APPENDIX III

THE FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UK – SOUTH EAST

QUESTIONS FOR CONSULTEES - THANET DISTRICT COUNCIL RESPONSE

SECTION 1 – HOW MUCH CAPACITY SHOULD BE PROVIDED?

Q1 Should new airport capacity be provided in the South East over the next 30 years and, if so, how much? What are the main reasons for your answer and how does it measure against the environmental, economic and social objectives of the Government’s strategy for sustainable development?

A1 It is the Council’s view that airport capacity should be developed over the next 30 years to match the forecast growth in demand. However, the situation should be reviewed and adjusted to meet any change in circumstances that would occur over this period, particularly in relation to the nature (long haul hub or point to point) of the growth in demand. The Council considers that the air industry contributes substantially to the economic wellbeing of the country and failure to respond to market growth could undermine the economic position of the country as a whole. Improved technology, particular in the development of quieter aircraft and environmental controls, should enable the achievement of the Government’s strategy, whilst maintaining the appropriate balance on environmental concerns, notably noise.

Q2 Should the Government aim to maintain at least one large hub airport in the South East? Is a second hub plausible, and if so, should Government seek to promote one, and what would it need to do to achieve this?

A2 It is the view of the Council that sustained economic growth of the UK economy is best achieved through the development of a new international hub if proved to be needed, to support Heathrow. Heathrow has reached the level of its environmental acceptability and the Government needs to seek methods to encourage airlines to move to a second hub airport. This can only be achieved by providing financial advantage to those who move by way of tax/charging advantage over those who wish to remain at Heathrow.

Q3 Are there any benefits of aviation to passengers, the aviation industry or the wider economy that the Government should aim in particular to secure through its airports policy? Are there any drawbacks it should aim to avoid?

A3 The principal benefit of a successful hub airport to the wider economy is the scale of operations and the quantity of international routes that it is possible to achieve. However, a balance has to be drawn between an over dominant single airport (such as Heathrow) and spreading the development opportunities that arise in association with air transport to a wider area. The over dominance of Heathrow has been largely responsible for the overheating of the economy of the area to the west of London with consequential major environmental problems. This situation has to be avoided in the future in the development of a second hub and by the spreading of air transport development opportunities to a wider UK market.

Q4 Should the Government seek to ensure that the potential employment benefits of aviation growth are spread to those people and localities which are most in need of such benefits? If so, what should it do to achieve this?

A4 The Government should ensure that the potential employment benefits of aviation growth are spread to as large a number of people and communities as is possible. There are many areas of the United Kingdom which are in need of economic development and regeneration. The Government policy should develop a balance between the need for hub airports, the growth in regional airports and making the most of existing capacity. It is not acceptable that the current situation where Heathrow is totally dominant should be permitted to occur again and regional airports should be permitted and indeed encouraged, to grow to the level of their capacity and of their ability to attract business. Subject always to the environmental balance that has to be achieved between economic growth and environmental concerns.

SECTION 2 – WHERE TO PROVIDE ANY NEW AIRPORT CAPACITY?

Q5 To which criteria should the Government attach the most and the least weight in reaching decisions about the location of any new capacity, and why?

A5 Inevitably, this must be a subjective decision and on sustainable grounds no one factor should be weighted more than another. The issues are economic wellbeing, both for the UK economy and to facilitate regeneration in deprived areas, an overheating economy close to Heathrow/M4, balanced against the environmental concerns of those living close to the airports, particularly for those who suffer noise pollution, and the environmental damage that airport development can do to sensitive areas. Assessment can only be based on a balance of impacts on each site. It is the Council’s view that based on that balance, Stansted offers the least damaging solution environmentally and economically, for substantial growth in capacity.

Q6 What are the relative merits of these alternative combinations of possible airport development as set out in Chapter 14?

