction industries are growing in the Study Area, with a higher proportion of employees when compared to national and regional averages. This is reflected in the proportion of relation companies and services found locally for each of these industries. Tourism is an important source of employment, and there is a large stock of tourist accommodation and services found locally. The Study Area has much to offer in terms of the natural environment (e.g. beaches, habitats and wildlife) that attract mainly domestic tourists to the area.

17.10.4 The proposed construction works for the runway extension are expected to create 4 Full Time Equivalent (FTE) jobs, whilst operation of the airport with runway extension would result in 180 direct jobs, 54 indirect jobs and 70 induced jobs.

17.10.5 This rise in employment demand should be readily absorbed by the local labour supply due to the relatively high unemployment rates and an occupational profile fit to suit that required by direct airport employment opportunities. A rise in local employment will have a positive impact upon the local economy and contribute to the regeneration of the Study Area.

17.10.6 Whilst some local communities will experience changes to their rural lifestyle and character of the area as a result of increased noise, human and aircraft activity and traffic, mitigation has been proposed to mitigate this wherever possible.

17.10.7 The proposed development will have a positive impact upon local tourism through a rise in demand for overnight accommodation and other tourism facilities; injecting direct foreign investment to the region through increased tourism spending.

17.10.8 The proposed development at LAA may promote inward investment and benefit local companies through the option of flying from LAA to a wider choice of locations than at present. The proposed development may also influence new businesses in their choice of location due to improved services offered by the airport.

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CHAPTER 18

CUMULATIVE IMPACTS

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18 CUMULATIVE IMPACTS

18.1 Introduction

18.1.1 Whilst an individual development may not have any significant environmental or social impacts when considered on a stand-alone basis, the impacts of several developments occurring at the same time or place may become more significant as a result of the cumulative effects either affecting a larger area or having a more concentrated or a greater duration of impact.

18.1.2 Cumulative impacts are generally considered to be “impacts that result from incremental changes caused by other past, present or reasonably foreseeable future actions together with the project” and may include:

• The combined effect of individual impacts on receptors; and

• Incremental impacts caused by separate developments within the area.

18.2 Legislative Drivers

18.2.1 European Community Directive 85/337/EEC “The Assessment of the Effects of Certain Public and Private Projects on the Environment” as amended by Council Directive 97/11/EC requires the assessment of cumulative effects at a project level within an EIA.

18.2.2 This legislation has been transposed into UK law through the Town and Country Planning (Assessment of Environmental Effects) Regulations 1988 (SI No 1199) superseded by the Town & Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (SI No 293). Schedule 4, Part I states that an ES must include a description of cumulative effects.

18.3 Assessment Methodology

18.3.1 An initial screening for potential cumulative effects can be undertaken by reviewing the key sensitive receptors within a region and the (multiple) project components that could affect them. The magnitude of any potential impacts can then be assessed by using the standard EIA approaches outlined in the previous chapters of this ES.

18.3.2 A number of technical papers written in recent years outlining approaches for undertaking such work have been reviewed as part of the assessment, including the following:

• Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions, EU (1999)1;

• Draft Guidance on Cumulative Effects Assessment of Plans, EPMG, Imperial College London (2003)2; and

1 European Union (1999) European Directorate XI: Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions.

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• EIA Newsletter 14, Cumulative Impacts Manchester University (1997)3 18.3.3 In assessing the magnitude of potential cumulative impacts, the definitions shown in Table 18.1 below have been used.

Table 18.1 Magnitude of Cumulative Impact Significant impact by nature of its extent, duration or magnitude of greater than Major local value or in breach of legislation, policy or guidance Limited impact by nature of its extent, duration or magnitude, which may be Moderate considered significant in context of the site and surrounding area

Minor Slight, short term or localised impact of no significance

18.3.4 In addition to the potential for cumulative impacts from other major projects near the proposed project site, relatively minor developments occurring within close proximity of a site could theoretically also accumulate to produce significant impacts over time. However, as it is generally not considered viable to predict (rather than monitor) such cumulative impacts with any degree of certainty, these activities are not considered any further here.

18.3.5 In addition, cumulative impacts of construction activities have not generally been assessed here, especially given the localised and temporary nature of such works and the ability of mitigation measures to be generally implemented to avoid, reduce or minimise the magnitude of any such effects. The exception is impacts related to local gravel extraction works and the decommissioning of Dungeness A, which have been assessed even though they are essentially construction activities.

18.3.6 Cumulative impacts have been addressed where possible but impacts from currently undisclosed projects cannot be addressed in this way and so some uncertainty will always remain for such unknowns.

18.3.7 The cumulative assessment has therefore focused on the following:

• Operational activities that have existing and current permission (including developments allocated in the development plans);

• Activities that are about to be implemented that have received planning permission; and

• (Under the precautionary principle), activities that have had detailed application(s) lodged and are awaiting the outcome of planning decisions.

