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Swansea Airport No Expansion submission on Section 6.8 Airport of Unitary Development Plan: Pre-Deposit Draft and associated Goals, policies and sections.

1. Introduction to SANE and the context of this Submission
Swansea Airport No Expansion (SANE) is a broad coalition of groups and individuals opposed to the expansion of Swansea Airport on economic, ecological, socio-cultural and health grounds. SANE was formed following two conferences on sustainable development hosted by the City and County of Swansea (CCS) from 3-5.12.02 as part of CCS's commitment to sustainability. At the first of these conferences delegates identified an increase in unsustainable transport as one of the three most significant blocks to sustainable development. Aviation is the most unsustainable form of transport, causing more pollution per passenger mile than any other transport mode. Whilst delegates at both conferences identified proposals to expand Swansea Airport specifically as a key block to sustainability, the second conference identified a lack of public participation and debate regarding proposals to expand Swansea Airport as an issue to be addressed by delegates directly. SANE formed following these conferences in order to address the significant block to sustainability created by plans to expand Swansea airport.

SANE therefore has established a remit to develop capacity for participation on this issue within Gower and Swansea and to foster a more thorough analysis of the implications of Swansea Airport's expansion. SANE has recently completed Phase I of its Public Consultation and Participation Programme. Phase I involved hosting a series of four public meetings attended by over 200 people at which members of the public made over 1500 comments . Collating, coding and analyzing these comments is a lengthy process, which will result in a Report due to be produced by 20.04.03.

Given CCS's commitment to sustainable development and participation (see below) it is somewhat surprising that there has been so little public consultation or participation on the issue of airport expansion. Part of SANE's remit, as mentioned above, is to remedy this omission. In the interests of public consultation and participation at the heart of sustainable development, therefore SANE recommends that the findings of this report be fed into any policies regarding the Airport within the UDP.

2. City and County of Swansea's Commitment to Sustainability and paragraph 6.8.1.and Policy AS12
2.1 Introduction

Whilst sustainability is a core aim for City and County of Swansea (CCS), and placed centrally within the UDP, paragraph 6.8.1.and Policy AS12 contradict this commitment.
2.2. The City and County of Swansea's commitment to Sustainable Development

A commitment to sustainability is one of the core aims of CCS. This commitment led CCS to host the two conferences mentioned above. Of the six Key Aims within CCS's Corporate Strategy for 2002-2004, the commitment to sustainable development is placed centrally:

'No.4. Swansea sustains and safeguards future generations.
Key word: Sustainability'
(http://www.swansea.gov.uk/sustainabledevelopment/policy.htm)

In order to implement this commitment CCS aims to 'Engage in partnerships with a wide variety of individuals and organisations to move towards a more sustainable community' and 'Ensure the Council itself acts in an environmentally responsible way.'
http://www.swansea.gov.uk/sustainabledevelopment/policy.htm)

Paragraph 1.1., p.5 of the UDP (in this submission UDP refers to Unitary Development Plan: Pre-Deposit Consultation Draft) states that the UDP's 'purpose is to promote sustainable development and support community planning'.

Encouraging people to fly, rather than carry out business/leisure locally, to tele conference or to travel by rail directly contradicts these aims. It is clear from recent UK Government reports such as that by the Royal Commission and the Sustainable Development Commission that CCS's commitment to sustainable development means it should be encouraging the use of rail and other alternatives to flying rather than seeking to further expand the unsustainable aviation sector. The Royal Commission Report, for example, notes:

'the disproportionately large fuel use for very short flights, including all UK domestic flights and many flights within Europe (...) precisely the journeys for which efficient rail travel should be available.' (Royal Commission on Environment Pollution, 2002, p. 24).

CCS has a Sustainable Development Policy, which was adopted by Council in April 1997. The policy is as follows:

To maintain the balance and diversity of life through local action to protect and care for the variety of animals, plants and landforms in the area.
To reduce the consumption of resources, to re-use resources as far as possible and, if waste is produced, to ensure that it is recycled.
To minimise the Council's adverse environmental impact of the use of transport particularly by the promotion of alternatives to the private car.
To reduce the environment impact of the goods and services consumed by the Council through a sensitive purchasing policy and the influencing of companies and other organisations with whom the Council deals, by means of specifications or conditions to adopt the same standards.
To raise the level of awareness of sustainable development issues in the Council and provide training in relevant aspects of the policy.

