Airports Commission publishes “Environmental Impacts” report on Thames Estuary airport, for comment

The Airports Commission has undertaken to commission studies to assess whether a Thames Estuary airport should be short-listed, with the 3 schemes (Heathrow airport, Heathrow Hub, and Gatwick airport) to Phase 2 – for detailed consideration. These studies would be published in July, and accordingly, now the first study has been produced. It is on Environmental Impacts, and it was carried out by Jacobs Consultancy.  The report is and is over 200 pages long, and appears to be thorough. It is clear that the extent of the environmental damage done by an airport would be huge, and the mitigation measures needed would be on a scale not seen before in Europe, if such mitigation was possible. It also stresses that, to allow this degree of environmental harm, “the Secretary of State for Transport would need to be certain that no alternative solutions existed, had considered the best scientific knowledge and taken into account the representations of Natural England and Environment Agency. If this test is passed it would need to be demonstrated that the proposals were needed for Imperative Reasons of Overriding Public interest (IROPI).” The Commission invites comment on whether the report contains errors, or if anything has been omitted, by 8th August.



Open consultation – Inner Thames estuary airport studies

The Airports Commission seeks comment on the Airports Commission’s inner Thames estuary study outputs. The consultation closes at  5.00pm on 8 August 2014

Inner Thames estuary feasibility study 1: environmental impacts

232 pages

The Airports Commission is seeking views on the first of a number of inner Thames estuary study reports. Specifically, we are inviting responses in relation to 2 questions:

is there information in the reports which is factually inaccurate?
is there any new information or evidence that you wish us to consider before making our decision?
The remaining final study reports will be available on 10 July 2014.


Publishing the inner Thames Estuary feasibility studies

1. The Airports Commission set out in its ‘Introductory Note’ on the inner Thames Estuary feasibility studies that it would publish the study outputs in early July 2014.

2.  Following consultation on the draft terms of reference, the final terms of
reference for each of the studies were published in March 2014.

3.  Consultees were also invited to submit comments and evidence against the terms of reference by 23rd May 2014. A total of just over 170 responses were received, of which around 44 were ‘technical’ [technical responses are those responses which are considered to include substantive policy content  rather than solely setting out an opinion towards the proposal] and 127 ‘non-technical.’ All of the technical responses are available on the Commission’s website.

4.  Both the Commission and its consultants have reviewed comments and evidence submitted as part of the consultation on the draft terms of reference and the call for evidence, and either incorporated or referenced such evidence in the studies where relevant and appropriate.

5.  Today the Commission publishes one of its studies in line with its
transparency agenda and to enable interested parties to submit views on the outcomes of the studies before a decision is made on whether to short-list the inner Thames Estuary for phase 2. The remaining three studies are expected to be published next Thursday 10th July.

6.  While general comments on the studies are welcome, the Commission is
particularly inviting views in relation to two specific questions:

a.  Is there information in the studies which is factually inaccurate? If so,
please let us know.

b.  Is there any new information or evidence that you wish the
Commission to consider before it makes its decision?

7.  Please send comments and evidence responding to the specific questions set
out above to                                                                                  by 5pm on Friday 8th August 2014.




The Summary, of the Executive Summary states:

(iv) Summary

This study confirms that an airport development on the Hoo peninsula is likely to result
in large scale adverse effects on international nature conservation designations,
principally the Thames Estuary Marshes SPA and Ramsar sites and Medway Estuary
Marshes SPA and Ramsar sites. There could also be potential impacts on other
designated sites in the Inner Thames Estuary area. It is expected that an airport would
need to demonstrate that there are no feasible alternative solutions for meeting
development objectives in accordance with the HRA process required under the
Habitat Regulations.

If an airport development was to pass the alternative solutions test and meet IROPI
requirements, a large area of compensation habitat creation would be required and this
would be on a scale unprecedented for any single development in Europe. There are a
number of potential sites associated with proposed managed realignment along the
east coast in Essex and Suffolk that could form at least part of the compensatory
measures required and technically it may be possible to look beyond this area also.

