swansea airport no expansion

SWANSEA AIRPORT NO EXPANSION
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Flights of Fancy? home about us press release briefing donations links	Re Planning Application number 2002/2267, Swansea Airport. Contents 1. Executive Summary 2. Introduction to SANE and the contexts of this Report 3. City and County of Swansea's Commitment to Sustainability and application No. 2002/2267 4. The Need for an Environmental Impact Assessment 5. The EU Habitats Directive 6. Conclusions 7. Recommendations 1. Executive Summary 1.1 There is strong public feeling regarding the expansion of Swansea Airport, with a majority of residents opposing further expansion. 1.2 This application forms part of a wider expansion plan, but this wider plan has not been made public. Indeed, the developer claims there is no long-term plan for the airport! This approach appears to be designed to avoid an Environmental Impact Assessment, through piecemeal development. 1.3 This application and the wider expansion plan for Swansea Airport fundamentally contradict CCS's core commitment to sustainability. 1.4 The Economic implications of this development are unclear and need further, independent scrutiny. 1.5 There should be a fully independent EIA before any determination is made on this application. 1.6 This application breaches a number of important local and national planning Policies. 1.7 The European Habitats Directive mandates survey work and actions which have not been undertaken. 1.8 Given all of the above this Application should not be granted. There is strong evidence to suggest the application should be refused at this stage. However, a second option is also feasible, delaying any decision until further research and consultation has been carried out. This research and consultation should include: a) A full Environmental Impact Assessment, to be carried out by an independent party. b) A full review of the implications of this application for CCS's sustainable development policies. c) As required by sustainable development, there should be full public consultation and participation, with the public's views being used to shape future policy regarding the Airport. d) For all of the above to be based on fact there needs firstly to be a public disclosure of the developers medium-long term business plan, covering the next 5-25 years. 2. Introduction to SANE and the contexts of this Report 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's formation was one of the outcomes of two conferences on sustainable development hosted by the City and County of Swansea (CCS) from 3-5.12.02 as part of CCS 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 20.03.03. 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 decision regarding Planning Application number 2002/2267. 3. City and County of Swansea's Commitment to Sustainability and application No. 2002/2267 3.1 Introduction Whilst sustainability is a core aim for City and County of Swansea (CCS), the planning application 2002/2267 contradicts this goal in a number of respects. 3.2 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) 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' (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: 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. 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…'. It is clear from the Sustainable Development Policy 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 policy mentions shifting modes form the car 'particularly by the promotion of alternatives to the private car', but does not mention aviation, which per passenger mile is far more polluting than even the private car and which, as a sector is growing at a faster rate than car travel. Finally, the 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.' As there is clearly an urgent need for greater awareness of the impacts of aviation within CCS and the wider public, the decision on the above application should be postponed to enable awareness levels to be raised before any decision is made. 4. The Need for an Environmental Impact Assessment 4.1. Introduction This section considers the relevance Environmental Impact Assessment (EIA) legislation may have for Swansea Airport's expansion; of which Planning Application number 2002/2267 forms part. The case for EIA is strong as there are several specific references pertinent to this application within the relevant legislation. This section therefore leads to the recommendation that the decision regarding Planning Application number 2002/2267 should not be made until there has been a full independent EIA. 4.2. 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 EIA' (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 application number 2002/2267 specifically, and the wider plans for Swansea Airport more generally, require an 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 SAC status. Furthermore, the nature of a development is particularly important in determining the relevance of an EIA. In this case application 2002/2267 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 'hidden' expansion plans, including application numbers 2001/1135 and 2003/0052. From this it is clear that the nature of application 2002/2267 is that it forms part of a series of wider developments 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) 4.3 Applying EIA Policy to Swansea Airport and the above planning application The most serious obstacle to a comprehensive analysis of the likely impacts of developing Swansea Airport is the absence of detailed plan of future activities and developments. The developer maintains that he has no long-medium term