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Essex Wildlife Trust letter to UDC on the - Stop Stansted


									30 June 2006

John Mitchell
Executive Manager (Development Services)
                                                                                The Joan Elliot
Uttlesford District Council                                                     Visitor Centre at
Council Offices                                                                 Abbotts Hall Farm
London Road                                                                     Great Wigborough
Saffron Walden                                                                  Colchester, Essex
                                                                                C05 7RZ
Essex     CB11 4ER
                                                                                Tel 01621 862960

                                                                                Fax 01621 862990
Dear Mr Mitchell                                                                Website
PROPOSAL: Extension to the passenger terminal; provision of additional
aircraft stands and taxiways, aircraft maintenance facilities, offices, cargo
handling facilities, aviation fuel storage, passenger and staff car parking
and other operational and industrial support accommodation; alterations to
airport roads, terminal forecourt and the Stansted rail, coach and bus
station; together with associated landscaping and infrastructure as
permitted under application UTT/1000/01/OP but without complying with
Condition MPPA1 and varying Condition ATM1 to 264,000 ATMs
LOCATION: Stansted Airport/Stansted/Birchanger/Elsenham/Takeley

We refer to your letter of 27 April 2006 asking for comments on the above
planning application.

Essex Wildlife Trust raises an objection to this planning application as
there are significant potentially adverse impacts upon ecology. We are
particularly concerned about adverse ecological impacts arising from
increased nitrogen levels at Hatfield Forest NNR/SSSI and Eastend Wood
(part of Elsenham Woods SSSI). EWT has lodged concerns and
objections to the expansion of Stansted since the early stages of the Air
Transport White Paper (ATWP). This latest expansion proposal is driven
by the Government’s recommendations within the ATWP. We maintain our
position that unconstrained expansion of Stansted Airport, fuelled by unfair
low-cost air travel, is fundamentally unsustainable and will result in a
serious decline in quality of life for many people in the vicinity. EWT is
fundamentally opposed to this individual planning application, which is
supported by unsustainable and flawed Government policy on the future of
air travel.
                                                                                  Essex Wildlife Trust
Environmental Statement                                                           Company Registered
                                                                                  No 638666 England
In making comments on this planning application we have referred to a             Registered Charity
limited number of documents within the Environmental Statement (ES),              No 210065
mainly pertaining to nature conservation issues.                                  VAT Registered
                                                                                  No 623 0920 72

                                                               Protecting Wildlife for the Future
Planning Statement
In the Planning Statement it is claimed that the additional throughput of 10 mppa will result
in “only very modest impacts” (1.34 v). In terms of adverse impacts on nature conservation
interests there are a number of direct effects which will are of moderate significance.
Notably the loss of floristically rich grasslands at two sites: Zone G Car Park and South
Gate West Hotel site. While it is recognised that these grassland habitats are man-made
(previously arable land), they have taken at least 15 years to develop into ecologically rich
areas. They have developed good assemblages of breeding birds (including Skylark, an
Essex BAP species) and form a significant part of the habitat network throughout the
Airport. It is unfortunate that they are now to be destroyed. The compensatory grassland
(20 ha) will take some time to reach the same level of maturity. There will therefore be a
temporary net loss of biodiversity as the replacement habitat develops. The timing of the
creation of compensatory habitat is therefore crucial.

EWT notes that the ongoing construction works at Echo Stands North affect some
protected and Biodiversity Action Plan (BAP) species. The site has been cleared and
mitigation is in place. We acknowledge that these works are already consented and that
the need for this development was evaluated as outweighing the nature conservation
value of the site. It is extremely unfortunate that the extension of the taxiways has resulted
in the direct loss of two County Wildlife Sites (Pigeon Wood and Green Street Spring

Master Volume and Summary of Environmental Effects (ES Volume 1)
At 3.2.6 consideration is given to undertaking a Quality of Life assessment, raised by
Uttlesford DC as developed jointly by the Environment Agency, English Nature, English
Heritage and the Countryside Agency. Stansted Airport Ltd (STAL) decided not to carry
out the assessment on the grounds that:
   increased use is wholly contained within the airport boundary;
   indicators for Quality of Life (economics, air quality, etc.) are discussed in the ES; and
   consultation (part of a Quality of Life assessment) has been fully undertaken and
    reported in the ES.

