LONDON ASHFORD AIRPORT

LONDON ASHFORD AIRPORT AT

TERMINAL BUILDING ENVIRONMENTAL STATEMENT

December 2006

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

LONDON ASHFORD AIRPORT

TERMINAL BUILDING 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

TERMINAL BUILDING ES

ENVIRONMENTAL STATEMENT - TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS AND TERMS 1 INTRODUCTION 1 2 EIA METHODOLOGY 20 3 LYDD AIRPORT 26 4 PROJECT DESCRIPTION 35 5 PLANNING POLICY FRAMEWORK 50 6 GROUND CONDITIONS 85 6.1 Introduction 86 6.2 Legislative Drivers 86 6.3 Assessment Methodology 87 6.4 Baseline Environment (Existing Conditions Scenario) 88 6.5 Baseline Environment (Future Assessment Conditions Scenario) 91 6.6 Predicted Impacts (Construction Works) 91 6.7 Predicted Impacts (Operational Impacts) 92 6.8 Proposed Mitigation (Construction Impacts) 92 6.9 Proposed Mitigation (Operational Impacts) 94 6.10 Residual Effects 94 6.11 Summary 95 7 WATER RESOURCES AND FLOOD RISK 96 7.1 Introduction 97 7.2 Legislative Drivers 97 7.3 Assessment Methodology 97 7.4 Baseline Environment (Existing Conditions Scenario) 98 7.5 Baseline Environment (Future Assessment Conditions Scenario) 103 7.6 Predicted Impacts (Construction Works) 104 7.7 Predicted Impacts (Operational Impacts) 105 7.8 Proposed Mitigation (Construction Impacts) 106 7.9 Proposed Mitigation (Operational Impacts) 107 7.10 Residual Effects 108 7.11 Summary 108

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8 SOLID WASTE MANAGEMENT 110 8.1 Introduction 111 8.2 Legislative Drivers 111 8.3 Baseline Environment (Existing Conditions Scenario) 116 8.4 Baseline Environment (Future Assessment Conditions Scenario) 116 8.5 Predicted Impacts (Construction Works) 117 8.6 Predicted Impacts (Operational Impacts) 118 8.7 Proposed Mitigation (Construction Impacts) 118 8.8 Proposed Mitigation (Operational Impacts) 119 8.9 Residual Effects 121 8.10 Summary 122

9 LAND USE 123 9.1 Introduction 124 9.2 Legislative Drivers 124 9.3 Assessment Methodology 125 9.4 Baseline Environment (Existing Conditions Scenario) 127 9.5 Baseline Environment (Future Assessment Conditions Scenario) 131 9.6 Predicted Impacts (Construction Works) 132 9.7 Predicted Impacts (Operational Impacts) 132 9.8 Proposed Mitigation (Construction Impacts) 133 9.9 Proposed Mitigation (Operational Impacts) 133 9.10 Residual Effects 134 9.11 Summary 134

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10 ECOLOGY AND NATURE CONSERVATION 135 10.1 Introduction 136 10.2 Legislative Drivers 136 10.3 Assessment Methodology 137 10.4 Baseline Environment (Existing Conditions Scenario) 144 10.5 Baseline Environment (Future Assessment Conditions Scenario) 154 10.6 Predicted Impacts (Construction Works) 155 10.7 Predicted Impacts (Operational Impacts) 157 10.8 Proposed Mitigation (Construction Impacts) 158 10.9 Proposed Mitigation (Operational Impacts) 159 10.10 Residual Effects 160 10.11 Summary 160

11 BIRD CONSERVATION AND HAZARD MANAGEMENT 161 11.1 Introduction 162 11.2 Legislative Drivers 162 11.3 Assessment Methodology 163 11.4 Baseline Environment (Existing Conditions Scenario) 168 11.5 Baseline Environment (Future Assessment Conditions Scenario) 191 11.6 Predicted Impacts (Construction Works) 192 11.7 Predicted Impacts (Operational Impacts) 192 11.8 Proposed Mitigation (Construction Impacts) 195 11.9 Proposed Mitigation (Operational Impacts) 196 11.10 Residual Effects 201 11.11 Summary 202

12 LANDSCAPE AND VISUAL AMENITY 203 12.1 Introduction 204 12.2 Legislative Drivers 204 12.3 Assessment Methodology 204 12.4 Baseline Environment (Existing Conditions Scenario) 209 12.5 Baseline Environment (Future Assessment Conditions Scenario) 214 12.6 Predicted Impacts (Construction Works) 214 12.7 Predicted Impacts (Operational Impacts) 215 12.8 Proposed Mitigation (Construction Impacts) 217 12.9 Proposed Mitigation (Operational Impacts) 218 12.10 Residual Effects 219 12.11 Summary 219 Table 12.4 220

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13 CULTURAL HERITAGE AND HISTORIC ENVIRONMENT 227 13.1 Introduction 228 13.2 Legislative Drivers 228 13.3 Assessment Methodology 231 13.4 Baseline Environment (Existing Conditions Scenario) 234 13.5 Baseline Environment (Future Assessment Conditions Scenario) 241 13.6 Predicted Impacts (Construction Works) 241 13.7 Predicted Impacts (Operational Impacts) 241 13.8 Proposed Mitigation (Construction Impacts) 242 13.9 Proposed Mitigation (Operational Impacts) 242 13.10 Residual Effects 242 13.11 Summary 243

14 TRAFFIC AND TRANSPORT 244 14.1 Introduction 245 14.2 Legislative Drivers 245 14.3 Assessment Methodology 245 14.4 Baseline Environment (Existing Conditions Scenario) 248 14.5 Baseline Environment (Future Assessment Conditions Scenario) 253 14.6 Predicted Impacts (Construction Works) 258 14.7 Predicted Impacts (Operational Impacts) 259 14.8 Proposed Mitigation (Construction Impacts) 264 14.9 Proposed Mitigation (Operational Impacts) 265 14.10 Residual Effects 266 14.11 Summary 267

15 AIR QUALITY 268 15.1 Introduction 269 15.2 Legislative Drivers 271 15.3 Assessment Methodology 273 15.4 Baseline Environment (Existing Conditions Scenario) 280 15.5 Baseline Environment (Future Assessment Conditions Scenario) 285 15.6 Predicted Impacts (Construction Works) 269 15.7 Predicted Impacts (Operational Impacts) 290 15.8 Proposed Mitigation (Construction Impacts) 295 15.9 Proposed Mitigation (Operational Impacts 297 15.10 Residual Effects 298 15.11 Summary 298

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16 NOISE AND VIBRATION 300 16.1 Introduction 301 16.2 Legislative Drivers 301 16.3 Assessment Methodology 301 16.4 Baseline Environment (Existing Conditions Scenario) 308 16.5 Baseline Environment (Future Assessment Conditions Scenario) 311 16.6 Predicted Impacts (Construction Works) 316

16.7 Predicted Impacts (Operational Impacts) 318 16.8 Proposed Mitigation (Construction Impacts) 323 16.9 Proposed Mitigation (Operational Impacts) 324 16.10 Residual Effects 325 16.11 Summary 325

17 SOCIO-ECONOMIC 327 17.1 Introduction 328 17.2 Assessment Methodology 328 17.3 Baseline Environment (Existing Conditions Scenario) 333 17.4 Baseline Environment (Future Assessment Conditions Scenario) 346 17.5 Predicted Impacts (Construction Works) 346 17.6 Predicted Impacts (Operational Impacts) 347 17.7 Proposed Mitigation (Construction Impacts) 352 17.8 Proposed Mitigation (Operational Impacts) 352 17.9 Residual Effects 353 17.10 Summary 353

18 SUSTAINABILITY 355 18.1 Introduction 356 18.2 Legislative Drivers 356 18.3 Sustainability of the Proposed Terminal Design 362 18.4 Sustainability Appraisal 366 18.5 Summary 368

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19 CUMULATIVE IMPACTS 375 19.1 Introduction 376 19.2 Legislative Drivers 376 19.3 Assessment Methodology 376 19.4 Assessment of Cumulative Effect 378 19.5 Summary 385

20 SUMMARY TABLES 386

20.1 Construction Mitigation 387

20.2 Operational Mitigation 392

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TERMINAL DEVELOPMENT ES - LIST OF FIGURES LYDD AIRPORT 3.1 Airport Location 3.2 Current Facilities & Proposed Terminal Building Location 3.3 Existing Circuit Pattern 3.4 ILS Non-Directional Beacon 3.5 ILS Approach Offset

PROJECT DESCRIPTION 4.1 Proposed Site Plan Proposed Development 4.2 Proposed Site Plan Proposed Development 4.2a Proposed Ground Floor Plan 4.2b Proposed First Floor Plan 4.3 Proposed Site Sections Proposed Development 4.4 Proposed Site Sections Proposed Development 4.5 Proposed Elevations Proposed Development 4.6 Proposed Elevations Proposed Development 4.7 Proposed Terminal Building Alternatives 4.8 Proposed Car parking to Accommodate 300,000 Passengers 4.9 Proposed Car parking to Accommodate 500,000 Passengers

GROUND CONDITIONS 6.1 Soil Types 6.2 Geology Map 6.3 Groundwater Vulnerability 6.4 Existing and proposed SSSI and CBR Locations Undertaken Indicated

WATER RESOURCES AND FLOOD RISK 7.1 River Quality 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 of Northern Drainage Ditches 10.6b Aquatic Mammals Survey Northern Drainage Ditches

BIRD CONSERVATION AND HAZARD MANAGEMENT 11.1 Breeding Birds Survey Area (2006) 11.1 (Legend) 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 Influnce

CULTURAL HERITAGE 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 Passengers by District Home Borough of South East Air Passengers 14.2 Drive Time Catchment for LAA 14.3 Distribution of Vehicle Trips on Surrounding Road Network 14.4 Locations of Traffic Surveys 14.5 Hammonds Corner 2009 -August Flows Baseline 14.6 Proposed Junction Improvements to Hammonds Corner Roundabout 14.7 Brenzett - 2009 Baseline August Flows 14.8 Hammonds Corner 2010 August Flows Terminal Proposed Development 14.9 Brenzett 2010 August Flows Proposed Development 14.10 Proposed Construction Vehicle Route 14.11 Traffic Flows Increase Proposed Development

AIR QUALITY 15.1 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 ), emissions based on current (2005) airport activities 15.4 Annual Mean Nitrogen Deposition from Local Sources (kgN/ha/yr), emissions based on current (2005) airport activities. 3 15.5 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ) emissions based on baseline airport activities. 3 15.6 Total Ambient Air Annual Mean Nitrogen Dioxide (NO2) Concentrations (μg/m ), emissions based on LAA serving 300,000 passengers. 15.7 Annual Mean Nitrogen Deposition from Local Sources (kgN/ha/yr), emissions based on LAA serving 300,000 passengers. 3 15.8 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ), emissions based on LAA serving 300,000 passengers. 3 15.9 Total Ambient Air Annual Mean Nitrogen Dioxide (NO2) Concentrations (μg/m ), emissions based on LAA Phase 1 operations, serving 500,000 passengers. 15.10 Annual Mean Nitrogen Deposition from Local Sources (kgN/ha/yr), emissions based on LAA Phase 1 operations, serving 500,000 passengers. 3 15.11 Total Ambient Air Annual Mean Oxides of Nitrogen (NOx) Concentrations (μg/m ), emissions based on LAA Phase 1 operations, serving 500,000 passengers. 15.12 Roadside concentrations of nitrogen dioxide (NO2) and particulate matter (PM10), for the B2075 between Hammonds Corner and LAA approach road. 15.13 Roadside concentrations of nitrogen dioxide (NO2) and particulate matter (PM10), for the A259 through New Romney.

NOISE & VIBRATION 16.1 Baseline Noise Monitoring Positions 16.2 INM Noise Contours Baseline 16.3 INM noise contours for 300,000 Passengers with Extension 16.4 INM Noise Contours for 500,000 Passengers per year 16.5 Indicative Night Time Noise Contours

SOCIOECONOMIC 17.1 Education and Health Services for Lydd and the Surrounding Area

CUMULATIVE EFFECTS 19.1 Cumulative Impacts - Proposed and Existing Developments

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LIST OF PLATES

LANDSCAPE AND VISUAL AMENITY Plate 12.1 Looking south east from the B2075 c.140m south of its junction with the A259 at Hammond’s Corner; 20.2.1 Plate 12.2 Looking south west from just south of where the public footpath crosses the Romney Hythe and Dymchurch Railway line approximately 350m south of the eastern end of Church Lane, New Romney; Plate 12.3 Looking south west from dune tops at the back of Greatstone-on-Sea public car park; Plate 12.4 Looking west from the shingle platform at the back of the Romney Sands holiday park at a point approximately 200m to the south of the causeway that leads to the Sound “Mirrors”. Plate 12.5 Looking north west from the northern extremity of the shingle where it gives way to farmland; Plate 12.6 Looking north west from the public footpath just to the south of the Sound “Mirrors” information plaques; Plate 12.7 Looking north west across the Dungeness shingle ridges from the west end of Taylor Road, Lydd-on-Sea; Plate 12.8 Looking north west from the earthworks just to the north of the old coastguard cottages at Dungeness Point; Plate 12.9 Looking north east from Dungeness Road approximately 800m east of the Dungeness Nature Reserve Visitor Centre; Plate 12.10 Looking north east from Denge Marsh Road at the point where the public footpath joins it in the vicinity of Manor Farm; Plate 12.11 Looking north east from the junction of Tourney Road and Robin Hood Lane on the south east edge of Lydd; Plate 12.12 Looking south east from the point on the airport entrance road at which the proposed terminal building becomes visible, approximately 150m east of the B2075 Romney Road. Plate 12.13 M1 Daytime: Looking south east from the B2075 approximately 140m south of its junction with the A259 at Hammond’s Corner; Plate 12.14 M2 Daytime: Looking south west from the west end of Baldwin Road, Greatstone-on-Sea; Plate 12.15 M3 Daytime: Looking north east from Dungeness Road in the vicinity of Cockles Bridge; Plate 12.16 M4 Daytime: Looking north east from the eastern edge of Lydd where the public footpath to Greatstone on Sea leaves the town at the end of Oakham Drive; Plate 12.17 M5 Daytime: Looking south east across Lydd Golf Course from the public footpath that skirts the North West corner of the course; Plate 12.18 M2 Nighttime: Looking south west from the west end of Baldwin Road, Greatstone-on-Sea; Plate 12.19 M4 Nighttime: Looking north east from the eastern edge of Lydd where the public footpath to Greatstone on Sea leaves the town at the end of Oakham Drive;

TRAFFIC AND TRANSPORT Plate 14.1 Brenzett Photo 1 Plate 14.2 Brenzett Photo 2

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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 & 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 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

GLOSSARY OF LAA TERMS TERMINAL BUILDING 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

GLOSSARY OF LAA TERMS TERMINAL BUILDING 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

GLOSSARY OF LAA TERMS TERMINAL BUILDING 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 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;

GLOSSARY OF LAA TERMS TERMINAL BUILDING 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.

GLOSSARY OF LAA TERMS TERMINAL BUILDING 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 CHAPTER 1 LAA

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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.

As part of the long term aspiration, LAA proposes to build a new terminal building to the north of the existing terminal building to allow the airport to eventually accommodate up to 2,000,000 passengers per annum. However, an incremental approach has to be taken to reach this long term aspiration and accordingly this is accompanies a full planning application for a new terminal building to accommodate 500,000 passengers per annum by utilising a floorspace of 7,380 m2 (79,438 sq.ft) (referred to as the ‘Project’ of ‘Proposed Development’. The building will be constructed in a single phase with a view to the effective operation of the airport. 1.1.3 Whilst the existing terminal building can accommodate up to 300,000 passengers per annum (and currently houses a range of facilities such as offices, customs, security, restaurant and bars), when the current capacity of 300,000 passengers per annum has been reached the existing terminal will be decommissioned. Thus, the new development will itself only process up to 500,000 passengers, as the existing terminal will not be used for commercial flights. Further details on this and other elements of the proposed Project development are provided in Chapter 4 of this document.

1.1.4 The proposed terminal building development will involve both development and planning, and (ultimately) comprise a detailed planning application. The accompanying Environmental Statement (this document), assesses the impacts of the development wherever practical..

1.1.5 In addition to the proposed terminal developments, the Masterplan also includes proposals to increase the length of the existing runway by just under 20% from 1505m to 1799m, and to add a new 150m starter extension to its northern end. These works, which are the subject of a separate planning application, and for which a separate, but cross-referenced Environmental Statement has been produced, 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 payloads or

1 This figure is based on the 1987 British Airports Authority’s (BAA) Report on Lydd Airport 2 The development of LAA to 2,000,000 passengers per annum 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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quantities of fuel, hence allowing them to either transport more passengers per flight, or service a greater range of (more distant) destinations than at present.

1.1.6 As part of the supporting documentation for the Project planning application, Parsons Brinckerhoff Ltd (PB) have been commissioned to undertake an Environmental Impact Assessment (EIA) and prepare an Environmental Statement (ES) for the proposed new Terminal Building. The ES (this document) should be read in conjunction with both the 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.

1.1.7 It should be noted that whilst the proposed terminal building and runway extension 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 runway extension 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 Project and have been taken into account throughout the development of the Project design.

1.2.2 The statutory requirement to undertake an Environmental Impact Assessment (EIA) for the project 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 area of works exceeds 1 hectare. 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.

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 project 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 terminal buildings, 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 (see Appendix 1.2). The Scoping Opinion comments showing that the ES has addressed the issues raised is shown in Table 1.1 below.

3 Detailed assessment methodologies are provided in Chapter 5.

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Table 1.1 Scoping Opinion Comments (Terminal Building)

No Technical Requirement Comment Ref 1 Different alternatives to the proposals at LAA, should be examined (for example, An analysis of alternatives is included in Chapter 4 to address 4.13 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 with or without the proposed project. This scenario is addressed in each chapter. Alternative airport locations are also addressed and are part of the 4.12 project needs case. 2 It is useful to consider the distribution to all residencies of the NTS, details of Information on the public consultation programme is summarised in 1.3 public exhibitions /meetings to be held, where to obtain or view the ES, methods Chapter 1. available to comment upon the proposals and potential environmental impacts. 1.7

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 7 The layout of the airport and infrastructure, should be provided and illustrated Airport layout and infrastructure is provided in Figures 4.1 – 4.4. 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.

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No Technical Requirement Comment Ref 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 4.10 margins, surface drainage, sewage disposal or management, water supply, passenger levels are included within each Chapter. parking facilities, fuel storage areas, Instrument Landing System, access All 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 Details should be provided of pollution prevention measures, construction These issues are addressed in Chapter 4. 4.2- timescale, additional infrastructure changes and set parameters that the design 4.10 must adhere to, e.g. maximum dimensions of the terminal building, and maximum number of car parking spaces. 12 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 4.13 (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. 13 Lighting proposals should be discussed. These are addressed in Chapter 4, with visual impacts further 4.2 evaluated in Chapter 12. 12.5 14 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.

15 Changes to Policy TP25 Lydd Airport, should be reviewed and the proposal This is addressed in Chapter 5. 5.526 tested against the Policy and placed into the context of the maximum potential capacity that the airport can accommodate under existing permissions. 16 The applicant must demonstrate the need for the proposals, The need for the project is included in Chapter 4. 4.12 17 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).

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No Technical Requirement Comment Ref 18 A Construction programme is required to include phasing and duration, main The construction programme and activities are addressed in 4.9 – construction activities, (including piling), likely plant, numbers of vehicles Chapter 4. Construction impacts are addressed in each chapter. 4.10 generated and distribution over the construction period, infrastructure Waste issues are specifically addressed in Chapter 8, and noise requirements such as access arrangements and construction compounds, levels in Chapter 16. 8.5 production of construction waste: types, estimates of volume and management 16.5 (preferably reuse on site). Details of noise generating activities/equipment that may result in significant impacts, e.g. auxiliary power units should be provided. 19 Details are required of passenger forecasts, hours of operation, frequency of Anticipated flight details and passenger forecasts are addressed in 4.11 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 16.5 the busiest period in the year, and worst case impacts. the airlines using the airport the worst case scenarios have been referred to, though it is the predicted impact of the proposals that have been assessed. 20 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 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 21 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. 22 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 23 The relationship between the watercourses and the ecological integrity of the This is addressed in Chapter 10. 10.5- surrounding habitats should be described. 10.6 24 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. 10.5

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No Technical Requirement Comment Ref 25 Identification and assessment of potential pollutants during the construction and This is addressed in Chapter 7. 7.4 operation, and significant impacts on water quality should be evaluated along 7.5 with spillage of toxic pollutants during the construction and operational phases. - impacts on the environment, including any predicted changes to the volume of runoff and implications should be discussed. 26 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. 27 In case of flood risk assessment, reference should be made to PPG 25. This is addressed in Chapter 7. 7.2 28 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). 29 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. 30 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 10.2 designation would occur prior to the granting of planning permission and commencement of construction. 31 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.

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No Technical Requirement Comment Ref 32 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. 33 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. 34 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. 35 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. 36 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. 37 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 11.6 changes in feeding patterns, weather conditions, bird strike precautions. 38 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. 39 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

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No Technical Requirement Comment Ref 40 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 10.4 significance. The IEEMs guidelines for Ecological Impact Assessment (July 2005) should be used. 41 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.

42 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. 43 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. 44 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. 45 Potential landscape impacts of presence of aircraft in the sky should be This has been undertaken and is addressed in Chapter 12 12.5 considered. 46 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 47 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 48 The worst case scenario should consider weather conditions. For the landscape assessment clear conditions have been 12.3 assumed to represent a worst case (ie most visible) scenario.

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No Technical Requirement Comment Ref 49 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 Romney Marsh Research Trust. 50 Mitigation measures for significant impacts should be agreed with the County No significant effects are expected as a result of the proposed 13.6 Archaeologist. development, although an archaeological watching brief will be implemented during construction. Impacts to geological resources 6.6 are discussed in Chapter 6. 51 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. 52 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. 53 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 54 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. 55 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. 56 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 5 number of construction vehicles for the terminal proposal, and an illustration of the construction routes and access points. 57 Proposals for dust suppression measures should be included These are included in Chapter 15. 15.6

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No Technical Requirement Comment Ref 58 Baseline noise monitoring should include properties immediately adjacent to and This has been undertaken and is addressed in Chapter 16 16.6 surrounding the airport and should be done at several locations determined by identifying the most sensitive receptors, including any relevant consented 16.7 proposed developments. Separate baseline measurements for day, evening, night and weekends. 59 Sites that are important for their bird populations should be considered as This has been undertaken and is addressed in Chapter 11. 11.6 sensitive receptors. 60 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. 61 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. 62 The assessment should be according to PPG24 and noise contour maps This has been undertaken and is addressed in Chapter 16. 16.7 produced illustrating the noise level. Forecast noise levels should use measurement indices used on the baseline assessment. 63 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. 64 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. 65 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. 66 An evaluation should be undertaken of employment data, employable This has been undertaken and is addressed in Chapter 17. 17.3 – population, unemployable figures, number of people currently employed by the 17.4 airport, employment catchment area, and service industry provision in the area. 67 Prediction should be made of the number of jobs to be directly created by the This has been undertaken and is addressed in Chapter 17. 17.4 proposals during the construction, and operational stages, including an estimation of the number of indirect employment opportunities created.

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No Technical Requirement Comment Ref 68 The EIA should assess whether there are sufficient local employment resources This has been undertaken and is addressed in Chapter 17. 17.4 to meet the needs of the development and the likelihood of demand for supporting services with potential positive and negative effects

69 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. 70 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. 71 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. Instead, 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. 72 Inclusion of an impact assessment to identify, describe and evaluate the effects A cumulative impact assessment is included as Chapter 19 to 19.4 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

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No Technical Requirement Comment Ref 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 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) - These represent impacts at the 300,000 passengers per annum level with no terminal development4, and is considered the ”no project” or “do nothing” scenario, since the airport is permitted to grow to such level with its existing facilities. The scenario is currently proposed for 2009

Predicted Impacts: Construction Works

• Existing Conditions Scenario - This represents the environmental impacts that may arise during the construction of the terminal building (given that the runway extension is in place), when compared to th existing conditions. The scenario is currently proposed for 18 months prior to operating.

• Future Assessment Conditions Scenario– This represents the environmental impacts that could arise during the construction of the terminal building, were it to take place once the 300,000 passengers per annum Future Assessment Conditions (with runway extension in place) had been reached. The scenario is currently proposed for 18 months prior to operating.

Predicted Impacts: Operational Impacts

• Existing Conditions Scenario– This represents the environmental impacts that may arise during the operation of the terminal building with 500,000 passengers per annum with runway extension when compared to the conditions that are present today. This scenario is currently expected to be reached in 2010.

• Future Assessment Conditions Scenario – This represents the environmental impacts that could arise during the operation of the terminal building with 500,000 passengers per annum (and runway extension) when compared to the conditions that are present at 300,000 passengers per annum (with runway extension) given that this capacity can be reached without the proposed development in place. This scenario is currently proposed for 2010.

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:

4 Whilst not interdependent in planning terms, at an economic level the construction of the terminal building is only feasible if the runway extension has been constructed. Accordingly, the Future Assessment Conditions scenario of 2009 looks at the impacts related to traffic and airport movements associated with the runway extension in place .

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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 Project 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 iterative consideration of potential environmental impacts throughout the design and development of the Project, the work has also 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 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 5.1 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) Numbers not recorded Mar/05 London Ashford Airport (Lydd) Numbers not recorded Mar 05 Greatstone-on-Sea Numbers not recorded Apr 05 London Ashford Airport (Lydd) Numbers not recorded June 05 New Romney Assembly Rooms Numbers not recorded June 05 Dymchurch Assembly Rooms Numbers not recorded July 05 Hythe Town Hall Numbers not recorded July 05 Dymchurch Assembly Rooms Numbers not recorded Aug 05 London Ashford Airport (Lydd) Numbers not recorded

05.04.06 New Romney Assembly Rooms 80+ 12.04.06 Lydd Community Hall 60 19.04.06 London Ashford Airport (Lydd) 120 26.04.06 Hythe Town Hall 50+ 27.04.06 London Ashford Airport (Lydd) 130 10.05.06 Folkestone South Kent College Main Hall 5

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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+

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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

• 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

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• Chapter 9: Land Use

• Chapter 10: Ecology and Nature Conservation

• 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: Sustainability

• Chapter 19: Cumulative Impacts

• Chapter 20: 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 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 a separate 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);

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• 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 (overwintering 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.

1.8 Further Details

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

1.8.2 Zaher Deir

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

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CHAPTER 2

EIA METHODOLOGY

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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 Project 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 Prediction of impacts Consultation

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

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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 Project, 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 Appendix 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. This is based on the airport being able to reach 300,000 passengers per annum with no planning permission required (but for the purposes of the Terminal ES it has also been assumed that the runway extension which has been applied for separately would have been constructed by the date that the Terminal would be operational). Given the investment in the airport in the last few December 2006 Page 22 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 2 LAA

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years (as well as the assumption that in the case of a planning permission for the Terminal development applied for, the runway extension would be in place by the time the Terminal would be operational), 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 in this ES. Accordingly, the mitigation measures which the airport is proposing as part of the application are based on the impact of the 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 Impact Assessment

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 Project 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 impacts. 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 20 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 Environmental Management Plan (EMP).

2.5.3 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 included as the final chapter of this document, for easy reference.

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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”.

2.6.2 Cumulative impacts may include:

• 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. 2.6.3 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 19 of this ES.

2.6.4 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 3

LYDD AIRPORT

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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 started to operate a short-haul car transporting service across the channel to (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 from and Folkestone, and the premium cost of air-freight became prohibitive. As a result, the last 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 (approximately 1km north east), St. Marys Bay (6km north east), Littlestone-on-Sea (approximately 3km north east), Lydd-on-Sea (approx 2km south east) and Dungeness (approximately 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 to 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 connects the airport to Hastings and Rye in the west and Hythe, Folkestone and Dover in the east. The airport is located approximately 28km 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 the name of London Ashford Airport Ltd) and leasehold from Shepway District Council. Further details on the land-use 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 re-clad 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

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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.

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 sufficient for the 500,000 passenger scenario. 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

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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 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 licensed 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.

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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 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 Total4 Annual Daily Movements 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

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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extension. General Aviation is also likely to increase and the effect of this has been assessed.

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 passengers carried per 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 are 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 of the airport (by helicopter) 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 are 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.

3.7 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

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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 meets regularly to discuss issues relating to the airport and the local community and includes representation 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.

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;

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• 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 Overview

4.1.1 The proposed terminal building facility will be located to the north of the existing terminal building and will be constructed in a single phase. The building will comprise the construction of two linked rectangular structures with shallow curved roofs, one 11.6m high to the eaves and 15m in height to the top of the roof, the second 6.5m high to the eaves on the lower south west side and 12.5m high to the eaves/roof top.

4.1.2 With a floorspace of 7,380 m2 (79,438 sq.ft) and the ability to accommodate some 500,000 passengers per annum, detailed planning permission will be sought for the proposed terminal building.

4.1.3 Further details on the layout designed for the development is included below and shown in Figures 4.1-4.9. Details of the proposed construction approach and methodology are included in Section 4.9.

4.1.4 Estimated costs for the terminal development are in the order of £15M, not including costs for car-parking and access. All works are scheduled to take approximately 18 months to complete.

4.1.5 During the construction of the new terminal, the existing single-story 2,500 m2 terminal building will be retained in situ. This building, which was built in 1954 has been remodelled internally over the years and has recently undergone extensive re-cladding and refurbishment to prolong its life. At present it provides facilities to process up to 300,000 passengers per annum and forms the main link between landside and airside functions. It also houses all the current airport facilities including offices, customs, security, restaurant and bars. On completion of the works and once the current capacity of 300,000 passengers per annum is reached the existing terminal will be decommissioned. The proposed development will by itself, therefore, only process up to 500,000 passengers.

4.1.6 A number of buildings exist on the site such as the two maintenance hangars located to the north of the terminal building. These comprise of a recently reclad main hangar of approximately 2,664m2 (a double height structure of some 8m) to eaves level and a smaller hangar of approximately 441m2, both of which are used by Sky-Sure Engineering to service aircraft. Other structures onsite include workshops, a control tower, the fuel farm, fire station and the new Instrument Landing System (ILS). None of these are currently planned to be effected by the proposed development.

4.2 Terminal Design Principals

4.2.1 The proposed new terminal complex, with its associated apron (proposed apron:110m wide, 254m long), access and car parks, will act as the link between the landside access and the airside runway systems and will provide space for passenger processing and holding as well as allowing intermodal transport changes. The design has to reflect the nature and numbers of traffic anticipated, and has been developed to provide an appropriate split between domestic/international and scheduled/chartered operations whilst bearing in mind the availability of the physical space on site to accommodate these operations.

4.2.2 The design has taken into account the following principles of good design:

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• Simple Passenger Flows where passenger movements within the building are direct, avoiding cross flows and back-tracking with level changes kept to a minimum;

• Good Layout of Primary Facilities enabling passengers to move to and from aircraft with minimum staff involvement, with logical flow patterns supported by good signage to reassure passengers that they are moving in the right direction;

• Terminal security against terrorist acts (as far as possible) without causing passenger and other users undue alarm; and

• An airy, comfortable and well lit environment for passengers and employees. The use of space should allow ease of movement while at the same time providing access for passengers to the amenities, commercial activities and opportunities. 4.2.3 The design has a centralised profile, with all the major physical elements e.g. car park, passenger and baggage processing, government controls etc. concentrated together independent of any flight to deliver both economy of human resources and equipment.

4.2.4 Further details on the Terminal Design Concept are provided in the accompanying Design Statement.

4.2.5 The architectural proposals for the terminal have therefore been derived from the functional requirements of the airport and the new building is seen as a response to the requirement to process as efficiently as possible those passengers arriving and departing to and from the site. Further, the internal configuration of the building has been designed to ensure that the future expansion of the building could, as far as possible, be achieved with minimum impact on existing operations. The proposal is to offer a minimum landside elevation to arriving and departing passengers and maximise the airside elevation so that the greatest number of aircraft can be accommodated.

4.2.6 The proposed terminal building will be the first significant structure to be seen on arrival at the airport either from the air or road. Further, given the size and nature of the building, the significance of the location on the site is such that it will be exposed to view through almost 360º and therefore, the building form is seen as being significant in context with the surrounding landscape. It is therefore intended to represent a contemporary design that reflects the aspirations of those involved in the development of the site and is consistent with the modern day requirements of transportation terminal structures.

4.2.7 The building will also lie within an internationally recognised landscape and must be seen as responding sensitively to this landscape. With reference to examples of existing communities located within the Romney Marsh area, the new building will be designed in such a way that suggests a controlled response to its context. On the landside of the building, it is proposed that the new terminal building will respond appropriately to its context with careful consideration within the landscape.

4.3 Proposed Terminal Location

4.3.1 The area selected for the development of the terminal complex is shown on Figure 3.2 and has been selected after careful consideration of the following:

• It will be located adjacent to the main apron, thus reducing passenger transit times;

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• The development will take place entirely on land within the control of the airport (LAA has a long lease of the land, with SDC being the freeholder);

• The location provides a good contact ratio between airside and landside at higher throughputs, i.e. the airside periphery of the terminal is larger than the landside;

• The site is well located adjacent to the access road; and

• It makes maximum use of the existing facilities, until they are phased out. 4.3.2 Details of further sites evaluated as part of the project are included in Section 4.13.

