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Saturday, 14 June 2003

Dear Councillor,

SANE (Swansea Airport No Expansion) objection to
Planning Application number 2003/0052: Aircraft hangar

SANE urges you very strongly to reject the above Planning Application, being discussed at the Planning Meeting, Tuesday 3rd June 2003, for the following reasons (for details see the following pages):

1. Keep your promises: No piecemeal planning approach. A piecemeal approach contradicts Council policy with regard to the Airport:
'Care is needed in relation to development at the airport. Essentially it will be important to avoid proliferation of piecemeal developments which cumulatively could have an adverse effect on the character of the area.' (Swansea Local Plan Review Policy RE2 18.94, p. 153; emphasis added)
2. The operators have still not produced a medium-longterm business plan: demand one before granting any more applications.
3. Massive expansion planned: 300,000 passengers a year throughput, extension of runway and complete rebuilding of airport.
4. Airport Operators want to reach point-of-no-return, but people of Swansea need to know about all the implications before it is too late.
5. Why the amended plans? Collusion between the Council and Airport operators to get this application through.
6. Still no official public consultation, but vast majority of local residents consulted by SANE say: NO to any expansion of Swansea Airport.
7. Environmental Impact Assessment urgently needed
8. Don't believe the economic fairy tales, the figures don't add up: the aviation industry is one of the most heavily subsidised in the country. If you don't pay tax (aviation fuel is tax-free, flight tickets, aircraft and aviation fuel are VAT free), get massive subsidies and don't pay the costs for the damage you cause, it is easy to be 'economically successful'.
9. Swansea Airport/Air Wales rely on public subsidies and tax breaks
10. Increasing flights is against the Council's own Sustainable Development Policy, because air travel is the most unsustainable form of transport.
11. Swansea Airport is in the wrong place, situated in the middle of an AONB, SSSI and cSAC.

SANE urges you to refuse Planning Application 2003/0052, until:
1. The application is not granted, until:
Ø the Airport operators have produced a 10-year business plan
Ø there has been a full public consultation, particularly of the directly affected communities, about the proposed 10-year plan
Ø there has been a full Environmental Impact Assessment for the 10-year plan
Ø the Council adopts a fair and transparent information policy and in particular makes publicly available their discussions with the Airport operators and Air Wales.

Please find here an extended discussion of the reasoning behind the rejection of the above Planning Application:

