Airspace and runway concerns

CPRE Kent has taken part in two consultations on airports – the UK Airspace Policy consultation and the Department of Transport Runway Consultation.

We do not accept that there is a case for additional runway capacity in the south east. Under-used runways exist within the UK and to add capacity in the south east will only further aggravate the north-south economic divide. Plus, there will be further impact on the environment and it will further damage the UK’s efforts to control carbon emissions, there will be additional pressure on transport and housing and more people affected by noise and air pollution.

Read our response here.

In the Airspace consultation we raised concerns about flight paths and noise including:

• More call-ins by the Secretary of State to changes in flight paths – there have been three major changes to flight paths at Gatwick over the past four years (the ADNID trial, the concentration of approach routes to the east of the airport, and the concentration of departure routes). These changes have caused thousands of complaints, yet none of them would have fallen within the proposed criteria for call-in so it needs to be much wider.
• We consider the proposals for compensation to be inadequate. The proposals for increased noise insulation would only apply very close to the airport and would provide no benefit to those who wished to open their windows or spend time out of doors. Compensation for new or changed flight paths should be paid by the airport concerned.
• We are disappointed at the proposal to retain unchanged the guidance which states that noise should be given priority up to 4,000ft, while noise and climate change should be given equal priority between 4,000 and 7,000ft. We do of course recognise the importance of limiting climate change emissions, but we are aware that many of our members are severely disturbed by the noise of aircraft at heights of 4,000 to 7,000ft and even higher. This is particularly true in areas where ambient noise is low.
• We strongly oppose a policy of transferring some noise controls to the airports. It would be wrong in principle to put such controls into the hands of a commercial business, which will always put profit first.

Read our full response here.

May 22nd 2017

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document