• The Department for Transport (DfT) states that it wishes to develop a sustainable strategy to accommodate the predicted growth in the aviation sector. CPRE Kent contends that the unconstrained growth of aviation is not, and never can be, sustainable.
  
• We challenge the projections on which the perceived need for additional runway capacity are based. We believe these to be seriously flawed, and contend that they grossly overestimate the demand for air travel during the 30-year forecast period covered by the consultation. We suggest that the actual growth likely to occur in the aviation sector can, with appropriate management, be accommodated within the existing available runways, and without the massive expansion or additional airports proposed.
  
• CPRE Kent opposes the destruction of areas of unspoilt countryside for the development of additional runway capacity in the South East. We are particularly concerned at the proposals for an entirely new hub airport at Cliffe, a Special Protection Area and one with Ramsar status, which should be afforded high levels of protection. The deliberate destruction of an important wildlife habitat runs counter to any reasoned argument for sustainable development; moreover the on-going requirement to control wildfowl activity to mitigate the considerable risk of accidents due to birdstrike make this option the most hazardous for passengers and craft.
  
• The increased impact of aviation on the population of the South East and beyond has been largely overlooked. The massive increase in noise pollution, which would be the inevitable consequence of allowing unconstrained expansion of the aviation sector, is not sufficiently acknowledged; nor is the impact on local and global atmospheric pollution.
  
• There is at present no known way to minimise the adverse environmental impacts of aviation: any significant improvements in fuel efficiency or the use of non-fossil fuels are distant goals. The failure of the industry to compensate for the environmental damage it causes, and the resources it uses, is inequitable and cannot be sustained.
  
• We propose that, rather than simply providing the runway capacity to cater for the dubious predictions of increased air passengers, attention should be focused on measures which offer more sustainable alternatives to the unconstrained growth in aviation:
  
• A more equitable cost basis for the aviation industry, with the removal of the exemptions on fuel duty and zero-rating of VAT, a credible emissions trading scheme and an environmental levy
  
• The auctioning of runway slots, to maximise the efficiency of use of existing runway capacity
  
• Investment in cleaner and more efficient mass transit options, such as electric high speed rail
  
• A re-appraisal of the forecasts for the growth in passenger numbers, in line with the current economic performance of the aviation industry
  
• A clearer commitment to the protection of the population and the environment from the damaging effects of aviation – particularly noise pollution, air pollution and loss of habitat and amenity.

• Summary 
• 1 Sustainability
•     1.1 Environmental Damage
•         1.1.1 Pollution
•             1.1.1.1 Global Pollution
•             1.1.1.2 Local Pollution
•         1.1.2 Noise
•         1.1.3 Habitat Despoliation
•     1.2 Use of Finite Resources
•         1.2.1 Energy
•         1.2.2 Land Use
•     1.3 Social Sustainability
•     1.4 Economic Sustainability
• 2 Economic Viability
•     2.1 Projected Passenger Numbers
•     2.2 Accuracy of Forecasts
•     2.3 Current Growth
•     2.4 Fares Structure
•     2.5 Cost Forecasts for the Cliffe Option
•     2.6 Traffic Congestion
• 3 Efficient and Safe use of Capacity
•     3.1 Use of Hub Airports
•     3.2 Re-balancing the Regions
•     3.3 Air Traffic Control Capacity
• 4 Environmental Damage
•     4.1 Noise
•         4.1.1 Measuring Noise Levels
•         4.1.2 Noise Levels around Cliffe
•         4.1.3 Other Airports in Kent
•         4.1.4 Other Modes of Air Travel
•         4.1.5 Actions to Reduce Noise
•         4.1.6 Impacts on Quality of Life
•         4.1.7 Noise: Conclusions
•     4.2 Climate Change
•         4.2.1 International Conventions Controlling Climate Change
•         4.2.2 UK Activities to Limit Climate Change
•         4.2.3 Emissions Control from the Aviation Sector
•         4.2.4 Aviation’s Contribution to Climate Change
•         4.2.5 Climate Change: Conclusions
•     4.3 Local Pollution Effects
•     4.4 The Cliffe Proposal: Specific Concerns
•         4.4.1 Birdstrike Potential
•         4.4.2 Land Take and Loss of Amenity Value
•         4.4.3 Landscape and Habitat Destruction
•         4.4.4 Compensation for Destruction of Habitat
•         4.4.5 Population and Employment Implications
•         4.4.6 Flooding
•         4.4.7 Air Pollution
•         4.4.8 Other Risks
• Conclusions

The DfT’s consultation documents on the future of air travel in the South East speak of a commitment to ensuring that the expansion of aviation capacity is sustainable. We believe that the unconstrained growth in air travel is not, and can never be, sustainable.

The commonly accepted definition of the term requires four criteria to be considered simultaneously in assessing the sustainability of development. These are the potential for environmental damage, the use or destruction of finite resources, the social benefits and the economic viability of the development. We believe that on all four counts the unconstrained expansion of air travel fails to demonstrate its sustainability. We consider all four in turn in the following sections.

The acknowledged environmental harm from aviation is well known and has been discussed at length by many authors. It is not our intention to reiterate these arguments in depth, but to highlight the following primary areas of concern:

1.1.1 Pollution

Despite its major pollution issues, the aviation sector has no obligation to adhere to the ‘polluter pays’ principle that underpins national and European environmental legislation – a situation unique among European industry.

1.1.1.1 Global Pollution

The impacts of aviation on global pollution, and thus on the global environment, are disproportionate in comparison to virtually all other forms of transport. Not only is much more fuel used per passenger-kilometre in aviation (see sections 1.2.1 and 4.2.4), but the pollutants emitted during airline flight at altitude have an impact on global warming some three times greater that they would were they to be emitted at ground level.

1.1.1.2 Local Pollution

The huge amounts of aviation fuel consumed during take-off, landing and taxiing, combined with the effects of the induced road vehicle traffic around airports, result in significant local impacts on air quality.

