Agenda Item No.7 Committee: Regulatory Planning Committee Date: 12 December 2007 Report by: Director of Transport and Environment Proposal: Erection of a Terminal Building (capable of processing 500,000 passengers per annum) and 637 car parking spaces. Construction of a 294 metre runway extension together with an additional 150 metre starter extension. Site Address: London Ashford Airport, Lydd, Romney Marsh, Kent Application No: Y06/1647/SH and Y06/1648/SH Applicant: London Ashford Airport Ltd Strategic Issues: • Economic Development • Surface access impacts in East Sussex • Biodiversity and Landscape RECOMMENDATION:- EAST SUSSEX COUNTY COUNCIL STRATEGIC REPRESENTATIONS To resolve to inform Shepway District Council that:- These proposals to increase passenger capacity at London Ashford Airport (Lydd) may bring social and economic benefits to an area characterised as having a poor performing economy in need of regeneration and as such can be supported in principle. However, neither application should be permitted until the applicant has demonstrated that these proposals, either in combination or individually, will not give rise to surface access requirements which would have an adverse impact on the highway network in East Sussex, (TR1, TR3, and S1 (c) (d)). If the District Council is minded to approve these applications it:- • should secure a legal agreement to restrict flight paths to those that form the basis of the Environmental Statement accompanying the applications, to avoid overflying East Sussex and consequent adverse impacts on its communities and environment; and, • should ensure that adverse cross border transport impacts are minimised and that access by alternative modes is enhanced by securing a transport interchange at Appledore Station and regular public transport services connecting the station with the airport.
Transcript
Agenda Item No.7 Committee:
Regulatory Planning Committee
Date: 12 December 2007
Report by: Director of Transport and Environment
Proposal: Erection of a Terminal Building (capable of processing 500,000 passengers per annum) and 637 car parking spaces. Construction of a 294 metre runway extension together with an additional 150 metre starter extension.
Site Address: London Ashford Airport, Lydd, Romney Marsh, Kent
Application No: Y06/1647/SH and Y06/1648/SH
Applicant: London Ashford Airport Ltd
Strategic Issues:
• Economic Development • Surface access impacts in East Sussex • Biodiversity and Landscape
RECOMMENDATION:- EAST SUSSEX COUNTY COUNCIL STRATEGIC REPRESENTATIONS To resolve to inform Shepway District Council that:- These proposals to increase passenger capacity at London Ashford Airport (Lydd) may bring social and economic benefits to an area characterised as having a poor performing economy in need of regeneration and as such can be supported in principle. However, neither application should be permitted until the applicant has demonstrated that these proposals, either in combination or individually, will not give rise to surface access requirements which would have an adverse impact on the highway network in East Sussex, (TR1, TR3, and S1 (c) (d)). If the District Council is minded to approve these applications it:-
• should secure a legal agreement to restrict flight paths to those that form the basis of the Environmental Statement accompanying the applications, to avoid overflying East Sussex and consequent adverse impacts on its communities and environment; and,
• should ensure that adverse cross border transport impacts are minimised and that access by alternative modes is enhanced by securing a transport interchange at Appledore Station and regular public transport services connecting the station with the airport.
