MEDWAY COUNCIL'S RESPONSE TO:

THE FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UNITED KINGDOM - A NATIONAL CONSULTATION

NOVEMBER 2002

  1. INTRODUCTION
    1. Medway Council wishes to emphasise that it welcomes the Government's Consultation on the future of air transport and fully recognises the need to plan positively for the long term.
    2. Although the Council's area is directly affected by one of the options (Cliffe) it has sought to take an objective and positive approach to its evaluation of all of the options and arising from this recommend a specific way forward to Government.
    3. The response is based on extensive research undertaken both directly by the Council and by its consultants. It also reflects a detailed examination of all the South East and East of England Regional Airports Study (SERAS) source material.
    4. The response deals with all the major topics identified in the consultation and puts forward a number of additional points, that the Council considers should be considered fully by the Government in formulating its forthcoming white paper.
    5. The response reflects the key issues raised and debated during a wide ranging and structured public consultation programme.

  2. FORMAT
    1. The submission deals with all the major questions raised in SERAS, grouped under a number of self-explanatory headings. In the interests of brevity, appropriate cross-references to source material or specific evidence are included, rather than the use of extensive quotes from them.
    2. The conclusions set out below draw from a very wide range of sources, including:
      • Detailed technical studies produced by: MVA and associated consultants for Medway Council; Mott Macdonald & associated consultants for Kent County Council; Roger Tym & Partners, consultants to SEERA; and TRL, consultants to English Nature, the Royal Society for the Protection of Birds (RSPB) and others.
      • Direct discussions with key industry players, including BAA and BA, together with a poll of major airlines.
      • Special interest groups, including SASIG.
      • Government agencies including the Environment Agency, English Nature, English Heritage and the Health and Safety Executive.
      • A structured opinion poll of Medway residents and businesses.
      • A range of balanced public debates including with the local Chamber of Commerce, The More to Medway local strategic partnership, the Kent and Medway Economic Board and a range of other local bodies.
      • A detailed audit of the Cliffe site and its surroundings, undertaken by the Council.
    3. In addition to assisting the Government in its considerations, this response has also been formatted to allow its distribution to a wide range of interested parties and to allow for its publication on the web and CD-Rom.

  3. OVERALL AVIATION STRATEGY
    1. The Council firmly believes that aviation, while important in its own right, must be considered as one component of a national transport strategy. It cannot and should not function in isolation from other transport modes, but rather developed as one component of an integrated transport system for the nation, that is relevant to its users, acceptable to the public at large and provides a robust framework for investment decisions. Mainland Britain is a relatively small and densely populated island within which major airport development has profound local impacts.
    2. The starting point for meeting future needs must be an assessment of future demand, and the Council and its advisors have given due regard to the air traffic forecasts which underpin the consultation. It has concluded that the headline forecasts for 2030 (500 mppa for the UK and 300 mppa for the South East) provide the best available forecast of unconstrained demand. However, it notes the inherent problems of forecasting over such a long time horizon and concludes that this can only be a starting point in determining what provision should be made.
    3. Three factors in particular are considered important in this context. The first is the considerable uncertainty throughout the aviation industry of what the future holds. This is amply illustrated by the recent consolidation of capacity and routes by the major flag carriers on the one hand and the growth of new point-to-point services by low cost airlines on the other. The second is that, despite technological improvements, aviation is the most polluting form of transport by a considerable margin. This manifests itself in a global context in the form of greenhouse gas emissions, and in a local context through severe noise and air pollution in and around airport developments. Third is the increasingly dominant view that despite the global nature of the market, the aviation industry will be forced to adapt to a new fiscal regime, that reflects internal costs and environmental effects properly.
    4. Taking all these factors into account it is considered the Government should adopt a demand management strategy for aviation as opposed to the traditional 'predict and provide' approach implied by the unconstrained demand forecasts. Such a demand management strategy must balance the need to maintain international competitiveness with environmental responsibility and the ability to absorb new airport capacity and associated surface access systems within densely populated areas. A cautious but realistic approach is required and the Council has concluded that a target capacity of 250 million passengers per annum within the SERAS region in 2030 would be most appropriate.
    5. The demand management strategy should be coupled with a functional national airport system and a robust air traffic control regime. Regional needs should then be assessed in the context of the agreed national framework.
    6. Proposals for the major expansion of existing sites or the development of new sites should also be accompanied by appropriate noise and pollution caps and comprehensive multi-modal surface access strategies, at least at a sub regional scale. At the same time Government should commit itself to actively pursuing international agreements and fiscal regimes which aim to reduce local environmental impact and which do not place individual operators at a disadvantage.
    7. It is further considered that Government should adopt a long-term strategy which is renewable and can be adapted in the light of changing circumstances; for example major changes in previously forecast demand.

  4. HUB AIRPORTS
    1. Against the background of the current and likely future operation of existing airports the Council finds no case for a new purpose built hub airport in the south east:
      • Britain has attained a leading position in the aviation market without such a facility;
      • Heathrow (30% of traffic) and Gatwick (20% of traffic) already function as partial hubs. Three airports serving one city with substantial hub capability would dilute the viability of each and create confusion in the market;
      • Pure hub airports are intrinsically inefficient and could not therefore compete with sites offering mixed operations in terms of capacity utilisation or revenue costs;
      • Any business case has been reduced by the decline in passengers carried by the major airlines and the corresponding growth in low cost operators offering solely point to point services;
      • The long term development of a hub capability may be an option at Stansted but this would necessitate a corresponding downgrading of either Gatwick or Heathrow. Developing a new site (such as Cliffe) would mean an even more robust policy of decline, at Heathrow in particular, and would result in an overly complex London system. It would not be financially viable (see elsewhere in this submission);
      • A positive policy of decline at Heathrow to enable a new hub to succeed would result in loss of jobs and business connections in the most buoyant area of the South East and create increased commuting on the M25 as jobs are displaced;
      • 'Seeding' a new hub location is not practical in a south east context. Neither airline alliance (Oneworld or Star) wants to relocate, and direct intervention would be contrary to domestic and EU competition regulations and international bilateral agreements;
      • Hubs are primarily an American concept, wholly unsuited to the geography of Britain; Schiphol and Frankfurt are single site city airports and Paris Charles De Gaule only achieved partial success that required the closure of Le Beugeot and pressure on the Government owned flight carrier;
      • Where hubs have been developed in locally competitive environments, they have failed, the most striking example being Montreal (Mirabel).