1.1.2 Noise

Noise is one of the least regarded and arguably most locally damaging of the impacts of aviation, affecting the well-being and quality of life of many thousands the world over. The expansion scenarios outlined in the consultation document will result in hundreds of thousands of additional people suffering the effects of noise pollution from aviation.

The impacts of noise pollution from the proposed airport expansions are considered in more depth in section 4.1 of this paper.

1.1.3 Habitat Despoliation

The destruction of unspoilt land required for the construction of additional runway capacity has been considered in the consultation document, but relatively little attention has been given to the associated land-take for the development of the necessary access arrangements and other infrastructure required to service these developments. Particularly in the case of the suggested new hub airport at Cliffe, the destruction of very large areas and of significant protected wildlife habitats, compounded with the impact of massive development on the remaining heritage and archaeological legacy of the area – including many listed buildings – would be of significant detriment to North Kent.

1.2.1 Energy

Aviation is profligate in its use of energy, consuming more energy per passenger/km than any other form of mass transport. Something of the order of half the world’s total oil reserves have been used within the past century, and the rate at which these reserves are being used continues to increase. The continued expansion of aviation to the detriment of other forms of more energy efficient mass transport – such as electric high-speed rail – cannot be considered sustainable in this respect. The continental High Speed Rail Network is largely replacing internal flights in the Central Cities zone of the European Union; we contend that investment in high speed rail is a far more sustainable policy than the unconstrained growth in air travel.

1.2.2 Land Use

The option of a wholly new airport at Cliffe represents the most significant land-take of the alternatives considered. However the consultation document greatly underestimates the total land required since it does not consider the requirement for ancillary services and infrastructure, nor the requirement to manage adjacent habitats to reduce bird numbers and thus limit the potential for birdstrike. The importance of the wildlife habitats present at Cliffe, as well as the considerable heritage and archaeological value of the site, are of particular concern. It would also appear impossible to meet the requirement to provide compensatory wildlife areas.

The lack of regional balance in the consultation’s proposals gives us cause for concern. The proposals plan for 65% of the UK air capacity to be in the South East, where only 35% of the population is resident. Whereas this might reflect the current situation, with the South East much more affluent than other parts of the country, it would not seem appropriate to assume that this disparity will continue indefinitely. There are many signs that more northerly areas are beginning to redress the balance. The effect of focusing the expansion of the aviation industry in the South East will be to increase the distances that passengers have to travel in order to join flights.

The local effects of increased aviation – air and noise pollution, and induced traffic congestion – have a disproportionately high impact on those living and working near airports (see section 4.1.6).

Further afield, the damage of unconstrained tourism on indigenous populations has historically outweighed the benefits, with pollution and environmental damage inflicted on environments unable to support the growing number of tourist arrivals.

We further believe that the predictions for population growth underlying the projections for air traffic demand are flawed. According to the 2001 census figures, population numbers will be reducing. In 2006 the largest age group, at 4.9 million, will be the 40 to 45 year olds. By 2030, when they will be aged between 64 and 69, this cohort will still be the largest age group. The Treasury acknowledges that, to achieve reasonable pension provision in 2030, this group should now be paying double their current pension contributions. Birth rates are declining while longevity is increasing, and by 2030 well over half the population will be too young or too old to work. Very many of the latter may well be drawing inadequate pensions. The assumption of ever-increasing GDP is clearly questionable. To saddle future generations with the costly infrastructure of airport expansion – especially that which would be required at Cliffe – simply to ensure that holiday makers have unconstrained access to air travel between 2020 and 2030 appears to be utter folly.

We question the causal link between available aviation capacity and economic growth, particularly as the growth in capacity is currently concentrated on the low cost airlines. These in the main cater for leisure travel, rather than business travel. More than twice as many Britons travel abroad as visitors from overseas visit Britain; additionally Britons on holiday overseas on average currently spend more per head than tourists visiting Britain, resulting in a net outflow from the British economy. It can be argued that the unconstrained expansion of aviation capacity will encourage more British holidaymakers to travel, and spend money, abroad. A fairer pricing structure, which more accurately reflects aviation’s true costs, would encourage the same leisure travellers to spend more of their spare time and their disposable income within the British economy.

The arguments for the economic sustainability of an expanding aviation sector are further compromised by recent developments in electronic communication, offering an increasingly efficient and cost-effective alternative to physical travel for business purposes.

We would also wish to point out that in the South East alone some 230,000 people are employed within the environmental sectors and that they contribute over £7.8 bn Gross Value Added to the economy. This compares with 180,000 people employed in the aviation industries throughout the whole of the UK. This suggests that the need to protect the environment, and the economy dependent on it, is more important than allowing the expansion of aviation with its associated environmental damage.

2.1 Projected Passenger Numbers

The consultation document presupposes an ‘unconstrained demand’ for 300 million passenger trips per annum (mppa) in the South East by 2030. Of these, an estimated 28 million will be conducted on modes of transport other than air – typically, by high-speed rail. The scenario offering the highest capacity for air transport in the South East is the option of a new hub airport at Cliffe which, in conjunction with the existing airports, will provide for 314.5 mppa, 272 mppa of which would be at Cliffe. However, the currently available runway capacity alone, with relatively minor improvements (referred to in the consultation as the ‘Maximum Use of Existing Airports’ Scenario) will cater for 201.5 mppa. Thus the difference in potential traffic on which the case for airport and runway expansion rests is just 70 mppa.

