An assessment of proposals for additional runway capacity at Gatwick and Heathrow airports was published by the airports commission. The LNP responded to their consulation with the following.
Q1 What conclusions, if any, do you draw in respect of the three short-listed options? In answering this question please take into account the Commission's consultation documents and any other information you consider relevant. The options are described in Section 3 of the Consultation Document.
The Berkshire Local Nature Partnership (LNP) is one of 48 LNPs in England, providing a strategic vision for the local natural environment. The LNP has considered the proposals for a third runway in terms of the impacts on our biodiversity, natural capital and ecosystem services. Our response does not attempt to consider other aspects of the scheme as we believe other organisations are better place to provide this comment.
The current evidence base for biodiversity is weak for all three possible options and not sufficient to conclude which of the options will have the least negative impact on UK and EU biodiversity. It is, however, clear that all of the options will result in a significant loss to biodiversity that is unable to be avoided or mitigated.
The LNP urges the Commission to consider the impacts on our biodiversity and Natural Capital when making the decision about where to place the third runway. Economic development must be sustainable, and not at the detriment to our society's health and wellbeing. Nature and the benefits and services that this provides us are fundamental to our future prosperity and economic sustainability.
Further, the impacts on designated sites should be considered in the decision making process and the LNP urges the commission to not allow any scheme to progress which is likely to damage a designated site, protected for its nature conservation interest, particularly those of importance at a European level such as the South West London Water Bodies SPA.
The UK has made it clear that it aims to achieve 'no net loss' to biodiversity by 2020. There is a lot more work required to ensure that this proposal manages to fit with this agenda.
Q2 Do you have any suggestions for how the short-listed options could be improved, i.e. their benefits enhanced or negative impacts mitigated? The options and their impacts are summarised in Section 3 of the Consultation Document.
Scoping work is required to identify where gains to biodiversity can be achieved in the local vicinity to each runway proposal. This will also help to identify the accuracy of the costs attributed to biodiversity offsets. We suspect that due to the high price of land in the Greater London area, these costs have been underestimated by using the figures provided in the 2011 guidance (also note that more recent guidance on Biodiversity Offsetting is now available from Government).
The LNP strongly opposes any proposal that will result in a net loss to biodiversity or a reduction in ecosystem services.
In terms of ecosystem services, the analysis has failed to identify the losers and winners of the schemes. It seems likely that it will be the local communities where development takes place losing their ecosystem services with 'compensation' proposed elsewhere; although this has not been detailed. There has been no account of the fact that unless adequate compensation to offset these losses to vital services is found within an appropriate geographical area, the resulting communities will be unattractive places to live and work.
The proposers of the of the Heathrow North West runway are particularly lacking in an explanation of how they have managed to calculate losses and gains to ecosystem services, this is especially surprising as they also state they there is not enough information to perform an ecosystem services assessment.
Q3 Do you have any comments on how the Commission has carried out its appraisal? The appraisal process is summarised in Section 2 of the Consultation Document.
Q4 In your view, are there any relevant factors that have not been fully addressed by the Commission to date?
Biodiversity and ecosystem services have not been fully addressed.
In terms of biodiversity, the cost related compensation required from the footprint of the runway has been roughly calculated. However there has been no attempt to assess the opportunity for providing the required compensation within an agreeable distance from the development site – can enough opportunities for biodiversity gain be identified to be able to offset the loss to biodiversity and ecosystem services? The details provided by the scheme developers do not follow the current biodiversity offsetting guidelines, and this does not seem to have been picked up by Jacobs in their report.
In addition there has been no attempt to assess the loss to biodiversity associated with the additional development requirements that will result from each scheme – only the runway footprint has been considered. It is likely that such large scale development in already densely populated areas will be difficult to offset for loss to biodiversity and ecosystem services.
The Biodiversity Assessment concludes that both the Heathrow proposals may significantly impact the South West London Bodies SPA and Ramsar site; yet an Appropriate Assessment has not been carried out for either scheme. This should form a key piece of evidence in the decision making process and any scheme that is likely to significantly effect a designated site of European importance should not be allowed to progress.
Only once this information has been gathered and assessed can a decision be made which factors in the impacts to biodiversity and ecosystem services of the proposed schemes.
Q5 Do you have any comments on how the Commission has carried out its appraisal of specific topics (as defined by the Commission's 16 appraisal modules), including methodology and results?
Jacobs have provided a biodiversity baseline and assessed the likely overall compensation required, but have made little to no comment on the suitability of the mitigation and compensation proposed by each of the scheme developers.
There is also no comment on which of the 3 proposed schemes has the least negative impact on biodiversity and ecosystem services. This conclusion is vital in order for the decision makers to factor the effects on biodiversity into their decision making.
Q6 Do you have any comments on the Commission's sustainability assessments, including methodology and results?
Q7 Do you have any comments on the Commission's business cases, including methodology and results?
Q8 Do you have any other comments?