1. Ecological objections - London

Report 6 Appendix A
Thames Estuary Airport Objections – from Kent County Council
1. Ecological objections
Significant negative impact on the Thames Estuary Special Protection Areas
The Thames Estuary has significant areas of internationally protected wildlife habitats -
Special Protection Areas (SPA) – which see some 300,000 migrant birds on an annual
basis. As Natura 2000 sites, SPAs are afforded the highest level of legal protection. Under
the EU Habitats and Species Directive (92/43/EEC), all Member States have a duty to
protect Natura 2000 sites from deterioration of their natural habitats and the habitats of
their component species. This is applied in England through the Conservation (Natural
Habitats etc.) regulations 1994, as amended.
An airport situated in the Thames Estuary would damage (and potentially destroy)
significant areas of the SPA and it is therefore difficult to see how the proposed airport will
be able to show that, beyond reasonable scientific doubt, it would not negatively impact
the SPA. In order for the project to go ahead, it will need to demonstrate “imperative
reasons of overriding public interest” and show no alternative exists. Even if these tests
could be satisfied, large scale compensation, through recreation of damaged or lost
habitat, will be required to address the effects on the Greater Thames Estuary SPAs – it is
considered that adequate compensation could not be found within the area (or potentially
elsewhere).
Significant negative impact on the Outer Thames Estuary Proposed Special
Protection Area
The Outer Thames Estuary Proposed Special Protection Area (pSPA) has been identified
as the wintering area for 38% of the UK red-throated diver population (Listed on Annex 1
of the EC Birds Directive). As above, it is considered that an airport situated in the estuary
would have a significant negative impact on areas of this pSPA. In addition to direct
disturbance of the birds, for which the area is proposed, their primary prey species (sprat
and herring) are also likely to be negatively affected. Sprat and herring are particularly
sensitive to noise and vibration, and construction and operational activities have the
potential to negatively affect the submerged sand banks where this species live.
pSPA are afforded the same level of protection as designated SPAs and the same
requirements, and concerns over meeting these requirements, outlined above would apply
to this proposed site.
Management of bird strike risk and detrimental effect of this on the SPA’s bird
populations
In order to ensure the safety of aircraft and passengers using an airport situated in the
estuary as proposed, extensive bird control measures would need to be undertaken (e.g.
bird scaring and nest control). The Government’s Aviation White Paper noted that the
estuary airport presented a significantly higher risk of bird strike than at any other major
airport in the UK – even with management, up to 12 times higher. Furthermore, the
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previous proposal for an airport at Cliffe highlighted major bird strike safety concerns which
“could not be managed to an acceptably low level of risk”.
In an area of key international and national importance for birds, the extent of the
measures necessary to reduce the risk of bird strike to acceptable levels would be highly
detrimental to the Special Protection Areas, legally protected for their bird populations.
Bird disturbance from aircraft activity in the Special Protection Areas
In addition to the detrimental affects on the bird population from direct damage of the SPA
and management of bird strike, disturbance from the noise, sight and lighting of day and
night aircraft movements are also of concern. This is particularly applies to the vitally
important intertidal feeding areas of mudflat and saltmarsh in the SPA.
Potential inhibition of SPA enhancement and potential deterioration of site
The aerodrome authority would have a right to comment on, and object to, land
management changes that may become bird attractants within 13km of the aerodrome.
Such objections, if upheld, would inhibit any future SPA enhancement/management
measures, potentially leading to the SPAs’ condition becoming unfavourable.
Potential negative changes to hydrological and sedimentary estuary processes and
resulting loss of intertidal habitat
The ability of the area to support the internationally and nationally important bird
populations could be diminished if the proposed development results in changes to the
hydrological and sedimentary regimes of the Estuary. Intertidal habitats (e.g. mudflats,
saltmarsh and seagrass) are dependent on the stability of these regimes and are crucial to
the Thames Estuary ecosystem, whilst also contributing to the management of flooding
risk.
A barrier across the estuary would have significant effects, including a reduction in the tidal
range and loss of intertidal habitat. These concerns are supported by the Thames Estuary
2100 (TE2100) project. This project has predicted that 1,200 hectares of salt marsh and
mudflat could be lost this century as a result of sea level rise and efforts are being made to
recreate this loss in order to comply with EU habitats and birds directives. The proposed
airport development would make this objective even more of a challenge to meet.
Potential flood risk impacts
The Thames estuary is particularly vulnerable to sea level rise and flooding. The full
impact of the airport development in terms of flood risk to land and properties along the
length of the estuary will require extensive study (particularly if incorporating a barrier) and
must consider existing management policies within the relevant Shoreline Management
Plans.
Reduction in water quality and pollution from airport construction and operation
Water pollution, as a result of the construction (for example suspended sediment) and
operational phases (for example runway runoff) of the proposed airport development, is
highly likely to be detrimental to the intertidal habitats of the Thames Estuary (including
those in the SPAs).
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TE2100 research suggests that the construction of a barrier would adversely affect the
water quality of the Thames, and would result in difficulties in meeting Water Framework
Directive (2000/60/EC) standards as a result of “the impoundment of polluted waters.”
This “impoundment” would be particularly severe if a tidal energy unit was incorporated
into the project.
Detrimental impact of Thames Estuary fisheries
The Thames Estuary is a significant nursery and spawning ground for many commercially
important fish and hosts important shellfisheries. The health of these fisheries is important
to the ecosystem as a whole, in addition to their economic and anthropogenic importance.
The proposed airport could adversely affect these fisheries through:
• Increased levels of suspended solid concentrations.
• Noise and vibrations causing avoidance behaviour, physiological damage or mortality.
• Artificial lighting affecting reproduction and migration.
• Reduced fish movement and migration, particularly relevant for barrier option.
Disturbance of, and negative impact on, protected marine species
Protected species such as short-snouted seahorses (legally protected under Wildlife &
Countryside Act 1981 (as amended), and UKBAP species) common and grey seals
(legally protected under the Conservation of Seals Act 1970) and cetaceans (legally
protected under Conservation (Natural Habitats etc) Regulations and EU Habitats
Directive) are known in the waters of the Thames Estuary.
These marine species will be vulnerable to any reduction in the quality of the habitat and
noise and vibration impacts – likely affects of the proposed airport.
2. Historic Environment/Heritage objections
General
The Thames estuary has formed an arterial route into the heart of England for at least
400,000 years. As a result of this important strategic location the estuary is extremely rich
in archaeological remains from the Palaeolithic to the second world war. It also contains
buried prehistoric landscapes, preserved as sea level rose after the end of the last
glaciation.
In the estuary between Cliffe and Herne Bay there are records of 462 shipwrecks, many of
which date from the last world war, including the SS Montgomery which is located 250m to
the north of the Medway Approach Channel. The wreck contains about 3000 tons of
explosives, including about 1400 tons of TNT; it has been surveyed and is regularly
checked for its condition.
Because of its strategic position the estuary has always been important for defence of the
realm, with many nationally important sites from the Tudor period to WW2, including the
Maunsell Sea Forts located in the estuary on Red Sands and the Shivering Sands, close
to the suggested airport location off Sheppey.
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The north coasts of the Hoo peninsula and Sheppey are particularly important historically
because of their key positions protecting access to the inner Thames estuary, Medway
estuary and Swale sea channel respectively.
Each of the possible landfall sites is considered below:
Sheppey landfall
Within 3 km of the suggested road route lie:
• more than 1,440 Historic Environment Record records. These include:
• 276 listed buildings (43 Grade I or Grade II*)
• 8 scheduled monuments (Minster Abbey, Castle Rough medieval moated site,
Murston old church, Chetney Cottage anti-aircraft site, Shurland House and
Queenborough Castle, Boxted Roman villa, Church Farm ringwork),
• 12 conservation areas and
• 8 parks and gardens included in the Kent Historic Gardens Compendium.
The route of the M2 link passes through a landscape rich in heritage sites. These include
the home of British aviation at Muswell Manor, Leysdown, an important area of Roman
and medieval salt working and a landscape known to contain numerous prehistoric sites at
Kingsborough Farm and Shrubsoles Hill, Brambledown.
Further to the west the route crosses an important historic landscape in the marshes of
southern Sheppey with its military remains from the Second World War including pillboxes
and defence obstacles and maritime assets including historic barges, wharves and
jetties. The area is also likely to be rich in palaeoenvironmental remains.
Across the Swale at Iwade excavations have revealed extensive archaeological remains
including cremation burials and extensive enclosures, field boundaries and settlement
evidence from the bronze Age and iron ages and activity from the Anglo-Saxon and
medieval periods. At Grovehurst evidence of important neolithic activity has been found
and Milton Regis is thought to have been a Saxon royal estate centre from at least the
sixth century AD. Significant remains are likely to be encountered in this area.
Cliffe landfall
A proposed site at Cliffe would be likely to have a high adverse impact on important
archaeological and historical features. These features include the full range of findspots,
occupation sites, Listed Buildings, and military and industrial structures dating from the
Palaeolithic through to the recent past.
The Historic Environment Record lists:
• more than 1,000 records on the Hoo Peninsula including:
• more than 60 listed buildings
• five Scheduled Monuments (Cliffe Fort, Cooling Castle, Slough Fort, St. Mary’s
Priory and the Coastal Artillery Defences at Grain).
• three other nationally important sites within the Peninsula are due to be considered
by English Heritage for scheduling (Cliffe Cement Works A & B, Curtis’s and
Harvey’s explosive factory and a decoy pond.
In addition to the protected sites there are a large number of sites and findspots in the
area. The recorded sites represent only a small proportion of the actual resource likely to
be present. Prehistoric sites have been located at Cliffe, Allhallows, High Halstow and the
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Isle of Grain, the location of a major multi-period site. Recent survey work produced a
significant increase in the number of Iron Age and Roman sites. Similar estuary locations
in Essex and elsewhere have demonstrated that this type of location has a high
archaeological potential.
In addition to this, the area is likely to contain a particularly high potential for palaeoenvironmental
data for what may prove to be a largely
intact archaeological landscape. This information alone is likely to be of
regional and even national importance.
Whitstable
The Whitstable area from Graveney to Chestfield contains more than
• 470 records in the Historic Environment Record. These include:
• 7 scheduled monuments (6 of them related to salt-working indicating the importance
of the theme in this area
• more than 100 listed buildings, plus another 100 on the Canterbury City Council
local list, and
• 7 conservation areas, including those related to the historic town of Whitstable.
In addition to the protected sites there are numerous heritage assets in the area. There are
numerous prehistoric sites from Swalecliffe, Radfall Corner and Brooklands Farm,
including the site of a prehistoric log boat from Seasalter. Anglo-Saxon and medieval
remains are also known from the area including another log boat from Graveney. A recent
study has also identified an important defence landscape in the area with numerous
surviving assets related to the Second World War. The most important heritage asset in
the area may is probably the medieval and post medieval town of Whitstable itself. This is
one of Kent’s heritage ‘gems’ and the setting of the town would certainly be damaged were
an airport to be located anywhere in the vicinity.
As with the two other sites the inter-tidal zone is of very high potential for the discovery of
archaeological remains in this area and a recent inter-tidal survey discovered dozens of
new sites that certainly extend out beneath the sea.
3. Planning and Transport Objections
Economics
Airport reputed to cost some £40bn. Unclear how it would be funded and what element of
public funding would be required. A new offshore airport is likely to be significantly worse
value for money than other options with which it would need to compete, unless
Government sought to regulate prices and investment in the London airport network,
contrary to its policies and actions towards privatisation.
Thames Estuary Airport (TEA) would need to attract at least one major airline alliance to
switch from Heathrow. The airline industry very reluctant to move from Heathrow and
most unlikely to do so unless offered very attractive deal on landing charges, reducing
income for the airport. To be viable a new hub airport would require extensive seeding –
moving significant existing services from Heathrow in particular to provide an attractive
choice of routes from the outset so that the new airport could compete. There are no
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established or internationally accepted policy mechanisms which could ensure such
relocation of airline operations.
A new offshore airport requires major investment at the outset, and lacks flexibility in the
face of market change because it cannot be developed incrementally. It is an “all or
nothing” proposal.
TEA is poorly positioned in relation to the catchment area of the South East which
currently focuses west of London. It is poorly positioned to capture market share
particularly from Heathrow.
Would not be ready until 2030, ie 20 years hence. There will be a need to expand runway
capacity at the existing London airports in the interim (Heathrow, Stansted and/or
Gatwick), further eroding viability of TEA.
Continued significant growth in air travel (after the recession) is far less certain than in the
past with the need to comply with carbon targets. It is more likely that costs of air travel
will rise significantly above inflation
Maximising capacity at existing runways (including Manston), incremental expansion at
existing London airports and development of regional airports is better to meet the
changing levels of demand rather than big bang approach which is inflexible and highly
risky
Transport
TEA requires extensive and costly new road and rail infrastructure which is likely to attract
significant opposition. Strategically the location is a ‘cul de sac’ – it is the only destination
on the routes needed to serve it and as such their viability depends entirely on the success
of the airport
If successful, TEA would increase traffic on strategic road and rail links in Kent – no figures
available but likely to be significant over a large area of Kent
• would strain capacity on A2/M2 (already mostly four lanes) with little scope for
significant increase in capacity. Would probably require widening of three lane
sections of M25, two lane M26, three lane M20 and two lane A249 with appropriate
junction improvements
• would cause pressure on the capacity of HS1 and Kent domestic rail services using
HS1 (Eurostar likely to be immune).
It is very unlikely that by 2030 there will be spare capacity on High Speed 1 which is linked
to the Channel Tunnel for passenger and freight services, and provides commuter services
in Kent and East London. The stopping patterns and terminal location must be attractive
to long distance air travellers.
Significant adverse impact therefore on Kent’s economic development plans (Ashford, E
Kent etc) which depend on maximising existing and planned transport infrastructure.
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Urban Development & Regeneration
The urbanisation and travel impacts of a new airport with 4 runways will be very great.
Little of the additional pressure could be absorbed in the immediate area of landfall for the
road and rail links to the airport. Major green-field land release would be required in Kent
and Essex.
To be viable the new airport must transfer passengers from other South East airports. A
dramatic pace of urban development and investment in public services would be needed in
advance of the airport opening to provide workforce and services on day one of the airport
operation. There would be matching under capacity and loss of activity in the Heathrow
area.
The services and labour supply required to support the airport would need to be located as
closer to the island as possible. Little development could be absorbed in Sheppey and
Southend requiring major development on green-field land in Kent and Essex.
Safety
National Air Traffic Services (NATS) was concerned over severe problems a new airport at
Cliffe would create. TEA could be expected to raise similar problems that need to be fully
investigated.
The proposed airport construction in the Estuary could have significant consequences for
flood protection within London and the Thames Estuary area. The implications would
need detailed assessment
EHW/Feb10
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Thames Estuary airport: Oakervee feasibility review
