There was a co-ordinated response to the proposals for a Midlands Airport, with a detailed document produced to highlight the issues arising from the Government proposals, as well as providing the response to the Government questionnaire. The summary section of the SACG response is reproduced below, with more complete details held in the Research section of this archive. Additional responses were made by other groups, including one from Stretton-on-Dunsmore Parish Council, and one from the Wolston, Brandon and Bretford Anti-Airport Action Group.
1.1 WHAT IS THE SACG?
The Strategic Anti-Rugby Airport Co-ordinating Group (SACG) was established following a public meeting hosted by Andy King MP in the Benn Hall, Rugby, which was attended by about 1,000 people. The Group is non party political and has the support of individuals, community groups, parish councils and village action committees, environmental organisations, borough and county councillors, MPs and MEPs.
The Group’s primary objective is to ensure that the Department for Transport (DfT) is made aware of the damaging impacts that the proposal for a new airport at Rugby will have on the local community and environment. We are convinced that the proposal for a new airport is wrong and must be abandoned prior to the publication of the White Paper in 2003.
1.2 STRUCTURE OF THIS RESPONSE
We have structured this response so that we can focus on the issues we consider critical to the consultation. We have chosen not to follow the questions raised in the consultation document, as this would not have helped us to express our views clearly. However in Appendix IV we provide a brief summary of our response to the questions, related where appropriate to particular sections of our response.
1.3 SUMMARY OF THE RESPONSE
1.3.1 Section 2 – Demand Forecasts
We reject both the level of national growth assumed by the Government, and the proportion of future demand assumed to be met by airports in the Midlands.
- The passenger numbers forecast are greatly exaggerated, being based on highly optimistic assumptions about a range of factors which will help to determine rates of growth.
- The objectivity of the work that the Government has based its forecasts on is, at best, questionable.
- A ‘predict and provide’ policy model is totally inappropriate. Demand should be managed, as it is for other forms of transport – particularly in light of the fact that air transport is more socially and environmentally damaging than any other means of travel.
- The number of passengers using Midlands airports should not exceed 30 million per annum.
1.3.2 Section 3 – The Financial and Economic Case for the New Airport
The Government’s economic and financial analyses have a number of major gaps and defects, all of which make the results more favourable than they would be if more realistic criteria were applied.
- When they are corrected, the scheme performs so badly in economic and financial terms that it has no reasonable prospect of proceeding.
- Of particular concern is the fact that in the capital cost estimates, costings for a series of vital elements – including road and rail schemes, land acquisition, flood prevention works, geotechnical work, compensation I resulting from the closure of Birmingham and Coventry airports, and compulsory purchase and compensation to local residents – have either been seriously underestimated or omitted altogether.
- It is peculiar that the Government has opted for a projected opening date of 2011, when the economic and financial performance of the scheme is at its worst.
1.3.3 Section 4 – Relationship of the Proposal to National and Regional Planning Policy
We have matched the proposal against national planning policy (in the form of
Planning Policy Guidance Notes – PPGs), the Regional Planning Guidance (RPG) for the West Midlands, and the Government’s policy on sustainable development.
- PPGs – the new airport would be either directly or indirectly contrary to the great majority of this guidance. It is a glaring weakness of the Government’s proposal that there is no assessment of how this relates to such a large body of its own policies.
- RPG – The existing RPG calls for the development of the north and west of the West Midlands Region in preference to the more prosperous south and east. Building an airport on the south-east side of the region and closing two airports further west is directly contradictory to that policy. Regarding the new, draft West Midlands RPG, the airport proposal would be consistent with 6 and inconsistent with 33 RPG policies. It would be particularly detrimental to the urban regeneration strategy for the region.
- The airport proposal is also seriously at odds with the Government’s own policy on sustainable development.
1.3.4 Section 5 – Economic Impact
The overall economic impact of the proposed new airport – on jobs and the wider economy – has been greatly exaggerated. The supporting evidence is tenuous and there is much wishful thinking.
- Little account has been taken of the highly disruptive effect of closing Birmingham and Coventry airports, and the DfT’s analysis fails to estimate the loss of jobs and economic activity as a result of these closures – a serious weakness.
- The number of jobs required directly and indirectly by the new airport would far exceed the numbers unemployed in areas within easy commuting distance, so the great majority of jobs would need to be filled by migrants to the area or long-distance commuters.
- The net loss of revenue to the UK economy from aviation-based tourism – currently running at £8 billion per annum – has been completely disregarded. While the Government appears to believe that the gap will close if unconstrained growth in air travel is allowed, it has presented no evidence to support this claim.
1.3.5 Section 6 – Scale of Associated Development, and Impact on the Green Belt and Landscape
The consultation document contains little information on the likely scale and nature of development associated with the airport. However, we estimate that:
- the area of associated development between Coventry and Rugby is likely to amount to between one and a half times and twice the area of the airport itself
- in total, the airport and its associated development would probably occupy between 4,000 and 4,500 hectares – about half the green belt between Coventry and Rugby
- green belt policy is an important strategic planning device to prevent urban and industrial sprawl (PPG2). While the policy is strong enough at present to resist almost all the pressure resulting from expansion in Rugby and Coventry, the imposition of a major international airport would transform the situation and make it very difficult to resist further development proposals. Rugby and Coventry would eventually coalesce.