4.4 The Terminal Building

External layout

4.4.1 The terminal building has been designed as a “landmark building”, as shown in Figures 4.1-4.9. On approaching the airport, the departures lounge, with its extruded low pitch barrel vault roof, will act as a focal point for visitors, complimented by the simple curved monopitch roof of the combined departure and arrivals concourse. The two areas will be linked by a two storey flat roof area that has been designed to avoid conflict with the adjacent structures.

4.4.2 The first floor and plant area within the building will acts as a “spine” through the building and can be utilised as support space for the primary functions below. This area accommodates the office space and plant necessary to provide comfortable conditions within the building.

Internal Layout

4.4.3 Internally the facilities will be provided in a linear arrangement, offering the basic functions of passenger processing at a single level, with arriving and departing passengers processed side-by-side. Additional support facilities will be provided at first floor level as described above. The proposed layout of the proposed facility is provided in Figures 4.2, 4.2a, and 4.2b and described in detail below.

Departures

4.4.4 Departing passengers will enter the building via an entrance door leading directly into the shared departure concourse. This area has been designed as a double height space, with sufficient space to orientate oneself before identifying where to check in. The multi function check-in desks will be immediately presented to departing passengers with a single queue arrangement provided for efficient processing. Support facilities in this area will include retail space, areas for self-service check-in desks, storage for furniture, airline offices accessible for the public, toilets, security and staff offices and vertical circulation to upper levels. An additional office area will be provided at a mezzanine level above the retail space to accommodate additional airline offices, airside business lounges, etc.

4.4.5 Once checked in, all international and domestic passengers will move to the security screening area from where they will enter a shared departure lounge (which may be split into two distinct areas if necessary). All baggage will be checked-in and moved to a position behind the airline desks where it can be screened and moved to departing

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aircraft. Adequate storage facilities and interview space have been provided here should it be necessary to screen passengers.

4.4.6 Two screening channels are provided, with an additional fast track screening route for crew members and periods of heavy use. Offices and interview areas for individual searches are also present. Passengers then move through a passport control area before entering the departure lounge.

4.4.7 The departure lounge will be a combination of single and double height spaces, with all facilities orientated towards a full height glazed façade facing the aircraft apron area. A number of retail units will be provided along one side of this space, keeping the airside and departure gates free of obstructions. Servicing of all airside retail space will be provided via the public security screening area, which should occur during quiet periods.

4.4.8 The departure lounge is provided with general seating areas and café seating, facing the four departure gates. Once passengers are called for boarding, sufficient space for queuing is provided in addition to general seating and circulation space. It is anticipated that passengers will walk, or be transported by bus to waiting aircraft. A separate business lounge is provided off this space offering passengers an increased level of service. An upper level of accommodation has been provided here with toilet facilities and the majority of retail space provided. Should passengers be required to wait for delayed flights, then this area is designed to provide adequate facilities for the public before departure. A number of offices have been provided that can be directly accessed from the departure lounge, including a security office, first aid room, light aircraft flight and crew briefing and a MET data (weather collection) room.

Arrivals

4.4.9 On arrival at the passenger terminal, two gates will be provided, one for international passengers, and one for domestic arrivals. On entering the baggage claim area, a single baggage claim carousel is provided with generous circulation space for passengers with trolleys. Support facilities for this space include toilets, an office for both Special Branch and Immigration, an interview room and over size baggage facility.

4.4.10 Once passengers have claimed their luggage, they will move through the customs area, where three channels will be provided, together with an office for customs officers for individual screening. Domestic arrivals will enter a separate space for baggage collection before moving into the arrivals hall.

4.4.11 On entering the double height shared arrivals hall, passengers are greeted by visitors to the building, with an information desk, toilets, and car hire desk provided. From here, passengers exit the building where they gain access to parking areas, taxi ranks and coach and bus pick up points.

Offices and Management Suite

4.4.12 A first floor level management suite will be provided as well as additional offices which can be directly accessed from the land side of the building. These spaces form a spine through the building and overlook the departure and arrival halls below. Above these rooms, an external area is provided which can accommodate all necessary plant to support the interiors below.

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4.5 Parking and Access Arrangements

4.5.1 The proposed access route to LAA is via the airport access road from the B2075 (Romney Road). The existing access road to LAA has recently been improved and re- surfaced and is adequate to cater for all planned construction and operational traffic. The junction of the access road and the B2075 would require minor improvements to be agreed with the highway authority as indicated in Chapter 14 and the Transport assessment.

4.5.2 The access to the airport is nearly 3 kilometres south of the B2075 junction with the A259 (Hammonds Corner). 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). The Hammonds Corner junction of the B2075 and A259 requires improvements in order to cater for the additional traffic generated by the expansion of the airport. This is detailed in the related application for extending the runway at the airport and Transport Assessments.

4.5.3 There is sufficient capacity for up to 860 carparking spaces at the airport (on 100% hardstanding) which is the requirement for 500,000 passengers per annum (as shown in Figure 4.9).

4.6 Power and Utilities

4.6.1 Power, utilities and water for the proposed terminal buildings will be provided by local utilities supplier, using existing access routes to avoid areas of conservation value.

4.7 Sustainability

4.7.1 Sustainability is an integral part of the proposed terminal buildings and such issues have been addressed throughout the design of the project – See Chapter 18 Sustainability for further details.

4.8 External Lighting

4.8.1 To avoid confusion with aeronautical ground lights, it is recommended that flat glass full cut-off luminaires mounted horizontally be used, so that no light is emitted above the horizontal. Uplighting is not to be used unless full approval of the proposed luminaires is confirmed by the CAA.

4.8.2 The external lighting shall be further developed in conjunction with the architect to suit specific building requirements. This may include a combination of column lighting, soffit/bulkhead mounted recessed luminaires or building mounted floodlights. The lighting will be controlled by photocell with optional time clock override. The external lighting is to comply with the Local Authority’s lighting practices, the relevant British Standards and Codes of Practice, CIBSE Lighting Guideline 6 (The Outdoor Environment) and the requirements of the CAA.

4.8.3 All external lighting is to be specified and controlled as defined by Part L2 of the Building Regulations.

4.8.4 The external lighting within the boundary zone may be broken down into the following categories:

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• Architectural Façade lighting

This style of lighting shall comprise façade mounted luminaires at high level. The luminaires shall provide a relatively high colour rendering index, using a white light source, in order to facilitate and attractive source of light. Metal halide lamps shall be considered for this purpose. The luminaires shall also offer general illumination for the circulations areas around the buildings. The type and style of luminaire is to be selected such that it offers optimum benefits.

• Entrance and reception lighting

The entrances to the building shall be illuminated to a level of 150 lux and shall offer a focal point for the public in order to assist passenger movements and guidance. It is intended that these areas are illuminated using high frequency compact fluorescent luminaires. The colour temperature of the light source is to be sympathetic with the overall floodlighting scheme mentioned above.

• Utility Lighting

External circulation areas and pathways shall be illuminated to a level of 20 lux. The luminaires shall offer a Ra of 80 and deliver a vertical illuminance of 15 lux.

Areas used for work shall be illuminated to a level of 10 lux for general areas, 20 lux for storage areas and 50 lux for walkways and platforms. Lighting shall be provided by building mounted luminaires. Bollard lighting shall not be considered.

General illumination on the airside is to be by way of the column mounted luminaires serving the stands. These are to be selected and erected in accordance with the design parameters dictated by CAP 168.

• Emergency Exit Lighting

Emergency lighting to the external boundary area shall be provided by self-contained, non-maintained low-level bulkhead luminaires. These luminaires shall be mounted at each emergency egress point and along defined escape routes to a level of 1 lux on the centre line of the escape route.

• Baggage Handling Operations

Areas used for baggage handling operations are to be illuminated to a level of 200 – 300 lux. The lighting utilised in these areas is to be sympathetic to the exterior scheme and the dynamic nature of the baggage handling process (i.e. internal to external transition).

4.9 Construction Process

4.9.1 The proposed terminal building superstructure comprises of steelwork, with composite concrete/profiled metal sheet floors. As well as providing a lightweight structure, this form of construction minimises deliveries of materials to the site, as there are fewer components involved in the erection of the superstructure.

4.9.2 Having considered the structural design of the terminal building, every effort has been made to remove the reliance on a concrete frame, as this can have a significant impact

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on the environment. This is the case in its construction phase, as well as during any further development work and ultimately the demolition of the building. The deadweight of the steel superstructure is considerably reduced when compared with utilising a concrete frame.

4.9.3 The design proposal for the foundations to the building is the formation of reinforced concrete pads throughout. Although a high water table is present on the site, it is possible to found above the water level, thus reducing the risk of pollution to groundwaters. This also has additional benefits such that the quantities of excavated soil are considerably reduced and the volume of concrete delivered to site to form the foundations is minimised. It is anticipated that approximately 4,500 m3 will be generated from the excavation for the foundations.

4.9.4 The use of batching plant onsite is not anticipated, as there are relatively small quantities of concrete required. However, deliveries of pre-mixed concrete to site will occur during the early stages of the erection process.

4.9.5 Closely controlled construction processes implemented by the main contractor will significantly reduce the risk of groundwater contamination. The implementation of a Construction Environmental Management Plan (CEMP) by the main contractor and all sub-contractors will ensure the environment is protected. The CEMP will include the recycling of materials where possible, the management of material waste such that it is removed from site immediately and limitations placed on the excessive ordering of materials to reduce waste.

4.9.6 The adoption of offsite pre-fabrication for selected construction assemblies will be implemented prior to delivery of those assemblies to site. This will bring a number of benefits to the project, namely:

• Speed of erection and reduced time within the overall contractors programme;

• Reduction of labour onsite and therefore reduced daily traffic movements to and from the construction site;

• Reduction in the delivery of raw materials to site, again reducing daily traffic movements; and

• Reduced risk of contamination to watercourses due to reduced storage of materials onsite.

4.10 Construction Methodology

4.10.1 The construction methodology for the erection of the terminal buildings will follow the sequences stated within the contractors programme. Construction for the proposed development is expected to commence 18 months prior to operating, with fully operational services anticipated in 2010.

4.10.2 The contractors programme states that the contractor will follow a logical construction process which will be carefully managed to provide an efficient use of available labour including the formation of the sub-structure and removal of waste from the site, erection of the superstructure, as well as the construction of the building.

4.10.3 The proposed construction methodology is as follows:

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• Site setup and compound on Bravo Apron and identification of existing services with possible protection or diversion;

• Installation of bases and ground beams to allow sufficient depth for drainage and any service ductbanks;

• Drainage and ducting;

• Erect steelwork frame followed by secondary steel work after the laying of ground floor slab;

• Install of cladding and roofing to make building water tight;

• Block work for internal walls;

• 1st and 2nd fixings and finishes; and

• Commissioning.

Construction Traffic

4.10.4 It is anticipated that 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 14.11 (referenced in Section 14.5). Construction activities will generate the following daily one way vehicle movements:

• During the excavation of bases drainage and floor slab, there will be approximately 16-25 movements per day of HGVs dependent on the tasks being carried out. The actual number of HGVs will be dependent on the location of the tipping site and available standing area;

• During the steelwork phase there will be approximately 40 HGV movements per day, those can be reduced dependent on the size of the lay down area;

• The ground floor slab will comprise of a subbase and concrete construction generating approximately 30 HGV movements per day; and

• During the fitting and finishing phases there will be variable amounts of site traffic and deliveries, largely comprised of cars and small vans.

4.11 Operational Implications of the Terminal Development

4.11.1 The proposed terminal extension will not affect either the size of the aircraft or the types of aircraft that the airport can accommodate, which are determined by a combination of runway length, width and strength.

4.11.2 As outlined in Chapter 3, LAA currently has one operational runway which can be approached from either direction dependant upon the prevailing wind direction, the previous cross runway having been taken out of service. Both approaches make use of a single 1505m by 32m asphalt pavement and run northerly/southerly at orientations of 215o and 035o to the magnetic North respectively.

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4.11.3 It is anticipated that approximately 43 jobs will be created during the construction of the terminal building. During operation, it is envisaged that approximately 300 direct jobs during the development.

4.11.4 Under the CAA Aerodrome Reference Codes (see Table 4.1 below), the current runway length of between 1200m and 1800m means that the CAA has designated the aerodrome 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 a runway length of 1,768m and 1,722 m respectively to allow them to take off with full payloads.

Table 4.1 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 15m Up to but not including 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 including 52m 14m E 52m up to but not including 9m up to but not including 65m 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

4.11.5 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.

4.11.6 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.

4.11.7 The proposed terminal development will also not affect the flightpaths available for aircraft landing or taking off from LAA. It will, however, enable increased numbers of passengers to use the airport and as such is likely to result in modifications to the frequency of use of the different aircraft with the fleetmixes to that which would be expected under a 300,000 passengers per annum scenario. The predicted fleetmixes and aircraft movements for the 500,000 per annum scenario is shown in Table 4.2 below.

`

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Table 4.2: Predicted Fleetmix and Aircraft Movements for 500,000 Passengers per annum

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 4 544 1460 198560 A319 140 112 4 448 1460 163520 BAE146 100 78 2 156 730 58940 Dash 8 50 40 2 80 730 29200 ATR42-500 48 40 4 160 1460 58400 Saab 340 33 25 2 50 730 18250 TOTAL - - 18 832 6570 524870

4.11.8 Based on the 500,000 passengers per annum (Year 1 Operating Conditions) scenario, there will be 18 scheduled aircraft movements per day (defined as either an aircraft landing or take-off)1. Larger aircraft and jets will preferentially take-off and land from Threshold 21 and will be required to turn right shortly after take-off to avoid the Dungeness and Lydd Ranges restricted airspace and will flyover the town of Lydd. Smaller aircraft using the runway could turn left on condition that they maintain clearance from the Dungeness restricted airspace.

4.11.9 The mixture and makeup of any destinations serviced by Lydd would ultimately be down to those which airlines found to be successful over time. The routes are likely to be a mixture of both domestic and European destinations and a number of strong candidate destinations have been highlighted as a result of marketing studies. From a domestic prospective, routes to Glasgow, Edinburgh, Manchester and Plymouth all have potential. With regards prospective European routes, these are thought to include Barcelona, Nice, Lyon, Dublin, Brussels and Amsterdam.

4.12 Project Need

The UK and Regional Need

4.12.2 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 increase 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.

1 General Aviation will also increase as a result of the proposed development and this has been taken into account in the modelling for the noise assessment.

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4.12.3 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 East2.

4.12.4 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.

4.12.5 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. 4.12.6 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”.

4.12.7 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 4.3 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.

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

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Table 4.3 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 Shepway includes 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

4.12.8 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 Plan3 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:

4.12.9 ‘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’.

4.12.10 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 Lydd. Kent County Council also supports

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

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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.

The Local Need

4.12.11 LAA is recognised in the first paragraph of the Shepway Local Plan 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.

4.12.12 The employment chapter of the Adopted Local Plan (2006)4 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.

4.12.13 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

4.12.14 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 UK 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.

4.12.15 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.

4.12.16 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 Shepway District Local Adopted Plan (2006)

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

4.13 Alternatives Analysis

Alternative sites

4.13.1 As part of the development of the scheme design, a number of alternative options have been evaluated for the proposed terminal facilities. The option of refurbishing the existing terminal building and construction of a new terminal on one of six other physical locations, as shown on Figure 4.7 was considered. Each of the options was assessed in terms of airfield operations, safety, visual impact, security, construction processes and environmental considerations, this is also shown in Table 4.4 below. In addition, options regarding the constraint of the existing aircraft hangar were reviewed.

4.13.2 The assessment of these locations has also considered the strategic future development of the airport, taking into account the development of the airfield in recent years to ensure that proposals for improved passenger terminal facilities are compatible with overall development strategies. This would have an impact on environmental considerations as any proposal to locate such facilities that are not compatible with future development strategies would naturally have a more onerous environmental and operational impact.

4.13.3 A requirement for the provision of improved passenger terminal facilities is also to retain both the existing passenger terminal building and aircraft hangar if possible throughout the construction works.

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Table 4.4 Alternative Location Assessment Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 Description Refurbishment of Extension of Located on existing Located west of Located north-west Located east of Located west of existing terminal existing terminal terminal car park existing terminal of existing bravo existing bravo existing bravo building building car park apron apron. apron Advantages Utilisation of Utilisation and Viable access to Viable access to Viable access to Viable access to Viable access to existing building extension of transport networks. transport networks. existing Bravo existing Bravo existing Bravo reduces level of existing building Apron. Apron. Apron and environmental reduces level of Concealed Concealed Transport impact. environmental positioning within positioning within No Security Risk Networks. impact. current building current building from Restricted structures to structures to Zone or Internal No Security Risk Positioning of decrease visual decrease visual Space concerns from Restricted building closer to Viable access to impact. impact. Zone or Internal current structures transport network. Viable access to Space concerns reduces visual transport network. impact No Security Risk No Security Risk Construction all on from Restricted from Restricted airport land Zone or Internal Zone or Internal including existing Space concerns Space concerns hardstanding. No Security Risk from Restricted Zone or Internal space concerns Disadvantages (Physical) security (Physical) security No direct access to This is outside the Dispersed Dispersed Minor loss of risk to passengers risk to passengers existing Bravo application site positioning of positioning of improved would be would be Apron. boundary on land building away from building away from grassland. considered considered not owned by LAA. current structures current structures unacceptable to unacceptable to Relocation of car increases visual increases visual Regulatory Regulatory park would involve impact. impact. Authorities due to Authorities due to environmental impacts. Dispersed compromised compromised positioning of 5 1 ‘Restricted Zone’ ‘Restricted Zone’ Airside access from building away from Need to relocate Impingement on waiting aircraft current structures balancing ponds. existing SSSI site would require early increases visual and associated Insufficient space demolition of impact. species. and internal existing terminal No direct access to

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

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Table 4.4 Alternative Location Assessment Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 configuration to building with transport networks. accommodate all associated passenger facilities environmental No direct access to No direct access to impacts. existing Bravo transport networks. Apron

Overall Dismissed on Dismissed on Dismissed on Dismissed on the Dismissed on Dismissed on Taken forward as Assessment grounds of security grounds of security environmental and grounds of land environmental and environmental preferred option risk and Restricted risk logistical grounds. ownership and access grounds. grounds space. access constraints.

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Refurbishment of the New Facility

4.13.4 Over the last three years, approximately £20 million has been invested in upgrading the airport and extensively refurbishing the existing terminal building to improve facilities, including the creation of a new business executive lounge. These investments have resulted in a significant increase in the use of the airport, with a corresponding increase in direct employment.

4.13.5 The existing terminal is, however, severely restricted in its potential for expansion. For example, at present there is a temporary Restricted Zone (RZ) in place for international flight arrivals and departures, and passengers leaving the terminal building to access the aircraft must leave the RZ in order to do so. Should the size and number of aircraft serving the improved passenger facilities increase, this would be considered an unacceptable security risk. The space available in the existing terminal building is inadequate to process the required number of passengers successfully with the building’s internal configuration in its current form. In addition to being further refurbished, the building would therefore need to be significantly extended to meet the demands of improved passenger processing.

4.13.6 The nature of the constraints placed upon the building on both landside and airside mean that this cannot be easily achieved without compromising the buildings’ surroundings. In particular, as the existing terminal building is located approximately 170m away from the runway, modern safety constraints would not allow the building to be extended any closer to the runway on the airside.

4.13.7 Furthermore, any extension to the building on the landside would impact on existing parking areas, which, in turn, would need to be provided for elsewhere. Anecdotal evidence indicates that the foundations supporting the terminal building are unlikely to be adequate to support the loads associated with an upper storey extension. Whilst a vertical extension to the existing building would therefore be difficult to achieve without extensive sub-structure work there are also height restrictions for any structure within 170m of the runway which would discount the addition of a further storey being added to the existing terminal building. This option was therefore discounted.

Further Development in the Vicinity of the Existing Terminal Building

4.13.8 The proposal to locate the improved passenger facilities on the site of the existing terminal car park was also discounted on the grounds that provision of airside access between waiting aircraft and the new facilities would require the early demolition of the existing terminal building, with the associated business interruptions before the new facility opened. The work would also require the displacement of public and staff parking to a position elsewhere on the site.

4.13.9 In terms of other alternatives, four further locations (in addition to the preferred option) were considered, all of which were positioned away from the existing buildings on the site. Many of these proposed locations would however result in an increased visual impact (a position away from the existing buildings on the site will naturally tend to isolate the new development and consequently appear to extend and increase the impact of such a proposal on the surrounding landscape), when compared with a location close to the existing terminal building or the aircraft hangar. Furthermore some of the alternative locations had poor links to existing airside infrastructure (apron areas, taxiways, and runway).

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4.13.10 As a result of the above factors, the preferred location was selected with the new facility to be erected on an area of hardstanding close to existing buildings, but not compromising the required safety zones.

Alternative Designs - Alternative Construction Methodologies

4.13.11 The terminal building has been designed to utilise a steel frame. An alternative frame using concrete construction has been dismissed for the following reasons:

• A steel frame provides a light weight solution to the provision of a superstructure;

• The erection of a concrete frame is labour intensive at the construction stage; and

• The refurbishment and ultimate removal of a concrete frame structure is labour intensive and time consuming when compared with steel. 4.13.12 The use of heavy construction plant to form alternative deep excavated foundations is avoided with relatively small equipment needed to remove soil and form excavated trenches. It is anticipated that a tower crane will not be necessary to erect the steel frame for the proposed terminal building. Relatively small mobile cranes will be used for the erection process, providing flexibility and reducing the visual impact on the surrounding environment.

4.13.13 In consideration of the use of a steel frame, the quantities of concrete required are unlikely to justify setting up a batching plant onsite. This will avoid the potential risk of contamination involved in using such plant.

4.13.14 The use of “dry” construction methods throughout the construction process has been considered with a view to reducing all “wet” trades where possible. This has the benefit of potentially increasing the performance of materials used, reducing the reliance on workmanship methods onsite where they may be difficult to control and stabilising all components and assemblies that have been fabricated offsite such that their performance is not affected by conditions onsite during the construction period.

4.14 Summary

4.14.1 The current proposal is to design a passenger terminal building to accommodate 500,000 passenger movements per annum. This is referred to as the ‘proposed terminal development’.

4.14.2 At present, a detailed planning application is being sought for the proposed terminal development building. Estimated costs for the development are in the order of £15M, including costs for car-parking and access; the work is currently scheduled to take approximately 18 months to complete. On completion of the works, and when the current capacity of 300,000 passengers per annum has been reached the existing terminal will be decommissioned. Thus, the new development will itself only process up to 500,000 passengers, as the existing terminal will not be used for commercial flights.

4.14.3 The completed design for the terminal building will provide an appropriate response to the functional requirements of passenger processing. Furthermore, careful consideration of all proposed external building and will ensure that the completed building will be seen as a sensitive response to an internationally recognised landscape.

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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.

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) PPS22 (2004) PPS23 (2004) PPG24 (1994) PPG25 (2001)

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

LOCAL POLICY Kent and Medway Structure Adopted Plan AND GUIDANCE (1996)

Kent County Council Local Transport Plan 2001-2006

Kent Prospects – Economic Development and Regeneration Framework to 2006

Ashford’s Future (2005)

Shepway District Local Adopted Plan (2006)

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

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

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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:

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

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• 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.

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.

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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)

• PPS22 Renewable Energy (2004)

• 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

• Integration of sustainable development in development plans. 5.3.15 Sustainability objectives have been considered in the terminal design and this is discussed in Chapter 18 Sustainability.

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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 developments at LAA support 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;

• 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;

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• 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 to scale with respect to its location, and sensitive to the character of the countryside and local distinctiveness”. 5.3.24 The proposed development will result in improved grassland 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).

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:

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(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.

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.

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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 developments will have on tourism.

PPS 22 Renewable Energy (2004)

5.3.41 This PPS outlines the key principles, targets, policy development requirements and locational considerations for renewable energy development and as such it covers a range of renewable technologies such as onshore wind generation, hydro, photovoltaic’s, passive solar, biomass and energy crops, energy from water and landfill and sewage gas. The guidance indicates that Local Planning Authorities and developers should consider the opportunity for incorporating small scale renewable energy schemes utilising technologies such as biomass heating in all new developments and this is supported by the LAA proposals to install a biomass boiler as an alternative to traditional forms of heating and cooling within the terminal building development.

PPS 23- Planning and Pollution Control (2004)

5.3.42 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".

5.3.43 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.

5.3.44 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.

5.3.45 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:

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• 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;

• 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. 5.3.46 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 subject of discharge licenses have been discussed with the Environment Agency with regard to the proposed development at LAA. 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.

5.3.47 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.

5.3.48 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)

5.3.49 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.

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

5.3.51 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.

5.3.52 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)

5.3.53 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:

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

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

• 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. 5.3.54 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.

5.3.55 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.

5.3.56 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.

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

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

5.3.59 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.

5.3.60 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’.

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

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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 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 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;

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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 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.

5.4.17 Key Development principles

5.4.18 One of the key cross-cutting spatial strategies for the region is the reduction of intra- regional disparities.

5.4.19 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.”

5.4.20 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.

5.4.21 The Plan also seeks to ensure improvements to the character of the environment and the quality of life.

5.4.22 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.”

5.4.23 The Proposed terminal 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 development will also aid the

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enhancement of local living standards through the creation of sustainable economic growth.

Countryside and landscape management

5.4.24 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”.

5.4.25 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

5.4.26 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.

5.4.27 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”

5.4.28 LAA 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.

5.4.29 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.

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

5.4.31 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.

5.4.32 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)

5.4.33 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.

5.4.34 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.

5.4.35 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. 5.4.36 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’.

5.4.37 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 and Kent International Airport (Manston) and states that other airports in the region are not considered to have strategic potential.

5.4.38 The proposed terminal 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.

5.5 Local Policies and Guidance

Kent and Medway Structure Adopted Plan (2006)

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

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Key Themes

5.5.3 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. 5.5.4 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.

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;

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• 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. 5.5.5 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. 5.5.6 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

5.5.7 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 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

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• 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. 5.5.8 The proposed terminal 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.

5.5.9 As LAA is currently operating as an airport, the expansion in any other location would not be feasible nor suitable.

Chapter 3 Kent and Medway Area Based Policies

5.5.10 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

• 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. 5.5.11 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

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

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• 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. 5.5.13 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.

5.5.14 Dungeness SLA is identified within Policy E5. 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.

• North Downs

• Greensand Ridge

• High Weald

• Eastern Low Weald

• Western Low Weald

• Old Romney Shoreline

• North Kent Marshes

• Sandwich Bay/Pegwell Bay

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• 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.

5.5.15 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.

• 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.

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• 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. 5.5.16 The proposed development at LAA will have a potential impact on a SSSI, and this is discussed in Chapter 10 Ecology and Nature Conservation.

5.5.17 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

5.5.18 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.

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

Chapter 6 Fostering Prosperity

5.5.20 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:

• 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.

5.5.21 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.

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

5.5.22 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:

5.5.23 ‘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’.

5.5.24 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.

The Kent and Medway Structure Adopted Plan1 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.

5.5.25 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. Policy of the KMSP is dedicate4d to LAA: TP25.

• 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

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

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• 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

5.5.26 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 (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.

5.5.27 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.

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

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• 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; (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.

5.5.29 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.

Chapter 10 Managing our waste and mineral resources

5.5.30 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. 5.5.31 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.

5.5.32 The construction of the proposed developments at LAA will require significant quantities of aggregate materials. The Structure Plan outlines how the use of

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aggregates “can have a major impact on land use and transportation.” Policy WM7 outlines the Structure Plan’s approach:

5.5.33 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.

5.5.34 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

5.5.35 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.

5.5.36 The proposed developments at LAA support Policy S32 through this ES, which investigates the environmental, traffic and employment implications.

5.5.37 Policy UKG 5 of the draft Kent Local Transport Plan 2006 – 2011 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”.

5.5.38 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.

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

5.5.39 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).

5.5.40 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.

5.5.41 The framework’s view is that:

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

5.5.42 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.

5.5.43 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.

5.5.44 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 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”

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

Ashford’s Future (2005)

5.5.46 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 Future2, 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.

5.5.47 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:

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

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“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 Local Plan (2006)

5.5.48 Shepway District Council adopted the Local Plan 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. 5.5.49 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;

• 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 peoples 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. 5.5.50 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 implementation of the proposed mitigation measures in this ES, significant adverse effects upon landscape and nature conservation will be minimised.

Sustainable Development

5.5.51 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

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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.

5.5.52 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; 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

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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.

5.5.53 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

5.5.54 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 any adverse impacts.

5.5.55 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.

Tourism

5.5.56 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.

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

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

Transport

5.5.59 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.

5.5.60 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

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• To achieve a level of public car parking facilities compatible with sustainability aims.” 5.5.61 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.

5.5.62 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.

5.5.63 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.

5.5.64 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.

5.5.65 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 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. 5.5.66 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. The proposed development will provide employment opportunities to offset the unemployment resulting from the decommissioning of Dungeness power station.

Countryside

5.5.67 Much of the Local Plan’s countryside policy is relevant to the proposed development at LAA. The aims of the countryside section of the 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. 5.5.68 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.

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5.5.69 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.

• 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.

5.5.70 The proposed development at LAA will have a potential impact on Policy (a) of CO1, and this ES recommends mitigation measures to minimise significant adverse impacts. The proposals are going to be located within the airport boundary 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 proposed mitigation measures proposed.

5.5.71 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”.

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

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• 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.

5.5.73 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.

• 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.

5.5.74 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.

5.5.75 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;

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• 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.

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

5.5.77 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.

5.5.78 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.

5.5.79 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.

5.5.80 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

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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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CHAPTER 6

GROUND CONDITIONS

CHAPTER 6 LAA

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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;

• Environment 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 Terminal 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

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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shingle in the fringing beaches is typically found to be aligned in sub-parallel ridges of 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 area surrounding the terminal development (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 and Nature Conservation), the shingle structures present are geomorphologically important in their own right, as described further below.

Geomorphology

6.4.8 The proposed terminal development is located approximately 200m 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.

6.4.9 The important geomorphological features of the SSSI site comprises 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 SSSI site is considered to be of national geomorphological importance for this aspect (8, 9).

6.4.10 An extension to the existing SSSI has been proposed by Natural England which may extend across the airport site including the location of the proposed terminal building (Figure 6.4). Whilst this figure is only indicative the proposals have been included within the assessment in accordance with best practice.

6.4.11 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

6.4.12 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).

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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6.4.13 Details of surface waters are also included in Chapter 7: Water Resources and Flood Risk. 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

6.4.14 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.

6.4.15 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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6.4.16 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 proposed terminal location 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 eight 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 Predicted Impacts (Construction Works)

Existing Conditions Scenario

6.6.1 The proposed development is located outside of the boundaries of the current North Lade SSSI, although the CBR locations tested (see Figure 6.4) detected coarse shingles within the immediate vicinity of the proposed terminal site and it is likely that these are an extension of the same geomorphological features for which the SSSI is designated. Given the proposed extension to the SSSI (see Figure 6.4), any land that is currently undeveloped within this vicinity should be considered to be of at least moderate environmental sensitivity. However, whilst the proposed construction works will inevitably result in an irreversible change to any soil or buried geomorphology on the site, the majority of the land to be affected is already under hardstanding or temporary gravel. Impacts to geology and soils are therefore considered to be of only minor adverse significance.

6.6.2 It is anticipated that approximately 4,500 m3 of spoil will be generated from the excavation of the foundations. Whilst much of the site has been previously developed, there is no evidence of any especially contaminative activities occurring on the land to be developed and the spoil is expected to be clean in nature, although further investigations will be undertaken to confirm this prior to construction commencing. Any clean spoil will be disposed of at sites around the airport to an average depth of less than 10cm (and avoiding impacts to sensitive habitats) to provide low level landscaping features. Where spoil does need to be removed from site, the level of contaminants within the soil will be assessed and the spoil disposed of to an appropriate offsite location. Given the expected clean nature of the soil and the low volumes to be generated, impacts relating to spoil generation and disposal are expected to be of only minor adverse significance.

6.6.3 Whilst the concrete pad foundations of the new terminal building are expected to extend for at least 1 m below ground level there are no important aquifers located below the proposed site location and impacts on either availability or quality of groundwaters are expected to be negligible.

6.6.4 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.

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6.6.5 Overall therefore, no effects to local residents, workers or ecology are expected as a 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 minor.

Future Assessment Conditions Scenario

6.6.6 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.

6.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

6.7.1 The operation of the terminal building (and associated drainage – see Chapter 7) 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 Waste) 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 Airport Environmental Management System for the airport (see mitigation below), 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 impacts arising from operation of the facility under this scenario are expected to be the same 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 are proposing to work with Natural England to undertake a targeted site investigation of the geomorphologically important areas of the 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;

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• Drilling of a deep borehole to determine the ancient sedimentary record of site evolution in an area where ridges of gravel deposits at the surface with troughs (swales) in-filled with finer grained sediment. 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.