How accurate is the prediction of an unconstrained demand of 300 mppa by 2030? Preparing this forecast presented the DfT with something of a problem. Their explanation starts with the comment ‘Looking so far ahead is difficult, not least in an industry as dynamic as aviation’. In fact there are no actuarial techniques available to forecast a future so distant. The consultants they hired to develop these forecasts were industry specialists, previously with the British Airports Authority and British Airways, who principally canvassed opinions amongst the stakeholders in the aviation industry. Their choice, in the light of the UK and OECD world economic forecasts at that time, was 500 mppa for the whole of the UK and 300 mppa for the South East. However even they frankly admit that there is a probability of a 20% error either way! A 20% reduction makes the total 240 mppa. Deducting the DfT figure of 28 mppa still travelling by other means, such as rail results in the number of air passengers falling to 212 mppa, just 10 mppa over the DfT’s Maximum Use Scenario. The DfT’s preferred options are therefore crucially dependent on the unconstrained demand at major South East airports exceeding this figure to approach 300 mppa. What are the odds?

These last five years have been the worst in the history of aviation and growth has been negative over much of this period. This is not just a temporary phenomenon due to terrorism, the Gulf War, SARS etc. The major factor is that economic growth across most of the world has stagnated or fallen into recession. All the major world airlines are in difficulties. Several have gone bankrupt or made major cutbacks to their schedules. The two largest are in the USA: United Airlines (in protected bankruptcy) has cut back 26% of capacity and made 20,000 redundant; American Airlines has cut back 15% of capacity and made 22,000 redundant. In the UK British Airways has made a 15% reduction in capacity and announced 13,000 redundancies. A lucky few airlines have been temporarily bailed out by their Government’s support.

The start date for the DfT’s growth projections was 1998 when the total South East demand was some 100 mppa. The average annual increase was forecast as 4.25% by the consultants. Now, five years on, the demand in the South East should therefore have risen to around 123 mppa. The most recent figures for this period suggest that the actual growth in passenger numbers has been far below this.

Even when there is an upturn in the world economy (which, at the most optimistic, will be two or three years ahead) the airlines will then have to recruit and train operational staff before any significant expansion can occur. Thus it is likely to be the best part of five years before any real upturn can occur. So, after the first 10 years of the 30-year period addressed in the consultation the actual growth figure is likely to be some 60% below the original expectation. To reach the forecast of 300 mppa would then require growth hugely in excess of that in any decade since the start of civil aviation.

Furthermore, there is an anomaly in the growth figures used for forecasting the required runway capacity. The normal DfT Highways Agency approach is to use a figure of 40% of the difference above the minimum value in a range. This consultation, however, relies on using figures at the mid-point of the range. We question why this should be so.

We envisage two conflicting factors affecting the fares structure within the aviation industry over the next 20 years and more. Market forces will continue the trend towards driving fares down, while local and global environmental considerations are likely to press for levies on the aviation industry’s activities

The DfT’s consultation document argues that the mid-point of their growth forecast is based on fares falling by 1% per annum up to2020 (although, as the consultation document states, … ‘greater competition, especially from the low cost carriers, could well lower figures at a faster rate’). It suggests that a 2% reduction in fares per annum would increase demand for flights by 20%. Sustained over a 20-year period, a reduction in fares of 2% per year would represent a one-third cut in fares attributable to increased competition. For this to be feasible suggests that the existing airlines are very inefficient, or are making excessive charges, or both.

The EU is moving towards the imposition of an environmental levy on the use of aviation fuel, and the consultation document considers that overall cost savings of 1% pa will be sufficient to pay for such a levy. This would require a further reduction of 1% of overall costs annually to meet the reduction of air fares which were the basis for the mid-point of the passenger growth forecast (300 mppa) on which the consultation is focused. However this reduction, if it occurs, is likely to arise predominantly in the budget airline sector, increasing its attraction for leisure travel.

It is our opinion that this sustained decrease in air fares over a long period is unlikely: we have already illustrated the downsizing and staff reduction going on in many of the world’s major airlines. British Airways made a loss of £200 million in 2002, and they continue to struggle under current conditions. In addition it has a current debt of £5.2 billion and a pension deficit of £1.2 billion. It is difficult to see how market forces can stimulate further cost cutting under these conditions.

If cost reductions to air fares are to occur at all, they will be confined to the budget airline sector, which will divert the trend away from major hub airports and – inevitably – away from the South East.

The consultation document does not include any additional costs from the need to directly reduce emissions or pollution. It also gives no consideration to the possibility of future fuel duties or VAT charges imposed on the aviation industry; the effect of these could be highly significant on the future of air travel.

We do not believe that the economic case has been adequately made for the construction of a new airport at Cliffe. The costs of construction, at £8.9bn, are the highest of all the stated options, because of the need to construct 4-runway platform 15 metres above sea level. The financial benefits of the Cliffe option are stated at £17.3bn, leaving a net economic benefit of £8.4bn.

However, the projected costs, which Kent County Council in particular have calculated as being substantially underestimated, include no allowance for the essential infrastructure (the road and rail links and the suggested two tunnels under the Thames). Our conservative estimate is that these costs alone would easily wipe out the £8.4bn benefit. Moreover, these costs do not take into account the necessary environmental works for construction to proceed at Cliffe.

A recent report for the treasury called into question the consistent underestimation of infrastructure and other costs within DfT construction projects. This is referred to as ‘optimism bias’ which is considered to be responsible for cost forecasts being underestimated by as much as 60%.

A further factor is the likely future costs of oil. Currently we have consumed around half the world’s total supply of oil, and our rate of use is increasing dramatically. New supplies are coming on-stream at a lower rate than existing supplies are being exhausted. Whereas this situation is not likely to reach crisis before 2030, we believe that in the longer term – and well within the operational lifespan of Cliffe – fuel costs will soar as producer states begin to hoard their own supplies (as the US is already doing). This will have enormous implications to traffic, and in consequence will significantly reduce the return on investment made in constructing the airport.

A surprising omission from the consultation document is the effect on the M25. This already overloaded road will suffer massive additional congestion if the proposed expansion of runway capacity in the South East goes ahead. Heathrow, Stansted and Gatwick already generate high volumes of traffic on the M25. Expansion at these airports would have a serious effect on traffic flows, which would feed back into Kent; a wholly new airport at Cliffe would have disastrous consequences on its already over-pressured transport system.