Expanding Swansea Airport clearly contradicts several elements of this Policy, as well as several Goals, objective and policies within the UDP:

Fairwood Common and the surrounding area are locally, nationally and internationally important sites (AONB, SSSI, SAC ). Airport expansion appears to contradict the commitment to biodiversity, which could be particularly sensitive to the impacts of increased aviation through, for example, increased nitrogen deposition on sensitive heath land. Thus policies EV23, EV24, EV25, EV 26 and EV 27 are all potentially compromised by paragraph 6.8.1.and Policy AS12.

As mentioned above, and in the Royal Commission Report (2002), a modal shift towards local and regional flights will increase the 'consumption of resources' and maximize, rather than 'minimise the Council's adverse environmental impact of the use of transport…'.

Equally, Goal 5 on maximizing access for all is compromised, as are objectives 5.a., 5.b., 5.c., and 5.f. (UDP, p. 8-9).

Objective 5.c., for example: 'To improve safety and reduce the adverse environmental impacts of transport' is clearly contradictory to the aim of expanding Swansea airport. Increasing either flight or passenger numbers would involve a modal shift towards aviation, the most polluting form travel, not to mention the increase in car traffic to and from the airport.

Within Section '3.6 Health and The Environment' (UDP p.70 objective 2.j. 'To avoid unacceptable adverse environmental impacts from new development') is compromised by paragraph 6.8.1.and Policy AS12 as it would not avoid, but encourage further pollution and there has been no study of what levels of pollution are involved and what, therefore would constitute appropriate levels.

It is clear from the Sustainable Development Policy and contradictions within the UDP that CCS has not yet fully embraced or understood the environmental costs of aviation. For example, in the point on minimizing the environmental impact of transport the SD Policy mentions shifting modes from the car 'particularly by the promotion of alternatives to the private car', whilst objective 5.b. is 'To reduce reliance on the car'. However, neither the SD Policy, nor the UDP mention the need to reduce our use of aviation, which, per passenger mile is far more polluting than even the private car. Equally, as a sector aviation is growing at a faster rate than car travel and therefore the pollution from aviation is the most rapidly growing of any transport sector.

Finally, the SD Policy obliges CCS: 'To raise the level of awareness of sustainable development issues in the Council and provide training in relevant aspects of the policy', whilst consultation is clearly central to the UDP. There is an urgent need, therefore, for greater awareness of the impacts of aviation within CCS and the wider public, there should be a clear policy of no further expansion of activities at Swansea Airport and in addition to this the policy should include raising awareness of the environmental, social, cultural and economic implications of aviation. This educational programme should be carried out either by CCS's sustainable development unit, or by independent consultants.

3. The Need for an Environmental Impact Assessment
3.1. Introduction

This section considers the relevance Environmental Impact Assessment (EIA) legislation may have for Swansea Airport's expansion as proposed in paragraph 6.8.1.and Policy AS12. The case for EIA is strong as there are several specific references pertinent to this paragraph 6.8.1.and Policy AS12 within the relevant legislation. This section therefore leads to the conclusion that paragraph 6.8.1.and Policy AS12 would require a full independent EIA.

3.2. EIA Policy - Schedule 2 developments and 'significant' impacts

The EIA Directive (85/337/EEC) came in to effect as of 06.88. An amending Directive (97/11/EC) came into effect on 14.03.99. The main enabling Regulations relating to Environmental Assessment are the Town and Country Planning (Assessment of Environmental Effects) Regulations 1988 and Town and Country Planning (Assessment of Environmental Effects) Regulations 1999 (both covering England and Wales). This legislation creates two categories of development, which require EIA. Annex 1 developments (referred to as Schedule 1 within the UK enabling legislation) are those large projects like nuclear power stations, where an EIA is mandatory. Annex 2 (Schedule 2 within UK enabling legislation) developments require EIA if the development is likely to have a significant effect on the environment. Each application must be considered on it own merits. A project may have a significant effect on the environment by virtue of its size, location or nature. In particular, the sensitivity of the receiving environment will be a factor in the evaluation.

There are a considerable number of instances where EIA is required as developments are likely to have significant effects on the Environment. Whilst airports with a runway length of 2, 100m and above fall into Schedule 1, requiring mandatory EIA, airports with a runway length below 2, 100m are specifically mentioned throughout the EIA literature and legislation. The UK Office of the Deputy Prime Minister, for example, states:

'Airports; smaller airports (i.e. runway under 2,100m) will generally require EA'
(http://www.planning.odpm.gov.uk/eia/assess/doc02.htm)

This policy position alone places a strong presumption in favour of an EIA in the case of Swansea Airport, which has, to our knowledge, received no EIA to date on any aspect of its development. However, there are other aspects of the EIA legislation which further emphasis that paragraph 6.8.1.and Policy AS12 require EIA. For example, one provision states that size is not the only factor determining whether or not an EIA is needed:

'Smaller schemes may require EA in particularly sensitive areas' (http://www.planning.odpm.gov.uk/eia/assess/doc02.htm)

Whilst this policy gives the example of smaller developments in historic towns, it seems particularly pertinent to Swansea Airport, located as it is on Britain's first designated AONB as well as having SSSI and cSAC status.

