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DETAILED COMMENTARY ON THE ENVIRONMENTAL IMPACT STATEMENT FOR LONDON MANSTON AIRPORT 1 Description of the Development 1.1 The requirement of the Section 106 Agreement was to identify the Environmental Impact of the planned levels of development for the period of 5, 10 and 15 years. Such levels of development were to have been identified in the Masterplan documents submitted to the Council earlier in 2001. Unfortunately, the submitted Masterplan document was less then robust in its handling of the suggested levels of development to be planned for. Consequently, in advising on the development of the EIS, the Council has had to insist on the development levels associated with the timeframes identified being revisited to ensure that the base information was available on which to formulate the EIS document. 1.2 Whilst the base development information has been more robustly calculated, it is still somewhat obscured by all sorts of caveats, not least the particular period in which the EIS is being developed, when Government Policy in respect of the future of Aviation is far from clear and in the light of the events of September the 11th, 2001. 1.3 Table 4, page 10, indicates the growth in traffic on which the Environmental Impact Statement is based (on figures produced by the owners, but which the consultants consider are “achievable”). These indicate the following: 2005 - 1,467,140 passengers and 250,000 tonnes
of cargo 1.4 Given the uncertainty of the market and of Government Policy in respect of the future of the existing London Airports, and given the DLTR’s projection of the future of air traffic movements in the period from now to 2030, the figures identified in total do seem achievable provided the company has identified a robust Business Plan and Investment Strategy sufficient to capture an appropriate market share. 1.5 However, whilst the Council is supportive of the figures identified for development, in the medium to longer term, there are some real doubts about the timescale for delivery of such levels of development. Achieving almost 1.5 million passengers and 205,000 tonnes of freight by 2005 from a starting position at the end of 2001 of virtually no passengers and less than 40,000 tonnes of freight appears extremely optimistic (particularly in the development of passenger services). 1.6 Nevertheless, any doubts in relation to the timescale of achieving the development identified does not invalidate the environmental considerations, merely the timescale during which they will need to be addressed and could, therefore, be considered to be ‘worst case’. 1.7 Based on the information supplied for the years 2005, 2010 and 2015, that level of development will result in:
1.8 No information is supplied as part of the study to indicate the types of aircraft envisaged, or load capacity on which this information is based. 1.9 However, it is based on a 16-hour day (0700 - 2300 hours). In respect of night-flights the document has the following statement to make: “LMA has no plans for night flying and all aircraft dependant developments and their associated environmental impacts are based on a 16/17 hour day (0600-2300 hours).” 1.10 In order to meet the expected growth in passenger and freight traffic a number of developments are anticipated to be undertaken as phased development. An initial phase of extension of taxiways and apron surfaces has clearly received planning permission and this work is substantially complete. New radar facilities, additional instrument landing systems and additional warehousing are proposed. The other major development proposed is the construction of a new single storey passenger terminal building with associated car parking and aircraft standing areas. This is envisaged as a phased development. The first phase before 2006 being a new building of some 17,000 square metres. A second phase in 2010 at 43,168 square metres with a third and fourth phase being added in subsequent years such that in 2020 the terminal building would be 165,000 square metres. The first phase is envisaged to be capable of handling 1.5 million passengers per year. 1.11 In order to meet this development timescale work would be required to start on preparing the background information and the formal Environmental Impact Statement for such a development proposal if the intention is as stated, to submit a planning application, for at least the first phase of the passenger terminal development, during the middle part of 2002. Much more detailed work will be required on the development of not only a more robust Environmental Impact Statement, but substantially more work in the way of Traffic Impact Assessments and of the Economic Justification for such development to be undertaken, if the formal consultees are to be encouraged to accept the findings and not make negative representation to the planning application. 1.12 Clearly, the development of the airport passenger and freight traffic along the lines envisaged will have substantial impacts on the surrounding areas in terms of surface transport to and from the site. Forecast traffic levels associated with the levels of development envisaged would generate the following traffic movements in a 16 hour day:
1.13 Whilst roads to and from the M25 by way of the A299 and M2 are generally of good quality, many of the local roads are of a much poorer quality and will require substantial improvements before the levels of development envisaged can realistically take place. 1.14 Equally, if the level of development envisaged takes place the parking requirements as identified in the document provide for the following:
1.15 For comparison this would suggest that in 2010 short term car parking would require a multi-storey car park (three floors) taking about an acre of land adjacent to any potential terminal building, whereas long term car parking would necessitate some 52.4 acres (21 Hec) of surface car parking. Whilst this may be suitable on a short-term basis, it would not be desirable to use valuable, operational land for this purpose in the longer term. 2 3 Aircraft Noise and Mitigation 3.1 Aircraft noise is one of the significant environmental impacts from airport development and it represents one of the main concerns of local residents around the airport. 3.2 Whilst generally noise output from newer and better civilian aircraft can be reduced very significantly through technological advances in engine and airframe design, increasing numbers of aircraft will obviously cause local concern. In the case of LMA much of the flight path is over the sea or over relatively sparsely populated areas. However, the final stage of the principal approach from the east is over land and over the densely populated town of Ramsgate. It is not surprising, therefore, that noise, and in particular concerns about night flights, has caused the greatest amount of concern for local people. 3.3 Manchester Airport has acted as consultants to the owners of LMA to produce noise contours for the years 2000, 2001 and 2005. 3.4 Given the importance of the issue of aircraft noise in relation to the development of the airport and the impact that this issue has on all of the other matters contained in the EIS, it is disappointing that this section of the document does not include a full background explanation of measurement practice, the units used, standards applicable, modelling construction and uncertainties contained within the model and base data and some explanation of the monitoring systems at the airport. 3.5 The only real information provided is contained in the three noise contour maps (which are actually quite hard to read and, therefore, to make any meaningful comparison). However, what is even more surprising is the lack of information in respect of the basic assumption and forecasts which underly how these contour maps were constructed. The 2000 contour map and 2001 contour map are presumably based on actual information about the exact nature of the aircraft using LMA in those years. The 2001 contour appears to have extended the noise footprint of the airport to both the east and the west of the runway. However, there is no explanation as to how this occurred or to what change in circumstances (such as the types of aircraft changing) may have brought this alteration about. It is also understood (although it is not referred to in the document) that the actual data on which these maps have been constructed was drawn from a three month summer period which it is understood is an industry norm to represent the busiest period of the year. However, LMA does not operate as perhaps other holiday flight airports do and the busiest time of the year is not the summer, but appears to be in a period either side of Christmas, when freight business peaks. (Although it is accepted that this is likely to change as further business develops.) 3.6 It would have been more useful if the information contained on these two noise contour maps had been clarified to indicate that they were a reflection of the exact usage of the airport throughout the two years concerned, with an explanation as to how the variation occurred. 3.7 The predicted 2005 noise contour (again very difficult to read) appears to indicate a reduction in the noise footprint from both the 2000 and 2001 actual contours, but again without any explanation as to why that might occur given the substantial increase in the number of aircraft movements envisaged by 2005 (an increase from three flights to 50 flights per day). Again, no information is given as to what assumptions concerning the types and characteristics of the aircraft likely to be involved in the use of the airport in 2005, have been given. Does it, therefore, assume that all aircraft using London Manston Airport in 2005 have got substantially quieter? 3.8 As noise is such an important issue in the public’s consideration of the development of Manston Airport and whilst the use of Leq 16 hour contours may be helpful in deciding the total amount of noise affecting the surrounding area, it provides no indication of the likely peak noise when aircraft pass directly over the centre of Ramsgate (for example). Average noise over a 16-hour period, whilst the industry norm, gives no indication to the public of peak activity, which will increase considerably with the number of air traffic movements. At present there is insufficient information to enable a rational judgement to be made on the level of disturbance that will occur to those living directly under the flight path in terms of peak events, and given that such events are going to increase in number then the level of information is somewhat lacking. Prior to considering any major planning application which might result in substantially increased air traffic movements, the Council will expect to see a consideration of peak noise activity and its effects, as well as average noise activity. 3.9 It is noted that in accordance with the requirements of the Section 106 Agreement the prediction of the development of air traffic movements is over a 5, 10 and 15 year period, however; it is noticeable that the predicted noise contours are only provided to 2005. Clearly, in the minds of many members of the public a substantial increase in the number of flights a day from three in 2001 to 50 in 2005 to 98 in 2010 and to 106 in 2015, will represent a greater intensity of noise disturbance and in the minds of many of those not familiar with the way noise contours are constructed, there will be an assumption that a trebling of activity will result in a substantial increase in the area of the noise footprint. In order to provide the public with more information it would have been more satisfactory if predicted noise footprints had been given for the years 2010 and 2015, as well as for 2005. Even given that there would have to have been a substantial number of caveats and assumptions concerning the predicted nature of the aircraft using the airport at those dates. Nevertheless, some unnecessary fears concerning the future noise impact could have been allayed if this information had been provided. The Council will, therefore, expect noise contour maps to be produced for 2005, 2010 and 2015. 