This is a very disappointing decision based on a weak argument. The increased use is not
wholly contained within the airport boundary, as the proposal will impact on a broad range
of external issues affecting people and wildlife in the wider countryside. Since the
information to compile a Quality of Life assessment is within the ES, why not use it? STAL
has a duty to address the concerns of its consultees in an open and transparent manner –
it should not be the sole responsibility of third parties to draw conclusions on Quality of
Life issues from the complexities of the ES.

In addressing air quality issues that may affect Hatfield Forest and Eastend Wood
(10.9.22), it is claimed that nitrogen oxide contours for a 30 µg/m3 level (upper limit for the
protection of vegetation) would lie largely within the airport boundary (i.e. not encroaching
on either ancient woodland). STAL conclude that no specific additional ecological impact
will arise from airport related nitrogen or other elements. This suggests that the minor
expansion of the nitrogen contour predicted for the 35 mppa case relative to the 25 mppa
would have no significant impact beyond that of the general nitrogen deposition load. It is
therefore claimed that there will be additional harm to the ancient woodlands arising from
increased aircraft movements.

This conclusion is in direct contradiction with adverse effects of nitrogen deposition being
experienced within the nearby Hatfield Forest NNR/SSSI. The National Trust who own and
manage the Forest has noted that many of the veteran trees are already showing negative
signs of the effects of eutrophication (nitrogen loading) and air pollution. Veteran tree
crowns are dying back, lichens are declining and ground flora is less diverse. Pollution
levels around Stansted show that nitrogen deposition from the air is about 17 kg of
nitrogen per hectare per year and is above the level at which the European Commission
Committee on Long Range Atmospheric Pollution, following their detailed studies on the
health of forests, consider that there is damage to woodland habitats. (National Expert
Group on Transboundary Air Pollution (NEGTAP) Transboundary Air Pollution
Acidification, Eutrophication and Ground-Level Ozone in the UK, prepared for DEFRA in
2001). EWT therefore rejects the claim that ancient woodlands will not be adversely
affected through increased air pollution arising from the proposals.

Scoping Opinion
In its Formal Scoping Opinion (November 2004) for this planning application Uttlesford DC
asked that the ES address levels and impacts of emissions on ecosystems in Hatfield
Forest and general habitats. STAL responded to this request in March 2005 - details are
found in Table 1 of the ES in Volume 10 (Nature Conservation). For example, detailed tree
health surveys of selected trees in Hatfield Forest were requested by UDC. In response
STAL stated that the ubiquitous and pervading nature of emissions would suggest that
impacts specifically from the Airport could not be separated from the many other factors -
therefore such tree surveys would not be undertaken as part of this assessment. While
one cannot easily attribute to what extent the airport has an effect upon tree health, the air
pollution arising from the airport’s operation must logically be a contributory factor per se.
We are disappointed that STAL have not carried out this work upon the request of
Uttlesford DC.

Nature Conservation (ES Volume 10)
At 3.1.5 it is claimed that “even if the Airport was removed, it would make no significant
difference to the total nitrogen deposition rate as these are derived from regional, national
and international emission sources”. We are extremely sceptical about the validity of this
conclusion when confronted with the evidence that the airport is already having a
damaging effect upon ancient woodlands (see above). It is an irrefutable fact that nitrogen
deposition from the air around Stansted already exceeds European levels, above which
there is considered to be damage to woodland habitats. We do not accept the conclusion
that the airport does not make a significant contribution to the increasing eutrophication in
the woodlands and surrounding countryside.