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 Environment 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 ;

• 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

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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• Should any contaminated areas be identified, a remediation approach would be agreed with the regulatory authorities before the commencement of any 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 the 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 Proposed mitigation for construction impacts 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 an 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 terminal building will result in an irreversible change to a limited amount of soil and buried geomorphology on the site. The majority of the land to be affected is already under hardstanding and with the proposed mitigation no significant impacts are expected. The use of good spill prevention mechanisms will help minimise impacts to geology and soils, and overall impacts are considered to be of only minor adverse significance.

Future Assessment Conditions Scenario

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

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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 contamination onsite, none are expected in the area of the proposed terminal building, 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 terminal building, 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 outlined 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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CHAPTER 7

WATER RESOURCES AND FLOOD RISK

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 Terminal development to (and from) the water environment. As such, it covers issues of:

• Surface water and groundwater quantity and quality;

• Flood risk;

• 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 Risk, 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 flooding1; and

• PPS 23 Planning and Pollution Control.

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.

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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7.3.2 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 Terminal Construction, 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 watercourse or within 8 m 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 7.4.11) is ultimately connected to the site via these lateral drains.

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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 7.4.11). 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, which has been designed to ensure that neither rates nor pollutant levels (current and predicted) exceed either discharge limit levels or the capacity of the receiving watercourses. 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' runoff rates in accordance with the recent discharge consent issued by 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.

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.

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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 landuse 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 waterbody 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 waterbody 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.

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

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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 27th 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;

• 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 consist 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:

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• 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 Treatment Works 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

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 Terminal Construction, 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 passenger movements per annum, 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

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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.

Table 7.5 Predicted Water & Sewage Volumes at 300,000 Passengers per annum Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or Tanker Visits sewage per Week generated) per week (m3) 300,000 180 181 8

7.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

7.6.1 Construction of the terminal building will be primarily on existing hardstanding and temporary surfaces (gravel). Due to the relatively flat nature of the site, there will be little recontouring or grading required and little change to overall drainage patterns. No surface water features will be directly affected by the works. The potential impact upon drainage is therefore considered to be only minor in significance.

7.6.2 The works will have a localised minor impact on groundwater due to the potential requirement for dewatering. However, such works are not expected to affect any groundwater abstractions due to the small volumes involved, the distance to the nearest third party abstraction point and the short period of time when dewatering may be necessary (weeks rather than months).

7.6.3 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 Construction Environmental Management Plan (CEMP) (see mitigation)to minimise such impacts and to include drainage plans to control runoff, erosion and sedimentation.

7.6.4 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.

7.6.5 Construction works will require a quantity of water for such uses as the production of concrete and other construction materials, 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 moderate adverse impact.

7.6.6 Existing sewage and water discharge systems are considered adequate to deal with any construction requirements, and no significant impacts to these resources are expected.

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Future Assessment Conditions Scenario

7.6.7 Construction impacts under this scenario are expected to be as for the Existing Conditions Scenario outlined above.

7.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

7.7.1 The proposed terminal development will not significantly increase the amount of hardstanding present on the site, and as its proposed drainage system is being developed in consultation with the IDB and EA, no significant impacts are expected to the quality or quantity of local surface or groundwater resources. In particular, as rainfall collected by guttering will be reused as grey water onsite to minimise water consumption (for example in flushing toilets), overall impacts are considered to be of only minor adverse significance.

7.7.2 Carparking for 500,000 passengers will be located on existing hardstanding and no additional impacts on groundwater or surface water quantity are expected to arise from this change of use. Run-off will be treated to ensure that it meets existing discharge consent requirements. With such a system in place impacts are expected to be of only minor adverse significance.

7.7.3 The increased number of aircraft movements required for 500,000 passengers 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 proposed 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 moderate 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 (AOD). At such a level, the potential impact of flooding is considered significant and in consultation with the EA the minimum finished ground floor level design has been developed to ensure that it is not below 3.3m AOD and no living (or similar) accommodation is located on the ground floor. This and other associated mitigation measures have been taken into account in the design of the proposed terminal buildings which means that overall impacts are expected to be of only minor adverse significance. For further details please refer to the separate report “Flood Risk Assessment Report, For the Proposed Terminal Construction, 2006 by BSF Consulting Engineers”.

7.7.5 Levels of water consumption and associated sewage generation will increase as a result of the terminal development as outlined in Table 7.7 below:

Table 7.7 Predicted Water & Sewage Volumes at 500,000 Passengers per annum Annual Passenger Staff Water Estimated 25m3 Numbers consumed (or sewage Tanker Visits per generated) per Week* week (m3) 500,000 300 302 13

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7.7.6 The increased number of passengers and staff will require an almost 6 fold increase in the quantity of water required at the airport (up from 45 m3 to 302m3 per week), although adequate water supply for this increased level of passengers is understood to be available within the existing piped system.

7.7.7 The increased numbers of passengers passing through the airport will similarly create an almost 6 fold increase in the volume of sewage generated on a weekly basis (again up from 45 m3 to 302m3 per week), which will result in an increase from two to thirteen (25,000 litre) tanker visits a week, or an average of 2 visits a day.

7.7.8 Volumes of additional sewage collected for disposal from arriving aircraft are dependent upon the carrier, aircraft type, passenger numbers and the origin/ flight time of the aircraft, but will be generally expected to be disposed of at the aircrafts origin airport. Overall impacts on water consumption and sewage generation are therefore considered to be a moderate adverse impact.

Future Assessment Conditions Scenario

7.7.9 Operational impacts under this scenario are expected to be as for the Existing Conditions Scenario outlined above. The exception will be in the significance of the increases in water consumption and sewage generation, which will increase by about 70% from 181m3 (eight sewage tanker movements) per week to 302m3 (thirteen sewage tanker movements) per week. Overall, given the available capacity, this is still however, considered a moderate adverse impact.

7.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

7.8.1 Whilst overall, it is considered unlikely that the construction of the proposed terminal building will significantly affect surface and groundwater resources, the following mitigation is proposed in accordance with best practice.

7.8.2 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.

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

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• 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

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

7.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

7.9.1 The design of the terminal building will incorporate a drainage system that will collect and reuse rainwater from the roof. This will enable LAA to reuse this finite resource during operation of the airport and it will also mitigate any adverse impacts on surface water drainage.

7.9.2 Given LAA’s location within an area potentially subject to flooding, the terminal buildings have been designed to avoid and minimise the significance of any such

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flooding events. In particular, the types of building material used in the construction of the building have been chosen for their capacity to prevent or reduce the risk of structural damage should flooding occur, whilst electrical services have been designed at a sufficient height to allow for their safe function and maintenance under such conditions. The construction of the terminal buildings will cause only minor displacement of any floodwater and will not have a detrimental effect upon any neighbouring property. For further details please refer to the separate report “Flood Risk Assessment Report, For the Proposed Terminal Construction, 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 proposed terminal building 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 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.

7.11.2 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. 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 new terminal building will be located on a relatively flat site and away from any significant surface watercourses. Whilst groundwater levels are high in this area, there are no abstractions in close proximity that are likely to be affected.

7.11.4 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.

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7.11.5 The terminal buildings will have no direct discharges to controlled waters, and overall, the construction and operation of the terminal buildings is expected to have no more than a minor impact on surface and groundwater resources. No significant impacts on or arising from flood risk are envisaged.

7.11.6 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

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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 terminal building 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

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costs of disposal of 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.

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 documents are within Table 8.1 below.

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Table 8.1 Summary of Key Legislation Primary Act Secondary Legislation Remit Prohibition on unauthorised or harmful Environmental Waste Management depositing, treatment, or disposal of Protection Act S 33 Licensing Regulations 1994 waste (e.g. facilities to be licensed; and 1990 Part II (as amended) certain activities onsite to be registered exempt) Environmental Protection Duty of Care in respects to waste (e.g. S 34 (Duty of Care) Regulations use of transfer notes) 1991 (as amended) Specifies arrangements for the Hazardous Waste (England) management of hazardous waste (e.g. Regulations 2005 and producer registration and use of S 62 List of Wastes (England) prescribed consignment notes) and Regulations 2005 ratifies the European waste catalogue into UK law Controlled Waste Control of (Registration of Carriers and Pollution Requires carriers of waste to be Seizure of Vehicles) (Amendment) registered with the Environment Agency Regulations 1991 (as Act 1989 amended) European Supervision and control of waste Transfrontier Shipment of Communities shipments between Member States into Waste Regulations 1994 Act 1972 and out of the EU Collection, transport, storage, handling, processing, and use or disposal of Animal By Products animal by-products (e.g. catering waste);

Regulations 2005 and placing on the market, export and transit of animal by-products and certain products derived from them Pollution Ratifies the EU landfill directive (i.e. Landfill (England and Wales) Prevention & banning of certain wastes to landfill, and Regulations 2002 (as Control Act introducing acceptance procedures amended) 1999 which apply to producers and operators) Pollution Prevention and Ratifies the EU IPPC directive (i.e. Control (England & Wales) certain activities will require a permit

Regulations 2000 (as from the environment agency or local amended) 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 passenger 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.

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, which is less than 0.24% of the annual waste produced by a major local centre such as Ashford.

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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 also produce an increase in sewage which will be disposed of offsite (see Chapter 7: Water Resources).

8.5 Potential Impacts (Construction Works)

Existing Conditions Scenario

8.5.1 Whilst no accurate volumetric data are currently available, construction of the terminal building will result in the generation of the following types of construction waste:

• 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.);

• Electrical waste (cables, cable drums, cable trays etc.);

• Potentially contaminated soils; and

• Uncontaminated excavated soils. 8.5.2 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 only minor adverse significance.

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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8.5.3 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.

8.5.4 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

8.5.5 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.

8.6 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

8.6.1 The increase of passenger levels to 500,000 passengers per annum is expected to result in the same waste types as outlined in Table 8.2. Volumes of waste will, however increase to approximately 160,000 kg of waste per annum, which represents an 80-fold increase over the existing conditions. Despite this increase, it will still represent less than 0.4% of the current annual waste production of a major local centre 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).

8.6.2 Traffic implications associated with increased waste disposal movements are addressed in Chapter 14,

Future Assessment Conditions Scenario

8.6.3 Predicted waste streams and traffic implications under this scenario are expected to be the same as described under the “existing conditions scenario” above. However the volume of waste produced will only represent less than a two-fold increase over the future assessment scenario conditions, and the impact is therefore considered to be of negligible significance.

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

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)

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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 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

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

8.8 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

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 System (EMS) for the airport, before the proposed new terminal building is operational. 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

3 WRAP Quality Protocol - http://www.aggregain.org.uk/quality/quality_protocols/index.html

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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.

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.

4 Proposed development at Stansted Airport Environmental statement volume 15 Waste Management, August 2001, Entec UK Ltd

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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.

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 Scenario

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 new terminal building 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. However, even at the 500,000 passenger scenario, once the

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proposed waste management systems have been put in place, impacts are expected to be of only minor adverse significance.

Future Assessment Conditions Scenario

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

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 new terminal building.

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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LAND USE

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9 LAND USE

9.1 Introduction

9.1.1 This Chapter describes the existing land uses in and around LAA and assesses the potential impacts associated with the proposed new terminal building 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 terminal building would be built on land currently under the management of LAA to the west of the large hangar between the main apron and the current access road east of the fuel farm. This location is shown in Figure 3.2.

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,

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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should be taken into account alongside other sustainability considerations”. This latter 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 cereals – 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.

9.3.2 The land use assessments have paid particular attention to:

• Land take;

• Local ALC;

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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• 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.

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.

7 Institute of Ecology and Environmental Management (IEEM) (2005) Draft Guidelines for Ecological Impact Assessment. 8 Institute of Envionmental Management and Assessment (2004) Guidelines for Environmental Impact Assessment, IEMA, Lincoln.

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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 new terminal building (2010) is to be built primarily on hardstanding or temporary surface (gravel) on land already within the airport boundary From that which exists as part of the baseline conditions scenario (present day), the 2010 scenario will occupy a range of land-uses, as detailed in Table 9.5.

Table 9.5 Percentage Land-take of Footprint Type % Land-take of Footprint Existing Hardstanding (Tarmac) 15% Temporary Surfacing (Gravel) 85% Current SSSI 0% Current SSSI affected 0% Proposed SSSI 71.8% Proposed SSSI affected 0.01%

9.4.2 A desktop study has been undertaken to identify existing land uses in the area which has included a review of:

• Local plans for the study area, primarily the Shepway Adopted Local 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 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-

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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 19 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 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 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

21573.pdf, 2006

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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 itself, the residential area includes the historic centre surrounded by newer housing developments. Impacts upon residential land uses as a result of construction and operation of the proposed Terminal are, against baseline and future assessment scenarios, addressed throughout this document, rather than as a stand-alone issue.

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

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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 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

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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.

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, apart from the construction of a runway extension which will result in a minor change to land use around the perimeter of the airport.

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9.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

9.6.1 Although areas of agricultural land around LAA will create a buffer zone from many of the impacts anticipated during the construction of the proposed terminal building scenario, a limited number of impacts on land-use have been identified.

9.6.2 In relation to the Existing Conditions Scenario, construction of the proposed terminal building will result in a small amount of direct landtake (approximately 7,380m2) but this will be confined to hardstanding and a small area of temporary surfacing (gravel) within the airport fenceline. 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. No other temporary structures are envisaged at this stage and overall direct impacts on landtake are considered to be minimal.

9.6.3 Over and above the current services (baseline scenario), a number of utilities will need to be provided to support the proposed terminal building. These utilities will include the provision of electricity, power, telecommunications, water and drainage. Any further connection to such services will require excavation of trenches which will have a temporary adverse effect on adjacent land uses, including areas of arable farming. Access may also be required for any connection works, but all other access for the main construction works will be via the existing airport access road and no other impacts on the adjacent agricultural lands or other land uses in the area are expected during the construction works. Overall impacts on land use are, therefore, envisaged to be minimal and restricted to immediately adjacent farmland.

9.6.4 Temporary and indirect impacts arising as a result of changes to the local ambience arising from construction traffic, noise and vibration, air and water emissions which could affect other land uses (including areas in residential and tourism / leisure use). Such indirect impacts are discussed within the other Chapters of this ES.

9.6.5 The car parking spaces required for the terminal development can be accommodated on existing hardstanding. Consequently, there will be a negligible effect on land use.

Future Assessment Condition Scenario

9.6.6 Predicted impacts arising from construction of the proposed terminal building under this scenario are expected to be the same as described under the ‘existing conditions scenario’ above.

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 terminal may also have an indirect impact on land management practices in the area, especially through the development of agreements

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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 As the additional car-parking for 500,000 passengers will be located, in its entirety, on existing hardstanding within the airport boundary (see Figure 4.8) no impact on external land-use is envisaged. No other operational impacts on land use for the proposed development are envisaged at this stage.

Future Assessment Condition 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 terminal building will, primarily, be through the development of a Construction Environmental Management Plan (as outlined elsewhere in this ES). This will include, but not be limited to, provisions to ensure that any further utilities’ connections are provided within the ground with impacts on sensitive areas avoided by careful routing of pipes where feasible and retention of access to farm land so that no restrictions occur.

9.8.2 Any clean soil excavated during the construction works will be stored on site 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 Condition 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)

Baseline Scenario (Existing Conditions)

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 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 Condition Scenario

9.9.3 Proposed mitigation for operational impacts under this scenario is as described under the ‘existing conditions scenario’ above

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9.10 Residual Effects

9.11 Baseline Scenario (Existing Conditions)

9.9.1 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 arising through bird hazard control practices. 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.

9.9.2 The total land-take for the proposed terminal development is considered insignificant and is confined to hardstanding and temporary surface (gravel) of no nature conservation value.

9.9.3 Amenity impacts on other users (e.g. recreational users) are discussed elsewhere in this ES.

Future Assessment Condition Scenario

9.9.4 Residual impacts are expected to be as described for the ‘existing conditions scenario’ above.

9.10 Summary

9.10.1 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 terminal building will be built on land currently within the airport boundary on existing hardstanding and temporary surface – gravel (of limited nature conservation value) and no significant changes in land use are envisaged.

9.10.2 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.

9.10.3 Overall, the impacts of the proposed terminal building will be the same (by comparison) for both the Baseline and Future Assessment Condition scenarios.

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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 terminal modifications. The Chapter focuses on impacts to flora and non-avian fauna – impacts on, or derived from, interactions with birds are addressed in Chapter 11.

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 Legislative 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 Plan – Deposit Plan September 2003; & Adopted Plan 2006 and

• Shepway District Local Plan Review - 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 terminal building 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 Appendices 10.2.

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

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.

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Study Area Surveys undertaken Survey Lead Dates Surveyor 2005 Amphibian Survey May - June HRA 2004 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).

2 Joint Nature Conservatrion Committee (JNCC) Handbook for Phase 1 Habitat Survey: A Technique for Environmental Audit.

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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 following:

• 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;

• the vegetated shingle to the south and east of the runway which could support interesting ecological assemblages including Cladonia lichens; and

• the 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

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.

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Groups of Britain and Ireland (HGBI) 10 11 12(including refuge searches and direct 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 has undertaken detailed monitoring of a number of waterbodies near the proposed project since 1994 13.

10.3.14 To supplement these data, waterbodies that could be affected by the proposed 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:

• 2004: survey of 15 ponds and waterbodies within the airport boundary15 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.

10 English Nature (1998) Species Conservation Handbook (Herps). 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.

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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 existing 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 10.2D). 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.

10.3.22 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.

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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

10.3.23 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.

10.3.24 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

10.3.25 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.

10.3.26 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 the published selection criteria for national designation (e.g. SSSI selection guidelines) irrespective of whether or not it has yet been notified.

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

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Receptor Examples Importance/ Sensitivity 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.

10.3.27 Impact magnitude has then been assessed for the airport site on 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.

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• 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.

10.3.28 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.

10.3.29 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

10.3.30 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.

10.3.31 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.

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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 is 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 southern shore. 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;

• 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.

27 English Nature Leaflet (2005) The Romney Marshes and Rye Bay: A Review of the area’s nature conservation designations.

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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 Sites

10.4.11 There are two internationally designated areas of nature conservation importance located within the vicinity of LAA, namely:

• The Dungeness SAC, located immediately east of the existing runway; and

• 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;

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• 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 is 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.

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.

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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 and location of these species are provided in Appendix 10.4.

10.4.24 There are 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 than 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 (see Appendix 10.2E) 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- shaded sewers compared with the larger drains 28.

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 boundary, 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 29.

28 Ball, J (2005) Watercourse survey at Lydd Airport, Kent 29 Pitts, J. (2005) Botanical Survey Report and Report on the Lichens of the Main Study Area, Lydd Airport.

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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 10.2F.

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. No surveys for medicinal leech have been undertaken to date within the drainage ditches to the west of the existing terminal building. It is therefore assumed for the purposes of this assessment that medicinal leech is present within these waterbodies.

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.

10.4.35 A summary of notable and protected invertebrate 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 electro-fishing 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 (Denge Marsh Sewer) and a ponded area of the ditch within two culverts linked to these slightly to the east, as well as drainage ditches in proximity to the existing terminal building.

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Reptiles

10.4.38 Common lizards were recorded from 11 locations within the airport site 30 (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 (see Appendix 10.2G), namely great crested newt, smooth newt and marsh frog 31 32. 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 (see Appendix 10.2H). 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 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 33 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 existing terminal building and 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.

30 Ecoline (2005) Protected Species Survey Report, LAA Lydd Airport Expansion Programme. 31 English Nature Great Crested Newt Survey Data for the Dungeness Area. 32 Humphries Rowell Associates (2004) Lydd Airport: Amphibian Surveys 33 Tanner, I. (2005) Phase 1 Habitat Survey of Lydd Airport Site

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Mammals

10.4.47 Substantial evidence of water vole activity was found in the ditches to the north of the runway 34 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 (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 Although no evidence of water vole activity was noted along the drainage ditch to the west of the existing terminal building during the 2005 survey, this area has not since been surveyed. Given the substantial water vole activity noted to the north of the runway in 2006 (which was not noted in the 2005 survey), it is assumed that water voles are present within the drainage ditch to the west of the terminal.

10.4.50 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. Although no specific surveys have been undertaken of the drainage ditch to the west of the existing terminal building, it is assumed for the purposes of this assessment that water shrew are likely to be present within this drainage ditch.

10.4.51 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.

10.4.52 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.

10.4.53 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 were also noted in the vicinity of the main pond.

10.4.54 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.

34 Parsons Brinckerhoff Ltd (2005) Lydd Pond A: Aquatic Mammal Survey

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Birds

10.4.55 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

10.4.56 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.

10.4.57 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.

10.4.58 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.

10.4.59 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.

10.4.60 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

10.4.61 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.

10.4.62 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 be of ‘international’ importance.

10.4.63 The various ecological units and features are listed in Table 10.5 along with the importance / sensitivity category assigned to each one.

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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

10.4.64 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.

10.4.65 Ongoing habitat management practices at the airport 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.

10.4.66 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 oxides of nitrogen (NOx) for the protection of vegetation and ecosystems35 36. For

35 These are broadly equivalent to the critical levels set by United Nations Economic Commission for Europe (UNECE) and the World Health Organisation (WHO) 36 English Nature Scoping Opinion, letter to Shepway District Council dated October 4th 2005

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–3 37 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.

10.4.67 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 include natural ecological succession, but in this instance, such changes would be driven by 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 Whilst most of the ecological resources in and around the site are described in the existing conditions scenario above, 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. However 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.

10.5.3 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 may 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.

10.5.4 Asoutlined in 10.4, above, 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 (see chapter 15) indicated that such impacts are expected to be of no more than

37 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/

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minor significance.

10.5.5 The increased numbers of aircraft, support vehicles/plant and road vehicles using the airport site as the airport grows 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 is not expected to affect the baseline conditions

10.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

10.6.1 The proposed construction works will result in a number of potential impacts,, including direct habitat loss, the potential for contamination and siltation of watercourses, disturbance effects and incidental mortality. Each of these is addressed further below.

Direct habitat Loss

10.6.2 The proposed terminal building will be primarily located on hardstanding and improved grassland of limited nature conservation value, but will also involve the loss of some 0.56 ha from the proposed North Lade SSSI. Despite the designated nature of this site, the loss represents less than 0.01% of the total 5661 ha that are designated, and of itself is therefore considered to represent only a minor impact. Potential impacts upon the SAC are also considered to be of only minor significance as habitat disturbance will be limited to the proposed development footprint outlined above, with all construction works confined within this area. Further assessment of the implications to the SAC will be undertaken in the form of an Appropriate Assessment, to be undertaken by the Competent Authority (in this case Shepway District Council) in accordance with the requirements of Regulation 48 of the Conservation (Natural Habitats& C.) Regulations (1994). A “Statement to Inform” is currently being prepared in accordance with these regulations to assist the Competent Authority.

10.6.3 Impacts on sensitive habitats elsewhere on the airport site, including the vegetated shingle and lichen communities to the east of the site, would not be affected due to their distance from the construction works

Impacts due to Contamination / Siltation of Watercourses

10.6.4 Although a drainage channel runs adjacent to the existing terminal area, the proposed works would not directly affect this or any other watercourse nearby. Whilst there is always the potential for accidental pollution to watercourses during construction works, these will be addressed through the use of good construction practices (as detailed in Chapter 7 Water Resources and Flood Risk of this ES) and no significant ecological impacts are expected.

Air Quality Effects

10.6.5 Air quality can be adversely affected by both particulates emitted during construction, (e.g. dust from stockpiled material) and from emissions from construction plant and vehicles. Whilst such pollutants can be carried around the site via aerial transmission, dust in particular tends to only affect habitats within 200m of the construction site and

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as no sensitive ecological receptors are located within this area, (with the possible exceptions of the drains), no significant impacts are expected.

10.6.6 Issues related to air quality impacts are addressed in more detail in Chapter 15 Air Quality of this ES.

Disturbance

10.6.7 Construction activities are likely to cause general disturbance to ecological receptors in the area, primarily as a result of increased noise, vibration and lighting levels, as well as increased vehicular movements. Whilst 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.

10.6.8 Potential impacts upon the SAC and other ecologically designated sites in the area arising from such impacts are considered to be of minor significance as the habitat within the proposed SSSI is either hardstanding or temporary surfacing (gravel). Impacts on sensitive habitats elsewhere on the airport site, including the vegetated shingle and lichen communities to the east of the site, would also not be affected due to their distance from the construction works.

10.6.9 Most of the faunal species known to inhabit the area 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.

10.6.10 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. It appears unlikely that the works associated with the proposed terminal development would disturb great crested newts and given the distance of the proposed works from the known breeding pond to the east of the site and the ponds of potential interest to the north-west within the golf course, no significant impact is predicted.

Future Assessment Conditions Scenario

10.6.11 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.

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10.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

10.7.1 Operational impacts on non-avian ecology include impacts arising through changes to air quality, disturbance effects from noise and vibration, water quality and drainage effects and disturbance effects from lighting, all of which are discussed further below. Impacts on birds are addressed in Chapter 11.

Air Quality Effects

10.7.2 The increased numbers of movements of aircraft and road traffic associated with the proposed development is expected to lead to localised changes to air quality (including the potential for increased nitrogen disposition).

10.7.3 The local shingle communities, with their rare lichen and bryophyte communities, are characteristic of nutrient-poor environments and are considered particularly sensitive to the effects of nitrogen enrichment. However, no such habitats are located near the main access roads to the airport, and modelling shows that impacts arising from changes in air quality in these locations are not expected to add significantly to existing pollution loadings. Some habitats are, however, located near the runway itself, and existing nitrogen deposition levels also exceed critical loads for these habitats throughout the area as whole. Given the sensitivity of these habitats, overall impacts are expected to be of moderate significance.

10.7.4 Communities associated with the drainage ditches, which support both notable botanical species such as divided sedge and uncommon fauna such as medicinal leech are also sensitive to changes in air quality leading to acidification and eutrophication. However, given the levels of nitrogen deposition presently experienced throughout the area, the predicted changes in air quality levels are not considered large enough to cause a significant effect.

10.7.5 Further information on Air Quality effects on ecological receptors in the area is provided in Chapter 15 Air Quality of this ES.

Noise and Vibration Effects

10.7.6 The increased levels of air and road traffic will result in locally increased levels of noise and vibration effects, as discussed in Chapter 16 Noise and Vibration of this ES. Impacts on flora and non-mobile fauna are considered negligible. For other (non avian) wildlife, existing evidence regarding the potential disturbance effects of noise and vibration on such species is inconclusive and, as many of the species present appear habituated to living in an active airport environment, overall the proposals are expected to only have a minor impact. The potential for impacts on bird conservation is assessed in Chapter 11 Bird Conservation and Hazard Management of this ES.

Water Quality and Drainage Effects

10.7.7 Whilst no effects on hydrological conditions are envisaged as a result of the proposed development, increased use of surfactants such as detergents and fire retardants may increase levels of phosphates and other chemicals entering the drainage system. The increased numbers of aircraft and road vehicles using the airport will naturally increase the risk of accidents, with the associated risks of oil, fuel or other

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chemicals (including fire fighting chemicals) entering the waterbodies. These and other impacts on water quality are addressed fully in Chapter 7 Water Resources and Flood Risk of this ES.

10.7.8 The aquatic communities associated with the Dungeness SAC and SSSI, and surrounding areas are considered particularly sensitive to pollution and increased levels of Biological Oxygen Demand (BOD), nitrogen deposition, phosphorous or ammonia could in turn affect the associated faunal populations. The development of algal blooms in particular could lead to a reduction in dissolved oxygen content of the water, causing impact to sensitive faunal species, whilst detergents, oil and other substances can have poisonous effects on aquatic life or lower the surface tension of water, thus affecting the survival of aquatic invertebrates. Any such changes would be considered a moderate impact.

Lighting Effects

10.7.9 The proposed development would be located next to the existing airport terminal building, car park, hangars and aprons and it is not expected to result in any ecologically significant increase in lighting levels.

Future Assessment Conditions Scenario

10.7.10 Predicted impacts under this scenario are expected to be the same as described under the “existing conditions scenario” above, although levels of 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 , and generic mitigation measures will be implemented during construction to prevent and/or minimise potential impacts upon habitats and species in the area.

10.8.2 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;

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• 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.

10.8.4 No direct habitat loss will be caused by the proposed development as it is confined to existing hardstanding and temporary surface (gravel) of limited nature conservation value. As there will be no works undertaken in close proximity to drainage ditches, no habitat specific mitigation is therefore required.

Future Assessment Conditions Scenario

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

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 as part of the proposed EMS for the airport in discussion with Natural England. 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.

10.9.2 In addition, and 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.

10.9.3 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.

10.9.4 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

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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

10.9.5 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 indirect disturbance to habitats and species as a result of increased passenger capacity and associated air and road traffic.

Future Assessment Conditions Scenario

10.10.2 Residual impacts are expected to be as described for the “existing conditions scenario” above, although the magnitude of any impact will be reduced due to habituation.

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 impact, particularly once the mitigation measures included within this Chapter have been implemented.

10.11.2 No significant differences are expected between those impacts predicted under the “existing conditions” and “future assessment” scenarios, although the magnitude of the impacts under the latter will be reduced.

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CHAPTER 11

BIRD CONSERVATION AND HAZARD MANAGEMENT

CHAPTER 11

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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 birds, 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 summarises 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 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. In addition 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;

• Kent & Medway Structure Adopted Plan 2006; and

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• Shepway District Local Adopted Plan 2006.

11.3 Assessment Methodology

Ornithological Studies

11.3.1 The key objectives of these studies 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 review existing data on 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 Areas

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 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 birdstrike risk, whilst others, especially the smaller passerines, have not been recorded as causing damage to commercial turbine engines 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 both 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; • Gamebirds;

• Grassland plovers and • Corvids; coastal waders; • Starlings; and • Raptors; • Pigeons. • Waterfowl; 11.3.8 11.3.8 The bird-strike risk assessment has therefore focussed on all of these groups, of which the first four are also of conservation importance.

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 by 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 development be allowed to proceed, appropriate mitigation can be put in place 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 study area and to identify important non-designated breeding sites. Surveys were carried out in spring/summer 2005 and 2006, by the same experienced surveyor.

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11.3.14 In 2005, four visits were made to the study area (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 British Trust for Ornithology (BTO) 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 Ten further 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 Bird 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). 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).

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

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 existing data;

• Site visits and refinement of the risk assessment 5 with reference to 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. 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.

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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’ 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. For the purposes of such assessments, the CAA SRG defines hazard as ‘a physical situation that, often following some initiating event, 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 Potential hazard of birds to aircraft has been assessed in terms of general groups, as outlined in 11.3.7, which reflect those species likely to visit the airport to determine tolerability and 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) 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 can 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.

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 the Baseline Environment for the key species of Birdstrike and Conservation Importance paragraphs.

Hazard Severity

11.3.27 A four level system is used to define hazard severity and definitions are used as shown in Table 11.6 below. 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 birdstrikes 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 airport’s 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

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ruff (Philomachus pugnax) and is considered to be of local importance for its 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 below.

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 189 3.8% GB population Red-throated diver (Gavia stellata)

824 5.2% GB population Great Crested Grebe (Podiceps cristatus)

Cormorant 246 1.1% GB population

3 3.0% GB population Bittern (Botaurus stellaris)

Bewick’s Swan 147 1.8% GB population

European White-fronted Goose 430 7.4% GB population (Anser albifrons)

3,107 0.8% GB but >2,000 indivs Wigeon (Anas Penelope)

Gadwall 216 1.3% GB population

Shoveler 495 1.2% International population

4,177 1.7% GB population Golden Plover (Pluvialis apricaria)

12,106 0.6% GB but >2,000 indivs Lapwing (Vanellus vanellus)

251 1.2% GB population Sanderling (Calidris alba)

Waterbird assemblage 33,800 + >20,000 indivs -

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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 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

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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 bird 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 11.2 for 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.

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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.

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 (see Appendix 11.1). 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 11.2) 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. 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.

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SITE Field Survey Data: Winter 2004/05 and 2005/06 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 (Appendix 11.3 and 11.4). 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 Figures 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).

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

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Site Field Survey Data: Spring / Summer 2005 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. 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.

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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 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 presence of gulls and terns near 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. Mediterranean gull International Mainly summer visitor. Has bred. Until the 1950s this was 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.