The DfT’s own guidance states that ‘The prime criterion is overall value for money. However authorities must also consider financial performance and financial sustainability of higher and lower fare assumptions’. It goes on to say ‘An overall assessment of the practicality and public acceptability is required’. This guidance document also calls for clear risk assessment. We believe that a full analysis, taking these issues into account, would coincide with the result from the Government computer model, SPASM, showing that no additional runways are needed.

The real measure of runway capacity is the number of aircraft using it, not the number of passengers. For much of the year aircraft fly half-empty, because airlines have historically been reluctant to form passenger-sharing alliances; they do not want to lose landing slots at peak periods. The DfT’s forecasts are based on a very small increase in the number of passengers per aeroplane (currently averaging fewer than 140 at Heathrow and around 115/120 at the continental airports). This represents an annual average of about 70% of available seating capacity, compared to over 80% on budget airlines.

If the number of passengers each year increases because holiday makers are making several trips each year, then this will have the effect of broadening the annual peaks in travel and the effective runway capacity will be increased.

We would strongly support the auctioning of runway slots because this would encourage the most efficient use of resources as well as providing funds for more sustainable transport links. By encouraging maximum use of larger aircraft, auctioning would reduce the pollution generated per passenger and ensure the survival of the most efficient airlines.

It is claimed that constraints to aviation caused by lack of runway capacity will adversely affect GDP. However, these potential economic impacts have been considered in isolation. Any such demand for which the consultation seeks to cater will be replaced by rail, road and ferry transport. The consultation is incomplete in that it makes no assessment of the impact of future high-speed rail travel. The Eurostar rail link to Paris and Brussels is already proving more convenient and often faster, door-to-door, than air transport, even though the high-speed section of the CTRL through Kent is not yet open. Soon there will be high-speed travel on both the East and West Coast main lines, and links are proposed to Manchester, Birmingham and London airports. CPRE Kent believes that these factors should have been considered in any professional analysis of the need for further capacity. We presume that the DfT will agree that the current problems being experienced on the existing rail networks will be resolved in the reasonably near future.

A secondary factor omitted from the DfT’s projections is the capacity of this new rail network to reduce considerably the demand for feeder flights in to London. This would generate a significant reduction in the need for small aircraft runway slots at London’s airports, allowing these slots to be used by larger long haul aircraft.

Hub airports are in the main used by travellers making long-haul flights in large aircraft. This is a trend already well established at Heathrow and Gatwick and with relatively minor terminal improvements they can cope with moderate increases in this trend.

We have already discussed the disproportionate growth of the budget airlines over more traditional carriers. Most of the low cost carriers do not operate from the large hub airports. Increased travel by these carriers is not relevant to the expansion of major South East airports.

Another argument of dubious logic is the need to maximise ‘interlining’ (the use of hub airports by travellers from overseas changing to another overseas flight). These passengers add to terminal congestion and to the security burden of the airports, while bringing relatively little direct financial benefit. If interlining also involves surface travel across London it will cause additional traffic congestion, but this is not considered. The DfT’s figures suggest that, if ample runway capacity were to be made available in the South East, interlining activity could increase four-fold, from 15 mppa to 60 mppa. If, instead, the DfT’s ‘Maximum Use’ scenario were to be adopted, the increase in interlining would be unlikely to increase beyond 28 mppa.

The primary benefit of interlining is said to be to increase the total numbers travelling, therefore giving travellers greater choice of routes and more frequent services, and thus increasing the prestige of London as the premier international business centre. We contend that this ambition is dubious. For example, both Schipol (Amsterdam) and Charles de Gaulle (Paris) already have more capacity, fewer constraints, and excellent ground transport links. Yet neither of these airports has experienced an increase in interlining of the scale suggested in the DfT’s consultation document, and neither city offers a challenge to the status of London as a business or financial centre.

CPRE’s 2002 campaign on ‘Even Regions’ presented the case against the unrestrained growth of the South East’s economy at the expense of the other regions and devolved administrations. While some parts of Britain experience heavy traffic congestion, soaring house prices and severe environmental strains, others suffer from decline, abandonment of housing and dereliction. Urban renaissance and countryside protection need to be primary objectives if we are to improve both economic performance and quality of life in the UK as a whole. We contend that the pursuit of maximum economic growth in the South East is inconsistent with the goals of more balanced economic growth across the country.

We believe that as far as air safety is concerned, the timing of this consultation is premature. There is no certainty that air traffic control will be able to cope with a three-fold increase in air traffic. Existing air traffic control measures are under pressure: during peak periods, delays at Heathrow occur on 35% of flights, due not to lack of runway capacity but to the overloading of air traffic control.

DfT concede that new procedures will be needed in order for aircraft to fly safely at higher densities. The design, simulation and phased implementation of procedures which have yet to be developed means that there can be no certainty that the proposed runway capacity could be utilised safely until well into the 30-year review period. For the DfT to commit to a massive and costly construction programme without the assurance that airspace capacity is available would be foolhardy in the extreme.

We have briefly considered some of the impacts of aviation in considering its sustainability. These impacts and others are dealt with in more detail in the following sections.

We are greatly concerned that the DfT has inadequately considered the impact of noise from the proposed expansion of aviation. This is in part due to the methods they have used to estimate future noise levels, but also because too high a threshold has been used for the beginning of public annoyance. As part of the main organisation fighting for a tranquil England, we are horrified at the potential impacts of expansion of aviation on the scale envisaged.

We are surprised that the DfT continues to use the A-weighted sound level in its consultation, since it is a poor descriptor of the perceived loudness and annoyance. For example, the A-weighted sound level underestimates the loudness of low frequency sounds as well as broadband noise and sounds that include strong tonal components. Time-varying loudness (the loudness level that is exceeded 10% of the time) is a better measure. Alternatively Lmax, which measures the maximum sound pressure levels during a period of time, captures individual aircraft movements that exceed noise standards, and this should be used, especially at night, when it would be most useful.

