Welcome

Newsletters

LAAG publishes regular newsletters to keep members up to date on what is happening. You can view the current newsletter on this page and/or use the menu below to read past issues.

Current Newsletter: 12 Q4, 2007 & Q1 2008

Latest News: Shepway District Council has postponed the determination of the planning application for the large scale development of Lydd Airport. The meeting was scheduled for January 30, 2008 but has been deferred for an indefinite period. The need to provide additional information was the official reason given. Although LAAG wholly supports the need for more information, one suspects there is more behind the deferment given that the announcement came a few days after Mr Hutton’s statement in the House of Commons on January 10th , 2008 setting out the government's case for backing new nuclear power plants in Britain.

What Next?: Shepway District Council has yet to outline the nature of the information it requires from Lydd Airport for the third round of information. Whatever information is produced, will require Shepway to allow a period of consultation which means the determination is some months away.  If ecological studies are requested Lydd Airport may need to wait until the appropriate season before surveys can be carried out which will further delay the process.

The Second Consultation:  After the first consultation on the planning application for Lydd Airport’s development (Y0/1647/SH and Y06/1648/SH) in Q1, 2007, Shepway District Council requested further information from Lydd Airport. This information was submitted for public consultation in October 2007 and the second consultation was completed on November 15, 2007.  In responding to the additional information LAAG again called on its advisers for professional advice – particularly the aviation consultant, Malcolm Spaven and the entomologists Dr John and Barbara Ismay.  Our conclusions are set out below: 

(a) LAAG believes the planning applications - Y06/1647/SH and Y06/1648/SH should be rejected. The supplementary information does not change our view and we stand by the comments made in our original response.  

(a) The supplementary Environmental Information (SEI) only includes a proportion of the additional information requested by LAAG in April 2007 and a high proportion of the key fundamental information that is provided in the SEI is either incorrect or inadequate.  

We outlined over 20 areas where there were shortfalls, inaccuracies and omissions in the supplementary information submitted by the airport. In particular, most of the flight path information was incorrect. The baseline current conditions scenario for the airport was incorrect. The current number of aircraft movements had been inflated, and regular, commercial service use of the airport was claimed, by aircraft types which rarely, if ever, use the airport. The incorrect flight paths combined with the inflated “current conditions” scenario invalidated all the noise contour maps presented in the supplementary information and the analysis of the impact of aircraft noise on bird species of conservation interest. This incorrect information also cast doubt on the validity of the air quality analysis, the analysis of the predicted impacts of bird hazard control programmes on bird species of conservation interest, the analysis of the negative impacts of the airport’s development on tourism and the quality of the information used in the Appropriate Assessment required under the Habitats Regulations.   

We made these recommendations to Shepway District Council 

Shepway District Council should either:

(1) Reject the planning application outright on the basis of Lydd Airport’s persistent reluctance to provide factual information on which to make the determination, or
(2) Recommend that Lydd Airport provide the required information before proceeding with a normal determination of the planning application. 

Additional Expert Advice:

Since Shepway District Council ignored the recommendation made by LAAG and many other organisations such as the RSPB, Natural England and Kent Wildlife Trust - that the information was inadequate and incomplete - and intended to proceed with determination on January 30th, 2008, we appointed Matthew Horton QC, one of the foremost barristers in the country specialising in Planning and Environmental law, to advise on legal aspects associated with Lydd Airport’s planning application. Mr Horton had also agreed to represent LAAG on the evening of January 30th - LAAG along with other groups and individuals had the right to present its case (in 3minutes). 

LAAG also appointed Brian Banks of Swift Ecology to produce a paper summarising the main ecological attributes of Dungeness as we believe the level of awareness of the importance of Dungeness nationally and internationally is very low. This document has been used in our marketing programme. 

LAAG’s team of specialist advisors is set out below:
Brian Banks – Swift Ecology (The Environment at Dungeness)
Dr John Ismay & Barbara Ismay (Entomological Consultants)
John Large - Large & Associates (Nuclear Safety)
Malcolm Spaven – Spaven Consulting (Aviation)
Matthew Horton QC (Planning Law)
Owen Williams, part of Amey Plc (Transport) 

Other LAAG Initiatives: LAAG has continued to lobby councillors, government ministers and departments on all aspect of this campaign ranging from nuclear safety to the need for a public inquiry – as an organisation in its own right and via member letter writing campaigns. We have also continued to advertise when appropriate, and mount poster campaigns. Our ability to successfully run these campaigns has been helped by a successful fund raising campaign.   