  5. FUTURE CAPACITY AND PATTERN OF PROVISION FOR THE SOUTH EAST
    1. Subject to determining a national airports structure and establishing an overall capacity level, a logical airport system for London must be determined. Only after this has been done can the needs of the rest of the SERAS region be properly addressed.
    2. It follows that Government must give a clear and unequivocal view on the future of Heathrow - not only in terms of its capacity but also its function. This is due to its current pivotal role in a national and local context.
    3. All available evidence points to a strong business case for further expansion at Heathrow, but it is also quite clear that there would be serious environmental and social implications if this were allowed. Should a cap be placed on its undoubted success and if so what would the implications of that be? It is considered that continued expansion over the long term to meet continuing demand, is simply not practical in view of its physical constraints. Therefore, sooner or later, it has to be accepted that its pre-eminent role will have to be questioned. A fundamental decision to be made is whether that should occur now or at a later date.
    4. On balance, a strategy that allows more efficient operation but does not extend basic runway capacity is considered appropriate. This implies phased increases in capacity at Gatwick and/or Stansted. This would not threaten Heathrow's role in the short term and it would allow both operators and airlines to start to adjust their long-term investment plans. Above all, uncertainty over Heathrow's future role should be minimised.
    5. Gatwick is currently the sixth busiest airport in the world and the second airport in the SERAS region. It serves more destinations than Heathrow, albeit at less frequency. It also has an extensive area of influence, underpinning the economy of towns such as Crawley, and towns along the south coast, including Brighton. Its influence extends into Kent.
    6. The business case (see SERAS stage 2 options) for expansion of Gatwick is excellent and a number of alternatives are available. The Redhill option is not dependent on the legal agreement between BAA and West Sussex County Council.
    7. If Gatwick capacity is capped at around its existing level and significant capacity is added at other sites, its current role will be threatened with likely disinvestment in the medium to long term. This is not considered to be a reasonable strategy for such a well-established and high capacity facility.
    8. Accordingly, the provision of a further runway at Gatwick is recommended as part of a balanced response to meeting future capacity in the South East.
    9. Stansted has the greatest potential to match capacity to actual demand. Even if it were planned to meet the non-constrained demand forecasts, capacity could be increased incrementally. An efficient demand response can only be achieved by adding capacity when it is required. Stansted is best placed to do this.
    10. Cliffe by comparison would have a very long lead-time and would involve commitment to a massive increase in capacity at one date. If for any reason that demand was not realised (and considerable doubt exists - see later in this document) it could have the most profound implications for the viability of the project.
    11. The case for limited expansion at Luton as set out in SERAS is accepted on the basis that:
      • It is an already established facility
      • It is well related to the South East catchment
      • The capacity proposed would mean that it would not be a direct rival to Heathrow, Gatwick or Stansted.
    12. Taking all relevant factors into account the Council therefore commends the following strategy for the SERAS region:
      • Capacity: Acceptance now of a positive policy of demand management through the adoption of a planned capacity limit for the South East of 250 mppa recognising the environmental cost of air travel.
      • Heathrow: No further runway provision but adoption of a regime that encourages continuing investment in the existing capacity to maximise efficiency and maintain competitiveness over the long term.
      • Gatwick: The provision of a further runway to avoid future disinvestment and reflect the exceptionally strong business case for this location.
      • Stansted: Provision of one further runway with a review after ten years to determine the case for a third runway in the long term.
      • Luton: Limited growth in accordance with the maximum use scenario as set out in SERAS.
    13. This would easily and flexibly meet a limited constraint capacity of 250 mppa and allow a planned response to higher demand levels should these be justified in the longer term.

      Recommended option Total capacity provided Total demand forecast
      Maximum use of existing capacity option plus Gatwick + 1 wide spaced runway(2011) plus Stansted + 1 runway (2018) 285mppa 255mppa

    14. It follows from the above that there is simply no case for the development of any new high capacity airport.
    15. The council would further urge the Government to commit to a comprehensive surface access strategy for all four airports listed above, to ensure their efficient operation in the future and that they meet the needs of the region as a whole.
    16. In a Thames Gateway context, this implies a strong case for a multi-modal Lower Thames Crossing with associated rail investment to provide direct links to both Stansted and Gatwick. Not only would this directly benefit the Gateway, but it would also relieve London of significant volumes of unnecessary transit traffic.

  6. ADDITIONAL NOTE ON NEW AIRPORTS
    1. The Council wishes to emphasise that it is not against the principle of new airports, but its extensive research leads to the following firm conclusions:
      • The often expressed 'estuary model' for new airport locations simply does not stand up in practice. Estuarine locations of which Cliffe is an example have a poor relationship to catchment populations, present the highest conflicts with nature conservation interests, pose the highest bird strike risk and are the most technically difficult (and costly) to service adequately with road and rail links. Shoreline or island options also have a tendency towards markedly higher construction costs than inland alternatives.
      • Within the South East regard must also be had to the fact that London already supports four 'primary' airports plus one 'first tier' airport (London City). The wider region supports a further two first tier airports and seven second tier airports. Further additional sites (such as Farnborough) cater for business general aviation. The overall system is therefore already highly complex and the effects of this are exacerbated by the comparatively small geographical size of the region and its dispersed population structure. This has obvious implications for air traffic control management and the resident population. Adding a further large site to this already volatile mix, therefore cannot make sense.