18.4 Assessment of Cumulative Effects

18.4.1 The key sensitive receptors that have been identified within the ES are shown in Table 18.2 below:

2 Cooper, L. M. (2003), Draft Guidance on Cumulative Effects Assessment of Plans, EPMG Occasional Paper 03/LMC/CEA, Imperial College London. 3 C. Wood, A.J. Barker and C.E. Jones (ed.), (1997) EIA Centre, Planning and Landscape, University of Manchester, Manchester, EIA Newsletter, 14 Cumulative Impacts.

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Table 18.2 Key Sensitive Receptors Water Resources The area is drained by numerous sewers and ditches. Recorded water quality is generally poor, but they do play an important ecological role. There are no major aquifers in the areas, but groundwater levels are generally high. Ground Conditions Much of LAA overlies unconsolidated shingles and gravels, some of which of are noted for their geomorphological value. Land Use Much of the surrounding land is under arable farming, or used for conservation purposes. Gravel extractions are found throughout the area. Ecology The area is of high ecological value, primarily for the bird life it supports and much of the area is protected by national or international designations. Landscape and The area surrounding LAA is generally flat and landscapes are a Visual Amenity combination of drained marshes and coastal seascapes. Cultural Heritage & LAA and its surroundings contain a few areas of industrial or military Historic Environment archaeological value, but these are limited in extent. Traffic Traffic levels around LAA are currently low, although the numbers of HGVs associated with mineral workings can lead to local traffic jams. Air Quality Air quality in the area is generally good, given the local sea breezes. Noise and Vibration The area is generally quiet, with the major noise sources being existing aircraft and traffic noise. Socio-Economic Lydd and the surrounding area are considered to be in need of economic support, with declining employment opportunities and an increasingly aged population. Developments at Ashford are beginning to reverse this trend to some extent.

18.4.2 The developments and proposals that have been identified in the surrounding area with the potential to have cumulative effects with the proposed development are described in Table 18.3 overleaf.

18.4.3 Local mineral workings4 are listed in Table 18.4 below.

Table 18.4 Permitted and Proposed Mineral extractions within 4km of LAA Site Name Approximate Site Name Approximate distance distance from from LAA LAA Existing Planning Permissions New Proposals Allens Bank Quarry 900m Denge Pit 2.4km Land east of Denge Lane (Part) 1.3km Land north west of Jurys 3.2km South Gap Road Land adjacent to Whitehall Farm 1.6km Scotney Court Quarry 3.4km Land east of Denge Lane (Part) 2.3km Land west of Tourney Hall 3.5km West Land east of Denge Lane (Part) 2.4km North Land north east of Dering Farm 2.7km

4 Kent Adopted Construction Aggregates Minerals Local Plans, 1993. http://www.kent.gov.uk/static/mwdf/Search_Construction_Aggregates.htm

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Table 18.3 Proposed Developments in the LAA area with Potential for Cumulative Impacts

Project Description Dungeness A Nuclear Power Dungeness A, BNFL’s Magnox 450 MW Nuclear Power station, is scheduled to cease generation on 31 December 2006. Fuel will Station Decommissioning then be progressively removed from the reactors and sent to Sellafield for treatment over a period of some three years. The actual decommissioning process i.e. dismantling and removal of all the buildings, plant and equipment will be undertaken in three phases as follows: 1. Care and Maintenance Preparations – 0-15 years: The reactor building will be prepared for an extended period of safe storage. All radioactive and non-radioactive plant and buildings other than the reactor building will be dismantled and removed. 2. Care and Maintenance – 15-105 years: This is scheduled to continue until radioactivity levels inside the reactors will be low enough to enable final dismantling. During this period no significant work will take place although the site will continue to be managed, monitored and maintained in a safe state. 3. Final Site Clearance – 105-123 years: The reactors and their buildings will be removed and the site finally cleared and will involve removal of the remaining structures, including the reactors as well as residual radioactivity clearance. The Care and Maintenance Preparation for the first 15 years is the most crucial when considering the impacts relating to levels of traffic on the surrounding road network. Levels of traffic will considerably decrease after this period as no significant work will be taking place. Little Cheyne Court Windfarm Little Cheyne Court Windfarm is proposed to be located to the west of Walland Marsh and 6.5km west of LAA within a low lying flat of reclaimed marshland currently in arable farming and designated as a local landscape area. The windfarm will consist of 26 2.3MW turbines, providing a capacity for nearly 60MW. The turbines hub height will be 70m with a maximum blade tip of 116m where the maximum rotor diameter will be 92m. Local mineral extraction activities Mineral extraction occurs in the immediate vicinity of the airport and in the surrounding area. Permitted and proposed extractions located within a 4km radius of LAA are shown in Table 18.4. Lydd Golf Club Hotel Lydd Golf Club Hotel is being developed alongside the Golf Club, with which it will share facilities. The hotel will have a total gross floor area of 7,555m2 and will include 75 bedrooms, 304 carparking spaces, a swimming pool and leisure facilities, a conference centre and a bar and restaurant. The hotel and conference facilities will be aimed at seasonal guests and business users and is likely to attract visitors from Kent and the wider southeast. LAA Proposed Terminal A new terminal building built in two phases is also being proposed for LAA and is subject to a separate planning application. The Buildings construction phase of Phase 1 is planned for 2009 and is expected to take approximately 18 months and Phase 2 is planned for 2013 and last approximately 12 months.

