Representation by Tunbridge Wells Borough Council (Tunbridge Wells Borough Council)
- Date submitted
- 5 September 2023
- Submitted by
- Local authorities
Please see below a copy of the representations previously submitted by TWBC. December 2021 Response from Tunbridge Wells Borough Council to Gatwick Northern Runway Consultation Questionnaire. Q1 To what extent do you support or oppose our proposals to bring the existing Northern Runway into routine use? Strongly oppose At a Full Council meeting on the 6 October 2021 the following resolution was passed: Tunbridge Wells Borough Council continues to oppose any further expansion of Gatwick Airport. This council does not support the airport’s proposal to use its northern runway for routine use as it will lead to more flights and more pollution for our residents. The environmental damage this will cause goes against tackling the climate change emergency. The Council is strongly opposed to the expansion of Gatwick and the proposed routine use of the northern runway. Tunbridge Wells is unlikely to see wider economic benefits from the growth in flights and capacity at Gatwick. It will however be impacted by the increased volume of aircraft and the larger aircraft that the airport is seeking to encourage. The impact of increased flights is increased air and noise pollution affecting the local population. The Council’s aspiration to reduce CO2 emissions, to net zero by 2030, is not met by the strategy being proposed by Gatwick. While there is an aspiration to use sustainable fuels there is little clarity on how the airport will directly achieve this, nor is there a clarity that new propulsion methods will be in place to remove carbon emissions in the timeframe. Aviation is recognised as both one of the most carbon-intensive forms of transport and one of the most difficult to decarbonise. To be consulting on increasing airport capacity during the COP26 highlights the lack of commitment to wider national objectives. It is not clear how Gatwick will achieve its shift to sustainable transport for access to the airport with or without the proposed use of the northern runway. The ambition to increase modal shift to rail will be difficult to achieve without ensuring a frequent direct rail connection via Redhill towards Tonbridge and beyond, linking with appropriate services along this alignment. It is essential that a comprehensive and sustainable transport strategy is developed working with wider transport partners, both national and regional, to cost and fund this connection whether the proposed use of the northern runway goes ahead or not. Q2 Do you think we could do anything more - or differently - to maximise local and regional employment and skills benefits? The consultation documents identify wider skill and job benefits. The number of additional local jobs outside the Gatwick Diamond across Sussex (East and West), Surrey and Kent is 7,500. Across such a wide geographic area and particularly as there is no suitable direct access routes from Tunbridge Wells, the benefits locally are likely to be very limited. In terms of skills development and creating high quality jobs there does not appear to be a strategy for developing this across a wider area. There is a commitment to develop a plan during the next stage of Gatwick’s work, but nothing is proposed at present. Q3 Do you think we could do anything more - or differently - to maximise benefits to business and the economy? We recognise and support Gatwick in making procurement opportunities in the supply chain available to small businesses (which should already be a priority for Gatwick). If growth is to take place these opportunities should be widened out through the construction phases as well ensuring that more small businesses can engage in different parts of the supply chain, from materials through to manufacturing and professional services. It is suggested that the proposed growth of Gatwick as a result of the routine use of the northern runway may lead to business relocations to take advantage of this growth. However, as connectivity to Tunbridge Wells is not being improved this does not seem likely to be a potential benefit to our local economy. Competition is cited as an economic benefit with reduced fares and innovation. The main consultation report suggests that it ‘could affect prices’ rather than confirming this is a clear benefit. Nor does it actually suggest fares could decrease as alluded to in the summary document. In reality, improved facilities and service standards are as likely if not more so to improve competition as increased capacity. In addition, given the significant impact of aviation on climate change consideration should be made of the ‘polluter pays’ principle when setting fares. The proposal suggests resilience is a key issue, however the northern runway is already available for resilience so it is not clear what additional benefits of making it a full dual runway airport are other than increasing flights, volume of people, freight and consequently CO2 emissions. If the intention is to allow recovery from unexpected events and for use in an emergency or to address specified events this could be managed by the airport rather than through the permanent change made to use of a second runway. The economic benefits suggest an increase in freight by 115%, yet there is no proposed increase in freight infrastructure capacity, just some internal improvements. This may suggest very limited dwell time within the airport or else highlights that the significant increase is from an exceptionally low base raising the question as to whether there are actually any wider opportunities that will be afforded. Q4 Airport supporting facilities - Relocation of the current Central Area Recycling Enclosure (CARE) facilities. Do you think this location is appropriate/inappropriate: Option 1 Don’t Know, Option 2 Don’t Know Given the distance of the CARE facility to the borough of Tunbridge Wells, it is not considered appropriate to provide detailed comments in relation to this question, as this element of the facility is unlikely to have any direct material impact on the Tunbridge Wells residents and/or environment. However, it should be noted that careful