It is anticipated that airside grasslands will be lost under the current 25 mppa consent
(9.3). Compensation is offered for 20 ha of new open grassland to be created bordered by
an irregular fringe of longer grass and scrub. This compensation is acceptable to EWT.

In section 10, an assessment is made of the impacts arising from the loss of flower-rich
grasslands at Zone G Car Park and South Gate West Hotel site. We reiterate that there
will be a temporary net loss of biodiversity as the replacement habitat develops.

We note that there is no mitigation offered for the predicted increase in badger and deer
road kills arising from these proposals (10.4.23 onwards). We ask that consideration is
given to addressing this problem through measures such as underpasses on Thremhall
Avenue and badger / deer fencing.
We agree with the conclusion at 11.1.1 that there will be no cumulative effects arising
from nearby developments at Priors Green (Takeley), Rochford Nurseries (Stansted
Mountfitchet) and Woodlands Park (Great Dunmow).

Under “Additional Mitigation and Compensation” (section 12), Planning Conditions should
be agreed to cover the proposed mitigation measures, incorporated into detailed site
designs (Table 20). In this Table there are several references to the retention of ditches “if
possible” (South Gate Hotel West and Yankee Stands South). We would prefer if these
features can be retained and incorporated into the design.

We are pleased to note that an up-to-date Design Guide is proposed (12.2.2) linked to an
integrated Habitat Creation and Landscape Masterplan. This should ensure that any
habitat creation and management is consistent with the Biodiversity objectives for the

EWT agrees that the 20 ha of compensation grassland should ideally be provided within a
single area, but that a holistic approach may not be possible as each site is brought
forward for development. It is important to secure a long-term commitment to manage and
monitor these new habitats.

Sustainability Appraisal
A Sustainability Appraisal (SA) has been conducted to study the extent to which
economic, social and environmental considerations have been integrated into the
proposed development to make further use of the existing runway. With respect to the
objective “Protect and enhance biodiversity”, the SA concludes that the proposal meets
the objective. Issues considered include predicted changes in habitat loss (woodlands,
hedges and ponds), impacts on species and off site effects.

While we do not raise concerns with the first two issues, EWT has expressed its serious
concerns about negative impacts arising from air pollution on nearby ancient woodlands
(Hatfield Forest and Eastend Wood). We therefore do not agree with the overall
assessment that the proposals meet the SA objective of protecting and enhancing
biodiversity in the wider context of the surrounding countryside.

We now turn our attention to generic air transport issues that are relevant to the current
planning application:

Growth in Air Travel
The basic premise of the current proposal (25 mppa to 35 mppa) is to accept the
Government’s promotion of unconstrained growth in air travel. On current forecasts,
including overseas visitors, as many as 500 million passengers will use UK airports by
2030, nearly three times the present figure of 180 million. This projection is based on
established 1990s growth at 5 per cent per annum.

Air transport policy is formulated on the basis that the economic benefits of the growth of
air traffic are so compelling and overwhelming that the primary objective should be to
provide sufficient airport capacity to enable growth to continue unconstrained by limitations
on airport space. This is the well-known predict and provide model that is now wholly
discredited in all other areas of transport policy, particularly road building.
We believe that this outdated model is fundamentally flawed and will simply fuel an ever-
upward spiral of greater demand and further provision. This worrying scenario is totally
unsustainable, environmentally damaging and is therefore strongly rejected by EWT. Air
traffic should not be treated as though it is a special case and somehow free of the
Government’s own policies on sustainable transport.

An alternative strategy is to use a sophisticated mix of demand management, change in
modal shift and better infrastructure provision (particularly rail); a more controlled plan,
manage and monitor approach. Such a strategy would allow greater diversification in
transport provision and has been put into practice in other EU countries, for example, by
building high-speed rail links to reduce demand for domestic and short haul flights.