A6 It is the Council’s view that the most attractive combination for the development of airport capacity is to make the maximum use of existing runways in the South East whilst at the same time earmarking Stansted as a potential new hub with up to three new runways. Heathrow should be developed to the level of its existing capacity – without additional runway capacity. The Council considers this combination to provide the best balance between economic improvements to the UK economy whilst limiting the environmental impacts of increasing airport capacity in the South East.

Q7 Giving reasons for your answer, which combinations do you prefer and which do you not favour?

A7 The Council considers that the combination of incremental growth of Stansted and maximum use of existing capacity provides the appropriate balance of economic growth with a limitation on environmental damage. Stansted has the potential to grow substantially without affecting either a large population or an internationally important environmentally sensitive area and, in combination with allowing and encouraging existing airports to expand to their potential (given any environmental concerns) would, in the Council’s view, provide the most acceptable combination.

Q8 If you think either Cliffe or Stansted should be developed as a hub airport, should the Government take action to ensure such development can be financed and subsequently fully utilised and if so what form should any action take?

A8 It is the Council’s view that if proved by review of demand, Stansted should be developed as a hub airport. Cliffe should not.

Clearly, no development proposal to create a hub airport will be a totally acceptable solution and all proposals are likely to bring representations against further development. It is imperative, therefore, that the Government develops a time limited approach to the development of additional airport capacity such as to avoid protracted public inquires and legal challenges. This can only be achieved by developing airport capacity by Act of Parliament which, having heard representations, enables Parliament to make the final decision, rather than through a process of interminable public inquiries. However, any development should be undertaken on an incremental basis, with review before the next stage of development.

Other South East airports (Chapter 12)

Q9 Should the Government encourage the development of smaller airports to meet as much of the demand as they can attract?

A9 Yes, smaller airports can share in the economic development associated with the development of airport capacity and many of the smaller airports in the South East are located in areas of relative economic and social deprivation and would benefit considerably from Government encouragement to develop business opportunities. (Such as Southampton and Manston.) Equally it is the Council’s view that point to point service growth experienced in recent years will continue and smaller airports are capable of meeting a substantial part of this market without creating new capacity.

Q10 Should support be given for a specialised low cost/freight and maintenance facility at Alconbury?

A10 Alconbury has the advantage of 24-hour operation, but in all other respects offers no advantage over Manston - both are equidistant from London. For many companies in the area south of London, Alconbury is a long way, particularly when there are other alternatives available such as Manston. Alconbury may have a position to play as a 24 hour operation, specialising in packages and parcels or to a catchment area to the north of London, but Manston should be considered as the alternative and promoted accordingly and equally.

Q11 If so, what conditions, in broad terms, should be attached to this support?

A11 Alconbury is particularly distant from the core activities of the South East Region, particularly the area to the south and east of London and is perhaps better related to the development of airport activities in the Midlands. The Council’s position is that development should be encouraged at Alconbury, particularly for 24-hour usage, but not at the expense of other areas and that Manston should attract equal attention.

Q12 What views do you have about the six sites identified in the SERAS study as having the potential to cater for the demand for Business and other General Aviation?

A12 Given that the majority of business and general aviation activity is related to the availability of access to London, the Council has no particular position in respect of the six sites identified for this purpose.

Freight (Chapter 13)

Q13 How far should the Government make specific provision for the air freight sector in its decisions about future airport capacity in the South East? What might this involve in practice?

A13 In order to make the most of the available capacity, as much airfreight cargo as is possible should be diverted from the principal London airports. A key factor in the development of airfreight is the availability of business parks/industrial land in the immediate vicinity of the airport and in that respect Manston offers a substantial opportunity, particularly in relation to any source of or destination, for freight operations South of London. The Council, therefore, considers that the options should consider issues in relation to the development of freight services and that as stated above that Manston should be actively promoted for that purpose.

SECTION 3 MANAGING THE IMPACTS OF AIRPORT GROWTH

Q14 Are there any specific conditions that you feel should be attached to any or all of the airport options described in Chapters 7-11?

