ࡱ> ܥhc e+!   )))))$)))))*.4*X)*e**(*************+Xw+{*)*{******))******)*)**7R))))))**** HEATHROW TERMINAL 5 DECISION KEY POINTS AND ISSUES Introduction West London Friends of the Earth (FOE) were the main non-statutory objectors at the T5 public inquiry. This note gives a summary of the key points and issues of the Heathrow Terminal 5 (T5) decision. It is not intended as a review or summary of all the aspects covered by the public inquiry or the decision; rather it seeks to summarise the main points of the decision and highlight the key arguments and strategic issues. These issues will be of relevance to other major planning applications and should give a useful indication of government thinking on development and the environment. There are two main decision documents. The first is the report by Roy Vandemeer, the Inspector at the Public Inquiry, and covers about 1400 pages. This report does not give a decision, only recommendations to the Secretary of State. The final decision was taken by the Secretary of State, Stephen Byers, and this is documented in the Decision Letter and in his statement to the House of Commons. In most cases the Sec of State has agreed with the inspectors report, so the view of one can be taken as the view of the other. In the few cases the Sec of State did not agree with inspector, this is noted. Quotes from the inspectors report or the decision letter are italicised and included in . Bolding within quotes is our emphasis. Items enclosed in [ ] are explanatory or background information. Where a reference such as [34.1.1] is given, this is the paragraph of the inspectors report from which the quote is taken. A number of more detailed briefings, each covering one topic, are available on request. Full details of any issue should be sought in the inspectors report and in the inquiry documents. (Copies of the Inspectors report can be provided as Adobe Acrobat files.) This briefing is divided into a number of sections. They are : T5 to go ahead Planning policy including Green Belt Sustainable development and balance Demand and capacity The size of T5 The national economy The local economy Employment Surface access Noise Air quality * Greenhouse gases Public Safety * Biodiversity * Twin Rivers Runway 3 Construction Conditions * More detailed briefings available. T5 to go ahead Stephen Byers, Secretary of State, gave the go-ahead to T5. The main reason was its importance to the national economy. Significant adverse effect were acknowledged, including : development on Green Belt, traffic congestion, aircraft noise, air pollution, safety risks and ecological damage. The issue was characterised by the inspector as economy versus impact on local residents. He said (paras 16,17 of his summary) In essence the decision on Terminal 5 comes down to a balance between its benefits to the national and local economy and to the travelling public as opposed to its impacts on local residents. I have come to the clear conclusion that the benefits would substantially outweigh those impacts as long as its effects are properly controlled. The Sec of State concurred (para 9 of the Decision letter) .. the Secretary of State acknowledges the importance of Heathrow to the national economy. He has very carefully considered the economic and other arguments in favour of permission being granted and weighed them against the environmental and other impacts that the grant of permission for Terminal 5 will have. In reaching his decisions, the Secretary of State has concluded that with strict controls in place the benefits of Terminal 5 to the national and local economy, to UK airlines and to passengers will outweigh the environmental and other disbenefits associated with Terminal 5. The inspector recommended a number of controls and made strong statement about them .. In the absence of effective controls the picture would be different. If such controls were not imposed the balance would, in my view, tilt against Terminal 5. [para 17 of the summary] The Sec of State confirmed the main controls but did not say that he agreed with the inspectors view that the balance would be tilted if the conditions were not imposed. In granting T5 there were 5 important conditions or changes imposed on the scheme submitted by BAA : Limit on flights to 480,000 pa Area enclosed by 57dB noise contour limited to 145km2 Car parking reduced to 42,000 spaces No M4 widening Twin Rivers to be agreed before T5 construction starts Details of these are given in the relevant sections. Planning policy including Green Belt The inspector noted that Although the scale of the Terminal 5 development is exceptional and it raises issues of national significance, the approach to the decision as to whether it should be granted planning permission must be the same as that for any other planning application. .. it should be determined in accordance with the statutory [local council] development plan unless material considerations indicate otherwise. [34.1.1] There was a good deal of debate about the east/west balance in economic development and general agreement that development was needed more in the east than the west. However, the inspector concluded .. there is nothing in the regional planning framework to suggest that development in the west should be refused simply because it would be contrary to the regional strategy. [4.2.13] The Terminal 5 site is within Green Belt and the inspector concluded it represents inappropriate development .., that is, it goes against the normal Green Belt policy. He continued .. it is necessary to demonstrate that there are very special circumstances justifying the grant of planning permission for Terminal 5. Those circumstances will exist only if the benefits of the new terminal would outweigh the harm it would cause not only to the Green Belt but also in all other respects. [34.1.1] As well as T5 itself, there are a number of major ancillary developments .. that are clearly inappropriate in the Green Belt .. the M25 Spur Road, the Colnbrook Logistics Centre and the Forward Lorry Park .. and the sludge treatment plant at Iver South. [34.2.6] He considered that these should go ahead because they are a part of the overall T5 scheme. The inspector considered that the effects on landscape would vary .. landscape of this part of the Park remains undistinguished. .. cause harm due to the loss of openness and would be visually intrusive. .. I firmly conclude that the harm to the Green Belt caused by the loss of Perry Oaks would be marginal. .. would diminish to a material degree the rural character of this part of the Park [Colne Valley Park] [34.4] On the M25 spur road he was clear there would be landscape impact .. would have a substantial impact on this part of the Green Belt. I accept that the improvements proposed by BAA and the landscaping measures put forward by the Highways Agency represent a reasonable package of compensation. Nevertheless, I do not believe that they would completely outweigh the harm caused by the Spur Road which would be contrary to the aims of the Colne Valley Park and the policies of the development plans. He was not too concerned about development pressures Although many of the local authorities around Heathrow were concerned that Terminal 5 would generate development pressures that would cause great difficulties these fears were not shared by Hillingdon, the authority most directly affected. [Although Heathrow is in Hillingdon, many of the development pressures have been elsewhere.] I have examined the evidence for these fears with great care but agree with Hillingdon that any pressure arising from Terminal 5 could be resisted. [34.4.1] Sustainable development and balance The inspector had some sympathy with the an interpretation of the 1985 White Paper .. policy places the primary emphasis on meeting the demand for air travel and only then