EAST OF ENGLAND REGIONAL OFFICE
WESTLEY BOTTOM · BURY ST EDMUNDS · SUFFOLK IP33 3WD
Telephone +44 (0)1284 747500 ∙ Facsimile +44 (0)1284 747506 ∙
Website www.nationaltrust.org.uk
The Rt Hon Hazel Blears MP
Secretary of State for Communities and
Local Government
Eland House
Bressenden Place
LONDON
SW1E 5DU
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Date
Keith.turner@nationaltrust.org.uk
01284 747552
03.03.08
Dear Secretary of State,
Town and Country Planning Act 1990 – Section 78: Appeal by BAA Ltd and
Stansted Airport Ltd against the decision of Uttlesford District Council; land at
Stansted Airport, Stansted, Essex, CM24 1QW
We understand that you are currently considering the Planning Inspectors Report of
the above Appeal. We are therefore writing to provide you with our response to the
letter of 18 February 2008 from CMS Cameron McKenna on behalf of BAA Ltd and
Stansted Airport Ltd to the Planning Central Casework Division of your Department
providing assessments of the air quality impacts of the proposed Stansted G1
development.
The letter seeks to revise modelling work undertaken by BAA which now means that
it would have the effect of increasing the NOx concentrations in both the 35 mppa
and 25 mppa cases. The 30 μg/m² concentration contours for the 35 mppa and 25
mppa cases would then extend into Hatfield Forest in both cases (rather than skirting
the edge of the Forest) by up to about 250 metres and 150 metres respectively.
This is of grave concern to the National Trust as to fulfil our statutory duty under the
National Trust Acts we are bound to safeguard from damage our properties
(including Hatfield Forest) in perpetuity. At the Inquiry we raised serious concerns
about air quality and indeed the Inspector at the start of the Inquiry identified ‘the
effects of increased air pollution from aircraft and surface transport on nearby
woodlands’ as one of the key issues. BAA consistently claimed that NOx levels
greater than 30μg/m² would not encroach on Hatfield Forest.
Contrary to BAA’s Closing Submission, the National Trust in its evidence on Air
Quality provided by Dr Nicholas Haycock (NT/2/a) sought to demonstrate:

The need to achieve a NOx concentration below 30μg/m². Hatfield Forest has
been declared inalienable by the National Trust, it is a Site of Scientific
PRESIDENT: HRH THE PRINCE OF WALES
REGIONAL CHAIRMAN: SIR NICHOLAS BACON Bt
REGIONAL DIRECTOR: PETER GRIFFITHS
Registered Office: Heelis · Kemble Drive · Swindon · Wiltshire · SN2 2NA
Charity Number: 205846
Registered
Interest and a National Nature Reserve. All these designations have been
conferred on the property in order to safeguard it for the future. The World
Health Organisation (WHO 2000) identified 30μg/m² as an annual mean of
NOx above which vegetation is damaged. Elevated levels of NOx are
therefore in direct contravention of the designations made by the British
Government.

That below the 30μg/m² NOx limit it is likely to be causing harm to the
vegetation. These NOx limit values are based on extensive experimental
research. However, crop plants are the most commonly used vegetation in
such experiments, mainly due to the associated commercial value. Species
such as mosses (bryophytes) and lichens are particularly sensitive to air
pollution as they depend on absorption from the atmosphere for their nutrient
supply, do not have protective waxy cuticle and cannot close their stomata
like woody vegetation. For this reason, the concentrations of NOx that may
result in damage to mosses, lichens and other vulnerable plants, like veteran
trees, is less than the 30μg/m² general vegetation limit.

That there are effects on the vegetation. The impacts of unnatural levels of
atmospheric NOx on plants (including bryophytes) can be visible in terms of
damage to leaves. This takes the form of physical damage to the stomata
cells, which then results in the death of the leaf or a portion of it. NOx
concentrations even if they do not physically damage the stomata cells
themselves, can interfere with the activity of these cells by disrupting the gas
exchange processes within them. This disruption suppresses photosynthesis
rates which over short time periods can have implications for the health of
plants and their viability. For older or weaker plants there can be further
implications for hydration and infection.
BAA claim that no evidence was introduced to explain the likely effect on vegetation
as a result of the proposed development. This is clearly untrue as you can see
above. Also BAA in their Deed of Unilateral Undertaking in Part 14 dealing with
Obligations relating to Nature Conservation (Para 1 & 2) obviously have concerns
about damage to vegetation related to the 30μg/m² limit as they have suggested that
they need to undertake a study of the effects of air pollution on the flora and fauna in
Hatfield Forest and any consequent compensation arising from it.
It is clear to the National Trust that the Inspector and the Rule 6 parties have been
unintentionally misled by the BAA evidence on Air Quality at the Public Inquiry. We
would therefore support Stop Stansted Expansion in their request for further
information and seek your views as to how the new evidence provided by BAA can
best be dealt with in a way which is fair and equitable and which ensures that the
new evidence and its implications thereof can be properly tested.
We would welcome your views on this matter.
Yours sincerely,
Keith M Turner
Area Manager - Essex, Herts & Suffolk