Other News: LAAG welcomes British Energy’s decision to object to the large scale development of Lydd Airport. The company has opposed the current planning application on the basis of the “potential additional aircraft accident hazard to the safe operation of Dungeness B Power Station” and because of the “potential additional aircraft accident hazard on the safe operation of potential new build at Dungeness” ie Dungeness C. Dungeness is amongst the top 4 sites for a new nuclear build programme.   

LAAG believes that regional airports should not be built close to nuclear power stations as the risk of aircraft crash damage is too great. The consulting engineers Large & Associates estimated for the expansion to 500,000 passengers per annum (ppa) at Lydd Airport that the overall risk of a commercial airliner accidentally crashing onto the Dungeness Nuclear Power Plant site was 14.5X higher than the acceptable risk guideline imposed by the Nuclear Installations Inspectorate (NII) in order to maintain the nuclear safety case, and at 2,000,000 ppa, 24.4X higher.  

LAAG also welcomes the decision of Kent County Council and Ashford Borough Council to object to the planning application. Kent County Council objected on the basis of the inability to conclude that there would not be a negative impact upon the integrity of the international and national environmental designations surrounding the airport, while Ashford Borough Council’s objections centred on the inability to make a decision due to the inadequacy of the information provided by the airport. 

                    SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.
Louise Barton, The Hook, Madeira Road, Littlestone TN28 8QX, 01797 361 548, blmbarton@aol.com

Newsletter 11 Q2 & Q3 2007

Planning Application Update: Lydd Airport filed planning applications for a 444m runway extension and a new terminal on December 18th, 2006 - Y0/1647/SH and Y06/1648/SH. The public consultation was completed officially on March 5th 2007, although Shepway District continued to receive submissions, including LAAG’s, after the close period. LAAG argued that even on the basis of the inadequate information provided in the Environmental Statements there was sufficient evidence to demonstrate that planning permission for both applications should be refused. LAAG’s 150 page submission including individual consultants reports (see LAAG’s website www.lyddairportaction.co.uk) also highlighted that (a) the planning applications were riddled with errors. In some sections virtually every paragraph could be challenged and (b) that crucial material had been omitted from the Environmental Statements or had been poorly scoped so that the findings were inadequate.   

Shepway District Council has assessed all submissions and has returned to the airport requesting additional information. There will be another consultation before Shepway District Council makes its final decision. Since the airport has yet to agree to the final catalogue of additional information required to satisfy Shepway District Council, the determination of this planning application is many months away.  

Nuclear Safety: LAAG attended a meeting of NuSAC (Nuclear Safety Advisory Committee) on July 5th to raise awareness of the specific safety issues at Dungeness resulting from the proposed development of Lydd Airport and to lobby for wider principles to be established to ensure regional airports are not established close to nuclear power stations. This was NuSAC’s first open public meeting. Only five members of the public attended which gave LAAG an excellent opportunity to present its case. In the end it was acknowledged that the Lydd Airport situation required examination by the Committee.   

Other Marketing Initiatives:
We have re-started our local “60 Seconds to Disaster” advertising campaign in Shepway and will have a banner running on the Rye and Battle Observer’s website from August (www.ryeandbattleobserver.co.uk or www.hastingsobserver.co.uk or www.bexhillobserver.co.uk ). We will use the recently published book Wildflowers of Dungeness by Heather Silk and Barbara Gray to help raise awareness of what is at stake if Lydd Airport is allowed to expand on the scale proposed. This book only captures a small proportion of the huge range of plants that grow at Dungeness which is a unique nutrient deficient habitat of vegetated shingle and acid grasslands.  Many of the plants growing at Dungeness would thus be adversely affected by the enrichment caused by the deposition of nitrogen derived from NOx produced as a result of fuel combustion from large aircraft. We will continue to respond to government consultations whenever they present an opportunity to promote the implications of our case. After the planning White Paper we will make contributions to the Energy White Paper. 

We continue to work closely with other organisations - particularly the RSPB which is devoting considerable resources to fighting this campaign - successfully promoting the issue nationally and funding promotional material such as posters, car stickers and T-Shirts (available at the RSPB Dungeness Nature Reserve Visitor Centre, (suggested donation £10 ).

 SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.  

