Dear Sir

Mayor?s Transport Strategy

response from Friends of the North Kent Marshes

The Mayor?s transport vision

Friends of the North Kent Marshes support the goal of the Mayor?s to reduce transport?s contribution to climate change and improve its resilience. However, we are extremely concerned that this goal is incompatible with parts of the Mayors Transport strategy, particularly regarding airport capacity.

5.8 ? River Crossings

Friends of the North Kent Marshes note the support in Proposal 39 (f) for government proposals to reduce congestion at the Dartford Crossing. However, depending on the solution chosen to this problem, there could be adverse effects on internationally important bird sites. For example, it would be difficult to site a crossing downstream of Gravesend without substantial direct land take from the Thames Estuary and Marshes Special Protection Area (SPA).

5.11 ? London?s Airports

Climate change is the greatest threat facing our planet. Without immediate action to reduce greenhouse gas emissions there will be devastating consequences for man and biodiversity, and we risk the extinction of thousands of species. Emissions from aircraft remain one of the fastest increasing sources of greenhouse gases and the demand for flights should be managed rather than just accepted as necessary. Friends of the North Kent Marshes remain opposed to the expansion of air travel until Government can demonstrate how this can be achieved whilst still meeting UK targets for emissions reductions across the whole economy.

The Climate Change Act 2008 requires UK reductions in greenhouse gas emissions, against a 1990 baseline, of at least 34% by 2020 and 80% by 2050. The Climate Change Committee has advised Government that aviation emissions should be taken into account in the UK's strategy for meeting its long-term climate change goal. It is clear from the Committee?s and others' analyses that it will be almost impossible to achieve this goal if aviation emissions are not constrained.

Therefore, Friends of the North Kent Marshes are extremely concerned about the statement in paragraph 438 that the Mayor is interested in looking at whether optimum use is being made of London?s existing airport capacity, and the potential benefits of additional capacity elsewhere in the South East. This ?predict and provide? approach is incompatible with the proposals for reducing CO2 emissions in the Mayor?s Transport Strategy and draft replacement London Plan, and may make those proposals unachievable. Friends of the North Kent Marshes note the considerable investment proposed in improved rail and other public transport links, and note the recognition in paragraph 440 that there is potential to increase transfer from short-haul domestic and European flights to rail journeys through existing and possible future high-speed rail services. However, the reason for increasing rail capacity in the Mayor?s Transport Strategy is to free up air capacity, so this will not reduce emissions.

5.20.5 ? Reducing CO2 emissions from aviation

Paragraph 632 states that ?strict limits on aviation growth are untenable?, but recognises that meeting both the Government target for aviation CO2 emissions and the Mayor?s target for London CO2 emissions will require either a breakthrough in aviation efficiency or significantly lower than forecast growth. Proposal 100 is, therefore, for further research into improved aviation carbon efficiency. However, the Climate Change Committee states quite clearly that demand management, rather than a reliance on future technological development, is the only credible means of ensuring that aviation emissions do not rise to unsustainable levels for the climate. Friends of the North Kent Marshes view is, therefore, that the Mayor?s Transport Strategy?s failure to adopt significant demand management measures and to reduce emissions of greenhouse gases from the aviation sector threatens to undermine its whole approach to mitigating climate change.

Additional comment

Friends of the North Kent Marshes note that an airport in the Thames Estuary does not form part of the Mayor?s Transport Strategy and that this strategy cannot advocate an estuary airport because that is outside its jurisdiction. However, due to the media interest on this subject generated by the London Mayor himself we will take this opportunity to register our absolute opposition to it. Friends of the North Kent Marshes are wholly opposed to the construction of an airport anywhere in the Thames Estuary because of the immense damage it would cause to the area?s internationally important wildlife and the wider environment. The whole issue was exhaustively investigated between 2002 and 2005 in the Government?s Aviation White Paper. All the key players, including the aviation industry, contributed. An airport in the Thames Estuary was conclusively ruled out and this decision upheld by the High Court. In addition to the unprecedented environmental damage and the resulting massive legal implications, the investigation found that an estuary airport did not make sense economically, would not meet the requirements of the aviation industry and presented a significantly higher risk of ?birdstrike? than at any other major airport in the UK.

This is our submission and we thank you for the opportunity to respond to this consultation.

Yours faithfully

George Crozer, Joan Darwell, Gill Moore.

For and on behalf of Friends of the North Kent Marshes