3.10 It has to be said that the interpretation of the noise information contained in paragraph 5.6 of the Environmental Impact Statement is somewhat lacking and the various arguments made concerning disturbance as a result of noise have little technical support. 3.11 There is no disputing the fact that air traffic movements are noisy and are likely to lead to disturbance for the local community particularly those closest to the runway. In that respect the urban area of Ramsgate is undoubtedly going to be affected by noise resulting from aircraft arriving and departing on runway 10. 3.12 A balance has got to be struck between the economic development benefits of airports and the likely noise and disturbance to those living close to the runway, particularly when the population numbers affected are as substantial as they are in the case of Ramsgate. One cannot prevent noise disturbance, but one can mitigate sufficiently to reduce the level of disturbance to the minimum necessary. In that respect, a number of issues need to be addressed more fully in any revised document with clear statements concerning the future management of air movements to reduce disturbance to the residents of Ramsgate particularly. 3.13 At present there are no restrictions on night flights at the airport, but the airport owners have voluntarily entered into a legal agreement with the Council that prior to any regular night flights being implemented a Night Flying Noise Policy will be agreed with the Council, at least six months before the commencement of such flights. 3.14 The airport has indicated in the Environmental Impact Statement that they have no plans for night flights and that the development of the airport envisaged is formulated on the basis of a 16 hour day with no flights past 2300 hours at night or before 0600/0700 in the morning. Clearly, the more information and clarity that there can be in respect of the future use of the airport during ‘night-time hours’ the more confidence the local community will have in being able to avoid the problems experienced at other large airports, where sleep disturbance is a problem. 3.15 It is inconceivable that Manston would ever develop a second runway. It, therefore, follows that final approaches to and from the existing runway are unlikely to change from the current flight paths. The relationship of Ramsgate to the end of the runway is a given position and there is no opportunity to vary flight paths to avoid overflying Ramsgate for planes landing and taking off on runway 10 (that is flying in and out from the east). To the west runway 28 is far less constrained by the proximity of centres of population. The current departure route on runway 28 takes aircraft to the west and to the north between Birchington and Herne Bay over a relatively unpopulated part of the District. Planes landing from the west pass over areas of Herne Bay, but at substantial height. There may be a case, therefore, for the airport operators to reconsider the alignment of flight paths to the west and to examine, at this stage of development, if the flight paths are those most appropriate to minimise disturbance. Clearly, a significant increase in the number of flights per day will have a marked impact particularly on those living closest to the runway in the Ramsgate area. 3.16 The greatest impact of aircraft noise is on the use of runway 10 when aircraft are either landing or taking off to or from the east over Ramsgate. (Whilst there are obvious concerns for smaller communities and more distant communities to the west, relatively speaking, substantially more of the population is affected by low level aircraft landing and taking off to and from the east.) The Section 106 Agreement requires the airport to operate where possible on the basis of 70% of departures being to the west. However, this is often frustrated by weather conditions and by either commercial or pilot preference. Whilst clearly wind conditions have a bearing on the choice of take off direction modern jets are not as susceptible to wind condition as their predecessors and there is scope for consideration as to whether there needs to be a more strongly enforced regime of both landings and departures for heavy jets, to and from the west and a substantial managed reduction on departures and landing to and from the east over Ramsgate. This could reduce substantially the impact of aircraft noise for those most affected. 3.17 Noise Abatement Procedures have already been agreed between the Council and the airport operators and these should be reviewed regularly to ensure that heavy jet aircraft using LMA do so in such a way as to provide the minimum disturbance to the local population. The Noise Abatement Procedures agreed appear to be working satisfactorily, however; without accurate track keeping and enforcement of the Noise Abatement Procedures. such efforts will be frustrated. The airport needs to be more active in policing aircraft to ensure that they comply with local noise procedures. To that end, before any substantial increase in aircraft numbers are agreed, such as might arise from development of a new terminal, the airport operators should invest in the appropriate tracking equipment to ensure greater compliance from pilots using the airport. 