Now that Aggregate Industries' "wetland and open water habitats" mitigation plans are on the table - with their inherent risk of attracting birds and conflicting with the safeguarding of Exeter Airport - here's a timely reminder of why such 'watery' proposals are unacceptable. Below are 10 quotes on the subject of birdstrike that we have previously posted over the last year or so:
1. Under the Air Navigation Law, it is a criminal offence to endanger an aircraft or its occupants by any means. Exeter Airport
2. To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development. Exeter Airport
3. Almost without exception, water developments increase the bird hazard in ways that cannot be adequately controlled. CAA
4. It must be recognised that it is not possible for an aerodrome or aircraft operator to mitigate the hazard caused by water bodies and watercourses, or to prevent birds using areas of open water in the vicinity of the aerodrome. CAA
5. The exact position of a site within the safeguarding zone is another important factor. If an extraction operation is located directly under the take-off and landing approaches, then this is going to be far more critical than a location 12km out on the runway flanks. Surrey County Council
6. With the move away from infilling sites, those within safeguarding zones worked below the water table and with wet restorations will provide a particular challenge. SCC
7. Wetland creation is one of the most problematic development types in terms of birdstrike prevention at aerodromes. Wherever possible developers should seek to keep proposals as far from aerodromes as possible and outside the 13km safeguarded zone of major civil and all military aerodromes. Birdstrike Avoidance Team
8. Bird management plans should thus be regarded as an additional measure to give aerodrome managers confidence that no additional risk will result after location and design modification measures have already been used to minimise any additional risk from a wetland development. They are not a means by which otherwise unacceptably hazardous developments can be transformed into acceptable ones. BAT
9. Whatever the actual increase in risk, the key test that an aerodrome manager applies is one that asks the question ‘if there was an accident involving loss of life at my aerodrome could I defend allowing this development to proceed without objection when I believed that it would cause an increase in the birdstrike risk, however small?’ A planning inspector is likely to ask him/herself the same question. BAT
10. The aviation industry, be it the airport itself, the MOD or CAA, has never lost a public enquiry regarding an objection if an unacceptable birdstrike risk has been predicted from a development. BAT
And finally, a reminder of what a planning inspector said, in connection with a farmer appealing for permission to keep a 40x25m pond:
...because of [the pond's] critical location so close to the main flight path of the aerodrome at a point where aircraft are on their final approach to the runway, aircraft safety must be paramount. I consider that this development feature which has the potential to attract birds in increasing numbers at this location poses a serous risk to aircraft safety. I find this unacceptable. I conclude that the undoubted ecological benefits of the development cannot outweigh the safety needs of the aerodrome.
It all seems clear to us, but is it causing any head-scratching at AI yet? One might imagine a scene at AI HQ: "To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate... ah, for goodness sake, how difficult can this be?" Or perhaps we underestimate, perhaps AI has a cunning plan...