seeking means of minimising the impact on the environment. [3.3.1] However, he noted .. there has now been a significant shift to an approach which gives more explicit emphasis to the need to take account of environmental impacts and balance these against economic benefits. [3.3.5] He concluded that .. the real issue .. is the relative importance to be placed on the environmental impacts. [3.3.8] It was argued by the Local Authorities (LAs) and Friends of the Earth (FOE) that sustainable development represented a radical change in thinking. This meant that the traditional idea of balance, which in practice could mean sacrificing the environment, was no longer acceptable. The inspector disagreed .. do not .. accept that the current approach imposes a new and additional test on proposed development. [3.3.38] .. The framework for this balance [between impacts and the economy] is to be found in the normal national and regional planning policy guidance supplemented by the statutory development plan. [3.3.39] The concept of environmental capacity or environmental carrying capacity was considered very briefly. The LAs and FOE argued that there should be agreed limits on impacts on the total environmental impacts of Heathrow and that operations should not be allowed to grow such that those limits were exceeded. The inspector seemed sympathetic I totally endorse the principle underlying Hillingdons plea for an environmental framework for Heathrow with agreed parameters which should not be broken, although the difficulties of achieving this should not be under-estimated. [3.3.36] But he rapidly ruled out the idea On the other hand, I find it almost impossible to believe that it is possible to define an environmental capacity for an urban area as complex as that with which I am dealing here. [3.3.35] Of RPG3 (Regional Planning Guidance document no. 3) the inspector noted .. whilst clearly indicating the need to strike a balance between economic and environmental considerations, [RPG3] in no way suggests that the fact that a proposal for airport development might cause environmental harm could, of itself, justify the refusal of planning permission. [4.3.15] Aviation policy The local plan was given short shrift .. the application for Terminal 5 raises matters of national concern which, in my opinion, are not and cannot be fully covered by the provisions of the development plan .. Insofar as there is conflict with the development plan, clearly national policy is a material consideration. As far as national aviation policies are concerned, the 1985 White Paper remains the most recent comprehensive statement. .. the wish to meet the demand for air travel where and when it arises remains at the centre of Government policy. [34.2.1] .. the UDP as the statutory development plans adds little if anything to the national aviation policies .. [5.2.16] The T5 site, Perry Oaks sludge works, is in Green Belt, but the inspector noted .. the 1985 White Paper recognises the benefits of releasing the Perry Oaks site for airport development .. [34.2.6] Demand and capacity The increasing demand for air travel is the root cause of the T5 application It was common ground among the major parties that the demand for air travel will continue to grow. The inspector added .. there is little evidence that this growth would be reduced significantly even if the cost of travelling by air were to be increased. [34.3.1] [This statement was made repeatedly and is unconvincing. The government considers that the volume of air travel is strongly affected by its price. It assumes that a price elasticity of close to 1; that is, an increase in the price of 10% would lead to a decrease in the volume of nearly 10%.] On the subject of forecasts, the inspector said I accept without reservation that all forecasts and particularly those concerned with the demand for air travel are subject to uncertainties .. the demand at Heathrow in 2016 would be 118 mppa [million passengers per annum]. [34.3.2] .. On the basis of all the evidence placed before me, I have assumed that the demand at Heathrow in 2016 is likely to be within the range of 118-143 mppa although it could well be higher. [34.3.7] There was much debate about whether other airports, could or should meet the demand that BAA wanted to meet with T5. The inspectors view was that regional airports would not affect matters .. I saw no evidence to suggest that their potential was sufficiently great as to make any substantial difference to the forecasts of demand at Heathrow. [ 7.3.21] The LAs put forward considerable evidence that Gatwick and/or Stansted could meet the demand in the southeast. The inspector was not impressed .. the lack of a second runway is a fundamental limit on both Gatwick and Stansted. While there is some evidence that Gatwick might be capable in the long term of serving as a second international hub a second runway is unlikely to be constructed in the short term. [34.5.5] On Stansted he added The position at Stansted is even less promising. The evidence shows that it is unlikely to develop as an international hub airport and the provision of a second runway would be very difficult to justify in economic terms even if it were environmentally acceptable. [34.5.5] He also said While there is evidence of rapid growth at Stansted in recent years with throughput reaching 6.8mppa in 1998. .. It remains to be seen whether this rate of growth can be sustained. [7.3.20] [Then BAA forecast 20mppa at 2016. They have now put in a planning application to take it to 25m in 2010 !] The inspector concluded I doubt whether the BAA forecasts for Gatwick and Stansted .. have so under-estimated the attractions of other airports as to inflate the demand at Heathrow. [7.3.22] The inspector did not believe BAAs forecasts for Heathrow .. I do not accept the assumptions put forward by BAA. They predicted a capacity of 50 mppa in the long term without Terminal 5 rising to 80 mppa with the new terminal. These estimates were disputed by many at the inquiry and as the inquiry drew to a close it was already clear that Heathrow was handling more than 60 mppa. [34.3.9] He added .. the construction of Terminal 5 would be likely to increase capacity to some 90 mppa. .. There is evidence that the actual capacity of the new terminal itself would be more than 30 mppa but other constraints would come into play. [34.3.10] He then considered the implications of BAAs under-estimate : I believe that the capacity of both terminals and stands could reach 95 mppa .. and that this could exert pressure to extract the greatest possible capacity from the 2 existing main runways, for example by the introduction of mixed mode operations or even to construct an additional runway. [34.3.10] This leads to perhaps the most interesting and important conclusion, other than the go-ahead itself: Since I consider that either of these responses could have unacceptable environmental consequences, I have suggested I have suggested a limitation on the number of aircraft movements. [of 480.000 flights pa]. On that basis I have worked on the assumption that the capacity of Heathrow with Terminal 5 would be 90 mppa but I do not rule out the possibility that it could exceed this level. [34.3.10]. Stephen Byers confirmed this recommendation in his statement to the House of Commons: "With regard to the limit of 480,000 flight movements, I was very aware of the concern expressed about Terminal 4. Planning conditions were not laid down with regard to the number of flights .. it was not part of the planning decision. We are making it a planning condition that there will be a limit of 480,000 flight movements a year. That means that it cannot be changed, even by my successor, unless a fresh planning application is made and new consideration given to the matter. [If this cap were adhered to, there would be no