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Species Status Comments Black headed gull Local Common resident. A declining breeding species – the populations colony that nests on the islands of the Burrowes Pit within not of the RSPB reserve has dwindled to just a handful of pairs. particular Formerly bred on the open shingle of the ARC Pit. The conservation highest breeding counts are 1150 pairs in 1979 and 1100 status 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 Burrowes Pit, New Excavations and Dengemarsh and not of formerly bred on the Water Tower Pits. The best year particular was 1996 with 13 pairs compared with the 2000-2004 conservation breeding five-year mean of 11 pairs. Dungeness is the status only site where this species breeds in England. Herring gull Local Common resident. Breeds annually on Burrowes and populations ARC Pit with a peak of 129 pairs in 1997 compared with not of the 2000-2004 breeding five-year mean of 70 pairs. The particular peak counts are 30,000 in February 2000 at Lade Sands conservation and 8,000 in February 2001 on Burrow’s Pit. status

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. Information on the abundance of grassland plovers and coastal waders near LAA is provided in Table 11.14. Table 11.14: Abundance of Grassland Plovers and Coastal Waders at LAA Species Status Comments Golden plover International 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 importance Sanderling Local Passage migrant and winter visitor. The peak count at Lade populations not Sands in recent years is 330 in March 2000. The 1999/2000 – of particular 2003/04 five-year peak mean for this site of 221 is of national conservation importance. status Whimbrel International Rye harbour (passage) importance

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Species Status Comments Oystercatcher National Resident. Breeds annually with a peak count on the RSPB 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 Scarce breeding summer visitor and passage migrant. A pair Plover populations not bred successfully on the RSPB reserve in 2003. of particular 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. 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

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Common Con. Status Comments Name 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. Over- wintering species present include Bewick’s swans, shoveler, pochard and smew. These species are both of conservation importance and significant bird strike hazards.

11.4.30 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 Importance and 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) Coot National Importance Common resident (National Breeding)

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Common Con. Status Comments Name Overwintering (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

11.4.31 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

11.4.32 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 airfield, 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

11.4.33 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

11.4.34 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

11.4.35 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.

Additional data from the Wintering Bird and Breeding Bird Surveys

11.4.36 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).

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11.4.37 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.

11.4.38 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.

11.4.39 Species recorded during the winter and breeding bird surveys are shown in Tables 11.18 and 11.19 and Table 11.20 below, with raw data from the surveys provided as Appendix 11.3 and 11.5

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 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

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Red listed Amber listed Green listed 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

11.4.40 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 although no specific sightings of such movements have yet been collected in the LLA’s vicinity.

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Summary

Bird Conservation

11.4.41 It is clear that the greater 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, however, there are parts of the study area, especially extending north from the airport towards New Romney, that appear more or less devoid of birds in the winter months, especially in harsh weather. A key 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.

11.4.42 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

11.4.43 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.

11.4.44 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.

11.4.45 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 recorded however because of local game rearing practices.

11.4.46 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

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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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.

11.4.47 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 (both Bewick and Whooper swans in particular) and (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 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 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

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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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 Direct impacts associated with the proposed construction works will be limited to the loss of an area of existing hardstanding and some temporary surface (gravel) of limited nature conservation value. The magnitude of this impact is considered negligible, and its overall significance low.

11.6.2 Disturbance impacts associated with noise, vibration air quality, traffic and other construction activities are addressed in detail elsewhere in the relevant chapters of this environmental statement, but given the temporary nature of the works the magnitude of this impact is again considered negligible, and its overall significance low.

11.6.3 No changes to birdstrike hazard are expected to arise from construction works.

Future Assessment Conditions Scenario

11.6.4 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

11.7.2 As outlined in the Baseline Environment (Future Assessment Conditions Scenario) the increased levels of air traffic associated with 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

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• Indirect impacts on future bird conservation measures in the area through safeguarding; 11.7.3 Each of these is discussed in more detail below.

Bird overflight

11.7.4 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.

11.7.5 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 only take place after negotiation and agreement with the relevant landowner or tenant, as well as discussion with the conservation authorities.

11.7.6 Overall, therefore, impacts arising through overflight are considered to be of moderate significance.

Indirect impacts from disturbance

11.7.7 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.

11.7.8 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.

11.7.9 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.

10 Burger J 1981. Behavioural responses of Herring Gulls (Larus Argentatus) to aircraft noise. Environmental Pollution (Ser A) 24:177-184

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11.7.10 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.

11.7.11 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

11.7.12 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 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.

11.7.13 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

11.7.14 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.

11.7.15 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.

11 Kushlan JA. Effects of helicopter censuses on wading bird colonies. J Wildlife Management 43:756-760. 1979.

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Impacts to Bird Conservation arising as a result of safeguarding measures

11.7.16 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.

11.7.17 Appropriate mitigation for such impacts is included in Section 11.9 below.

Birdstrike Hazard

11.7.18 With 500 000 passengers pa passing through the proposed terminal, 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 14 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.

11.7.19 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

11.7.20 Operational impacts on bird conservation arising through the use of the new terminal facility (and as a result supporting 500,000 passengers per annum) are expected to be similar to those outlined under the Existing Conditions Scenario above. The prior implementation of the bird control programme and the habituation of existing bird populations to the operational airport would however mean that the magnitude of any impact would be considered to be reduced , and any impact would therefore be of no more than moderate significance.

11.7.21 In addition, with the proposed bird control programme in place, the airport would expect to see only a minor increase from 13 to 14 birdstrikes per annum for the 500 000 passengers pa scenario. 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.

11.8 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, and implementation of mitigation to minimise disturbance as outlined in other

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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 above, some of the bird populations present at LAA 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 the airport as it expands, 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, 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. 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) to 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

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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.

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.

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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 proposes 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

• 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

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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 approximately 150mm tall. Ripening crops may attract corvids and pigeons for a short while, as will any stubble 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.

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 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.

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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 described above, overall impacts on wintering bird populations as a result of the proposed terminal developments to facilitate the handling of 500,000 passengers per annum 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 Again, as discussed, overall impacts on breeding birds as a result of the proposed developments are 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 (as described below) and will be used to refine it if needed to optimise the areas of ornithological interest.

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

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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 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

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hazard species are discouraged. It is clear that the development proposals brought forward by LAA 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 terminal expansion is located in an area of unusually high ornithological value and the sensitivity of the wintering and breeding bird population is thus considered to be very high. The significance of the direct impacts from habitat loss is considered to be low. The direct impact of the terminal expansion 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 terminal expansion are predicted to have low-moderate impacts.

11.11.3 When benchmarking LAA against other airports with comparable bird populations, the predicted number of birdstrikes for the proposed terminal development is considered to present an acceptable 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 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 the 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 severity of any impacts resulting from a comparison with the “future assessment” scenario would be significantly lower that arising from the “existing conditions” scenario.

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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 is to determine the magnitude and significance of any impacts likely to be associated with the proposed terminal building at London Ashford Airport (LAA) at Lydd, by comparison with the a) baseline (existing conditions) and b) future assessment condition (300,000 passengers and the proposed runway extension) scenarios.

12.1.2 The scenarios modelled in this chapter are as described in Chapter 1, and full details of the proposed scheme are provided in Chapter 4.

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 (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 (Chartered Landscape Architects also registered with The Landscape Institute) carried out field surveys in April and May 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 (2006);

• Shepway District Local Adopted Plan (2006);

• The Kent Landscape Information System online database; and

• Guidelines for Landscape and Visual Impact Assessment – 1st Edition 1995; and 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;

• 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.

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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 (AONB) 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).

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 Medium of AONB’s, usually County / District notations and some Conservation Areas and settings of some Listed Buildings and with some detractors.

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LANDSCAPE RECEPTOR RANKING MAGNITUDE OF CHANGE SENSITIVITY

For example, a relatively unimportant Virtually imperceptible change in any

area, the nature of which is potentially components. Low tolerant of substantial change and probably has significant detractors.

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 of rural and semi rural public rights of way, Medium ordinary visual quality or clearly views from commercial premises or visible changes that are subordinate from moving vehicles, where view is to other elements in the view occasional.

For example, industrial premises, some For example, few viewers affected or residential properties, urban public Low 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

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 three 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.

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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 might be visible, and the degree of unmitigated impact was assessed. 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 residual effect 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.

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 land form of the site and its surroundings.

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 Tables 12.4 provide descriptions of the extent and significance of views from particular areas surrounding the site, on the ZVI plan (Figure 12.1) 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

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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 (i.e. the viewer’s) cone of vision and the proposed development themselves 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 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, extended to 5km to the north west towards Old Romney and to the south east in the vicinity of Dungeness Point. Locally elevated areas within these radii were also checked (e.g. sand dunes, overbridges).

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12.4 Baseline Environment (Existing Conditions)

Site Description

12.4.1 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 and Lydd-on-Sea lie just over 2.3 km east of the proposed terminal building, with New Romney lying approximately 3km to the north and Lydd approximately 1km 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 5.4km from the site.

12.4.2 The proposed site for the new terminal building comprises of an area of hardstanding “airside” and a small area of improved grassland within the existing airport perimeter.

Site Surroundings

12.4.3 The site of the proposed terminal building is just over 2.2km inland from the coast. Lydd Airport itself extends for approximately 1.5km to the north east, east and south east of the proposed site. Between the airport and Lydd Golf Course, which lies to the north of the site, is an area of flat open farmland. The airport site and the area of farmland are defined as area B (see Figure 12.1).

12.4.4 The existing 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 8m in height. The two adjacent aircraft hangars are a visual feature of the 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 (approximately 30m high) associated with the hardstanding in the vicinity of the proposed terminal building.

12.4.5 There are large areas of hardstanding 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.

12.4.6 Beyond the airport boundary, to the north of the site, flat open farmland stretches for approximately 2km to the edge of New Romney. This area of farmland features clumps of tree planting around one or two farmsteads, some intermittent shelterbelts and areas of scrub willow along some of the watercourses (Area A, Figure 12.1).

12.4.7 Beyond the airport to the north east of the site, flat open farmland extends to the edge of Greatstone-on-Sea approximately 2.3km from the site. To the east of the site, flat farmland gives way to flooded former gravel workings within 600m of the airport perimeter. 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 approximately 1450m from the site (Area C, Figure 12.1). Beyond this the predominantly residential edge of Greatstone-on-Sea sits on a shallow shingle platform approximately 150m above the farmland and the flooded gravel workings. There are some limited views of the site from dune tops at the back of the public car park in Greatstone-on-Sea (Area D, Figure 12.1).

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12.4.8 To the south east of the airport lie the shallow shingle ridges of the Dungeness Shingle SSSI and SAC, crossed by a number of public footpaths, and further flooded gravel workings now part of designated nature reserves. An old water tower and above-ground storage tank are visual features of the shingle. Public access on the shingle is possible to within approximately 750m of the site (Area E, Figure 12.1). To the south east, sandwiched between the shingle and Lydd-on-Sea, is an operating gravel pit approximately 1.4km from the site.

12.4.9 The shingle and flooded former gravel workings extend beyond Dungeness Road to the Dungeness Power Station complex and Dungeness Point approximately 5.8km from the site (Area F, Figure 12.1).

12.4.10 To the south and south west of the proposed site, flat open farmland extends for approximately 3km. The southern edge of this area of farmland to the south of Dungeness Road gives way to former gravel workings, some of them flooded, which now accommodate a number of sports facilities (e.g. water skiing, karting, etc). Along the western edge of this area of farmland lies the southern part of Lydd, with a mixture of residential and industrial buildings forming the edge that looks out over the farmland towards the site (Area G, Figure 12.1).

12.4.11 The area of farmland to the north of Dungeness Road stretches west and south west from the proposed site for approximately 1-1.5km as far as the eastern edge of the northern half of Lydd where a mixture of residential and industrial uses, together with several farmsteads, overlook the farmland (southern part of Area H, Figure 12.1). Lydd Golf Course is situated immediately to the north west and north of the proposed site and includes the location of a proposed mainly three-storey, part four-storey, hotel that has been granted planning permission. As a comparison with the proposed terminal building, the bulk of this building will be approximately 16m in height and the four-storey element over 20m in height. The golf course has been created as a links style course with undulating landform, its nearest edge being approximately .180m from the site of the proposed terminal building (northern part of Area H, Figure 12.1).

12.4.12 The B2075 comes to within 950m of the site at its nearest point; beyond it and Lydd, flat farmland stretches for several kilometres to the west and north west. Pockets of tree planting and intermittent shelterbelts are a feature of the farmsteads and occasional houses scattered either side of the B2075 between Lydd and the A259. This results in the site being screened from view from much of the B2075 and from much of the area beyond (Area J, Figure 12.1). It should be noted, however, that there are some distant glimpses of the proposed terminal building from the latter area.

12.4.13 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 proposed terminal building. Montages have been produced for five of these viewpoints (numbered M1to M5 in the list below, see Plates 12.13 - 12.17). The proposed montages were selected as being typical of a range of viewpoints of the proposed development from varying directions and distances. Although 6 were commissioned, one was needed to be a night-time view and therefore only five day-time views were available. These views were then discussed and agreed with SPC as required by the scoping report.

12.4.14 Photographs of the other viewpoints (numbered V1 to V12, see Plates 12.1 - 12.12) with the extent of the proposed building indicated on them. The list of viewpoints which has been agreed with SPC as required in the scoping report is as follows:

Plate 12.1 Looking south west from the eastern part of Church Lane on the V 1 southern edge of New Romney;

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Plate 12.2 Looking south west from just south of where the public footpath V 2 crosses the Romney Hythe and Dymchurch Railway line approximately 350m south of the eastern end of Church Lane, New Romney;

Plate 12.3 Looking south west from dune tops at the back of Greatstone-on- V 3 Sea public car park;

Plate 12.4 Looking west from the shingle platform at the back of the Romney V 4 Sands holiday park at a point approximately 200m to the south of the causeway that leads to the sound “mirrors”;

Plate 12.5 Looking north west from the northern extremity of the Dungeness V 5 shingle where it gives way to farmland;

Plate 12.6 Looking north west from the public footpath just to the south of the V 6 sound “mirrors” information plaques;

Plate 12.7 Looking north west across the Dungeness shingle ridges from the V 7 west end of Taylor Road, Lydd-on-Sea;

Plate 12.8 Looking north west from the earthworks just to the north of the old V 8 coastguard cottages at Dungeness Point;

Plate 12.9 Looking north east from Dungeness Road approximately 800m east V 9 of the Dungeness Nature Reserve Visitor Centre;

Plate 12.10 Looking north east from Denge Marsh Road at the point where the V 10 public footpath joins it in the vicinity of Manor Farm;

Plate 12.11 Looking north east from the junction of Tourney Road and Robin V 11 Hood Lane on the south east edge of Lydd;

Plate 12.12 Looking south east from the point on the airport entrance road at V 12 which the proposed terminal building becomes visible, approximately 150m east of the B2075 Romney Road.

Plate 12.13 Looking south east from the B2075 approximately 140m south of its M1 junction with the A259 at Hammond’s Corner;

Plate 12.14 Looking south west from the west end of Baldwin Road, Greatstone- M2 on-Sea;

Plate 12.15 Looking north east from Dungeness Road in the vicinity of Cockles M3 Bridge;

Plate 12.16 Looking north east from the eastern edge of Lydd where the public M4 footpath to Greatstone on Sea leaves the town at the end of Oakham Drive;

Plate 12.17 Looking south east across Lydd Golf Course from the public M5 footpath that skirts the north west corner of the course.

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Geology, Topography and Drainage

12.4.15 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.

12.4.16 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, and nearer to Lydd (in the area known as Denge Marsh), the ploughed farmland and pasture become increasingly soil-based and are strewn with the rounded flints.

12.4.17 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

12.4.18 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 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 sound “mirrors” to the 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 as part of a Natural England ongoing programme to restore shingle habitats.

12.4.19 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.

12.4.20 Surrounding agricultural land is a mix of sheep pasture, amenity turf production and mixed arable, with a significant amount of vegetables of varying kinds.

12.4.21 The Lydd Golf Club is a links style course with a characteristic mix of managed grassland of varying height.

Landscape Character

12.4.22 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.

12.4.23 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.

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12.4.24 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.

12.4.25 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.

12.4.26 Vast areas of disturbed shingle, security fencing and flooded mineral workings/gravel extraction mark the centre of the character area. The airport and thus the site of the proposed terminal building lie on the transition from the exposed shingle to grassland and agriculture on thin soils.

12.4.27 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 preclude 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 and creates an almost continuous built skyline to the east, south east and south west of the airport.

12.4.28 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 structures of the “Lydd Ear” 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 it is reduced by frequent mists and haze and the considerable distances between features in the open landscape.

Sensitivity

12.4.29 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 south east of the airport, approximately 900m from the site of the proposed terminal building.

12.4.30 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, although most of the airport, including the site of the proposed terminal building, is not within any landscape designation.

12.4.31 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.

12.4.32 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

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the many unique features. The cluster of defence installations, the power stations, the “Lydd Ear”, the old water tower, holiday properties on the spit and specialised coastal and shingle-based vegetation, all contribute to a very strong sense of place in which buildings as well as natural forms contribute significantly to the character of the landscape. The landscape is highly valued as demonstrated by the various designations described above.

12.5 Baseline Environment (Future Assessment Conditions Scenario)

12.5.1 The Future Assessment Condition scenario would see the airport continuing to be maintained in accordance with safety requirements.

12.5.2 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 the planned scrub removal from parts of the Dungeness Shingle SSSI and SAC which are within the airport boundary to the east of the existing runway.

12.5.3 Although the condition of the airport would therefore be expected to remain generally in its existing form as current management practices are anticipated to continue, the scrub removal will result in increased visibility of the existing airport buildings seen from the east and south east.

12.5.4 As it is anticipated that there will be no changes to current management practices, there will be no changes to the landscape resource or landscape character of this area.

12.5.5 As with the effects on the landscape itself, the fact that no changes are anticipated to current management practices, means that there will be no change in its visual appearance and therefore no change in its effect on visual receptors.

12.5.6 However, removal of scrub vegetation elsewhere within the airport boundary will result in the existing airport buildings becoming more visible from the publicly accessible parts of the Dungeness Shingle SSSI and SAC. Given the fact that the airport exists and the buildings are already familiar in other views and given also the distance that receptors would be from the buildings and the resulting receptor sensitivity and magnitude of change, the significance of this visual impact would be slight and neutral.

12.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

Landscape Effects

12.6.2 Construction of the proposed terminal building will not result in the loss of any soft landscape resource. Consequently, with regard to the landscape resource of the site the change has no impact at all.

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Visual Effects

12.6.3 The most likely visual impacts on receptors during construction will be the presence of a crane or cranes, the skeletal structure of the building and in close views security fencing/hoardings around the construction site. These are an inevitable part of any construction project and, being temporary are seen at more than 1km distance by the great majority of receptors, are considered of slight significance.

12.6.4 In the case of construction traffic delivering to the site, which is transient, the visual impact of large vehicles on the road network in the area that already carries considerable HGV traffic to and from local gravel extraction and landfill sites, is likely to be of slight and neutral significance. Construction workers’ cars and vans will be parked close to the construction site within airport car parks and will therefore not impinge on local residential areas which are anyway more than walking distance from the site. The impact of these cars on local residents will therefore be negligible.

Future Assessment Condition Scenario

12.6.5 Construction impacts under this scenario are predicted to be as for the ‘existing conditions scenario’.

12.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

Landscape Effects

12.7.1 Operation of the proposed terminal building will not result in the loss of any soft landscape resource. Consequently, with regard to the landscape resource of the site the change has no impact at all.

12.7.2 With regard to the intrinsic landscape character of the airport and its surroundings, it is not only the landform, vegetation (or lack of it) and land use that contributes to the scale and texture of the landscape, but also the buildings within it. In views across the area, single individual buildings (whether large ones such as the power stations, or medium sized ones like the modern farm sheds such as the one at Belgar Farm, or the aircraft hangars on the airport itself) are generally seen as relatively small and separate skyline elements within the overall view. The scale and simple form and texture of the proposed terminal building is similar to that of the larger farm buildings in the landscape and the existing aircraft hangars on the airport. Consequently, whilst both the sensitivity of the landscape character of the airport and its surroundings and the magnitude of change can be said to be medium, and the significance of its effect on the landscape character therefore to be moderate, the proposed building fits with the scale and grain of the wider landscape and, as a result, its impact is considered to be neutral.

Visual Effects

12.7.3 The ZVI (see Figure 12.1) from which some part of the proposed site may be seen extends approximately 3km to the north, approximately 2-2.5km to the north east and east, approximately 5km to the south east, approximately 3km to the south west and approximately 4.5km to the west and north west.

12.7.4 The attached table of receptors (Table 12.4) sets out on an area by area basis, starting in the north and working clockwise around the compass, definable areas of

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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.

12.7.5 Additional information explaining the context of the various views to an extent that cannot be accommodated in Table 12.4 is set out in the paragraphs below.

12.7.6 The open flatness of the site and its surroundings means that there is a relatively large area, most of it either the airport itself or surrounding farmland or the shingle, from which the proposed terminal building would be visible.

12.7.7 However, 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, visitors approaching the airport along the airport access road and golfers on parts of the Lydd Golf Course.

12.7.8 Even in an area within 1km of the proposed development, the only additional receptors other than farm workers, airport workers, visitors approaching the airport and golfers, would be walkers on the public footpath from Lydd to Greatstone-on-Sea, which passes along the southern boundary of the airport, and the residents of the small number of properties just to the east of the B2075 in the vicinity of and including Jack’s Court and Forty Acre Farm.

12.7.9 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 building generally forms only a small part of the viewer’s natural cone of vision, resulting in only small changes to the view. The only exceptions are some views from dwellings on the eastern edge of Lydd between Lydd Golf Course and Dungeness Road, views from Lydd Golf Course, views for some public footpath users within 1km of the site, views for some pedestrians from the western edge of Greatstone-on-Sea and from near the sound “mirrors” and the views for pedestrians and road users on a stretch of Dungeness Road to the south of the site and on the airport access road itself. In these cases, the significance of some of the unmitigated visual impacts is moderate.

12.7.10 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 close views of the proposed building are available to relatively few receptors and there are no substantial changes to views means that the significance of the changes can, in all but one case, be considered neutral and in that one other case, beneficial.

12.7.11 With regard to visibility of the proposed terminal building at night, the greatest visibility will be in side-on views from the north east and south west. These views would be seen by the small number of pedestrians that might be out walking after dark. They provide a benchmark against which the views from nearby housing can be judged. Furthermore, those most likely to have night-time views of the terminal building are road users on the Dungeness Road 1.3km or more to the south, whose views will be similar to Night Montage 4. It can be seen by comparing before and after views, that the location of the airport is already visible due to the presence of night-time security lighting. The lighting within the proposed terminal building will draw more attention to the airport location, although it will be seen by relatively few people and in many

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cases the visibility will be less distinct compared with the montage views. By comparison with night views of the Dungeness Power Station complex from the Dungeness Road and Lydd-on-Sea, its impact will be far less extensive, more isolated and more muted. Consequently, the significance of the impact of the proposed terminal building at night is considered to be slight.

12.7.12 In the event that the surplus soil (approximately 4,500m3) generated from excavations for the foundations is spread evenly within non sensitive areas, such areas would be filled to an average depth of less than 10cm and therefore this change is considered imperceptible in visual terms. It will therefore have no effect on the significance of the unmitigated impacts.

12.7.13 Notwithstanding the fore-mentioned visual impact from landing planes, the great majority of receptors at 500m or more from the runway will only be affected by these temporary and transient elements of the overall view.

12.7.14 The magnitude of change in the baseline view (when compared with the aircraft in the View 12 (Plate 12.12) would be medium. As most of the receptor sensitivities are low, this would, ultimately, result in an unmitigated future assessment scenario impact significance of slight to moderate. In the few cases where receptor sensitivities have been assessed as ‘medium’, the overall significance of unmitigated impact would be ‘moderate’.

12.7.15 Due to the distance between source and receptor, and the temporary and transient nature of landing planes, the significance of associated visual impacts can (overall) be considered ‘neutral’.

Future Assessment Condition Scenario

12.7.16 The only significant difference between the impacts associated with the future assessment conditions and with project scenario is the effect on visual amenity caused by increased air traffic, as a result of up to 500,000 (rather than 300,000) passengers passing through LAA on an annual basis. This would result in an increase from 12 to 18 planes per day, which is considered a minor impact.

12.7.17 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 approximately 1km from the viewer. Only 18 movements per day of aircraft larger than this would result from implementing the proposed terminal building and only 8 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.

12.7.18 Impacts arising through traffic disturbance or other effects on local ambience are dealt with elsewhere in this document.

12.8 Proposed Mitigation (Construction Impacts)

Existing Conditions Scenario

12.8.2 Due to the fact that the most significant impacts on this scenario will be the temporary and transient nature of cranes against the skyline, no mitigation measures are deemed necessary or practicable during construction phases.

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Future Assessment Condition Scenario

12.8.3 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.

12.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

Landscape Impacts

12.9.1 The proposed terminal building is similar in scale to the existing hangars and the occasional large modern barn or farm building visible in the surrounding open landscape and therefore relatively in keeping with the texture and grain of the wider landscape as a consequence. Extensive screen planting where none is necessary, would only draw the eye more and look out of place within the open landscape of the area would therefore be an inappropriate introduction in relation to this building.

Visual Impacts

12.9.2 Often, where visual impacts of a proposed development occur, screening with landform and/or planting is 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.

12.9.3 Planting of trees and hedges to effect partial screening is also considered inappropriate in this context. Minimisation of visual impact is achieved by the fortuitousness of distance between the site and the great majority of receptors, and the flatness of the site and its surroundings. In addition, although relatively limited, the presence and disposition of what offsite tree planting does exist in the vicinity of the site helps to limit visibility of the proposed building from the B2075 and the relatively few residential or farm buildings within 1km of the site.

12.9.4 It is also not possible to mitigate against visual impacts from aircraft movements, so no mitigation measures are therefore presented.

Future Assessment Condition Scenario

12.9.5 In relation to the development of the proposed terminal building, no mitigation measures as proposed for the future assessment condition scenario as discussed for the baseline scenario above.

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12.10 Residual Effects

Existing Condition Scenario

12.10.1 No significant adverse residual effects are anticipated from the proposed development.

Future Assessment Conditions Scenario

12.10.2 No significant adverse residual effects are anticipated from the proposed development.

12.11 Summary

12.11.1 The landscape character of the site and its surroundings and the impact of the proposed terminal buildings on that character and on human receptors has been assessed.

12.11.2 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 both the SLA and the LLA and there will be no impact of the proposed terminal building on the landscape resource of this area as no soft landscape elements will be lost to the proposed development. With regard to the building’s impact on the intrinsic landscape character of the area, whilst the significance of the degree of change that the building introduces into the landscape is moderate, its scale and simple form are in keeping with other larger individual buildings within the open landscape of the area and its impact is consequently neutral.

12.11.3 With regard to the terminal building, in almost all cases the significance of the unmitigated impact on those with a view of the proposed terminal building will be slight and neutral. In only a small number of instances, the impact is considered greater, being moderate and neutral and, in one case, moderate and beneficial. The degree of significance of these unmitigated impacts is due principally to distance, the infrequency and transience of many of the impacts and the fact that for many the changes caused by the proposed development will form only a small part of the viewer’s natural cone of vision.

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. There are, therefore, no residual effects to anticipate as a result of the proposed developments, as either a comparison between the 2010 scenario and a) the baseline or b) the future assessment condition scenarios.

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Table 12.4 Visual Impact on Receptors by Area for the Proposed Terminal Building

Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA A

Area of open flat farmland compartmented c.750-3150m Proposed terminal building seen at oblique angle in conjunction Low Low Slight, neutral by drainage ditches with existing hangars as small part of view by farm workers when working on the land whose presence is infrequent and transient.

Walkers heading south on footpath to Belgar Farm or south west Public footpath across parts of this land c.1250-3000m or south east on footpaths between B2075 and edge of New Medium to Low Slight, neutral Romney. Proposed building seen as small part of view partly low obscured by intervening vegetation.

c.2900-3100m Glimpse views from parts of Church Lane and possibly from Residential and industrial development on some buildings, mainly upper floor windows. Proposed buildings Low Low Slight, neutral southern edge of New Romney seen as small part of view in some cases partly obscured by intervening vegetation (View 1). c.2450-3150m Proposed building seen in conjunction with existing hangars as Pedestrians and road users on parts of the small part of view partly obscured by intervening vegetation Low Low Slight, neutral B2075 and A259 (Montage 1).

AREA B

Some flat open farmland to the west of the c.200-800m Clear views of proposed terminal building in conjunction with Low Medium to Slight, neutral airport compartmented with drainage existing airport buildings for farm workers when working on the low ditches land, whose presence is infrequent and transient.

Clear views of proposed terminal building in conjunction with ‘Airside’ part of Lydd Airport 0-c.1050m existing airport buildings for outside airport staff and aircraft Low Medium to Slight, neutral occupants, whose presence is infrequent and transient. low

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA C

Area of open flat farmland compartmented c.800-2300m Proposed building seen side-on or obliquely in conjunction with Low Medium to Slight, neutral by drainage ditches existing airport buildings by farm workers whose presence is low infrequent and transient.

Flooded former gravel workings with c.1250-1800m Fenced private land with ‘keep out’ signs but unofficial access to Low Medium to Slight, neutral vegetated margins with the sound “mirrors” walk the margins appears commonplace. Glimpse views through low structures sitting within the scrub on the scrub vegetation in places by people whose presence is western margins infrequent and transient. c.900-2100m Publicly accessible part of the shingle Clear, if distant, views of proposed building in conjunction with Medium to Medium to Moderate to ridges which are part of the Dungeness existing airport buildings for walkers who get this far (numbers low low slight, neutral SSSI and SAC likely to be limited) (View 5).

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact AREA D

Romney Hythe and Dymchurch railway line c.2250-2600m Glimpse views at a distance for passengers facing south on Low Low Slight, neutral narrow gauge railway. Proposed building a small part of overall view in views that are generally infrequent and transient (View 2). Residential development on Dunes Road, Greatstone-on-Sea c.2300-2400m Occasional glimpse views mainly from limited number of upper floor windows at a considerable distance from proposed building. Low Low Slight, neutral

Small area of sand dune tops at back of c.2400-2500m The most elevated, publicly accessible views available of the Greatstone-on-Sea public car park proposed building seen as small part of view just visible above foreground buildings which tend to draw the eye. Viewers limited Medium to Low Slight, neutral to some walkers and holiday makers whose presence is low infrequent and transient (View 3). c.1700-2375m Publicly accessible shingle platform up to Proposed building seen side-on or obliquely as a relatively small 2m above farmland/gravel workings/ part of the view in the vicinity of the existing hangars. Clearest shingle ridges immediately to the west, with views for walkers on edge of shingle platform or path leading to Medium to Medium to Moderate to a school, caravan park and residential sound “mirrors” information plaques, some of whom will be low low slight, neutral development along its eastern edge regular but many of whom will be infrequent and transient (Views 4, 6 & 7). Views from residential edge of Greatstone-on-Sea, Lade and Lydd-on-Sea will vary according to boundary vegetation and fencing and apart from occasional street level viewpoints such as Montage 2, are most likely to be glimpses from upper floor windows where these exist.

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA E

Publicly accessible part of the shingle c.1000-3450m Top of proposed building just visible over existing hangars as Medium to Low Slight, neutral ridges which are part of the Dungeness small part of distant view. View limited to walkers who are low SSSI and SAC generally infrequent and transient. c.1000-2600m Flooded former gravel workings with Top of proposed building just visible over existing hangars as Medium to Low Slight, neutral vegetated margins with some public access small part of distant view. View limited to bird enthusiasts visiting low to bird hides in some parts of the area nature reserve who are generally infrequent and transient. Water tower in middle ground is more likely to draw the eye. c.1600-3000m Drivers and pedestrians on Dungeness Top of proposed building just visible over existing hangars as Road between Boulderwall Farm and the small part of distant view for those heading westwards. Views Low Low Slight, neutral entrance road to the Dungeness Power generally infrequent and transient and water tower in middle Stations. ground is more likely to draw the eye (View 9).

AREA F

A large area of shingle ridges and flooded c.1850-5800m As building forms such a small part of the view at this distance Low Low Slight, neutral gravel workings with some public access on and in most cases is seen behind the existing hangars and/or the footpaths in the Dungeness Nature water tower/tanks, it will only be visible to walkers who stop and Reserve and the Dungeness National make an effort to spot it on the skyline and generally only in good Nature Reserve and on roads and light and visibility (View 8). footpaths in the Dungeness Estate land that lead to the lighthouses on Dungeness Point

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA G

An area of predominantly flat farmland c.1400-3750m Proposed building seen side-on in conjunction with existing Low Low Slight, neutral compartmented by drainage ditches and hangars as small part of view by farm workers whose presence with some flooded gravel workings is infrequent and transient. c.2250-3600m Public footpaths across parts of the Proposed building seen side-on in conjunction with existing Medium to Low Slight, neutral farmland hangars as small part of view by walkers whose presence is low c.1600-2250m generally infrequent and transient (View 10).

Residential development along the south Oblique views of proposed building in conjunction with existing Medium to Low Slight, neutral eastern edge of Lydd hangars seen as small part of overall view, in some cases low c.1600-3500m partially obscured by intervening vegetation and buildings (View 11).

Pedestrians and road users on Robin Hood Proposed building seen side-on in conjunction with existing Medium to Low Slight, neutral Lane and Dengemarsh Road, including hangars as small part of overall view, at times partially obscured low visitors to the various industrial sites and by intervening vegetation and buildings. Views seen by drivers sports facilities to the south west of and walkers, some of whom will be regular, others infrequent, Dengemarsh Road. and all transient (Views 10 & 11).

AREA H

Lydd Golf Course and the public footpath c.200-1100m Clear views of proposed building from much of golf course and Medium to Medium to Moderate to along its north west boundary by southbound walkers on public footpath. Building will largely low low slight, neutral screen existing airport buildings from view. Views generally infrequent and transient (Montage 5).