consideration should be made to any potential adverse impact on any nearby residents, the impact on character and features of the landscape and townscape and the changes as a result of the Project proposals, in considering the location of the CARE facility. Q5 What are your views on our landscape and ecological proposals? Again, given the distance of the landscape and ecological proposals to the borough of Tunbridge Wells, it is not considered appropriate to provide detailed comments in relation to this question, as this element of the facility is unlikely to have any direct material impact on Tunbridge Wells residents and/or environment. However, it should be noted that careful consideration should be made to the provisions set out in the National Planning Policy Framework (NPPF) and the recently enacted Environment Act. In light of the biodiversity emergency there should be an ambitious approach to net gain. The Act provides for a minimum of 10%. What is not clear is the level of net gain proposed as part of the proposals, if any. Q6 What are your views on our approach to land use? The consultation material does not set out what the existing uses of the proposed construction compounds are, so the proposal which sets out what their restored use will be is not clear. However, depending on their existing use and/or whether they are required for their existing use in perpetuity, we would ask whether the opportunity to improve these areas should be taken. Could these areas be used to improve landscape and/or visual setting, particularly where they are on the outer perimeter of the airport? Q7 Do you think we could do things better, or differently, to ensure all passengers and staff have appropriate choices for accessing the airport? We welcome the commitment to a transport strategy that aims to increase the number of journeys to and from the airport by sustainable transport modes. However, it is considered that the proposed actions will not meet the strategy aims. Providing a frequent direct rail connection via Redhill towards Tonbridge (East/West) and beyond, linking with appropriate services along this alignment would start to make the strategy more achievable. It is assumed that regardless of increased capacity that the airport is committed to improved sustainable access. However, there are insufficient proposed accessibility and connectivity improvements across the network to encourage this modal shift. A number of strategy documents have set out the priority of improved east-west rail links to Gatwick including the recently published Kent County Council Rail Strategy 2021: Kent Rail Strategy - Kent County Council. A second concern is that the strategy focuses on passengers which is a primary traffic generator for the airport. However there doesn’t appear to be any assessment of how the increased freight (115%) to the airport would transfer sustainably from the airport. Despite the proposed increase in freight the proposal suggests there is no need for additional capacity, just some internal improvements. There is no suggestion of distribution of this additional freight traffic being by rail and while a percentage may be internal transfers to other flights this isn’t clear nor has it been quantified. It is assumed that a percentage of the increased freight traffic, again not quantified, will be road based. Q8 What are your views on our proposals to improve local junctions to support airport growth as well as provide capacity for local traffic? Please specify the improvements to which your comments refer Road improvements are restricted to proximity to the airport where the extra traffic will be focussed. Improvements appear mainly focussed on car borne traffic and it is not clear how this relates to the stated ambitions for a sustainable transport strategy. Q9 What are your views on how our proposals for increasing use of public and sustainable transport apply in your area? Please specify the proposals to which your comments refer and tell us if there are other things we could do that would be relevant to your journeys. There is a bold figure proposed for an increase in passengers/employees using public and sustainable transport. This should be the aim regardless of any capacity increases as a result of the norther runway proposal.The proposed mitigation regarding road and rail transport connectivity with West Kent is inadequate, which is a longstanding concern of TWBC. The consultation highlights that 42% of passengers who access the airport do so by rail. However, there is very little in the proposals regarding improving rail connectivity to encourage public transport use rather than the car. Rail access beyond the direct north south Brighton line access will not see any improvement. The ambition to increase a modal shift to rail will be difficult to achieve without ensuring a frequent direct rail connection via Redhill towards Tonbridge and beyond, linking with appropriate services along this alignment (see Kent Rail Strategy above). It is essential that a comprehensive sustainable transport strategy is developed working with wider transport partners both national and regional to cost and fund this connection regardless of the northern runway proposals being successful. A significant barrier to increasing sustainable access is the timing of public transport in relation to early morning and late night flights. Detailed proposals are required for increased public transport prior to the first morning flights and post late night flights to ensure it is a reasonable alternative to get to and from the airport. Improved direct links from east/west onto the Brighton line and therefore direct access to Gatwick is not being addressed despite the proposed significant increase proposed in traffic. The purported shift to public transport will not happen unless the journey is made significantly simpler and more accessible to all potential passengers. The 24 hour service from a central London terminus is recognised but there is no comment on how passengers get to that terminus or other stops along the alignment when there is little or no sustainable public transport 24 hours a day outside of London. Q10 Are there any particular measures or activities for managing