1.3.6 Section 7 – Surface Access
The consultation and background reports acknowledge that the new airport would put heavy additional pressure on the surrounding road and rail networks. However they have greatly underestimated the improvements required.
- The A46, A45, M6, M69, Ml, and A14 would all be seriously over capacity by 2030, even with the proposed improvements.
- Four further road improvements would be required: construction of a Coventry Southern Bypass; a new route south to the M40 near Gaydon; widening of the M5 south of the M42, and widening of the M42 between the MS and M40.
- Scant details of the ‘further capacity enhancements’ required regarding rail transport are given in the proposal.
- The total cost of road and rail improvements will be in the region of £1 billion, a sum which should be added to the costs used in the economic and financial evaluation.
1.3.7 Section 8 – Health Impact, Noise and Air Pollution
A new airport between Rugby and Coventry would result in a large increase in noise, air and light pollution in the area, as well as other pollutants which have the potential to affect the district’s water supplies.
The number of people affected by a new airport has been significantly underestimated in the proposal, and other important noise factors have not been apportioned their due weight.
1.3.8 Section 9 – Safety and the Bird Strike Issue
The proposal has been put forward without an assessment of whether it could be operated safely. Bird strike is a well known hazard to aviation, and the Civil Aviation Authority (CAA) has drafted clear advice on the management of the issue for existing airports. It identifies a 13-kilometre ‘safeguarding’ zone around an airport, where any habitat that attracts large birds and species which form flocks is regarded as a serious hazard. The proposed airport is closely related to at least five features which would create serious safety hazards, particularly Draycote Water which hosts a large gull roost.
1.3.9 Section 10 – The River Avon and Site Conditions
Any development which will increase the risks of flooding should either be rejected out of hand, or at the very least contain costed proposals to eliminate any increase in flood risk. The analysis in the consultation document for an airport which will lie across the floodplain of the River Avon is woeful. It also fails to contain any adequate investigation of the site conditions, which could impact significantly on feasibility and costs.
- Scott Wilson s initial analysis of possible sites for a new airport used flooding and the impacts on rivers as negative criteria. The location of the River Avon was not reflected in the scoring of the Church Lawford site. This was because Scott Wilson considered a different location, orientation and runway length than that put forward in the consultation paper. It is clear that the Scott Wilson analysis was not adequately reconsidered in the light of the revised airport layout used by Ove Arup in its subsequent analysis. This would have affected the site selection process.
- PPG25 provides clear advice about development in a floodplain. The analysis of the site in the consultation documents and Ove Arup’s report does not refer to this guidance or provide any analysis of the impacts that the proposal will have on flooding.
- Remarkably the DfT, in drawing up these proposals, did not consult the Environment Agency on the impacts on the river prior to launching the consultation.
- The underlying geology has not been considered – an amazing oversight, as this is critical to the feasibility of any major engineering project. Our geological expert has concluded that the geology of the site is ‘not good’.
- There is no reference to a number of major gas pipelines and a pumping station that cross the site – all of which would need to be relocated, at considerable trouble and expense.
1.3.10 Section 11 – Impact on the Natural Environment
The impact of unconstrained growth in air travel on the global climate through greenhouse gas emissions and the impact of contrails is unsustainable. The proposal for a new airport would itself increase growth and therefore aviations environmental impact.
The work done by Ove Arup on assessing the impact of a new airport on the biodiversity in the area is at best superficial.
- The surrounding countryside is ancient, diverse and unspoilt, and includes many sites of high nature conservation and recreational importance – all of which would be adversely affected.
- The destruction of this countryside would have a massive impact on wildlife.
- There would be a significant impact on peoples’ ability to enjoy wildlife and natural places.
1.3.11 Section 12 – Impact on Heritage and the Built Environment
The consultation document includes errors of fact, inconsistencies and lack of transparency regarding the impact of the proposed new airport on the heritage and history of the area. It relies unacceptably on inference, so that parts are not only wrong but also difficult to interpret. As with the flooding issue in section 10, there was no amendment to Scott Wilson’s initial scoring when the site location was revised by Ove Arup. This would have affected the site selection process.
1.3.12 Section 13 – Impact on Agriculture
The consultation document gives scant recognition to the impact of the proposed new airport on the agricultural economy within the affected area. The limited acknowledgement that is given relates purely to land that would be covered by the airport footprint, and no reference is made to the devastating effect that associated development and expansion to road and rail networks would have on farmland within Warwickshire, Leicestershire and Northamptonshire.
1.3.13 Section 14 – Impact on Communities
There is scant recognition in the documents of the blight imposed on local communities by the announcement of the consultation process on 23 July 2002.
- The housing market is frozen in all these areas, and people are suffering from considerable stress and anxiety.
- This blight could continue for years, if the proposal is not ruled out in the forthcoming White Paper or preferably sooner.
- There will be unimaginable disruption to a wide area if construction ever takes place – the impact of which has not been assessed.
1.3.14 Section 15 — Conclusions
Nationally, the Government has miscalculated the need for a new airport at all, ignoring its own planning and environmental policies, exaggerating the passenger forecasts, and failing to recognise its responsibility to manage demand.
Locally, there are many irrefutable reasons why the proposed airport at Rugby should not have been included in any consultation. It should be withdrawn immediately from the options for the future.