
A Society Dedicated to Preserving and enhancing the environment of the Stour and Orwell AONB
Stour and Orwell Society appears at the Stansted G1 Inquiry |
The Society's Honorary Treasurer, Stephen M Clark, presented the following submission to the planning inspectors appointed by the Government to consider Uttlesford District Council's refusal of BAA application to increase flights by 170 per day increasing the use of Stansted from 25 million to 35 million passengers a year. |
The submission was made into week 10 of the inquiry held at Sudbury Town Hall on Tuesday 4th september 2007. |
1. The Stour and Orwell SocietyThe Society was formed to protect and enhance a peninsula of land bounded by the estuaries of the River Stour and River Orwell in south Suffolk. The area is known as the Stour and Orwell Area of Outstanding Natural Beauty and together with the adjacent Special Project Area forms part of the Suffolk Coast and Heath Area of Outstanding Natural Beauty and is located adjacent to the Dedham Vale AONB. The area has significant statutory recognition as follows;
a) As an Area of Outstanding Natural Beauty (AONB) it forms part of only four designated AONB’s in the six counties of the Eastern Region (see map 1).
b) The Convention on Wetlands of International Importance was signed in Ramsar, Iran as an inter-government treaty for the conservation and protection of bird life. This covers both estuaries and as such provides an international designation protecting internationally renowned wildlife and wetland areas. As well as an international designation, the salt marsh fringed estuaries contain some of Britain’s most important wildlife areas.
c) The area contains above average sites of Special Scientific Interest, conservation areas, ancient woodland, listed buildings and historic parkland.
The Society, with over 200 members, was formed to protect and enhance the natural assets of our area, but there has been a groundswell of outrage relating to the over-flying of the peninsular by air traffic, routed in and out of Stansted and Luton airports, which never existed before March 2004.
2. Stour and Orwell AONB characteristics“The AONB presents an unchanged sense of the English Countryside which it is designed to protect and enhance.” (Ref: Natural England). The area is characterised by reed beds, salt marsh and mudflats of the Stour and Orwell estuaries which, together with a rich mixture of undulating and vulnerable lowland landscapes, make the area unique.
The rural tranquillity enjoyed by residents and visitors alike up to March 2004 was significantly valued. In the Rural White Paper 2000 the Government recognised the contribution of tranquillity to the character of the countryside. So concerned at the increased disturbance, members of the Society asked Douglas Sharps to make an assessment of our own tranquillity. Mr Sharps runs one of the largest acoustic consultancies in the UK, known as the Sharps Redmore Partnership and lives on the peninsula. He has given evidence at over 300 planning enquiries into nuisance involving noise, most often related to noise from aviation. He carried out noise tests within the AONB, his findings showed that the background noise was frequently at 35 dB and that only the sound of whispering grass was audible on his acoustic recording apparatus. Over-flying aircraft noise was recorded at 60 dB which he described as a medium frequency rumble or roar with sometimes a crackle from certain aircraft types. One of the chief characteristics of this noise, that he noted, was the unrelenting nature of the noise which, on several occasions, he found to be continuous or almost continuous due to the number of flyover events but also due to the low background noise, meaning the aircraft could be heard from long distances and at high altitudes.
3. Current levels of over-flying of the Stour and Orwell Area of Outstanding Natural BeautyUp until the change of routing introduced by NATS in March 2004, the tranquillity of the area was not undermined by aircraft noise.
The change to the airspace in March 2004 by NATS was to relieve heavy traffic on the Clacton Beacon (see map 2 based on Stansted flight data, 3rd August 2003 before the change) and to reduce the effects on the western area of the Dedham Vale Area of Outstanding Natural Beauty (AONB). Indeed, Suffolk County Council’s response to NATS consultation on the new routes, dated 27th June 2003, was “The emphasis placed on reducing noise disturbance on the Dedham Vale AONB in framing these proposals is welcomed. The routing of the majority of flights inbound to Stansted and Luton from continental Europe to the north of Ipswich rather than to the south via the Clacton Beacon should significantly reduce the over-flying of the Vale”.