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18.4.4 Given these proposed projects, a number of potential areas of cumulative impact have been identified as shown in Table 18.5 below.

Table 18.5 Potential Areas of Cumulative Impact Little Mineral Golf LAA LAA Dungeness Receptors Cheyne Extractions Club Phase Phase A Hotel 1 25 Water XX ~ XXX X X XX Resources Ground ~ ~ XXX ~ X X Conditions Land Use ~ XX ~ X X X Ecology & Nature ~ XX X X XXX XXX Conservation Landscape & 999 XXX XXX X X X Visual Amenity Cultural Heritage & ~ ~ XX ~ ~ ~ Historic Environment Traffic & XXX ~ XXX X XX XXX Transport Air Quality XX 99 XX X XX XXX Noise and XX XX XX X XX XXX Vibration Socio-Economic XX 99 99 9 999 999

Key Nature of Impact 9 Beneficial X Adverse ~ Negligible Potential Magnitude 999 / XXX Major 9 9 / XX Moderate 9 / X Minor

18.4.5 Following this initial screening, the following resources are considered to be potentially affected by significant cumulative impacts and are therefore discussed further below:

• Water Resources;

• Ecological Resources;

• Traffic and Transport;

• Air Quality;

• Noise and Vibration; and

5 “There is an aspiration for 2million passengers per annum however no detailed planning application for Phase 2 has been lodged at this time”

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• Socio-economic. 18.4.6 It should be noted that none of these proposals are considered likely to affect the viability of the proposals at LAA. In particular, given the current designs and distance from the airport, the proposed windfarm is expected to have no discernable effect on either the radar or the navigational systems at LAA6 and indeed PPS 22 on Renewable Energy (2004) make the specific statement with respect to wind farm operations that “it is the responsibility of developers to address any potential impacts, taking account of Civil Aviation Authority, Ministry of Defence and Department for Transport guidance in relation to radar and aviation, and the legislative requirements on separation distances, before planning applications are submitted’ and that “Local Planning Authorities should satisfy themselves that such issues have been addressed before considering planning applications”. Given that there are no proposed changes to the radar requirements of the airport as part of the currently proposed development, it must be accepted that such issues have already been satisfied from a planning perspective.

Water Resources

18.4.7 Potential cumulative impacts to local water resources include the following:

• discharges to surface and groundwaters during the decommissioning of Dungeness A which could affect water quality;

• changes to local hydrological patterns, water consumption, and water quality following discharges as a result of mineral extraction works;

• altered drainage at the Lydd Golf Club Hotel and impacts to water quality from runoff via the carpark, landscaping and the discharge of any treated effluent; and

• affects on the local hydrology and water quality arising from spills or run-off to drains and directly to the ground. 18.4.8 Whilst there is the potential for these to result in cumulative impacts to local surface water quality, the local enforcement of appropriate environmental management plans and discharge consents and the current poor water quality of these watercourses, means that overall impacts are considered to be of no more than a minor adverse impact cumulatively. In addition, given the distance between the project locations, and the limited aquifer within the area, no significant cumulative impacts to groundwaters are expected.

Ecological Resources

18.4.9 The local area is renowned for its sensitive ecological characteristics. Potential for cumulative impacts arises from the interactions of the Project with the following:

• Dungeness A Decommissioning – general disturbance to wildlife;

• Little Cheyne Court Windfarm – disturbance to birds and collision impacts;

6 Wind Energy, Defence and Civil Aviation Interests Working Group, (2002) Wind Energy and Aviation Interests- Interim Guidelines

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• Local Mineral Extractions – disturbance and local habitat loss. Positive impacts for birds if new waterbodies are generated within the pits;

• The proposed development – impacts on bird life from aircraft movements. 18.4.10 The cumulative impacts of the activities have the potential to result in elevated disturbance levels to birds and given the high conservation value of the local area, the development of locally agreed biodiversity management plans and bird hazard risk management plans is considered crucial. Local mineral extractions may also impact upon the operation of the airport if waterbodies are created and attract birds in proximity to LAA flightpaths and this must also be addressed in such plans.

Traffic and Transport

18.4.11 Potential cumulative traffic impacts include the following:

• HGV and other traffic movements on the local road network during the decommissioning of Dungeness A care and maintenance period (first 15 years);

• HGVs movements associated with mineral extraction works;

• Peak season visitor and employee generated trips to the Lydd Golf Club Hotel; 18.4.12 The increase in traffic movements as a result of 2 million passengers can be accommodated within the local road network as the proposed roundabout at Hammonds Corner will be built before these passenger numbers are reached.

18.4.13 Whilst the cumulative impact of these vehicles and particularly HGVs movements is expected to result in a significant adverse impact on the local road network, this has been taken into account in this ES. The proposed roundabout at Hammonds Corner has been designed to accommodate the increase in traffic from both LAA and these other current and future works.