1. Keep your promises: No piecemeal planning approach: When the last planning application for Swansea Airport (No. 2002/2267) was approved on 25 March 2003 a number of Councillors spoke up. They said that they would in future not automatically nod applications through, because of the danger of a piecemeal development.
2. Still no medium-longterm business plan: Piecemeal development can only be avoided if you as Councillors and the citizens of Swansea know what the Airport operators and Air Wales are planning to do with the Airport in the medium-longterm future. In public discussions, the managing director of the Airport, Mr Rackham has repeatedly claimed that they cannot produce a business plan because the operators themselves wouldn't know where they would like to be in the future.
3. Massive expansion planned: Yet behind closed doors, questioned by the UK Parliament Select Committee on Welsh Affairs, the Airport operators have been rather more forthcoming. There they are quite happy to state that they plan to:
Ø 'handle 300,000 passengers a year';
Ø 'fund the substantial development costs' with 'support from the City and County of Swansea, the WDA and the EU', i.e. taxpayer's money;
Ø corner 'a large amount of the tourist market' and for that purpose build a large car park;
Ø extend the runway in order to get a low cost airline in: 'If we could get our runway, which is very possible, to 1900ms our first aim would be to try and get a low cost carrier in'.
4. Airport Operators want to reach point-of-no-return: It is obvious that such a large-scale development would require proper public consultation and an Environmental Impact Assessment. Yet the operators clearly want to pursue this plan in incremental steps without ever having to own up to it in public. This is in breach of the Swansea Local Plan Review Policy RE2 which clearly states:
'Care is needed in relation to development at the airport. Essentially it will be important to avoid proliferation of piecemeal developments which cumulatively could have an adverse effect on the character of the area.' (18.94, p. 153; emphasis added)
This may be your last chance to stop such an adverse effect.
5. Why the amended plans? Collusion between the Council and Airport operators: Why have the operators submitted amended plans to the Council? When SANE met with David Gill on 29 May 2003 he admitted that the City and County Council had instigated the 'Landscape and Visual Impact Assessment' because they felt (Mr Gill's words) that it was 'a sensitive application'. The amended application is the Council's attempt to push this through by advising the operators to amend the plans and put up a tree shield between the road and the new hangar, so as to minimise visual impact, and, one might add, to increase the chances of the application being passed with the help of this greenwashing exercise. This is not at all what we understand under open Government and transparency.
Yet even so, the Landscape and Visual Impact Assessment report states that 'mitigation is difficult due to the size and location of the building'.
6. Still no public consultation: despite the massive expansion plans and the already noticeably increased noise pollution due to the London flights, affected local residents have never been consulted about the expansion plans, except for the four public meetings held by SANE where the vast majority of local people expressed their strong opposition to any expansion of Swansea Airport.
7. Environmental Impact Assessment needed: the above planning application should automatically trigger an Environmental Impact Assessment because of the large area it covers (19,500 sqm), especially because an SSSI and cSAC is affected. SANE's background research has confirmed that for the airport as a whole there ought to be an Environmental Impact Assessment. 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. In addition, 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.
The reasons given in the Council's Environmental screening are more then questionable. It unlikely that a body which is hell-bent on supporting the expansion of the airport (the Council) is independent enough to make a sound judgement on whether or not a full EIA is necessary.
On a further interesting point, the Council has consulted CCW (Countryside Council for Wales) only about the AONB, not about the SSSI or the cSAC.
8. Don't believe the economic fairy tales: Both the Council and the Airport operators always use as their joker card the argument that the airport expansion will boost the local economy. This claim is invariably supported by a 1999 Oxford Economic Forecasting (OEF) report, financed mainly by the aviation industry, which made the link between airports and growth. Since its publication independent analysis has shown that the report is seriously flawed:
Ø the OEF report did not factor the environmental and social costs of aviation into its economic equations, yet the health costs of air pollution from the UK aviation sector alone amount to £1.3 billion pounds per year;
Ø the report ignored the aviation industry's £7 billion a year subsidies and tax breaks. This means that each of the 58 million Britons donate an average of £185.90 to the aviation industry per year.
If you don't pay tax (aviation fuel is tax-free, flight tickets, aircraft and aviation fuel are VAT free), get massive subsidies and don't pay the costs for the damage you cause, it is easy to be 'economically successful'.
9. Swansea Airport/Air Wales rely on public subsidies and tax breaks: In the UK Parliament Select Committee on Welsh Affairs questioning, Swansea Airport and Air Wales state that they
Ø want the Assembly to fund new services, otherwise they 'would not be able to consider (...) some routes';
Ø with the help of Swansea City and County Council the Airport secured a £500,000 grant of EU money for Security Fencing;
Ø 'have free landing fees for Dublin on our Swansea route for a year, reduced up to three years, and free fees for four years at Cork'.
10. Increasing flights is against the Council's own Sustainable Development Policy: Aviation is the most unsustainable form of transport, expanding the airport, therefore, contradicts the Council's commitment to sustainable development, e.g. Corporate Aim No. 4 and the Sustainable Development Policy. Some facts:
Ø the Royal Commission on Environmental Pollution states that short-haul passenger flights (under 1000km) 'make a disproportionately large contribution to the global environmental impacts of air transport';
Ø an average 500km flight produces over 3 times more CO2 which contributes to Global Warming than the same journey by train;
Ø aviation is by far the fastest growing source of CO2 emissions in the UK;
There is no such thing as environmentally friendly aviation.
11. Swansea Airport is in the wrong place: Swansea seems determined to attempt to 'match' whatever Cardiff is doing and this seems to be the driving force for the airport development despite the fact that Swansea airport is in completely the wrong place (not least because it is the 'the only airport in the country which is located within an Area of Outstanding Natural Beauty (AONB)', to quote Sue Essex, then Minister for Environment) and can never become a competitive 'Regional' airport because of its poor transport links.

To make sure that the people of Swansea stay in control of developments at the Airport you should press for the following conditions for granting the planning application:
2. The application is not granted, until:
Ø the Airport operators have produced a 10-year business plan
Ø there has been a full public consultation, particularly of the directly affected communities, about the proposed 10-year plan
Ø there has been a full Environmental Impact Assessment for the 10-year plan
Ø the Council adopts a fair and transparent information policy and in particular makes publicly available their discussions with the Airport operators and Air Wales.

In the interest of democracy, transparency, sustainability, and above all, the welfare of the people of Swansea and the safeguarding of our local jewel, the Gower, we urge you again to reject the above planning application.

On behalf of SANE
Yours sincerely,

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
Tel: 01792-280368
Email: r.jucker@swansea.ac.uk

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