  7. CLIFFE: IS THERE A BUSINESS CASE
    1. The development of a new four runway airport at Cliffe would:
      • Be the largest single project of its type ever attempted in Britain, even exceeding the new Hong Kong airport in scale (which was based on the closure of the existing airport);
      • Propose achieving an initial market share of 30mppa from the first day of opening, rising to 58mppa within four years;
      • Due to its location, the geology of the site, the many pinch points on the road and rail networks to which new links from the site would have to connect, and the scale and intensity of construction activity required, it would significantly eclipse both the Channel Tunnel and the CTRL in engineering scale and complexity;
      • Be designed to achieve a passenger throughput of 110mppa within fifteen years. By comparison Heathrow has taken fifty years to reach 65mppa.

      With these points in mind is there a viable business case for the airport? The Council doubts this firmly.

    2. In assessing this the Council has looked at a number of key aspects and its findings are as follows.
    3. Capital cost: At SERAS stage 2 the total cost was estimated at £13.3 billion but in the final consultation document this reduces to £11.5 billion. Other than the exclusion of the Lower Thames Crossing (£0.75 billion) the reasons for this are not explained. Initial checks indicate that even the £13.3 billion was under-estimated and the true costs of the works as defined in SERAS would be nearer £16.1 billion.
    4. This is still considered an under-estimate because:
      • There are no current plans to have the Lower Thames Crossing constructed for the opening year and no financing has been identified;
      • Both local links to the site and capacity improvements required to road and rail networks north and south of the Thames have been under-estimated;
      • The anticipated capacity expected to be provided by CTRL is totally un-realistic, requiring the shortfall to be made up in other ways - at additional cost;
      • SERAS assumes a balanced cut and fill approach to development, whereas there would be a significant shortfall in material.
      • No evidence has been found by the Council as a result of enquiries of any private sector interest in financing or promoting a new airport at Cliffe.
    5. Logistics: There is no realistic chance of a 2 runway facility being available in 2011 as anticipated in SERAS. But, even with an opening year of 2018 the following pre-conditions would have to apply:
      • Simultaneous construction of all surface access improvements. This would place an unprecedented strain on the European construction sector; and require the highest level of co-ordination bearing in mind that all existing surface routes would have to remain open throughout the construction phase.
      • At the very least, conditional contracts with a number of airlines and one alliance to re-locate on opening day. Without guaranteed business no investor could start to consider backing the project.
      • A harsh charging regime at competitor airports.
      • Financial guarantees provided by Government. It is simply unrealistic to expect the required level of private investment in the absence of firm and significant public financial underwriting in view of the lead time, uncertainty over transferring business, the need to align so many surface access projects and the front loading involved.
    6. Market demand: Despite extensive investigations, no evidence has been found of any interest amongst airlines in transferring operations to Cliffe. There appear to be two prime reasons for this:
      • The pre-eminent rôle of Heathrow. No current occupier will yield capacity to a rival;
      • All parts of the industry freely express uncertainty about the future. For this reason they require a low risk, incremental strategy to meeting future demand. This means the Government should opt for manageable levels of investment in existing sites and the gradual introduction of new capacity.
    7. Seeding: SERAS accepts that for Cliffe to function at a viable level, 40% of Heathrow's scheduled services, 23% of Gatwick's charter services and 11% of Stansted's low cost services would have to transfer at the commencement of operations. Yet it also states that "the current regulatory environment would be unlikely to facilitate the movement of carriers to a new airport..." What it does not do is state how a new regulatory regime could be introduced or how it could work. A number of possible measures are floated but they are not defined or backed by a business case which would allow airlines to assess the implications. This is not surprising since domestic competition, EU regulations and international agreements would appear to rule out the level of control which would be required.
    8. Legal and procedural uncertainty: The location of Cliffe and its complexity as a project pose additional legal and procedural uncertainties which impact directly on the business case. In summary these are:
      • The inevitability of an extended legal battle through both the British and European courts, due to the impact on areas of nature conservation which are supposed to be afforded the highest level of protection. This will occur whichever method of promotion is followed, either by the Government or a private promoter. The challenge will come from a number of parties and extend over an unknown timeframe.
      • The potential for legal challenges over any seeding arrangements as this will impact directly on both existing site operators and airlines.
      • Uncertainties over the project planning process itself. Aside from the complexity of construction on the site there will be a need for numerous off-site packages to deliver the required standard of surface access. Many of these will require compulsory purchase and a variety of consents, which are unlikely to be covered in one over-arching hybrid bill or other consent process. At best it is estimated it would take at least 15 years to get from an initial decision to proceed to first opening. It is difficult to see how such a lead-time would be acceptable to commercial funding institutions.
      • Even if the legal hurdles surrounding the nature conservation sites can be overcome there will still be a requirement to put full mitigation in place. Not only is this required on a large and unprecedented scale, but the intended results cannot be guaranteed beforehand. It could take many years before an adequate standard of replacement could be demonstrated. In turn this is highly likely to delay the start of construction. The timetable for the project as a whole is hugely complex and on any reasonable estimate Cliffe could not be operating until 2018 at the earliest.
    9. Taking all these factors into account it is concluded that there is no viable business case for a new airport at Cliffe.