RSPB critique
Summary
Douglas Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October
2009 following a request from London’s Mayor, Boris Johnson for the feasibility of an
airport in the Thames Estuary to be evaluated.
An airport in this location is not a new idea; it has previously been considered and
rejected, partly because of the ecological sensitivity of the Thames Estuary Location. The
Thames Estuary has nine internationally important nature conservation designations,
the majority of which relate to rare and vulnerable bird species.
These designated sites already experience significant pressure from an array of existing
activities and developments that occur in that broad location. The pressure also
continues to increase, with several other projects, such as major port developments and
energy infrastructure, being proposed in the area.
The environmental effects of an airport in this location are likely to be significant and
wide ranging. They could include the loss of protected habitat, disturbance of sensitive
protected species, increased atmospheric emissions, including emissions of greenhouse
gases, and alteration to the hydrodynamics of the Estuary resulting in accelerated
patterns of erosion and/or deposition. These effects could lead to a population scale
decline of bird populations in and around the Thames Estuary.
The scale of potential effects would result in likely significant effects on protected
habitats and species in the internationally designated nature conservation sites. These
adverse effects would be very difficult, and in all probability, impossible to mitigate.
Given the range of alternatives solutions to the airport available and in the absence of
imperative reasons of overriding public interest, an airport in the Thames Estuary could
not be consented without contravention of UK law on the protection of nature
conservation. The RSPB therefore views the proposal as a totally unfeasible and
impractical scheme.
2 Introduction
An airport in the Thames Estuary has previously been considered in the Government’s
2003 Aviation White Paper, to which all key players, including the aviation industry,
contributed. The White Paper conclusively ruled out an airport in the Thames Estuary.
Despite this however, London’s Mayor, Boris Johnson, requested a study into the
feasibility of the potential for an airport in the Thames Estuary. Subsequently, Douglas
Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October 2009.
From the very outset of London’s Mayor first raising the idea of developing a major new
airport in the Thames Estuary, the RSPB has had serious concerns about the likely
environmental consequences. However, the Feasibility Review falls short of adequately
considering the likely environmental effects of such a proposal and thus the feasibility of
creating an airport in the estuary. As such, the Review fails to alleviate the RSPB’s
concerns regarding the likely direct and in-direct environmental effects, as well as the
consequences on the UK’s ability to meet commitments to its climate change targets.
The importance of the Thames Estuary and the designated sites for conservation
The RSPB is pleased to see that Oakervee acknowledges the internationally outstanding,
sensitive environment of the Thames Estuary:
“When reviewing the Thames Estuary and the creation of a sustainable
future for London and the South East of England…we must recognise the
sensitivity of the environment and safeguard it to the best of our ability. The
challenges we face in the Thames Estuary are complex and the approach
needs to be rethought if we are to avoid leaving future generations an even
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igger challenge with an even bigger price tag.” (page 21).
The challenges in the estuary are indeed complex, and the consequent approach to
managing the estuary needs to reflect this. With such a proposal likely to result in
significant environmental damage, a “rethought approach” for a “sustainable future”, as
Oakervee suggests, should logically discard the idea of an estuary airport as wholly
unfeasible.
The Thames Estuary is a dynamic place formed by the meeting of the Thames, the North
Sea and the landforms of London, Kent and Essex. The estuary is an area of outstanding
international importance for birds; reflected by a network of Special Protection Areas designated
under EU Directive and protected accordingly. The estuary has the highest
concentration of bird species in internationally important numbers in the south east. The
diversity of waterbird species places the estuary in the top five internationally important
sites in the UK, out of 143 recorded.
Whilst the Oakervee Review acknowledges the conservation importance and
environmental sensitivities of the estuary, it wholly fails to comprehend the real
implications of an airport in the estuary, instead choosing to adopt the line that the
environmental harm arising from such an airport can be managed.
Thames activities/developments
The Thames Estuary area is currently the focus of many existing activities including
large-scale commercial port operations, minerals extraction, dredging, transportation,
recreation and numerous energy projects. The area is also presently the focus for new
developments in a variety of sectors including further large-scale port and energy
projects.
These activities alone, and together with other pressures such as climate change, exert a
significant pressure on the sensitive habitats and species in the Thames Estuary. These
existing pressures may also be exacerbated if potential future developments that may
also have an impact on the estuary, such as the proposed lower Thames crossing, get the
go ahead.
Impacts on designated nature conservation from an airport in the Thames Estuary
As acknowledged in the Feasibility Review, an airport in the Thames Estuary could
clearly result in significant environmental effects:
“It takes little imagination to appreciate that if any of the proposals or
schemes under consideration were introduced without appropriate
amelioration measures then the impact on this precious ecological reserve
could be disastrous and in this day and age almost certainly unacceptable”
(page 28).
However, despite recognising this, the Review fails to understand that an airport in the
estuary is an impractical and unfeasible proposition, with very little opportunity to
apply “appropriate amelioration measures”. As such, an airport will undoubtedly result
in significant damage to the environment, protected habitats and species. Further to this,
it is unfortunate and disappointing that the Review, when listing the impacts of an
4
airport in the Thames (on page 40), does not identify potential significant environmental
harm as a “disadvantage”.
Instead, the Review proceeds with considering a broad location of a possible airport as
approximately “7Km to 10Km north east of Whitstable in the direction of the Shivering Sands
Fort and The Kentish Flats Wind Farm”.
Due to its location, the proposal has the potential to directly and indirectly impact on of
a range of internationally protected nature conservation sites (Special Protection Areas
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(SPAs), Special Areas of Conservation (SACs) and Ramsar sites), including:
- Essex Estuaries SAC;
- Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar;
- Benfleet and Southend Marshes SPA and Ramsar;
- Thames Estuary and Marshes SPA and Ramsar;
- Medway Estuary and Marshes SPA and Ramsar;
- The Swale SPA and Ramsar;
- Thanet Coast SAC; and
- Thanet Coast & Sandwich Bay SPA and Ramsar.
In addition, the airport would have a direct impact in the Outer Thames proposed SPA
(pSPA), and the Margate and Long Sands possible SAC (pSAC). Government policy
affords the same level of protection for a pSPA as it would a designated SPA. A
candidate SAC (cSAC) is also afforded the same level of protection as a classified SAC.
However, although the pSAC is not afforded the same protection as a cSAC, we strongly
recommend that this site be considered as though it were a cSAC, since this classification
is likely to come into effect by the end of 2010.
Designated for a wide range of species and habitats, these sites are also underpinned
and protected by the national Site of Special Scientific Interest (SSSI) notification.
The Feasibility Review also identifies that access to the airport would be via new road
and rail infrastructure from the Kent and Essex coastlines. Whilst not certain at this
stage, it is suggested that tunnels would be utilised for the sea section of the routes. The
broad location of these new infrastructure developments could potentially coincide with
the Thanet Coast & Sandwich Bay SPA and Ramsar, The Swale SPA and The Swale SAC,
on the Kent coastline in addition to the Benfleet and Southend Marses SPA and Ramsar,
the Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar, and the Essex Estuaries SAC
on the Essex coastline.5
There are clearly, therefore, a large number of internationally designated nature
conservation sites that could be affected (both directly and in-directly) by a new airport
in the Thames Estuary. The potential impacts on protected bird species, from the airport
alone, are numerous and significant. These include:
- direct loss of bird foraging habitat (and thus a reduction of food resource) in the
Outer Thames Estuary pSPA;
- disturbance to birds from airport construction, including noise, vibration and
lighting effects, resulting in displacement of a large (foraging) area in the estuary;
- disturbance to birds from airport operation, resulting in displacement of a large
(foraging) area in the estuary;
- direct loss of (foraging, roosting and/or loafing) coastal and inland bird habitat
due to airport transport links to Essex and Kent;
- disturbance to coastal and inland sites from associated transport links to Essex
and Kent;
- potential alterations to hydrodynamics – flow changes can resulting accelerated
patterns of erosion and/or deposition and therefore potential loss of intertidal
habitat;
- atmospheric pollution - NOx is the principal pollutant arising from aircraft and
road traffic associated with airports. Deposition of nitrogen compounds (nitrates
(NO3), nitrogen dioxide (NO2) and nitric acid (HNO3)) can cause eutrophication
of soils and water. This alters the species composition of plant communities and
can eliminate sensitive species; and
- water pollution as a result of accidental spillage of aviation or other fuel.
From loss of foraging, roosting and/or loafing habitat, through direct and indirect
habitat loss and from increased human disturbance, bird populations could face decline
in and around the Thames Estuary. This will have knock on effects for the environment
and wider ecosystem because of the Thames Estuary’s international importance (being
in the top five internationally important sites in the UK) due to the numbers of
waterbirds found there during winter and on migration1.
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Safety and bird strike
The hazard to aircraft from bird strike is well known and at estuary sites, an obvious
concern. The Feasibility Review, although recognising bird strike as an issue, suggests it
is solvable:
“data indicates that although bird strikes are a real issue there are ways to
overcome the problem without being aggressive towards the birds. Whilst
much is written on how best to resolve the problem and should be reviewed in
detail, I believe the issue should be addressed with the RSPB to find the right
solution for the Thames Estuary” (page 51).
The RSPB considers it impossible to control bird strike risk for an airport in this location
without “being aggressive towards birds”, since attempting to control the risk of bird
strike will require many invasive techniques, including intensive and wide spread bird
scaring.
In the RSPB’s response to the Air Transport White Paper in 20032, we drew attention to
our concerns regarding aircraft safety at an airport at Cliffe, which was to be located in
the midst of the Greater Thames (in a similar position to that of a possible Thames
Estuary airport).
With regards to an airport at Cliffe and the 2003 Air Transport White Paper, several
studies were undertaken to assess bird strike, including research commissioned by the
Secretary of State for Transport. All studies concluded a significant risk of bird strike,
with the Secretary of State’s report (by CSL and BTO, published in March 2003)
concluding that:
“Without a comprehensive and aggressive bird management programme in
place, incorporating careful and considered airport design, appropriate habitat
management and active bird control, an airport could not operate safely in this
location.
Even with such world class management and mitigation measures in place, the
hazard posed by birds is severe and would probably be higher than at any other
major UK airport.”
Pages 203-4 of the CSL/BTO report place this in perspective. The expected number of
damaging bird strikes at an airport at Cliffe would be between 2.97 and 8.65 per year,
whilst total hull loss would be expected to occur between 1 in 102 years and 1 in 297
years. Yet, for ten of the largest civil airports in the UK, the estimated rate of total hull
loss is between 1 in 304 and 1 in 1210 years, with a mean of 1 in 653.5 years.
2 Future Development of Air Transport in the UK – South East (Second Edition), RSPB consultation, May 2003
7
In other words, the hazard associated with the Cliffe option was, at best, equal to the
greatest risk at any of the top ten UK civil airports in 2003 and, at worst, the level of risk
was up to 12 times higher. And this is with a bird hazard management regime in place
which would have a major adverse impact on the waterfowl and waterfowl habitats of
the SPA.
The RSPB therefore concluded that the level of bird strike risk associated with the Cliffe
option was unacceptable, in terms of human safety. We further concluded that the
habitat modification and active bird scaring measures associated with reducing the level
of bird strike risk even to this unacceptably high level was also wholly unacceptable in
terms of its implications for the SPA.
With many similarities between possible airports at Cliffe and in the Thames Estuary,
we are very concerned that the risk of bird strike could be of at least a similar scale and
nature.
A key consideration in assessing bird strike risk is bird flight lines. However,
the Feasibility Review does not attempt to provide any primary information on bird
movement within the broad airport location, but instead makes reference to flight path
mapping provided by MetroTidal:
“MetroTidal in their studies have produced a map of the flight paths across
the estuary and is included as Figure 20 below. If this is representative of the
actual situation it would appear that the likely location is relatively free from
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ird movements. This coincides with my own visit to the area” (page 51)”.
It is very concerning that the conclusion is reached that “the likely location is relatively free
from bird movements” when the MetroTidal study appears to relate to a location further to
the west of the broad airport location. Furthermore, the robustness of the MetroTidal
data is unclear, as no details are provided on the timing or duration of the study.
Decision making
With any proposal for an airport in the Thames Estuary, the Habitats Regulations 19943
(among other requirements such as environmental impact assessment) will apply. And
as such the relevant competent authority will have to determine whether the project is
likely to have a significant effect on either the Ramsar sites4, the SPAs, pSPA5 and/or the
SACs (known collectively as the European sites) either alone or in combination with
other plans or projects6.
The Likely Significant Effect Stage - any project not directly connected with or necessary
to the management of an European site is to be subject to an appropriate assessment of
its implications for that site in view of the site's conservation objectives if it cannot be
excluded, on the basis of objective information, that it will have a significant effect on
that site, either individually or in combination with other plans or projects.
If the project is likely to have such an effect there is a legal duty for the competent
authority to make an appropriate assessment of the implications for the European sites
in view of those sites’ conservation objectives. The project can only receive permission if
it can be ascertained that it will not adversely affect the integrity of the European sites7.
As part of the appropriate assessment mitigation measures can be considered. The
Feasibility review in recognising the potential impacts on the environment, suggests
that:
“It will…be necessary to pioneer mitigation measures to create equal habitats
to maximise the survival potential of all.”
However, whilst there may be some mitigation measures available to avoid and/or
reduce the harm, providing “equal habitats” will only compensate for the harm/loss
rather than avoid or reduce the harm. The RSPB believes that many effects of such a
proposal on protected species cannot be mitigated, and therefore adverse effects cannot
be avoided.
If it cannot be ascertained that the project will not adversely affect the integrity of the
European sites, the provisions in regulations 49 and 53 of the Habitats Regulations
would fall for consideration namely that there are no less damaging alternative solutions
to the project, there are imperative reasons of overriding public interest to justify the
project receiving permission despite the adverse effects on the integrity of the European
sites and that compensatory measures can be provided before those effects occur.
The RSPB believes that there are alternatives solutions to the project and that there are
no imperative reasons of overriding public interest. Finally, we believe it would also be
extremely challenging, if not impossible, to replicate the habitats lost elsewhere.
Climate change
The RSPB welcomes the Feasibility Review’s acknowledgement of the seriousness of
climate change and the recognition of the scale of reductions in emissions required:
“Recent revisions to government policy with respect to climate change and
the requirement for an 80% reduction in carbon emissions by 2050 must be
the driving force behind many major decisions and how we live in the years
to come.” (Page 23).
It is therefore surprising and concerning that the Review fails to address the issue that
the carbon costs (of both constructing and operating a new airport in the Thames
Estuary) would be entirely at odds with the Government's carbon reduction
commitments. Such a proposal will lock the UK into yet more carbon-intensive infrastructure for
decades. If the airport were to be progressed therefore, it would place a huge and
Page 12 of 14