While it is technically possible to create large scale habitats, there is, however, a high
level of uncertainty in achieving this. The full requirements for functional quality of
habitat to meet the needs of all species affected needs to be understood. The
compensation habitat also needs to be provided in a geographic region which would
support the species affected. In order to demonstrate deliverability, further extensive
studies would be needed over a large area and over many years, including the affected
area and the possible compensation sites.

Inner Thames estuary feasibility study 1: environmental impacts

232 pages



The report’s conclusions state:  (pages 136 – 138)


This study sets out to consider the scale and significance of the potential impacts of
a new airport development on the Hoo Peninsula, Inner Thames Estuary location,
focusing particularly on the implications for internationally designated sites and the
relevant legal process. The study scope responds to the recognition that the impacts
and risks associated with a completely new airport location on the Inner Thames
Estuary need to be better understood. In addition, the study has taken account of
stakeholder comments to consider the wider environmental effects on the estuary
processes and morphology, as well as on flood risk, landscape and cultural

The Hoo peninsula supports a complex mosaic of intertidal, wetland and terrestrial
habitats that interact with each other. This complex of a wide range of habitat types
within the ecosystem results in high biodiversity. The Thames estuary has relatively
high productivity that supports internationally important habitat areas and species;
and this in turn supports internationally important bird assemblages and numbers.
This is recognised by the designation of large parts of the estuary as Ramsar, SPA
and/or SAC sites.

The study was based on a review of desk based information, available data on the
designated sites and species and referred to some of the information submitted as
part of the call for evidence. The key findings are listed below:

 All the airport options proposed on the Hoo Peninsula would result in large scale
direct habitat loss to Thames Estuary and Marshes SPA and Ramsar sites.
Some locations would also involve direct loss to the Medway Marshes SPA and
Ramsar sites.

 The minimum permanent loss of habitat on the Thames Estuary and Marshes
SPA/Ramsar sites alone is estimated to amount to 24%/27 of their total area
and it would not be possible to mitigate these losses in close proximity to the
airport due to bird strike risk and geomorphology and flood risk management

 In terms of the Habitats Regulations Assessment process, it is expected that any
future appropriate assessment would conclude that there are likely significant
effects on the Natura 2000 network.

 Under the steps of the HRA process, the proposals would, therefore, be required
to progress to the Alternatives Solutions test. The Competent Authority
(Secretary of State for Transport) would need to be certain that no alternative
solutions existed, had considered the best scientific knowledge and taken into
account the representations of Natural England and Environment Agency. If
this test is passed it would need to be demonstrated that the proposals were
needed for Imperative Reasons of Overriding Public interest (IROPI).

 In the event that the proposals were to be taken through HRA alternative
solution and IROPI steps, an acceptable package of compensatory measures
would need to be developed. The compensatory measures would need to be
created in advance and would need to demonstrate that they would be adequate
before losses occur.

 A minimum of around 2130ha is likely to be needed for habitat compensation for
the airport proposals and displacement of other compensatory habitat. An upper
estimate of 6800ha attempts to capture some of the potential indirect losses.
The road and rail transport infrastructure schemes required for airport access
are also likely to result in additional direct losses to Natura 2000 sites and are
therefore likely to add to the total area required for compensation.

 Compensatory habitat the purpose of attracting birds would need to be provided
at least outside the 13km birdstrike safeguarding zone and it is recommended
that habitat for birds is created beyond 20km from the airport

 Given the uncertainty with providing compensation habitat further afield it is
likely that a ration of gain for loss of greater than 1:1 would be required. Gain for
loss ratios from other studies indicate that 2:1 and 3:1 ratios might be applied. It
is possible that higher ratios might be considered appropriate to reflect higher
uncertainty over the success of proposed compensation measures is considered

 There is good experience on provision of compensatory habitat from the
Environment Agency’s Regional Habitat Creation Programmes. There are also a
number of potential intertidal habitat creation sites associated with managed
realignment policies along the Essex and Suffolk coast. Potential compensation
areas would need to be investigated in detail to identify potential constraints in
terms of availability, suitability and additional impacts and these would require
significant study to determine realistic deliverability.