  8. CLIFFE: ECONOMIC AND URBANISATION IMPACTS
    1. Cliffe is located within the Thames Gateway and SERAS argues the development of a new airport would realise some of the Gateway's economic objectives and could be accommodated without further urbanisation beyond that already planned.
    2. In fact, while the Thames Gateway strategy (set out in the Thames Gateway Planning Framework—RPG9a), commits the area to high levels of growth over a 30 year period, this is critically balanced by protection for important natural assets in order to achieve a sustainable form of regeneration and growth. In this context the Hoo Peninsula is specifically highlighted because of its unique landscape and its extensive network of nature conservation sites of the highest national and international importance. Detailed work has therefore been carried out to check the assumptions made in SERAS.
    3. The detailed findings can be found in the forecasting work undertaken by SQW for Medway Council and PACEC for Kent County Council. In summary the studies forecast total employment as a result of the airport of 99,000 and 98,000 respectively, each using different techniques. This gives a high level of confidence in the results. This compares to a figure of 79,000 in SERAS.
    4. With no airport, employment in the Kent & Medway Structure Plan Area is forecast to increase by 117,000, including the exceptional effect expected from major Thames Gateway sites such as Ebbsfleet. Of these jobs 14,000 would be located in Medway.
    5. The airport would add another 98,000 jobs to this figure giving a total of 215,000. 71,000 of these would be located in Medway.
    6. With no airport, SERAS assumes that new dwellings will be built in the airport catchment at the rate suggested in regional planning guidance for Kent of 5,700 per year. If this were assumed for the structure plan area (Medway plus KCC area) there would be 177,000 new dwellings.
    7. In order to maintain labour supply for the airport and the local economy an additional 79,000 - 112,000 dwellings would be needed, giving a total dwelling need of 256,000 - 289,000 over 30 years. The lower end of this range assumes some increase in activity rates and reduced out commuting, thus reducing the need for new dwellings.
    8. For Medway this creates the following pressures:
      • 85,000 jobs growth (most of this is "fixed" i.e. jobs within the airport)
      • Between 99,000 and 109,000 additional dwellings
      To put this into context, Medway (the largest urban area in the South East outside London) currently has a dwelling stock of 133,000. Therefore, if it were physically possible to accommodate this pressure locally it would require between 87.6% and 96.5% physical growth over 30 years.
    9. In reality the whole Medway administrative area has nowhere near the physical, nor environmental capacity to accommodate this scale of development. An assessment made with only the retention of national restraint areas (AONB's, green belt and national nature conservation sites) shows that around 25,000 additional dwellings could be physically fitted within the administrative area. This figure takes no account of normal planning considerations or the availability of services. However, it does assume an ability to develop on the southern half of the Hoo Peninsula, whereas the SERAS appraisal carried out by Arup's states that this is not practicable.
    10. Moreover, it needs to be appreciated that, if the Medway area and North Kent is to accommodate the currently planned regional growth figures extrapolated over 30 years, then this scale of development will have occurred in any event, leaving no local capacity to absorb additional demands for employment and housing pressures that would arise from an airport.
    11. The implication therefore is that virtually all the airport generated development pressure would be displaced to other areas, notably Kent and Essex in the first instance. In turn this means longer commuter trips on an inherently unsustainable development pattern. It also means large scale development in areas hitherto protected locally and regionally.
    12. The success of the Thames Gateway strategy is already dependent on major, currently unfunded, investment in transport infrastructure to facilitate key development projects. An airport at Cliffe would place huge demands on road and rail networks and even with planned improvements would have the effect of constraining development prospects in the Gateway.
    13. The implications of the airport for the Thames Gateway would therefore be extreme, undermining all current planning, and future infrastructure investment plans, and creating rampant overheating within the local economy. The extremity of the impacts would be exacerbated by the unprecedented scale of the project and the massively compressed development period compared to normal economic events.
    14. An important implication of such massive and rapid expansion would be the substantial demands on public services (schools, health care, highway maintenance). Immediate capital investment in public sector services would be necessary and an ongoing commitment to revenue resources to maintain a standard of services required to properly support this level of growth. Nothing in SERAS deals with these very fundamental points.

  9. CLIFFE: SITE SELECTION
    1. Despite the most extensive review of all the published material, the Council has been unable to ascertain why Cliffe was selected as the only new site option. Not only does this raise serious questions about the transparency of the SERAS process, there are also strong indications that Cliffe should not have been chosen for the consultation paper.
    2. The basis for this view is set out in the MVA report but, in summary, it would appear that an incorrect score was given to Cliffe at the earliest stage for its 'designated conservation area' ranking. Had it been given an appropriate score, it would have ranked joint 140th out of nearly 400 options. As far as can be ascertained, this error was repeated at the second stage.
    3. Even at the supposed conclusion of the new site selection process, Cliffe was only ranked joint third below sites at Harlow and Thurrock and equal with a site near Bristol. No published reasons have been given for its subsequent promotion to number one. This casts grave doubts on the efficacy of the new site selection process and suggests that Cliffe should be withdrawn from the consultation process forthwith.