expensive burden on other sectors of the economy to decarbonise even further to
account for the contribution from aviation.
With the greater travel distances between London and the proposed airport compared to
London’s existing airports8, the additional distances required to travel to the new airport
would have a further significant carbon cost.
In any serious proposal, we would expect to see detailed analysis of the carbon cost of
building and operating the airport, together with measures for mitigating the substantial
carbon release. However, we do not believe that a development of this size or nature
could adequately mitigate these impacts in an increasingly carbon-constrained world.
Conclusion
We are very concerned that the Thames Estuary is even being considered as a location
for a new international airport. The proposal is likely to harm the sensitive estuarine
habitats and species of the designated sites through habitat loss, noise disturbance and
atmospheric pollution.
Given the evidence of the impacts of climate change on biodiversity and the significant
and rapidly increasing contribution aviation is making to global warming, the RSPB also
has serious concerns that a new airport is likely contribute to environmental degradation
via exacerbating climate change and would seriously hamper all attempts to cut the
UK’s greenhouse gas emissions.
3 Conservation (Natural Habitats &c.) Regulations 1994 as amended (the Habitats Regulations)
4 As a matter of government policy the procedures applicable to SPAs and SACs apply to Ramsar sites - Paragraph 5 of
ODPM Circular 06/05
5 Government Policy affords the same level of protection for a pSPA as it would a designated SPA
6 Regulation 48(1) of the Habitats Regulations
7 Regulation 48(5) of the Habitats Regulations
8 The proposed airport would be some 96 km to Charing Cross, whilst Heathrow is only 28 km and Gatwick 47 km from
Charing Cross.
Page 13 of 14