SUMMARY OF CONCLUSIONS ON KEY ISSUES 1. The Application 1.1 These applications for full planning permission propose the construction of a new terminal building and car parking capable of processing 500,000 passengers per annum (ppa) and a separate application to extend the runway at Lydd Airport, on the Dungeness peninsula in Kent (Shepway District). The applications will enable the airport to intensify activity, which currently stands at 4,000 ppa, to between 300,000 to 500,000 ppa. 1.2 The County Council was initially consulted on these applications earlier in the year by Shepway District Council to identify what additional information they should seek from the applicant. Some additional information has now been supplied and Shepway District Council is now seeking our formal views. 2. Economic Development 2.1 The applicant considers that between 300 to 500 jobs will be created as result of these proposals and as such could bring benefits to the poor performing economy of this part of the coastal south east. Long standing County Council policy in the form of Structure Plan policy TR45 supports growth at this location subject to acceptable environmental impact. However, as a consequence of the transition to a new planning system this policy no longer has formal development plan status. 3. Surface access impacts in East Sussex 3.1 Cross border transport impacts are central to the concerns expressed by officers earlier this year. Intensification of the scale envisaged by the applicant either in simply operating at its available capacity (300,000 ppa) or expanding to 500,000 ppa, will have implications for the County Council’s highway network, and especially the A259 trunk road which is characterised by its poor standard and difficulties in accommodating current traffic levels. I consider that the transport assessment accompanying the applications is inadequate in failing to recognise the nature of the access demands that development of this type and scale will create and, as a consequence, that the proposed mitigation measures (i.e. road signage) are, therefore, inadequate, contrary to the requirements of national and regional policy and Structure Plan policies S1(c) (d) TR1 and TR3. 3.2 Given the airport’s peripheral location and the potential for adverse cross border transport impacts, it is essential that the applicant provides a range of measures to ensure that the accessibility of the airport by non-car modes is significantly enhanced, in accordance with national and regional transport policy. Despite the opportunities provided by a rail service stopping at Appledore station the applicant has not sought to exploit this by proposing a transport interchange with connecting services between the station and the airport. Moreover, I remain unconvinced that the proposed travel plan will secure the necessary changes in travel patterns that this remote location requires.
4. Biodiversity and Landscape
4.1 The environmental statements for both applications focus their studies on the Dungeness peninsula, but it is not readily apparent which flight paths will ultimately be used by operators in the future and whether they will cross East Sussex with consequent impacts on the environment and communities of the county. Some information on the flight path to be used for larger aircraft taking off from the airport is provided and this shows flights effectively restricted to Kent’s airspace. As such, I am reassured that the identified cross border impacts on landscape and biodiversity
would be minor in nature. To ensure that this remains the case, I consider it appropriate that any permission should involve the applicant entering into a legal agreement limiting flight paths to those used in the assessment of environmental impacts accompanying the applications.
RUPERT CLUBB Director of Transport and Environment 4 December 2007 Contact Officer: Nick Claxton 01273 481407 Local Member: Cllr Keith Glazier BACKGROUND DOCUMENTS East Sussex and Brighton & Hove Structure Plan (1991 – 2011) Memos from Landscape Group (3 March 2007 and 20 November 2007) Memo from County Ecologist (13 March 2007) Memos from Assistant Transport Policy Manager (1 March 2007 and 16 November 2007) Memos from Assistant Section Manager Development Control Transport (2 March 2007 and 16 November 2007)
APPENDIX
CONSIDERATION OF THE ISSUES
1. Site
1.1 London Ashford Airport Lydd (LAA) is located beyond the East Sussex border in Shepway District (Kent) on the Romney Marsh, and is some 9 km distant (as the crow flies) from Camber. The site is 132 ha in area and is located 2 km from the town of Lydd to the west, New Romney lies just to the north, with Dungeness nuclear power station 3.5 km to the south and Lydd military firing range 2.3 km to the south west. Both the firing range and the power station are restricted flying areas.
1.2 The airport has been open to the public for over fifty years, and according to the Airport Operators Association, handled 4,000 passengers in 2004.
1.3 The site is accessed from the south by the C24 Camber Road (the B2075). To the north of the site, the B2075 connects with the A259.
2. The Proposals
2.1 These two related applications (one for the extension of the runway and one for the construction of a new terminal building) seek the expansion of London Ashford Airport (Lydd) and would represent a substantial intensification of current levels of activity. They form part of the operator’s ambitions to expand the airport’s current stated capacity from 300,000 passengers per annum (ppa) to 500,000 ppa. This figure of 300,000 ppa is based upon the capacity of existing buildings and is not determined by a regulatory cap on the number of air traffic movements, for example. The applicant has expressed the longer term aspiration of expanding capacity further to 2 million ppa. However, this larger figure does not form part of these applications.
2.2 The ability of the airport to achieve its immediate ambitions (expansion to 500,000 ppa) depends upon the development of both a new terminal building and an extension to the runway. Without the runway extension the applicant considers it unlikely that it would proceed with the terminal building, if permitted. It is, however, important to note that the airport has a capacity of 300,000 ppa and applicant implies that it may be possible to increase activity by exercising permitted development rights without recourse to the planning system.