Louise Barton, The Hook, Madeira Road, Littlestone TN28 8QX, 01797 361 548, blmbarton@aol.com

Newsletter 10 Q1 2007

Planning Application: Lydd Airport filed planning applications for a 444m runway extension and a new terminal on December 18th, 2006 - Y0/1647/SH and Y06/1648/SH. These plans can be viewed on Shepway District Council’s website, www.shepway.gov.uk. The associated Environmental Statements are extensive and cover many social, environmental and technical issues. They are also punctuated by omissions, inaccuracies and inconsistencies which we will address when responding to Shepway District Council. We do not expect this planning application to be determined by Shepway District Council until the second half of 2007 since there are Council elections on May 3rd and outstanding information to be provided by statutory consultees.   

Marketing: Despite over two years of campaigning the level of awareness of Lydd Airport’s development proposal remains low. We have attempted to counter this by stepping up our marketing post the filing of the planning application - weekly full page ads in local papers, leafleting (13,000 to date) and weekly press releases. Our LAAG meetings with guest speakers have attracted good attendances - over 200 people at the Lydd Community hall on January 12th for John Large, the nuclear safety expert and over 150 people at the Dymchurch Village Hall on January 31st for the aviation consultant, Malcolm Spaven. We also presented to caravan park owners/managers on February 8th at the New Romney Caravan Park. Attendance was disappointing despite contacting 40 caravan site owners on Romney Marsh. Unfortunately January/February is “caravan down time” and many owners were on holiday. A few of the caravan park owners were in favour of the development, in the mistaken belief that there would be inward tourism and that people would be prepared to stay in caravans 1000/1500 ft under a flight path. We also presented to Shepway District Council and have a number of Parish Council presentations pending. We continue to work closely with the RSPB who had their own successful Public Meeting on February 7th - filling the visitor centre at Dungeness with over 100 people.  

LAAG’s Response: LAAG is preparing its response and we have been given permission to file a late submission by Shepway District Council. We are combining in-house professional expertise with that of outside consultants. So far we have engaged the nuclear safety expert John Large of Large & Associates, the aviation consultant, Malcolm Spaven of Spaven Consulting, two invertebrate specialists, and we are waiting confirmation of engagements in transport and hydrology - all of whom will contribute to LAAG’s response.  

We have also engaged a leading environmental lawyer and partner in Bond Pearce LLP, John Houghton to investigate whether the Habitats Directive has been correctly applied to Lydd Airport’s proposal. We are particularly concerned about the nature of the planning applications which have been submitted with supporting Environmental Statements based on considerably lower passenger numbers than the airport’s real objective which is to grow passenger numbers to 2million passengers per annum (2mppa) by 2015. The Environmental Statement for the runway extension is based on 300,000 passengers per annum and 500,000ppa for the terminal. We believe that the planning application should have been based on 2million passengers as this is the airport’s widely stated intention - or at least that for the runway extension as runways dictate airport’s underlying capacity. The 444m runway extension is only predicated on 300,000ppa whereas it will give the airport the infrastructure to easily achieve its 6mppa longer term goal.  

Under the Habitats Directive Shepway District Council must undertake an Appropriate Assessment to determine whether the proposal will adversely affect the European designations at Dungeness - the Special Area of Conservation (SAC), the Special Protection Area (SPA) and a proposed RMSAR site. If the proposal is shown to adversely affect these areas the development cannot proceed unless it is in the over-riding public interest which we believe could not be argued in this case particularly when there is an alternative solution to the development - Manston Airport. The problem arises because Shepway District Council is only doing an Appropriate Assessment based on 500,000ppa. We believe the Appropriate Assessment should be based on 2mpppa. If Bond Pearce LLP find in our favour then the planning application would need to be resubmitted based on 2mppa.  

The direct impacts on the SAC will be caused by the runway extension which cuts across the top of the SAC and the need to create a 150m safety zone on either side of the centre line of the runway which will also eat into the SAC. This will lead to the need to fill in a large species rich pond which is close to the runway. In addition there are the indirect impacts on habitats caused by air and noise pollution.  

