Representation by Horley Town Council (Horley Town Council)
- Date submitted
- 20 October 2023
- Submitted by
- Parish councils
Horley Town Council (HTC) welcomes the opportunity to register as an Interested Party and make its Relevant Representation to the proposals by Gatwick Airport Ltd (GAL) for its proposals to bring the northern runway into dual use. HTC sets out below our initial relevant representations regarding the main issues and impacts relating to the proposed development. Please note that our comments are not exhaustive, and we reserve the right to expand on the topics raised below during the Examination process. Background to Horley Horley is a town of some 23,000 people (as per the 2011 census) which has grown considerably since then and is located on the north side of Gatwick Airport, with a shared boundary in places, so is both indirectly and directly affected by operations and development in and around the airport site. Horley is situated within the administrative boundary of Reigate and Banstead Borough Council (RBBC). As a commuter town situated close to London and Gatwick Airport, the airport had in the past provided good employment prospects for our residents. However, the local economy has suffered from the short-term and long-term impacts on the aviation industry from the Covid-19 pandemic in respect of job losses both directly and indirectly. We are therefore supportive of the airport re-building its business but by doing so in a way that has the least possible impact on our community and the environment, both now and in the future. We have reviewed the documentation and have identified the following key issues which we believe would have a significant impact on Horley, as summarised below. WATER ENVIRONMENT Flooding The River Mole is located to the western side of Horley, with the Burstow Stream tributary running to the east and northern reaches of the Town. Large areas of Horley are therefore located in Flood Zones 2 and 3a & 3b and at an existing high or medium risk from flooding. Surface Water run-off caused by intense short periods of rainfall affect low lying areas around these streams, including Gatwick and Horley. Any additional development that exacerbates flooding is of great concern to the residents of Horley and Horley Town Council. Crawley Borough Council’s Level 1 Strategic Risk Assessment for the Upper Mole Catchment states that ‘The provision of buffer strips is important in preserving watercourse corridors, flood flow conveyance and future watercourse maintenance and improvement. It also enables the avoidance of disturbing ecology and the structural integrity of riverbanks’. The SFRA states that ‘Developers should: • Not build within 12m from the edge of bank of any Ordinary Watercourse within the district • Not build within 8m from the edge of bank of any Main River within the District in accordance with the Environment Permitting Regulations (2016) • Seek opportunities on a site-by-site basis to increase these buffer distances to ‘make space for water,’ allowing additional capacity to accommodate climate change’. Both the River Mole and Gatwick Stream pass close to Gatwick and with GAL’s proposals to build on more land around the current Gatwick area, this means that there are fewer buffer strips available. We note that the Proposals have been amended to show only one new attenuation pond by the Longbridge Roundabout, which HTC consider an improvement from earlier designs. HTC wish to ensure that the attenuation pond and resultant landscaping works will be a true enhancement to this part of Horley, as it is located adjacent to Church Meadows, currently a popular amenity space used by local residents. Whilst we note that the proposals include ‘replacement open space’ adjacent to the new balancing pond not all plans show an ‘indicative’ footbridge across the River Mole to enable users to access Church Meadows and this new open space. HTC seek clarification that GAL propose to allow public access of this widened area as compensation for the alterations. In addition, HTC seek clarification regarding the responsibility for future land management of this area, as Church Meadows falls within RBBC, but we believe the Gatwick Dairy Farm lies within the neighbouring Mole Vale District Council authority area. We trust that any ongoing maintenance costs and responsibility for ensuring effective functionality of the attenuation pond and surface water outflow mitigation pipes in the event of a significant rainfall event will rest with GAL in perpetuity but confirmation of this should be provided as part of the DCO. We also note that GAL are still proposing a further attenuation pond on the land to the north of the South Terminal flyover (currently identified as Site Allocation HOR9 in Reigate and Banstead Borough Council Local Plan for Horley Strategic Business Park). The same site is also identified in the GAL proposals for use as a construction compound for the duration of the project. We note that this would therefore have future implications for the delivery of the strategic site allocation in both the short term (i.e. any time before 2032 due to its use during the construction period) and in the long term, in respect of the siting of the attenuation pond potentially compromising the comprehensive redevelopment of this strategic site as set out in adopted policy. Sewage/ Wastewater We understand that the existing airport facilities currently discharge foul wastewater and sewage between two discrete systems, one discharging to Thames Water’s Crawley sewage treatment works and the other into Thames Water’s Horley sewage treatment works approximately 6 km to the north of the airport via the trunk sewerage system. HTC note that Horley is a water stress area and the Thames Water Horley Sewage Treatment Works is also at capacity and pending further investment to support growth. We raise concerns that the level of increase in passenger