Representation by Kent Wildlife Trust (Kent Wildlife Trust)
- Date submitted
- 8 October 2018
- Submitted by
- Non-statutory organisations
Manston Airport - Nationally Significant Infrastructure Project - Development Consent Order application
Relevant Representation by Kent Wildlife Trust
Kent Wildlife Trust appreciate the invitation to comment on the proposals to redevelop Manston Airport for international air freight. We have already submitted comments in our previous letters of 11th August 2017 and again on 12 February 2018. Please note that our previous comments remain valid. Comments below relate to additional information that has been provided in this current consultation stage.
Species and Habitats Kent Wildlife Trust is concerned about the potential negative impact on species and habitats, both on the site itself but also in the immediately surrounding area, which includes a number of sites of local, National, European and International importance for nature conservation. This position has not changed and although there has been further survey, there remains insufficient information to reassure us that there will be no negative impact on these sensitive sites and their associated species.
Noise Mitigation Plan We are concerned that the 'Noise Mitigation Plan’ does not consider in sufficient detail the impacts of specific flightpaths. We would hope to see a further examination on the predicted level of disturbance and pollution that will be caused by the airport proposal at sensitive nearby sites, such as Sandwich and Pegwell Bay.
This new section of the consultation does not provide sufficient information about noise mitigation for potential disturbance and damage to species and habitats in the surrounding area. We note that a community fund to spend fines for individually noisy aircraft and also those that stray from established flightpaths is proposed. Kent Wildlife Trust would advocate a “precautionary approach”, rather than one which attempts to compensate after the damage has already been done.
Designated sites and species It is crucial that it can be demonstrated by the Environmental Statement that this proposal does not have a negative impact upon nearby internationally protected sites, such as Thanet Coast and Sandwich Bay SPA and SAC and its nearby Local Wildlife Sites, which act as supporting sites for associated bird populations; also to other internationally protected sites in the vicinity.
Measures to safely disperse birds and other wildlife from the runways without harm should also be further demonstrated, alongside a long-term conservation management plan that can demonstrate how consideration for wildlife can be accommodated alongside the specific requirements for commercial airport land use management.
It is the view of Kent Wildlife Trust that these above matters have still not been adequately considered since the last iteration of statutory consultation, in particular with respect to Sandwich and Pegwell Bay. We defer to RSPB consultation comments and support their concerns over the methodology of the bird surveys undertaken. We would like to add that there appears to be contradiction in the Barn Owl survey where it comments 'it is considered unlikely that barn owls currently use the site and even if a worst case assessment were adopted, given the available habitats no more than a single pair of barn owl could nest on site, however signs of Barn Owl are reported in 1.1.7 of the Barn Owl survey.
Kent Wildlife Trust have similar concerns over the methodology and detail of further species surveys undertaken:-
Section 41 species: S41 species are the species found in England which were identified as requiring action under the UK BAP and which continue to be regarded as conservation priorities under the UK Post-2010 Biodiversity Framework.
The S41 list is used to guide decision-makers such as public bodies, including local and regional authorities, in implementing their duty under section 40 of the Natural Environment and Rural Communities Act 2006, to have regard to the conservation of biodiversity in England, when carrying out their normal functions. It is to important on such a big development to have more regard to S41 species. We are concerned about the potential impact upon the Kent priority species brown hare. We would have expected to see further survey and detailed proposals to mitigate for this species.
Invertebrate Survey: The timing and survey effort for the invertebrate survey is disappointing. Considering that the survey was made late in the season and under poor conditions for bees and wasps, and that few of the group, in terms of either species or individuals, were encountered, the number of scarce aculeates with restricted distribution is impressive and suggests that this group will prove of substantial interest.
Biodiversity opportunity Kent Wildlife Trust would hope to see more detailed proposals that would demonstrate good quality enhancement opportunities for biodiversity. Although this site is just outside the Biodiversity Opportunity Area (BOA), any habitat creation should give consideration to its position on the chalk plateau and a locally-appropriate species planting list for any green spaces within the site itself. The mitigation and enhancement package does not reflect in both scale and detail what we would expect in order to mitigate for the impacts associated with this application and the level of survey effort thus far is not appropriate to inform such a plan.
Yours Sincerely,
Vincent Ganley Conservation Advice Manager