The Employment Case:  Shepway District Councillors will vote on the recommendations made by their planning officers as to whether this planning application should be accepted or rejected. It is therefore vital that we address the issue of employment as many councillors want employment at any cost which means other issues such as the environment will be ignored when it comes to making a decision about the airport. Some LAAG members are concerned about LAAG’s adoption of the nuclear issue in our campaign. We are merely promoting the facts. The government is resuscitating the nuclear power industry, first preference is being given to existing sites and Dungeness is one of the top five new build sites which mean Dungeness C is highly likely. Dungeness C will replace Dungeness A &B. Many councillors believe that they can have both - a new nuclear power station and a new airport. We are pointing out that councillors must choose one or the other. If SDC votes for a regional airport this will jeopardise Dungeness C - nuclear regulations preclude large aircraft flying frequently beside a nuclear power station and the heavy movement of people - all for safety issues. We argue that a nuclear power station provides more employment, better quality employment and does not lead to the destruction of tourist employment on Romney Marsh or the environment through urbanisation and noise and air pollution.  

SEERA, Examination in Public (EIP): LAAG attended the Examination in Public on February 13th - the last consultation for the South East of England Regional Assembly’s (SEERA’S) South East Plan. In planning law this plan will take over from the various County Council Structure plans which mean in Kent it will supersede the Kent & Medway Structure Plan. At the EIP the various factions sat around a table before an Inspector and discussed outstanding issues, one being Lydd Airport.   

SEERA after strong lobbying in earlier consultations deleted any reference to Lydd Airport in the South East Plan, deeming the airport to be of local, not regional significance. The EIP provided the last opportunity for interested parties to challenge this, and other decisions. Predictably Lydd Airport argued for Lydd Airport to be reinstated in the South East plan. But this time Lydd Airport was supported by Kent County Council who wants the policy it has in the Kent & Medway Structure Plan (TP25) included in the South East Plan. This policy (TP25) favours development of Lydd Airport subject to very strict conditions but KCC now wants to modify the wording to include development up to 2mppa. This is astounding as Kent County Council eliminated the reference to “development up to 2mppa” in TP25 after strong lobbying by LAAG and others. Kent County Council justified this change of heart by saying that when they first saw the airport it was run down so therefore did not justify their support, but having visited it after £10m had been spent on upgrading facilities they thought it warranted support! We can only hope the Inspector is a sensible person. No conclusions are made at EIP hearings. All will be revealed in the Inspector’s Report. 

       SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.  

Louise Barton, The Hook, Madeira Road, Littlestone TN28 8QX, 01797 361 548, blmbarton@aol.com

Newsletter 9 Q4 2006

Latest News: Planning Update and Concerns: Lydd Airport now claims the planning application for the 444m runway extension and new terminal will be submitted in November, although this date is not set in stone as the Airport continues to consult with Shepway District Council about the timing. We believe the filing of the planning application must be delayed until all the vital information prescribed in the Scoping Opinion for the Environmental Impact Assessment (EIA) has been completed. We know that important elements of the EIA have been ignored - in particular the vital issue of nuclear safety has not been addressed. This requires revised crash damage safety cases for Dungenesss A & B. An important radar based migratory bird study has also been excluded, while the wintering bird study has not been completed. 

The revised aircraft crash damage safety cases have not commenced and the process will take at least a year to complete. The safety cases will be prepared by the respective nuclear power station operators, British Energy, (Dungeness B) and Magnox (Dungeness A), and will be based on projected aircraft movements supplied by Lydd Airport. The completed safety cases will then be reviewed by the Nuclear Installations Inspectorate (NII) on behalf of the Health and Safety Executive (HSE) and the HSE will advise Shepway District Council (SDC). The planning application cannot be determined by Shepway District Council until the HSE has advised on nuclear safety. LAAG is urging SDC to encourage the airport to delay the filing of its planning application until the safety cases are completed as this will save all parties time and money. 

LAAG believes the aircraft crash damage safety cases will fail. Our belief is confirmed by the work carried out by LAAG’s nuclear safety advisor John Large of Large & Associates. LAAG engaged John Large to quantify the probability of aircraft crash damage on the basis of the target 2million passengers per annum (mppa). John’s conclusions were disturbing - particularly the following: Lydd Airport’s proposed development would exceed the minimum acceptable risk by a factor of 20 - a probability of 1:500,000 years versus 1:10,000,000 as set out in P119 of the Safety Assessment Principles for Nuclear Plants.  

When the application is submitted the public will be granted more than the statutory 21 days to respond and Shepway District Council is likely to delay making a decision beyond the normal 16 weeks recommended for applications accompanied by an Environmental Impact Assessment (see last Bulletin for the chronology should the application be called in for a public Inquiry). 