  10. CLIFFE: LOCAL IMPACTS
    1. The Council has undertaken its own detailed site appraisal. The results can be summarised as follows.
    2. Site Audit: The Council has completed an inventory of the major assets within the indicative airport perimeter and within a 'high impact zone', defined at this stage as the modified (SERAS Stage 3 Noise Assessment) 57 Leq noise contour. This is a robust area for assessing practical effects of the Cliffe option and takes account of the SERAS air pollution forecasts for the site and the published public safety zones for the four runway configuration. The full schedule is attached at annex 3.
    3. The inventory shows that:
      • The number of residential properties required to be taken would exceed 3,200
      • Eight settlements would be physically lost or would become uninhabitable.
      • Some 1,200 holiday homes would be lost
      • A substantially higher number of listed buildings and other heritage assets would be lost or severely affected compared to those listed in SERAS
      • Some 90 businesses would be displaced
      • Very substantially larger areas of the highest nature conservation interest would be seriously affected beyond the airport perimeter.
    4. Nature Conservation: Sites adjoining and intruding into the proposed site are designated as Special Protection Areas (SPA's) under the EU Habitat Directive and RAMSAR sites under the International Convention on Wetlands. They comprise a key part of a network of sites on each side of the Thames Estuary making up one of the largest and most important bird habitats in Europe. As such they form a key part of the Natura 2000 network.
    5. Investigations, not only by the Council but also by English Nature, The Royal Society for the Protection of Birds, The Environment Agency, Kent Wildlife Trust and Kent County Council, clearly demonstrate that the implications of the Cliffe proposal extend well beyond the direct land take and construction impact, primarily due to the essential requirement for bird strike management and modifications to the hydrology of the estuary system.
    6. The areas affected potentially run into many thousands of hectares.
    7. There are 4 internationally protected areas and 2 nationally protected areas in the vicinity of the Cliffe airport site. These are:
      • Thames Estuary and Marshes SPA and RAMSAR site 4,839 Ha
      • Medway Estuary and Marshes SPA and RAMSAR site 4,684 Ha
      • Benfleet and Southend Marshes SPA and RAMSAR site 2,251 Ha
      • Swale SPA and RAMSAR site 6,514 Ha
      • Northward Hill SSSI/NNR 292 Ha
      • Chattenden Wood SSSI 129 Ha

      4,288 hectares of SPA land lies within the high impact zone referred to above. This represents 88.6% of the Thames Estuary and Marshes SPA.