plan for the airport and this view has not been sufficiently questioned by CCS. It is highly unlikely that a businessman can afford to invest substantial sums of money without a medium-long term plan. Even if this were the case, however, the need for a more detailed outline of future plans for the airport is clear from a number of perspectives: a) Firstly, it serves the interests of CCS, when planning for the future, to have an overview of where developments such as application no. 2002/2267 may lead. In particular when drafting policies including the Unitary Development Plan and seeking to implement sustainable development CCS has a significant need to plan for the medium and long term future! b) Secondly, a detailed medium-long-term plan for the Airport is necessary in the interests of members of the public. This need is illustrated by the large number of people concerned about plans for Swansea Airport's future development. It is particularly acute in the interests of participation. If people are to be engaged in decisions affecting their lives they need to have access to information. It is therefore imperative that CCS require the developer to produce a plan covering the next 5-10 years. The need for both a detailed long to medium-term plan and an independent EIA can be illustrated by looking at many aspects of the development, from damage to habitat through increased nitrogen deposition to the impacts of increased noise upon surrounding human and other populations, particularly if noise is deemed to occur at inappropriate times and levels. However, this report will use just one example, that of traffic projections. 4.4. Traffic Projections and EIA In the report prepared for Councillors by CCS officers, traffic projections have been based on the developer's suggestion that there will be a maximum of 274 passengers a day. Using this figure it has been estimated that there would be a maximum of 274 movements a day over a 10-hour period, equating to 28 movements/hour (CCS 2003, Application No. 2002/2267, Appraisal). On this basis Council officers have concluded that traffic volumes will not have a detrimental effect on local highway conditions. However, in the absence of a clear long-medium term plan from the developer it is unclear where the figure of 274 passengers comes from and how long it is likely to last. The very starting point of these projections, therefore, is problematic and Councillors may wish to question the developer on this figure, how it was produced, the period for which it serves, etc. The need for a more detailed explanation of future plans and projections is further illustrated by the fact that the developer's own statements regarding passenger capacity increases could result in considerably greater traffic volumes. One study, for example, which is lodged in the file for application 2002/2267, but which has not been referred to in the report to Councillors suggests that the developer's predictions of 10 scheduled flights/day in 48 seat ATR42's would lead to a conservative estimate of approximately 500 vehicle movements/day. The report goes on to highlight the parking implications this would have. Using a figure of 60% of travelers remaining away for 5 days, this would lead to 1500 cars being permanently parked on Fairwood, in addition to those moving about on a daily basis . These figures can be adjusted in various ways to account for different factors and assumptions. However, several facts remain: a) A large number of cars will be present at the airport at any one time. b) In addition to these permanently parked cars there will be additional demands for car parking from other passengers and staff. c) In addition to the above figures regarding scheduled flight passengers there will also be a series of other airport users, each with the potential to generate traffic demands, these include airport staff, non-scheduled flights, etc. Indeed, what this may include is still speculation precisely because there has not yet been a clearly presented long-medium term plan of airport activity. d) No detailed analysis of existing levels of airport use has been presented to CCS. This base-line study would be a vital starting point in accurately gauging future impacts and Councillors may consider requesting this before determining the application. e) There has been no analysis of the implications of car parking and the permanent presence of hundreds of cars. Implications this may have include, for example, i) greater risk of crime in the area and associated impacts of increased security measures (barriers to wildlife, aesthetic intrusion of security fencing, etc) ii) a large area of concrete with its associated visual, ecological and water catchment implications (see, for example, section 5 on the implications this may have for the EU Habitats Directive) 5. The EU Habitats Directive The area around the Airport is part of a Candidate Special Area of Conservation (SAC), designated under the European Habitats Directive. European Directives are law. This has been established in the courts. Consequently all arms of government are legally bound to adhere to the Habitats Directive. In the case of SACs the following section of the Directive applies. Article 6 For special areas of conservation, Member States shall establish the necessary conservation measures involving, if need be, appropriate management plans specifically designed for the sites or integrated into other development plans, and appropriate statutory, administrative or contractual measures which correspond to the ecological requirements of the natural habitat types in Annex I and the species in Annex II present on the sites. Member States shall take appropriate steps to avoid, in the special areas of conservation, the deterioration of natural habitats and the habitats of species as well as disturbance of the species for which the areas have been designated, in so far as such disturbance could be significant in relation to the objectives of this Directive. Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public. If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest. It is clear what this piece of law says. The council has a legal obligation to take all the proposals as one unit and get an assessment as to what damage will occur to the SAC. If there is any then they must introduce compensatory measures or prevent the development occurring. One of the reasons that the SAC was designated is the presence of an important population of the rare Marsh Fritillary Butterfly. The directive mandates that the "population dynamics data" of the species are taken into account when dealing with its conservation. The species and its close relatives have been the subject of a lot of detailed scientific research on population dynamics. Consequently it is possible to say with confidence that any deterioration in quality or loss of habitat will lead to an increased probability of its loss from the SAC. There are a number of factors that have to be taken into account here. These include. I. Direct damage to the habitat as is proposed by the construction of the road across the site. II. Changes in grazing management which could be forced on the commoners due to increased traffic on the roads. III. Any subsequent road widening which might prove necessary. IV. Increased nitrogen deposition from car or aircraft exhausts which could cause damage to habitat quality. 6. Conclusions 1) There is a strong presumption in favour of an EIA in this case, given the nature of the development and the receiving environment. 2) CCS has established a clear core commitment to sustainability. This places it in a position from which it could establish itself as a leader in promoting sustainability. However, the proposed expansion of Swansea airport, of which Planning Application number 2002/2267 is but one small component, has the potential to undermine these commitments to sustainable development. 3) There has so far been a lack of public participation regarding the decision to expand the airport, yet public participation is a central part of sustainable development, as established through international conferences such as the World Summit on Sustainable Development (Johannesburg, 09.02) and their local follow-up conferences such as 'Debate, Decision, Direction: A national follow-up Conference to the World Summit on Sustainable Development' (Brangwyn Hall, Swansea 3-4.12.02). 4) Planning Application number 2002/2267 and the wider expansion plans of which it forms part appear to contradict a number of aspects of CCS's commitment to sustainability, both in terms of specific and general aspects of policy. 5) Concerning: Area of Outstanding Natural Beauty (AONB), Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC). Whilst all three place responsibilities upon CCS to protect the site, the latter, covered by the EU habitats Directive entails international responsibilities and potentially international liabilities should the airport expansion be deemed as detrimental to the site. 7.Recommendations 1) Following the above conclusions, this report recommends that Planning Application number 2002/2267 should not be determined until a full EIA has been carried out by an independent party. 2) Equally, there should be no determination of application 2002/2267 until a full assessment of its sustainability implications is carried out. 3) The latter should allow time for the Report of Phase I of the Public Consultation and Participation Programme being undertaken by SANE to be included in the decision making process. 4) Furthermore, in line with Council Policy on Sustainable Development: 'To raise the level of awareness of sustainable development issues in the Council and provide training in relevant aspects of the policy', any decision regarding expanding Swansea Airport should be made only after 'the level of awareness' has been raised regarding its sustainability implications. There should also be further 'training in relevant aspects of the policy' before any decision is made . 5) Whilst this report seeks to contribute to this process it is imperative that the resources and expertise within CCS as well as members of the public are drawn upon fully in this process. 6) The above recommendations can only be implemented meaningfully and on a factual basis after the developer has submitted a detailed medium to long-term plan covering the next 5-25 years of business. Given that CCS officers extended the lease on Swansea Airport from 18 years to 125 years it is reasonable that such a timescale be covered by the business plan in the interests of both sustainability and making reasoned, balanced decisions on this matter. It is therefore recommended that before application 2002/2267 is considered any further, or any of the above recommendations are implemented, CCS require the developer to present a detailed business plan covering the next 5 years and the next 25 years. 7) Furthermore, given the ecological sensitivity of the site, the policy clashes created by planned aviation expansion and the high level of public, it is recommended that Councillors require application 2002/2267 to be amalgamated with application number 2003/052 and any other developments either currently lodged with CCS, or due to be lodged in the next 5 years. Swansea Airport No Expansion Home page