English Nature - New Designation

English Nature (now called Natural England) has designated a new enlarged Site of Special Scientific Interest (SSSI) called The Dungeness, Romney Marsh and Rye Bay SSSI. This designation has been created by consolidating eight existing Sites of Special Scientific Interest (SSSIs) and by extending boundaries in a number of important areas including Lydd Airport. This enlargement demonstrates the national importance of the shingle foreland, sand dune, saltmarsh, open water and grazing marsh habitats in the Dungeness, Romney Marsh and Rye Bay area.  

Lydd Airport Action Group (LAAG) welcomes the decision to surround the runway at Lydd Airport with SSSI designated land as we believe it is crucial for the long term survival of this important habitat. The newly designated land covers the entire area where Lydd Airport management has proposed to build a 444 metre runway extension. The proposed extension of the runway and the new runway safety margin will directly impinge on the new SSSI designated by English Nature and the existing Special Area of Conservation (SAC), a European designation.  

Noise Test: The airport plans to conduct a noise test before the planning application is filed by flying a Boeing 737 over the area. Please, when making noise complaints to the airport give your full name, address and telephone number to ensure the complaint is registered (see previous newsletter for the noise reporting procedure).  

  SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.  
Louise Barton, The Hook, Madeira Road, Littlestone TN28 8QX, 01797 361 548, blmbarton@aol.com

Newsletter 8 Q3 2006

Latest News: Planning Update: Lydd Airport claims it signed off the Environmental Impact Assessment (EIA) on July 28th and will be consulting Shepway District Council over the coming weeks about the timing of their planning application. We know that important elements of the EIA have been ignored (the nuclear safety case and radar based migratory bird studies) or not completed (the wintering bird study). We believe all vital information in the EIA must be completed before the planning application is filed. Fortunately government policy is in our favour and we believe the planning application will be delayed until the requisite information is provided.  

When the application is submitted the public will be granted more than the statutory 21 days in which to respond. The Department for Communities and Local Government (DCLG) (was Office of the Deputy Prime Minister) has the right to call in the application for a public inquiry at any time after it is submitted. The proposal in our view satisfies 4 of the 5 criteria used to assess whether a planning application should be called in. However, the normal route to a call in is thus - if Shepway District Council is minded to grant permission for the development and there are grounds for a call in, the application will be passed to the DCLG’s office for review. This department then has 21 days in which to make a decision. If Shepway rejects the planning application, the DCLG does not get involved. The Airport has the right to appeal. 

Latest News: Energy Review Implications: The government’s decision to back the construction of new nuclear power stations raises the issue of nuclear safety - particularly aircraft crash damage risk. Since the last AGR construction programme over 30 years ago there has been a significant increase in aviation and airports have expanded to meet this demand. Local airports are expanding to become regional airports with all the associated dangers when they are located close to nuclear power stations. The position at Dungeness is particularly worrying since Lydd Airport is located less than 3 miles away and the airport is planning to expand from a small local airport to a busy regional airport carrying 2million passengers per annum using heavy jet aircraft weighing up to 70 tonnes.  The nuclear safety consultant John Large believes Lydd Airport’s proposed development would exceed the nuclear regulator’s minimum acceptable risk criteria by a factor of 20 - 1:500,000 versus the guidelines set by the Nuclear Installations Inspectorate of 1:10,000,000. LAAG will continue to lobby to ensure that regional airports are not built or operated close to nuclear reactors since the risks are too great. We believe restricted flight zones around nuclear power stations should be strictly enforced for commercial passenger aircraft.   

NuSAC: LAAG lobbied the various nuclear regulators early in the year and had the most promising response from the Nuclear Safety Advisory Committee (NuSAC). This body which meets 3 times per year and has its own experts advises the Health and Safety Executive (HSE) on matters which require attention regarding nuclear safety policy. In practice NuSAC sets principles for the nuclear power industry. NuSAC is totally independent and effectively acts as the final overseer in the industry - it could for example, oppose the Nuclear Installations Inspectorate. LAAG’s request not to site regional airports near nuclear power station was noted as an issue at NuSAC’s July 6th meeting and one that needs revisiting. The issue will be raised again (and hopefully addressed) in the organisation’s November meeting when NuSAC will be fully conversant with the contents of the Energy review which was published on July 11th.  

Nuclear Decommissioning: LAAG voiced its concerns to the HSE in the Dungeness A Decommissioning Consultation - although these concerns were recognised they were not acted upon because the planning application for the development has not been submitted.  