    8. In addition, the RSPB's landholding at Northwood Hill (currently Britains largest heronry) has been extended to include reversionary grazing marsh and regenerative woodland. As a result of careful management much of this land is considered to be of SPA quality and a formal submission has been made to English Nature to have the SPA enlarged. The great majority of this land lies within the proposed airport perimeter.
    9. Setting aside the issue of bird strike (dealt with below), it is considered that the disruption to the Thames Estuary and Marshes SPA would be highly damaging due to a combination of:
      • Disruption from construction
      • Changes in the groundwater regime and the hydrology of the estuary system
      • Essential safety installations (such as approach lighting) and ancillary development which cannot be contained within the airport perimeter (including a sewage works)
      • Damage to the surviving ecology from air pollution
      • Disturbance from light pollution - this would also affect both the Medway Estuary and Marshes SPA and the Benfleet and Southend Marshes SPA.
    10. The Government is bound by the EU Habitats and Birds Directives. To justify damage on this scale it has to demonstrate that there is no alternative solutions and that there are "imperative reasons [for it] of overriding public interest, including those of a social or economic nature." Even where these tests can be is satisfied the member state has to secure compensatory measures necessary to ensure the protection of the overall coherence of Natura 2000 and must inform the Commission of these measures.
    11. It is abundantly clear that the Cliffe option cannot satisfy the first of these requirements. The published consultation options include alternatives to fully meet the un-constrained demand figures for air travel and Stansted provides an alternative for a large hub airport option - should that be justified.
    12. Once again, therefore, the Council cannot see a rational basis for the inclusion of Cliffe as an option in this consultation.
    13. Mitigation: The SERAS report "North Kent Marshes Ecological Study - Phase 1" accepts that appropriate environmental compensation would have to be provided and makes a preliminary assessment of an option near the Isle of Thanet in east Kent (Reculver to Birchington extending south and east). It does so having ruled out options along much of the south east coast of England and even shoreline areas in Holland, Belgium and France. It also contains a number of warnings to the effect that much more work will have to be done before it can be demonstrated that the concept is viable.
    14. A number of bodies, including English Nature will be commenting in detail on this issue but Medway Council would make the following summary points:
      • The scale of damage/loss to existing sites has not yet been quantified and it is therefore not possible to define the level of mitigation required. However, all indications support the view that SERAS reflects a least worst case and as such has under-estimated the likely true impact;
      • As far as the council can determine, the likely scale and complexity of the mitigation required is without precedent, and no prior guarantee can be given that it would be successful. Particular issues concern the re-creation of mudflats with comparable invertebrate populations and the creation and maintenance of saltmarsh and saline lagoons;
      • No accurate assessment can be made as to how long it would take to create the necessary replacement habitats. This factor alone makes the possible timetable for construction, at best uncertain, bearing in mind the requirement to have mitigation in place before the affected habitats are destroyed;
      • The Isle of Thanet is a defined Priority Area for Economic Regeneration (PAER). The current economic and planning strategies for the area rely heavily on the development of Manston airport to underpin regeneration. The SERAS mitigation proposal would:
        • Almost certainly lead to the closure of Manston, due to the threat of bird strikes;
        • Add significantly to the perception of Thanet as remote from other centres of economic activity, so increasing feelings of marginalisation and making it even more difficult to deal with already high levels of deprivation.
    15. Flooding/Hydrology: SERAS has only made a preliminary assessment of this issue. Accordingly Government will wish to give substantial weight to the advice it receives form the Environment Agency. For its part the Council has concluded that:
      • The impact of Cliffe, together with other planned developments in the Thames Estuary (including the Swanscombe Peninsula and Shell Haven) will materially reduce capacity within the estuary in flood conditions. Not only will this impact on local areas (as admitted in SERAS) but it will place additional pressure on the Thames Barrier - with a consequential risk to Central London. In this context the Council has noted that the Thames Barrier has been closed more in the last two years than in the rest of its installed history put together;
      • It will modify the natural erosion and deposition patterns of the Estuary, with an associated risk to the future maintenance of protected areas - including areas proposed for mitigation;
      • Depending on the severity of the impact, it could have implications for a number of key regeneration sites along both the Thames and the Medway, the successful redevelopment of which is critical to the Thames Gateway strategy.
    16. Water Supply: The groundwater regime across North Kent is currently just in balance. Additional development will require the installation of new capacity but this cannot be provided locally. Large-scale transfer from other catchments will, therefore, be required. To serve Cliffe airport and the associated development, significant investment in new capacity would be essential.
    17. Site Hazards Including Bird Strike: At the preliminary new site assessment stage SERAS restricted consideration of man-made hazards to two types: nuclear installations and refineries. Both of these were regarded as "show stopper" constraints. At subsequent stages, consideration does not appear to have been given to even notifiable hazards scheduled in accordance with the Notifiable Installations Regulations. Nor has the Council been able to find any evidence of consultation with the Health and Safety Executive (HSE).
    18. In close proximity to Cliffe there are a number of hazardous installations. These include a high-pressure natural gas storage facility at Grain and the Government is advised there is a current planning application to convert this into Britain's sole importation point for liquefied natural gas (LNG). A 24 inch high pressure trunk main also runs through the airport site from this facility to feed the national gas grid.
    19. Given the nature, extent and disposition of these installations, Government is urged to urgently seek advice from HSE, CAA and other safety advisors to determine the risk to the proposed airport.
    20. Government is further advised that a working landfill is located within the central area of the proposed site (Shakespeare Farm, St. Mary Hoo). This contains some 2 million cubic metres of material, including a significant proportion of special wastes. These wastes include both BSE and foot and mouth carcasses and contaminated material from the Greenwich Dome site.
    21. Bird strikes represent a significant risk to even the largest aircraft while they are approaching or departing airports. Active and ongoing management of the risk is therefore a prior condition of the site being licensed by the CAA. Reference to the relevant CAA guidance indicates that a buffer area with a radius of some 13 km may need to be subject to bird management measures. The attached plan shows the indicative 13 Km for Cliffe, together with the affected SPA and RAMSAR areas. Should the 13km buffer be confirmed, the total extent of internationally protected habitat affected would be 14,708 hectares.
    22. At a bare minimum it is clear that the suppressing of bird populations over a very extensive area will be required. Regard would also have to be had to the migration flyways which cross the site and other factors causing local bird populations to overfly the site. Action could take a number of forms but extensive habitat modification/suppression would be required and this would be bound to have knock on implications for the ecological balance and biodiversity of the wider Thames and Medway estuary systems.
    23. The Council is not surprised therefore, that Government has already received advice to the effect that Cliffe is probably the worst possible site in Britain in terms of bird strike risk.
    24. Human impacts: As is apparent from the site inventory annexed to this submission the human impact of the Cliffe option is substantial; this despite what is perceived as its relatively remote location. The main SERAS consultation document indicates that around 1,100 homes "would be physically taken." However, this figure applies only to the airport site itself. Many other properties lie within the public safety zones for the 4 runways or the 69 Leq noise contour and would become effectively uninhabitable. When this "high impact" is taken into account it is estimated that 3,213 homes would be lost along with 3 residential care homes. The simple reality of this is the eradication of every community on the northern half of the Hoo Peninsula and the Isle of Grain.
    25. This scale of impact is substantially greater than for any other consultation option. Even at Heathrow only 260 homes are estimated to be directly "taken."
    26. Moreover, impacts are already being felt. Properties are virtually un-sellable, burials in local graveyards have been suspended and elderly owners in large residential homes fear being made homeless because no existing compensation scheme would allow them to move to more permanent accommodation. These are but a few examples but they do serve to illustrate the fact that local communities feel traumatised and bewildered as to how Cliffe could have been identified in the first place.
    27. The Hoo peninsula is considered to be of high archaeological potential. A recent archaeological assessment carried out by Wessex Archaeology identified 588 archaeological sites. The report considers this to be a gross underestimate of the full potential of the area with a large number of sites still to be found. This is due to the fact that the heavy peat deposits in this area hide the visible traces of sites. The fact that the area has not been developed and that the peat is waterlogged means that these sites are likely to have an exceptional degree of preservation. Deposits range from the Palaeolithic period (pre 10,000 BC) to the modern era. Particular sites of interest that would be destroyed are as follows:
      • Peat deposits on Cliffe marshes. These are of significance in that they preserve a record of environmental conditions in the north Kent area from the Palaeolithic period onwards.
      • A large iron age farming settlement and salt working site on the isle of Grain
      • A Romano British Settlement including pottery kilns and salt works to the southwest of the airport footprint
      • The medieval and post medieval field system on the airport site
      • 4 medieval settlement sites including standing buildings
      • The post-medieval Buckland decoy pond (considered for Scheduled Ancient Monument Status)
      • The 19th century Thames defences, including Slough Fort (considered for Scheduled Ancient Monument Status)
      • The Hoo stop line, a string of WWII defences designed to protect London from a landward attack.

      The area is poorly understood, with little research being carried out in the area and it is therefore difficult to assess its archaeological potential. Certain sites, such as those considered for SAM status and listed buildings must be regarded as of national importance. As a whole the area should be seen as being of regional importance archaeologically. There is the real possibility that there are further remains of importance still to be found and that the site as a whole may be turn out to be of national importance.