capacity generated by the proposals would push the Horley Sewage Treatment Works over capacity (if it is not already) – particularly as we have raised recent concerns with the Environment Agency (EA) regarding the current leak from the Horley sewage works, near the new Westvale Park development. Furthermore, we note the recent consultation response from Thames Water to new housing proposals in neighbouring Hookwood that Thames Water has “identified an inability of the existing FOUL WATER network infrastructure to accommodate the needs of this development proposal”. Without reinforcement works to the existing network this area is at risk of continued sewage flooding and pollution incidents, the likes of which are regularly occurring at other development sites nearby. Whilst we understand from the ES that ‘Thames Water will complete an assessment of the impact of an increase in passenger numbers as a result of the Project on water treatment capacity at Crawley and Horley STW and that GAL has engaged with Thames Water’, we would urge the decision maker to resist granting consent for such a large project without the utmost confidence that the existing system (plus any yet to be determined mitigation) can actually accommodate such growth. We are supportive that the GAL proposals have sought to identify a potential location for a new treatment works (near the existing Crawley Sewage Treatment Works), should there be insufficient capacity, however, Thames Water and GAL must jointly undertake such an assessment to adequately determine the likely impacts and provide certainty that even with a new Treatment Works there remains enough sewage treatment capacity for both Gatwick Airport and the future organic growth of the town itself. NOISE In relation to aircraft noise, Horley Town Council is protected by regulation in the AIP that aircraft departing from Gatwick must not overfly the town. Our southern neighbourhoods are likely to be the most affected by arrivals on westerly operations and departures on easterly operations but neither fly directly overhead. A major new residential development in Horley has been built under one of the NPR’s and is not protected by the current AIP regulations. HTC remain concerned about the noise impacts to residents living in Horley South (including the Gardens Estate and Riverside), particularly during the lengthy construction period. Despite mitigation being proposed, a significant number of residents will be impacted for over a decade and subject to construction noise 24/7. We note that the DCO documents indicate that noise insulation schemes may be necessary with an option of temporary re-housing of residents. However, the documentation provides no suggestions on the type & quality of the temporary accommodation, how long for & who will pay for this and associated removal costs, and whether there is a difference between homeowners and tenants. We have concerns regarding this level of mitigation, particularly regarding the “temporary” nature of any rehousing. As the project is likely to take in excess of 10 years to complete, it is questionable as to whether it can realistically be considered a “temporary situation”. We note that GAL has now removed a mitigating noise bund along the A23 boundary with Riverside Garden Park. Whilst we hope that this will enable more of the existing high quality valuable community open space, as well as the mature tree screening along the existing A23 to be retained we remain unconvinced that sufficient noise mitigation has been designed into the scheme for the residents at Riverside and Gardens Estate. Noise Envelope Experience from complaints received by the airport in 2019 indicated that the main cause of annoyance was not from an individual aircraft event but the continuous noise from an increase in movements or ‘overflights’. Therefore, increasing the number of flights proposed under the DCO has the potential for a massive increase in annoyance to residents and the number of complaints lodged with GAL. HTC welcome the introduction of a noise envelope, however, we are concerned about the metrics and contours being used to establish the Noise envelope and what scrutiny there will be once a noise envelope is in place. HTC believe that such scrutiny should be undertaken jointly by the host local authorities to ensure rigorous compliance and that this should be funded by GAL as part of this DCO. Whilst we understand the need to strike a balance between the negative impacts of noise, such as on health and wellbeing, and the positive economic impacts of aviation, we consider a general principle is to ensure that benefits from future growth are shared between the aviation industry and local communities. As such, the industry should continue to reduce and mitigate noise as airport capacity grows, with the government’s policy on aviation noise consistent with agreed international approaches and relevant European laws. We consider that, to date, benefits have not been shared with the local community, as the noise contours have not significantly reduced over time with the introduction of quieter aircraft. Whilst this could change with the increasing number of NEO’s & MAX’s in the airline fleets operating from Gatwick, we still remain very concerned. TRAFFIC/SURFACE ACCESS The DCO proposes a Construction Code of Practice which we support. However, we are sceptical that the requirement for construction traffic to use the M23 can be successfully controlled. In particular, any construction traffic using the proposed construction compound along the Balcombe Road as there is currently no access to the south terminal/ M23 spur Road nor is one proposed. It is not clear how GAL propose to manage construction staff traffic not adding to the pressure on local roads particularly in the Horley area surrounding the airport? Whilst we welcome the long-term objective of the proposed road alterations which seek to separate airport