need for a 3rd runway or an end to runway alternation. But even more significant, T5 itself would not be viable, or at least not in the form proposed by BAA. It is inconceivable that BAA would invest over 2 billion in order to increase the number of flights from 460,000 to 480,000. It can only be concluded, therefore, that BAA and Byers are planning to break this limit within the next few years. The new study on the effects of noise (see section on noise) may provide a get-out clause. Alternatively, an application for a third runway, with the inevitable changes needed to the terminals, could be the fresh planning application.] There was a subtle but important comment in the decision letter [The Sec of State] notes the inspectors views expressed .. that the ATM limit would have benefits in terms of other factors such as surface access, air quality and public safety but the Secretary of State does not consider it necessary to express a conclusion on these matters. [This appears to confirm the conclusion above, namely that a get-out is planned. If the Sec of State were to recognise that issues other than noise disturbance were grounds for keeping to the 480,000 limit, this would make it harder to justify breaking it.] BAAs case was for a terminal to take 30mppa. BA, who were to be the sole users of T5, believed the capacity would be about 36m. Noting that T5 would be bigger than Terminals 1 to 4 put together and that they already carried over 50m, other parties considered that the capacity could go as high as 40 or even 50m. The inspector made a working assumption of 30m : .. I need to adopt specific figures as a basis for my subsequent assessment of the benefits and impacts of Terminal 5. I shall therefore focus my attention on a capacity of 60 mppa without Terminal 5 and 90 mppa with it. [8.2.59] He would not be drawn on the real or ultimate capacity, but gave no indication that he believed the limit for T5 was 30m or even close to it. Because of time between the end of the inquiry and the announcement of the decision, there was the opportunity for appreciable changes to have occurred in matters that were given in evidence at the inquiry. However, the decision letter (para 6) said that Since the inquiries closed .. over 150 written representations .. Nothing in these representations appears to the Secretary of State to constitute new evidence, or to raise a new issue, which needs to be referred to the parties before the Secretary of State proceeds to a decision. [This was a remarkable statement in view of the fact that BAAs forecast of flights was demonstrated to be totally wrong and that even the highest of the inspectors sensitivity tests looked a severe under-estimate. The number of flights is a crucial factor in determining impacts and the need for a third runway.] The size of T5 LAs, FOE and other objectors argued that the amount of retail space in T5 (greater than Staines town centre) was excessive. They considered that in view of the large adverse impact of T5, the space should be used for core air travel activity, not shopping. The inspector disagreed Government recognises that facilities at airports would include activities such as shopping and that it is for the operators to assess the need for such facilities. .. it is now normal practice [at airports] to offer a wide range of shops. .. passengers make extensive use of these shops if only as a means of passing time while waiting for their flights. .. no evidence to suggest that the provisions proposed for Terminal 5 are excessive in comparison with those at comparable modern airports. [11.4.52] Objectors also argued that the T5 retail (landside especially) would compete with local shops. The inspector disagreed .. the shopping impact study carried out by BAA was not disputed. .. there is no real basis for concern. [11.4.53]. However the Sec of State imposed a condition such that any increase above 7,300 m2 of landside retail floorspace would require a further planning application. [para 38 of decision letter] It was also argued by objectors that the hotel and office accommodation were not core uses and should not be included. The inspector disagreed. [11.4.59,60] Some objectors suggested that as T5 was being proposed as a means of handling only 30mppa, its size should be reduced accordingly. This would mean that not all of the Perry Oaks site would be needed. The inspector did not accept this idea, not because he disagreed that the whole site was necessarily needed for 30mppa, but because he felt that the demand to use the whole of the Perry Oaks site would be there and because government policy was to release the site for airport use. The national economy The economic benefits of Heathrow were considered crucial by the inspector Heathrow is the busiest airport in the world in terms of international passengers. .. it does give some indication of the importance of Heathrow as a factor in the economy of London and the UK. It is abundantly clear that neither Gatwick nor Stansted with their single runways can provide such a wide range of international services. [34.3.15] He cited the competition arguments .. the position of Heathrow is being challenged by a number of other European airports particularly Paris Charles de Gaulle, Amsterdam Schiphol and Frankfurt all of which have ambitious plans to expand their capacities and improve their services. [34.3.15] .. Of course the economic role of Heathrow is inextricably linked with its capacity. If this is restricted to 60 mppa, Heathrow will effectively stand still. Airlines based there will have no opportunity to increase the range or frequency of services. This would have a disproportionate impact on British airlines and could well affect the relative attractions of London and the UK as a location for international investment. [34.3.16] The inspector noted the implications for the UK airline industry .. national policy does take into account the effect of airport capacity on the national airline industry. .. I hold the firm view that a failure to provide Terminal 5 would damage the British airline industry. [34.3.18] The inspector was impressed at Heathrows contribution to the national economy Heathrow almost certainly makes a larger contribution than any other single site. It would be most unwise to place the competitive position of such a significant enterprise in doubt by refusing to permit fundamental investment, particularly when no viable alternative is available. .. I believe that Heathrow could play an increasingly significant role in the national economy. [34.3.20] [The inspector did not appear to recognise the point that contribution only means that aviation is part of the economy not that it makes the economy bigger. If a particular sector is constrained, consumer spending and resources are likely to diverted into other sectors, thus offsetting potential losses to the economy.] The inspector did refer to the aspect that was relied upon primarily by the proponents of T5 Heathrows contribution to GDP under-estimates its significance since it does not include any recognition of its role in improving productivity in other activities. [24.3.20] [This is of course true of virtually every supply industry such as water, electricity or road transport.] He was concerned about Londons position While I do not believe that it [Heathrow] is the dominant factor in Londons role as the leading European financial centre, I do consider that it is a factor of considerable importance. Any decline in its relative position as compared with airports such as Charles de Gaulle, Schiphol or Frankfurt could only harm the prospects for Londonas a financial centre. [34.3.21] The inspector also said Heathrow has also played a significant role in attracting international investment into the UK. Any decline in its competitive position could only damage the prospects for