Air Quality

18.4.14 Potential cumulative impacts to air quality may result from dust arising as a result of the Dungeness decommissioning works and local mineral extractions (although this will tend to be a local impact) and emissions from vehicles, aircraft, and construction / extraction plant. However the severity of such impacts is likely to be reduced by the areas coastal location and regular sea breezes, as well as the implementation of EMPs during the works. No significant cumulative impacts are expected.

Noise & Vibration

18.4.15 Whilst all of the proposed works will generate noise, such impacts are likely to be localised and cumulative impacts are likely to be of only minor significance, especially in comparison to aircraft noise events, although even these will be limited in number and duration. No cumulative vibration impacts are anticipated due to the location of the developments being sufficiently far away from each other.

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Socio-economic

18.4.16 Whilst the decommissioning of Dungeness A will provide short-term employment during the works, overall it will reduce levels of local employment, although the other developments will add to the employment opportunities in the area. Lydd and the surrounding area needs local employment opportunities to be actively encouraged and cumulative impacts to the local economy are considered to be of major positive benefits.

18.5 Summary

18.5.1 There are a number of projects taking place within the surrounding area that have the potential for cumulative impacts with the proposed development. Issues that may arise include potentially adverse impacts on water quality, ecology, traffic, air quality, noise and beneficial impacts to the local economy. Mitigation for many of these have been included throughout this ES, with mitigation for impacts to traffic (including construction of a new roundabout at Hammond’s Corner) and ecology (including agreement of biodiversity action plan and bird hazard mitigation plan) considered the most significant. The cumulative economic impacts of the proposed developments are considered to be both beneficial and significant, and contribute directly to local initiatives regarding regeneration and employment in the region.

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CHAPTER 19

MITIGATION TABLES

CHAPTER 19 LAA CONSTRUCTION MITIGATION TABLES RUNWAY EXTENSION ES

Table 19.1 - Key Mitigation for Construction Phase Impacts

Area Aspect Mitigation

A Construction Health & Safety Plan (CHSP) and Construction Environmental Management Plan (CEMP) will be required from the Management contractor which will include both work method statements and risk tables to manage the key environmental risks outlined in the ES. General Plans The plans will meet the requirements of all relevant legislation, and the airport management will ensure that these plans meet the requirements of the regulatory authorities.

All personnel will have appropriate instruction on the use of these management plans to minimise environmental risks with specific General Training instruction on issues such as spill avoidance, hazard management and special precautions for sensitive areas.

The CEMP will meet the requirements of the Construction (Design and Management) Regulations (1994), the Health and Safety at Work Act, the Management of Health and Safety at Work Regulations, the Control of Substances Hazardous to Health Regulations and Health and General the Construction (Health, Safety and Welfare) Regulations. It will specifically require all works to be properly barriered off and Safety adequate signage installed to indicate appropriate Personal Protective Equipment (PPE) required (and to be worn at all times), and all health and safety equipment to be available onsite, including spill kits fire extinguishers etc.

LAA will work with Natural England to further understand the buried geomorphology of the site. Site investigations will be undertaken in areas of potential geomorphological importance areas prior to construction to provide further information on the importance of the local geomorphology. Work will involve a surface topographic survey of the site; hand coring of soils and analysis to provide a detailed Ground Conditions Geomorphology description of sediments encountered. In addition a single deep borehole will be drilled to determine the ancient sedimentary record on the site (at a location to be decided following completion of the hand coring) with optically-stimulated luminescence (OSL) dating of sediments from two levels within the deep borehole to provide a chronology of back-barrier sediment in-filling of the marshland during historical times.

Whilst no contamination is expected in the proposed area for the runway extension, any requirement for targeted site investigations would be agreed with the regulatory authorities. Should any potentially contaminated land be encountered, it will be analysed for Existing Land Ground Conditions hazardous materials and an appropriate remediation strategy agreed with the regulators before construction works commence. In Contamination addition, should any contaminated ‘hot-spots’ be identified by onsite contractors, work in that area will stop until the material present has been analysed and appropriate remediation agreed.

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Area Aspect Mitigation

Risks of contamination to the underlying geology and soils of the area will be minimised through implementation of the CEMP, with particular requirements that:

• Fuel/oil tanks and chemical storage tanks/areas to be provided with locks and placed on compacted areas, within bunds that have a capacity equal to 110% of the storage capacity of the largest tank, to prevent spilled materials from leaking offsite. All valves and Ground Conditions Spill Prevention couplings to be located within the bunded area;

• Any excavated material will be placed on hardstanding located least 20m from the nearest watercourses and covered;

• All clean material arising from construction works will be spread evenly within the application boundary over the clear and graded area (but not within 20m of watercourses) before grassing;

Ecology Soil handling Soil will be stripped, handled, stored and managed carefully for re-use on site wherever possible.