Furthermore, the nature of a development is particularly important in determining the relevance of an EIA. In this case paragraph 6.8.1.and Policy AS12 clearly forms part of a wider series of developments. Application No.2002/2203 (Gantry and Information Landing System), for example, was passed by Council on 11.02.02, with no evaluation of the potential this development had in contributing towards further airport expansion. Such implications, however, are clear from statements made by the developer's own agents . Furthermore, there are other applications still sitting with CCS that form yet further components of these wider expansion plans, including application numbers 2001/1135 and 2003/0052. From this it is clear that the nature of paragraph 6.8.1.and Policy AS12 is that they form part of wider development and cannot be considered in isolation from these.

If the question of whether an Environmental Assessment is required is unclear, the developer is formally able to obtain the local planning authority's opinion on the matter. If an opinion is requested, the developer will write to the local planning authority providing specific information about the project.

If the opinion is that Environmental Assessment is required, and the developer accepts this, the planning application for the development must be accompanied by an environmental statement. If the developer disagrees with the opinion the developer can ask the Secretary of State for a direction on whether Environmental Assessment is necessary. The Secretary of State will try to issue his/her direction within a period of 3 weeks. There is no appeal against the Secretary of State's direction.

'If a third party feels that a proposed development should be subject to Environmental Assessment but is progressing without one, they may contact the relevant planning authority to set out their views.' (http://www.planning.odpm.gov.uk/eia/assess/doc02.htm)

4. Suggested Changes

4.1 Goal 5 should be consolidated with 2 additional Objectives:
'To reduce the need to travel through careful planning and mixed use development
To order travel modes so the most sustainable modes are given priority.'
Whilst some forms of travel encourage health and community, others are more polluting, socially exclusive and disruptive of community. The most sustainable forms of travel are walking and cycling, followed by train, bus, taxis, private car then flying, which is the most polluting form of travel, emitting the most pollution per passenger mile. The ecological footprint, i.e. the measurement of the ecological impact of air travel, is at least 3 times that of an equivalent bus or train journey. This figure does not even take into account the mentioned higher impact of upper atmosphere emissions (Sharing Nature's Interest, 2000, 86). The Royal Commission on Environmental Pollution concluded that short-haul flights like those proposed from Swansea Airport 'make a disproportionately large contribution to the global environmental impacts of air transport', with CO2 emissions per passenger-mile 'at least an order of magnitude' higher than a comparable rail journey.
4.2. Paragraph 6.8.1., Policy AS12 and the associated amplification should be replaced with the following:
'Aviation is the most unsustainable form of transport as it emits the most pollution per passenger mile and is the least socially accessible. It is envisaged, therefore, that Swansea Airport will remain primarily recreational.
Given the unsustainable nature of aviation and the highly sensitive nature of the Airport's location, there will be a presumption against further expansion of operations at Swansea Airport.
Developments that may facilitate airport expansion, whether increasing passenger numbers or the number of flights, will be discouraged.
There will be a broad programme of information and awareness raising on the various social, cultural, economic and ecological implications of all travel modes and aviation in particular.'
Amplification: whilst there has been established use of the site as an aerodrome for many years, its situation stems from historical accident, rather than reasoned planning, established as a temporary, emergency airfield during the Second World War. The location of the airport on this site conflicts with Goals 1, 2, 4 and 5, so over the medium term aviation activities at the airport should be reduced.
Aviation is the least accessible form of transport. Across the UK less than 12% of people make more than 50% of all flights, whilst the figures for Swansea Airport, were they to be available are likely to be even more pronounced than this, due to the cost and nature of business at Swansea.

It is recognised that provision shapes demand, planning to provide for aviation in the future, is likely to encourage further growth in aviation, the most unsustainable sector. It is crucial, therefore, that CCS embrace its responsibilities as a policy provider and prevent further expansion of Swansea airport.

SANE (Swansea Airport No Expansion) contact details:
c/o Dr Rolf Jucker
Environment Sub-Committee
Keir Hardie Building
University of Wales Swansea
Singleton Park
Swansea SA2 8PP

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