The Terminal Building (Y06/1647/SH)
2.3 The proposed terminal building is three storeys high, located on an area used as open storage in the western sector of the built area of the airport and with a footprint of some 7, 400 sqm. It would include:
• departure lounge and arrivals hall; • check in facilities; • airline offices; • retail uses; • passport control; • baggage handling; together with, • associated parking of an additional 637 spaces. The Runway Extension (Y06/1648/SH)
2.4 The proposed runway extension would involve the construction of a 294 metre extension to the northern end of the runway, along with a further 150 metre “starter extension”: a total of 444 metres. The applicant states that the proposed extension will not affect the size of aircraft using the airport or the numbers of flights and passengers that the airport can accommodate. However, it will enable the larger aircraft to take of with full payloads, thus enabling the airport to support flights to more distant destinations.
3. Comments / Appraisal
3.1 Shepway District Council initially consulted the County Council on these applications in February 2007 but it was soon evident that Shepway DC would require further information from the applicant to enable it to determine the applications. An initial officer response identified key areas of concern to the County Council that helped Shepway identify the additional information it sought. Shepway District Council is now seeking the formal views of the County Council on the applications now that the applicant has supplied additional information.
3.2 The key strategic planning issues raised in the officer response were:
• Economic development; • Transport; and, • Biodiversity and Landscape.
Economic Development
3.3 East Sussex and Brighton & Hove (ESB&H) Structure Plan policy TR45 notes that the intensification/expansion of activities at Lydd may provide a welcome increase of job opportunities in an area which possesses a poorly performing local economy. That policy therefore supports the use and development of the airport provided it is on a scale compatible with the protection of the important environment of the eastern part of East Sussex.
3.4 However, some policies of the ESB&H Structure Plan have now expired as part of the transition to the new planning system, including policy TR45 (Shoreham and Lydd Airports). Although now no longer part of the statutory development plan for the county, it remains as the County Council’s own adopted policy stance on development at Lydd Airport. There is little doubt that an intensification of activities at LAA will create direct and indirect employment opportunities, but it is located within a part of the South East characterised by its remoteness and tranquillity and the presence of a range of internationally valuable habitats. Therefore, growth is acceptable but is subject to significant environmental constraints. This approach is echoed in the Kent and Medway Structure Plan and the Aviation White Paper “the Future of Air Transport (2003).
3.5 However, given its distance from East Sussex, concerns over transport and access, and the number of jobs to be created (the applicant considers this to be in the order of 304 to 507 total jobs for 300,000 and 500,000 ppa respectively), I consider that the intensification of operations at this location will have limited direct employment benefits for East Sussex. Nevertheless, these proposals represent an opportunity to improve the local economy of this part of Shepway District.
Surface access impacts in East Sussex
3.6 It is a fundamental aspect of planning policy that new development must cater for the demands for access that it creates, that it can be accessed by a variety of modes of transport and that unacceptable traffic conditions are not created or perpetuated as a result of development (ESB&H policies S1 (c) (d), TR1 (h) and TR3). This approach is expressed in Planning Policy Guidance Note 13 (Transport), Regional Planning Guidance for the South East (RPG9) and its draft successor the South East Plan.
3.7 The Transport Assessments accompanying both applications do not provide an assessment of the impact of the proposals on the county or trunk roads of East Sussex. The trip distribution indicates limited use of the Lydd Road and the A259 into East Sussex by traffic leaving the site, but no further assessment of the suitability of these roads and junctions on this route to accommodate the additional traffic is included.
3.8 The County Council has long-standing concerns about the standard of the A259 trunk road, and its ability to sustain further increases in traffic using it. The poor quality of the A259 also results in drivers seeking alternative routes and thus encouraging far greater use of the C24 linking Lydd with Camber. The Transport Assessment for the Terminal application states that just 5% of traffic leaving the site will use the C24 Camber Road, but given the standard of the adjacent trunk road network, I consider that this percentage will be higher, especially at peak times.