future investment. [34.3.22] [He failed to point out that most of Heathrows traffic and most of the forecast growth is for tourism, not business.] On the quantification of economic benefits, the inspector concluded I have real doubts as to the weight that should be attached to any of the specific figures presented [at the public inquiry] but have been able to reach some clear conclusions. On the basis of the CAAs [Civil Aviation Authority] work, which I broadly accept, Terminal 5 would produce substantial benefits for passengers amounting to some 10-11bn over a 30 year period. [34.3.23] [The inspector did not mention the point made by objectors that passenger benefits do not equate to societal benefits. The objectors argued, unopposed, that tax exemptions and the absence of polluter pays for aviation meant that the benefits for passengers may well be more than offset by costs for society.] On tourism the inspector said It [T5] would also make a positive contribution to the national economy by enabling and encouraging foreign tourists to visit this country. [34.3.23] [He failed to mention in reaching this conclusion the fact that tourism takes more money out of the country than it brings in.] On the cost to business the inspector concluded While I have some reservations about British Airways estimates of increased costs for business travellers if Terminal 5 were not provided, I accept that these costs would be higher and that this would have a disproportionate impact on businesses based in the UK. Again this could only harm the national economy. [34.3.24] In conclusion, the inspector said It would be difficult to envisage any other single project that would be likely to have such an impact on the national economy. .. In my view, the failure to provide Terminal 5 would almost certainly result in a substantial loss to the economy. [34.3.25] [He failed to mention the argument of objectors (uncontested) that the failure of the aviation industry to pay its true costs (external costs and the taxes paid by other sectors) means that the volume of air travel is higher than can be justified in economic terms. Thus constraining supply to some extent may well give a net economic benefic, not a cost.] The inspector summarisd the economic case as follows Although Terminal 5 is, in my view, essential to the maintenance of a strong and competitive airline industry in this country, its economic benefits do not end there. Heathrow contributes some 1% to the national economy and is by far the most significant element in a sector of the economy that it likely to grow relatively quickly. I believe that it has also played a significant part in attracting investment to the UK. Unless Heathrow is able to maintain its competitive position there must be a substantial risk that Londons success as a world city and financial centre would be threatened. By ensuring the continued success of Heathrow, Terminal 5 would make a major contribution to the national economy. [34.5.8] The local economy Relatively little was said by supporters about the significance of T5 for the local economy as opposed to the national economy at the public inquiry. [By contrast the public relations campaign by BAA and the supporters of T5 emphasised this constantly.] The LAs were very concerned about over-heating in an area were there were already development pressures and labour shortages. The inspector did not address the issue in great detail and his justification was based almost entirely on national economic benefit and, within this, Heathrows contribution to London as a whole. Employment At the public inquiry BAA had claimed relatively few jobs would be created by T5 6,200 including direct, indirect and induced jobs. [By contrast the public relations campaign by BAA and the supporters of T5 emphasised jobs constantly.] The LAs thought BAA had significantly under-estimated the jobs. The inspector was not convinced by any of the estimates. The LAs were concerned that any more jobs would exacerbate existing staff and skills shortages in the rest of the local economy and would prove detrimental to the area overall. The inspector did not agree I conclude that Terminal 5 would not cause material damage to the labour market in the surrounding area. In any event I firmly believe that any risk of damage would be more than outweighed by the benefit of the job opportunities Terminal 5 would provide. [10.3.51] [He did not address the point that creating jobs per se is not an objective, only reducing unemployment. These do not correspond in areas of low unemployment. He also did not address that issue that creating jobs in an area of low unemployment and housing shortage would cause new staff to travel longer distances, mainly by car.] Surface Access The traffic implications were recognised It is self-evident that Terminal 5 would generate a large increase in trips to and from Heathrow and that these could cause substantial problems on the surrounding road network. .. I have emphasised the relationship between public transport provision and road traffic. [34.4.16] [Over 46,000 extra trips per day and an estimated 326m extra km of driving pa.] The inspector appeared critical of BAA plans for public transport The 1998 White Paper on A New Deal for Transport puts more emphasis on improving rail access to airports and expects the aviation industry to contribute funding to such improvements .. BAA have gone some way towards this new approach .. their only specific target is that 40% of terminating air passengers should use public transport. Even this .. is not related to any particular date. BAAs primary case was just to extend the Heathrow-Paddington Express to T5. The inspector noted .. only 38% of terminating passengers would use public transport in 2016. .. The number of trips made by car and taxi would increase from 19.6 mppa in 1991 to 39.9 mppa in 2016. .. The proportion of employees at Heathrow using public transport would fall from 13% in 1992 to 10% in 2016. .. I do not consider these levels to be acceptable. [34.17,18] The inspector mentioned other public transport proposals including Gateway South Station, Gateway North Station and a St Pancras service. He noted BAA are pursuing many of these. .. If all of these measures were in place in 2016, BAA would just meet their target for 40% of passengers to use public transport. [34.4.19] He imposed a condition that the Piccadilly Line should be extended to T5. [This was already a virtual certainty as it had always been part of the plan and BAA and LUL were finalising the agreement during the in inquiry.] He imposed no other condition requiring additional public transport. BAA used a traffic model (called HRTM) which simulated traffic over an area of about 45 sq miles around Heathrow. The local authorities used a different model (LAHTM), which modelled over a much larger area. They argued that modelling was needed over a larger area as the effects of Heathrow were great and stretched a long way. The inspector preferred the BAA model. He did not consider it was necessary to take account of the wider area as the effects on any particular road became small further away from Heathrow. The LAs and FOE agreed that the effect fell away with distance, but said that due to the greatly increased area, the aggregate effect was greatly under-estimated by modelling over a small area. The Highways Agency (HA) confirmed this with their own modelling. FOE used BAA, HA and LAs results to calculate that T5 would lead to some 326 million km of extra driving every year and an economic cost of 60m pa due to congestion alone. LAs and FOE argued that the total effect, not just the effects in the area closest to Heathrow, was a material consideration, but this was ignored by the inspector The inspector recognised the related issues of extra traffic, congestion and road capacity National