3.18 An Instrument Landing Systems (ILS) has been installed for aircraft landing on runway 10 from the east, but no such similar equipment has been installed for aircraft landing from the west. An important component for the avoidance of undue noise from aircraft landing at the airport is the adoption of “continuous descent approaches from 6000 feet” which helps to avoid the variation in noise volume on approach that can often be very disturbing to residents. ILS will make the achievement of such continuous descent approaches that much easier and, therefore, make for a more acceptable landing procedure for local residents, particularly those to the west. Again, no substantial increase in air traffic movements should be agreed without the installation of full ILS equipment and more strict adherence to ‘continuous descent approaches’. 3.19 Consideration should also be given in consideration of mitigation to the development of a robust noise insulation programme to protect those residential properties most affected by aircraft noise as part of the development proposals. Currently, this will be required for a limited number of properties closest to the airport. Some further thought on the impact of noise, particularly peak noise, should properly be reflected with the development proposal of a major planning application to ensure that those most affected by low level aircraft noise have the possibility of noise insulation being considered along with the development proposals. 4 5 Surface Transport 5.1 There are essentially three principal concerns associated with the development levels envisaged. A) Strategic traffic generation matters B) Local traffic generation matters C) Parking and vehicle handling at site. A Strategic Traffic Generation 5.2 Road access to North Kent/London via the A299/M2 is generally good and likely to remain so for the foreseeable future, despite a major build-up of traffic to and from LMA. However, in line with Government Policy, a greater effort has to be made to achieve a modal split, which is less in favour of the use of the private car. In strategic terms that means greater encouragement of the use of rail and coach services for access to LMA. It is unlikely that passenger traffic will build to such numbers as to warrant commercial consideration of the provision of a dedicated rail access directly to LMA in the first phase of development. In the meantime, much more definite proposals for the use of the existing rail station/coach services, have to be formulated before consideration can be given to a proposal for substantial development, such as a new terminal building. 5.3 It is extremely regrettable that the Green Transport Strategy, required as part of the Section 106 Agreement, has not yet been produced and has, therefore, not been taken account of in the documentation. Clearly, any such consideration of a change in modal split will have substantial bearing on the likely traffic generation figures currently envisaged. On that basis, as a matter of urgency, and well in advance of the likely submission of any substantial new development at LMA, a piece of consutlancy work is required by LMA in the way of a Traffic Impact Assessment and Strategy related to the development levels proposed which will determine the full extent of traffic impacts that will result through airport development and offer phased solutions. Central to the consideration of that work will be a realistic attitude to changes in modal split and the implementation of the Green Transport Strategy policies. B Local Traffic Generation 5.4 The principal concern locally is in respect of the impacts of a substantial increase in the volume of traffic on local roads, particularly those to the north of the airport, which are substandard even for existing traffic and the potential impact of a substantial increase in the volume of traffic passing through local villages such as Manston and Acol. 5.5 The growth in development of the airport as it affects these issues relates principally to the access to services by local people, but perhaps more importantly the access from the surrounding area to what it a potential major employer at the airport. 5.6 Again, it is extremely important, particularly in relation to the movement of employees that a successfully operated Green Transport Strategy is in place and clearly this will have a major impact on the volumes of traffic on surrounding roads. Encouragement/incentives through a Green Transport Strategy for journeys to and from work to be made other than in a private car will clearly be an important issue in the consideration of any substantial planning application. 5.7 However, as the existing road system, particularly to the north of the airport, is already considered to be inadequate, any development proposals will have to be accompanied by proposals by the airport owner for a phased scheme of road improvements/road closures such as to reduce the impact of development on the surrounding villages and to ensure that local highways can cope with the envisaged volumes of traffic. Any proposal for the substantial growth in airport traffic is likely to necessitate at least the partial closure of the B2050 to avoid undue damage to the environment of the village of Manston. Again, specific proposals by way of closures and mitigation measures will be required as part of the consideration of any major planning application. C Parking/Vehicle Handling at Site 5.8 Based on the development proposed substantial levels of car parking, both long term and short term, are envisaged in the document. Clearly, car parking will remain a major land use in the development proposals and, until the point that a dedicated rail access is commercially viable, the level of car parking is likely to be higher than at other equivalent airports. However, irrespective of the availability of direct rail access, the amount of car parking proposed in the Environmental Impact Statement will have to be scaled down in relation to any agreed Green Travel Strategy and clearly the figures envisaged in the current document do not sufficiently reflect that approach. A balance has to be struck between encouraging the use of other modes of transport and the commercial necessity of providing adequate car parking to grow the business, at least in the formative years, (particularly so in the absence of alternative means of access). 