In March 2004 a new entry route into Stansted (see map 3 based on Stansted flight data, 15th August 2004 after the change) was from IDESI to the LAPRA way point, north of Ipswich. However, the vast majority of flights were ignoring the new route and were being directed into Stansted and Luton airports over the Stour and Orwell AONB and Dedham Vale AONB. Quite clearly something had seriously gone wrong with the new flight paths since they were having environmental consequences that were never predicted or consulted upon by NATS. Whilst NATS had designed the route north of Ipswich to IDESI, a route approved by the Secretary of State, unfortunately it transpired that the air traffic controllers were not bound by the statutory protection of areas on the ground. The Dedham Vale Society appealed to the High Court over the fact that 90% of the traffic was going over the Dedham Vale (and over the Stour and Orwell ANOB), rather than taking the approved route north of Ipswich.
In the court case much evidence was provided. For example I was able to hear 38 flights over my house between 7.00 pm and 8.30 pm on the 5th June 2005 (ie. 1 plane every 2.3 minutes) and this was corroborated by Mr L Boulton of NATS Corporate and Technical Centre. On the same day, I also noted 25 flights between the time of 10.00 pm and 11.00 pm (ie. 1 plane every 2.4 minutes), again correlated by NATS. Because of the very low ambient noise as illustrated by Mr Sharps’ technical observations as the noise of one plane faded away another could be heard leaving a continuous noise in the sky. As a result of the court case which took place on the 14th–20th December 2005 the Hon. Mr Justice Newman found for the Dedham Vale Society and costs were awarded. The judge stated that “The events which transpired after March 2004 reasonably gave rise to a deep sense of grievance on the part of the claimants and to all those concerned for the environment in the Dedham Vale and other areas of outstanding natural beauty.” He went on to say that the Dedham Vale Society had served the public interest in forcing the issue which has now led to NATS reconsidering air traffic control in the south east, due to be implemented in March 2009. However, there is no guarantee as to the outcome of this exercise and further damage to the AONB’s (by yet further over-flying) should not be sanctioned until this issue has been satisfactorily resolved.
4. Impacts of intensification of use of Stansted airporta) The Stour and Orwell Area of Outstanding Natural Beauty is located some 50 miles from Stansted but the effects of further intensity of aviation traffic will be felt by communities not only close to the airport but those a distance away.
b) The Secretary of State’s guidance to the CAA on environmental objectives relating to the exercise of its Air Navigation Functions was published as part of the Transport Act 2000 and clearly states at paragraph 46 that “The governments aim is to give stronger protection to the most valued landscapes in designated national parks and areas of outstanding natural beauty. Therefore, wherever practical the Director of Airspace policy should pursue policies that will help to preserve the tranquillity of the countryside where this does not increase significantly the environmental burdens on congested areas.”
c) Paragraph 55 goes on to say that visual intrusion by aircraft above 7,000 ft may be a consideration in exceptional cases such as national parks and AONB’s.
d) There is therefore statutory acknowledgement of the importance of protecting AONB’s in terms of both noise (tranquillity) and visual intrusion. Despite such protection, unrelenting inbound and outbound air traffic is causing major disturbance in the area. Increased usage of Stansted will further threaten our area.
e) We would therefore urge that you reject the proposal from BAA to increase flights by 170 a day at Stansted Airport.
f) However, if you are minded to approve BAA’s proposal then may I respectfully ask that a precondition for the implementation of such approval should be the adoption of routing arrangements which generally direct aircraft away from the Dedham Vale and Stour and Orwell AONB’s which are recognised areas of tranquillity and whose environmental quality is expressly protected by statute.
Stephen M Clark BSc FRICS ACIArb 21st August 2007 |