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Representation by Buckinghamshire and Milton Keynes Association of Local Councils (BMKALC) (Buckinghamshire and Milton Keynes Association of Local Councils (BMKALC))

Date submitted
12 June 2023
Submitted by
Parish councils
  1. Inadequate noise controls: The applicant has not complied with Government policy re tailoring the Noise Envelope to local priorities and designing it in meaningful consultation with local communities. It is not discussed how future benefits will be shared or that communities will be meaningfully consulted post DCO. The noise thresholds cited in Table 3.1 of 7.08 Green Controlled Growth Framework are at once misleading and meaningless: for 95% read 99%. Night flight restrictions are inadequate and mean some villages plagued by night noise miss out on insulation. 2. Misleading promises re greenhouse gas emissions: Reliance on SAF to control greenhouse gas emissions is flawed. At least as much CO2 is emitted when all SAF is burned as from kerosene; any net life-cycle emissions’ savings come from a) the assumption that CO2 has previously been removed from the atmosphere; b) the assumption that ‘waste’ raw material would have otherwise gone to landfill and released CO2 and methane; c) assumptions as to what else might have happened to the waste, and also to the land where plants-for-fuel are grown. The Royal Society concludes that “Life Cycle Analysis tools can be very flexible in how they are applied, which would significantly produce different results depending on how the boundaries are set.” 3. Unacceptable loss of farmland and biodiversity: Approximately half of the agricultural land to be built on is classified as “Best and Most Versatile”. More land would be lost to provide new areas of habitat creation to mitigate biodiversity losses elsewhere. However, this would not be like-for-like habitat replacement so, as well as losing the agricultural land itself, the biodiversity associated with open farmland (e.g. hare, deer, fieldfare, skylarks, lapwings) would also be lost. Damage to the Winch Hill Wood ancient woodland owing to habitat fragmentation and reduction in ecological connectivity cannot be avoided. There are numerous “minor adverse effects” of the proposed development, individually classed as “not significant”, yet the cumulative effects and significance have not been discussed.