SWANSEA AIRPORT NO EXPANSION

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mumbles, swansea

Flights of Fancy?

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Re Planning Application number 2002/2267, Swansea Airport.

Contents

1. Executive Summary

2. Introduction to SANE and the contexts of this Report

3. City and County of Swansea's Commitment to Sustainability and application No. 2002/2267

4. The Need for an Environmental Impact Assessment

5. The EU Habitats Directive

6. Conclusions

7. Recommendations

1. Executive Summary

1.1 There is strong public feeling regarding the expansion of Swansea Airport, with a majority of residents opposing further expansion.

1.2 This application forms part of a wider expansion plan, but this wider plan has not been made public. Indeed, the developer claims there is no long-term plan for the airport! This approach appears to be designed to avoid an Environmental Impact Assessment, through piecemeal development.

1.3 This application and the wider expansion plan for Swansea Airport fundamentally contradict CCS's core commitment to sustainability.

1.4 The Economic implications of this development are unclear and need further, independent scrutiny.

1.5 There should be a fully independent EIA before any determination is made on this application.

1.6 This application breaches a number of important local and national planning Policies.

1.7 The European Habitats Directive mandates survey work and actions which have not been undertaken.

1.8 Given all of the above this Application should not be granted. There is strong evidence to suggest the application should be refused at this stage. However, a second option is also feasible, delaying any decision until further research and consultation has been carried out. This research and consultation should include:

a) A full Environmental Impact Assessment, to be carried out by an independent party.
b) A full review of the implications of this application for CCS's sustainable development policies.
c) As required by sustainable development, there should be full public consultation and participation, with the public's views being used to shape future policy regarding the Airport.
d) For all of the above to be based on fact there needs firstly to be a public disclosure of the developers medium-long term business plan, covering the next 5-25 years.

2. Introduction to SANE and the contexts of this Report

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's formation was one of the outcomes of two conferences on sustainable development hosted by the City and County of Swansea (CCS) from 3-5.12.02 as part of CCS 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 20.03.03.

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 decision regarding Planning Application number 2002/2267.

3. City and County of Swansea's Commitment to Sustainability and application No. 2002/2267
3.1 Introduction

Whilst sustainability is a core aim for City and County of Swansea (CCS), the planning application 2002/2267 contradicts this goal in a number of respects.

3.2 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)

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' (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:

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.

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…'. It is clear from the Sustainable Development Policy 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 policy mentions shifting modes form the car 'particularly by the promotion of alternatives to the private car', but does not mention aviation, which per passenger mile is far more polluting than even the private car and which, as a sector is growing at a faster rate than car travel.
Finally, the 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.' As there is clearly an urgent need for greater awareness of the impacts of aviation within CCS and the wider public, the decision on the above application should be postponed to enable awareness levels to be raised before any decision is made.

4. The Need for an Environmental Impact Assessment
4.1. Introduction

This section considers the relevance Environmental Impact Assessment (EIA) legislation may have for Swansea Airport's expansion; of which Planning Application number 2002/2267 forms part. The case for EIA is strong as there are several specific references pertinent to this application within the relevant legislation. This section therefore leads to the recommendation that the decision regarding Planning Application number 2002/2267 should not be made until there has been a full independent EIA.

4.2. 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 EIA'
(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 application number 2002/2267 specifically, and the wider plans for Swansea Airport more generally, require an 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 SAC status.

Furthermore, the nature of a development is particularly important in determining the relevance of an EIA. In this case application 2002/2267 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 'hidden' expansion plans, including application numbers 2001/1135 and 2003/0052. From this it is clear that the nature of application 2002/2267 is that it forms part of a series of wider developments 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)

4.3 Applying EIA Policy to Swansea Airport and the above planning application

The most serious obstacle to a comprehensive analysis of the likely impacts of developing Swansea Airport is the absence of detailed plan of future activities and developments. The developer maintains that he has no long-medium term plan for the airport and this view has not been sufficiently questioned by CCS. It is highly unlikely that a businessman can afford to invest substantial sums of money without a medium-long term plan. Even if this were the case, however, the need for a more detailed outline of future plans for the airport is clear from a number of perspectives:

a) Firstly, it serves the interests of CCS, when planning for the future, to have an overview of where developments such as application no. 2002/2267 may lead. In particular when drafting policies including the Unitary Development Plan and seeking to implement sustainable development CCS has a significant need to plan for the medium and long term future!