  11. CLIFFE: SURFACE ACCESS
    1. The viability of any airport is strongly influenced by its accessibility via surface routes, to staff, passengers and freight. Some airports have their own dedicated links to major catchment centres (e.g. the Paddington-Heathrow express) but most have to compete for capacity on established networks serving other needs.
    2. Within the Thames Gateway deficiencies on the established road and rail networks, both within and serving the area, have been a long-standing concern to Government and local authorities and agencies working in the area. They are seen as an impediment to effective regeneration.
    3. Proposals for Cliffe cannot therefore be looked at on a standalone basis, as is the case with SERAS. As in east London, the Thames in Kent and Essex is a very substantial barrier to movement. Currently there is no rail crossing east of the capital and the only road crossing (Dartford) is, approaching capacity. The wider distribution of traffic is not possible since virtually all mainline train services terminate in London, and the M25 provides the only effective north/south link. As a consequence there is a high incidence of local congestion, over-crowding on commuter lines and a perception amongst investors and others that the area is generally inaccessible. To those for whom London is not a destination, the capital represents a further barrier to movement.
    4. East/west road and rail links are already under intense strain: examples include the A13 and Fenchurch Street/Tilbury/Southend line north of the Thames and the A2/M2 and North Kent Line south of the river. Capacity improvements are not easy to achieve. Substantial development is already committed north of the A2/M2 corridor and its junction with the M25 is operating well beyond capacity. The North Kent line is part of a hugely complex system with many junctions and inefficient signalling and power systems.
    5. The Cliffe proposal on the other hand, is of a scale beyond any UK operational experience and yet it must achieve high quality surface access if it is to overcome its remote location and distance from the catchment market.
    6. Rail capacity and inter-connectivity are set to improve with the completion of CTRL and (possibly) Crossrail but there is already serious concern about the funding and availability of slots/capacity for fast domestic services on CTRL. The Crossrail project is emerging as an urban metro system with many stops to support its commercial viability. In this form it would be entirely unsuited to serve as a fast link to and from an international airport.
    7. This requires a comprehensive set of solutions, to provide very high capacity, reliable, efficient and fast systems with excellent intra-regional and inter-regional connections. As with so many other aspects of the Cliffe option, there is no evidence to suggest that this is the case, or even that practical solutions are achievable or fundable.
    8. A detailed analysis of the SERAS proposals (and their deficiencies) is set out in the reports prepared by MVA and Mott McDonald but the main points of concern can be summarised as follows:
      • Assumptions about available capacity on CTRL are totally unrealistic and without any technical foundation;
      • No coherent strategy is developed to separate or reconcile domestic and airport rail services - each of which has very different operational requirements;
      • No apparent consideration has been given to wider regional connections (road or rail), instead concentrating on movements from (and therefore through) Central London;
      • Within London a variety of rail destinations are proposed. This would not facilitate the marketing of airport services (or compete with Heathrow services) and the proposals appear to have simply arisen from assumptions about taking capacity from existing lines;
      • No proposals whatsoever are included to achieve connectivity with the nearest large urban area (Medway) despite the assumption that a large proportion of the workforce will come from there;
      • In what would seem to be an effort to limit costs it would appear that in stage 3 the Lower Thames Crossing has been down-graded to a road-only crossing compared to a combined crossing shown in stage 2. Similarly there seem to be doubts as to the commitment to the road only Benfleet tunnel. This would severely constrain the local catchment. It is considered that both these omissions would further significantly diminish an already weak case.
    9. On the basis of these conclusions it is the Council's view that the proposed airport at Cliffe could not function to the required level on the basis of surface access elements as currently proposed.