Stormwater management measures will be developed in consultation with the Local Authority, EA and the IDB and installed by the Surface Water Water Resources contractor prior to commencement of works. These will prevent erosion of any exposed substrates and/or sediment laden or Drainage contaminated water draining offsite into adjacent controlled waters (eg through the use of treatment/detention ponds).

Approximately 1256m of new drains have been included in the runway design, in consultation with the EA and the IDB, which will connect to the existing drainage features and will replicate the abandoned drains in width and depth. This will ensure that storage Water Resources Run-off Capacity volumes of surface water are greater or equal to those abandoned and that adequate storage is available for runoff volumes from the runway extension during peak rainfall ‘events’.

Specific water-resource protection measures will be included within the CEMP, such as:

• Oil interceptors will be provided in any drainage system downstream of possible oil/fuel pollution sources. The oil interceptors will be emptied and cleaned regularly to prevent the release of oils and grease into the stormwater drainage system. Waste Water Resources Water Quality materials will be disposed of at an appropriate facility. Any surface water contaminated by hydrocarbons which are used during the construction phase will be passed through these oil/grit interceptor(s) prior to discharge;

• Measures will be taken to ensure that no leachate or any surface water that has the potential to be contaminated will enter directly or indirectly into any watercourse, underground strata or adjoining land;

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Area Aspect Mitigation

• Water inflows to excavated areas will be minimised by the use of lining materials, good house keeping techniques and by the control of drainage and construction materials in order to prevent the contamination of groundwater;

• Refuelling of construction vehicles and equipment will be restricted to a designated area with properly designed fuel tanks and bunds and appropriate operating procedures;

• All channels and attenuation ponds (permanent or temporary) will be maintained to prevent flooding and overflowing and protected where necessary against erosion;

• All temporary hardstanding areas and exposed surfaces or storage areas will be designed to discharge to attenuation ponds, and will not discharge to watercourses or flow offsite in an uncontrolled manner;

• Portable chemical toilets and sewage holding tanks will be placed onsite to accommodate sewage generated by the construction workforce. A licensed contractor will be responsible for appropriate disposal and maintenance;

• Handling and storage of any potentially contaminating material will only occur in designated areas to prevent discharge to watercourses, the drainage system, or offsite;

• No washdown areas will be located near watercourses, or open drains and washdown waters will be collected and directed to appropriate treatment; and

• A spill management plan will be in place at all times.

Water Quality A water quality monitoring program will be developed for the project in conjunction with the regulatory authorities. Water Resources Monitoring

Solid Waste The CEMP will include measures to control waste production, based on the Department of Trade and Industry (DTI) voluntary code of Management Management practice. Plans

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Area Aspect Mitigation

Solid Waste Spoil An exemption will be sought from the Environment Agency under Paragraph 19A, Schedule 3, to the Waste Management Licensing Management Management Regulations 1994 (as amended) for the excavation and reuse of soil as part of the construction works.

Connections & Any utilities’ connections required will be below ground and routed to avoid impacts on sensitive areas. Farm access in the surrounding Land Use Access area will be maintained with no restrictions.

Habitat The CEMP will include habitat management plans to ensure adequate protection of important habitats from accidental leaks or spills of Ecology Management oil or other petroleum-based products. Areas outside the footprint will be fenced off to prevent unauthorised access by site plant or Plans personnel, and vehicle movement will be confined to existing roads and access tracks.

Works will be scheduled wherever possible to avoid the various species’ periods of particular vulnerability. For example vegetation clearance will only be done outside the bird nesting season, works in areas of suitable reptile habitat would be undertaken during the Ecology Timing of Works summer months, when reptiles are active (rather than during the hibernation period) and maintenance work will be undertaken outside of the water shrew-breeding season (which is April-September).

The new drainage ditches (and wetland habitats) will be created to be sympathetic to the local ecological conditions and aim to enhance Compensation and recreate existing habitats, maintaining natural bank conditions where possible and use natural materials for bank protection as Ecology for loss of ditch required. The recreation of aquatic and terrestrial habitats will benefit a variety of species including great crested newt, medicinal leech habitat and otter.

Any drainage ditches to be disturbed will be strimmed to ground level prior to work commencing, to encourage any animals present to Work in and seek refuge elsewhere. Following any species-specific measures require the drains will be carefully emptied and any animals present Ecology around ditch allowed to disperse naturally over a period of several days. The loss of marginal and bankside vegetation will be minimised and the use habitats of hard engineering structures along the banks avoided. Works durations will be minimised to reduce impacts of silt disturbance upon aquatic and terrestrial habitats.

Recreation of Appropriate aquatic and bankside vegetation will be planted to maximise the ecological interest of the drainage ditches following advice Ecology ditch habitats from NE, to provide suitable resources for species such as water vole and medicinal leech.

Further surveys will be undertaken for Medicinal leech in the drainage ditches to the north of the runway in advance of any works commencing. The results of these surveys will inform any mitigation required which strategy would be devised in consultation with NE Ecology Medicinal Leech and may involve a translocation exercise to an appropriate receptor site. Any surveys and any translocation activities would be carried out following best practice guidance and under DEFRA licence by an EN licensed surveyor.