b) Secondly, a detailed medium-long-term plan for the Airport is necessary in the interests of members of the public. This need is illustrated by the large number of people concerned about plans for Swansea Airport's future development. It is particularly acute in the interests of participation. If people are to be engaged in decisions affecting their lives they need to have access to information.

It is therefore imperative that CCS require the developer to produce a plan covering the next 5-10 years.

The need for both a detailed long to medium-term plan and an independent EIA can be illustrated by looking at many aspects of the development, from damage to habitat through increased nitrogen deposition to the impacts of increased noise upon surrounding human and other populations, particularly if noise is deemed to occur at inappropriate times and levels. However, this report will use just one example, that of traffic projections.

4.4. Traffic Projections and EIA

In the report prepared for Councillors by CCS officers, traffic projections have been based on the developer's suggestion that there will be a maximum of 274 passengers a day. Using this figure it has been estimated that there would be a maximum of 274 movements a day over a 10-hour period, equating to 28 movements/hour (CCS 2003, Application No. 2002/2267, Appraisal). On this basis Council officers have concluded that traffic volumes will not have a detrimental effect on local highway conditions.

However, in the absence of a clear long-medium term plan from the developer it is unclear where the figure of 274 passengers comes from and how long it is likely to last. The very starting point of these projections, therefore, is problematic and Councillors may wish to question the developer on this figure, how it was produced, the period for which it serves, etc.

The need for a more detailed explanation of future plans and projections is further illustrated by the fact that the developer's own statements regarding passenger capacity increases could result in considerably greater traffic volumes. One study, for example, which is lodged in the file for application 2002/2267, but which has not been referred to in the report to Councillors suggests that the developer's predictions of 10 scheduled flights/day in 48 seat ATR42's would lead to a conservative estimate of approximately 500 vehicle movements/day. The report goes on to highlight the parking implications this would have. Using a figure of 60% of travelers remaining away for 5 days, this would lead to 1500 cars being permanently parked on Fairwood, in addition to those moving about on a daily basis .

These figures can be adjusted in various ways to account for different factors and assumptions. However, several facts remain:

a) A large number of cars will be present at the airport at any one time.

b) In addition to these permanently parked cars there will be additional demands for car parking from other passengers and staff.

c) In addition to the above figures regarding scheduled flight passengers there will also be a series of other airport users, each with the potential to generate traffic demands, these include airport staff, non-scheduled flights, etc. Indeed, what this may include is still speculation precisely because there has not yet been a clearly presented long-medium term plan of airport activity.

d) No detailed analysis of existing levels of airport use has been presented to CCS. This base-line study would be a vital starting point in accurately gauging future impacts and Councillors may consider requesting this before determining the application.

e) There has been no analysis of the implications of car parking and the permanent presence of hundreds of cars. Implications this may have include, for example,
i) greater risk of crime in the area and associated impacts of increased security measures (barriers to wildlife, aesthetic intrusion of security fencing, etc)
ii) a large area of concrete with its associated visual, ecological and water catchment implications (see, for example, section 5 on the implications this may have for the EU Habitats Directive)

5. The EU Habitats Directive

The area around the Airport is part of a Candidate Special Area of Conservation (SAC), designated under the European Habitats Directive. European Directives are law. This has been established in the courts. Consequently all arms of government are legally bound to adhere to the Habitats Directive.

In the case of SACs the following section of the Directive applies.

Article 6
For special areas of conservation, Member States shall establish the necessary conservation measures involving, if need be, appropriate management plans specifically designed for the sites or integrated into other development plans, and appropriate statutory, administrative or contractual measures which correspond to the ecological requirements of the natural habitat types in Annex I and the species in Annex II present on the sites.