5.9 Land use for car parking is in some respects an unproductive use of available land, particularly of land within the airport perimeter, which has a much greater potential for operational use. 5.10 Whilst clearly it is imperative that short term parking/set down/pick up facilities are all closely associated with the construction of any terminal facilities, long term parking can take place at distance. Whilst there may be a short term requirement for the use of land within the operational perimeter of the airport, for long term parking, there is undoubtedly a case to be made in the long term planning of the airport for off site long term car parks, a) to ensure that operational land is maintained for that purpose and that the growth of the airport is not impeded by using operational land for other purposes which might constrict the potential for growth of the airport in the longer term. 5.11 It is the view of the Council that prior to the submission of any major application which is likely to lead to substantial growth in passenger traffic, such as a proposal for a new terminal, a substantial study of all of the above issues needs to be undertaken to establish a clear and agreed Surface Transport Masterplan for the airport which will establish phases of development with specific surface transport and infrastructure improvements, such that the two proceed in parallel. 6 7 Water Quality 7.1 One of the problems with the current airport facility is that it has been in operation as an MOD facility for a substantial number of years prior to its conversion to a civil airport and has thus been outside of the normal regime of regulatory control. As a consequence, very little is known of the impacts that have occurred in the past and which may still occur in respect of potential contamination of the underlying aquifer, the quality of water extracted from the area through local adits, nor of its impact on Pegwell Bay to which surface water currently discharges. 7.2 Clearly, it has been extremely beneficial to have the Environment Agency working closely with the owners in developing the appropriate regime of control as development proceeds. Work is currently underway to install a drainage system to meet the standards required by the Environment Agency to prevent, as far as possible, contaminants such as de-icing fluid, fuel spillages, etc, reaching the sensitive water collection point, or indeed being discharged into Pegwell Bay with its important nature conservation designation. Equally, it has been unfortunate that Southern Water did not feel able to join the discussion prior to publication of the Environment Statement and in fact were somewhat uncooperative in the release of information to the consultants endeavouring to put together the Environmental Statement work. 7.3 The Council is reasonably confident that the good working relations between the Environment Agency and the owners of the airport will continue and will result in substantial improvements to the current regime and close working between these organisations will ensure compliance with the requirements of the Water Resources Act 1991. Clearly, substantial developments involving large areas of hardstanding can alter the surface and ground water hydrological conditions creating a greater flow from the site than is currently the situation. Such matters need to be carefully studied and particularly so when such surface water has the potential to contain de-icing/anti-icing agents or fuel residuals. Clearly, there are two substantial issues that need to be addressed. The first is in terms of the available infrastructure to ensure that surface water runoff is controlled both in terms of the quantity and the quality of the water that is discharged to ground. Secondly in terms of the management system agreed with the Water Authority and the Environment Agency, to minimise the adverse impact through a proper management regime which has previously been agreed with the Environment Agency. The Local Authority will wish assurances that both are in place to the satisfaction of the Environment Agency or, that any programme of development includes such proposals. 7.4 The question of surface water disposal to Pegwell Bay has obvious consequences for the nature conservation issues within that important site. At present, there is no control over the quality or quantity of outflowing material. Urgent work is required to establish the base level position in terms of the impact of the existing surface water drain and then to seek a discharge consent from the Environment Agency which will establish the appropriate level in terms of quantities and quality of the water discharged. (The owners have already confirmed that they are willing to fund this work.) Quite clearly, this will be of major interest also to English Nature in terms of the impact on the SSSI/SPA/RAMSAR Site. Again, the Local Authority will require more detailed information on this issue. 7.5 One further matter in terms of the discharge of water relates to foul sewage. This is a matter which has not been addressed in the Environmental Impact Statement and will be a key element in any proposal for a passenger terminal which is to be submitted to the Local Authority. The issue of how sewage is to be dealt with will be a major issue for consideration as part of the proposals. Clearly, the Local Authority will wish to ensure that there is adequate foul sewerage available to deal with the likely level of use. This in turn could have an impact on the issues of water quality in the vicinity. 8 9 Nature Conservation 9.1 Again, it is rather unfortunate that English Nature did not feel able to join the Steering Group in the preparation of the Environmental Impact Statement as now produced. 