  12. OTHER ISSUES
    1. A number of additional issues are addressed below. They either deal with questions raised in the consultation and not already dealt with in this submission, or other pertinent matters relevant to the consultation as a whole.
    2. Air Traffic Control: This is a matter of particular expertise which the Council would not presume to advise on directly. It is however a critical factor for Government to consider. Advice from CAA/NATS indicate if is clear that a new airport at Cliffe would greatly increase the number of conflicts and severely impact on London City Airport. It is also noted that potential complicated interactions would occur between Cliffe, Heathrow and Gatwick. Southend, Biggin Hill and Manston would also be affected with implications for their continued functioning. The SERAS study accepts that the operation of an airport at Cliffe would not be possible with current technology, and assumes technological improvements over the next 10 years. However, recent experience suggests that significant technological change would be uncertain within such a timescale.
    3. Role of Small Airports: The Council supports, in principle, growth at small airports, particularly in the more remote parts of the UK where they could provide a useful stimulus to local economic growth. However, as far as the South East is concerned, it is considered that the following tests should be applied:
      • Would the proposal worsen an already complex air traffic control regime?
      • Are surface access proposals adequate and would the development be in conformity with relevant regional guidance (planning, economic and transport)?
      Given the already complex pattern of provision in the SERAS region safe management of available airspace must be the first and overriding priority. It is also important that aviation supports relevant and up to date spatial, economic and transport planning.
    4. Freight: It is noted that the great majority of airfreight is carried in the holds of passenger aircraft and that that will continue to be the case. Manston is being promoted as a dedicated freight facility and, if successful, could bring substantial economic benefits to East Kent.
    5. No case in seen for the Alconbury proposal in addition to Manston, unless a highly restrictive demand management regime is adopted for passenger capacity. In that event dedicated freight only services, such as currently operating from Stansted, are likely to be squeezed. Otherwise even the most optimistic growth forecasts do not point to the need for a new dedicated facility.
    6. It is surprising that SERAS's references to "general aviation" only cover the business segment of that sector. In this regard the council would support the principle of carefully controlled growth at facilities such as Farnborough and Biggin Hill to counteract displacement of executive traffic, from Heathrow in particular. Indeed there may be merit in promoting one location in the north west/south west quadrant of outer London for such services. However, all proposals should be compatible with air traffic control considerations and acceptable in terms of local impacts.
    7. The Council would also make the point that Kent and Medway lie on what might be termed the "continental flyway" for light aircraft, that is, small single and twin craft making one off trips to continental destinations. For obvious safety reasons these seek the shortest crossing of the English Channel. It follows that this is also a consideration in respect of the Cliffe option but one that has not been addressed in any of the published material.
    8. Finally, it is assumed that an air traffic control conflict would arise between an airport at Cliffe and the established light aviation facility at Rochester. Again this issue has not been addressed in any published material.
    9. Rail Substitution: As has already been pointed out in this submission, the small geographical size of mainland Britain must be reflected in transport policy. Efficient high-speed rail services have been demonstrated to offer a viable and more environmentally responsible alternative to short haul flights. With increased airport check-in times following September 11th and direct access to city centres, rail services have become an even more viable alternative for national and near continental journeys. To take one example, a flight from Stansted to Teeside would make little sense if a modern domestic rail system was in place. The completion of CTRL and its full availability to Eurostar services will promote a more convenient and attractive route to the continent. It is noted that this view is borne out by BA through its promotion of "Airtrack" proposal linking Heathrow with CTRL.
    10. Accordingly, it is considered that rail substitution should become an explicit element of Government policy.
    11. Funding and Delivery of Surface Access Proposals: As has been made clear, elsewhere in this submission, adequate surface access is fundamental to all airport expansion. However, the Council is concerned that the message given in SERAS is that airports need only consider their direct requirements and that Government has no funding role.
    12. It is accepted that this thinking can be applied to purpose built dedicated links carrying only airport traffic, but in most circumstances this will not be practical or desirable. Surface route planning must be conducted at least at sub-regional scale to reconcile the needs of different traveller groups, and optimise the return on investment in what is part of the nation's infrastructure.
    13. It follows that Government should:
      • Carefully vet private proposals to ensure that they are fit for purpose and compatible with other transport investment programmes;
      • Consider funding, in whole or in part, where there will be clear shared benefits.
    14. Consultation undertaken by Medway Council: The council wishes to emphasise the fact that, in response to this consultation, it has undertaken an extensive and objective programme of activities to first inform local communities and then to encourage debate and gather views. It has done so despite many other calls on its limited resources and the very short period of time available due to the late release of much information.
    15. The results of the many activities undertaken are detailed in separate annexes. The first records the results of direct consultation, including a structured opinion poll, while the second sets out the findings of a Task Group of Members, which undertook evidence gathering as part of the Council's scrutiny process.
    16. As will be seen the results bear out the conclusions set out above.
    17. Observations on the SERAS Consultation Process: While the Council unreservedly welcomes the opportunity to contribute to this consultation, it nevertheless finds it necessary to record some failings in the process:
      • Despite assurances by officials at the Department for Transport, the Council and its consultants had the greatest difficulty obtaining copies of all the relevant background documents. Not only did this effectively cut the time available to prepare this response by nearly 2 months but it also caused widespread confusion and suspicion among local people. This was particularly upsetting for those directly affected by the Cliffe option.
      • Too little attention was given to the distribution of the summary document to properties directly affected. One household would receive a copy but not their neighbour, again causing distress and confusion.
      • No account was taken of the potential to use parish councils as liaison with local communities. This could have done much to reduce the suspicion and hostility which occurred.
      • For parties directly affected further guidance could usefully have been issued. This could have more carefully explained the process and dealt with issues such as blight and compensation. It must be appreciated just how distressing airport proposals can be for those directly affected, particularly the elderly and those with no security of tenure.
    18. The Council also wishes to record its disappointment that no briefing was given to it prior to the Secretary of State's statement to Parliament. It had been hoped that there could be more trust between public agencies in these circumstances, bearing in mind a common duty to serve the public.
    19. Ministry of Defence - RSME PPP: The Secretary of State for Transport should be aware that the Ministry of Defence (MOD) is a major landowner in Medway and is currently completing the selection process for a major public/private partnership project. This involves the Royal School of Military Engineering (RSME) and the Secretary of State for Defence is expected to announce the contract award at any time.
    20. A critical part of the process is the probable large-scale disposal of surplus land and property, including extensive parcels at Chattenden and Lodge Hill on the Hoo Peninsula near to Cliffe. This is identified in the Thames Gateway Planning Framework as a potential new village scale settlement location.
    21. In the Cliffe appraisal work undertaken by Arup's it is indicated that if Cliffe became a preferred option, development at Chattenden and Lodge Hill might not be able to proceed. It follows that this has now put at serious risk MOD's flagship PPP with a potential value in excess of £180 million.
    22. The Council has informed MOD officials of the facts of the case but wishes to record its concern that comparable advice was not offered by the Department for Transport.
    23. This is particularly frustrating given that local authorities are regularly exhorted to deliver "joined up government" and that the Council has been trying to facilitiate the PPP process for in excess of 5 years.
    24. Shellhaven - Proposals by P&O: Proposals for a major new container and RoRo facility at Shellhaven on the North bank of the Thames are the subject of current applications for various consents. Integral to this proposal are compulsory purchase orders to acquire land for habitat compensation and mitigation. These CPOs include significant areas of land within the proposed footprint of the Cliffe airport option and displays a major conflict and lack of co-ordinated approach to key transport related projects.

  13. JUDICIAL REVIEW
    1. At the time of writing the Council is preparing for a judicial review hearing of the Secretary of State's decision to omit all Gatwick options from the SERAS consultation exercise. The Council wish to be clear that this submission made in response to the public consultation exercise is without prejudice to the forthcoming court hearing and the completion of any subsequent legal proceedings.