The True Financial Cost of Air Travel
Air transport is directly and indirectly heavily subsidised in relation to other modes of
transport and products. There is no VAT on any aspect of air travel; not on airline tickets,
nor on the purchase of aircraft, nor on their servicing, nor on aviation fuel, nor on air traffic
control, nor on baggage handling, nor on airline meals. Everything directly associated with
air travel is zero rated, even the cost of landing slots is subsidised by duty free airport
sales. At present the annual cost of this subsidy to the UK economy is estimated at a
conservative £7 billion. In the Hidden Cost of Flying, Brendan Sewell puts the true figure
closer to £9 billion.

This artificial and unjust system of subsidy is grossly unfair and sets the aircraft industry
apart from all other modes of transport. It encourages an expectation and culture of cheap
air flights where passengers and airlines have neither responsibility nor charge for the
environmental damage they cause. This is unacceptable and unsustainable. The
insatiable demand for bargain-basement air fares is at the root of the alarming increases
in predicted air passenger numbers to 2030.

Climate Change and the Environmental Cost of Air Travel
Aviation is the world’s fastest growing source of greenhouse gas emissions, which
contribute negatively to climate change. While accounting for around 3.5% of global
emissions currently, this figure could rise to around 15% by 2050, if these unconstrained
growth predictions are fulfilled. In terms of the amount of CO 2 produced per passenger
kilometre, aviation is the worst offender of all types of transport. Global warming is already
having, and will in an increasing way have, a major and damaging impact on biodiversity in
the South East, UK and globally.

It is highly questionable that technological advances in jet engine efficiency will bring
about a net reduction in greenhouse gas emissions (attributable directly to air travel) or
that noise pollution will be significantly abated. These future benefits, however welcome,
will simply be swamped by the increased use of aircraft. This situation has already
occurred for motor vehicles – while engine efficiencies and exhaust emissions have
improved over the years, the increased number of vehicles on our roads have resulted in a
net increase in air pollution.

With increased rainfall, rising sea levels and slow geological land-sink (1mm per year in
the South East), the South East will suffer the most severe climate changes in the UK.
With increased flood risk there will be significant loss of habitats such as those on the
coast and wetlands, and associated loss of important species. This is apart from the
impacts on people of flooding, storms and drought.
The Royal Commission on Environmental Pollution in its report The Environmental Effects
of Civil Aircraft in Flight (2002) recommends that:

       climate protection charges are imposed for aircraft taking off and landing within the
        EU, and press for changes to adopted beyond Europe; and
       international aviation is included in the emissions trading scheme that is envisaged
        as one of the Kyoto Protocol’s implementing mechanisms.

The Commission concludes that, unchecked, air travel will become one of the major
sources of anthropogenic climate change by 2050 but that they fear the Government
shows little sign of having recognised this.

Essex Wildlife Trust wishes to lodge an objection to the intensification of passenger use
at Stansted Airport. Our main reasons for objection are adverse ecological impacts arising
from air pollution on nearby ancient woodlands (notably Hatfield Forest NNR/SSSI) and
the generic issue that forecast increases in air passenger numbers are unsustainable
(fuelled by unfair low-cost air fares). It is now widely recognised that global warming will
have a major and damaging impact on biodiversity. Air travel is the world’s fastest growing
source of greenhouse gas emissions, which contribute negatively to climate change.
Therefore the current planning application will exacerbate the negative impact on
biodiversity arising from increased greenhouse gases.

For general advice on dealing with planning applications where wildlife may be affected
we respectfully refer the applicant to the publication on interactive CD by Essex
Biodiversity Project entitled: “Integrating Biodiversity into Development…realising the
benefits: Guidance for Planners and Developers in Essex, Southend and Thurrock”. This
proactive guide is available to view on the Internet at

Please keep us informed of the progress of this high-profile planning application and any
decision made in due course.

Yours sincerely

Phil Sturges
Conservation Officer
on behalf of Essex Wildlife Trust
01621 862976
07880 702793 (email) (website)

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