Page 14 of 14

www.medway.gov.uk
Thames Estuary Airport
Visit to Kit Malthouse by Medway Council
2 March 2010
Cllr Rodney Chambers – Leader of the Council
Cllr Paul Godwin – Leader of the Labour Group
Cllr Maureen Ruparel – Leader of the Liberal Democrat Group
Cllr Tony Goulden – Leader of the Independent Group
Robin Cooper – Director of Regeneration, Community and Culture
John Staples – Media Manager

Location Map Medway and Airport
Thames Estuary Airport
MANSTON

10 reasons
to oppose the airport
Medway’s View
1. An airport would cause environmental destruction to sites of special scientific
interest and internationally important areas where hundreds of thousands of birds
migrate to annually.
2. As the Thames Estuary is a hub for hundreds of thousands of birds, there would be a
significant risk of bird strike. Even with an aggressive bird hazard management
programme, such as shooting or scaring birds away, the bird strike hazard would be
up to 12 times higher than at any other major UK airport (source: RSPB)
3. An airport would increase the pressure for additional major development due to the
increased attractiveness of the area to business. This could result in vast swathes of
Kent and Medway being lost to development. At least 320 businesses are directly
associated with Heathrow, there are hundreds more supporting industries and
Heathrow employs 72,000 people. If the Thames Estuary airport were to replace
Heathrow many of these people would move to Kent and Medway, leading to
significant house building and infrastructure requirements.
4. The airport feasibility report by engineer Douglas Oakervee did not consider the risks
associated with operating an airport in close proximity to the existing import facility
for liquified natural gas (LNG) at Thamesport.
5. Kent International Airport at Manston has one of the longest runways in Europe and
this could be connected to the high speed train link already in place at far less cost.
6. The cost of a new airport would be prohibitive.
7. The noise, light and air pollution would be intolerable.
8. The airport would be fogbound and affected by high winds.
9. Nearly nine out of 10 international airlines that use Heathrow are against an
estuary airport.
10. Existing airports already have potential to increase capacity. For example,
Birmingham says it could double the passengers it carries. A high speed rail link
from London to Birmingham is already on the cards.