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Area Aspect Mitigation

No relocation of individuals is proposed as the most valuable areas for reptiles onsite would not be affected by construction works. However, as animals may be present throughout the site measures to avoid their incidental mortality will be employed, and areas to be Ecology Reptiles impacted by the works would be subject to targeted habitat management to reduce their attractiveness. For example, grass would be kept short and scrub covered removed to discourage use by reptiles. Considerable tracts of suitable habitat in the vicinity are available for any displaced reptiles.

Further great crested newt surveys will be undertaken of the drainage ditches to the north of the runway prior to construction works Great Crested commencing. Should any great crested newts be found in the ditches, population size/class will be assessed and the information used Ecology Newt to inform an appropriate strategy of translocations to suitable waterbodies and terrestrial habitat to the east of the runway. Any such mitigation strategy (including any requirement for the creation of replacement habitat) would be agreed in advance with NE.

Given the presence of these animals in the drainage ditches to be lost, specific works will be undertaken to exclude them from proposed working areas. The mitigation strategy will follow best practice guidance and be agreed in advance with the EA and NE prior to any Water Vole / works commencing, and may include a trapping, removal and release exercise. The loss of water vole habitat in the long term will be Ecology Water Shrew mitigated for by the creation of new drainage ditches around the runway. Further surveys will be undertaken to establish the presence of water voles and shrews in the wider area and opportunities to enhance habitat management for these species will be developed in consultation with NE.

Bird Conservation Skylark and As part of the BAP, and in order to mitigate for small areas of lost skylark and meadow pipit breeding habitat, LAA will put aside an & Hazard Meadow Pipit appropriate (larger) area of land on or near the airfield to be managed specifically to provide good nesting conditions for these species. Management breeding

Bird Conservation No other significant impacts are expected to arise from construction works. General & Hazard

An archaeological watching brief will be developed for earthmoving works in accordance with the requirements of PPG 16 and the Local Cultural Heritage Watching Brief Plan Policy.

A programme of environmental soil sampling will be undertaken to investigate palaeo-environmental and marsh formation deposits as Cultural Heritage Geomorphology described under “Ground Conditions” above.

Landscape & No significant impacts are expected to arise from construction works. General Visual Impact

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Area Aspect Mitigation

Construction An agreed route and schedule for construction vehicles will be set up in agreement with Shepway District Council in order to reduce the Traffic Traffic level of disruption on the surrounding road network.

The CEMP will contain specific precautionary measures to limit dust. For example the prolonged storage of materials in stockpiles will be avoided, and any such stockpiles will be located as far away as practicable from potential receptors, with slopes at angles less than the natural angle of repose of the material. Any stockpiles will also be sheeted, contained within wind barriers or damped down. Dust Air Quality Vehicles removing demolition or site clearance materials will have their loads sheeted on all sides. Crushing of material for reuse, Management transportation or disposal will be undertaken as far away as possible from sensitive receptors. The number of handling operations will be minimised, ensuring that dusty material is not moved or handled unnecessarily. Fine material will be delivered to site in bags. Drop height will be kept to a minimum.

To ensure that atmospheric dust, contaminants or dust deposits generated by the construction work do not exceed levels which could constitute a nuisance to local residents or damage to ecosystems, visual inspections of dust, odours and exhaust emissions will be undertaken along airport approach roads and along the boundary of the construction works / sensitive ecosystems, by a trained and Air Quality Dust Monitoring competent person on a weekly basis. If dry windy weather prevails then the rate of dust monitoring will be increased to daily initially and 4 times per day if levels remain high. If, despite the implementation of best practicable means of dust/odour mitigation, levels of dust soiling, odours or visible exhaust smoke remain unacceptable, the site manager will ensure the cessation of the relevant generating construction activities.

Air Quality Smoke Burning of waste material will be avoided.

Hardstanding areas for vehicles entering, parking and leaving the site will be provided, with wheel washing facilities at access points. Site Roads and Site roads will be cleaned regularly and damped down if necessary. Site vehicle movements will be kept to a minimum and, where Air Quality Haulage possible, restricted to paved haulage routes. Vehicle speeds will be limited to 20 km/h or less on surfaced roads and 10 km/h on unpaved surfaces. The idling of vehicles will be kept to a minimum.

Mechanical Static and mobile plant will be well maintained, regularly serviced and located as far away as practicable from sensitive receptors. Air Quality Operations

Normal working All construction activities will be carried out in accordance with the recommendations of BS 5228, and appropriate but practicable Noise & Vibration hours working hours and noise limits will be agreed between the Contractor and Local Authority.

Noise & Vibration Non-normal Specific method statements and risk assessments will be required for night working and the contractor will inform and agree any works

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Area Aspect Mitigation

working hours in advance with the Environmental Health Officer, whilst also informing affected residents of the works to be carried out outside normal hours who would be provided with a point of contact for any queries or complaints.