policies no longer seek to increase road capacity to meet the full demand for car travel even though this means that levels of congestion will increase at least in the interim period before their policies to reduce that demand take full effect. [34.4.16] He accepted that T5 would increase congestion It is plain that many of the roads around Heathrow are already congested. .. the proposed highway schemes would claw back only 50% of the congestion effects of Terminal 5. This means that the trunk road network would be worse off with Terminal 5 than it would be in the four terminal case. .. the schemes required to get back to congestion levels in the four terminal case would be in conflict with the Governments policies relating to commuting into central London. The key issue was the amount of extra congestion and what was acceptable Even BAA accepted that their assessment showed that Terminal 5 would cause congestion to become worse, although they argued that the effect would be small. It would increase flows on the M25 by 7-10% but I am satisfied that Terminal 5 and the Spur Road would not cause major new problems on the motorway. .. I found no evidence that the increases in congestion would be unacceptable. BAA had proposed a cap on parking spaces (on-site), this being 46,000, the number that BAA actually wanted in 2016. The inspector was not satisfied I do not consider that this goes far enough in the light of current national policies to reduce the growth in demand for car travel. .. While I do not believe that the draconian controls proposed by the local authorities would be reasonable or even feasible, I do consider that the number of parking spaces for employees should be reduced as compared with present levels. He recommended a cap of 42,000 car parking spaces (ie a reduction of 4,000 from BAAs figure) with a specific restriction of 17,500 on staff parking. [34.4.22,23] The inspector concluded On the basis of BAAs primary case with a throughput of only 80 mppa and assuming the implementation of the proposed road schemes, I conclude that traffic objections would not justify refusing planning permission for Terminal 5. However, he noted that this conclusion was based on BAAs assumptions about passenger throughputs which he was clear were too low. Since the actual throughput is likely to rise to 90 mppa or even more .. the volumes of traffic could also increase. A sensitivity test .. forecast a 19% increase in total delays. While a higher throughput of 90 mppa or more would increase congestion, the effects of this would be offset by the improved public transport provision I have proposed and the imposition of a limit of 17,500 on parking for staff at the airport. [34.4.29] A contentious road was the proposed spur from the M25 to T5 It was accepted [not by all parties] that there needed to be a high quality link from the M25 to Terminal 5 although the form this should take was not agreed. M25 widening was also contentious. The inspector said The M25 between Junctions 12 and 15 is to be widened regardless of Terminal 5 to accommodate projected traffic growth at least until 2010. [34.4.25]. [This is not necessarily true. The Labour Party had rejected widening of the M25 when in opposition and when they came power, they put it on the list of roads to be reviewed. Before they had carried out the review, they announced that the M25 would be widened anyway. This was at exactly the time when the public inquiry would have been thrown into disarray without it being confirmed that the M25 would widened. There is no evidence that widening would have been announced but for T5. Indeed, the DoT said M25 widening would pave the way for T5.] BAA had also proposed widening of the M4 between junctions 3 and 4B and a number of other works. The inspector noted that most of forecast growth on the M4 was not related to T5 I am satisfied that the predicted traffic flows would justify the widening of the M4 and the improvements to Junctions 3 and 4 on the basis of the former predict and provide approach. However, the Government has now said this approach does not work and is seeking to reduce the demand for car travel. [34.4.30] He therefore recommended that the M4 should not be widened. Noise The inspector was very critical of government noise policy .. difficulty I experienced in establishing current Government policy towards aircraft noise .. after the phasing out of Chapter 2 aircraft in 2002 .. the policy objective appears to have been lowered without any added security for local residents .. This approach also seems to be at odds with the increasing awareness of the principle of sustainable development. [34.4.38,39]. He was impressed by the evidence given by residents on the effects of noise .. in many locations noise levels are already unacceptable to many residents, although others do not find them to be so. .. satisfactory conditions might not be achieved at some sites even with sound insulation. .. no form of insulation can enable people to enjoy their own gardens or public open spaces exposed to the levels of noise which is all too common around Heathrow. .. parks and public spaces including Kew Gardens, Bushy Park and Richmond Park .. aircraft noise does detract from the quiet enjoyment of these attractive and historic areas. [21.3.46] The inspector had serious misgivings about the use of Leq (Loudness Equivalent) as the measure of the noise climate .. severe criticism much of which I consider to be well-founded. It does not reflect the operation of runway alternation which is a key feature of Heathrow .. nor does it give any indication of the number of times activities are interrupted by passing aircraft. .. More significantly I believe that it fails to give adequate weight to the number of aircraft movement. .. Even the Department recognised the deficiencies of the LAeq system. [34.4.42,43] Leq is used to define contours enclosing populations affected by noise and the inspector said, despite his misgivings about Leq, Nevertheless the starting point must be the area covered by the 57 dB(A) LAeq 16hour contour which encloses the area within which annoyance is most likely to occur.. [34.4.44] He noted that on BAAs assumptions (80m ppa, 453k patm pa and no Concorde) the area enclosed by the 57dB contour would fall from 175 km2 in 1994 to 95 km2 in 2016 if T5 were not built and to 128 km2 if it were. But if Concorde remained, the area with T5 would increase to 182 km2. He noted .. any improvement in the noise climate by 2016 would be entirely due to the removal of Concorde from the fleet [34.4.44] BAA offered a cap of 175km2, ie the 1994, levels but the inspector said .. while the governments objective of achieving an improvement in the noise climate as measured solely by the 57 dB(A) contour would be met even if Terminal 5 were built, this would be entirely due to the removal of Concorde from the fleet. Furthermore the noise climate with Terminal 5 would be significantly worse than it would be with only 4 terminals. This must be a substantial objection to Terminal 5. [34.4.46]. He proposed a cap of 145km2 at 2016. This was confirmed by Byers. However the cap can excludes Concorde [Condition A5/2]. [The inspector did not mention that the 1994 baseline is now very out of date. The area within the 57dB contour in 2000 was 135.6km2 and this included some Concorde flights. It appears, therefore, that the contour could be larger in 2016 if Concorde is flying. Also, the noise contour could grow from now, because the condition only applies to 2016 and not to any intermediate dates.] The LAs noted that noise levels and the 57dB contour used BAA and the government would be above World Heath Organisation (WHO) limits. [The WHO, to which the UK was a signatory, does not consider an Leq of 57dB to be the level of onset of annoyance. It considers that 55dB should be the maximum