The effect on wildlife

Associated risks
Medway’s Liquid Natural Gas site at Grain

COUNCIL
14 JANUARY 2010
Agenda Item: 11A
THAMES ESTUARY AIRPORT – FEASIBILITY REVIEW
Portfolio Holders: Councillor Rodney Chambers, Leader
Councillor Phil Filmer, Front Line Services
Report from: Robin Cooper, Director of Regeneration and Development
Author: Steve Hewlett, Head of Integrated Transport
Summary
This report advises Members of the Thames Estuary Airport – Feasibility Review,
published in October 2009.
1. Budget and Policy Framework
1.1 The issue is whether to review Medway Council’s opposition to the
plans to construct a new Thames Estuary Airport.
1.2 This is a matter for Council because of the potential for decisions which
may seek to amend the existing policy framework and budget.
2. Background
2.1 Following a report to Cabinet on 17 February 2009, on 5 March 2009
Full Council considered proposals from the Mayor of London, Boris
Johnson for a new Thames Estuary Airport. Full Council agreed the
following:
The Council object to the Mayor of London’s proposal to construct a
Thames Estuary Airport on the following grounds:
(i) It is unnecessary and not wanted
(ii) The cost of an airport would be prohibitive
(iii) The current infrastructure would not cope with huge increases in
traffic
(iv) The environmental damage would be catastrophic
(v) The noise, light and air pollution would be intolerable
(vi) The risk of air strike from migrating and nesting wildfowl would be

high especially as this is an internationally important site for
wildlife
(vii) The airport would be disproportionately affected by fog and high
winds
(viii) The airport would lead to blight in the surrounding area including
falling property prices and uncertainty for many years about
inward investment into Medway
(ix) Kent County Council is promoting Manston as an airport
destination and this provides a viable alternative
2.2 The Mayor for London has employed Douglas Oakervee OBE to
advise him on the feasibility of an estuary airport. In October 2009 the
Feasibility Review was published, which provides more information
than was available when Members considered the proposal earlier in
the year. However, the details are still not subject to any formal
consultation as they are not a proposal from government.
2.3 This report is intended to enable Members to consider whether they
wish to review their previous decision taking into account the more
detailed information that is now available.
3. Summary of the Thames Estuary Airport - Feasibility Review
3.1 The study states that a new major airport serving London and the
South East will be needed by 2030, stating that the Department for
Transport’s “overwhelming” evidence showed a capacity shortfall of
“about 70m passengers per annum by 2030, even when all other
potential expansion is put in place”. The study notes that Heathrow has
been functioning at 99% operational efficiency, with approximately
477,000 Air Traffic Movements in 2008, and the prospect of this
increasing to 605,000 by 2020.
3.2 The review has identified a number of alternative Thames Estuary
Airport schemes that it alleges are being promoted by various
organisations. Several of these schemes have a direct, physical impact
on Medway, including schemes promoted by:
• Thames Reach Airport Limited and Metrotidal Limited
• Sir Terry Farrell & Scott Wilson
3.3 The study identifies the predicted level of growth in North Kent and
considers that the full potential of the regeneration goals will not be
reached without a catalyst, such as improved infrastructure and
transport links.
3.4 The report considers the main advantages and disadvantages of an
estuary airport and these details are reproduced in table 3.1 in this
report.

Table 3.1
Impact of an offshore airport
(Taken from Thames Estuary Airport - Feasibility Review, prepared by D. Oakervee OBE)
Advantages Disadvantages
• 24 hour operation
• Minimal pollution
• Approach not over central
London
• Reduced risk for residents
• Incremental expansion without
disruption
• A green airport
• The catalyst for regeneration
and wealth creation
• No CPO of land
• Distance from Central London
and transport links
• Reluctance of Airlines to move
and perceived loss of
premium revenue
• Air movement complicated
over SE England
• Possible loss of interline traffic
• Move in the centre of gravity
for business
• Capital costs will be high. How
will it be paid for?
3.5 Whilst the report considers that the project is technically viable, it does
recognise that the “delicate ecology of the area” and “very large bird
populations” must be central to any decision. Whilst the report does not
favour a specific location, it considers the most likely site would be in
the outer estuary some 4½ to 6 miles north east of Whitstable in the
direction of Shivering Sands Fort and the Kentish Flats Wind Farm.
3.6 The report considers that economies of scale could be achieved by
considering how the scheme could be integrated with the demands of
other government departments, such as adding in estuary crossings
and renewable energy farms. Furthermore, the study refers to the final
draft Thames Estuary 2100 report (TE2100), which details future
problems as a result of rising sea levels and extremes in weather
conditions largely brought about by climate change. TE2100 suggests
a multifunctional barrier with both transport links and tidal energy
generation would provide a more cost effective and sustainable
solution. The airport study considers that this proposition would be
further improved if provision for an estuary airport was made.
3.7 The report acknowledges that the Thames Estuary is one of the most
important ecological sites in Europe and forms a key part of the huge
ecosystem surrounding the North Sea. It recognises that not only are
birds protected by stringent EU and UK legislation, but so too are
certain species of fish, molluscs and crustaceans, to ensure safe and
secure breeding grounds.
3.8 The report considers that whilst the present investment will provide new
transport links such as Crossrail, Thameslink and HS2, further
improvements in the Thames estuary “will be necessary to support the
existing housing programmes let alone the expansion, development
and regeneration that would result should the major infrastructure being
proposed by this review be constructed”.

3.9 The review makes reference to the findings of the Dartford River
Crossing Study – A Lower Thames Crossing. The route options for a
crossing were shown diagrammatically in the Lower Thames Crossing
study and have been reproduced at Appendix A. The study discarded
options D1, D2 and E. The study was considered by Cabinet on 2 June
2009, when Members supported recommending to government that
options A, B & C be taken forward for further consideration. However,
the airport review considers that options D & E are worthy of further
consideration because:
• Option D is the alignment on which Metrotidal’s scheme is based
• Option E alignment would be close to where access is likely to be
needed for an estuary airport and outer barrier.
3.10 The option D, Metrotidal scheme is situated near the Cliffe Airport
proposal, which was rejected by the Government’s White Paper on
Aviation. The scheme proposes an additional road and rail crossing of
the Thames and incorporates both tidal lagoons for power generation
and a Thames Barrier as well as an airport. The scheme conflicts with
major conservation areas and the risk of bird strike is likely to be high.
Option D directly affects Medway.
3.11 It is unclear whether option E directly affects Medway, due to
inconsistencies in the Dartford River Crossing study – these errors
have been reported to government, but no response has been
received.
3.12 Officers are aware that the brief for the detailed Lower Thames
Crossing study is being prepared by DfT. Working with our local
authority partners in north Kent through a Multi Area Agreement, we
have requested participation in the preparation of the brief, but this has
been declined by the DfT. It is therefore unclear at this stage whether
options D and E have been included in the Lower Thames Crossing
study.
3.13 The review suggests that a new airport located in the Thames Estuary
is likely to be approximately 60 miles from the centre of London at
Charing Cross, compared to 17 miles from Heathrow, 29 miles from
Gatwick and 43miles from Stansted.

The proposed location of the airport is shown in the figure below,
(extracted from the review document prepared by Douglas E Oakervee
OBE FRENG.)
3.14 It is clear that if an airport were to be built in the estuary, the whole
pattern of traffic would change dramatically, at a national, regional and
local level. An airport of this size will demand high capacity, high quality
transport links, particularly to central London but also to regional and
local destinations. The report places great reliance on rail links and the
need to discourage the use of car trips to the site. The review
recognises that if the airport were to be built, there would need to be a
significant rethink regarding rail connectivity, and especially High
Speed Rail from the network to the airport if a maximum journey time of
40 minutes from Central London to an estuary airport is to be achieved.
The report details potential links to High Speed 1 and the proposed
High Speed 2. However, the report also recognises the importance of
motorway connections and proposes the following new motorway
infrastructure:
• connection to the south to be built across the Isle of Grain 1 to link
both the M2 and M20 to the airport crossing;
• Estuary crossing to a rebuilt A13 in Essex and then link the
improved A130/A120 to Stansted Airport and the M11.
1 This may be an error, as figure 16 shows rail across the Isle of Sheppey. This point was
raised by Medway Council with the DfT on the Lower Thames Crossing study.

3.15 The review comments on the importance of trade and leisure activities
that the river supports and states that “no activity must undermine the
performance of the Port of London”. The review also acknowledges the
significant contribution that Thamesport, Chatham Docks and the Port
of Sheerness make to the UK’s economy.
4. Advice and analysis
4.1 Recent revisions to government policy regarding climate change and
the requirement for an 80% reduction in carbon emissions by 2050
must be a central consideration to national air travel strategy. The
review recognises that future studies should be holistic, with climate
change as the main driver. Furthermore, the report acknowledges that
in the past the effects of climate change “have frequently been
underestimated and even now the seriousness of the problem is still
being realised”. The report notes that aviation currently contributes at
least 5% of the world’s total carbon emissions, plus the contribution
from the activities of airports and acknowledges that a “fundamental
change in air travel behaviour and technology will become a necessary
if climate protection measures…are to be achieved”.
4.2 The report acknowledges that any scheme that did not undertake
“appropriate amelioration measures then the impact on the precious
ecological reserve could be disastrous”. However, given the scale of
the likely impact, it is unclear how an acceptable level of mitigation
could be achieved. Furthermore, in responding to the likely impact on
the ecology, the report suggests that this must be balanced against the
“many and complex issues surrounding climate change, as well as the
needs and demands of a growing population”.
4.3 Regarding the potential location for an airport, the identification in the
report of Upper Heyford as the “centroid for overall passenger demand
for the whole of the UK” argues in favour of an airport facility to the
west of London rather than the east.
4.4 There is no doubt that high speed rail would be essential to serve the
airport. The Southeastern High Speed services (rather than Eurostar as
mentioned in the report) demonstrate that it is feasible to offer services
for journeys such as London to Ebbsfleet with high speed trains.
However, this is not to say that there is sufficient capacity available in
the current high speed network to accommodate the dramatic increase
in service which would be needed to serve the airport. One particular
constraint on capacity is the terminal at St Pancras station where there
is little scope for additional international or domestic services to or from
the high speed line.
4.5 The written description of the proposed high speed rail link and the
arrangements illustrated in Figure 16 of the Oakervee review differ
dramatically. The written description talks about a branch from HS1 via
Southend and the Airport to Ashford. This would be at least 48 miles of
brand new high speed line and would make little use of HS1 except in