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA H (Contd)

Flat open farmland to the west and south c.100-1600m Clear views of proposed building in conjunction with existing Low Medium to Slight, neutral west of Lydd Airport airport buildings for farm workers whose presence is infrequent low and transient.

Public footpaths across parts of the c.650-1300m Clear views of upper part of proposed building over middle Medium to Medium to Moderate to farmland ground of intervening vegetation for walkers heading east, whose low low slight, neutral presence is generally infrequent and transient (Montage 4).

Some clear, some oblique views, extent of which dependent on Residential, farmsteads and some c.700-1450m garden boundary treatment. Most residential views from Medium to Medium to Moderate to commercial development along the eastern established properties more likely to be from upper floors low low slight, neutral edge of Lydd between Lydd Golf Course (Montage 4). and Dungeness Road Clear views of proposed building in conjunction with existing Pedestrians and road users on Dungeness c.1325-1600m airport buildings for road users and pedestrians, some regular, Medium to Medium to Moderate to Road between Lydd and Boulderwall Farm others infrequent, all transient (Montage 3). low low slight, neutral

Pedestrians and road users on a short c.950m Proposed building can be glimpsed through gap in intervening stretch of the B2075 in the vicinity of Forty vegetation and farm buildings. Some views will be regular, others Low Low Slight, neutral Acre Farm infrequent, all transient.

Airport access road from c.150m east of c.50-800m Clear views of proposed building which largely screens existing B2075 hangars from view in approach to airport entrance, presenting a Medium High to Substantial to more considered and attractive approach to the airport. For other medium moderate, than those who work at or from the airport, views will be beneficial infrequent and transient (View 12).

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Location Distances Significance of (to nearest Descriptions of View Receptor Magnitude Unmitigated edge of site) Sensitivity of Change Impact

AREA J

Farmsteads and occasional houses in open c.1600-4500m Glimpse views of proposed terminal building generally seen Medium Low to Slight to countryside to the west of the B2075 almost end on from some parts of the area when not screened negligible negligible, by intervening buildings, trees and scrub vegetation. neutral

Pedestrians and road users on lanes to the c.1800-4500m Occasional views of proposed terminal building generally seen west of the B2075 almost end on from some points on the lanes in the area when Medium to Low to Slight to not screened by intervening buildings, trees and scrub low negligible negligible, vegetation. neutral c.1000-4500m Flat open farmland to the west of the Glimpse views of proposed terminal building generally seen B2075 stretching as far as Old Romney almost end on when not screened by intervening buildings, trees Low Low to Slight to and scrub vegetation. Seen by farm workers whose presence is negligible negligible, infrequent and transient. neutral

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13 CULTURAL HERITAGE AND HISTORIC ENVIRONMENT

13.1 Introduction

13.1.1 This chapter assesses the impacts of the proposed new terminal building 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 is 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 (see Chapter 5.4). 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 Adopted Plan 2006 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 were 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 July 2006 Supplementary Planning Guidance SPG1: Landscape Character

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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.

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 NMR's listed buildings data have been consulted for a 2km (linear) square study area

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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 Structure Adopted Plan 2006 – SPG1: Landscape Character July 2006, and Kent and Sussex Biodiversity Action Plan (BAP) – Appendix D: Shoreline Management Plan 1.

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

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

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name - 'hlid' is an Old English word meaning slope 7. The settlement at Lydd 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 archbishop’s 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

7 Cameron K. 1969 English Place Names

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and the saltmarsh creeks 8. Evidence from the Lydd Quarry excavations also 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 SPG1)

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

8 Romney Marsh Research Trust 9 The National and Kent and Sussex Biodiversity Action Plan - Appendix D: Thematic Studies - Shoreline Management Plan (Draft January 2005)

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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 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' (SPG1 2003). 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 1km south-west of the proposed new terminal building.

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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 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 new terminal 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 proposed new terminal building.

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 new terminal building 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.

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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.

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 SER. The opportunity of eventually creating a rail / 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.

10 Harding P. A. 2004 The Romney Branch Line Peter A. Harding

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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 Lympne on the western side of Romney Marsh. Silver City relocated to Lydd in 1954 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.

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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13.5 Baseline Environment (Future Assessment Conditions Scenario)

13.5.1 The baseline environment under this scenario is the same as described under the “existing conditions scenario” above.

13.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

13.6.1 The current use of the airport is not considered to impact on cultural heritage.

13.6.2 There are no known archaeological remains or monuments that will be affected by these works.

13.6.3 Although 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 of minor adverse significance.

Future Assessment Conditions Scenario

13.6.4 Impacts will be as described for the ‘existing conditions scenario’ above..

13.7 Potential Impacts (Operational Impacts)

Existing Conditions Scenario

13.7.1 The operational impacts of the new terminal building upon the Historic Environment will be limited to visual aspects only. These were assessed and photographed during a site visit in August 2005 and are discussed in greater detail in Chapter 12 Landscape and Visual Amenity. At the request of Kent County Council, observations were made from vantage points on the 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.

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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.

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 will 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 (Operational 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 the Future Assessment Conditions 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 adverse due to the long term, irreversible effects of the foundation engineering works.

13.10.3 With regard to the Built Heritage, the proximity of the proposed new terminal building would be located some distance from both Jack's Court (listed building) and the WWII Listening Devices (scheduled ancient monuments). It lies approximately 1km to the

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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

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

13.11 Summary

13.11.1 An assessment of the potential impacts of the proposed new terminal building 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:

• Archaeology - 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.

• Built heritage - the construction of the proposed new terminal building 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 13 or the medieval Grade II Listed Building at Jack's Court 14 15. 13.11.4 A programme of archaeological works may be 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.

13 Eddison J. (et al) 1998 Romney Marsh: Environmental Change and Human Occupation in a Coastal Lowland Oxford University Committee for Archaeology 1998 Monograph No. 46 14 English Heritage Conservation Bulletin Issue 48 2004-5 Maritime and Coastal Heritage 15 English Heritage / ALSF Medieval Adaptation, Settlement and Economy of a Coastal Wetland: the Evidence from around Lydd, Romney Marsh, Kent EH Projects Number: 3280MAIN

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14 TRAFFIC AND TRANSPORT

14.1 Introduction

14.1.1 This chapter assesses the transport requirements of the proposed expansion of the passenger terminal at LAA and the associated increase in passenger movements per year. The Proposed Development will provide a passenger terminal with a capacity of 500,000 passengers per annum movements. 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 with the exception that for 300,000 passengers per annum, Future Assessment Conditions scenario, an ‘existing’ and ‘modified’ Hammonds Corner junction has been assessed for traffic modelling purposes.

14.1.3 A separate application has been made for the runway extension and it is assumed that this is in place throughout the assessment.

14.1.4 The implications on transportation policy are assessed in Chapter 5 Planning Policy Framework of this ES.

14.1.5 This chapter describes the methods used to assess the impacts of the proposed development, baseline conditions at and in the vicinity of the site, potential direct and indirect transport impacts arising from the development and the impact generated trips will have on the different transport modes.

14.1.6 Proposed mitigation measures required to prevent, reduce or offset any identified impacts have also been described.

14.2 Legislative Drivers

14.2.1 The proposals for the terminal development 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 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.

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Data Collection

14.3.3 Site visits have been undertaken to determine existing baseline environment. Surveys have been carried out to identify traffic flows, pedestrian activity, car park usage, retail activity and servicing requirements.

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 they have 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 Civil Aviation Authority (CAA) 2003 Passenger Survey Data Distribution, Mode Survey Data Split and Group Size Transport Assessment London June to accompany planning Mode Split Transport Assessment 2004 application for Manston assumptions Airport expansion

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 Civil Aviation Authority (CAA) passenger Passenger Catchment & Distribution survey data for Kent & East Sussex 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.

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Issue Method Using CAA passenger survey data on trip Car Park Occupancy duration, the car parking requirements for each scenario has been calculated. The following developments have been considered in the assessment: Lydd hotel Cumulative Impacts (construction will commence in Winter 2006), the gravel extractions and decommissioning of Dungeness ‘A’ reactor.

14.3.6 The data collected from show 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 approximately 778,178, with 322,558 households. The 90-minute catchment has approximately 3,497,855 with 1,446,945 households. This catchment 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.

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 onsite 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%

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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 provide 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 Employees have been split 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 as shown in Table 14.4 and 14.5 below.

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 Scenario)

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.

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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 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 (AADT) flows have been calculated from survey data for various points on the road network as shown in 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 for the airport and the local roads.

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)

14.4.7 A junction assessment was undertaken2 using the existing 2005 traffic data from KCC, with results shown in Table 14.7 below. 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 as an average to represent the peak hour periods.

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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

14.4.8 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.

14.4.9 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 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.

14.4.10 Onsite observations suggest that queuing is already a problem at the junction, even during off-peak times.

14.4.11 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)

14.4.12 The junction at Brenzett is a roundabout linking the A2070, the A259 Lydd Road and the B2080.

14.4.13 The baseline conditions at this junction are favourable, 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

14.4.14 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 5 year period. This included 3 fatal accidents and 18 serious accidents.

14.4.15 The accidents are mainly clustered around the road junctions. Hammonds Corner recorded 17 accidents, one of which was fatal, one serious. Brenzett recorded 12

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accidents, three of which were serious. On average there were 19 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 approximately 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.

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

Local Rail Network

14.4.20 The airport is located approximately 25km south of Ashford International rail station and 12km southeast of Appledore rail station. There is a single-track rail link between Appledore and Lydd but this is currently disused for 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 below 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.

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(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 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.

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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 and that the runway extension is in operation.

Trip Generation

14.5.2 Trips associated with the Future Assessment Conditions Scenario have been broken down into staff and passenger trips along with additional service vehicle movements. 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

14.5.3 Table 14.10 shows the trip profile of the Future Assessment Conditions Scenario.

Table 14.10 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

14.5.4 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 within this period.

Staff Trip Generation

14.5.5 Table 14.11 shows the levels of car trips generated by staff by hour under the Future Assessment Conditions Scenario. 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.

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Table 14.11 Daily Staff Car Trips – Future Assessment Conditions Scenario 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

Servicing and Delivery Trips

14.5.6 A total of four refuse collections per week and five sewage/waste water collections per week are anticipated under the Future Assessment Conditions Scenario.

Public Transport Trips

14.5.7 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

14.5.8 The level of bus trips generated per weekday is forecast to be as follows as shown in Table 14.12 below.

Table 14.12 Bus Passenger Trips – Future Assessment Conditions Scenario

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

14.5.9 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.

14.5.10 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.

Taxi Trips

14.5.11 Forecast levels of taxi trips under the Future Assessment Conditions Scenario are shown in Table 14.13.

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Table 14.13 Taxi Passenger Trips – Future Assessment Conditions Scenario Hour Inbound Outbound 00:00 – 06:00 9 9 06:00 – 12:00 18 18 12:00 – 18:00 27 27 18:00 – 00:00 10 10 TOTAL 64 64

14.5.12 The peak hours for taxi passenger trips are 09:00-10:00 and 17:00-18:00. 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.

Car Parking

14.5.13 Table 14.14 below details the duration breakdown used for this analysis.

Table 14.14 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%

14.5.14 The above assumptions have been used to forecast the car park occupancy over a month to calculate the total parking capacity needed as shown in Table 14.15 below.

Table 14.15 Car Park Capacity Type of Space Total Long-Stay 400 Short-Stay 40 Staff 70 TOTAL 510

14.5.15 A total of 510 spaces are required for the additional passenger movements planned to 2009 under the Future Assessment Conditions, in association with the runway extension which is assumed to be in place. 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, as shown in Figure 4.8.

Average Annual Daily Traffic

14.5.16 Average Annual Daily Traffic (AADT) for the Future Assessment Conditions Scenario is shown in Table 14.16. The flows have been factored up from survey data to reflect

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the average August flows, as this is the busiest period of the year for the airport and the local roads.

Table 14.16 7-Day 18hr AADT Flows – Future Assessment Conditions Future Assessment Site Baseline Traffic (2005) Conditions (2009) 1 - A259 Lydd Rd 8411 9891 3 - A259 Straight La 6061 6630 5 - B2075 Romney Rd 7166 9165 6 - A259 New Romney 11036 12265 7 - A259 Dymchurch 11219 12441 8 - B2075 Lydd 3141 3356 9 - A2070 11864 13306

Junction Assessments – Hammonds Corner & Brenzett

14.5.17 Junction assessments, based on traffic levels for the Future Assessment Conditions Scenario have been carried out on both the existing and proposed layouts (see below) for Hammonds Corner and the existing roundabout at Brenzett at the junction of the A259 and the A2070, For the purpose of the analysis, the maximum Ratio to Flow Capacity (RFC) and the maximum queue length for each fifteen minute period have been averaged over the hour.

14.5.18 Tables 14.17 and Table 14.18 show the junction assessment results for Hammonds Corner based on the roundabout design, and the Future Assessment Conditions of 300,000 passengers per annum including an extension to the runway.

Table 14.17 A259/B2075 Hammonds Corner Junction Assessment (existing layout) Future Assessment Conditions 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

14.5.19 With no modifications, the above scenario would result in the junction operating significantly over capacity. The results show the need for identifying a suitable solution for improving the junction and increasing capacity. Traffic flows under the Future Assessment Conditions for the Hammonds Corner roundabout in 2009 are shown in Figure 14.5.

14.5.20 As part of LAA’s ongoing expansion plans to increase the airport’s capacity to 300,000 passengers per annum, a contribution towards improvements at the existing Hammonds Corner is, however, anticipated. This is expected to involve the

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modification of the T-Junction to a roundabout (or similar) in association with proposals for an extension of the runway (a separate planning application).

14.5.21 For this reason, the junction has been tested again using a proposed indicative roundabout design, as featured in the runway extension application. These results should be treated as a guide only as the exact layout of any future junction improvements would need to go through a detailed design process.

14.5.22 The results of this layout for the modified layout are detailed in Table 14.18 below:

Table 14.18 A259/B2075 Hammonds Corner Junction Assessment (Roundabout Layout) – 2009 Future Assessment Conditions. 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

14.5.23 The results show that with a roundabout in place, the junction operates well within adequate capacity. A junction operates efficiently with a RFC of 0.85. The maximum queue length at the junction is 1.2 vehicles on the eastern arm of the A259.

14.5.24 A proposed layout for the roundabout is shown in Figure 14.6. Future Assessment traffic flows for the Hammonds Corner roundabout in 2009 are shown in Figure 14.5.

14.5.25 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.

14.5.26 Results of the junction assessment for the roundabout are shown in Table 14.19 below.

14.5.27 The existing flows at the Brenzett Junction show that it is operating well within capacity, with the RFC being below 0.6 for all directions. The busiest arms are the north and south links of the A2070 to Ashford and the A259 to Rye.

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Table 14.19 A259/A2070 Brenzett Junction Assessment – 2009 Future Assessment Conditions

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) A259 to Rye 0.606 1.6 0.296 0.4

B2080 to 0.401 0.7 0.307 0.5 Brenzett

A2070 to 0.301 0.5 0.454 0.9 Ashford

A259 to 0.461 0.9 0.295 0.5 Romney

14.5.28 The results show that the Brenzett junction is operating well within capacity with the 300,000 passengers per annum scenario. The flows show very little increase between the existing conditions and the Future Assessment Conditions scenario incorporating the additional flows of 300,000 passengers per annum. The busiest arms are the north and south links of the A2070 to Ashford and the A259 to Rye.

14.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

14.6.1 The construction of the new terminal building will comprise four main stages (excavation, steelwork, ground floor sub-base and concrete, and fixing and finishing) and is scheduled to last for approximately 18 months. The works will generate additional traffic, in particular HGVs, but are scheduled to be completed prior to the decommissioning period at the nearby Dungeness Power Station and no major overlapping Dungeness-related HGV trips is expected.

14.6.2 The construction traffic will follow a designated route in and out of the site. This will be via the A2070 from Ashford, as this route provides direct links to the M20 and areas to the northwest. The increase in heavy traffic will temporarily increase the percentage of HGV vehicles on some of these routes. Construction traffic flows on the routes to and from the airport are shown in Table 14.20 and shown in Figure 14.10.

14.6.3 Overall effects of construction traffic on the routes to and from the airport are shown in Table 14.20. The increase in HGV movements does not increase the percentage of HGV traffic to above 10% on any of the affected routes.

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Table 14.20 Construction Traffic Impact Additional HGV Additional Additional Fixing & Excavation HGV HGV Ground Finishing Baseline Site Steelwork Floor % HGV Flows % Flows % Flows % Flows % 1 - A259 40 8.1 30 8.0 7.5 20 7.9 0 7.5 Lydd Rd 5 - 40 6.5 30 6.3 B2075 5.7 20 6.2 0 5.7 Romney Rd 9 - 40 8.9 30 8.6 7.8 20 8.3 0 7.8 A2070

Future Assessment Conditions Scenario

14.6.4 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 An increase in passenger numbers to some 500,000 passengers per annum is anticipated following the proposed development of the terminal building. This will be accompanied by an increase in the levels of staff and servicing requirements.

Passenger Trip Generation

14.7.2 Passenger trip profiles will be based on a combination of the proposed flight timetable, and arrival and departure patterns. These 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 Transport Assessment documents.

14.7.3 A total of 730 one-way car trips per weekday are predicted to be generated by 500,000 passengers per annum as shown in Table 14.21.

Table 14.21 Air Passenger Car Trips – Terminal Development Hour Inbound Car Trips Outbound Car Trips 00:00 – 06:00 33 32 06:00 – 12:00 135 101 12:00 – 18:00 145 140 18:00 – 00:00 52 92 TOTAL 365 365

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14.7.4 The peak hour for traffic into the airport for this scenario is between 09:00 and 10:00 when a total of 38 car trips are forecast entering the car airport. This is also the peak hour for outbound car trips from the airport. Approximately 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.

14.7.5 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

Staff Trip Generation

14.7.6 Table 14.22 shows the levels of car trips generated by staff during a 24-hour period. The peak inbound flows are forecast between 07:00 and 08:00 with 60 staff car trips entering the airport. The peak outbound flows are between 16:00 and 17:00 when 68 staff car trips are forecast to leave the car park.

Table 14.22 Daily Staff Car Trips –Terminal Development Hour Inbound Outbound 00:00 – 06:00 15 45 06:00 – 12:00 120 49 12:00 – 18:00 113 156 18:00 – 00:00 27 24 TOTAL 275 274

14.7.7 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

Public Transport Trips

14.7.8 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

14.7.9 The level of bus trips generated per weekday is forecast for the Terminal Development. The trip profile is as shown in Table 14.23 below:

Table 14.23 Bus Passenger Trips – Terminal Development Hour Inbound Outbound 00:00 – 06:00 9 10 06:00 – 12:00 50 19 12:00 – 18:00 46 44 18:00 – 00:00 3 35 TOTAL 108 108

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14.7.11 The increase in bus passengers suggests that additional services for buses to stop within the airport site (rather than on the B2075) are required.

14.7.12 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

14.7.13 Table 14.24 details the level of taxi trips forecast to be generated by the additional passenger movements.

Table 14.24 Taxi Passenger Trips – Terminal Development Hour Inbound Outbound 00:00 – 06:00 9 9 06:00 – 12:00 34 34 12:00 – 18:00 42 42 18:00 – 00:00 21 21 TOTAL 106 106

14.7.14 The peak hour for taxi passenger trips is 09:00-10:00 with 11 inbound and 11 outbound movements. A total of 212 one-way taxi trips are forecast. Taxi stands are also illustrated in Figure 4.2a.

14.7.15 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

14.7.16 The average length of trip has been obtained using the CAA passenger survey data for 2003 (See Table 14.1). This has allowed the car park occupancy to be modelled over a month. Table 14.25 details the duration breakdown used for this analysis.

Table 14.25 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%

14.7.17 The above assumptions have been used to forecast the car park occupancy over a month to calculate the total parking capacity needed, as shown in Table 14.26.

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Table 14.26 Car Park Capacity Requirements – Terminal Development Type of Space Total Long-Stay 680 Short-Stay 60 Staff 120 TOTAL 860

14.7.18 The car parking spaces required for the Proposed Development (860 spaces of which 39 will be required for disabled users) can be accommodated on existing hardstanding, as illustrated in Figure 4.9. Since space is available for this level of parking, the impact is considered of negligible significance.

Annual Average Daily Traffic

14.7.19 This section details the forecast change in AADT levels at various points on the road network. Table 14.27 below shows the percentage of total traffic that will be generated by the airport expansion to 500,000 passengers per annum in association with the terminal building. The survey locations are shown in Figure 14.4.

Table 14.27 7-Day 18hr AADT – Terminal Development % Increase % Increase Current Future of current of future Terminal Site Traffic Assessment and future assessment Development Levels Conditions assessment and terminal conditions development 1 - A259 6.8 8411 9891 10559 25.5 Lydd Rd 3 - A259 3 6061 6630 6832 12.7 Straight La 5 - B2075 9.1 Romney 7166 9165 9997 39.5 Rd 6 - A259 8.7 New 11036 12265 13338 20.8 Romney 7 - A259 4 11219 12441 12937 15.3 Dymchurch 8 - B2075 9.2 3141 3356 3664 16.7 Lydd 9 - A2070 11864 13306 13928 17.4 4.7

14.7.20 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. On this basis, traffic levels around the airport will increase by a maximum of 39.5%. 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.

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Junction Assessment

14.7.21 As stated earlier in the chapter, two of the nearby junctions have been assessed against the additional traffic flows generated by the terminal expansion.

14.7.22 Hammonds Corner is the junction of the B2075 Romney Road and the A259 Lydd Road. As stated earlier, it is recognised that improvements are needed in time for the terminal development so junction assessments have been based on the proposed roundabout junction layout included in the runway extension planning application.

14.7.23 The results of the junction assessment for Proposed Development are shown in Table 14.28 below.

Table 14.28 A259/B2075 Junction Assessment – Terminal Development 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) A259 Lydd 0.553 1.3 0.329 0.5 Road East

B2075 Romney 0.390 0.7 0.401 0.7 Road

A259 Lydd 0.425 0.8 0.519 1.1 Road West

14.7.24 The assessment shows that a roundabout layout would allow the junction to operate well within capacity in each peak hour in 2010. The highest flow to capacity ratio is from the A259 eastern arm at 55%.

14.7.25 The forecast flows for the peak hours at the junction are shown in Figure 14.8.

14.7.26 The additional flows have also been assessed for the Brenzett roundabout junction further west of Hammonds Corner, as shown in Table 14.29 below.

Table 14.29 Brenzett Junction Assessment – Terminal Development 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) A259 to Rye 0.634 1.8 0.307 0.5

B2080 to 0.418 0.7 0.317 0.5 Brenzett

A2070 to 0.326 0.5 0.467 0.9 Ashford

A259 to 0.485 1.0 0.319 0.5 Romney

14.7.27 The junction is shown to function well within capacity for the proposed development. The busiest arm in the morning peak is the A259 from Rye. During the evening peak hour, the busiest arm is the A2070 from Ashford. This reflects the general pattern of traffic flowing to Ashford in the morning and away from there in the evening. In addition, the carriageway width along the A259 to Rye is narrower than the arm linking to New Romney. The forecast peak hour flows are shown in Figure 14.9. December 2006 Page 263 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 14 LAA

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14.7.28 No junction improvements are proposed at Brenzett in association with the terminal expansion (see mitigation belowbelow), as the impact can be accommodated within the available capacity of the network in this location.

Future Assessment Conditions Scenario

14.7.29 Changes to levels of traffic generated through airport operations will be as described under the Baseline Conditions Scenario above.

Annual Average Daily Traffic

14.7.30 This section details the forecast change in AADT levels at various points on the road network. Table 14.30 below shows the percentage of total traffic that will be generated by the airport of the proposed development with 500,000 passengers per annum. The survey locations are shown in Figure 14.4.

Table 14.30 7-Day 18hr AADT – Terminal Development Future Assessment No of Terminal Site Conditions Vehicles % Increase Development Scenario 1 - A259 429 10130 10559 4.2 Lydd Rd 3 - A259 101 6731 6832 1.5 Straight La 5 - B2075 479 Romney 9518 9997 5.0 Rd 6 - A259 769 New 12569 13338 6.1 Romney 7 - A259 51 12886 12937 0.4 Dymchurch 8 - B2075 25 3639 3664 0.7 Lydd 9 - A2070 13600 13928 328 2.4

14.7.31 The additional traffic flows generated by the terminal development have a relatively small effect on the forecast traffic flows in 2010. The largest increase is at Sites 5 and 6 where an increase of 5-6% in average traffic flows is forecast. This is shown in Figure 14.11.

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 vehicle movements in the initial stages of the construction will reduce the longer term impacts on the road network, as shown in Figure 14.11.

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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 most significant mitigation factor related to the road network is the development of a roundabout at Hammonds Corner, already proposed within the earlier runway extension planning application. LAA recognises the need for an improvement at the junction and would be prepared to provide this as mitigation in association with an increase to 500,000 passenger movements per annum if such an improvement has not already been provided at an earlier stage.

14.9.3 The roundabout would greatly improve the capacity of the Hammonds Corner junction and allow the local road network to accommodate additional traffic generated by the terminal development and beyond.

14.9.4 Amendments to the access road junction with the B2075 were proposed within the runway extension planning application. It has been assumed that these improvements will have been already undertaken prior to the development of a new terminal building

14.9.5 Flows along other roads in the area are not considered to be affected significantly enough in light of the improved signage and proposed highway improvements included in the earlier planning application.

Signage Strategy

14.9.6 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.

14.9.7 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.

14.9.8 All travel information for passengers using LAA will identify the preferred route as well as suggesting public transport alternatives.

Travel Plan

14.9.9 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.

14.9.10 The overall objective of the Travel Plan is to maximise the opportunity for staff and air passengers to travel to the site by alternative modes to the private car.

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14.9.11 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;

• Contribution towards enhanced local bus services via the airport;

• Provided there is a financial case and is a viable option, LAA would consider providing a dedicated shuttle bus service to connect the Airport with Ashford International Station or alternatively, a financial contribution will be given local bus services to extend routes in to the airport;

• Higher short-stay car parking charges; and

• Promotion of travel options to connect to CTRL domestic services. 14.9.12 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. 14.9.13 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

14.9.14 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 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 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.

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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 between the Future Assessment Conditions (assuming that the Runway extension is in place and that passenger levels are at 300,000 passengers per annum) and the Proposed Development (with the terminal in place and 500,000 passengers per annum).

14.11.2 The impacts of the terminal development are greater than the baseline and so have been assessed in terms of both traffic and public transport impacts.

14.11.3 With the terminal development in place and assuming that 10% of passengers will access the airport by bus or coach (generating 106 inbound and 108 outbound passenger trips per day), it will generate 651 inbound car trips and 648 outbound car trips per day during the busiest time of year, which is an additional 280 two-way vehicle trips per day when compared with the Future Assessment Conditions.

14.11.4 The impacts of this level of car trips on AADT levels are low and represent less than a 5% increase on the Future Assessment Conditions scenario.

14.11.5 The car parking requirements for 500,000 passengers per annum will rise to 860 car parking spaces of which 680 will be long-stay. Proposed locations for the additional spaces will be agreed with the local authorities to ensure that the requirements do not conflict with long term traffic management policies.

14.11.6 No junction improvements are proposed at Brenzett in association with the terminal expansion.

14.11.7 If not already provided by the Runway Extension planning application, at 500,000 passengers per annum there will be a clear need to improve the Hammonds Corner Roundabout. Future discussion over the exact layout of this proposed roundabout is required with the relevant highway authorities.

14.11.8 A roundabout at Hammonds Corner would greatly improve its capacity of the and allow the local road network to accommodate additional traffic generated by the terminal development and beyond This modification would, however, be required as part of the Future Assessment Condition scenario, irrespective of the traffic requirements of the proposed 2010 development.

14.11.9 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 development. As a result the severity of impacts arising from the increased operational capacity of the airport (once the proposed terminal is in use) is reduced under this scenario.

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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 terminal building at LAA to serve 500,000 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 in this chapter are as described in Chapter 1.

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 AQS 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); and

• 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.

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, wood burning and uncontrolled fires. Road transport contributes approximately 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.

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 are potential Reduces capacity Incomplete sources. However, previous CO of blood to carry NO combustion of fuel studies of major airports oxygen. show that CO is not a significant concern1.

Impaired lung NO formed during function; Vehicle and aircraft Oxides of combustion in air. acidification and YES exhausts are a significant nitrogen NO formed by 2 eutrophication of source oxidation of NO soils

No man-made sources. Formed Eye, nose and No assessment required in through chemical throat irritation, O NO relation to local schemes 3 reactions in chest infection; due to lack of sources presence of affects crop growth sunlight.

Industrial processes, especially mineral Affects the and ferrous metals. respiratory and Vehicle and aircraft PM10 Combustion cardiovascular YES exhausts are a significant processes. systems, asthma source 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 main contributor Affects the before general sale synthesis of of leaded petrol was haemoglobin, No significant sources of banned on 1 kidneys, joints and Lead NO lead associated with this January 2000. reproductive project. Industry contributes system. Can cause to lead emissions damage to the but to a lesser nervous system extent.

1. AEAT, 2001, Proposed development at Stansted Airport: Air Quality Assessment

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15.2 Legislative Drivers

Human Health and Local Air Quality

15.2.1 Part IV of the Environment Act 19953 required the Government to develop a national AQS containing standards, objectives and measures 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 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 200 μg/m3 31/12/2005 Nitrogen Dioxide more 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 50 μg/m3 exceeded more than 35 times 31/12/2004 per year 24 hr mean not to be 3 Particulates (PM10) 50 μg/m exceeded more than 7 times 31/12/2010 per year3 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. 3. These objectives are currently provisional for the time being in England, Wales, Northern Ireland; Greater London has set different provisional objectives for particulates.

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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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 Environmental Protection Act, motorways and built-up areas of more than 5000 people. Dungeness Power Station, regulated under Part A of the 1990 Environmental Protection 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

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 villages in the surrounding area.

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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 Operational Impacts

15.3.5 The approach taken to assess the air quality impacts of the operation of the Terminal Building is to compare, using computer dispersion modelling, current local air quality with that anticipated in the future.

15.3.6 The scenarios modelled are as described in Section15.1.

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 the 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. Concentrations relevant to 2009 and 2010 are used in the assessment of the airport serving 300,000 and 500,000 passengers per annum, respectively.

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; and

• Brake wear and tear.

• Airside vehicle emissions

• Exhaust emissions from aircraft support vehicles; and

• Exhaust emissions from airport operational vehicles.

• Landside vehicle emissions

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 on public roads;

• Exhaust emissions on airport approach road;

• Exhaust emissions in airport car-park, including cold start emissions; and

• Tyre wear and tear.

• Emissions from terminal heating system (worst case, diesel Combined Heat and Power).

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 ; and

• NAEI19 . 15.3.12 Further details of the estimation of emissions and their spatial distribution is 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

300,000 500,000 Current passengers passengers

Runway Take-off roll 0.19 7.32 12.78 Landing roll 0.05 4.05 7.71 In Air Climb-out 1.26 17.02 28.54 Approach 0.87 3.48 5.16 Taxi In and Out 0.03 0.93 1.92 Gate Shut down 0.04 1.18 2.64 APU <0.01 0.67 1.24 Airside support vehicles 3.73 9.48 12.33 Helicopter Take-off <0.01 0.02 0.05 Landing <0.01 0.01 0.01 Carpark

Cold start 0.01 0.03 0.05

Finding space 0.02 0.05 0.11 Roads Main roads in study area 25.43 21.98 21.66 Boiler Terminal Heating/Power 0.28 0.28 0.98 Totals All sources 31.9 66.5 95.2 Aircraft engines1 2.4 34.0 58.7 Airport-related2 6.5 44.5 73.5 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

300,000 500,000 Current passengers passengers

Runway Take-off roll <0.001 0.011 0.019 Landing roll <0.001 0.006 0.011 Brake and tyre wear 0.131 0.564 0.838 In Air Climb-out <0.001 0.022 0.037 Approach <0.001 0.007 0.012 Taxi In and Out <0.001 0.002 0.002 Gate Shut down <0.001 0.002 0.002 APU 0.000 <0.001 0.000 Airside support vehicles 0.128 0.521 0.731 Helicopter Take-off <0.001 <0.001 <0.001 Landing <0.001 <0.001 <0.001 Carpark Cold start 0.001 0.003 0.007 Finding space 0.001 0.001 0.003 Roads Main roads in study area 0.88 0.70 0.68 Brake and tyre wear 0.33 0.38 0.41 Boiler Terminal Heating/Power 0.041 0.041 0.14 Totals

All sources 1.5 2.3 2.9 1 Aircraft engines 0.13 0.61 0.92 2 Airport-related 0.30 1.18 1.80 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

300,000 500,000 Current passengers passengers

Runway Take-off roll 0.42 0.51 0.54 Landing roll 0.44 0.92 0.96 In Air Climb-out 4.94 5.55 5.60 Approach 4.43 4.97 5.08 Taxi In and Out 0.56 2.41 3.23 Gate Shut down 0.65 3.41 3.86 APU <0.01 0.03 0.05 Airside support vehicles 0.32 0.85 1.12 Refuelling 0.03 0.67 1.12 Helicopter Take-off 0.01 0.02 0.04 Landing <0.01 0.02 0.04 Carpark Cold start 0.05 0.24 0.52 Finding space <0.01 0.01 0.02 Roads Main roads in study area 3.03 2.64 2.74 Boiler Terminal Heating/Power <0.01 <0.01 0.02 Totals

All sources 14.9 22.3 24.9 1 Aircraft engines 11.5 17.8 19.3 2 Airport-related 11.9 19.6 22.20 1. Direct emissions from aircraft engines during landing and take-off cycle 2. All sources except main roads in study area

Dispersion modelling

15.3.14 Dispersion modelling was undertaken using 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

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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 discussed 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 Local air 10% threshold pollutants) PC ≤ 1% of limit value and PEC ≤ quality value Or or 70% PC > 50% PEC > 70% and PC ≤ 10%

Uncertainties

15.3.21 The modelling of airport related emissions is based on a number of assumptions regarding activity levels and hence pollutant emission levels with their spatial representation over the airport. The limits to the accuracy of these assumptions, together with the uncertainties inherent in the numerical modelling of complex turbulent diffusion processes in the atmosphere, lead to potentially significant uncertainties in the predicted concentrations and deposition levels.