The European Union has found that ‘None of the computation methods (for calculating noise levels) presently used in the member states satisfies the requirements for modern harmonised methods.’ They go on to recommend a day-evening-night level, Lden, which adds 5 dBA to the evening value and 10 dBA to the night time value, thus emphasising the greater impact of noise in the evening and at night. We cannot understand why this method has not been used as this information has been available for some two years now.

In addition Leq is used which only takes account of average daytime noise levels, flattening short-term noise peaks that can impact disproportionately, especially at night. The limitations of Leq as a measurement are compounded in a failure to fully capture the effects of increasing numbers of aircraft movements.

As the Government’s Planning Policy Guidance note 24 (Planning and Noise) stipulates, a noise level of 57 dBA is considered sufficiently annoying to need investment in insulation. This is the level chosen for the noise contours in the consultation document. Huge noise nuisance is caused at far lower levels than this, affecting very much larger numbers of people than estimated.

In addition the World Health Organisation states that ‘to protect the majority of people from being seriously annoyed during the day-time, the sound pressure level should not exceed 55 dBA Leq for a steady continuous noise… At night, sound pressure levels at the outside façades of the living spaces should not exceed 45 dBA Leq and 60 dBA Lmax, so that people may sleep with bedroom windows open’.

Airspace capacity pressures cause flight paths to fan out, meaning that far greater numbers of people are exposed to noise than would otherwise be the case. Increased air traffic volumes also mean that descent happens further away from the airport for some craft The computer-generated models do not pick up this up. This is of particular concern around the proposed Cliffe airport where it will be difficult to avoid disturbing people in urban centres as well as to maintain the quiet areas of countryside.

Airlines currently have very little incentive to adopt new technology while they are able to use noisier, more polluting craft without penalty. The SERAS study assumed that new designs would be introduced in 2002, with phase-out of older versions beginning in 2007. In the event, the new designs are to be deferred until 2006 with no phase-out yet agreed for older engines. Hence air traffic will be noisier for longer than expected, so the overall noise impact will be worse.

The most recent study conducted by the European Environment Agency revised the number of people affected by more than 57 decibels of noise at Heathrow from 331,000 (1999) to 440,000. This shows that noise is a much more serious and difficult problem than the DfT has admitted.

The National Noise Incidence Study has found that 54% of the population of the UK live in dwellings exposed to day-time noise levels above the WHO level of 55 dBA Leq. Similarly, it has found that 67% of the population live in dwellings exposed to night-time noise levels above the WHO level of 45 dBA Leq. None of the dwellings in the sample experienced night-time levels of below 60dB Lmax.

They also evaluated results in terms of the EU recommended Lden, which showed that 66% suffer a noise level of more than 55 dB.

England is already a very noisy place. It needs to become quieter.

We recommend standardised noise measurements around airports, and that there should be no increase in the population exposed to more than 55 dB Lden, with appropriate measures to reduce bedroom noise below the WHO draft guidelines level of 50 dB Lden as well keeping below the 60 dB Lmax.

We consider that allowing expansion to occur only within these levels would reflect a proper concern by Government for local people and their environment.

At present the area around Cliffe is relatively free from aircraft noise. The SERAS data suggests that daytime 57 dBA contour area in 2030 would be 252 km², affecting a population around 26,800. However if the population exposed to more than 54 dBA is considered the figures rise to at least 65,900 – a figure equivalent to the population of the whole of Guildford.

Policies on night-time flying are currently under review - we would hope that the Government ensures that there is no increase in night time noise for anyone.

A major omission is that no estimate has been calculated of the noise caused to areas under the flightpaths away from the airport. Although planes are generally higher than in the area immediately around an airport, the noise is still disturbing, especially in the quiet countryside, which must be protected if tourists are to be attracted to it.

While Cliffe is the major proposal, the SERAS study also mentions other airports in Kent, Manston being the largest, which is proposed to expand to 3 million passengers per annum. However this appears to ignore the town of Ramsgate, within a mile of the direct line of the runway, and home to 40,000 people. We do not believe that this a sensible location for expansion of a noisy industry, especially as this area relies heavily on tourists.

The consultation makes no mention of other air traffic such helicopters, small aircraft and microlights. While unlikely (we hope) to proliferate to the level of scheduled flights, they are extremely noisy and intrusive, and as a result of requirements for increases in controlled airspace are likely to be forced to fly in the more restricted areas away from the major flight paths. There appears to be little planning control over their activities, so to protect the tranquillity of the countryside we strongly recommend that appropriate planning controls be introduced.

Noise policy both in the UK and in Europe is undergoing a radical change. As a result of the recent Environmental Noise Directive, we and our European partners will be required to assess environmental noise exposure levels for our populations, to map local areas and to produce appropriate action plans.

DEFRA’s strategy for the control of ambient noise calls for the reduction of noise generated by aircraft, and requires that noise be addressed at the planning stages of new developments (planning authorities must have regard to the ODPM Planning Policy Guidance note, PPG 24). It also includes a commitment that consideration will be given to the identification and preservation of ‘tranquil environments’.

Hence in order to comply with this strategy aviation needs to be controlled so that noise is not increased.

In all the above consideration of the quality of life for local people is very important, and should be a central issue for Government.

A growing awareness of these issues is now beginning to affect national and international policies. Kent County Council’s own researches show that the public believes improvements in environmental protection to be extremely important.

The Countryside Commission surveys of public attitudes record that one of the three most important things people value about the countryside is peace and quiet.

There has been considerable concern expressed regarding the loss of tranquil areas both in the open countryside and in urban areas. CPRE’s own studies report that the loss of rural tranquillity is rapid, and that it is an increasingly scarce but valuable resource.