 Although it may be technically possible to create large scale intertidal and
freshwater habitats for compensation, there is considerable uncertainty over the
ability to deliver the functional quality of habitat to meet the requirements of all
the species that might be affected. There is an added complexity in the potential
ability to adequately provide the like for like combination of habitats –not just the
habitat types in isolation but a mosaic of habitats for the requirements of some
species. Estuaries and coastal areas along the Essex and Suffolk coast should
be the first area to consider for compensation areas, locations further afield
might be possible but are likely to increase the uncertainty that all different
species needs could be met.

 In terms of the wider environment, there are additional areas of impact or risk
particularly associated with the construction of an airport into the estuary
channel, seaward of the existing defences, including:

– Construction impacts and the release of sediment which could potentially
result in long term effects on the estuary;
– Change to estuary geomorphology and hydrodynamics through changes to
tidal prism, wave reflection, sediment deposition, sediment entrainment and
bank or habitat erosion.
– Changes to current speeds and directions will change erosion and accretion
patterns and could lead to significant changes to intertidal habitats (affecting
up to 2500ha of estuarine intertidal and subtidal habitat).
– Changes to water levels, although these are expected to be minor
– Potential for impacts on the ecological status of Water Framework Directive
(WFD) water bodies through combination of impacts on a number of water
courses on the Hoo peninsula. These are likely to result in addition
ecological effects on aquatic species and may need to be subject to WFD
article 4.7 tests to determine if exemptions from normal WFD requirements
would apply;
– Uncertainty in relation to flood risk and the extent of impacts from airport
construction beyond existing defences, including reduced conveyance and
storage capacity in the Thames Estuary and possibly the Medway Estuary
and potential for increased flood risk in extreme event especially given the
high design standard for flood protection likely to be required for a new hub
airport; also high level of uncertainty over climate change and particularly
sea level rise, storm surges and extreme events;

 Extensive detailed studies including hydrodynamic modelling would be required,
along the lines undertaken for TE2100, in order to understand the
geomorphological and flood risk changes and requirements for mitigation and
related additional impacts on designated sites.

 Impacts on landscape and cultural heritage include large scale changes altering
the tranquil and remote character of the area, and resulting in direct loss of a
number of statutory designated or potential designated heritage features as well
as resulting in changes to the settings of remaining heritage interest.

Inner Thames estuary feasibility study 1: environmental impacts

232 pages






Airports Commission publishes interim report with 2 options for a runway at Heathrow and 1 at Gatwick. Estuary still being considered

December 17, 2013

The Airports Commission’s interim report has put forward 3 options for a new runway, and have kept their options open on an estuary airport. There would only be one runway, not two and they consider this should be in operation before 2030. At Heathrow the choices are a north west runway, 3,500 metres long, destroying Harmondsworth; and an extension westwards of at least 3,000 metres, of the existing northern runway. They also consider a wide spaced Gatwick runway to the south. The Commission also says “there is likely to be a demand case for a 2nd additional runway to be operational by 2050.” They claim this is “consistent with the Committee of Climate Change’s advice to government on meeting its legislated climate change targets.” Stansted is ruled out, and on the Thames Estuary they say: “The Commission has not shortlisted any of the Thames Estuary options because there are too many uncertainties and challenges surrounding them at this stage. It will undertake further study of the Isle of Grain option in the first half of 2014 and will reach a view later next year on whether that option offers a credible proposal for consideration alongside the other short-listed options.” The report also contains recommendations to the government for immediate action to improve the use of existing runway capacity. Among others, these include better airspace organisation and surface transport improvements such as enhancement of Gatwick station, a rail link from the south to Heathrow, and a rail link between Heathrow and Stansted.

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