Representation by Nicol Taylor Consulting Ltd (Nicol Taylor Consulting Ltd)
- Date submitted
- 23 June 2023
- Submitted by
- Members of the public/businesses
AIRPORT OPERATION The CAA approved an airspace change to the Luton arrivals airspace at the end of 2021, this was technically called the ‘Swanwick Airspace Improvement Programme – Airspace Deployment 6’ according to the CAA website. The information in the consultation said that ‘London Luton Airport currently shares arrival routes and holds with Stansted Airport. Any arrival delay or disruption at one airport can cause unnecessary arrival delay to the other, impacting the travelling public and local community’. In relation to this there are some questions: The airspace change at Luton focussed on reducing delay for arrivals; as this plan will increase both departures and arrivals does the potential impact in increasing the number of flights, now increase the potential for un-managed increases in delay for flights departing Luton? The information shared as part of the planning request does not seem to include enough detail or forecasting on how each departure route will be used and as a consequence what impacts this might have for delays and flights departing the airport. We know from experience that the rates of departing flights change on an hourly basis and it would seem that this information should be provided to help understand what delays will be like at the really busy hours. The application should also make clear whether the expected delays will have an impact on the attractiveness of the airport to airlines, whether the airlines have been consulted about the expected delays and whether there are potential implications for the forecast aviation traffic levels if delays are predicted to rise over todays levels. I also believe that the delay question extends beyond the area for which Luton is responsible and into the area for which NATS is responsible. Luton also has in progress an airspace change for airspace modernisation (FASI-S?) to help increase airspace capacity and is working with NATS on that project. I am not sure which order these changes are planned to happen, but if the Luton DCO plan comes in to play first will the airspace for which NATS has responsibility across London and the south-east have the capacity to accommodate Luton’s plans and the increase in flights from other airports which I understand are also anticipated? FORECASTS Unconstrained demand forecasts (Figure 6.2) What line was actually assumed for the central case forecasts including all economic work? How does the assumed line align with the Jet Zero forecasts from Government? What is the growth in ATMs implied by this, split between Long Haul and Short Haul? Is the profile of demand front end weighted? Constrained demand What assumptions have been made about constrained demand at Heathrow, Gatwick and Stansted? Do the assumptions on Gatwick demand align with materials published in Gatwick’s Autumn 2021 consultation? What is the new runway assumed in the south-east (6.4.8) – is this Gatwick or Heathrow? These projects would give rise to very different effects at Luton and cannot be equated in one downside scenario. Please explain the detailed effect of a third runway at Heathrow on the Luton forecasts and particularly the need case at Luton – is this expansion really still required if there is a third runway at Heathrow? This cannot be equated to a slower growth scenario or even to growth at Gatwick. Lumping all the sensitivities together does not seem appropriate. Please split these out. Please explain the detailed effect on the economic benefit case at Luton of a third runway at Heathrow? One would expect this to be significant but there does not seem to be any evidence provided on this. In answering the questions above, can you explain the spill model that has been assumed – traditionally in the London market Heathrow fills first, then Gatwick then Stansted and Luton. Does your case assume that this continues to be the case? The historical spill model would indicate that if Heathrow third runway is in place and the Luton additional capacity proposed is taken up as you forecast, then Gatwick would be expected to be full too. Is this what you have assumed? If not, why does your spill model work differently to the historical approach and where is the evidence for this new model being credible? If you are assuming the traditional approach, why have you only assessed one new runway in the south east? Can you evidence that the take up of additional capacity at Gatwick has no effect on Luton’s predicted levels of traffic – both with and without a third runway at Heathrow? Or explain why it has not been thought necessary to do any of the above – i.e. explain why the Heathrow third runway does not need to be accounted for. Is it because it is not likely to come forward as a development?