exposure and 50dB the target.] The inspector rather dismissed this, saying .. the Government has acknowledged the WHO guidelines of 55dB as the level above which significant annoyance might be expected during the day. .. However, the Department believed that the 55dB figure should be increased by 2dB to take account of the way aircraft noise is measured. On this basis, it would coincide with the 57dB used by Department. [21.3.39]. [An EU Directive requires noise maps to be prepared to show areas exposed to levels greater than 50dB (these have weighting to reflect the greater impact of evening and night noise). These figures are for all noise, ie aircraft plus other sources. This was not mentioned.] Because he considered that the Leq and the 57dB contour did not characterise the (daytime) noise climate sufficiently, the inspector recommend the limit of 480,000 flights pa. He said .. unless the controls I have proposed are imposed the impact of Terminal 5 would soon exceed that on which I have based my judgement. It would rapidly become wholly unacceptable whatever benefits it might bring". The inspector was clearly impressed by the evidence on night flights My conclusion .. is that noise from aircraft landing in the early hours causes substantial disturbance over a wide area and this leads to significant annoyance. For many people it causes genuine disturbance and very serious annoyance, albeit others sleep undisturbed. [34.4.48] He was as critical about night flights policy as he was about daytime .. The policy .. appears to include an acceptance that the noise climate might deteriorate at night albeit in the context of the overall commitment to seek an improvement in the noise climate. .. I find it difficult to believe that any increase in noise at night could be outweighed by improvements during the day. I also find it difficult to see how the policy on noise at night can be applied fairly and openly in the absence of any definition of what constitutes excessive noise or even how this is to be assessed. [34.4.40] He interpreted government policy as saying that economic issues could over-ride night noise My interpretation of the policy .. is .. that it would be permissible for noise at night to become excessive if the harm caused by this were outweighed by benefits to the competitive position of Heathrow and the airlines and the wider implications for employment and the economy. .. If my interpretation is not correct, the Government should consider whether at some point it should clarify its policy. [34.4.44] Byers did not clarify the policy and did not accept the word excessive. The inspector was very critical of the earlier night noise study .. sleep was interrupted regularly and that it was very difficult to get back to sleep. .. It is clear that the [1992] Sleep Disturbance Study on which the Department and BAA relied did not address these issues. Not did it attempt to measure annoyance. It also failed to exclude from the survey those who had connections with the airport. [34.4.47] Byers accepted the criticisms only to a limited extent. The Government is carrying out a new noise study (as announced in Spring 2001). Byers said in his decision letter: "It is envisaged that the results of this study will help to show whether the Leq index does in fact have the weaknesses suggested by the Inspector. The results would also inform any future consideration of the ATM [number of flights] condition. There was debate at the inquiry as to whether T5 would lead to more or less night flights. The inspector concluded that it was unlikely to cause much difference, but said .. it seems inevitable that Terminal 5 would result in a significant increase in arrivals soon after 06.00 hours and that this would cause a deterioration in the noise climate just before 06.00 hours. This must count significantly against its approval. [34.4.51] The Inspector took the view that night flights should, over time, be phased out. But he said I do not believe that a ban on night movements is realistic, at least in the short term but have proposed that the night quota period should be extended to cover the whole period from 23.00 hours to 07.00 hours. [34.4.55] Byers said "I recognise that there is considerable concern about night noise .. I shall consult on extending the night quota period when I next make proposals for the night noise regime .. I have decided that the consultation will take place by 2003 at the latest." On the night flight court case, Byers told the Commons: I am still giving detailed consideration to the European Court decision on the Hatton case. We have three months before a decision has to be taken, and I want to use that time to give a proper consideration to the details in that judgement. The inspector also considered a wide range of measures to reduce the impact of noise and concluded I believe that the continuation of westerly preference is not in the best interest of the population around Heathrow and that, indeed, there is much to be said for the introduction of an easterly preference at night .. the time might have come for a fundamental re-assessment of the Cranford Agreement [this agreement prevents take-offs eastwards from the northern runway] [34.4.53] In his overall conclusions the inspector said .. I am satisfied that Terminal 5 would significantly reduce the improvement in the overall noise climate which would otherwise occur. .. aircraft noise associated with Heathrow already causes substantial harm. .. residents near Heathrow experience more severe noise problems than those living near any other airport in the UK or Europe. [21.6.1] .. Terminal 5 would result in a material deterioration in the noise climate around Heathrow as compared with the position with only 4 terminals and that this must carry substantial weight in the final decision. [21.6.8] The inspector noted that ground noise and road noise were also issues, but concluded that while they must weigh in the balance [34.4.57], they were not as significant as air noise. Air quality A separate briefing has been produced on the subject of air quality (ie air pollution). This is available on request (Briefing Note 20). The key points are : The main concern is with NO2 and PM10. Ozone was not addressed in any detail. The effect of T5 would be relatively small compared with the total of other sources. There will be breaches in the National Air Quality Strategy (NAQS) objectives for NO2 and PM10 up to 2016 and beyond. Although pollution with T5 will be higher than without, pollution levels are generally expected to fall between now and 2016. The objectives do not have to be met if it would not be cost effective to do so. Pollution is not an issue as long as levels are below objectives. The pollution caused by T5 .. must count against it, but cannot be mean that planning permission must be refused. T5 would make it harder for LAs to meet the objectives of NAQS but would not affect LAs ability to carry out their duties. There would be a health impact but it is not likely to be substantial. Economic cost of pollution was ignored. T5 could make objectives of NAQS ..virtually impossible to achieve .. but this does not mean that planning permission must be refused. Greenhouse gases A few parties, notably Dr Meyer Hillman, argued that global climate change was a major T5 issue. This is because the emissions of greenhouse gases from the extra aircraft would happen at a time when we need to reduce emissions. The subject had been raised during the inquiry in respect of national aviation policies. However, the inspector said .. the wish to meet the demand for air travel where and when it arises is still at the centre of Government policy. .. there had been no change in the Governments view that global warming is of very limited relevance to decisions on the capacity of UK airports. [25.4.47] Dr Hillman