construction impacts that you would like us to consider including in our proposals as construction details are defined? The development of a full EIA will be expected and commitment to this is noted. There should be particular emphasis on the use of sustainable materials and that the construction phase contributes to reduced carbon emissions. The continued reduction and use of more innovative methods to further reduce waste material should be explored. The potential embedded carbon associated with any extensive renovation of existing and new infrastructure needs to be clearly set out along with information about how this will impact Gatwick’s net zero policies. Q11 What are your views on our construction transport proposals? The references to using low/zero emission vehicles, plant and equipment is noted. However, this needs to be delivered in practice. While referred to under the mitigating effects section, a similar clear statement setting out construction delivery and transportation plans including in the EIA would highlight a commitment to this goal. A key aspect of construction traffic is workforce related. It is noted that a workforce minibus is proposed though it is not clear if this is just for movement between the various construction sites or for access to site of workforce. Within the document the location of offsite points where workforce construction traffic will be transferred onto minibuses is not made clear and should be addressed. While the potential works may be some considerable time in the future and it is hoped that Covid-19 is no longer an issue, a plan to minimise social contact of the workforce should Covid or other viruses be an issue will also need to be in place and this must address access to the site to minimise traffic impacts. As regards the wider construction traffic including deliveries, a suitable batching site or sites could be used to minimise disruption around the airport. It is noted that this is still to be identified. The establishment of a construction management plan including defining appropriate routes for access to and from the site and proposed batching sites would be expected to minimise wider disruption and traffic taking inappropriate routes. A stronger commitment to sourcing materials locally to achieve wider local economic benefits to the region is expected. Q12 Do you have any comments on our approach or suggestions for specific measures to be incorporated into the Action Plan? The IPCC’s sixth assessment report, released 9th August 2021, makes clear that rapidly cutting CO2 emissions to net zero, while making major cuts to other greenhouse gases such as methane, is the only way to avert the worst impacts of climate change. Climate change affects all of us. Its impact is already being felt in the form of extreme weather and temperature rises, and we can only tackle this emergency if we see change in everything we do. (Climate change continues to be evident across UK – July 2021 Met office) Following COP26 at Glasgow and with all the pledges made, global greenhouse gas emissions in 2030 will still be around twice as high as necessary for the 1.5°C limit and with global temperatures predicted to increase to at least 2.4°C in 2100. (CAT_2021-11-09_Briefing_Global-pdate_Glasgow2030CredibilityGap) Aviation is recognised as both one of the most carbon-intensive forms of transport and one of the most difficult to decarbonise. As well as its’ CO2 impact, aviation also has a significant non-CO2 climate impact, the extent of this impact is as yet not fully understood and further research in this area is ongoing. (Climate Change Committee - Progress in reducing emissions 2021 Report to Parliament) This means that aviation could well be the largest contributor to UK greenhouse gas emissions by 2050, particularly as demand is expected to grow. (Aviation, Decarbonisation, and Climate Change, House of Commons Library Research Briefing – September 2021) The Climate Change Committee (CCC) advice in the Sixth Carbon Budget and confirmed in their 2021 progress report also states; that there should be no net expansion of UK airport capacity, unless the sector is on track to sufficiently outperform its net emissions trajectory and can accommodate the additional demand. Therefore, based on the lack of clarity and ability to meet the required emissions trajectory pathway as set out by the CCC’s the proposed expansion at Gatwick by bringing the northern runway into permanent use and increasing passenger numbers by an anticipated capacity of approximately 13.2 million passengers per year cannot be justified. If we are serious about the Paris Agreement’s goal of holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C temperature limit. It would be counterproductive to permit this significant infrastructure project. Therefore, to meet our net-zero goals and avoid the worst impacts on our climate we recommend the expansion of the northern runway at Gatwick be rejected. Q13 Managing and mitigating effects: noise envelope The proposed noise envelope is considered to be inappropriate. The use of the emergency runway for take-offs will facilitate more ATMs. It is presented as a separate issue but it is linked to other issues such as use of advanced navigation technology that allows more precise flying down narrow flight corridors. It links with stack systems or point merge systems to deal with queuing and it is hard to separate the impact of these things from the use of the runway, as ultimately they will blend together. Tunbridge Wells will not experience any noise issues from construction work or noise from aircraft on the ground at the airport nor from increased transport. However, the envelope scheme for noise mitigation is presented as a win for both the local community and for the airport in a sharing the benefits from quieter aircraft. This is flawed in that the long term averages of log numbers does not totally reflect annoyance. They give a better result for steady state noise like traffic rather than aircraft, but the metric does provide a benchmark. The N65 and N60 provide a better metric being the number of aeroplanes that exceed the 65dB LAmax during the day and 60dB LAmax during the night. The WHO indicates that an internal