All vehicles and mechanical plant used for construction will be fitted with effective exhaust silencers, and regularly maintained and inherently quiet plant will be used where appropriate. All major compressors will be sound-reduced models fitted with properly lined and Plant & vehicle sealed acoustic covers which will be kept closed whenever the machines are in use and all ancillary pneumatic percussive tools will be Noise & Vibration maintenance fitted with mufflers or silencers of the type recommended by the manufacturers. All ancillary plant such as generators, compressors and pumps will be positioned so as to cause minimum noise disturbance. If necessary, temporary acoustic barriers or enclosures will be provided

Socio-Economic Employment No further mitigation is proposed for construction impacts over and above those outlined in the previous rows.

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Table 19.2 Key Mitigation for Operational Phase Impacts

Area Aspect Mitigation Environmental General The airport will produce an Environmental Management Plan (EMP) based on the ISO14001 standards. Management All staff that work in the airport will undergo appropriate environmental training, including emergency spill response. The EMP will outline General Training the training requirements in more detail. Ground No mitigation measures are required for the operational phase of the terminal development. Geomorphology Conditions Drains within the airport boundary owned by the airport will be maintained by LAA (in consultation with the IDB) to ensure that there are Water Internal Drainage no obstructions to drainage or reduced storage volumes which could cause localised flooding, and that adequate water storage is present Resources throughout the system. LAA will monitor these facilities to ensure they remain effective. Water External Drains outside the airport boundary are owned by the IDB which undertakes annual maintenance of these drains to ensure they maintain Resources Drainage their drainage capacity and efficiency. LAA will assist the IDB in this process as required. Water The proposed drainage system for the runway has been designed to ensure that adequate volume is available to avoid any additional Flood Risk Resources flood risk. Water Spill The EMP will include spill prevention procedures and risk control measures to avoid contaminants entering watercourses. Such Resources Management measures will be agreed with the EA, IDB and NE. The airport has adequate water and sewage resources for handling 300k passengers, and whilst long-term options are currently under Water Sewage & Water consideration for connections to the sewer mains and/or installation of an on-site sewage treatment plant, this is not required at this Resources stage. LAA will produce an auditable Waste Management Strategy for the airport which will identify how individual waste streams are managed, Solid Waste Management collected, and disposed of (airside and landside) and which will focus on the top levels of the Waste Hierarchy (i.e. Reduce, Reuse, and Management Plans Recycle) before other options are employed (e.g. disposal to landfill). As the majority of waste is likely to be produced by passengers, waste prevention and minimisation programmes will also be targeted at the airlines Adjacent land The airport will work closely with local landowners and the Local Authorities to encourage local land use practices which discourage bird Land Use uses strike species and do not interfere with licensed airport operations. As part of the long-term management of the site, a habitat and biodiversity action plan (BAP) will be developed for the airport in discussion with NE. This will aim to maximise the ecological benefits of the airport (whilst not compromising safety), using complimentary Biodiversity Ecology habitat management initiatives to provide nature conservation benefits. The plan will include both habitat and species specific actions and Action Plan will ensure that potential impacts on valuable habitats and species continue to be either avoided or effectively mitigated whilst also allowing for the continued input of positive biodiversity enhancement measures.

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Area Aspect Mitigation Ecological Key elements of the existing system of ecological monitoring and management will continue to be undertaken following consultation with Ecology Monitoring the relevant consultees. Habitat suitability for reptiles, invertebrates and small mammals will be encouraged in locations away from the operational areas of the Species-specific Ecology site. Measures to conserve protected species will be developed and activities likely to affect such species will only be carried out under measures licence and at appropriate times of year. Habitat management of waterbodies and drainage ditches in the vicinity of the site will be undertaken in agreement with NE, the IDB and Aquatic habitat Ecology EA, using appropriate management such as those outlined below. management

To reduce the risk of siltation and contamination of watercourses during operation, vegetated ditch banks will be enhanced (following Ditch Buffer Ecology advice from NE) and additional buffer zones planted to act as filters to retain silt and potential contaminants. The banks of the Strips watercourses will be graded within the buffer zones in certain sections to create wet shelves to support a variety of plants.

Work will be from downstream to upstream to allow seeds and invertebrates to return to disturbed areas downstream. Work will be from Ditch Working one bank, as far back as possible from the water’s edge to minimise compaction of vegetation and burrows. Excavated material will be Ecology practices stored overnight on the bank to allow invertebrates and amphibians to return to the water; Ditch management will be scheduled for late autumn / winter to avoid disturbing water voles whilst breeding and on short stretches of time in rotation.