the capacity constrained London approaches. It would not offer links for
airport workers or users from North Kent to the airport except by way of
Stratford or Ashford, which would be very indirect routes and lose any
benefits of high speed travel. However, the illustration at Figure 16
shows a line branching off HS1 south of Sittingbourne to the Airport. In
practice, HS1 is south of the North Downs in this area so the branch
would need to climb the scarp of the Downs. This service would leave
HS1 between Ebbsfleet and Ashford stations. Medway passengers,
therefore could only access the airport with this route by “backtracking”
to Ebbsfleet. Neither option would overcome the terminal and line
capacity constraints at the London end of the HS1.
4.6 The report highlights the opportunities offered by HS2 – the proposed
high speed line from London northwards. This line is by no means
committed, with the route and the London terminal being a long way
from being resolved. One benefit of the airport proposal is that it would
strengthen the case for the London terminal for HS1 and HS2 being
linked, which would improve cross –London travel opportunities.
4.7 The report states that “…by 2030 it is inconceivable that the lines
serving both north Kent and south Essex will not have been upgraded
sufficiently to enable a high speed Javelin service to the airport from
the suburbs of London”. However, it is entirely conceivable that this will
not happen.
4.8 Whilst the report places great emphasis on serving the site by rail, as
demonstrated this is not without significant problems particularly for
local accessibility. Local employment opportunities are significant, but
possible problems with local access by rail services could result in a
high level of unsustainable trips by car.
4.9 There is little detail of the new road links in the report. However, the
written description of the links would appear inconsistent with the
diagram at Figure 16 of the Oakervee review. Page 50 of the review
describes the connection to the south as being “built across the Isle of
Grain to link both the M2 and M20 to the airport crossing”. Figure 16
shows the rail connection to the Isle of Sheppey and it is assumed for
economic purposes that the road connection would follow the same
route as the rail connection. Clearly from Medway’s point of view this
inconsistency is highly significant, as one option would have a direct,
major impact on the area. Furthermore, the report takes no
consideration of the capacity of the M2, M20 and the strategic road
network further afield, which are all likely to require significant
upgrading.
4.10 The impact of both the road and rail links to the proposed airport on the
environment could be catastrophic and this issue has not been
considered by the review.
4.11 The South East England Partnership Board is commissioning a
transport study on the transport corridor between London and Dover
Docks on behalf of government. This study will incorporate the M2 and

M20 corridors and it is understood that the study will not take into
account the proposals in the Thames Estuary Airport Feasibility
Review.
4.12 The report acknowledges that “bird strikes are a real issue” but
considers “there are ways to overcome the problem without being
aggressive towards birds” although it is unclear how this would be
achieved. It also suggests that the RSPB should be used to resolve the
issue of birds at an estuary airport. This is naïve when the RSPB have
already put themselves forward as a main objector to the scheme.
4.13 The report considers that the estuary presents an opportunity for tidal
energy to make a “meaningful” contribution to the overall needs of the
region. But, the estuary was not identified by Government as one of the
preferred locations in the UK for this purpose. Furthermore, the
adverse impact of tidal energy generation on the rich inter-tidal mud
flats in the estuary on which vast numbers of migratory birds feed has
not been determined. In addition, the increased risk of flooding as a
result of the impact of the airport on a surge tide has not been
determined.
4.14 Finally, the review has not considered the risks associated with
operating an airport in close proximity to the existing import facility for
LNG (Liquefied Natural Gas) at Thamesport and the proposed London
Array wind farm. The wind farm is a joint venture being developed by
three international companies with renewable energy interests. The
wind farm would be located more than 12 miles from the Kent and
Essex coast in the outer Thames Estuary. This is one of three strategic
areas in the UK that has been identified by government for offshore
wind farm development.
5. Benefits and disbenefits to Medway
5.1 It is likely that an airport would bring significant benefits to the local
economy and the regeneration of the area, by creating a significant
amount of direct and indirect employment and business opportunities.
However, the airport could bring major, unacceptable disbenefits,
including:
• Direct environmental destruction by causing harm to Sites of
Special Scientific Interest and internationally important areas where
hundreds of thousands of birds migrate to annually. The airport
would destroy huge areas of legally protected habitat.
• Encouraging more air travel which is likely to exacerbate climate
change. Assuming the airport would create new capacity, it is likely
that the proposal is contrary to the national statutory target to
reduce carbon emissions by 80% by 2050. Furthermore, increased
emissions from aircraft and associated passenger and freight
vehicles accessing the airport could significantly add to existing
local areas of known poor air quality.

• Significant risk of bird strike as the Thames Estuary is a hub for
hundreds of thousands of birds. Even with an aggressive bird
hazard management programme, such as shooting or scaring birds
away, the bird strike hazard would be up to 12 times higher than at
any other major UK airport (source: RSPB).
• Harm to areas of landscape importance by the construction of major
road and rail infrastructure links from the airport to the strategic road
and rail networks.
• Increased pressure for additional major development due the
increased attractiveness of the area. This could result in areas of
high landscape importance being lost to development, thereby
being detrimental to the local environment.
• Kent International Airport at Manston has one of the longest
runways in Europe that could be connected to HS1 at far less cost.
5.2 Therefore, whilst there could be economic benefits from an airport,
these would be hugely outweighed by the environmental damage and
other detriment to the area such an airport would bring. It is therefore
considered that the additional information contained within the
Feasibility Report does not alter the view taken by Cabinet on 17
February 2009 and Full Council on 5 March 2009. It is considered that
only by carrying out a much more detailed wider London and the south
east connectivity and accessibility study would any justification for the
location of a new airport in the south east be determined.
6. Consultation
6.1 Working in partnership with Kent County Council and the RSPB,
Medway Council has taken the lead on a “Stop the Estuary Airport”
campaign, with high profile media campaigns and a dedicated
campaign website. In summary, the campaign considers the project to
be undeliverable, unaffordable and unnecessary, and has raised the
following grounds for objection:
• Immense damage it would cause to the area’s internationally
important wildlife and the wider environment
• Exacerbate climate change
• High cost of construction
• Significant risk of bird strike
• It would require huge unsightly highways to be built linking the
airport to the motorway network
6.2 At the time of writing support, the campaign had been supported by
1,342 people on the website.
6.3 Given the concerns regarding the significant impact on the environment
and the high risk of bird strikes, it is considered that meaningful
proposals for environmental mitigation in line with the requirements of

the EU Birds Directive and the EU Habitats Directive are developed
prior to the principle of the scheme being considered further.
7. Cabinet
7.1 The Cabinet considered this report on 5 January 2010 and its
recommendations are set out in paragraph 10 below (decision no.
2/2010).
8. Risk Management
8.1 Risks associated with the development of a Thames Estuary Airport
are detailed in the table below.
Risk
Development of
Thames Estuary
airport.
9 Financial and legal implications
Description
Proposal to develop
an estuary report
obtains stronger
policy weight.
Action to avoid or
mitigate risk
High profile campaign
to raise awareness of
the devastating
impacts of the
proposal.
Respond to all
published proposals.
9.1 At present costs can be contained within existing budgets. However if
the proposal is taken to formal consultation by the government the
need to employ aviation and other experts so as to be able to consider
any planning issues properly and to be represented at planning
inquiries will led to significant costs to the Council.
10. Recommendation
10.1 That Council reaffirms its opposition to the plans to construct a new
Thames Estuary Airport and that Douglas Oakervee (the author of the
report) be contacted to:
- advise that any justification for the location of a new airport in the
south east could only be considered once detailed London and the
south east connectivity and accessibility studies had been
undertaken;
- seek to clarify the route of the road and rail links, as detailed in the
report;
- draw to his attention the risks associated with the close proximity of
the existing LNG import facility at Thamesport and the proposed
London Array wind farm; and