15.3.22 Where assumptions have been made in the modelling, estimates have been made on a realistic basis but tending towards a worst case scenario. With this in mind, it is considered that the predicted impacts of the airport expansion are unlikely to exceed to moderate significance predicted in this assessment.

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 the 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 for the baseline year and projected forward to the future assessment years i.e. 2009 for the future baseline conditions, and 2010 for the predicted impacts of the operation of the airport. 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. PM10 levels in 2010 are within the provisional objectives but there is little available headroom. Background concentrations of all pollutants are expected to decrease, primarily as a result of a tightening of emissions standards across all industrial and transport sectors.

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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 2010 9.6 7.6 18.6 0.09 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 as a result of the increasingly stringent standards to Air Quality and to assess likely future concentrations of the pollutants specified in the National (AQS) 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 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, Northlade Site of Special Scientific Interest (SSSI) and Dungeness SSSI (refer to Chapter 10 Ecology). 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 to 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% in each subsequent year to

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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 2000 15.3 2005 13.8 2009 12.8 2010 12.5

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 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 assessment is relevant to 2005. 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) are 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 The local contribution to ambient nitrogen dioxide levels, from existing airport activities, 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 For receptors off site, 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.

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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.

Table 15.9 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 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 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.

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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.

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

Overview

15.5.1 General environmental parameters hold for this scenario as outlined in section 15.4 above.

Local Environmental Conditions

15.5.2 Tables 15.3 to 15.5 show that airport related emissions of NOx, PM10, and NMVOC from LAA are predicted to increase to 44, 1.18 and 20 tonnes/year respectively in the “Future Assessment Conditions” i.e. the projected 300,000 passengers per annum scenario, assessed for the nominal year of 2009. Current emission totals are 6.5, 0.30 and 12 tonnes/year respectively. Aircraft emissions of NOx increase from 2.4 to 34 tonnes/year with the increased passenger numbers. Aircraft emissions of PM10 and NMVOC also increase, but show lower percentage increases over current levels.

15.5.3 Table 15.12 shows the predicted increment to annual mean pollutant concentrations of nitrogen dioxide resulting from the operation of the airport at 300,000 passengers per annum, 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.

15.5.4 Figure 15.6 shows a typical prediction of total ambient annual mean concentrations of nitrogen dioxide, modelled using meteorological data from 2001, for the “Future Assessment Conditions” scenario. As the number of passengers served by LAA increases, ambient air concentrations of NO2 in the study area become increasingly influenced on the airport pollution sources. Ground level concentrations in the vicinity of the airport are significantly influenced by both activities in the terminal gate area and aircraft LTO cycles.

15.5.5 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

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concentrations are also likely to be within the hourly mean Objective.

15.5.6 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 consequence 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 than offset by the increase in airport emissions, resulting in a net increase in concentrations. At the existing terminal building, there is a moderate increase in pollutant concentrations, but no predicted exceedence of the annual mean (and hence hourly mean) Objective.

Table 15.12 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum 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

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15.5.7 Table 15.12 shows the predicted annual mean concentrations of PM10 in the 300,000 passengers per annum 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 2009.

15.5.8 Direct assessment of the Air Quality Objective for daily mean concentration of PM10 is not appropriate using the methodology used for this study since total emission of PM10 are assessed on an annual basis rather than daily . 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 in 2009, 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.

15.5.9 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.

15.5.10 Table 15.13 shows the predicted annual mean concentrations of Benzene and Butadiene in the 300,000 passenger per annum scenario. Annual mean pollutant concentrations of NMVOCs are within the Air Quality Objective in all scenarios.

15.5.11 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.

Table 15.13 Ambient Air Pollutant Concentrations (μg/m3) for the 300,000 passengers per annum 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

7 Greatstone on Sea 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

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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

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

15.5.12 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 passengers per annum 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 scenario. Figure 15.8 shows the total predicted annual mean concentrations of NOx for this scenario.

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 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

3 Dungeness to Pett Level SPA 0.43 - 2.76 0.03 - 0.22 10.13 - 12.46 12.83 - 13.02

15.5.13 Offsite, concentrations of NOx are within the Objective for the protection of all 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 area. 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.

15.5.14 Offsite, nitrogen deposition is predicted to be above the most conservative estimate of the critical load, but within the upper limit. However, the predicted deposition in the 300,000 passengers per annum scenario is generally lower than current levels, with the exception of the aforementioned area of existing Northlade SSSI closest to the terminal.

15.5.15 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. There is no vegetated shingle habitat within the immediate vicinity of the proposed terminal building in the proposed SSSI.

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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 lies 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. 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 15.7.

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 15.7, 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 under this scenario are expected to be as described above.

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15.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

15.7.1 Tables 15.3 - 15.5 show that, in relation to existing conditions, airport related emissions of NOx are predicted to increase by 67 tonnes/year to 74 tonnes/year with the operation of the proposed terminal building development. This is primarily due to an increase in aircraft numbers and a corresponding increase in engine exhaust emissions from 2.4 tonnes/year to 59 tonnes/year. Emissions of PM10 and NMVOC also increase with the airport expansion, but show much lower percentage increases than oxides of nitrogen.

15.7.2 Table 15.15 shows the predicted increment to background annual mean nitrogen dioxide concentrations, at selected receptors, resulting from the operation of proposed development. 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, assessed for the nominal year 2010, 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 3 maximum annual mean concentration of NO2 is around 26μg/m , 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 500,000 passenger per annum scenario. In comparison to existing conditions scenario, the increased effects of on-airport pollution sources is clearly evident. Increased ground level pollutant concentrations are a result of significant increases in emissions both in the terminal gate area and aircraft LTO cycles.

15.7.5 However, by the time of operation of the proposed development (2010), ambient concentrations of NO2 are predicted to be lower than existing concentrations at all offsite receptors except those close to either end of the runway e.g. Greenhop Farm and Greatstone on Sea. Decreases in concentration occur as a result of decreasing background concentrations and, near roads, decreasing vehicle emissions due to improvements in vehicle technologies. At the receptors near the runway, the increase in airport related NO2 is greater than the decrease in background concentrations. However, the increase in the airport’s contribution to ambient NO2 concentrations is less than 10% of the Objective and, therefore, is considered to be of only minor significance.

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Table 15.15 Ambient Air Pollutant Concentrations (μg/m3) for the 500,000 passengers per annum 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 2.50 0.14 10.10 18.74

2 Lydd (School) 1.94 0.11 9.54 18.71

3 Greenhop Farm 2.75 0.16 10.35 18.76

4 Jack's Court 2.53 0.15 10.13 18.75

5 Lade 1.13 0.06 8.73 18.66

6 Greatstone on Sea 2.58 0.12 10.18 18.72

7 Greatstone on Sea (School) 4.01 0.18 11.61 18.78

8 Romney Sands 1.38 0.07 8.98 18.67

9 LittleStone on Sea 1.14 0.07 8.74 18.67

10 New Romney 2.33 0.15 9.93 18.75

11 Hammonds Corner 7.04 0.43 14.64 19.03

12 Calcott Farm 1.51 0.09 9.11 18.69

13 Belgar Farm 2.16 0.13 9.76 18.73

14 Lydd Golf Club 2.50 0.15 10.10 18.75

15 Forty Acre Farm 3.21 0.20 10.81 18.80

15.7.6 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 proposed expansion. At relevant receptor locations, the maximum number of exceedences is 2, well within the Objective which allows 35 exceedences. The value is also within the provisional Objective, which allows 7 exceedences of the standard.

15.7.7 Table 15.16 shows the predicted annual mean concentrations of Benzene and Butadiene in the 500,000 passengers per annum scenario. Annual mean pollutant concentrations of NMVOCs are within the Air Quality Objective in all scenarios.

15.7.8 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 500,000 passengers per annum 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 0.025 0.018 0.135 0.058

2 Lydd (School) 0.017 0.011 0.127 0.051

3 Greenhop Farm 0.030 0.024 0.140 0.064

4 Jack's Court 0.025 0.014 0.135 0.054

5 Lade 0.011 0.010 0.121 0.050

6 Greatstone on Sea 0.018 0.015 0.128 0.055

7 Greatstone on Sea 0.027 0.024 0.137 0.064 (School) 8 Romney Sands 0.011 0.008 0.121 0.048

9 LittleStone on Sea 0.008 0.005 0.118 0.045

10 New Romney 0.017 0.008 0.127 0.048

11 Hammonds Corner 0.036 0.013 0.146 0.053

12 Calcott Farm 0.011 0.006 0.121 0.046

13 Belgar Farm 0.019 0.012 0.129 0.052

14 Lydd Golf Club 0.026 0.017 0.136 0.057

15 Forty Acre Farm 0.043 0.022 0.153 0.062

15.7.9 Figure 15.10 shows the predicted airport related contribution to annual mean deposition of nitrogen, modelled using meteorological data from 2001, for the 500,000 passengers per annum scenario; Figure 15.11 shows the predicted annual mean concentration of NOx for this same scenario. Table 15.17 shows the range of nitrogen oxide concentration and nitrogen deposition over the existing designated ecosystem sites.

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 500,000 passengers per annum 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 2.89 - 33.34 0.23 - 2.67 12.49 - 42.94 12.73 - 15.17 2 Dungeness SAC 0.48 - 14.56 0.04 - 1.17 10.08 - 24.16 12.54 - 13.67 Dungeness to Pett Level 3 0.63 - 4.31 0.05 - 0.34 10.23 - 13.91 12.55 - 12.84 SPA

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15.7.10 Concentrations of NOx are within the Objective for the protection of all vegetation over Dungeness SAC and Dungeness to Pett Level SPA. Offsite, over the existing Northlade SSSI, the region of the SSSI closest to the airport terminal is predicted to experience concentrations above the Air Quality Objective. However, there is no sensitive vegetation in this area. Onsite, over the proposed SSSI, concentrations are predicted to exceed the Objective within 60m of the runway where vegetated shingle is present. However, 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.

15.7.11 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 the existing Northlade SSSI and within 10m of the runway in the proposed SSSI. However, there is limited vegetated shingle within these areas and no vegetated shingle habitat within the immediate vicinity of the proposed terminal building in the proposed SSSI.

15.7.12 However, the area of both the existing Northlade SSSI and proposed SSSI, where vegetated shingle is present, over which NOx concentrations are predicted to exceed the Objective and/or the upper limit of the critical load is less than 1% of the total area of the designated site. Concentrations decrease rapidly with distance from the airport and, therefore, the overall impact of proposed terminal development is assessed to be of moderate significance. Over Dungeness SAC, the impact of the 500,000 passenger per annum scenario is of major significance over less than 0.2% of the site, and of minor to negligible significance over the remainder of the site

Roadside Concentrations of Pollutants

15.7.13 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.

15.7.14 The figures show that concentrations at the roadside are well within the Air Quality Objectives in all scenarios.

Climate Change

15.7.15 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.

20 Highways Agency, Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1 (as amended in February 2003).

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15.7.16 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 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.

15.7.17 Whether, and if so 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 and restrictions on aircraft movements.

15.7.18 The current proposal to construct a new terminal building would increase passenger numbers to 500,000 ppa, and would alter the aircraft fleetmix 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.

15.7.19 However, greenhouse gas emissions estimates at 500 000 are difficult to make at this stage, as it is not clear which routes and exact fleetmixes 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.

15.7.20 The impacts of the different options for the terminal heating and lighting system on greenhouse gas emissions have been considered in a screening assessment. This has demonstrated that a diesel fired CHP plant provides a reduction of emissions with respect to an oil fired boiler, but that a biomass burner has the lowest overall impact.

Future Assessment Conditions Scenario

15.7.21 A comparison of Figures 15.6 and 15.9 shows that the spatial distribution of pollutant concentrations is similar in both the 300,000 and 500,000 passengers per annum scenarios, with both gate activities and LTO cycles remaining significant sources of pollutant.

15.7.22 However, with increased airport-related emissions with the terminal operation, predicted ambient concentrations of pollutants increase in the vicinity of the airport. The significance of the increase in pollutant concentrations is of low to negligible significance. The exceptions to this are at near-road receptors e.g. Hammonds Corner, where nitrogen dioxide concentrations in 2010 decrease in relation to the Future Assessment Conditions Scenario. This is a result of generally decreasing background concentrations and decreasing emissions per vehicle.

15.7.23 PM10 concentrations are dominated by the background concentrations, but show increases at all receptors between the future assessment scenario and the proposed terminal operation. However, in all cases, the change with respect to baseline is negligible i.e. <1% of the Objective.

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15.7.24 The increases in the total ambient pollutant concentrations of Benzene and Butaidene, with respect to the 300,000 passengers per annum scenario, are less than 1% of the relevant Objectives. Changes to NMVOC concentrations are, therefore, considered negligible.

15.7.25 On airport, predicted concentrations of nitrogen oxides and nitrogen deposition increase with the operation of the terminal. This occurs as the increased emissions of oxides of nitrogen outweigh the impacts of decreasing background concentrations and deposition.

Roadside Concentrations of Pollutants

15.7.26 As a result of generally decreasing background concentrations and improvements in vehicle technologies, concentrations in the Future Assessment Conditions scenarios for LAA terminal development are significantly lower than the current pollution levels, despite increasing traffic levels. The differences between the impacts of the scenario serving 300,000 passengers per annum and the proposed development are negligible. Concentrations along other roads within the study area will be lower than concentrations near the A259 in Romney due to the lower traffic flows and less congested conditions. Benzene and Butadiene show similar trends to nitrogen dioxide and particulate matter.

Climate Change

15.7.27 Impacts on climate change will be as described above.

15.8 Proposed Mitigation (Construction Works)

Existing Conditions Scenario

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 and local air quality impacts are undertaken.

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 will carry out monitoring on a weekly basis. However, if dry windy weather prevails, then the rate of dust monitoring will initially be increased to daily, and then 4 times per day if levels remain high.

15.8.3 The mitigation measures described below will be implemented as necessary. 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.

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.

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Site Clearance

15.8.5 The prolonged storage of debris on site, in temporary stockpiles will be avoided. Vehicles removing demolition or site clearance materials will have their loads effectively sheeted on all sides. Crushing of material for reuse, transportation or disposal will be undertaken as far away as possible from sensitive receptors. Burning of waste material will be avoided if possible. Excavation faces, when not being worked will be sheeted.

Handling and Storage of Materials

15.8.6 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.

15.8.7 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. Stockpiles will be sheeted, contained within wind barriers or potentially damped down. If long term stockpiles are required, consideration will be given to the use of chemical bonding agents.

Site Roads and Haulage Routes

15.8.8 Hardstanding areas for vehicles entering, parking and leaving the site will be provided, with wheel washing facilities at access points. Site roads will be cleaned regularly, and damped down if necessary. Site vehicle movements will be kept to a minimum and, where 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.

15.8.9 If required, cleaning of public roads used for transport of materials will be undertaken.

Mechanical Operations

15.8.10 Static and mobile plant will be well maintained, regularly serviced and located as far away as practicable for sensitive receptors. Spillages will 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 “existing conditions scenario” above

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15.9 Proposed Mitigation (Operational Impacts)

Existing Conditions Scenario

15.9.1 When assessed against the statutory Air Quality Objectives, the impacts of the expansion of Lydd airport are predicted to be of minor to moderate significance. However, the impacts of the expansion on sites designated for the protection of ecosystems, is potentially major, albeit over limited areas of the sites. Therefore, the following mitigation measures will be implemented as part of a long term strategy to minimise the impacts of the airport expansion on air quality.

• Commission of air quality monitoring to monitor the operational impacts of the proposed development.

• LAA will develop an 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 vehicle.

• 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.

• Minimise spillages and fugitive losses of VOCs from refuelling operations. 15.9.2 The modelling of the diesel CHP emissions for the ES has been undertaken on the basis of a 10m stack located to the north of the terminal building. The stacks for the proposed oil and biomass are 16.5m tall, located towards the south-east end of the terminal above the public concourse. Sensitivity test have demonstrated that, off- airport and on-airport, where the public have regular access, the impacts of the diesel boiler are a worst case.

Climate Change

15.9.3 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.

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Future Assessment Conditions Scenario

15.9.4 Proposed mitigation for operational impacts under this scenario is as described under the “existing 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 proposed terminal building is expected to have no more than a moderate 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 proposed development 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 500,000 passengers per annum capacity.

15.11.3 Changes in PM10 and NMVOC concentrations resulting from the increase in airport passenger numbers and the construction of the terminal building are negligible. PM10 levels are predicted to decrease from current levels as a result of generally decreasing background concentration levels.

15.11.4 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

15.11.5 Concentrations of NOx are currently predicted to be within the Air Quality Objective for the protection of vegetation and ecosystems.

15.11.6 In the vicinity of the airport, NOx concentrations are predicted to exceed the Air Quality Objective over the proposed SSSI. However, this limit has no statutory basis in this assessment. The Air Quality Regulations state that the NOx Objective relate to average concentrations over areas in the region of 100km2, and it should be noted,

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2 that taken over the study area as a whole (30km ), the annual mean NOx concentration is 22μg/m3. This concentration is well within the Objective.

15.11.7 Background levels of nitrogen deposition currently exceed the most conservative estimate of the critical load over the designated sites in the vicinity of the airport, but within the upper estimate. Deposition is predicted to remain within the upper estimate of the critical load over Dungeness SAC and Dungeness to Pett Level SPA in the future scenarios for airport expansion. A limited area of Northlade SSSI is predicted to experience nitrogen deposition levels at the upper estimate of the critical load. Taking into account the area of the sites affected, and the presence of sensitive habitats, the impact of the airport expansion on nitrogen deposition is predicted to be of moderate significance.

15.11.8 To mitigate the impacts of the expansion of LAA on designated sites in the vicinity of the airport, an Air Quality Strategy will be developed by LAA to ensure long term reductions in pollutant emissions in consultation with the appropriate bodies.

Climate Change

15.11.9 The current proposal to construct a new terminal building would increase passenger numbers to 500,000 ppa, and would alter the aircraft fleetmix 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.

15.11.10 However, greenhouse gas emissions estimates at 500 000 are difficult to make at this stage, as it is not clear which routes and exact fleetmixes 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.

15.11.11 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 fleetmix alterations.

15.11.12 The impacts of the different options for the terminal heating and lighting system on greenhouse gas emissions have been considered in a screening assessment. This has demonstrated that a diesel fired CHP plant provides a reduction of emissions with respect to an oil fired boiler, but that a biomass burner has the lowest overall impact.

15.11.13 Overall, for the majority of impacts, no significant difference in magnitude is expected between those impacts anticipated to arise when the “existing conditions scenario” and is compared to the “future assessment conditions” scenario.

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16 NOISE AND VIBRATION

16.1 Introduction

16.1.1 This section of the Environmental Statement assesses the potential noise and vibration impacts of the proposed terminal building development at LAA. The proposed building would significantly increase the capacity of the airport (in terms of passengers per annum) and hence lead to a greater number of aircraft movements. The assessment identifies all significant pre- and post-development noise and vibration sources, quantifies their potential effect on existing and future noise and vibration sensitive receptors.

16.1.2 The scenario’s 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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• Ground operations; and • 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; and • 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; and • 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 but still considered appropriate.

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 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

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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 flightpath 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 used1. 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 1 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):

Noise Exposure Category in LAeq,16hr dB Time of Day A B C D 07:00 – 23:00 < 57 57 – 66 66 – 72 > 72 Table 16.1: PPG24 – Noise levels corresponding to the daytime noise exposure categories (NEC’s) for new dwellings due to air traffic noise

1 Planning and Policy Guidance (PPG) 24: Planning and Noise

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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 flightpaths for takeoff 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.

16.3.18 It should be noted that the approach and departure flightpaths used in the model represent a worst case 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 flightpaths. The rate of climb of each aircraft will also differ depending on these factors. INM uses typical flight trajectories for each aircraft modelled.

16.3.19 Larger aircraft such as the Boeing 737 and the Airbus 319, 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.

16.3.20 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.

16.3.21 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 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.

16.3.22 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

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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 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)

16.3.23 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.

16.3.24 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.

16.3.25 PPG24 offers equivalent night-time levels for aircraft noise, expressed in terms of noise exposure contours in LAeq. The NEC table for night-time aircraft noise is presented in Table 16.2 (below):

Noise Exposure Category in LAeq,8hr dB Time of Day A B C D 23:00 – 07:00 < 48 48 – 57 57 – 66 > 66 Table 16.2: PPG24 – Noise levels corresponding to the night-time noise exposure categories (NEC’s) for new dwellings due to air traffic noise

16.3.26 The World Health Organisation (WHO) has produced Environmental Health Criteria 12: Noise, 19802, 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,8 or less at night (internal) will help preserve the restorative properties of sleep.

16.3.27 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 inside level of less than 30 dB(A) Leq,8h. The attenuation offered by an open window is typically around 16 dB, so this corresponds to an outdoor level of 45 dB(A) when allowing for natural free ventilation to the bedroom.

16.3.28 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 4 1992 . 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.

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16.3.29 For a small number of night-time flights, the most stringent criteria to be met is the Lmax levels at the nearest residential properties.

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Ground Operations

16.3.30 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.

16.3.31 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. 16.3.32 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 receptors5.

16.3.33 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 exposure 3. 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 annoyance 1.

16.3.34 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.

Increased Road Traffic Noise

16.3.35 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.

16.3.36 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.

5 ISO 9613 Acoustics (1993) Attenuation of sound during propagation outdoors 6 BS 8233, (1999) ‘Sound Reduction and Noise Reductions for Buildings’ BSI 7 Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 7; Traffic Noise and Vibration, Department of Transport. December 2006 Page 307 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 16 LAA

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The Effects of Noise on Schools

16.3.37 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.

16.3.38 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.

16.3.39 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 Birds

16.3.40 The noise impact on birds is assessed in Chapter 11, Bird Conservation and Hazard Management.

16.4 Baseline Environment (Existing Conditions Scenario)

16.4.1 The existing noise climate in the areas surrounding LAA has been determined by way of a baseline noise survey and modelling of existing impacts, each of which is described below. Noise monitoring took place in a number of positions representing typical residential locations that could be impacted by the proposed development. Refer to Appendix 16.1 for details of the monitoring methodology, including measurement periods, weather conditions during monitoring and the full set of measurement results.

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 with potential 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.

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 , 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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16.4.4 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.

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.

Table 16.3: Monitoring locations

16.4.5 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.

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 16.4: Summary of daytime (0700-2300) levels during unattended monitoring

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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 Table 16.5: Summary of night-time (2300-0700) levels during unattended monitoring

16.4.6 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 noise from the farm itself.

16.4.7 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.

16.4.8 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.

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

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

16.4.9 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 flightpath 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 ten seconds. In Location P8 (Church Road, New Romney), aircraft were visible, but only just audible, during two of the ten-minute monitoring periods.

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16.4.10 An INM computer noise model was created to show the noise levels 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).

16.4.11 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.

16.4.12 Given that monitoring data shows that current operations are not significantly audible beyond the site boundaries no further assessment of aircraft noise (eg SELs - see below), ground noise or road travel is included in this section.

16.5 Baseline Environment (Future Assessment Conditions Scenario)

Airborne Aircraft: Background Noise Levels

Daytime (07:00 – 23:00hrs)

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. As described in section 16.3, 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 flightpaths that will always be used by aircraft, as these will vary depending on the aircraft, pilot, weather, payload, and other factors.

16.5.3 The fleetmix for this scenario (300 000 passengers per annum) contains additional and larger aircraft than currently frequent the airport; (eg the Boeing 737 and the A319) and an average of 4 movements per day in total are expected for such aircraft. The ILS approach system and associated flightpath will be used by such large aircraft, and, 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, before banking right to avoid the no-fly zones.

16.5.4 Figure 16.3 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.

16.5.5 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.

16.5.6 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.

16.5.7 The 45dB(A) contour line extends to Lydd village, due to the flight paths 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

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bank left after takeoff as they can avoid the Dungeness power station exclusion zone. This indicates that residents in these locations will experience marginally elevated noise levels.

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.

Night-time (23:00 – 07:00hrs)

16.5.9 LAA currently has a license to operate 24 hours a day and night-time movements have been assessed.

16.5.10 To provide an indication of the number of night time flight movements 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.

16.5.11 The following combinations of aircraft would represent the limit at which the 48dB(A) contour noise level would not be breached at residential properties:

• South: One A319 either approaching or departing.

• North: Two A319 Approaching, or one A319 Departing, or one Boeing 737 either approaching or departing. Airborne Aircraft: Peak Noise Levels

Daytime (07:00 – 23:00hrs)

16.5.12 The computer noise modelling described above does not mean that no properties would experience intermittently elevated noise levels. Rather, the low number of large aircraft movements means that the corrected 16-hour average levels do not breach generally accepted criteria for disturbance. It is therefore also important to consider the instantaneous or peak noise levels.

16.5.13 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.

16.5.14 Table 16.7 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 16.7: 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

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16.5.15 Larger aircraft which take off towards the South will turn right soon after becoming airborne, in order to avoid the military exclusion zone. Although the rate of climb depends on a number of factors, an aircraft passing over Lydd village would generally have already reached an approximate height of 1000 feet. It is evident from table 16.7 that the SEL of this event is likely to be between 88 and 104 dB(A).

16.5.16 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.

16.5.17 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.

16.5.18 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.

16.5.19 Table 16.8 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 16.8: 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 St Mary’s Bay 6000 1350 86 73 47 Dymchurch 7500 1680 83 70 41

16.5.20 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.

16.5.21 When assessed against the recognised government criteria, the future assessment conditions scenario 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.

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Night-time (23:00 – 07:00hrs)

16.5.22 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.

16.5.23 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.

16.5.24 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 at some locations directly beneath the flightpaths. This has the potential to cause sleep disturbance.

Ground Operations

16.5.25 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 manoeuvred into parking positions. Such aircraft also introduce APU’s or GPU’s, which represent a continuous noise source at a much lower level.

16.5.26 These operations will not take place outside of the existing hardstanding areas (close to the existing 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 hardstanding 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.

16.5.27 Whilst it was not possible to measure the ground 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 11. 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.

16.5.28 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.

16.5.29 Whilst there are no existing scheduled night flight movements at present, night-time movements could occur as part of the future assessment conditions scenario. 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

11 Sharps Redmore Partnership (1999) Farnborough Aerodrome Environmental Statement, Technical Appendix IV: Noise. December 2006 Page 314 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 16 LAA

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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.

Road Traffic Noise

16.5.30 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 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 the future assessment conditions scenario 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.

16.5.31 Table 16.9 shows the baseline predicted traffic flows and the predicted traffic increase for this scenario. The increase in traffic flow due to the future assessment conditions scenario 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 16.9: 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 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 0.6 11500 73 11573 0.6 Site 7 11219 71 11290 0.6 11691 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

16.5.32 The calculated 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, and in accordance with DMRB guidelines this is not expected to result in traffic noise (or vibration) levels significantly different from the existing baseline .

16.5.33 The nature of traffic noise must also be considered, and this 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.

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16.6 Predicted Impacts (Construction Works)

Existing Conditions Scenario

16.6.1 The construction of the terminal building has the potential to generate noise impact throughout the construction phase, primarily at noise sensitive receptors close to the construction site.Construction activity inevitably leads to temporary noise generation at locations in close proximity to the construction site. However, due to the distances between the proposed site and the nearest receptors, the impact of construction activity on residents will be reduced.

16.6.2 Construction noise predictions can be made based on the methodology outlined in BS 5228: 1997 'Noise and vibration control on construction and open sites' 12 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 Sites13. This has been used to supplement the database contained in BS 5228.

16.6.3 Noise sensitive receptors exist in all directions from the construction site, including farms on the outskirts of Lydd town (to the West); the coastal communities of Lydd- on-Sea and Greatstone-on-Sea (to the East); and Greatstone Primary School to the north east. The typical distance between potential construction activities and receptors is however over 1000m. Table 16.10 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 worst-case estimates based on propagation attenuation only and do not account for any screening or directivity effects.

Typical A- weighted Estimated Sound CONSTRUCTION ACTIVITY/ Sound Pressure Level ASSOCIATED PLANT Pressure Level (LA) at 500m (LA) at 10m

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 Welding/Cutting Steel Welder (Welding Piles) 73 39 Generator for welder 57 23 Cutter (Cutting Piles) 68 34 Other Large Lorry Concrete Mixer 77 43 Concrete Pump (Discharging) 67 33 Tower Crane 77 43 TOTAL 89 55 Table 16.10: Example sound pressure levels associated with typical construction activities

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16.6.4 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 AL7214 can be used to assess the likelihood of a noise impact based on the above predictions. The “Total” figure shown in Table 16.10 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 even less at the noise sensitive receptor locations. Hence the impact of construction noise is not predicted to be significant.

16.6.5 Nonetheless, appropriate working practices would be adopted to minimise noise levels where practicable. Suggested mitigation measures for construction are described in the mitigation section.

16.6.6 Some construction activities can also be a source of ground-borne vibration, which can be a cause for concern at the nearest receptors. Typical proposed activities that would lead to vibration effects include compaction and breaking works.

16.6.7 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.

16.6.8 It is envisaged that the haul route for the terminal development will be similar to that used in the apron construction in 2005. Bulky construction materials were delivered to Ashford by rail and then transported to site by road. 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, See Chapter 14 for further details.

16.6.9 Material will be stockpiled where appropriate 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

16.6.10 Construction impacts under this scenario are expected to be as for the Existing Conditions Scenario outlined above.

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16.7 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

Airborne Aircraft: Impacts on Background Noise Levels

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 flightpaths that may be used. As before they are not intended to define the flightpaths that will always 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 500,000 passengers per annum scenario will see up to 8 movements of Boeing 737 and Airbus 319 movements (per aircraft, per day) with associated increases in equivalent continuous sound pressure level (over a 16 hour day). Figure 16.4 shows the noise contours produced by the computer model for this scenario.

16.7.4 The figure shows that the 57dB(A) contour line remains within the boundaries of the airport and does not extend over any noise sensitive receptors. This represents an increase of approximately 9dB due to airborne aircraft noise at these properties, but indicates that the noise levels remain below the onset of community annoyance at these locations.

16.7.5 The 54dB(A) contour line extends to Homeleigh Farm (to the south) and approximately half the houses on Dunes Road (to the north). This represents an increase of approximately 9dB due to airborne aircraft noise at these properties. These receptors are directly in line with the airport runway and it is likely that all aircraft will fly over these properties regardless of origin or final destination.

16.7.6 Properties in Littlestone are likely to experience an equivalent continuous noise increase of approximately as a result of the proposed project compared to the existing conditions scenario and a similar increase is also expected at Lydd town, as these aircraft will fly directly over Lydd when taking off towards the south. The 45 dB(A) contour in Figure 16.3 and the 48dB(A) contour in Figure 16.4 cover a similar area of Lydd town.

16.7.7 Greatstone Primary school now lies on the 48 dB(A) contour, whereas compared to the 45dB(A) contour in the “Existing Conditions” scenario. This indicates an increase in noise levels of 3dB is likely at this location, which is below the adopted significance criterion.

Night-time 923:00 – 07:00hrs)

16.7.8 LAA currently has a license to operate 24 hours a day and there is the potential for some night-time movements. The indication of the number of night flight movements that would cause the equivalent continuous sound pressure level not to exceed the stated 48dB(A) criterion are as outlined in the Baseline Environment (Future Assessment Conditions) section (and see Figure 16.5).

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Airborne Aircraft: Peak Noise Levels

Daytime (07:00 – 23:00hrs)

16.7.9 As described in sections 16.5.12 – 16.5.24, the computer noise modelling described above does not mean that no properties would experience intermittently elevated noise levels. Rather, the low number of large aircraft movements means that the corrected 16-hour average levels do not breach generally accepted criteria for disturbance. It is therefore also important to consider the instantaneous or peak noise levels, and this has been undertaken using the approach outlined previously for the Future Assessment Conditions Scenario (Baseline Conditions).