bedroom level of LAmax 45dB should not be exceeded more than 10 times a night. If we work on this level in terms of external level of LAmax that will give 45dB in the bedroom this will give a good indication. Typical noise reduction by a window open for ventilation will be 10-15dB. Thus outdoor levels would need to be between 55dB LAmax and 60dB and only have 10 flights in an night to comply. Thus a level of N55-N57 contour would be more appropriate where 10 or more flights occur at night for a better reflection of impact. The noise envelope scheme aims to share the benefits of quieter aircraft. However this can cause issues with assumptions that quieter aircraft but a greater number of them leads to an improvement. As an example a reduction of 3dB in aircraft noise would perceptually be a barely recognisable difference. However, this would allow a doubling of aircraft still keeping within the noise envelope. Thus a resident who experiences this will barely notice the difference in aircraft noise level but will clearly notice the increased number of times they are disturbed by aircraft transport movements (ATM). Q14 What are your views on our approach to noise mitigation? Please specify the measures to which your comments refer. When aircraft take off they cause no issues to Tunbridge Wells as they reach sufficient altitude to not be an issue over the borough. However, when they are landing and are vectored over Tunbridge Wells they are often at a height of 3-4 thousand feet. The glide path to the landing runway requires a 3 degrees landing approach for safety. Some airports abroad have a 5 degree landing angle. The issue for Tunbridge Wells occurs when there is congestion and aircraft are vectored eastwards to join the landing line further from the airport to give adequate spacing. Sometimes the aircraft have to use increased power to keep level and increased noise is the result. It is better for aircraft to join the flight path as close to the airport as possible at the correct spacing so they can have continuous decent from height so that they are at the correct height, speed and trajectory as they approach the runway for landing. Increasing the number of flights will have a negative effect on noise in Tunbridge Wells. More flights will add to noise levels – the fact that measurements are based on logarithmic additions means that the overall level closer to the airport will increase (the amount of traffic is likely to increase from 285,000 to 382,000 this would give an increase of only 1.3dB but 97k more aircraft movements). As the second runway is most likely to be used during peak times the hourly LAeq could go up by 3dB if the number of flights doubles for peak times. More important to long term measurements of LAeq as a noise metric, more flights will equate to increased numbers of disturbances from over-flight. Increased flights could result in aircraft congestion resulting in increased use of “Stacks”. This would be followed by vectoring aircraft to space them out for landing causing flights to be pushed further east with many flying over heavily populated conurbations like Royal Tunbridge Wells. The use of a system entitled “Point Merge” is a better option that “Stacking aircraft”. Better aircraft GPS type systems can allow tighter flying along designated routes but this can cause problems down the centre line of these with some properties getting more overflown than previous, while some properties will be less overflown. Government Policy tends to support reductions in noise levels and/or numbers of people being over-flown. It also will favour more efficient routes for fuel economy in relation to carbon emissions reduction initiatives. These will also be favoured by the airlines as aviation fuel is expensive. This will mean that it will possible to push for routes that do not overfly major conurbations. However, rural communities are potentially at risk of increased or new overflights. Rural areas tend to have lower background noise and could be more impacted by noise levels compared to residents in conurbations. Visitor economy businesses in the borough may be negatively impacted. Whilst the use of a second runway could be used to reduce congestion – reducing queuing and aircraft vectoring over local towns by allowing more planes to join the final flight path closer to the actual runway, there is the danger that this potential benefit would in reality result in more flights and a return to vectoring (akin to motorways reducing traffic on other roads but then getting congested due to increased numbers of vehicles). Q15 Please let us know if you have any comments about the consultation process. While it is acknowledged that early engagement is being sought by Gatwick, the consultation documents do not include all the relevant details that need to be considered before a decision is made on the proposal. Therefore, there needs to be a clear commitment to ongoing consultation throughout the planning process including new and more detailed information across a range of matters (raised above). Seeking to increase capacity and flights at Gatwick through the proposed change in the use of the northern runway will increase aviation carbon emissions with the growth in flights strongly outpacing any efficiency gains. In addition, the potential noise impacts of this on the borough’s residents and businesses are yet to be fully identified, as set out in our responses to Q13 and Q14 above and this raises significant concern. The Council will therefore engage with Gatwick’s future consultations to continue to address these concerns. We do not have any further comments about the format of the consultation. I consider that the following topic areas will be the subject of further discussion as part of the examination as they may impact on the residents of Tunbridge Wells Borough Council:- - Pollution and CO2 emissions, and general environmental impact - Limited benefits found locally - Whether the development fully assesses the impact on freight infrastructure capacity - Whether the development would maximize the use of sustainable transport - Whether the impacts on the local and strategic road network are properly mitigated - Construction management - Noise