There are economic implications as well. The English Tourism Council’s new ‘Tourism Brand’ highlights the tranquillity and diversity of the countryside as ‘one of the most powerful and evocative perennial images we have’.

Noise also imposes non-monetary costs, such as disturbance and health impairment, which have largely been ignored in the consultation. A recent report has highlighted the disparity between subjective perception of noise-induced disturbance at night and objectively measured disturbance. A further study confirms that people exposed to average aircraft noise levels of 55 decibels or higher were 60% more likely to report having been diagnosed with high blood pressure.

However in SERAS the assessment of noise impact is based on proximity of new runways to noise sensitive and visual sensitive species - but not people!

In addition the appraisal of the environmental effects arising from induced development and surface access has been excluded from this study. Even more remarkably the SERAS study excludes the costs of environmental mitigation measures and compensation to affected communities and companies adjacent to the development.

The Government has placed much emphasis on an urban renaissance. Integral to the Government’s vision is improving the quality of life in urban areas, and making them attractive places to live and work. Tranquillity, and a clean environment, are important elements of this. This is especially significant for the urban areas beside the Thames and Medway estuaries. Rapid growth of an airport in proximity to major urban areas is likely to jeopardise efforts to raise the quality of life.

A study carried out for the Seattle Tacoma Airport (Canada) for the airport developers, concluded:

‘Whether benefits are measured in terms of time saving to the travelling public, direct and indirect jobs (and income) created, or tax revenues generated, the vast majority of benefits go to persons who do not reside in the impacted areas that are the focus of this study. On the other hand, there is evidence that the adverse socio-economic impacts (costs) of the Airport are concentrated in the local areas. From the perspective of these areas, the Airport's benefits are far less than its costs’.

Furthermore the Government has emphasised the importance of Health Impact Assessment (HIA). We therefore contend that an HIA, both of the proposed airport construction or expansion and of the associated infrastructure such as roads, is essential before the proposals are developed any further.

Clearly noise assessment leaves much to be desired, with inappropriate selection of impact, inadequate measurement techniques, poor application and apparently little concern for people affected.

If the proposed Directive on Environmental Noise is to be successfully implemented, then the quiet areas of Kent must be protected from the noisy proposals, and areas under flight paths must have no increase in noise levels.

Equally if tourism is to continue to flourish in Medway, Kent and Essex, it must not be blighted by two planes roaring overhead every minute.

The Rt Hon. Michael Meacher, until very recently the Minister of State for Environment and Agri-Environment has said, ‘There is still a lot to do to make Britain a quieter place’. We agree and it is essential that the DfT supports the efforts of the Government to achieve that desirable result.

The consultation emphasises that it is up the aviation industry to find the solution to the problems. We agree and believe that if the DfT provides a clear framework of maximum permitted noise levels for all airports, then the industry will find the solutions. It is not appropriate for the Government to inflict additional noise on large numbers of the population; rather, it has a responsibility to reduce noise intrusion and protect the population from harm.

It is not the role of this report to reiterate the technical arguments linking climate change with the unconstrained growth in aviation, made so eloquently by the Royal Commission on Environmental Pollution and others. However, the disproportionate impact of aviation on the global environment cannot be ignored.

There is broad international consensus that the emissions responsible for climate change must be controlled. The United Nations Framework on Climate Change was agreed at the Earth Summit in Rio de Janeiro in 1992. Under this framework, all developed countries agreed to return their greenhouse gas emissions to 1990 levels by 2000. The UK is one of the few OECD countries to meet this target.

More stringent requirements were set in an agreement under the Kyoto Protocol, in which developed countries have agreed to limit their emissions of a series of the most important of the so-called ‘greenhouse’ gases. Under this protocol, signatory countries are expected to implement changes to either cut the total amount of greenhouse gases emitted, or to reduce the rate of growth in emissions of these gases. The European Union has set a legally binding target to cut emissions of the 6 most significant greenhouse gases by 8% against 1990 levels. The UK has agreed to cut its own emissions by 12.5%.

The UK aims to cut emissions of the most important greenhouse gas, CO₂, by 20%. The Prime Minister’s recent speech on Sustainable Development reaffirmed the UK’s commitment to a 60% cut in CO₂ emissions by 2050. In addition, the recent White Paper on energy policy outlined a commitment to ensure that the aviation industry is encouraged to take account of, and where appropriate reduce, its contribution to global warming.

The UK has instituted a domestic Climate Change Programme to deliver its Kyoto Protocol target. It supports energy and resource efficiency in industry, both domestically and in the support of overseas projects, and includes initiatives such as The Climate Change Levy, Carbon Emissions Trading, and Integrated Pollution Prevention and Control (IPPC). The latter is particularly relevant as for the first time it sets legal obligations on the efficient use of raw materials and of energy, with the aim of cutting waste and the emission of greenhouse gases. In the UK, regulations on Pollution Prevention and Control will be progressively implemented in an increasing number of industry sectors until 2007.

While emissions from domestic aviation are counted as part of the overall production of greenhouse gases by each participating country, emissions from international travel are not. However the Kyoto protocol (article 2.2) states that ‘… parties should pursue limitation or reduction of greenhouse gases from aviation bunker fuels, working through the International Civil Aviation Organisation’.

The failure of these agreements to impose stricter controls on the unconstrained growth in emissions from the aviation industry is incompatible with the Government’s stated commitment to reducing climate change

4.2.4. Aviation’s Contribution to Climate Change

Globally, aviation was responsible for about 145 million tonnes of carbon in 1996, comprising 2.4% of all anthropogenic carbon emissions – an amount roughly equivalent to the total carbon emissions of Canada.

Aviation contributes more CO₂ per passenger-km travelled than other forms of mass transport (200 to 300g CO₂ per passenger km). This compares to emissions of around 40g CO₂ per passenger km for high-speed rail). The more sustainable argument, therefore, is to encourage the development and use of the rail network before encouraging the expansion of short-haul and domestic flights.