- seek early meaningful proposals for environmental mitigation in line
with the requirements of the EU Birds Directive and the EU Habitats
Directive.
Lead officer contact
Steve Hewlett
Head of Integrated Transport
Ext: 1103
Email: steve.hewlett@medway.gov.uk
.
Background papers
• Reports to Cabinet dated 17 February 2009 and Full Council dated 5
March 2009
• Thames Estuary Airport Feasibility Review (prepared by Douglas
Oakwevee MBE, dated October 2009)
• Related web sites:
- Campaign website: www.stopestuaryairport.co.uk
- Thames Estuary Airport – Feasibility Review:
http://www.testrad.co.uk

Appendix A - Major Option Assessment routes for Lower Thames
Crossing

Summary
Thames Estuary airport: Oakervee feasibility review
RSPB critique
Douglas Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October
2009 following a request from London’s Mayor, Boris Johnson for the feasibility of an
airport in the Thames Estuary to be evaluated.
An airport in this location is not a new idea; it has previously been considered and
rejected, partly because of the ecological sensitivity of the Thames Estuary Location. The
Thames Estuary has nine internationally important nature conservation designations,
the majority of which relate to rare and vulnerable bird species.
These designated sites already experience significant pressure from an array of existing
activities and developments that occur in that broad location. The pressure also
continues to increase, with several other projects, such as major port developments and
energy infrastructure, being proposed in the area.
The environmental effects of an airport in this location are likely to be significant and
wide ranging. They could include the loss of protected habitat, disturbance of sensitive
protected species, increased atmospheric emissions, including emissions of greenhouse
gases, and alteration to the hydrodynamics of the Estuary resulting in accelerated
patterns of erosion and/or deposition. These effects could lead to a population scale
decline of bird populations in and around the Thames Estuary.
The scale of potential effects would result in likely significant effects on protected
habitats and species in the internationally designated nature conservation sites. These
adverse effects would be very difficult, and in all probability, impossible to mitigate.
Given the range of alternatives solutions to the airport available and in the absence of
imperative reasons of overriding public interest, an airport in the Thames Estuary could
not be consented without contravention of UK law on the protection of nature
conservation. The RSPB therefore views the proposal as a totally unfeasible and
impractical scheme.
1

Introduction
An airport in the Thames Estuary has previously been considered in the Government’s
2003 Aviation White Paper, to which all key players, including the aviation industry,
contributed. The White Paper conclusively ruled out an airport in the Thames Estuary.
Despite this however, London’s Mayor, Boris Johnson, requested a study into the
feasibility of the potential for an airport in the Thames Estuary. Subsequently, Douglas
Oakervee produced the ‘Thames Estuary Airport Feasibility Review’ in October 2009.
From the very outset of London’s Mayor first raising the idea of developing a major new
airport in the Thames Estuary, the RSPB has had serious concerns about the likely
environmental consequences. However, the Feasibility Review falls short of adequately
considering the likely environmental effects of such a proposal and thus the feasibility of
creating an airport in the estuary. As such, the Review fails to alleviate the RSPB’s
concerns regarding the likely direct and in-direct environmental effects, as well as the
consequences on the UK’s ability to meet commitments to its climate change targets.
The importance of the Thames Estuary and the designated sites for conservation
The RSPB is pleased to see that Oakervee acknowledges the internationally outstanding,
sensitive environment of the Thames Estuary:
“When reviewing the Thames Estuary and the creation of a sustainable
future for London and the South East of England…we must recognise the
sensitivity of the environment and safeguard it to the best of our ability. The
challenges we face in the Thames Estuary are complex and the approach
needs to be rethought if we are to avoid leaving future generations an even
bigger challenge with an even bigger price tag.” (page 21).
The challenges in the estuary are indeed complex, and the consequent approach to
managing the estuary needs to reflect this. With such a proposal likely to result in
significant environmental damage, a “rethought approach” for a “sustainable future”, as
Oakervee suggests, should logically discard the idea of an estuary airport as wholly
unfeasible.
The Thames Estuary is a dynamic place formed by the meeting of the Thames, the North
Sea and the landforms of London, Kent and Essex. The estuary is an area of outstanding
international importance for birds; reflected by a network of Special Protection Areas
2