Latest News: Lydd Airport Flight Paths: At a LAAG meeting at the Lydd Community Hall on Thursday June 29th, 2006, the aviation consultant, Malcolm Spaven presented a flight path analysis to over 200 LAAG members. He confirmed that commercial passenger aircraft will use the more precise Instrument Landing System (ILS) rather than the NDB/DME approach procedure. The Lydd Airport ILS will have a 5 degree offset from the centre line and 3.5 degree glide path due to the need to avoid the Hythe Military Ranges. The consultant confirmed that this is the only civil airport in the UK with an ILS with a 5degree offset from the centre line which means a manual flight path adjustment must be made 900metres from touchdown. This means Lydd Airport will have a more difficult ILS landing procedure than other airports and this makes a missed approach more likely.  

The ILS approach path which was published by the CAA on June 8th starts over Lyminge at 2900ft, crossing Dymchurch between 1900ft and 1600ft, St Mary’s Bay between 1500ft and 1200ft, Littlestone between 660ft and 530ft and Dunes Road Greatstone at 380ft. There will be no ILS for aircraft landing from the South West due to restricted airspace over the Lydd Military Ranges (4000ft) and the Dungeness Nuclear Power Stations (2000ft).   

Mr Spaven also outlined the preferred routes after take off from either runway 21 (towards Lydd -westerly winds) or runway 03 (towards Greatstone - easterly winds) with flights to France and Italy going directly over Camber, flights to Spain and Portugal over Rye, flights to Germany, Netherlands and Scandinavia over Hythe and Folkestone and flights to Scotland and Ireland over Romney Marsh towards Maidstone (Detling).  

Mr Spaven confirmed that all commercial aircraft taking off from runway 21 (towards Lydd) would be required to make a sharp right hand turn to avoid the Lydd Ranges and would pass over Lydd before beginning their on-ward routings. He also added that this procedure was challenging for fully loaded passenger aircraft because of the requirement to simultaneously meet the CAA’s noise abatement procedures while avoiding the Lydd Ranges.  

Postal Charges: The basis for pricing post changes on August 21st  to include size as well as weight. We will no longer be able to send mail in large envelopes as the cost increases from 23p to 37p, although we can still send smaller letters for 23p. If you are a LAAG member who obtained the internet after joining - could we have your e-mail address please to cut postage costs.  

SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

Newsletter 7 Q2 2006

Latest News: CAA Approved Landing Flight Paths: The Civil Aviation Authority (CAA) has approved the operation of an Instrument Landing System (ILS) at Lydd Airport starting on June 8th, 2006.  The ILS has a steeper than normal 3.5 degree glide path (normally 3degree) and 5 degree offset (normally zero) from the centre line of the runway. This is necessary because of the flight restrictions over the military ranges at Lydd and Hythe. The result is bad news for residents as the centre beam of the ILS which will be used to guide passenger aircraft onto the runway will not be out to sea as claimed by Lydd Airport management in presentations on numerous occasions.   

Malcolm Spaven of Spaven Consulting has analysed the flight paths for LAAG and has confirmed LAAG’s belief that the centre line of the ILS will be inland of the Hythe Ranges. The ILS starts over Lyminge (2800ft), crossing the M20 near junction 11, passing to the seaward side of Lympne and over the Royal Military Canal at St Botolphs Bridge (2600ft). The ILS centre line then passes over Dymchurch (1500ft), running along the beach at St Mary’s Bay (1200ft) before passing inland of Romney Bay House (800ft), across Littlestone Golf Course, meeting Littlestone Road between Madeira Road and St Andrews Road (600ft) before passing over the middle of Dunes Road in Greatstone (<400ft).  

We believe Lydd Airport will be the only passenger airport in the UK to have a landing procedure with a 5degree offset. Since the centre line of the ILS is offset from the runway, pilots must make a manual late stage correction to turn aircraft on to the centre line. This means Lydd Airport will have a more difficult landing procedure, making a missed approach more likely. 

The CAA has also published an alternative instrument based flight path using an NDB/DME (Non Directional Beacon/Distance Measurement Equipment) approach procedure which will be used primarily when the ILS is not functioning.  This flight path is further inland than the ILS approach. The NDB/DME centre line passes between Burmarsh and Newchurch on Romney Marsh, over Marlie Farm on the outskirts of New Romney, with the final approach over Shortlands School.    

In addition, the CAA has published a holding area for aircraft waiting to join the approach path in order to land. This holding pattern covers a wide area of Romney Marsh and its surrounding areas stretching between Newchurch, Ivychurch and Bromley Green.  