More significant, however, is the nature and location of the emissions of CO₂ and other gases from aviation. Unlike surface modes of transport, the emissions from aviation occur in the upper levels of the atmosphere – where they can have greater impact than they would if the same gases were emitted at ground level. Oxides of nitrogen emitted from aircraft exhausts at altitude undergo complex interactions with atmospheric gases, the net effect of which is to accelerate global warming. The Intergovernmental Panel on Climate Change estimates that the total emissions from aviation have some three times the impact, in terms of enhancing the greenhouse effect, than that which would be expected from equivalent emissions of CO₂ alone.

The impact of the aviation industry on the global environment is disproportionately large. Its continued status as an industry exempt from the taxes and levies imposed on fuel use in other industries, in the UK and elsewhere, is incompatible with stated policies on climate protection. This is an incompatibility thrown into sharp relief by the Prime Minister’s commitment to lead the developed world in the adoption of climate change control measures.

Local pollution effects as the result of activity at and around airports can be significant, and impact disproportionately on those who live and work in the area. Aviation fuel, like all other fossil fuels, produces carbon dioxide and water when it is burnt. As the combustion process is never completely efficient, partial oxidation products such as carbon monoxide and oxygenated organic compounds are also produced and emitted, together with soot and other unburnt hydrocarbons. The high temperatures reached in jet engines also result in the formation of nitrogen oxides. The combined impacts of these pollutants significantly affect local air quality, with its consequent results on local health and amenity for both people and wildlife.

4.4.1Birdstrike Potential

Initial concerns raised at the prospect of birdstrike-induced damage to aircraft using an airport at Cliffe were confirmed with the recent publication of a study quantifying these risks. This study confirmed that an airport could not operate safely at Cliffe without a comprehensive and aggressive bird management programme. In practical terms this would require continuous patrols of the airport perimeter using fireworks, distress calls and shotguns. Even with the maximum possible mitigation and control measures, risks to passengers and craft using Cliffe would still be significantly greater than those at any other UK airport – many of which, indeed, perceive the risk of birdstrike to be sufficiently great to warrant the operation of their own bird management strategies. J F Kennedy airport in New York operates just such a policy, and between 1991 and 1997 used gunmen to kill nearly 10,000 birds a year. Despite this, they have only succeeded in reducing the population of gulls in the neighbouring wildlife park by a half, and the shooting programme continues. Birdstrike is already a high risk and cost to the aviation industry. In the USA its costs are estimated at $1.3bn per year, and it has resulted in the loss of 55 civil aircraft and 214 lives.

We are concerned at the scale of potential destruction to natural estuaries, inter-tidal mudflats, salt marshes, grazing marshes and agricultural land. The consultation document projects that an airport at Cliffe would take up an area of 26km². This does not, however, take account of the land surrounding the airport that would have to be ‘managed’, removing habitats that could support birds that pose a threat to aircraft, nor of the associated land take. To reduce the risk of birdstrike, land to a distance of at least 3.2km surrounding the airport has to be cleared of such habitats, significantly increasing the effective land-take.

We acknowledge that some of the land included in the 3.2km swathe required for bird management will provide space for the infrastructure and support services required by the airport. However we believe that the vast majority of this land will be difficult to use, as much of it is already waterlogged or prone to flooding. Indeed, the construction of the airport will exacerbate these problems requiring greater investment in the development of supporting infrastructure.

A large proportion of the existing land use in the area of Cliffe is recreational, used by birdwatchers, naturalists and ramblers attracted by the ecology and landscape. A caravan site, hotel and yacht club are examples of some of the commercial ventures that make full use of the environmental uniqueness of this area, working in harmony with rather than opposition to it.

Many of the local businesses are based on recreation and tourism, and are unlikely to survive the impacts of construction followed by the constant aircraft noise, accompanied by the need to maintain a bird-free environment.

Much of the Thames Estuary and Marshes are both a Special Protection Area and a Ramsar designated site (a wetland of international importance). As such they are – or should be – afforded high levels of legal protection. Estuaries are unique environments of constant natural change. The proposed airport stands to destroy centuries of evolution of coastal landscape, and not just on the area directly under the built airport. The proposed airport boundary runs across the Ramsar, SPA and SSSI land of the Thames’ south bank. An area of 4.7km² of Ramsar-designated land would be lost to the airport. What would be left of the immediately surrounding area would become redundant in nature conservation terms because of the need to control bird populations for the safety of aircraft. The raising of the land to accommodate the airport safely, as well as the noise and other pollution caused, is likely to upset the whole balance of both the Thames and Medway estuaries and marshes, which run around much of the North Kent cost.

Mudflats and areas of salt marsh, both highly productive ecosystems, are able to support large numbers and high diversities of invertebrates and bird species and are linked to fish spawning rounds. They feature prominently in the area proposed for the new airport at Cliffe. They make ideal breeding grounds for wildfowl, and are an important overwintering habitat for many species. In addition, grazing marshes and agricultural land both support many species of birds and other wildlife around Cliffe. The destruction of these habitats for the construction of the airport would be compounded by the need to render much of the rest of the surrounding area unattractive to birds, to minimise the risk of birdstrike to aircraft and passengers.

Commissioned by the Government, the North Kent Marshes Ecological Study: Phase 1 Report suggests that, as a guideline for environmental compensation, three times the area lost should be replaced elsewhere. It has suggested that land is available between Reculver and Birchington on the North Kent coast, extending across marshes south up to the existing Stodmarsh Special Protection Area, and east along the valley of the River Stour up to Sandwich. We contend that this is highly questionable.

