Representation by Royal Society for the Protection of Birds (RSPB) (Royal Society for the Protection of Birds (RSPB))
- Date submitted
- 8 October 2018
- Submitted by
- Members of the public/businesses
Relevant Representation by the Royal Society for the Protection of Birds
Our involvement with Manston Airport The Royal Society for the Protection of Birds (the RSPB) was initially invited to comment on the first Preliminary Environmental Information Report (PEIR) consultation in 2017. However no further communication has taken place with us despite our request to that effect in our response to the PEIR consultation. In our response to the 2017 PEIR we highlighted concerns regarding the methodology of the ecological surveys undertaken. While some improvements have subsequently been achieved, the RSPB does not agree that the current survey work enables a conclusion to be reached of no adverse effect on the Thanet Coast and Sandwich Bay SPA and Ramsar site or the Thanet Coast to Hacklinge Marshes SSSI bird features (i) and their species, in particular non-breeding golden plover. Due to resource constraints, this representation comprises the RSPB’s final submission to the Examination. However we reserve the right to add to or change this submission should the design of the scheme change and/or significant new information is submitted.
Aviation infrastructure in UK The RSPB is opposed to any increase in the provision of aviation infrastructure in the UK until the Committee on Climate Change’s recommendation that government produce “A plan to limit UK aviation emissions to… 2005 levels by 2050.”(ii) is met and a realistic plan is set in motion. Reopening the Manston airport within current policy structures will damage the UK’s ability to keep emissions within carbon budgets, as legislated for in the Climate Change Act 2008.
Ornithological Surveys
Winter surveys The developer presents data for two surveys undertaken during the 2015/16 and 2016/17 winters. However, the 2015/16 winter survey does not include the standard 2km buffer around the development site (page 7-10 of the ES) and the 2016/17 winter surveys did not include the development site itself. The developer states that 75% of the site was visible from the perimeter of the site, but a survey conducted without access to the development site itself is unlikely to be adequate. Moreover, the methodologies of the two surveys are not comparable to each other and therefore cannot provide a suitable data source to evaluate the impact of this project on the features of the designated sites.
Breeding surveys The applicant presents data for only one breeding season (2016) whilst best practices is a minimum of 2 years. These data are derived from a Common Breeding Census (CBC) survey, which although a satisfactory survey method, is insufficient on its own. For example this methodology is inadequate to detect site usage by soaring raptors like marsh harriers, which is a species listed in Schedule 1 of the Wildlife and Countryside Act 1981 (as amended). 13km bird strike surveys This is a standard survey for any aerodrome and while this survey was mentioned in the 2017 PEIR we could not find references to it in subsequent consultation documents nor a description of the scope of the data to be collected by any such survey.
Barn owls survey Whilst the developer is committed to undertake a barn owl survey is it unclear if the survey will extend to 200m perimeter outside the site as is standard procedure.
Night time surveys In our response to the 2017 PEIR the RSPB highlighted that “there was no mention of night time surveys to assess golden plover and other birds activity while foraging at night and which will be relevant to assess collision risk as well.” The developer states in the 2018 PEIR that “A study of plovers on Thanet during 2016 (M. Sutherland, unpublished data) involving eight paired visits by day and night provided little evidence one way or the other as to whether the nocturnal distribution differed substantially from the diurnal. It was thought that, while locally, birds may be more dispersed at night, it is unlikely that the broad distribution patterns across the various survey areas would be substantially different from that recorded by day (Henderson & Sutherland, 2017)”. Since M. Sutherland, unpublished data is inconclusive the RSPB considers that this highlights the need to conduct night time surveys for the site and a 2km buffer in order to gain a clear understanding of the situation at local level in particular non-breeding golden plover which is a feature of the SPA/Ramsar site.
Conclusion Without such information, it is the RSPB opinion, that a conclusion of no adverse effect on the Thanet Coast and Sandwich Bay SPA/Ramsar site or the Thanet Coast to Hacklinge Marshes SSSI cannot be reached.
Foot notes i) Bird features include:
- Thanet coast &Sandwich bay SPA designated species: ruddy turnstone, European golden plover and little tern
- Thanet coast to Hacklinge Marshes SSSI: dunlin, oystercatcher, curlew, redshank, grey plover, sanderling, ringed plover, mallard, shelduck, brent goose -Thanet coast &Sandwich bay Ramsar site: turnstone, ringed plover, golden plover, grey plover, sanderling and Lapland bunting
ii) [Redacted]