16.7.10 Predicted SEL will values will be as outlined under the Baseline Environment (Future Assessment Conditions) section, which gives a clear indication of the likely noise levels of larger aircraft. Whilst the rate of occurrence of these high noise level events will be considerably higher than at present, these events will still only occur infrequently during a typical day, and this is only considered an impact of moderate (adverse) significance.

Night-time 923:00 – 07:00hrs)

16.7.11 LAA currently has a license to operate 24 hours a day and there is the potential for some night-time movements. The indication of the number of night flight movements that would cause the equivalent continuous sound pressure level not to exceed the stated 48dB(A) criterion are as outlined in the Baseline Environment (Future Assessment Conditions) section (and see Figure 16.5).

16.7.12 The investigation into aircraft SEL’s (presented above) indicates that the instantaneous or peak noise levels are likely to exceed the 80 dB(A) maximum level significance criteria at some locations directly below the flightpaths, and this has the potential to cause sleep disturbance should operations continue at night.

Ground Operation

16.7.13 The ground operations of the proposed larger aircraft, namely the Boeing 737 and A319, will give rise to the greatest instantaneous noise levels as outlined in the Baseline Environment (Future Assessment Conditions) section, and whilst operations will not take place outside of the existing hardstanding areas, , and the closest residential receptors to these areas are farms on the outskirts of Lydd town (to the West) and the coastal community of Lydd-on-Sea and Greatstone-on-Sea (to the East), some 1000m away, the increased number of daily movements will increase sources of ground noise.

16.7.14 However, as described earlier, the typical sound pressure level of a large aircraft during taxi manoeuvres equates to an equivalent level of 54dB at 1000m, not accounting for the effects of any screening or absorptive effects. Ground movement will also occur for relatively short periods of time, and 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) so no significant impacts are expected.

16.7.15 In particular, as this noise source does not lead to noise levels in excess of the WHO general daytime outdoor noise level criterion3 (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.

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16.7.16 Should ground movement and engine testing be required before 0700 or after 2300 hours for flights scheduled to fly during the day, 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.

Terminal Building Facilities

16.7.17 The proposed building will incorporate roof-mounted air handling units and chillers, which represent continuous noise sources. The combination of all chillers and air handling equipment is rated at 75 dB(A) at 10m, which equates to an equivalent level of 35 dB at 1000m, not accounting for the effects of any screening, directivity or absorptive effects. This is well below the WHO and BS8233 significance criterion stated above. Table 16.16 summarises the predicted noise level from these units and the existing lowest recorded background noise level, at the location of the nearest noise sensitive receptors, in accordance with BS4142 15.

Receptor Minimum Plant Noise Lowest Acoustic Exceedance of Location Distance Level at Recorded Feature Plant Noise from NSR Background Correction Rating Level Plant (m) (dB(A)) Noise Level, (for impulsive over LA90 (dB(A)) or Background tonal qualities) Noise Level (dB) Lydd town 1000 35 30 0 +5 Greatstone 1800 30 32 0 -2 Dunes 2200 28 34 0 -6 Road Table 16.16 Assessment of noise levels due to roof mounted air handling equipment, in accordance with BS4142.

16.7.18 In accordance with BS4142, the plant noise level is of Marginal Significance at the closest noise sensitive receptors in Lydd town. At other locations, which are further from the proposed terminal building, the plant noise level is likely to be below the existing lowest recorded background noise level. This is a worst case assessment not accounting for possible screening of noise sources due to intervening structures. As such no complaints are expected due to this equipment.

Road Traffic Noise

16.7.19 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 in this scenario is assessed with reference to DMRB [4], which states that a long term increase in traffic noise levels of 3 dB is the smallest perceptible change. This corresponds to a change in flow of 100% (all other factors staying equal, i.e. speed, etc).

16.7.20 Table 16.13 shows the baseline traffic flows and the predicted traffic increase for future assessment conditions scenario, including natural traffic growth in the intervening period. 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

15 BS 4142: 1997 ‘Rating industrial noise affecting mixed residential and industrial areas’, BSI.

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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 16.13: Existing and predicted traffic flows, with terminal building 7 day 18hr AADT 5 day 18hr AADT Increase 2005 Total (%) 2005 Total Increase (%) Site 1 8411 10926 29.9 8764 11342 29.4 Site 3 6061 6874 13.4 6316 7152 13.2 Site 5 7166 10322 44.0 7467 10687 43.1 Site 6 11036 12387 12.2 11500 12882 12.0 Site 7 11219 12563 12.0 11691 13065 11.8 Site 8 3141 3417 8.8 3393 3686 8.6 Site 9 11864 14097 18.8 12363 14657 18.6 16.7.21 The calculated increases in traffic flow due to the development and including traffic growth is not expected to increase by more than 100% at any of the AADT traffic count locations on public roads. According to DMRB, a long term increased impact from vehicle noise (and therefore vibration) is unlikely.

16.7.22 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.

Summary

16.7.23 When assessed against the recognised government criteria, the increase from the current situation to the 500,000 passengers per annum scenario will not lead to the onset of community annoyance, because no properties lie within the 57 dB(A) contour line. However, it should be recognised that the number of large aircraft movements per day will increase, leading to an increase in the frequency of occurrence of comparatively high noise levels, albeit for short periods of time.

Future Assessment Conditions Scenario

Airborne Aircraft

16.7.24 Impacts for the Future Assessment Conditions Scenario will be as described for the Existing Conditions Scenario above, although the magnitude of any such impacts will be reduced as the increase from 300,000 to 500,000 passengers per annum will only increase the number of Boeing 737 and Airbus 319 movements from 4 to 8 movements (per aircraft, per day). Such a doubling of movements is typically associated with a 3dB increase in equivalent continuous sound pressure level (over a 16 hour day), as can be seen from the INM contours.

16.7.25 As previously, Figure 16.4.shows that the 57dB(A) contour line under this scenario remains within the boundaries of the airport and does not extend over any noise

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sensitive receptors. This indicates that the noise levels remain below the onset of community annoyance at these locations.

16.7.26 The 54dB(A) contour line, which extends to Homeleigh Farm (to the south) and approximately half the houses on Dunes Road (to the north), represents an increase of only approximately 3dB due to airborne aircraft noise at these properties, when compared to the “Future Assessment Conditions” scenario.

16.7.27 Properties in Littlestone are likely to experience an equivalent continuous noise increase of between 1 and 3dB in the “Future Assessment Conditions“ scenario.

16.7.28 The 3dB increase under this scenario, due to the doubling of large aircraft movements, will also affect Lydd town, as these aircraft will fly directly over Lydd when taking off towards the south. The 45 dB(A) contour in Figure 16.3 and the 48dB(A) contour in Figure 16.4 cover a similar area of Lydd town.

16.7.29 Greatstone Primary school now lies on the 48 dB(A) contour, whereas it was on the 45dB(A) contour in the “Existing Conditions” scenario and an increase in noise levels of 3dB is still likely at this location, which is below the adopted significance criterion.

16.7.30 SEL’s) for the scenario will as be described previously (including night time impacts), and whilst the rate of occurrence of these high noise level events will double when compared to the future assessment baseline, these events will still only occur infrequently during a typical day,

Ground Operations

16.7.31 Impacts of the proposed project when assessed against the Future Assessment Conditions Scenario will be as described for the Existing Conditions Scenario above.

Terminal Building Facilities

16.7.32 Impacts of the proposed project when assessed against the Future Assessment Conditions Scenario will be as described for the Existing Conditions Scenario above.

. Road Traffic Noise

16.7.33 Traffic noise will change as traffic levels vary over time, which has the potential to impact upon existing receptors. The expected increases in traffic flow figures due to increase in passenger movements are compared to the future assessment conditions scenario flows. 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.

16.7.34 Table 16.17 shows the future assessment conditions scenario traffic flows, and the predicted traffic increase due to the terminal development. 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) 7. Refer to Chapter 14 for information regarding the traffic flow data, and the locations of the AADT Traffic counters. December 2006 Page 322 Prepared by Parsons Brinckerhoff Ltd for LAA CHAPTER 16 LAA

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7 day 18hr AADT 5 day 18hr AADT

Baseline Additional Baseline Additional (300,000 Operational Increase (300,000 Operational Increase PAX) Traffic Total (%) PAX) Traffic Total (%)

Site 1 9891 1035 10926 10.5 10280 1061 11342 10.3

Site 3 6630 244 6874 3.7 6903 250 7152 3.6

Site 5 9165 1157 10322 12.6 9501 1186 10687 12.5

Site 6 12265 122 12387 1.0 12757 125 12882 1.0

Site 7 12441 122 12563 1.0 12941 125 13065 1.0

Site 8 3356 61 3417 1.8 3623 62 3686 1.7

Site 9 13306 791 14097 5.9 13845 812 14657 5.9 Table 16.17: Baseline and Terminal Development traffic flows

16.7.35 Increases in traffic flow due to the proposed development are not expected in excess of 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. 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. It is also likely there will be large traffic movements in the morning and evening. 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.

Summary

16.7.36 Overall, when assessed against the recognised government criteria, the increase to 500,000 passengers per annum will not lead to the onset of community annoyance, because no properties lie within the 57 dB(A) contour line. However, it should be recognised that the number of large aircraft movements per day will increase, leading to an increase in the frequency of occurrence of comparatively high noise levels, albeit for short periods of time.

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 11. In addition, the following mitigation measures will be implemented through the Construction Environmental Management Plan (CEMP):

• Working hours will be agreed with the Local Authority and are specific to the construction site;

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• 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;

• 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; and

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. This is also referred to within the Civil Aviation Act 2006, giving airports power to take economic measures to minimise noise impact. • 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

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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;

• 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; 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 Conditions 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 Scenario

16.10.1 With the implementation of the mitigation measures detailed above, the construction and operation of the proposed terminal building 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 night-time are likely to lead to some sleep disturbance in some individuals, which would be considered a moderate/major adverse impact.

Future Assessment Conditions Scenario

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

16.11 Summary

16.11.1 The potential noise and vibration effects of the proposed terminal extension, in both construction and operational phases, have been assessed

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 11.

16.11.3 The proposed expansion to 500,000 passengers per annum will lead to increases in noise level, but not above the Onset of Community Annoyance. The number of large aircraft movements will double (when compared to the assumed baseline scenario), leading to a 3dB increase in equivalent continuous noise level due to airborne aircraft, and an increase in the frequency of occurrence of high noise levels due to aircraft, although for comparatively short period of time.

16.11.4 Any large passenger aircraft movements occurring during the night have the potential to cause sleep disturbance due to the high maximum noise levels likely.

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16.11.5 For the terminal development 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 3.

16.11.6 For the proposed development, 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.

16.11.7 On balance, in terms of noise, the increase to 500,000 passengers per annum would lead to 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 night-time are likely to lead to some sleep disturbance in some individuals, which would be considered a moderate/major adverse impact.

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 The airport has announced that is will investigate the possible introduction of a compensation scheme for cases where it can be demonstrated that noise levels exceed the onset of community annoyance values, and there is demonstrable evidence of house-price reductions.

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CHAPTER 17

SOCIO-ECONOMIC ISSUES

CHAPTER 17 LAA

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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 four potential terminal development 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 impact assessment will 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 1.4 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 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 Condtitions)

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 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, 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

35 30 25 20 15 10 5 0 0-15 16-24 25-34 35-44 45-59 60-64 65+ % Change 1991 - 2003 -5 -10 -15 age group

immigration of more elderly people, including those of retirement age.

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 Area.

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. South Kent College serves the study area and has sites in Dover, Ashford and Folkestone. There are universities at Canterbury and Medway. The Airport recognises the need to work with the Education service providers and to that extent it has a representative on the Governing body of the college with whom it will develop appropriate training programmes.

Health Services

17.3.9 There are doctor surgeries in Lydd, New Romney 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 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

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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 2007.

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 for 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.

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20 18 16 14 Study Area 12 W ider Environs % 10 8 South East 6 Great Britain 4 2 0

l s e rial na in ry arial vice ta ge io ional t rades rvice r ch a ss s a en fe fes r Se m an o l Se M le M ro d E P Pr na e Skilled T o lant an Pers P Associat Sales & Customerocess, P Administrative and Secre

Figure 17.4 Occupational Groups (1995-2003) Source: Annual Employment Survey (1995- 1997) (factored) / Annual Business Inquiry (1998-2003)8

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)9

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

8 Information for Rother and Hastings was not available for this analysis, and these councils are not included when collaborating data for the Wider Environs 9 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 Inquiry10

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).

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

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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/NOMIS11

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)

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

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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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, employment numbers will drop further, although there will be opportunities to transfer to ‘B’ station or 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 201812.

• 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

12 Dungeness A Nuclear Power Station Environmental Statement, 2005, British Nuclear Group

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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.

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)

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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. 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).

Figure 17.8 Overseas and domestic tourism spending by category, 2001 Source: House of Commons, 2003

17.3.25 The South East of England attracted over 16 million domestic visitors per annum, and nearly 4 million overseas visitors in 2004 (IPS13). The overseas trips were predominantly holiday visits, followed by visits to friends or relatives, then business

13 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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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 Holiday 1.08 £274 m Visiting Friends and Relatives 1.40 £389 m Business 0.99 £472 m Other 0.46 £331 m Total for South East England 3.95 £1,467 m

17.3.26 The highest number of visitors to the South East by nationality in 2004 was 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.

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)

17.3.27 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

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local economy is estimated to have supported approximately 2,700 Full Time Equivalent Jobs and 3,670 Actual Jobs (Tourism South East (TSE), 2004).

17.3.28 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).

17.3.29 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 recommenced in 2006.

17.3.30 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 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

17.3.31 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.

17.3.32 Airport companies themselves typically account for approximately 20% of direct employment, although this will vary with the extent of outsourcing14. The Regional Air Services Co-ordination Study (RASCO) study15 provides a breakdown of airport

14 Regional Air Services Co-ordination Study (RASCO), DfT (2002) 15 ibid

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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.

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

17.3.33 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

17.3.34 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.

17.3.35 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.

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17.3.36 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 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

17.5.1 The scale of construction employment will be 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.

17.5.2 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 £15 million for the terminal development, which would be completed by 2010. 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.

17.5.3 Based on this ratio and the estimated construction costs of £15 million, it is estimated that approximately 280 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 some 28 FTE jobs.

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Future Assessment Conditions Scenario

17.5.4 Predicted impacts from the construction of the terminal are expected to be the same as described in the ‘existing conditions scenario’ above.

17.6 Predicted Impacts (Operational Impacts)

Existing Conditions Scenario

Operational Based employment forecast

17.6.2 The proposed terminal 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 that is 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 17.6.3 Using the calculations, outlined in Section 17.2 it is predicted that 500,000 passengers per annum would support

• a direct employment workforce of 300 persons (ie an increase of 232 jobs);

• an indirect employment workforce of 90 persons (ie an increase of 70 jobs); and

• an induced employment workforce of 117 persons (ie an increase of 91 jobs);

The combined amount of employment is therefore an increase of 393 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 terminal development should be met by the labour supply in Shepway and the Wider Environs, with the majority of

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employees expected to live locally and LAA have a commitment to preferentially employ at least 80% of its direct employees locally16.

17.6.5 The relationship between labour demand and supply 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 are insufficient, locally-qualified resources available to absorb the demand, in- migration and/or increased competition for local labour supply will generally result, 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 17.4.8. 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 Shepway17. 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.

17.6.6 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.

17.6.7 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.

17.6.8 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

16 See ECOTEC (2001) The Local and Regional Economic Impacts of the Expansion of Regional Air Services 17 Dungeness A Nuclear Power Station Environmental Statement, 2005, British Nuclear Group

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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.

Population

In-Migration

17.6.9 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.

17.6.10 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

17.6.11 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.

17.6.12 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 Noise Events (ANEs) on sleep disturbance18 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

17.6.13 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,

18 Department of Transport paper 1992

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increased levels of employment and opportunities for travel may have the opposite effect. Longterm impacts to house pricing are therefore uncertain.19.

Schools

17.6.14 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

17.6.15 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.

17.6.16 “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.

17.6.17 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

17.6.18 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.

17.6.19 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.

19 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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Inbound Tourism Impacts

17.6.20 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.

17.6.21 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 tourism20 indicates that overseas visitors are currently worth approximately £242 each to the South West economy21and 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.

17.6.22 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 travel22. 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

17.6.23 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.

17.6.24 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.

17.6.25 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

20 Value of Tourism (2003) South East Tourism 21 Data taken from BIA Economic Impact Study (2005) BIA & SW RDA 22 The Impacts of Future Aviation Growth in the UK, Strategic Aviation Special Interest Group (SASIG) December 2000

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(COFAR)23 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 Conditions Scenario

17.6.26 As described above, using the calculations outlined in Section 17.2, it is predicted that 500,000 passengers per annum would support

• a direct employment workforce of 300 persons (ie an increase of 120 jobs against this baseline);

• an indirect employment workforce of 90 persons (ie an increase of 36 jobs against this baseline); and

• an induced employment workforce of 117 persons (ie an increase of 47 jobs against this baseline);

The combined amount of employment is therefore an increase of 203 jobs from the existing conditions baseline, which is a positive impact.

17.6.27 The combined amount of employment is therefore an increase of 203 jobs from the existing conditions baseline, which is a positive impact

17.6.28 Other impacts associated with this scenario are similar as to those discussed in the ‘existing conditions scenario’ above.

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.

23 Common Options for Airport Regions COFAR (2001) Airport City and Regional Embeddedness: Final Report

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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 Whilst the construction jobs are a significant short term boost they do not, of themselves, raise the long term productive capacity of the regional economy. Longer term jobs are more beneficial, but any expansion at LAA will also enhance the attractiveness of the Shepway District and surrounding region as a location for inward investment.

Future Conditions Scenario

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.

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 at LAA are expected to create 28 Full Time Equivalent (FTE) jobs, and operation of the airport with 500,000 passengers per annum and the new terminal would result in 300 direct jobs, 90 indirect jobs and 117 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.

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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

SUSTAINABILITY

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18 SUSTAINABILITY

18.1 Introduction

18.1.1 This chapter considers the extent to which the proposed development accords with the principles of sustainable development. The degree to which developments are considered to be ‘sustainable’ is an increasingly important consideration in the planning process. The main impetus behind sustainable development is the concept of ensuring a better quality of life for everyone, now and for future generations. Therefore to achieve this, planners and developers must take full account of the long-term social, economic and environmental impacts, of development. The widely accepted definition of sustainability (from the Brundtland Report) is “development which meets the needs of the present without compromising the ability of future generations to meet their own needs.”

18.1.2 The Chapter addresses two key issues, namely the incorporation of sustainability principles into the design of the facility (Section 18.3), and an assessment of the sustainability of the concept of the Project as a whole (Section 18.4). The assessment has been undertaken in the context of those key local and regional issues that are considered to be of direct relevance to the planning application – the sustainability of air travel per se is considered an issue for debate at a different level.

18.1.3 It should also be noted that this Chapter includes a review of the proposed sustainability of the project and therefore includes no evaluation of the existing Baseline Conditions or Future Assessment Conditions.

18.2 Legislative Drivers

18.2.1 This Chapter should be read in conjunction with Chapter 5: Planning Policy Framework.

International Sustainability Guidance

18.2.2 The Objectives of the World Summit on Sustainable Development, Johannesburg, 2002 have been reviewed as part of this sustainability assessment, as well as the numerous EU Directives and other international agreements that are discussed in the previous chapters of this ES.

National Sustainability Guidance

18.2.3 National guidance is issued by the Government in the form of Planning Policy Statements (PPSs) which are currently replacing Planning Policy Guidance (PPGs) notes. PPSs are reflected at a local scale in Regional Planning Guidance (RPG) and in the local development plans. PPS1, published in February 2005, places a strong emphasis on sustainable development and states that the planning system should seek to promote the Government’s four aims for sustainable development, which are as follows:

• Effective protection of the environment;

• Prudent use of natural resources;

• Social progress which recognises the needs of everyone; and

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• Maintenance of high and stable levels of economic growth and employment. 18.2.4 A number of other PPSs / PPGs are also considered relevant to the proposed development at LAA, as described in the previous chapters.

18.2.5 In addition to these PPSs and PPGs, a number of national plans, programmes and environmental objectives have been reviewed, including, but not limited to:

• A Strategy Towards Sustainable Development of UK Aviation (2005);

• Climate Change: UK Programme (2002);

• Our Countryside: The Future – A Fair Deal for Rural England (Rural White Paper) (2000);

• Our Towns and Cities: The Future (Urban White Paper) (2000);

• Securing the Future: UK Government Sustainable Development Strategy (2005);

• The Future of Air Transport White Paper (2003);

• The Future of Transport: A Network for 2030 (2004); and

• UK Biodiversity Action Plan.

Regional Sustainability Guidance

SEEDA Sustainability Checklist

18.2.6 The South East England Development Agency (SEEDA) Checklist is the key document used for assessing the sustainability of development in the South East. This Checklist has been developed, in collaboration with an advisory group consisting of Local Authorities, developers, researchers and SEEDA, from Building Research Establishment (BRE)’s Sustainability Checklist for Developments. It aims to bring a regional focus to the original Checklist, giving information on regional good practice, sources of further information, as well as how it relates to regional policy. The purpose of this Checklist is to demonstrate to the region the context they are working in and move them towards a common goal.

18.2.7 The Sustainability Checklist draws together the various regional strategies and forms a significant tool in the assessment of the sustainability of new developments in the South East. In particular, it outlines the positive measures that can be applied to reduce environmental impact or enhance environmental, social and economic benefits and encourages good practice through a scoring system.

18.2.8 The various regional strategy documents that have been used in the identification of criteria for the Sustainability Checklist include the following:

• South East Regional Economic Strategy (2006-2016);

• Regional Planning Guidance for the South East (2001);

• Draft Waste Management Strategy;

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• Energy Efficiency and Renewable Energy;

• Tourism and Related Sport and Recreation;

• Regional Spatial Strategy;

• The South East Sustainable Development Framework – ‘A Better Quality of Life in the South East’ (2001); and

• Regional Transport Strategy (2004). 18.2.9 The Checklist in its entirety is addressed in Section 18.4 and a summary of each of the relevant strategies follows below.

South East Regional Economic Strategy

18.2.10 This document, published in 2006, sets a 10 year framework for delivering the economic aspirations of the vision for sustainable development. The Regional Economic Strategy (RES) has been developed to meet the aim that by 2016 the South East will be recognised as one of the world’s top 15 performing economies, as measured against a broad range of economic, social and environmental indicators. The RES has been developed to help manage the challenges of living in one of the most economically advanced regions in the World. The three main challenges identified within the RES are broadly similar to those contained within the Draft 2002-2012 RES:

• The Global Challenge – maintaining the South East’s competitive edge;

• Smart Growth – investing in underperforming areas, communities and individuals; and

• Sustainable Prosperity – applying the principles of sustainable development. 18.2.11 The principles of sustainable development require that economic growth must assist the region to achieve the objectives of sustainable development and this is the cornerstone of the RES. As such, the RES has five key objectives:

• Competitive businesses;

• Successful people;

• Vibrant communities;

• Effective infrastructure; and

• Sustainable use of natural resources

Regional Planning Guidance for the South East (RPG9) (to be replaced by the Regional Spatial Strategy)

18.2.12 This covers the period up to 2016 and sets the standard for the long term future. The primary purpose of this guidance is to provide a regional framework for the preparation of Local Authority Development Plans, as well as a spatial framework for other strategies

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and programmes, including Local Transport Plans and Regional Strategies. The document covers areas such as:

• Environment;

• The Regional Economy;

• Transport;

• Infrastructure;

• Minerals; and

• The Sub-Regions. 18.2.13 The RPG has identified potential targets and indicators for these areas which have been included as relevant in the SEEDA Checklist.

South East Regional Spatial Strategy

18.2.14 RPG9 will eventually be replaced by the South East Plan, which sets out a vision for the region from 2006-2026, focusing on housing, transport, economy and environment. The South East England Regional Assembly (SEERA) has formally submitted the draft South East Plan to the Government, but, as it is currently in the consultation phase, it is still subject to changes. As a result the policies found in RPG9 are discussed here as the current relevant policy for South East England.

The Regional Sustainable Development Framework (RSDF): A Better Quality of Life in the South East

18.2.15 This is published by the Regional Assembly, Government Office, Regional Development Agency, Environment Agency and National Health Service. The document provides a vision for the South East and includes sustainability indicators and targets. This document has now been replaced by The Integrated Regional Framework for the South East (2004) (IRF), which is an evolution of the RSDF; providing a framework for integrating key regional strategies and plans, through presenting summaries and an analysis of the links between those documents and setting out a universal approach to sustainability appraisal.

Regional Transport Strategy (2004)

18.2.16 This strategy lays out the South East’s transport policies. It also provides the context for the preparation of Local Development and Transport Plans by Local Authorities. The aim of the South East RTS is to achieve a transport system which reaches the standards of the best in North West Europe by:

• promoting good management and investment in the transport system;

• offering value for money by fully utilising existing transport capacity;

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• improving the structure of the transport system in favour of more sustainable means of transport; and

• supporting the South East spatial strategy, particularly fostering links with other regions and supporting urban regeneration.

Local Sustainability Guidance

Kent Design Guide

18.2.17 The Kent Design Guide is a document produced by all the Local Authorities in Kent - County, Unitary and District Councils - on behalf of all the communities they represent for the purpose of promoting sustainability and good design in Kent. The Guide has been formally adopted in Kent as Supplementary Planning Guidance and is being adopted locally by the County's 12 District Councils. The main objectives and principles of the Kent Design Guide are as follows:

• Adopt a proactive and collaborative approach to development proposals to achieve the optimum solution for a given site;

• Seek environmentally sustainable solutions through innovative design;

• Ensure the public realm is maintained for its lifecycle through formal adoption or other management arrangements;

• Bring together residential, commercial, retail and community uses in a manner which reduces the need to travel and improves quality of life;

• Promote the movement of people by walking, cycling and public transport to reduce car dependency and maintain and improve air quality;

• Embrace local distinctiveness, promote quality and protect existing features of cultural, visual and historical importance;

• Provide a safe, healthy and secure environment for both people and property;

• Maximise the use of land by encouraging the development of recycled land and increasing density;

• Conserve natural resources and minimise pollution in the layout, construction and ongoing use of development; and

• Conserve, create and integrate open space, landscape and natural habitats as part of development. 18.2.18 As part of the Kent Design Guide, a guide to sustainable design services within Kent has been produced, entitled “The Directory”. The Directory has been designed for use by all those involved in the development process and construction industry across Kent. It is an attempt to provide practical advice and information to translate the Kent Design Guide principles into practice. The main objective is to provide a listing of local expertise, suppliers, contractors and products for use in more sustainable design and construction.

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The Kent and Medway Structure Adopted Plan (July 2006)

18.2.19 The Kent and Medway Structure Adopted Plan (July 2006) has the primary role in providing the strategic planning framework which will guide decisions on development, transport and environmental matters in Kent and Medway over the 20 year period 2001- 2021. The Plan shapes the scale, location and form of private and public investment in Kent over that period and interprets National and Regional policies as they apply to Kent and Medway. The Structure Plan's prime contribution to improving economic, social and environmental well being will be through promoting a more integrated, better designed and more sustainable pattern and form of development.

18.2.20 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; (Issues relating to Climate Change have been dealt with in Chapter 15 Air Quality).

• 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.

• The Structure Plan seeks to ensure that development incorporates sustainable construction techniques and that consideration of energy conservation, prudent used of water and other natural resources has been considered in the design of the development. A reduction of ‘greenhouse gas emissions’ through the efficient use of resources is also sought.

• The Kent Design Guide has been developed for Kent County by all the Local Authorities in Kent. The guidance seeks to foster high quality, well planned and sustainable development.

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The Shepway Adopted Local Plan (2006)

18.2.21 The Shepway District Local Plan was adopted July 2006. Policy surrounding sustainable development is outlined in Policy SD1, which provides a starting point against which proposals for development should be assessed. All development proposals should contain environmental criteria, which include:

• Sustainability, in terms of development patterns, energy efficiency and the need to travel;

• Preserving built and cultural heritage;

• Protecting and enhancing areas of countryside that are of special quality, or of international, national, countrywide and local importance; and

• Maintaining and enhancing water, soil and air quality. 18.2.22 Any development proposals that significantly conflict with the environmental criteria outlined in Policy SD1 would only be permitted where there is an overarching economic or social need, where negative impacts are minimised as far as possible and where measures are taken to compensate for adverse environmental effects.

18.3 Sustainability of the Proposed Terminal Design

18.3.1 The proposed terminal has been designed with a number of key sustainability objectives in mind, namely:

• Rainwater harvesting has been incorporated within the terminal design and storage tanks provided for grey water so that it is readily available for appropriate uses such as flushing toilets and watering landscaped areas.

• Options have been included to allow the use of biomass fuel for heating (woodchip or wood pellets) as a backup to oil for the boilers. Such fuel, if produced sustainably and locally can be considered carbon-neutral. A more detailed biomass feasibility study will be undertaken to establish the availability of a reliable source of biomass fuel sources local to Ashford. 18.3.2 Natural ventilation has not been included within the terminal design as it is deemed counteractive to other sensitive issues, primarily acoustics insulation (from aircraft noise) and control of the building environment. Instead, three options have been considered for mechanical ventilation and cooling systems as shown in Table 18.1 overleaf.

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Table 18.1: Options Considered for Mechanical Ventilation and Cooling Systems

Proposed System Advantages Disadvantages

Displacement Ventilation Better indoor air quality than conventional mixing systems – It is not an effective design solution with ceiling heights lower fresh air is introduced at low level and extracted at high level than 2.5m; after picking up heat and contaminants produced by occupants or equipment in the space; It is susceptible as a system to strong air movements in the room Where mechanical ventilation e.g. caused by continuous strong internal movements or from is to be considered, a Air is supplied into the room at higher temperatures and in lower leaky, poorly insulated buildings where infiltration and down particular type is displacement quantities than conventional mixing systems; drafts adversely affect the ventilation performance; ventilation which has the following advantages and Air is allowed to stratify over the height of the room, meaning It is not very effective at providing heating to the space and disadvantages that a higher return air temperature is achievable than for separate heating systems may be required e.g. radiators, radiant conventional mixing systems; panels or convectors;

It lends itself to use of ground source heat pump technology for Loss of floor space due to displacement air terminals located at cooling due to higher supply air temperature when compared to floor level. One alternative is to create a false floor and use this conventional mixing systems. If mechanical refrigeration is used as a supply air plenum, supplying air into the room via floor the chiller can be set to achieve a better CoP (Coefficient of grilles in a swirl pattern. Furniture layout is therefore limited by Performance) due to higher flow and return temperatures the pattern of the floor grilles; improving system efficiency and reducing electrical energy consumption; and Can produce cool drafts at low level if poorly designed; and

The system is available for free cooling for a higher percentage Cannot usually provide cooling duties greater than 40W/m². of the year than a conventional ‘mixed’ system. Supplementary cooling required for areas of high heat gain.

Active Chilled beams with Caters for high cooling loads; The disadvantages associated with the use of chilled beams Fresh Air Plant include: Smaller ductwork and air handling plant required than for TermoDeck (see below); • higher capital costs;

Roof mounted air handling Relatively rapid response to changing loads; • higher cooling energy consumption; and units would provide tempered fresh air to the chilled beams Easily zoned. It can be laid out to enable future subdivision of • the need for mechanical air handling equipment which in the rooms. Chilled beams space by erecting partitions; will take up space which could be more effectively used would be fed with chilled water for other purposes. Very little maintenance required; Although an excellent system, it is considered that a chilled Very quiet – virtually silent; beam solution is excessive for this development, especially as the building should be able to satisfy internal comfort conditions

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Utilises relatively high temperature chilled water, thus increasing by more passive and low energy means. free-cooling options and/or use of chiller plant to operate at higher CoP;

Simple controls; and

Can provide heating as well as cooling, although not recommended due to various design restrictions this imposes.

TermoDeck Good indoor air quality as system uses 100% ‘fresh air’; Floor/roof construction method of prefabricated hollow slabs – this could impose design restrictions, e.g. steel framed building The TermoDeck concept is a Utilises ‘thermal flywheel’ effect of building mass to absorb instead of in-situ concrete frame; simple one, to utilise the internal heat gains, purging the stored heat with night-time building structure to soak up ventilation, thus reducing or eliminating mechanical cooling Supplementary cooling required for areas of high heat gain or for the heat gains during the day, requirements; areas with long or continuous usage; which are then purged at night by ‘free cooling’ using lower Significantly lower energy costs than for an air-conditioned Suspended ceilings cannot be used; outdoor night-time air building; temperatures. It has proved Pre-cast concrete slabs require building to have steel framework possible to construct a Lower maintenance costs than for an air-conditioned building; construction - this makes horizontal distribution of ductwork building that can maintain difficult, more prominent; comfort conditions comparable Provides stable, comfortable conditions, with relatively low mean to a conventionally radiant temperatures; Additional cost of structure and core drilling of holes in slabs; and conditioned building, without any mechanical cooling at all. Few restrictions on locating furniture, screens and air outlets; Larger air handling plant, ductwork and risers than for chilled Fresh air is passed through a and beams or fan coil systems. hollow core slab prior to delivery into the space and will TermoDeck/Tarmac design team expertise. transfer heat or cool into the structure.

