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THE NATIONAL TRUST

for Places of Historic Interest or Natural Beauty

∙EAST OF ENGLAND REGIONAL OFFICE

WESTLEY BOTTOM, BURY ST EDMUNDS ∙SUFFOLK IP33 3WD

Telephone +44 (0)1284 747500∙Facsimile +44 (0)1284 747506∙ Website

Mr T Morgan
Managing Director
BAA Stansted
Freepost CL4055
Chelmsford
Essex
CM1 3BR / Direct tel / 01284 747552
Direct fax / 01284 747506
E-mail /
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Our ref

24 March 2006

Dear Mr Morgan,

Stansted Generation 2 consultation.

Introduction.

The National Trust welcomes the opportunity to respond to proposals for the expansion of Stansted Airport. The Trust exists to promote the enjoyment of the natural and historic environment. The country’s largest conservation organisation, we are responsible for the management of, and access to, over 820 square kilometres of land, 300 major historic buildings and one in four miles of the coast of England, Wales and Northern Ireland. We are the largest membership organisation in Europe, with nearly 3.4 million members.

The Trust takes an active involvement in aviation and related issues. This has included making representations at public inquiries into airport expansion at Manchester and Stansted and publishing research into the impact of the expansion of aviation on domestic tourism. We made detailed comments on each of the regional reports that made up the Government’s aviation green paper. We believe the resulting Aviation White Paper is flawed, with it findings based on:

-Unrealistic growth forecasts: Government growth forecasts are based on a continuation of current trends for increased air travel. However, this growth relies on anomalies within the tax system and does include environmental and social costs. Such forecasts represent derived demand, and are not a response to need.

-Damage to domestic tourism: Actively encouraging people to holiday overseas has created an £18 billion balance of payments deficit at the expense of the domestic tourism industry. Such impacts are not included in the economic case made for airport expansion.

-Damage to the local environment: In proposing locations for new airport capacity, Government failed to take account of impacts on natural and historic environment beyond the loss of listed buildings. In the case of sites such as Stansted, such damage is significant and militates against the expansion proposals.

Hatfield Forest

We are convinced that proposals to expand Stansted will cause damage to Hatfield Forest. Hatfield is a rare survival of a medieval hunting forest which incorporates 850 ancient pollarded trees, some as much as 1000 years old. With over 250,000 visitors a year the Forest is a regionally important greenspace as identified in the East of England Spatial Strategy. It is an important nature conservation resource, designated as a National Nature Reserve and a Site of Special Scientific Interest. The significant negative effects of Stansted on the Forest include increased noise leading to loss of tranquillity and public enjoyment, the impact of emissions on the Forest’s ecosystems, and the direct effect of surface access and associated development on the Trust’s ownership and setting. These issues stand to be substantially worsened by the G2 proposals.

Overall comments

The Trust wishes to make the following comments on the proposals set out in the G2 document. Together they represent substantial shortcomings in the consultation and decision making process, the provision, presentation and proposed monitoring of information, and the measures to militate against the negative consequences of airport expansion. Together they represent a failure by BAA to make a case for the development of a second runway at Stansted.

Planning process

The Government has acknowledged that a final decision on a second runway will depend upon a number of factors, including a full assessment of environmental impacts. To allow a proper consideration of the options put forward, all runway location options should be subject to a full Environmental Impact Assessment at this stage, rather than compared by a limited number of variables as BAA has done. The Trust understands that such an approach would have financial and time implications. However, assessing the overall environmental impacts of each runway location option, rather than focusing on the differences between options (the approach taken for the G2 document), requires an in-depth interrogation of the issues.

Promotion of sustainable development

BAA regards its purpose as the pursuit of profitable and responsible growth of air travel. This is not consistent with a truly sustainable approach. The Trust believes the impacts of BAA’s proposals at Stansted locally, regionally, nationally and globally are severe, not least in their contribution to climate change.