Management will involve strimming /cutting of bankside vegetation on rotational basis (alternate and opposite strips of waterway banksides in alternate years) to approximately 15cm in height. Where possible, a fringe of uncut vegetation wil be left at the waters edge. Ditch Vegetation Ecology Cuttings will be disposed of away from the buffer strip to prevent smothering of bankside vegetation. If bank reinforcement is necessary to Management prevent erosion and collapse, ‘soft’ reinforcement techniques will be used which stabilise banks but also allow water voles to burrow and promote potential food growth;

Bird LAA will work with NE and the RSPB to develop appropriate methods to ensure that the ornithological value of the area is retained (and Conservation & Wintering Birds where possible enhanced) as a result of the proposed project. As part of this, LAA propose to fund a research study to further assess the Hazard Mitigation potential for air traffic to disturb wintering (and breeding) birds, in the area. Management Bird Conservation & Wintering Birds A series of wintering bird monitoring surveys will be undertaken or financed by the airport, using, as a minimum, the same methodology Hazard Monitoring as the field survey used in 2005/06, for a minimum of ten years. Management

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Area Aspect Mitigation Bird LAA will work with NE and RSPB to develop an ‘airfield biodiversity action plan’, which will be designed in conjunction with the birdstrike Conservation & Breeding Birds hazard management plans, to ensure that those species not constituting a birdstrike hazard are able to continue breeding within and Hazard Mitigation (BAP) around the airfield. Management Bird Conservation & Breeding birds A monitoring programme (to the same methodology as the 2006 survey) will be undertaken or financed by the airport for a minimum of Hazard (monitoring) ten years, with the study outcome compared to the 2006 baseline. Management Bird Conservation & A regular monitoring programme of the effectiveness of bird control will be maintained as part of the bird hazard control programme. The Bird Hazard Hazard results of this will be used to manage appropriate change in conjunction with the airfield BAP. Management Bird Conservation & LAA will review their safeguarding approach, in consultation with NE and the RSPB, to ensure that a balance is met between recognising Safeguarding Hazard the importance of the wetland habitat around the airport for bird conservation and the need to minimise bird strike hazard. Management Landscape General There are no mitigation measurements required. Visual Amenity Cultural General There are no mitigation measurements required. Heritage LAA will develop a Travel Plan to encourage the use of sustainable modes of transport for both passengers and staff and reduce the Traffic & Travel Plan reliance on private cars. The use of sustainable transport options for travel to and from the site will be promoted and contributions made Transport to enhancing the existing bus services between Lydd and Ashford International Station via the Airport. Traffic & Hammonds LAA will work with the local authorities to develop an appropriate upgrade to the Hammonds Corner ‘t-junction’ (eg a roundabout or Transport Corner signalling) to allow for a far greater level of traffic to be accommodated and the junction to function more effectively. To ensure that nearby ‘C’ and unclassified roads are not affected by the increased traffic, the airport will be clearly signposted from the Traffic & Signage Brenzett junction encouraging all traffic to travel to the airport via the A259 and the B2075. All travel information for passengers using Transport LAA will identify the preferred route as well as suggesting public transport alternatives.

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Area Aspect Mitigation LAA will develop an air quality management strategy. Particular emphasis will be placed on the reduction of emissions for gate activities by reducing time spent on APU; using low emission ground support equipment; reducing time spent with aircraft and vehicle engines Air Quality idling; and increasing efficiency of use of aircraft support vehicle. Aircraft will also be encouraged to operate in the most fuel efficient Air Management manner during LTO cycles by minimising the time of aircraft spent on hold on runways; minimising the thrust used during take-off, climb- out and approach; and minimising the time spent on reverse thrust during landing roll. Spillages and fugitive losses of VOCs from refuelling operations will also be minimised. Air Monitoring A long-term air quality monitoring study will be developed in association with the regulatory authorities. LAA will develop a Noise Management Plan to comply with the International Civil Aviation Organisation (ICAO) detailed guidelines for a Noise & Noise ‘balanced approach’ to managing aircraft noise (as outlined Directive EC/2002/30). This will balance the needs of the airport with the Vibration Management concerns of the local affected residents, through the use of a range of mitigation measures including those outlined below. Noise & Landing / The airport operators will introduce noise-abatement operating procedures such as a penalty system to fine pilots using excessive thrust Vibration Departure Noise when departing or arriving at LAA. The money from these fines will go into a community fund to benefit the local area. Location options for ground operations will be reviewed to ensure that nearby sensitive receptors are not subject to unnecessary noise Noise & Ground Noise due to taxiing aircraft, engine testing and other sources of ground noise. The requirement for Noise Abatement Zones (in which there are Vibration restrictions on ground activity) will be reviewed. Noise & Sensitive The airport will provide secondary glazing for Greatstone Primary School to minimise the likelihood of increased noise levels affecting Vibration Receptors learning and ability at this school resulting from airport operations. The airport will establish clear lines of communication with local residents, such that concerns regarding noise from airport operations can Noise & Communication be addressed, in the first instance, directly to the airport. Vibration

LAA will provide permanent external noise monitoring stations, in order to quantify and monitor noise levels close to the nearest affected Noise & Noise Monitoring sensitive receptors due to the airport operations. Appropriate monitoring positions will not be unduly influenced by other noise sources Vibration and will be agreed in consultation with the Local Authority. Socio-Economic Employment Employment impacts associated with each scenario are all positive, and therefore require no mitigation.

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