3.9 The Runway Extension environmental statement at paragraph 4.4.7 (and table 4.5) refers to the benefits of its location and lists the major towns surrounding LAA. This includes Brighton & Hove, the East Sussex coastal towns and Crowborough. The implication is that residents of these towns (and the rural areas) would wish to use LAA as an alternative to the London airports, particularly those north of the capital. To emphasise this point the applicant provides the catchment of LAA based upon 90 and 60 minute drive times as part of the terminal building environmental statement (figure 14.1). To achieve these journey times from the Sussex coast it would be necessary to approach Lydd from the west, rather than from the north (the M25/M20) as assumed by the applicant.
3.10 The applicant has been made aware of these concerns but has not sought to address them.
3.11 The only mitigation identified by the applicant to ensure that drivers do not use less suitable local roads is to erect signs directing drivers to the airport via the A259 and the B2075.
3.12 Given the absence of adequate information on the impact of the proposals on the road network in East Sussex, I consider that the proposed mitigation to be inadequate. These shortcomings are contrary to structure plan policy and the intent of national policy and RPG9.
Public Transport
3.13 The remoteness of the application site is reflected by its inaccessibility by public transport. Bus services are infrequent and the unmanned rail station at Appledore is some 12 km’s distant. It is suggested by the applicant that it would be appropriate if passengers arriving by rail should disembark at Rye where bus and taxi services may be accessed. Given the concerns expressed over the suitability of the C24 and the poor condition of the A259, the applicant should explore the potential for developing a transport interchange scheme at Appledore Station.
3.14 The applicant has acknowledged that since the submission of the applications stopping services at Appledore have now improved; thereby meaning access by rail is considerably more viable for passengers. However, this does not represent a commitment by the applicant to secure a transport interchange at Appledore station. Considering the potential cross border impacts on the communities and roads of East Sussex and the remote location of the proposals, it is essential that the applicant enhances public transport facilities for those accessing LAA from the west, and not just the north. Without the provision of an interchange and services linking the station with the airport a gap will remain between the two, effectively negating the benefits achieved by an increase in rail stopping services. Therefore, if the Shepway District Council is minded to approve these applications it must ensure that a transport interchange is secured at this location.
Travel Plan
3.15 The intention of the applicant to include a travel plan as part of the development proposals as a means of reducing the reliance on the private car is welcomed. This would help in ensuring the impact on East Sussex County Council roads is minimised. However, the scarcity of targets setting out how the Travel Plan will reduce car dependency and promote sustainable access is of concern. Should Shepway District Council be minded to approve both or either of the applications it should ensure that a robust and effective travel plan is secured.
Seasonality of Impacts
3.16 Table 4.2 (in both documents) provides details of anticipated annual average passenger and flight movements arising from the development proposals. However, seemingly no attempt has been made to describe seasonal variations in these numbers. This leads to the question of what seasonal profile is expected by the applicant. Such information is essential to model accurately the potential impacts of the development proposals and, without it, the conclusions of the environmental statement are, at best, misleading.
3.17 Whilst the applicant concedes that there may be some seasonal variation in passenger numbers, the environmental statements conclude (at paragraph 4.3.2 of the Runway Extension environmental statement) that seasonality “will be determined by the business plans of the airline operators using the airport and so a 'busiest' period cannot be determined at this stage”. In response to the County Council’s officer concerns the applicant states that there are no additional likely significant environmental effects from the seasonality of the airports operations, which have not already been assessed in the Environmental Statements or Technical Appendices.
3.18 The seasonality of operations has a direct bearing on the intensity and duration of impacts that may be felt within East Sussex, particularly demands for access. The applicant’s assertion that there are no additional likely effects arising from the seasonality of the proposals’ operations is difficult to substantiate given that the peaks of activity “cannot be determined at this stage”. It would be reasonable to expect the applicant to be aware of operator interest in the intensification of activities at LAA, and that a most likely scenario could be developed drawing upon this and the experiences of comparable airports in the south of England.
3.19 I consider that this omission from the assessment of the proposals’ impacts to be significant. Whilst the impact of seasonality may not markedly affect the type of impacts identified, it will have direct influence on the nature and severity of those impacts and without this assessment the environmental statement is incomplete.