9.2 Nature conservation interests relate firstly to the substantial area of land owned and controlled by the airport which can provide a good wildlife habitat, but can also have major implications in terms of bird strike. Perhaps more importantly in the case of Manston is the impact on the surrounding nature conservation interests of which there are many. English Nature has identified a deficiency in the study in that insufficient attention has been given to the impacts of airport development on the coastal designations around Thanet and Pegwell Bay (that is the SPA/RAMSAR/SAC and SSSI citations). These are all of national/international importance and the development of the airport has to be considered in the light of the potential disturbance to birds and the potential risk of pollution of surface water and of the habitats and species in these areas. 9.3 Further works on the potential disturbance to internationally important populations of birds needs to be taken into account, together with the information referred to above in the water quality section on the impact of the discharge of surface water to Pegwell Bay - one of the most sensitive sites in terms of nature conservation interest. 9.4 English Nature has, as part of the consultation exercise, identified five areas where they would require further reassurance:
9.5 These matters are already being considered by the owners of the site and their consultants and clearly any specific proposal for major development such as a new terminal building would have to take into account these issues in more detail as part of the planning application procedure. 10 11 Air Quality 11.1 As part of the Environmental Impact Statement a contract was placed with Kent County Council to undertake an air quality assessment based on the levels of development envisaged in the Environmental Impact Statement. The report concludes that although there will be an increase in concentrations of nitrogen dioxide, nitrogen oxide and particulates, the current UK air quality objective and limit values will not be exceeded even if the full level of development envisaged occurs. 11.2 Some representations as a result of consultation on the document have indicated the concerns in relation to limits of sulphur dioxide and VOCs (volatile organic compounds) although these are much more likely to be associated with ancillary uses such as paint spraying, etc. A much more likely source of atmospheric pollution could arise as a result of surface transport issues, particularly in relation to the potentially large areas of car parking and large numbers of vehicle movements in the immediate vicinity of a passenger terminal. These will be matters that will be dealt with specifically in relation to the environmental consequences of a passenger terminal and will need to be addressed as part of the consideration of any planning application for such development. 12 13 Economic Issues 13.1 The argument as far as the host community is concerned in deciding on any planning application for major development relates to the balance between the detrimental impact of the development in terms of the environment and the effects of those living under the flight path, and the general economic benefits that may be brought to the area in terms of employment and economic stimulus. This balance has to be explored in more detail to enable the Local Authority to balance the competing demands. 13.2 Considerably more work needs to be done on the issue of the economic consequences of the proposed development. Depending upon whether a case is being made out for the economic benefits or disbenefits of airport development, there is considerable variation in the direct economic benefits that flow from having an airport within the local community. The general ‘rule of thumb’ of 1000 jobs per one million passengers and 1000 jobs per 100,000 tonnes of freight has been questioned in some quarters and obviously will vary enormously between airports depending upon the efficiency of the operation and the economies of scale for larger airports. For smaller airports this figure could well be exceeded before the economies of scale that come with growth in throughput come into play. 13.3 In effect, the employment numbers at LMA are not derived in the ADL report from the ‘rule of thumb’, but are by a direct estimation of employment at the various stages of development by the airport operator. These are then considered in relation to indirect and induced employment and a potential total employment figure is produced within the report. 13.4 However, this section of the report is vital in terms of the community’s understanding of the benefits/disbenefits of having an expanded airport. The Council will need to be assured by some more detailed work on these matters, as clearly, there needs to be some common ground agreed by all parties as to the correct approach to calculation of employment and of the other economic consequences brought about as a result of the envisaged development of the airport. 13.5 One of the issues identified within the scoping assessment to be addressed in the Environmental Statement was the impact of the development on recreation and tourism, both as a positive influence, in terms of the direct benefit to the economy of visitors coming to the area to travel or arriving at their point of entry into the UK, and of the disbenefits resulting from aircraft noise and disturbance on the local tourism economy, particularly for areas such as Ramsgate. 13.6 It has to be said that the assessment of these effects is currently a little light. 13.7 This is an extremely important issue for the local community, not just in terms of the cost benefit analysis of having an airport in its midst, in terms of employment directly in relation to the airport, but also in relation to how an international airport in the local community will encourage other development to take place on business parks, etc, which is not directly related to the airport, but on which the airport has an effect. Equally increasing employment at the airport will affect other planned services needed for the community, such as housing, shopping, hospitals, etc, both in Thanet and surrounding Districts. 