designated under EU Directive and protected accordingly. The estuary has the highest
concentration of bird species in internationally important numbers in the south east. The
diversity of waterbird species places the estuary in the top five internationally important
sites in the UK, out of 143 recorded.
Whilst the Oakervee Review acknowledges the conservation importance and
environmental sensitivities of the estuary, it wholly fails to comprehend the real
implications of an airport in the estuary, instead choosing to adopt the line that the
environmental harm arising from such an airport can be managed.
Thames activities/developments
The Thames Estuary area is currently the focus of many existing activities including
large-scale commercial port operations, minerals extraction, dredging, transportation,
recreation and numerous energy projects. The area is also presently the focus for new
developments in a variety of sectors including further large-scale port and energy
projects.
These activities alone, and together with other pressures such as climate change, exert a
significant pressure on the sensitive habitats and species in the Thames Estuary. These
existing pressures may also be exacerbated if potential future developments that may
also have an impact on the estuary, such as the proposed lower Thames crossing, get the
go ahead.
Impacts on designated nature conservation from an airport in the Thames Estuary
As acknowledged in the Feasibility Review, an airport in the Thames Estuary could
clearly result in significant environmental effects:
“It takes little imagination to appreciate that if any of the proposals or
schemes under consideration were introduced without appropriate
amelioration measures then the impact on this precious ecological reserve
could be disastrous and in this day and age almost certainly unacceptable”
(page 28).
However, despite recognising this, the Review fails to understand that an airport in the
estuary is an impractical and unfeasible proposition, with very little opportunity to
apply “appropriate amelioration measures”. As such, an airport will undoubtedly result
in significant damage to the environment, protected habitats and species. Further to this,
it is unfortunate and disappointing that the Review, when listing the impacts of an
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airport in the Thames (on page 40), does not identify potential significant environmental
harm as a “disadvantage”.
Instead, the Review proceeds with considering a broad location of a possible airport as
approximately “7Km to 10Km north east of Whitstable in the direction of the Shivering Sands
Fort and The Kentish Flats Wind Farm”.
Due to its location, the proposal has the potential to directly and indirectly impact on of
a range of internationally protected nature conservation sites (Special Protection Areas
(SPAs), Special Areas of Conservation (SACs) and Ramsar sites), including:
- Essex Estuaries SAC;
- Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar;
- Benfleet and Southend Marshes SPA and Ramsar;
- Thames Estuary and Marshes SPA and Ramsar;
- Medway Estuary and Marshes SPA and Ramsar;
- The Swale SPA and Ramsar;
- Thanet Coast SAC; and
- Thanet Coast & Sandwich Bay SPA and Ramsar.
In addition, the airport would have a direct impact in the Outer Thames proposed SPA
(pSPA), and the Margate and Long Sands possible SAC (pSAC). Government policy
affords the same level of protection for a pSPA as it would a designated SPA. A
candidate SAC (cSAC) is also afforded the same level of protection as a classified SAC.
However, although the pSAC is not afforded the same protection as a cSAC, we strongly
recommend that this site be considered as though it were a cSAC, since this classification
is likely to come into effect by the end of 2010.
Designated for a wide range of species and habitats, these sites are also underpinned
and protected by the national Site of Special Scientific Interest (SSSI) notification.
The Feasibility Review also identifies that access to the airport would be via new road
and rail infrastructure from the Kent and Essex coastlines. Whilst not certain at this
stage, it is suggested that tunnels would be utilised for the sea section of the routes. The
broad location of these new infrastructure developments could potentially coincide with
the Thanet Coast & Sandwich Bay SPA and Ramsar, The Swale SPA and The Swale SAC,
on the Kent coastline in addition to the Benfleet and Southend Marses SPA and Ramsar,
the Foulness (Mid-Essex Coast Phase 5) SPA and Ramsar, and the Essex Estuaries SAC
on the Essex coastline.
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There are clearly, therefore, a large number of internationally designated nature
conservation sites that could be affected (both directly and in-directly) by a new airport
in the Thames Estuary. The potential impacts on protected bird species, from the airport
alone, are numerous and significant. These include:
- direct loss of bird foraging habitat (and thus a reduction of food resource) in the
Outer Thames Estuary pSPA;
- disturbance to birds from airport construction, including noise, vibration and
lighting effects, resulting in displacement of a large (foraging) area in the estuary;
- disturbance to birds from airport operation, resulting in displacement of a large
(foraging) area in the estuary;
- direct loss of (foraging, roosting and/or loafing) coastal and inland bird habitat
due to airport transport links to Essex and Kent;
- disturbance to coastal and inland sites from associated transport links to Essex
and Kent;
- potential alterations to hydrodynamics – flow changes can resulting accelerated
patterns of erosion and/or deposition and therefore potential loss of intertidal
habitat;
- atmospheric pollution - NOx is the principal pollutant arising from aircraft and
road traffic associated with airports. Deposition of nitrogen compounds (nitrates
(NO3), nitrogen dioxide (NO2) and nitric acid (HNO3)) can cause eutrophication
of soils and water. This alters the species composition of plant communities and
can eliminate sensitive species; and
- water pollution as a result of accidental spillage of aviation or other fuel.
From loss of foraging, roosting and/or loafing habitat, through direct and indirect
habitat loss and from increased human disturbance, bird populations could face decline
in and around the Thames Estuary. This will have knock on effects for the environment
and wider ecosystem because of the Thames Estuary’s international importance (being
in the top five internationally important sites in the UK) due to the numbers of
waterbirds found there during winter and on migration 1 .
Safety and bird strike
The hazard to aircraft from bird strike is well known and at estuary sites, an obvious
concern. The Feasibility Review, although recognising bird strike as an issue, suggests it
is solvable:
1 Waterbirds in the UK 2006/07 – The Wetland Bird Survey (WeBS), Graham Austin, Mark Collier, Neil Calbrade, Colette
Hall and Andy Musgrove, British Trust for Ornithology, Revised edition (28 Aug 2008)
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“data indicates that although bird strikes are a real issue there are ways to
overcome the problem without being aggressive towards the birds. Whilst
much is written on how best to resolve the problem and should be reviewed in
detail, I believe the issue should be addressed with the RSPB to find the right
solution for the Thames Estuary” (page 51).
The RSPB considers it impossible to control bird strike risk for an airport in this location
without “being aggressive towards birds”, since attempting to control the risk of bird
strike will require many invasive techniques, including intensive and wide spread bird
scaring.
In the RSPB’s response to the Air Transport White Paper in 2003 2 , we drew attention to
our concerns regarding aircraft safety at an airport at Cliffe, which was to be located in
the midst of the Greater Thames (in a similar position to that of a possible Thames
Estuary airport).
With regards to an airport at Cliffe and the 2003 Air Transport White Paper, several
studies were undertaken to assess bird strike, including research commissioned by the
Secretary of State for Transport. All studies concluded a significant risk of bird strike,
with the Secretary of State’s report (by CSL and BTO, published in March 2003)
concluding that:
• “Without a comprehensive and aggressive bird management programme in
place, incorporating careful and considered airport design, appropriate habitat
management and active bird control, an airport could not operate safely in this
location.
• Even with such world class management and mitigation measures in place, the
hazard posed by birds is severe and would probably be higher than at any other
major UK airport.”
Pages 203-4 of the CSL/BTO report place this in perspective. The expected number of
damaging bird strikes at an airport at Cliffe would be between 2.97 and 8.65 per year,
whilst total hull loss would be expected to occur between 1 in 102 years and 1 in 297
years. Yet, for ten of the largest civil airports in the UK, the estimated rate of total hull
loss is between 1 in 304 and 1 in 1210 years, with a mean of 1 in 653.5 years.
2 Future Development of Air Transport in the UK – South East (Second Edition), RSPB consultation, May 2003
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In other words, the hazard associated with the Cliffe option was, at best, equal to the
greatest risk at any of the top ten UK civil airports in 2003 and, at worst, the level of risk
was up to 12 times higher. And this is with a bird hazard management regime in place
which would have a major adverse impact on the waterfowl and waterfowl habitats of
the SPA.
The RSPB therefore concluded that the level of bird strike risk associated with the Cliffe
option was unacceptable, in terms of human safety. We further concluded that the
habitat modification and active bird scaring measures associated with reducing the level
of bird strike risk even to this unacceptably high level was also wholly unacceptable in
terms of its implications for the SPA.
With many similarities between possible airports at Cliffe and in the Thames Estuary,
we are very concerned that the risk of bird strike could be of at least a similar scale and
nature.
A key consideration in assessing bird strike risk is bird flight lines. However,
the Feasibility Review does not attempt to provide any primary information on bird
movement within the broad airport location, but instead makes reference to flight path
mapping provided by MetroTidal:
“MetroTidal in their studies have produced a map of the flight paths across
the estuary and is included as Figure 20 below. If this is representative of the
actual situation it would appear that the likely location is relatively free from
bird movements. This coincides with my own visit to the area” (page 51)”.
It is very concerning that the conclusion is reached that “the likely location is relatively free
from bird movements” when the MetroTidal study appears to relate to a location further to
the west of the broad airport location. Furthermore, the robustness of the MetroTidal
data is unclear, as no details are provided on the timing or duration of the study.
Decision making
With any proposal for an airport in the Thames Estuary, the Habitats Regulations 1994 3
(among other requirements such as environmental impact assessment) will apply. And
as such the relevant competent authority will have to determine whether the project is
likely to have a significant effect on either the Ramsar sites 4 , the SPAs, pSPA 5 and/or the
3 Conservation (Natural Habitats &c.) Regulations 1994 as amended (the Habitats Regulations)
4 As a matter of government policy the procedures applicable to SPAs and SACs apply to Ramsar sites - Paragraph 5 of
ODPM Circular 06/05
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SACs (known collectively as the European sites) either alone or in combination with
other plans or projects 6 .
The Likely Significant Effect Stage - any project not directly connected with or necessary
to the management of an European site is to be subject to an appropriate assessment of
its implications for that site in view of the site's conservation objectives if it cannot be
excluded, on the basis of objective information, that it will have a significant effect on
that site, either individually or in combination with other plans or projects.
If the project is likely to have such an effect there is a legal duty for the competent
authority to make an appropriate assessment of the implications for the European sites
in view of those sites’ conservation objectives. The project can only receive permission if
it can be ascertained that it will not adversely affect the integrity of the European sites 7 .
As part of the appropriate assessment mitigation measures can be considered. The
Feasibility review in recognising the potential impacts on the environment, suggests
that:
“It will…be necessary to pioneer mitigation measures to create equal habitats
to maximise the survival potential of all.”
However, whilst there may be some mitigation measures available to avoid and/or
reduce the harm, providing “equal habitats” will only compensate for the harm/loss
rather than avoid or reduce the harm. The RSPB believes that many effects of such a
proposal on protected species cannot be mitigated, and therefore adverse effects cannot
be avoided.
If it cannot be ascertained that the project will not adversely affect the integrity of the
European sites, the provisions in regulations 49 and 53 of the Habitats Regulations
would fall for consideration namely that there are no less damaging alternative solutions
to the project, there are imperative reasons of overriding public interest to justify the
project receiving permission despite the adverse effects on the integrity of the European
sites and that compensatory measures can be provided before those effects occur.
The RSPB believes that there are alternatives solutions to the project and that there are
no imperative reasons of overriding public interest. Finally, we believe it would also be
extremely challenging, if not impossible, to replicate the habitats lost elsewhere.
5 Government Policy affords the same level of protection for a pSPA as it would a designated SPA
6 Regulation 48(1) of the Habitats Regulations
7 Regulation 48(5) of the Habitats Regulations
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Climate change
The RSPB welcomes the Feasibility Review’s acknowledgement of the seriousness of
climate change and the recognition of the scale of reductions in emissions required:
“Recent revisions to government policy with respect to climate change and
the requirement for an 80% reduction in carbon emissions by 2050 must be
the driving force behind many major decisions and how we live in the years
to come.” (Page 23).
It is therefore surprising and concerning that the Review fails to address the issue that
the carbon costs (of both constructing and operating a new airport in the Thames
Estuary) would be entirely at odds with the Government's carbon reduction
commitments.
Such a proposal will lock the UK into yet more carbon-intensive infrastructure for
decades. If the airport were to be progressed therefore, it would place a huge and
expensive burden on other sectors of the economy to decarbonise even further to
account for the contribution from aviation.
With the greater travel distances between London and the proposed airport compared to
London’s existing airports 8 , the additional distances required to travel to the new airport
would have a further significant carbon cost.
In any serious proposal, we would expect to see detailed analysis of the carbon cost of
building and operating the airport, together with measures for mitigating the substantial
carbon release. However, we do not believe that a development of this size or nature
could adequately mitigate these impacts in an increasingly carbon-constrained world.
Conclusion
We are very concerned that the Thames Estuary is even being considered as a location
for a new international airport. The proposal is likely to harm the sensitive estuarine
habitats and species of the designated sites through habitat loss, noise disturbance and
atmospheric pollution.
Given the evidence of the impacts of climate change on biodiversity and the significant
and rapidly increasing contribution aviation is making to global warming, the RSPB also
8 The proposed airport would be some 96 km to Charing Cross, whilst Heathrow is only 28 km and Gatwick 47 km from
Charing Cross.
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has serious concerns that a new airport is likely contribute to environmental degradation
via exacerbating climate change and would seriously hamper all attempts to cut the
UK’s greenhouse gas emissions.
10