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18.3.3 Displacement ventilation will be adopted within the proposed terminal building in areas of high population, i.e. public concourse areas, departure lounge. The termodeck solution will be adopted where there is a cyclical process of populating a particular space i.e. offices and retail spaces assuming these areas are not in operation for 24 hours.

18.3.4 Heating, Ventilating and Air Conditioning (HVAC) and the plant necessary to support it, is to be included in the terminal design. The proposed system for most of the terminal building will be via a displacement system within the high volume areas. This will provide the most energy efficient system for delivering comfort conditions in the space. The offices and retail spaces will be served with fresh air from central, variable volume air handling plant along with chilled water and low temperature hot water connections also served from pumped variable volume circuits.

18.3.5 Utilisation of thermal mass effects will be encouraged within the terminal building wherever permissible within the structural engineering design, such as within the retail and office spaces. A co-ordinated approach will be taken to try and utilise the thermal mass of the building to reject heat throughout the un-occupied periods. The mass will be able to absorb heat gains during the occupied period and then with using lower air volumes and electricity tariffs will be able to use the ventilation system to purge the spaces at night. This will assist with levelling out the temperature fluctuations within the space during the occupied period and will also allow for lesser capacity cooling systems to be utilised.

18.3.6 A CHP feasibility study has been undertaken, and the results of this are provided in Appendix 18.1.

18.3.7 The primary heating medium will be produced from a combination of biomass boilers (subject to the considerations identified in clause 18.3.1), and oil fired boilers. The inclusion of ground source heat pumps in the terminal design is anticipated but cannot be confirmed until the ground conditions have been proved to be favourable (eg suitable aquifers below ground at a depth which is economically reachable and the presence of surface water that can be used as a heat sink/source for a heat pump). A slightly less efficient ground coupled system could also be considered which utilises the ground itself as a heat sink to improve the CoP of a reversible heat pump.

18.3.8 Wherever possible the primary cooling to the building will be delivered by passive means. An incremental approach shall be taken which shall first try and reduce the cooling load within the building via passive means, i.e. incorporating solar shading, glazing having good solar properties, reduced internal loads etc. Then non-energy intensive solutions will be considered such as absorption cooling fed from biomass boiler (Refer to Appendix 18.1), indirect adiabatic cooling etc, prior to opting for the more conventional energy intensive refrigeration from a vapour compression cycle.

18.3.9 The design of the mechanical and electrical services systems within the terminal building will be Building Regulations Part L compliant. This will ensure compliance with the five criteria. Full dynamic simulation of the proposed designs will be undertaken using Building Research Establishment (BRE) approved software. The purpose of this simulation is to ensure that the buildings carbon footprint is minimised and the necessary reduction in carbon emissions is achieved to comply with Part L2A.

18.3.10 The use of natural daylight has been incorporated into the terminal design in order to maximise available daylight where it is expedient to do, e.g. in public areas by incorporating transparent glazing panels in the wall and roof. Excessive heat gain in summer and heat loss in winter will have to be controlled, and such methods include, shading through external brise soleil (louvres).

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18.3.11 The terminal has been designed with an adaptable layout, in order that the evolution of the terminal building for future expansion may be achieved with the minimum of impact; this is facilitated by designing the terminal as a steel framed building. By ensuring that adaptability is inherent within the terminal design, the terminal will continue to be as operational under future development conditions.

18.3.12 The code for sustainable building seeks to provide a building design that conforms to best environmental practice and looks beyond the 2006 Part L requirements. Grant funding may be available for a range of renewable energy technologies such as wind power, solar hot water, photovoltaics as well as biomass. An option appraisal will be carried out during the development of the design to ascertain if any benefit can be gained over the lifetime of the building from renewable energy technologies.

18.3.13 Sustainable construction materials have been specified in accordance with BRE guidance (Green Guide to Specification), which includes specification of materials to be used within the project. The contractor is obligated to use materials specified, or those that are equal in the Green Guide.

18.4 Sustainability Appraisal

18.4.1 Specific ‘Sustainability Assessment Criteria’ relevant to the proposed development have been identified following a review of the Regional and Local sustainability guidance documents as described in Section 18.2 above. These have included the SEEDA Sustainability Checklist, the IRF, the Kent Design Guide and the Shepway Local Plan and take into account relevant international, national, regional and local sustainability objectives. The purpose of this review was to ensure that the relationship with these plans, programmes and strategies, and their requirements, has been taken into account as part of the assessment process.

18.4.2 The design codes for the proposed development have been assessed in relation to the assessment criteria and a summary of the findings provided in Table 18.4. Recommendations for sustainable design and construction methods are also outlined in the assessment.

Assessment Framework

18.4.3 SEEDA, Kent County Council and Shepway Council are committed to the principles of sustainability. The SEEDA Sustainability Checklist for Developments in the South East, identifies a series of topic areas which are used as the organising framework for this sustainability assessment, as follows:

• Outward focus – impact on the wider community;

• Land use, urban form and design;

• Transport;

• Energy;

• Impacts of buildings and infrastructure;

• Natural resources;

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• Ecology;

• Community; and

• Business.

Sustainability Criteria

18.4.4 Under each topic area, a number of assessment criteria have been identified. These criteria have been specifically adapted from Regional and Local sustainability guidance documents and the criteria taken from the SEEDA checklist have been adapted to incorporate changes made to the Regional Sustainability Framework since the formulation of the checklist. This assessment takes into account the level of detail available at this stage. These specific criteria and their source are identified in Table 18.3. It should be noted that there is a considerable degree of overlap between the various topic areas criteria and other sections of this ES.

18.4.5 The severity of impacts has been recorded using symbols and categories as defined in Tables 18.2 and 18.3 below.

Table 18.2 Framework describing Relevance of Issue Relevance Description Symbol of Issue

There is a clear relationship between the proposed Relevant development and the achievement of the criteria 9

There is no clear relationship between the proposed Not development and the achievement of the criteria, or the Applicable X relationship is negligible

Table 18.3 Framework describing Assessment of Impacts Impact Description

The proposed development contributes to the Positive achievement of the criteria

The proposed development detracts from the achievement Negative of the criteria

The proposed development either has both a positive and negative relationship to the criteria or the relationship is Unknown dependant on the way in which the aspect is managed or insufficient information is available to enable an assessment to be made

18.4.6 A qualitative assessment has been undertaken, based upon professional judgement and with reference to statutory and non-statutory policy guidance, the results of which are shown in Table 18.4.

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18.5 Summary

18.5.1 Relevant National, Regional and Local sustainability criteria guidelines have been reviewed and the proposed terminal development design, construction and operational plans and programmes have been examined with reference to them. Issues of air travel per se are considered a higher-level discussion and have not been included in this review.

18.5.2 Overall, whilst some aspects have less obvious sustainability benefits than others, the design intentions of meeting (as a minimum) BREEAM “very good” standards and incorporating sustainable technologies (such as rainwater harvesting and appropriate ventilation) and approaches (such as the use of a green travel plan) wherever practical are considered to be good practice for such a development.

18.5.3 However, in order to ensure that the development provides a suitable ‘best practice’ example to other developers in the South East region, the following issues in particular will also be addressed as part of the development:

• Public involvement should continue throughout the design and construction of the development to ensure the needs of the wider community are addressed;

• The airport will produce an Construction Environmental Management Plan which will set out the contractors’ roles and responsibilities during the construction of the terminal;

• The airport will produce an Environmental Management Plan (EMP) to ISO14001 standards;

• Implementation of an airfield Biodiversity Action Plan;

• A Travel Plan has been produced for the airport;

• Noise mitigation will be adopted to minimise the airport’s activities;

• LAA will develop, and report on, its own sustainable policies, including retaining a target that 80% of its employees to be local; and

• The airport will continue to maintain a public consultation strategy. 18.5.4 Given the above, the proposed development is considered to be broadly supportive of the sustainability objectives of the representative local and regional bodies.

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Table 18.4 Sustainability Assessment Sustainability Assessment Criteria Issue Impact Source 1. OUTWARD FOCUS – IMPACT ON THE WIDER COMMUNITY Do the development proposals… 1.1 Encourage partnership working? 9 Positive RPG 9 1.2 Involve the local community in the evolution of the scheme? 9 Unknown SEEDA Checklist 2. LAND USE, URBAN FORM AND DESIGN Do the development proposals… 2.1 Meet the requirements of the Development Plan & other guidance? 9 Positive SEEDA Checklist, PPG1 2.2 Fall outside any areas designated at risk of flooding by the EA? SEEDA Checklist 9 Negative Shepway Local Plan 2.3 Fall outside sites designated for mineral supply/ waste treatment? 9 Positive SEEDA Checklist 2.4 Avoid impact on areas of high ecological value/ wildlife habitats? SEEDA Checklist, PPG1 9 Negative Shepway Local Plan 2.5 Fall outside areas of importance for archaeology/ heritage? SEEDA Checklist, PPG1 9 Positive Shepway Local Plan 2.6 Fall outside areas of high grade agricultural land? Positive SEEDA Checklist 9 Shepway Local Plan 2.7 Use brownfield land? Positive SEEDA Checklist, PPG1 9 PPG3 2.8 Release any brown field land for re-development? 9 Negative SEEDA Checklist 2.9 Reclaim any contaminated land? 9 Unknown SEEDA Checklist 2.10 Ensure appropriate treatment of contaminated land? X SEEDA Checklist 2.11 Avoid the risk of soil pollution? 9 Positive Kent Design Guide 2.12 Create an appropriate mix of uses? 9 Positive SEEDA Checklist 2.13 Include higher density and diverse uses? 9 Positive Kent Design Guide, PPG3 2.14 Include flexibility to allow for re-use of buildings over time? 9 Positive Kent Design Guide 2.15 Add quality to the environment and surrounding area? 9 Unknown Kent Design Guide 2.16 Embrace good contextual design principles? 9 Positive SEEDA Checklist

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Sustainability Assessment Criteria Issue Impact Source 2.17 Express the distinctive quality of the natural topography, existing landscape and built character of the Positive SEEDA Checklist 9 site? 2.18 Respect local architectural heritage, make optimum use of existing buildings and recognise landmark Positive SEEDA Checklist 9 buildings and features? 2.19 Ensure the protection of privacy and amenity for a variety of new and existing occupiers? X Kent Design Guide 2.20 Provide visual interest to those on foot? 9 Positive Kent Design Guide 2.21 Use both traditional and modern materials and technologies? 9 Positive Kent Design Guide 2.22 Minimise the use of intrusive and inappropriate lighting? 9 Positive SEEDA Checklist 2.23 Enhance environmental quality and sustainability through innovative solutions in building design? 9 Positive Kent Design Guide 2.24 Locate new development within or around existing built up areas, in preference to ‘greenfield’ sites Positive Shepway Local Plan 9 Integrated Regional Framework 3. TRANSPORTATION Do the development proposals… 3.1 Meet the requirements of the Local Transport Plan 9 Positive SEEDA Checklist 3.2 Enhance environmental quality and sustainability through innovative solutions in transport? 9 Unknown PPG 13, RPG 9A 3.3 Accommodate a range of transport options? 9 Positive PPG 13 3.4 Link into existing public transport networks? 9 Positive PPG 13 3.5 Bring public transport into the heart of the development? 9 Positive PPG 13 3.6 Provide viable public transport at the initial phases? 9 Positive PPG 13 3.7 Fit within an existing public transport corridor, growth point or node? 9 Positive SEEDA Checklist 3.8 If yes to above, does it have spare capacity? 9 Positive SEEDA Checklist 3.9 Provide a fixed public transport node (train, tube tram) or regular link (every 10-15 minutes) to a major Positive SEEDA Checklist 9 public transport node for 50% of the footprint? 3.10 Provide a public transport link to the city/town centre? 9 Positive SEEDA Checklist 3.11 Provide bus stops/ other public transport, enabling a regular service for 80% of the development? 9 Positive SEEDA Checklist 3.12 Include safe, direct routes for pedestrians, cyclists and the mobility impaired? 9 Negative SEEDA Checklist 3.13 Link new infrastructure for cycling, walking and riding into existing networks? 9 Negative PPG 13 3.14 Give priority to the safety of pedestrians and cyclists over cars? 9 Negative SEEDA Checklist

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Sustainability Assessment Criteria Issue Impact Source 3.15 Include speed restraint as an integral part of road design? 9 Positive SEEDA Checklist 3.16 Incorporate convenient cycle storage incorporated into properties and destinations? 9 Negative SEEDA Checklist 3.17 Balance the availability/ charging of car parking with adequate public transport? 9 Positive SEEDA Checklist 3.18 Reduce the need to travel, especially by car, and increase the attractiveness of walking, cycling and Shepway Local Plan public transport? 9 Negative Integrated Regional Framework 4. ENERGY Do the development proposals… 4.1 Incorporate energy conservation features? Positive SEEDA Checklist 9 Shepway Local Plan 4.2 Consider provision of renewable energy sources? Positive SEEDA Checklist 9 Shepway Local Plan 4.3 Include consideration of a community wide renewable energy scheme (e.g. windfarm, hydro scheme, Positive SEEDA Checklist 9 photovoltaic bank, CHP operating on biomass or waste)? 4.4 Increase energy efficiency and the proportion of energy generated from renewable resources in the Positive Integrated Regional 9 region? Framework 5. BUILDINGS AND INFRASTRUCTURE Do the development proposals… 5.1 Re-use existing buildings? SEEDA Checklist 9 Negative Shepway Local Plan 5.2 Include proposals for an evaluation of the environmental performance of the development (such as Positive SEEDA Checklist 9 BREEAM)? 5.3 Ensure that development density is appropriate to the location? 9 Positive Shepway Local Plan 5.4 Maintain and improve the character and vitality of the built environment? 9 Positive Shepway Local Plan 5.5 Promote a high quality of design? 9 Positive Shepway Local Plan 6. NATURAL RESOURCES Do the development proposals… 6.1 Include provision for environmentally sustainable construction materials? 9 Positive SEEDA Checklist 6.2 Prevent the inefficient use of materials onsite by adopting the protocol of reduce, re-use and recycle? 9 Positive SEEDA Checklist

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Sustainability Assessment Criteria Issue Impact Source Shepway Local Plan Integrated Regional Framework 6.3 Maintain and improve the water quality of the region’s rivers and coasts and achieve sustainable water Positive Integrated Regional 9 resources management? Framework 6.4 Provide opportunities for the protection of water supplies by harnessing rainfall? 9 Positive SEEDA Checklist 6.5 Include a range of water-efficient appliances and systems to reduce water usage? 9 Positive Kent Design Guide 6.6 Protect the quality of water resources by appropriate treatment of sewage and runoff, and through use of SEEDA Checklist 9 Negative reedbeds where practical? 6.7 Minimise and mitigate any sources of water contamination? 9 Positive SEEDA Checklist 6.8 Prevent negative impacts on coastal protection, flood defence, land drainage and groundwater resources? 9 Unknown Shepway Local Plan 6.9 Minimise negative impacts on air quality and the release of CO ? Kent & Medway Structure 2 9 Negative Plan 6.10 Incorporate “green” screens? 9 Unknown SEEDA Checklist 6.11 Minimise and mitigate any sources of air contamination in or close to the development site? 9 Positive SEEDA Checklist 6.12 Reduce the global, social and environmental impact of consumption of resources by using sustainably Positive Integrated Regional 9 produced and local products? Framework 6.13 Reduce waste generation and disposal, and achieve the sustainable management of waste? Positive Integrated Regional 9 Framework 7. ECOLOGY Do the development proposals… 7.1 Include a baseline survey of species, habitat and significant natural features? 9 Positive SEEDA Checklist 7.2 Conserve and enhance the regions biodiversity Unknown Integrated Regional 9 Framework 7.3 Protect and enhance designated or proposed sites of international, national, countywide and local Unknown Shepway Local Plan 9 importance; and plant or animal life protected by law? 7.4 Include consultation of the Local Biodiversity Action Plan? 9 Positive SEEDA Checklist 7.5 Recognise the value of open space, landscape and nature conservation? Positive SEEDA Checklist 9 Shepway Local Plan 7.6 Include measures for the protection of sensitive sites & natural features? 9 Positive SEEDA Checklist

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Sustainability Assessment Criteria Issue Impact Source 7.7 Identify appropriate mitigation measures to address the impact of a development and to compensate for Positive Kent Design Guide 9 lost habitats and landscape features? 7.8 Contribute towards the creation of a network of open space and promote accessibility from residential and SEEDA Checklist X commercial areas to green space? 8. COMMUNITY Do the development proposals… 8.1 Have the support of the local community? 9 Unknown SEEDA Checklist 8.2 Include a continuing programme of community involvement in the development plans? 9 Positive SEEDA Checklist 8.3 Provide clear distinction between public and private space? X Kent Design Guide 8.4 Incorporate shared areas to encourage walking, cycling and socialising and to enhance safety and Kent Design Guide X security? 8.5 Encourage self-policing and offer surveillance of property? X SEEDA Checklist 8.6 Encourage a sense of ownership through the quality of the public realm? X Kent Design Guide 8.7 Conform to the latest safety and security advice? 9 Positive SEEDA Checklist 8.8 Provide an appropriate level of lighting to enhance safety and security? 9 Positive SEEDA Checklist 8.9 Meet the needs of people with disabilities? 9 Positive Kent Design Guide 8.10 Safeguard and enhance the amenity of residents 9 Positive Shepway Local Plan 8.11 Ensure that everyone has the opportunity to live in a decent, sustainably constructed and affordable Integrated Regional X home? Framework 8.12 Reduce the risk of flooding and the resulting detriment to public well-being, the economy and the Unknown Integrated Regional 9 environment? Framework 8.13 Improve the health and well-being of the population and reduce inequalities with health? Unknown Integrated Regional 9 Framework 8.14 Reduce poverty and social exclusion and close the gap between the most deprived areas in the South Positive Integrated Regional 9 East and the rest of the region? Framework 8.15 Raise educational achievement levels across the region and develop the opportunities for everyone to Positive Integrated Regional 9 acquire the skills needed to find and remain in work? Framework 8.16 Reduce crime and the fear of crime? Integrated Regional X Framework 8.17 Create and sustain vibrant communities? Integrated Regional X Framework

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Sustainability Assessment Criteria Issue Impact Source 8.18 Improve accessibility to all services and facilities? Integrated Regional 9 Positive Framework 8.19 Encourage increased engagement in cultural activity across all sections of the community in the South Integrated Regional X East? Framework 9. BUSINESS Do the development proposals… 9.1 Meet the general requirements of the economic strategy? 9 Positive SEEDA Checklist RES 9.2 Attract inward investment? 9 Positive SEEDA Checklist RES 9.3 Result in increased viability of existing businesses and public transport? Positive SEEDA Checklist RES PPG 9 13 9.4 Create permanent jobs? Positive SEEDA Checklist RES 9 Integrated Regional Framework 9.5 Sustain economic growth and competitiveness across the region? Positive Integrated Regional 9 Framework 9.6 Stimulate economic revival in priority regeneration areas? Positive Integrated Regional 9 Framework 9.7 Develop a dynamic, diverse and knowledge-base economy that excels in innovation with higher value, Positive Integrated Regional 9 lower impact activities? Framework 9.8 Encourage the development of a buoyant sustainable tourism sector? Positive Integrated Regional 9 Framework 9.9 Develop and maintain a skilled workforce to support long-term competitiveness of the region? Positive Integrated Regional 9 Framework

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CHAPTER 19

CUMULATIVE IMPACTS

CHAPTER 19 LAA

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19 CUMULATIVE IMPACTS

19.1 Introduction

19.1.1 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.

19.1.2 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.

19.2 Legislative Drivers

19.2.1 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.

19.2.2 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.

19.3 Assessment Methodology

19.3.1 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.

19.3.2 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 19.3.3 In assessing the magnitude of potential cumulative impacts, the definitions shown in Table 19.1 below have been used.

Table 19.1 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

19.3.4 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.

19.3.5 Given the localised and temporary nature of construction works, and the ability of mitigation measures to be generally implemented to avoid, reduce or minimise the magnitude of any such effects, cumulative impacts of such activities have also generally not been assessed here. 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.

19.3.6 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.

19.3.7 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.

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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19.4 Assessment of Cumulative Effects

19.4.1 The key sensitive receptors that have been identified within the ES are shown in Table 19.2 below:

Table 19.2 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.

19.4.2 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 19.3 overleaf. Local mineral workings4 are listed in Table 19.4 below.

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 19.4 Permitted and Proposed Mineral extractions within 4km of LAA

Site Name Approximate Site Name Approximate distance distance from from LAA LAA (km) Existing Planning Permissions New Proposals Allens Bank Quarry 900m Denge Pit 2.4 Land east of Denge Lane (Part) 1.3km Land north west of Jurys 3.2 South Gap Road Land adjacent to Whitehall Farm 1.6km Scotney Court Quarry 3.4 Land east of Denge Lane (Part) 2.3km Land west of Tourney Hall 3.5 West Land east of Denge Lane (Part) 2.4km North Land north east of Dering Farm 2.7km

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Table 19.3 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.

Mineral extraction occurs in the immediate vicinity of the airport and in the surrounding area. Permitted and proposed extractions Local mineral extraction activities located within a 4km radius of LAA are shown in Table 19.4.

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.

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LAA Proposed Runway A runway extension is also being proposed for LAA and is subject to a separate planning application. The construction phase of Extension the runway extension is planned for some time in 2007 and is expected to take approximately 4 months.

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19.4.3 Given these proposed projects, a number of potential areas of cumulative impact have been identified as shown in Table 19.5 below.

Table 19.5 Potential Areas of Cumulative Impact Little Mineral Golf LAA Receptors Dungeness A Cheyne Extractions Club Runway Hotel Water Resources XX ~ XXX X X Ground Conditions ~ ~ XXX ~ X Land Use ~ XX ~ X ~ Ecology & Nature ~ XX X X X Conservation Landscape & 999 XXX XXX X ~ Visual Amenity Cultural Heritage & Historic ~ ~ XX ~ ~ Environment Traffic & Transport XXX ~ XX X X Air Quality XX 99 X X X Noise and Vibration XX XX XX X X Socio-Economic XX 99 99 9 999

Key Nature of Impact 9 Beneficial X Adverse ~ Negligible Potential Magnitude 999 / XXX Major 9 9 / XX Moderate 9 / X Minor

19.4.4 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

• Socio-economic. 19.4.5 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 LAA5 and indeed PPS 22 on Renewable Energy (2004) make the specific statement with respect to wind farm

5 Wind Energy, Defence and Civil Aviation Interests Working Group, (2002) Wind Energy and Aviation Interests- Interim Guidelines

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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

19.4.6 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 runoff to drains and directly to the ground and alteration of drainage channels from the proposed runway extension.

19.4.7 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

19.4.8 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;

• Local Mineral Extractions – disturbance and local habitat loss. Positive impacts for birds if new waterbodies are generated within the pits;

• impacts on water flora/fauna along drains affected by the proposed runway extension, impacts on bird life from aircraft movements. 19.4.9 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

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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

19.4.10 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;

19.4.11 No increased vehicle movements are expected as a result of the proposed runway extension at LAA, over and above those used as part of the “Do minimum” calculations in this report.

19.4.12 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 impact assessment 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

19.4.13 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 and Vibration

19.4.14 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.

Socio-economic

19.4.15 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.

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19.5 Summary

19.5.1 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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MITIGATION TABLES

CHAPTER 20 LAA CONSTRUCTION MITIGATION TABLES TERMINAL BUILDING ES

Table 20.1 - 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 contractor which will include Management General both works method statements and risk tables to manage the key environmental risks outlined in the ES. The plans will meet the requirements of all relevant Plans legislation, including that outlined below. 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 instruction on issues such General Training 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 the Construction (Health, Safety and Health and General Welfare) Regulations. It will specifically require all works to be properly barriered off and adequate signage installed to indicate appropriate Personal Safety 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 description of sediments encountered. In addition a single deep Ground Conditions Geomorphology 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.

Pre-commencement site investigations will be agreed with the regulatory authorities, targeted to those areas where contamination could be most likely Existing Land encountered. Should any potentially contaminated land be encountered, it will be analysed for the presence of hazardous materials and an appropriate Ground Conditions Contamination remediation strategy agreed with the regulators before construction works commence. In 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 couplings to be located within the Ground Conditions Spill Prevention 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 contractor prior to Surface Water Water Resources commencement of works. These will prevent erosion of any exposed substrates and/or sediment laden or contaminated water draining offsite into adjacent Drainage controlled waters (eg through the use of treatment/detention ponds).

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 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;

Water Resources Water Quality • 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;

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

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• 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, 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 Management The CEMP will include measures to control waste production, based on the Department of Trade and Industry (DTI) voluntary code of practice. Management Plans

Solid Waste Spoil An exemption will be sought from the Environment Agency under Paragraph 19A, Schedule 3, to the Waste Management Licensing Regulations 1994 (as Management Management 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 area will be Land Use Access 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 oil or other petroleum- Ecology Management based products. Areas outside the footprint will be fenced off to prevent unauthorised access by site plant or personnel, and vehicle movement will be Plans confined to existing roads and access tracks.

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Works will be scheduled wherever possible to avoid the various species’ periods of particular vulnerability. For example vegetation clearance will only be Timing of Ecology done outside the bird nesting season, works in areas of suitable reptile habitat would be undertaken during the summer months, when reptiles are active Works (rather than during the hibernation period) and maintenance work will be undertaken outside of the water shrew-breeding season (which is April-September).

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 impacted by the works would be subject to Ecology Reptiles 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.

Bird Conservation No significant impacts are expected to arise from construction works. General & Hazard

Cultural Heritage Watching Brief An archaeological watching brief will be developed for earthmoving works in accordance with the requirements of PPG 16 and the Local Plan Policy.

A programme of environmental soil sampling will be undertaken to investigate palaeo-environmental and marsh formation deposits as described under Cultural Heritage Geomorphology “Ground Conditions” above.

Landscape & No significant impacts are expected to arise from construction works. General Visual Impact

Construction An agreed route and schedule for construction vehicles will be set up in agreement with Shepway District Council in order to reduce the level of disruption on Traffic Traffic 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. Dust Any stockpiles will also be sheeted, contained within wind barriers or damped down. Vehicles removing demolition or site clearance materials will have their Air Quality Management loads sheeted on all sides. Crushing of material for reuse, 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.

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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 competent person on a weekly basis. If dry windy weather prevails Air Quality Dust Monitoring 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 where practical.

Hardstanding areas for vehicles entering, parking and leaving the site will be provided, with wheel washing facilities at access points. Site roads will be Site Roads and Air Quality cleaned regularly and damped down if necessary. Site vehicle movements will be kept to a minimum and, where possible, restricted to paved haulage routes. Haulage 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 working hours and noise Noise & Vibration hours limits will be agreed between the Contractor and Local Authority.

Specific method statements and risk assessments will be required for night working and the contractor will inform and agree any works in advance with the Non-normal Noise & Vibration 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 working hours 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 sealed acoustic covers which will be kept closed Plant & vehicle Noise & Vibration 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 maintenance 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 20.2 - Key Mitigation for Operational Phase Impacts

Area Aspect Mitigation Environmental The airport will produce an Environmental Management Plan (EMP) based on the ISO14001 standards. Management General All staff that work in the airport will undergo appropriate environmental training, including emergency spill response. The EMP will outline the training Training requirements in more detail.

Ground Conditions Geomorphology No mitigation measures are required for the operational phase of the terminal development. Drains within the airport boundary owned by the airport will be maintained by LAA (in consultation with the IDB) to ensure that there are no obstructions Internal Water Resources to drainage or reduced storage volumes which could cause localised flooding, and that adequate water storage is present throughout the system. LAA Drainage will monitor these facilities to ensure they remain effective. External Drains outside the airport boundary are owned by the IDB which undertakes annual maintenance of these drains to ensure they maintain their drainage Water Resources Drainage capacity and efficiency. LAA will assist the IDB in this process as required. Given LAA’s location within an area potentially subject to flooding, the terminal building has been designed to avoid and minimise the significance of any such flooding events. In particular, the types of building material used have been chosen for their capacity to prevent or reduce the risk of structural Water Resources Flood Risk damage should flooding occur, whilst electrical services have been designed at a sufficient height to allow for their safe function and maintenance under such conditions. Refer to FRA for further mitigation measures. Spill The EMP will include spill prevention procedures and risk control measures to avoid contaminants entering watercourses. Such measures will be Water Resources Management agreed with the EA, IDB and NE. The existing terminal has adequate water and sewage resources for handling 300k passengers, and is understood to have spare capacity to take this to Water Resources Sewage & Water 500k passengers. Long-term options are also currently under consideration for connections to the sewer mains and/or installation of an on-site sewage treatment plant, although this is not required at this 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 Higher volumes of air traffic at the site will undoubtedly lead to an increase in maintenance and associated waste streams. Special arrangements will Solid Waste Maintenance be made for the disposal of hazardous wastes, with particular attention given to the appropriate management of rubber from aeroplane tyres and oily Management contaminated materials. The airport will work closely with local landowners and the Local Authorities to discourage local land use practices which encourage bird strike species Land Use General or 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 habitat Biodiversity Ecology management initiatives to provide nature conservation benefits. The plan will include both habitat and species specific actions and would Action Plan 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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Ecological Key elements of the existing system of ecological monitoring and management will continue to be undertaken following consultation with the Ecology Monitoring relevant consultees.

Habitat suitability for reptiles, invertebrates and small mammals will be encouraged in locations away from the operational areas of the site. Measures Species-specific Ecology to conserve protected species will be developed and activities likely to affect such species will only be carried out under licence and at appropriate times measures 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 EA, Aquatic habitat Ecology using appropriate management such as those outlined below. management

LAA will work with NE and the RSPB to develop appropriate methods to ensure that the ornithological value of the area is retained (and where possible Bird Conservation & Wintering Birds enhanced) as a result of the proposed project. As part of this, LAA propose to fund a research study to further assess the potential for air traffic to Hazard Management Mitigation disturb wintering (and breeding) birds, in the area.

Bird Conservation & Wintering Birds A series of wintering bird monitoring surveys will be undertaken by the airport, using, as a minimum, the same methodology as the field survey used in Hazard Management Monitoring 2005/06, for a minimum of ten years.

Bird Conservation & Breeding Birds LAA will work with NE and RSPB to develop an ‘airfield biodiversity action plan’, which will be designed in conjunction with the birdstrike hazard Hazard Management Mitigation (BAP) management plans, to ensure that those species not constituting a birdstrike hazard are able to continue breeding within and around the airfield.

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 ten years, with Hazard Management (monitoring) the study outcome compared to the 2006 baseline.

Bird Conservation & A regular monitoring programme of the effectiveness of bird control will be maintained as part of the bird hazard control programme. The results of this Bird Hazard Hazard Management will be used to manage appropriate change in conjunction with the airfield BAP.

Bird Conservation & LAA will review their safeguarding approach, in consultation with NE and the RSPB, to ensure that a balance is met between recognising the Safeguarding Hazard Management importance of the wetland habitat around the airport for bird conservation and the need to minimise bird strike hazard.

Landscape Visual General There are no mitigation measurements required. Amenity

Cultural Heritage General There are no mitigation measurements required. LAA will develop a Travel Plan to encourage the use of sustainable modes of transport for both passengers and staff and reduce the reliance on private cars. The use of sustainable transport options for travel to and from the site will be Traffic & Transport Travel Plan promoted. A financial contribution will be given local bus services to extend routes in to the airport and provided there is a financial case and is a viable option, LAA would consider providing a dedicated shuttle bus service to connect the Airport with Ashford International Station.

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Hammonds LAA will work with the local authorities to develop an appropriate upgrade to the Hammonds Corner ‘t-junction’ (eg through the development of a Traffic & Transport Corner roundabout or 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 & Transport Signage Brenzett junction encouraging all traffic to travel to the airport via the A259 and the B2075. All travel information for passengers using LAA will identify the preferred route as well as suggesting public transport alternatives. 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 idling; Air Quality and increasing efficiency of use of aircraft support vehicle. Aircraft will also be encouraged to operate in the most fuel efficient manner Air Management 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 & Vibration ‘balanced approach’ to managing aircraft noise (as outlined Directive EC/2002/30). This will balance the needs of the airport with the Management concerns of the local affected residents, through the use of a range of mitigation measures including those outlined below. The airport operators will introduce noise-abatement operating procedures such as a penalty system to fine pilots using Landing / Noise & Vibration Departure Noise excessive thrust 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 due Noise & Vibration Ground Noise to taxiing aircraft, engine testing and other sources of ground noise. The requirement for Noise Abatement Zones (in which there are restrictions on ground activity) will be reviewed. The airport will establish clear lines of communication with local residents, such that concerns regarding noise from airport operations can Noise & Vibration Communication be addressed, in the first instance, directly to the airport. LAA will provide permanent external noise monitoring stations, in order to quantify and monitor noise levels close to the nearest affected Noise & Vibration Noise Monitoring 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. Socio-Economic Employment Employment impacts associated with each scenario are all positive, and therefore require no mitigation.

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