Member States shall take appropriate steps to avoid, in the special areas of conservation, the deterioration of natural habitats and the habitats of species as well as disturbance of the species for which the areas have been designated, in so far as such disturbance could be significant in relation to the objectives of this Directive.

Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.

If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.

It is clear what this piece of law says. The council has a legal obligation to take all the proposals as one unit and get an assessment as to what damage will occur to the SAC. If there is any then they must introduce compensatory measures or prevent the development occurring.

One of the reasons that the SAC was designated is the presence of an important population of the rare Marsh Fritillary Butterfly. The directive mandates that the "population dynamics data" of the species are taken into account when dealing with its conservation. The species and its close relatives have been the subject of a lot of detailed scientific research on population dynamics. Consequently it is possible to say with confidence that any deterioration in quality or loss of habitat will lead to an increased probability of its loss from the SAC.

There are a number of factors that have to be taken into account here. These include.
I. Direct damage to the habitat as is proposed by the construction of the road across the site.
II. Changes in grazing management which could be forced on the commoners due to increased traffic on the roads.
III. Any subsequent road widening which might prove necessary.
IV. Increased nitrogen deposition from car or aircraft exhausts which could cause damage to habitat quality.

6. Conclusions

1) There is a strong presumption in favour of an EIA in this case, given the nature of the development and the receiving environment.

2) CCS has established a clear core commitment to sustainability. This places it in a position from which it could establish itself as a leader in promoting sustainability. However, the proposed expansion of Swansea airport, of which Planning Application number 2002/2267 is but one small component, has the potential to undermine these commitments to sustainable development.

3) There has so far been a lack of public participation regarding the decision to expand the airport, yet public participation is a central part of sustainable development, as established through international conferences such as the World Summit on Sustainable Development (Johannesburg, 09.02) and their local follow-up conferences such as 'Debate, Decision, Direction: A national follow-up Conference to the World Summit on Sustainable Development' (Brangwyn Hall, Swansea 3-4.12.02).

4) Planning Application number 2002/2267 and the wider expansion plans of which it forms part appear to contradict a number of aspects of CCS's commitment to sustainability, both in terms of specific and general aspects of policy.

5) Concerning: Area of Outstanding Natural Beauty (AONB), Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC). Whilst all three place responsibilities upon CCS to protect the site, the latter, covered by the EU habitats Directive entails international responsibilities and potentially international liabilities should the airport expansion be deemed as detrimental to the site.

7.Recommendations

1) Following the above conclusions, this report recommends that Planning Application number 2002/2267 should not be determined until a full EIA has been carried out by an independent party.

2) Equally, there should be no determination of application 2002/2267 until a full assessment of its sustainability implications is carried out.

3) The latter should allow time for the Report of Phase I of the Public Consultation and Participation Programme being undertaken by SANE to be included in the decision making process.

4) Furthermore, in line with Council Policy on Sustainable Development: 'To raise the level of awareness of sustainable development issues in the Council and provide training in relevant aspects of the policy', any decision regarding expanding Swansea Airport should be made only after 'the level of awareness' has been raised regarding its sustainability implications. There should also be further 'training in relevant aspects of the policy' before any decision is made .

5) Whilst this report seeks to contribute to this process it is imperative that the resources and expertise within CCS as well as members of the public are drawn upon fully in this process.

6) The above recommendations can only be implemented meaningfully and on a factual basis after the developer has submitted a detailed medium to long-term plan covering the next 5-25 years of business. Given that CCS officers extended the lease on Swansea Airport from 18 years to 125 years it is reasonable that such a timescale be covered by the business plan in the interests of both sustainability and making reasoned, balanced decisions on this matter. It is therefore recommended that before application 2002/2267 is considered any further, or any of the above recommendations are implemented, CCS require the developer to present a detailed business plan covering the next 5 years and the next 25 years.

7) Furthermore, given the ecological sensitivity of the site, the policy clashes created by planned aviation expansion and the high level of public, it is recommended that Councillors require application 2002/2267 to be amalgamated with application number 2003/052 and any other developments either currently lodged with CCS, or due to be lodged in the next 5 years.

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