A14 As in the development of all airports a balance has to be struck between the needs to develop the airport for the economic regeneration of the area, against the environmental concerns of those living close to the operation. This is a matter that must be resolved locally through negotiations between the surrounding local authorities and the airport owners and developed through best management practice.

Of most concern to those living close to an airport are issues related to aircraft noise and the potential for disturbance, particularly during night flying operations, if they exist. In order that one airport is not disadvantaged by the actions of another the Government should take a position in relation to all airports, above a reasonable size, in respect of night-time flying operations, even if this does mean an increase in costs for airport operators and airlines.

Q15 Are there any impacts reported in the chapters on individual airport options that you consider unacceptable?

A15 The environmental impact of the development of Cliffe is unacceptable as is the impact it would have on the economic regeneration of both East Kent and South East Essex.

Q16 How can local noise and air quality impacts in particular, best be reduced, controlled and mitigated?

A16 These matters are best dealt with locally in relation to legally enforceable planning agreements, such as the use of Section 106 Agreements on a planning permission, at which time the local authority and the airport operator can negotiate the appropriate balance between economic development and environmental concern.

Noise controls (Chapter 16)

Q17 What are your views on the following points on the control of noise impacts:

  • Do you think that caps on the size of noise contours are the best way to determine a noise limit for an airport? If not, what other limits might you suggest?
  • If you agree with the concept of contour caps, what size of noise contours might be desirable and feasible for each option?
  • How do you think a contour cap might be regulated and enforced?

A17 The Council considers that noise contours are the best way to limit the impact of noise on the local community. The Council has negotiated a Section 106 Agreement in relation to the use of the site at Manston, which establishes a base contour for the airport against which each year’s actual performance is mapped and any increase in the area of the contours results in a substantial fine for the airport operator. In order not to remain static, however, there is also built into the legal agreement a requirement for a percentage reduction over time in the base contour, with fines to the airport operator if this is not achieved.

However, the Council is conscious that every airport is different and operates under a set of different circumstances and, therefore, Section 106 Agreements would need to be negotiated to meet the particular circumstances of each site. However, the general principles of a decreasing noise contour area, should be a requirement, particularly given the improvement in engine and airframe design.

Noise mitigation and compensation (Chapter 16)

Q18 What views do you have on the following possible measures:

  • Should any residential property which suffers an increase in noise of 3dBA or more as a result of any of these options, and which would be exposed to a noise level of 63dBA daytime or more, be eligible for acoustic insulation?
  • Should acoustic insulation for households be extended to other noise-sensitive buildings not normally eligible, such as schools and hospitals, depending on detailed circumstances?
  • Should those eligible for insulation be given the choice of either having the insulation work done or accepting a cash payment of an equivalent amount?
  • Should assistance with relocation expenses be offered to households subject to very high levels of noise (such as 69dBA or more)?
  • Should offers be made to purchase those properties which would be subject to both a very high level of noise and a large increase in noise?
  • Should cash compensation be offered to those households suffering a significant increase in noise to a level greater than 57dBA but less than 63dBA – and therefore not qualifying for insulation?

A18 All residential properties which fall within the 63dBA contour for any airport, should be eligible for acoustic insulation.

In the Council’s view there should be specific requirements for acoustic insulation for those noise sensitive buildings, such as schools and hospitals that are located within an acoustic footprint of 57dBa or higher. The Council does not accept the principle of a cash payment in lieu of acoustic insulation as the sole purpose for providing the insulation is to overcome objections to noise nuisance. It cannot be acceptable that the present occupant takes the cash payment without making the necessary improvements to the property.

It is not unreasonable in the Council’s view for existing households suffering very high levels of noise (69dBa and above) to be offered the option of relocation expenses, given particularly the growing situation with airport safety zones where aircraft noise of such levels would be likely to be very close to a runway and, therefore, also to be subject to safety concerns. However, such acquisition and relocation should be relatively rare.

Cash compensation should not be offered to households in the 57-63dBa range. If they do not quality for insulation there can be no justification in a cash compensation.

Night noise (Chapter 16)

 

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