argued that much had changed since 1985 and that the statement by Mr Mawhinny to the effect that there had been no change in the governments view was out of date following the Kyoto protocol. [6/10.1.7-9] The inspector said I do not doubt the significance of the growing international concern over climate change but the Government has made its position clear. .. it believes that action on emissions arising from air travel must be taken at an international level. .. the planning application for Terminal 5 inquiry is not the vehicle by which international aviation policies could or should be decided. .. restricting the capacity of Heathrow would not necessarily reduce the overall demand. [25.4.8,9] A separate briefing has been produced on the subject of greenhouse gases. This is available on request. Public Safety The topic of Public Safety, sometimes referred to as third party safety, is the risk to people on the ground who are not involved with flying, either as passengers or as workers. Great emphasis was placed by the government on the high standards of safety in air travel in general and in this country in particular. The inspector endorsed the comments about safety of the industry. The government implied that public safety should not be a matter to be determined to any great extent via the decisions on airports or the planning system. Indeed, their witness argued that there were no grounds based on public safety for refusal of T5. This was because the Public Safety Zone policy could cater for the risks. The inspector disagreed This is not a view that I accept. [6.2.39] He considered that public safety was an important issue for T5. Public Safety Zones (PSZs) are drawn around major airports and show the risk to any individual (who is present all the time) of being killed by an aircraft. This is based on a computer modelling exercise. Contour lines are drawn to show the geographical area where the risk of being killed in any one year is greater than 10,000 and where it is greater than 1 in 100,000. These risks may be written as 10-4 and 10-5. Contour lines are also calculated for 10-6, although the area beyond 10-5 is not included in PSZs. There was a good deal of debate about whether the modelling used by BAA gave valid answers. The main issues were the assumed incidence of crashes and the toll if a plane did crash. The inspector said .. the model used .. to assess the risk to public safety is appropriate and produces acceptable results. [26.2.44] An area in and close to the airport is within the 10-4 contour. All parties accepted .. that an individual risk of 10 -4 is intolerable [for third parties]. Properties within this contour are in fact bought out by BAA. There was less agreement on the significance of the 10-5 contour. It was accepted by BAA that risks greater than 10-5 are important but BAA said .. the increased risk due to Terminal 5 was small. It should be considered as part of the overall planning balance. It certainly could not justify its refusal. [26.2.5] Government policy was that New development should be inhibited in the public safety zones .. [26.2.12]. Other parties considered that a risk as high as 10-6 was a major issue .. they [studies] showed that an individual risk of 10 -6 was unacceptable to 40% of the affected population. [26.2.25] The inspector did not make a clear statement about the minimum level of individual risk that he considered important, but said I find no reason to justify adopting a limit below the normally accepted 10 -6 . This is not to say that the risk beyond that contour could or should be ignored. The building of Terminal 5 would increase the individual risk in this wider area but its significance would be less. [26.2.47] BAA produced estimates of increased areas and populations enclosed by the contours due to T5: 10-4 or greater area 41 ha ; population 0 10-4 to 10-5 53 ha ; 1863 10-5 to 10-6 484 ha ; 13157 These were however based on BAA figures of 80mppa and 453,000atm. The inspectors sensitivity tests gave increase in the area of up to 6.6% and population of up 6.3%. [7/2.1.10] The increase in risk for an individual was noted A person exposed to a risk of 10 -5 or 1 in 100,000 in the absence of Terminal 5 would experience an increase of some 30% to a risk of 1 in 77,000. [26.2.48] There was an extensive debate on what was called societal risk. This looks at the total to risk to all people even though the risk to any one person may be very small, eg outside the PSZ or the contour lines. Although BAA did not consider it to be relevant, the inspector appeared to. No data on societal risk was presented to the inquiry, but the inspector commented .. it must be reasonable to assume in the absence of specific evidence that the societal risk associated with Terminal 5 would rise in line with the increase in individual risk. [26.2.50] The inspector noted that risks could be reduced if an easterly preference was introduced and he considered this .. a factor of some importance. [34.4.63] The inspector accepted that if expansion were concentrated at other airports, eg Gatwick or Stansted, the risk would be less. However, he appeared not to regard it as an issue in determining the acceptability of T5. In conclusion, the inspector said Terminal 5 would result in increases in individual and societal risk. Although the increased risk as a result of Terminal 5 would be marginal, they would clearly represent a material objection to Terminal which would have to be weighed in the balance with all of its other costs and benefits. [26.2.55]. [It is somewhat difficult to understand his assessment as marginal given that he accepted that the increased risk appears to be about 30%.] As well as the calculated risks, it was noted that fear of a crash could be a relevant factor. There was also an issue raised about parts of planes or ice from planes falling and an issue about vortices. The inspector noted these concerns but did not regard them as being significant. An expanded version of this section on public safety is available in a separate 4 page briefing. Biodiversity A separate briefing has been produced on the subject of biodiversity. This is available on request (Briefing Note 21). The key points are : Loss of Perry Oaks would be damaging but it was not worthy of SSSI status. It should be assumed for the purpose of assessing impacts that if T5 does not go ahead, the ecological value of Perry Oaks would be retained. Donation of 300,000 to the Wildfowl and Wetland Trust (who did not object to T5) for works on their Barn Elms site is good compensation for the loss of Perry Oaks. Special Protection Area for birds specially drawn to avoid Perry Oaks and Iver South, the latter being the area to where the sludge de-watering works will be moved. M25 spur road would cause significant ecological damage. Translocation of water avens and other plants may well be unsuccessful. Illegal destruction of hedges ignored. Re-location of sludge de-watering would cause significant ecological harm at Iver South. Basic principles of ecology such as carrying capacity and fragmentation ignored. No mention in decision letter of water voles at Perry Oaks. New evidence on water avens ignored Twin Rivers There are two rivers, the Duke of Northumberland and Longford Rivers, crossing the Perry Oaks site. These became named Twin Rivers. The original proposal by BAA was to culvert them under T5. The Environment Agency (EA) objected strongly to the culverting proposal. They undertook a lot of work and after extensive discussions with BAA, an alternative was proposed. This involved combining the two rivers and diverting them into a single channel around the western edge of the T5 site. All objectors agreed that the new scheme was a great improvement and the inspector concurred. He agreed the diversion scheme (but see below) and he proposed a condition that