BAA’s 2003 Sustainable Development Policy (reviewed in 2004 and due to be reviewed again this year), identifies negative impacts caused by the aviation sector and highlights the need for improved performance where the organisation has direct control. We would expect the company’s sustainable development policy to be assiduously applied to its proposals for the future of Stansted, particularly as it is one of the largest projects being promoted by BAA. However, we are unclear the organisation’s sustainable development policy has shaped the G2 document which, we believe, will significantly exacerbate the impacts which are under BAA’s direct control as well as those which are not.

We are particularly concerned by BAA’s statement that “Climate change was not considered as part of our runway optioneering process described in this document because it had been taken into account by the Government in its White Paper and is in any event subject to a separate, nation-wide, action programme”. Aviation is the fastest growing source of carbon dioxide emissions, the most significant cause of climate change. It is not sufficient for BAA to address this simply through a commitment to reduce emissions from its own activities. Nor do we accept that technological development will compensate for the impacts from overall growth in the sector.

Forecasting and monitoring

The justification for a second runway is based around forecasts of increasing demand for use of the airport. To promote this end, the G2 Report uses “preliminary forecasting information”. These figures, BAA admits, “are not definitive and may well change as are proposals are taken through the planning process”. As acknowledged in the consultation, BAA has a poor record in estimating air traffic trends, and we would urge more robustness and transparency in the price-sensitivity of the predicted growth.

The Trust contrasts BAA’s reliance of highly bullish projections for growth in the aviation sector with its unwillingness to fully assess the consequences of further development of Stansted. We set out detailed expectations and concerns over the monitoring proposals at Stansted in our response to ‘Growing Stansted Airport on the existing runway’ in October 2005. The impacts from the development of a second runway would be even more severe, necessitating transparent and detailed forecasting and monitoring.

Tourism

The Trust would question BAA’s claims for the benefits of an expanded Stansted to the region’s tourism sector. Tourism within Britain shows a substantial balance of payments deficit, which is worsened by the expansion in overseas travel. It is estimated that in East of England this deficit equates to £2 billion, dwarfing the £400 million contribution that BAA Stansted makes to the regional economy.

Surface access

Even accounting for the comparatively high percentage of passengers who arrive at Stansted by public transport, a new runway would mean a greatly increased numbers of car journeys beginning and ending at the airport. The Trust is concerned that Stansted garners a substantial percentage of its revenue from car parking, creating a disincentive to promote more sustainable forms of access. Increases in car journeys also contribute to noise, local pollution and greenhouse gas emissions, the impacts of which should form a prominent element of an environmental impact assessment.

The Trust understands that increased rail access to the airport is a pre-requisite to the establishment of a second runway. We recognise that the form such improvements take will be the subject of a separate consultative process. However, given that runway location would impact on the routing of new rail access, we would highlight our objection in the strongest terms to any scheme going through or under Hatfield Forest on the grounds that it would damage land held inalienable by the Trust for the benefit of the nation.

Public enjoyment

The Trust is particularly concerned by the dramatic increase in noise from any new runway and the effect this will have on the 250,000 visitors to Hatfield Forest. Despite requests from both the Trust and the local planning authority, BAA has declined to undertake research such as a Quality of Life Assessment, to measure noise levels in Hatfield Forest, or to supply projected noise contours other than those relating to legal limits which would shed light upon the impact of airport activities on local communities.

Without information relating to noise, odour, local pollution, increased traffic and associated development it is impossible to assess the overall impact of further development at Stansted, or to compare the options in the G2 document.

Conclusion.

In conclusion, the Trust strongly disapproves of any proposal to expand the capacity of Stansted Airport. None of the proposed runway locations is acceptable to the Trust in any form due to their impact on the local environment. On this, the Trust agrees with the conclusions of the 1984 public inquiry that a second runway at Stansted would be “an environmental catastrophe” and an “unprecedented and wholly unacceptable major environmental and visual disaster”.

The development of a second runway would also run contrary to the principles of sustainable development (including those adopted by BAA), would undermine attempts to tackle climate change, would badly damage public enjoyment of the local area, including Hatfield Forest and are based on insufficient data and monitoring.

Yours sincerely,

Keith M Turner

Area Manager

Essex, Hertfordshire & Suffolk