Airport Meetings: Lydd Airport held a series of meetings starting at New Romney on April 5th and finishing at Rye on May 31st, conveniently timed to be completed before June 8th. In the presentations the airport showed outline plans of flight paths but refused to give detailed information about them on the basis that they had not yet been published by the CAA.  The meetings revealed little new information.  

Airport Passengers: The airport had 2800 passengers in 2005 compared to 4000 in 2004. These figures include Fly & Dine passengers.  

Planning Update: The Environmental Impact Assessment (EIA) which must be filed with the planning application is now expected to be completed by July and the planning application filed in Q3. Again we believe there will be slippage on this date because of the scale and complexity of information that must be covered by the EIA. 

What is LAAG Doing?: We as an organisation continue to vigorously lobby to raise awareness of Lydd Airport’s proposed development and concerns related to the change of use from a local to regional airport. We have widely marketed the conclusions of the work undertaken for LAAG by the nuclear safety expert, John Large of Large & Associates - namely that the proposed development would exceed the nuclear regulator’s minimum acceptable risk criteria by a factor of twenty - 1:500,000 versus the guidelines set by the Nuclear Installations Inspectorate of 1:10,000,000. Our target audience has included the Cabinet, relevant members of the opposition, relevant government departments, CAA, British Energy and the various bodies regulating the nuclear power industry. The responses have varied from effective dismissal, to a belief that there are sufficient safety nets within the planning process to safeguard the Dungeness site, to the more enlightened response from NuSAC (Nuclear Safety Advisory Committee) that this may be time to take a fresh look at the siting of new nuclear installations and the subsequent control of development around these installations. 

We recently engaged the Aviation Consultant, Malcolm Spaven of Spaven Consulting to analyse the flight path routes so that we can communicate both the actual flight path positions to local residents and assess any safety issues that may arise due to the challenges posed by the physical constraints in the area (military ranges and nuclear power stations).  Malcolm has completed the landing flight paths and will report on the take off routes later in the month. His analysis has confirmed our earlier work that the flight paths are inland and not out to sea.  

Increase in Noise and Noise Reporting: After the new instrument approach procedures are published on June 8th there could be more activity at the airport even if the airport fails in its bid to attract small airlines such as Flybe. (The airport is currently attempting to gain business from airlines able to operate on the exiting runway using smaller turbo prop aircraft.)  FAL Aviation UK is promoting pilot training for both instrument approaches (ILS and NDB/DME), which if successful, will lead to increased activity at the airport. Hence, we are repeating our noise procedures.  

First, call the airport (01797 322 400/411/403) and report the incident noting the date and time of the incident. If the call is not taken leave a message. In addition, ring the Environmental Department at Shepway District Council (SDC) and repeat the details, mentioning that you have also reported the incident to the Airport. Ring 01303 853 549 and ask to have the complaint logged or email environmental.health@shepway.gov.uk.  Note, SDC cannot take any action but at least we will have an independent record. As a double back up as there have been difficulties with this facility - send/phone/email the details to Di Matra and she too is keeping an independent record for LAAG (01797 366 782, email di@matra.fsnet.co.uk or write to Di Matra, 127 Dunes Road, Greatstone TN28 8SP).  Remember you must ring the airport first and leave details before you log your complaint with SDC and Di Matra. 

SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.  

Louise Barton, The Hook, Madeira Road, Littlestone TN28 8QX, 01797 361 548, blmbarton@aol.com

Newsletter 6 Q1 2006

Latest News: Lydd Airport Removed from SEERA’s South East Plan

On March 1st The South East England Regional Assembly (SEERA) announced the changes to the South East Plan and revealed that the reference to Lydd Airport and development to 2mppa in Policy EKA3 has been deleted. Lydd Airport was deemed to have no regional significance and will be dealt with from a planning perspective at the local level in Shepway District Council’s Local Development Framework. Manston has been nominated as a regional airport and growth up to 6million passengers per annum is supported.  

This is a highly significant development as the new regional planning framework which will be enshrined in law (when the South East Plan is signed off in 2008) does not support Lydd Airport’s regional airport ambitions and this will make it more difficult for the airport to undertake large scale development, although it will not stop the airport from making its planning application as there are many facets to this issue.  LAAG’s letter writing campaign contributed to this excellent result.    