work on T5 should not commence until the Twin Rivers Scheme has planning permission. [It was estimated that the cost to the EA of objecting to Twin Rivers and having to work with BAA to develop a replacement scheme was about 300,000. As the EAs work was due to the inadequate nature of BAAs proposal, FoE considered that BAA should pay the costs. The EA were considering asking for costs, but the issue is not mentioned in the decision letter.] In spring 2001, BAA suddenly advised the government that the Twin Rivers proposals had been discovered to be unworkable and that in conjunction with the Environment Agency (EA), a revised scheme was being developed. This delayed announcement of the T5 decision. The scheme is now to divert the two rivers separately. This went out to a two-stage consultation and the final details are now being worked on. Calls from some of the objectors to re-open the inquiry were ignored (not just rejected) by the Secretary of State, Stephen Byers. All parties agreed that the new twin-channel diversion was ecologically equivalent or better than the previous single channel one, at least in terms of the aquatic habitat. The decision letter included a condition that work on T5 should not commence until the detail of Twin Rivers has been agreed. Futhermore, the Twin Rivers scheme should be the subject of a separate planning application. Runway 3 One of the strongest arguments of the objectors was that T5 would lead to a third runway. The inspector accepted .. broad consensus that the limit on the capacity of the runways at Heathrow in 2016 is most likely to be about 475,000 patms [passenger air traffic movements, ie passenger flights] or 480,000 atms in segregated mode which he believed would correspond to about 90mppa. The inspector agreed there would be pressure for a third runway I believe that the capacity of both terminals and stands could reach 95 mppa and that this could exert pressure to extract the greatest possible capacity from the 2 existing main runways, for example by the introduction of mixed mode operations or even to construct an additional runway. [34.3.10] He thought the only effective way to prevent the pressure was a legal agreement (similar to Gatwick) to prevent another runway. [8.5.20-21, 34.5.7] However, this was outside his remit and he seemed to consider that an agreement was unlikely as it would constrain the emerging aviation policy. The implication for T5 was clear .. in the absence of a water-tight guarantee the increased possibility of an additional runway should be taken into account as a factor weighing against the approval of Terminal 5. [8.5.22] The inspector was unequivocal about the impact : Since I consider that either of these responses [introduction of mixed mode or a new runway] could have unacceptable environmental consequences, I have suggested a limitation on the number of aircraft movements [of 480,000patm]. This makes it plain that he was opposed to a third runway. However, Byers refused to rule out a third runway. He told the Commons: ".. the third runway will be considered in the context of both the South-East of England study and the Aviation White Paper, which we shall publish next year." Construction The inspector recognised that there would be considerable impacts as a result of construction The construction work required to complete Terminal 5 would be an enormous project with widespread impacts. It would generate substantial traffic which would cause increased delays at a few junctions. .. the impact of construction noise would add materially to the case against Terminal 5 .. Increases in PM10 and NO2 would result in a small but not negligible increase in the risk to human health .. they would still add materially to the case against Terminal 5 .. [3.4.66-69] He also considered that the Colnbrook Logistic Centre and Foreward Lorry Park [needed for construction] were inappropriate development in Green Belt. [34.71,72] The construction of T5 would produce large amounts of spoil and BAA proposed to deposit this nearby and to landscape the area. The inspector said As I believe that BAAs proposals for the deposition of spoil would be appropriate development in the Green Belt and would enhance the landscape of the Colne Valley I do not consider they would cause harm that should count against Terminal 5. Conditions A large number of conditions were recommended and nearly all were accepted by Byers. Most are very minor in terms of effect they would have on the impacts. A large number of conditions relate to construction; relatively few would have any effect on the ongoing impact of T5 and the resulting increase in operations. The most important conditions have been described in the foregoing sections. The importance attached by the inspector to the conditions appears to be very large .. even if planning permission were granted for Terminal 5, it would not be acceptable without a package of conditions and other controls designed to limit its overall impact on the environment. .. any substantial reduction in the package I shall be identifying would render Terminal 5 unacceptable in spite of the economic benefits it would bring. [32.1.18] Briefing Note 22 (Dec 01)  PAGE 17  PAGE 20 .@Awwhxhxhxhxhxhxhxhxhxooo.@AQQQhxhxhxhxhxhxhxhxhxooo 7<=JW  -  > o &/Pb]byaap} \q~w|}~#$%gM;!>0>>>>? ?K?L?M?J@@0AAAVUa UVa UVa a UV^ABBBCCCCCC,DAEGH9JTKLLLMO9PPQQSTaTUUXXYYYZ[[[5]]{^__``acccidddeeffffghiiilllllnnnnn6qBrsssstsuwkwx`yzz4{9{UVa a hVccUa Va a VU\1Rӄl߆3t ŠۋpNȐʐːҐӒ JΗ FG "#?@m"./qw ʢ`DVQ]tUVVUchUcchUUVa Ua Va Vcca Wߩ>گ"y(acʶ)˷ƸǸθиn%3} fxgIJ &'gh Va ha hcchchUcVa VUa UVcVccV)+8vx:[]_(JL 5xhivwW)P0Ua Ua cVa cUVcVchVcchcVa ha hVa a T@tv}~!YMWbDcucauDa ccUVa UVa hVa a ) :;<=JKL N V W   - ? J Z ` n $  4hx &)')()))/ #   > ? \]) p@ P !) p@ P !) p@ P !$  4hx=Lp}~$%zzzzzzzzzzzzzzzz) p@ P !6 i3 4& p@ P !6 i 4) p@ P !;!!e!f!##&&P)Q)*****}-~-F.G.H.I.^._.0022-4.455;8=88) p@ P !) p@ P !%88;;<<>>4A5ACCOFPF8I9ILLLLLOOvQwQRRSSSTTU) p@ P !) p@ P !) p@ P ! UUXXYY\\P^Q^__KaLaIdJdeeffiilllllnnnnngphpssss) p@ P !) p@ P !%sss:u;uwwxxzz8{9{C}D} ԄՄ;ŠÊɐʐːҐ) p@ P !) p@ P !%ҐӐLM"# VWx) p@ P !) p@ P !) p@ P !) p@ P !xyR_cd)*˷) p@ P !) p@ P !) p@ P !) p@ P !˷pfo4\ yzJK}) p@ P !) p@ P !6 3 4hx& p@ P !'(hiIJ^_C|}ab<3) p@ P !& p@ P !) p@ P !) p@ P !`/VAhijvwkl) p@ P !6 3 4hx& p@ P !) p@ P !lUVWbc) p@ P !) p@ P !%1) 1q AQ!!%P !) p@ P !) p@ P !=K@Normala @ Heading 1U4@4 Heading 2&)')()))/ Uc$"@" Heading 3Uc"@" Heading 4Uc"A@"Default Paragraph FontO Hyperlink^b"O" Default Texta cB@ Body Textc"O"" Body Text 2Vc"O2" Body Text 3Uc"OA"FollowedHyperlink^b $OR$Level 1 `3a $Ob$Level 2 `3a $Or$Level 3 `3a $O$Level 4 `3a $O$Level 5 `3a $O$Level 6 `3a $O$Level 7 `3a $O$Level 8 `3a &O&Level 9 `3Ua O_263a HOH_25103# p@ P !a DOD_24. p03 p@ P !a BOB_23+!@ 03 @ P !a >O">_22("03P !a <O2<_21%#03P !a 8OB8_20"$03P !a 6OR6_19%03P !a 2Ob2_18&P03P !a Or_17'3a HOH_161(03# p@ P !a DOD_15.)p03 p@ P !a BOB_14+*@ 03 @ P !a >O>_13(+03P !a <O<_12%,03P !a 8O8_11"-03P !a 6O6_10.03P !a 0O0_9/P03P !a O_803a FOF_71103# p@ P !a BO"B_6.2p03 p@ P !a @O2@_5+3@ 03 @ P !a <OB<_4(403P !a :OR:_3%503P !a 6Ob6_2"603P !a 4Or4_1703P !a 0O0_8P03P !a O Default ParaO FollowedHype^bO SYS_HYPERTEXT^b&O& Body Text 2<3Va c ##A{|}~ 8UsҐx˷l #!!@eTimes New Roman Symbol "Arial1Courier NewWingdings"Arial Black"hl qf\f"e{?C:\WINDOWS\Application Data\Microsoft\Templates\WLFoE Brief.dotPRESS RELEASE Mr N Ferriday Mr N Ferriday  !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXYZ[\]^_`abcdefghijklmnopqrstuvwxyz{|}~Root Entry F7RWordDocument+CompObjjSummaryInformation(  FMicrosoft Word Document MSWordDocWord.Document.69q Oh+'0 , T ` l xPRESS RELEASEMr N Ferriday#C WLFoE BriefMr N Ferriday5Microsoft Word for Windows 9DocumentSummaryInformation8   FMicrosoft Word Document MSWordDocWord.Document.89qWL Friends of the Earthe PRESS RELEASE54@V@2@[L@fi6" ՜.+,0@Hhp x WL Friends of the Earthe PRESS RELEASE