This land take is a total area of approximately 35km² – which is far short of the amount lost at Cliffe considering only the buffer zone around the airport, let alone the transport links or support services. It is, however, a very large area that effectively cuts Margate and Ramsgate off from the rest of Kent, preventing their development to the west. This compensation scheme envisages creating mudflats, at an estimated cost of £230m - a figure not included in the costing of Cliffe Airport.

The consultation document only allows for 1.6 km2 of land for support services at Cliffe, based on a projected indirect workforce of 18,000. Again, we believe this to be a gross underestimate. Heathrow, less than half the size of the proposed airport at Cliffe, has 108,000 local indirect employees. Thus, even accounting for labour saving practices and economies of scale, it is likely that an airport at Cliffe could require well over 100,000 employees. We do not believe that the land take or infrastructure requirements required for this workforce have been adequately considered. Proposals for additional housing in the Thames Gateway area, to serve the existing projections for the population of the South East, do not take the development of an airport at Cliffe into account.

The effect of an airport at Cliffe on tidal flow and flooding has not been considered by the consultation paper, other than a two-line paragraph (11.22) which states ‘it is likely to increase the risk of flooding elsewhere in the peninsula’. The complacency of this statement is breath-taking.

We understand that the Environment Agency (EA) is carrying out a detailed and comprehensive review of the flood defence scheme for London and the other areas in the Thames and Medway estuaries. There is a grave danger that if the DfT were to make a decision to proceed with the Cliffe Airport development prior to receiving the EA report there could either be wasted cost or the possibility of severe flooding both in London, North Kent and South Essex.

When considering the effects of tidal flow, the proposed development at Cliffe can not be considered in isolation. A major development is proposed at Shellhaven on the north bank of the estuary. Combined, they may have a major impact on tidal flow and flooding.

The marshlands and mud flats of the Thames and Medway estuaries have the effect of absorbing high tidal flows. The importance of these natural phenomena as protection for those living in the low-lying areas is substantial. The development at Cliffe would not only destroy an area of 26km² at present used for flood absorption, but would considerably add to the problem by creating surface water which would immediately drain in to the Thames estuary. This would exacerbate the flooding problem.

During a recent planning inquiry into a development near Faversham, CPRE Kent requested the attendance of a representative of the EA, due to their concerns about flooding. On cross-examination, the EA representative revised upwards all his forecasts on the increase in water levels. He also stated that there was a risk of a tidal bore which could go up Faversham Creek and cause flooding, due to the embankments built to protect low-lying areas on either side. This evidence, suggests the strong possibility that the airport development at Cliffe, especially when considering its angle to the tidal flow, is capable of causing a Thames bore which could overflow the Thames barrier and flood large areas of London, especially Woolwich.

We have already learned, the hard way, of the effect of flooding on housing developments in Kent which may have been avoided had a comprehensive study been carried out. Before any decision to proceed with the Cliffe Airport development is made, a full investigation of the effects of a tidal flow and flooding should be carried out, if we are to avoid a major disaster.

We understand that the vicinity of Rochester and the Medway Towns is the fourth most polluted area in the England. At a recent planning inquiry into planning permission for a new cement works at Halling in the Medway valley, CPRE Kent submitted evidence of the level of respiratory illness in the area. It was submitted that this development would cause an extra sixteen premature deaths.

Much has been said about new aircraft producing lower levels of carbon dioxide and other pollutants. However the research programme on these engines is as much as ten years behind target. In addition there is little encouragement to progress any faster as aviation fuel is not taxed. It was only when the Government introduced tax advantages for those using less polluting fuel and engines in road vehicles that any advance was made.

Aircraft are a significant source of carbon dioxide pollution. Considering the present levels spread across Heathrow, Gatwick, Luton, Stansted and City airports it can be estimated that in the area of Cliffe it will increase by about one-third. This means that a level of about half the total pollution due to aircraft on the South East would fall on this small area and consequently make it easily the most polluted in Britain. The cost of medical treatment has not been included in the calculations. The cost to the people of North Kent in terms of respiratory illness, especially amongst children, and in premature death could be considerable. CPRE Kent does not believe that this is acceptable.

Another potential hazard specific to the proposed development at Cliffe is the S S Montgomery, a wrecked ammunition ship in the Medway estuary. This wreck is inspected on a regular basis as it is considered dangerous. Until recently frogmen carried out personal inspections but, as this is now considered too unsafe, a remote monitoring system has now been adopted.

The S S Montgomery is well known as a hazard by vessels using the Medway, who are advised to give the wreck a wide berth; any extra movement could result in an explosion. Before any decision is made on the future of Cliffe a proper investigation and report should be undertaken in order to evaluate the risk posed by this wreck.

CPRE Kent believes that the DfT’s approach to fostering the development of the aviation industry is unsustainable and places too little regard to its adverse impacts. A more considered approach to its growth could result in more efficient and cost effective use of existing runway capacity, and would obviate the need for the massive expansion that the DfT tells us we need.

Crucially, we believe that the projections for the unconstrained growth of the aviation industry over the coming decades are hugely over-estimated; the aviation industry is in crisis and its decline will, at best, take some years to reverse. We do not believe that there will be sufficient air traffic by 2030 to make additional runway capacity necessary; any growth can relatively easily be accommodated within the existing available infrastructure.

The aviation industry is acknowledged as the cause of disproportionate environmental damage, and its failure to conform to the ‘polluter pays’ principle which underpins all other industries is a situation which cannot continue indefinitely. We add our support to the call for a fairer pricing structure which acknowledges the relative impacts of aviation over other forms of travel.

We believe that the growth should be managed, and that together with external factors can result in a situation where no new runway capacity needs to be built.

The options proposed for the expansion of air capacity in the South East will result in massive reduction of the quality of life for many hundreds of thousands of people, the destruction of previously unspoilt land, the destruction of wildlife, the loss of architectural and cultural heritage and a significant increase in local and global pollution.

It would be contrary to the responsibilities of the Government to allow expansion on the scale envisaged in this consultation.