13.8 It is the Council’s view, therefore, that before a major planning application is submitted for a development such as a passenger terminal, a full economic study, by an appropriate independent consultant agreed in advance by the Council, needs to be undertaken, which will identify in much greater detail the potential jobs linked to the growth of the airport and the likely direct and indirect net impacts on the local economy brought about as a consequence of the expansion of activity at the airport. 14 15 Other Issues 15.1 Utility Infrastructure Provision 15.1.1 There is currently limited infrastructure capacity for the Central Island Area of Thanet including the business parks and the airport. Electricity, water supply and foul sewage facilities are all limited in their ability to accept new development and could, if problems are not addressed, result in severe restriction on the area’s ability to accept new development. 15.1.2 Clearly, any additional development requiring substantial use of such utility infrastructure, such as a passenger terminal, would need to take account of the existing capacity and, if deficient, allow for the provision of new facilities as part of the development proposal. 15.1.3 As Members will know, the deficiency in utility infrastructure is being addressed through the Spatial Development Company and it is hoped that the work of the company will facilitate development in this area. Clearly, this will be a matter which will need to be dealt with as part of any planning application, but, in addition, such utility provision, or indeed the absence of such utility provision, could have environmental consequences, particularly in relation to water quality, (not just on the central island aquifer, but, potentially on emissions to the River Stour) and on landscape issues. 15.2 Enhancement of Public Transport 15.2.1 Whilst development of the airport brings with it direct surface access issues that need to be addressed in relation to roads, rail, bus services, etc, the development can also have a beneficial impact by enhancing local services that otherwise would not be improved. For example, local bus services to the airport to carry the workforce could incidentally improve the quality of services on routes through the adjoining villages, offering a better service for residents in those areas. On a more strategic scale, the presence and development of the airport could in itself produce a demand for better quality rail services which in addition to improving the access to rail by the airport would incidentally improve rail services to the surrounding area. 15.3 Fuel Supply Options 15.3.1 The study at present considers fuel supply likely by tanker from the Isle of Grain for the foreseeable future, until such time as a fuel tank farm can be constructed at Port Ramsgate, at which time fuel tankers will increase on the Ramsgate Harbour Approach Road and A299. At some date in the future it is suggested that a pipeline from the Port directly to the airport might be appropriate. All of these have environmental consequences, either in terms of traffic movement or potential impact on the adjoining SSSI/SPA/RAMSAR sites and, therefore, have potential environmental consequences which need to be assessed. 15.3.2 In addition, any underground (or overground) pipeline could have potential implications for the water catchment area and water collection adits in the event of spillage. Such environmental consequences will need to be assessed and considered as part of any planning application. 15.4 Complementary Development 15.4.1 Clearly, it is inevitable that if the airport is as successful as is being predicted by the owners, then the pressures for complementary development in the vicinity of the airport will be considerable. Proposals for hotels, service facilities, car hire, aircraft repair facilities etc, could put considerable pressure on surrounding areas with potential knock-on consequences in terms of the amount of built development on the water catchment area and consequences for the rural environment of the central island area. These matters also need to be considered along with the other economic consequences related to the level of development envisaged in the environmental statement. 15.5 Landscape Assessment 15.5.1 At this stage the nature and form of built development is undecided, but clearly any buildings of more than single storey proportion in the vicinity of the airport will have substantial consequences for the landscape of the surrounding area, as the airport is located at the highest point of the island. Whilst obviously detailed proposals for the mitigation of the impact of large buildings will form part of any consideration of detailed building proposals, as they are developed, nevertheless, it should be possible to reach some generalised conclusions on the form that built development might take in order to mitigate its impact on the environment and for some definite statements to be made concerning the design and associated landscaping, particularly in terms of the long term views of the site from the south. 15.6 Runway Extension 15.6.1 Particular mention has been made in the Environmental Impact Statement of the potential for runway extensions at either end of the runway to ensure that the largest planes can take off at maximum payload. Clearly, such extensions will have environmental consequences, in terms of the loading and consequently noise generated by fully laden aircraft, but also will impact on the noise footprint such as to extend the noise contours by a corresponding amount. Any such proposal for extensions will, of course, require a planning application and will undoubtedly require a separate Environmental Impact Assessment. However, given the generalised nature of the Environmental Impact Statement being produced, some of these consequences should at least be acknowledged at this stage to ensure full understanding. |