Biodiversity and Landscape
3.20 In relation to specific ecological impacts, the direct and most intense impacts will clearly be in Kent. However, the site is located within the Dungeness, Romney Marsh and Rye Bay SSSI which forms an ecological unit with many shared populations of birds and other species. Adverse impacts on species using the area around the airport could, therefore, have an impact on sites used by those species in East Sussex.
3.21 Shepway District Council must be satisfied that there will be no damage to the features for which the site was notified, and I do not consider that this has been demonstrated. The District Council, in consultation with Natural England, will need to be satisfied that the adverse impacts on these nationally and internationally important sites are kept to acceptable levels according to national policy (PPS9).
3.22 An initial concern of officers was the lack of information on the flight paths to be used by operators and what impacts if any there may be on the environment and communities of East Sussex. However, the applicant has now provided further information stating that the take off flight paths for larger aircraft (e.g. Boeing 737) forms a tight loop heading west and returning to the east and out over Greatstone on Sea and the Channel, in order to avoid the restricted airspace at Dungeness power station and Lydd firing ranges.
3.23 Such an arrangement would, I consider, minimise adverse impacts on the communities and environment of East Sussex and in turn allay concerns that the proposals would involve flights over the eastern part of the County such as Rye and Camber. Nevertheless, I remain concerned that the applicant has not provided comprehensive and detailed information on the flight paths available to operators flying out of LAA.
3.24 The applicant has yet to guarantee that other flight paths which cross over East Sussex (with as yet unidentified adverse impacts for the environment and communities of this part of the county) will not be used. Therefore, if the District Council is minded to approve either or both applications, it is essential that the applicant is required to enter into a legal agreement guaranteeing the flight paths of aircraft using LAA will be restricted to those used as a basis for the assessment of environmental impacts, in the accompanying environmental statements, so as to avoid further environmental damage in East Sussex.
Assessment of Impacts
3.25 The applicant has provided an assessment of environmental impacts based upon a baseline assessment of existing conditions and operational scenarios of; “do nothing scenario” (this assumes that the airport will operate at its stated current terminal capacity of 300,000 ppa by 2009); and, the “future assessment conditions” scenario (which assesses the impact of both proposals leading to 500,000 ppa). The “do nothing “scenario is used as a comparator to assist in judging the significance of impacts arising from these proposals.
3.26 The presentation of the prospect of LAA being able to reach its full capacity without additional development by 2009 as a practical and realistic option is of concern. LAA is currently operating at a rate of approximately 3,000 – 4,000 ppa. To reach 300,000 ppa capacity within 2 years suggests a remarkable increase in activity. To imply that this is a “do nothing option” and therefore a valid yardstick
against which to compare the impacts of the 500,000 ppa proposal and to develop mitigation measures is, I consider, misleading.
4 Conclusion
4.1 This area of coastal Kent experiences economic difficulties and the County Council acknowledges that intensification of operations at Lydd may bring economic benefits to the local area. However, the site’s location with a relatively peripheral area notable for its high quality environment will ultimately constrain development here.
4.2 Despite having the opportunity to consider the comments of ESCC officers earlier this year, the applicant has not reassured me that the full range of cross border impacts have been adequately identified or assessed, leading to insufficient proposals for mitigation. Moreover, the applicant has failed to make a commitment to a transport interchange at Appledore station and thus assist in moderating the adverse transport impacts which arise from such a car dependent location.
4.3 Although original concerns regarding potential impacts on the biodiversity, landscape character and communities of East Sussex arising from flight paths over the county have largely been allayed, I remain to be reassured that alternative and more potentially damaging flight paths will not be used at a future date.
4.4 Whilst the principle of development of Lydd airport is acceptable in principle and may deliver economic benefits, these applications should not be permitted until an adequate assessment of cross border surface transport impacts is submitted by the applicant.
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Y06/1647/SH & Y06/1648/SH
Scale 1:Rupert ClubbBEng (Hons) CEng MICEDirector, Transport and EnvironmentEast Sussex County Council