Background to SEERA’s Decision

The South East Regional Assembly (SEERA) is administering a new planning regime which will ultimately take over from the existing regime which encompasses County and Local Structure plans revised every 5-10 years. The starting point is the regional planning framework embodied in the South East Plan. This provides a broad vision of the South East Region through to 2026, addressing issues such as housing, the environment and transport. (Local policy will be set by the Local Development Framework and the old Local and County Structure Plans will no longer be produced.) When the South East Plan is signed off it will become a legal document and local authorities and other government agencies in the in the South East will be forced to follow the guidance it provides.  

LAAG members contributed to the first Consultation on the South East Plan in March 2005 (consultation closed April 15th, 2005) arguing that the reference to 2mppa must be removed from policy EKA3 as the airport was not suitable for large scale development. In the end we achieved a better result as the reference to Lydd Airport was deleted altogether. For various technical reasons the decision on these policies was not taken until March 2006. Unfortunately this is not the end of the consultation process on the South East Plan. There are more consultations to come – the document will go to the government for its consultation, there will be an examination in public and a modifications consultation before the plan is signed off in 2008. It is always possible that the decision on Lydd Airport could be reversed but we believe it is unlikely.  In the meantime the Kent & Medway Structure plan rules in planning law and this supports development at Lydd Airport, although the 2mppa goal has also been deleted and strict conditionality placed on development (see last newsletter).  

Lydd Airport and Nuclear Safety

Lydd Airport Action Group (LAAG) held a member’s meeting on Wednesday, February 15th, 2006 at which the leading nuclear safety consultant, John Large of John Large & Associates gave a presentation to almost 200 people about the dangers of operating a regional airport beside a nuclear power station. LAAG engaged John because we are concerned about the change of circumstances at Lydd Airport - currently a local airport catering for light aircraft under 5.7m tonnes, it plans to develop into a regional airport catering for 2million passengers per annum by 2011 using Boeing 737s weighing 70tonnes fully loaded. This will increase the risk of aircraft crash damage at the Dungeness Nuclear Power complex which is less than 3miles away. In addition, locating a regional passenger airport close to a high profile nuclear power station site increases the accessibility for terrorist attack. 

John’s conclusions were disturbing - particularly the following: Lydd Airport’s proposed development would exceed the nuclear regulator’s minimum acceptable risk criterion by a factor of twenty - one in five hundred thousand versus the guidelines set by the Nuclear Installations Inspectorate of one in ten million.  

Even when Dungeness A is decommissioned in 2006-2008 the reactor hulks will remain for at least 25 years and contain tons of volatile radioactive material. 

John Large of Large & Associates recommended that: (1) British Energy and British Nuclear Fuels, the nuclear power operators should reassess the risks and consequences of the proposed introduction of fully loaded Boeing 737s. (2) The Nuclear Installations Inspectorate should scrutinise the revised safety cases against its own safety principles. (3)The planning authorities should give greater priority to the assessment of aircraft crash damage in the planning process and review the emergency evacuation plan. 

How has LAAG used this information?

John Large’s research is being used to make representations to relevant companies, and departments at government, county and district level. They include: the Nuclear Decommissioning Agency, British Energy, Civil Aviation Authority, Parliamentary Office of Science & Technology, Nuclear Safety Directorate, Nuclear Safety Advisory Committee, Office of Civil Nuclear Security, Health & Safety Executive, Air transport Management Division of the Department of Transport, Office of the Deputy Prime Minister, Department of Trade & Industry and Emergency Planning at KCC. In addition, we have contacted the relevant government ministers. The LAAG member letter writing campaign will also be focussed on government ministers.  The nuclear safety issue has been LAAG’s main focus in this quarter and will remain so. However, we continue to raise awareness of the airport’s proposed development through presentations to councils and other bodies - presenting to the Transport Committee of the Ashford Borough Council on February 24th. 

Planning Update: The planning application must be accompanied by an Environmental Impact Assessment (EIA).  At the Airport Consultative Committee in January the airport stated that it hoped the revised EIA would be completed by the end of March but admitted this was an ambitious target.  Given the complexity of the issues that must be addressed by the EIA we believe it is unlikely to be completed until later in the year, and the planning application filed at the end of the year at the earliest.  

SAVE ROMNEY MARSH - SUPPORT OUR CALL FOR A PUBLIC INQUIRY

LAAG does not charge a subscription for annual membership but if you would like to make a voluntary donation to LAAG to help cover operational costs please make cheques payable to LAAG.  

Louise Barton
The Hook, Madeira Road, Littlestone TN28 8QX
01797 361 548
blmbarton@aol.com