traffic from local road traffic, we are concerned about the phasing of these works and the visual/ noise impact of the proposed alterations to the A23/ M23 spur on the residents living in the Horley Gardens Estate. We are alarmed to read that the phasing of new road infrastructure is scheduled towards the end of the construction timeline (i.e. after the increase in passenger numbers). This is unacceptable to Horley Town Council as the existing road network is unlikely to have sufficient capacity to cope with the additional traffic. We would advocate for trigger points, based upon passenger numbers which will require certain new infrastructure to be in place and ask that this be given due consideration. We note that the M23 Spur Bridge over the Balcombe Road is likely to require substantial works to facilitate the proposed access improvements. However, limited information has been provided to determine what impact that could have on the free flow of traffic along the Balcombe Road, an important route for residents into and out of Horley. HTC seek clarification on the duration of any works needed and any potential diversion routes, alongside the phasing of these works in relation to the wider construction phasing. We have also been advised that the planned funding for major rail infrastructure improvements in the Croydon area (e.g. Windmill Junction) has been re-assigned and there is no indication when funding might be available in the future. This will mean the current Brighton Main Line will have to cope with a massive increase in demand from passengers [as forecast by GAL] and staff on the airports only rail link to the capital. North Terminal Roundabout The proposed new traffic light controlled junction along the A23 London Road, enabling traffic to exit the North Terminal, is welcomed as this could reduce the traffic currently having to use the Longbridge Roundabout to head south on the A23 towards Crawley. That said, we note that this junction is only for traffic exiting the North Terminal & provides no access for traffic heading southbound on the A23 (from Horley) which will have to, as currently, access the North Terminal via the South Terminal Roundabout & Airport Way. Horley Town Council (HTC) consider that the phasing of the traffic lights at this new junction will be critical, especially in peak times, to avoid queuing back into the Longbridge Roundabout. Similarly the distance between the North Terminal Roundabout and the new junction seems short which could result in traffic queuing back to the roundabout. Longbridge Roundabout The widening of the A23 London Road to ‘3’ lanes approaching the Longbridge Roundabout heading north is welcomed, however, the bridge widening to accommodate this is of concern with the potential for considerable traffic disruption. Surface Access General Comments HTC acknowledge the proposed highway alterations along the A23 and at the Longbridge Roundabout to provide additional capacity in and around the airport, however, we are also concerned about the resultant impact on the capacity of the local “feeder” roads and likely traffic congestion which do not benefit from any improvement or capacity building under the current proposals to cope with the increase in demand generated by the growth of the airport. Furthermore, Surrey County Council’s new Local Transport Plan 4 seeks ambitious targets to promote sustainable transport over the private car with a new hierarchy for road transport of “avoid, shift, improve” in order to meet the Council’s commitment to achieving net zero carbon emissions by 2050. HTC remain unconvinced that GAL have sufficiently addressed the impact on the wider local highway network that will be impacted both during construction and in the longer term once the airport has reached its targeted capacity. Whilst the ongoing commitment to support local bus & coach services locally is supported, HTC wish to see that additional investment is also targeted at new bus services from areas currently without any, as well as increasing the frequency of existing services to include a wider spread of services time wise throughout each weekday and particularly at weekends (in areas such as Westvale Park). HTC are concerned that GAL are not providing an indication of a timeline for the delivery of all the proposed highway works. As we commented previously HTC are concerned that the phasing of new road infrastructure will be scheduled towards the end of the Northern Runway Project (and after the increase in passenger numbers). HTC request that a Construction Phasing Plan is provided as part of the DCO and not just a Construction Travel Plan, that way HTC can be satisfied that appropriate modelling and mitigation has been considered throughout a phased construction period and that vital infrastructure is in place prior to passenger growth. In relation to passenger growth, HTC note that the expected level of growth is comparable with passenger numbers at Heathrow (a 5-terminal airport, supported by several rail services, bus and coach connections, and major arterial road network) yet even with the proposed Northern Runway Project the airport does not have anywhere near the comparable infrastructure of Heathrow. HTC therefore question whether such growth can ever be considered sustainable given the limitations on infrastructure. Car Parking We understand that GAL are now proposing a reduction in the level of on-site car parks. Whilst HTC support more sustainable modes of transport we remain concerned that limiting car parking at the airport will continue to place pressure on the local residential roads that are currently exploited by holiday makers travelling through Gatwick. HTC also wish to understand whether GAL have modelled how passengers access the airport in the post COVID pandemic world. Given car usage increased during the pandemic to avoid disease transmission, HTC question whether passenger behaviour will have changed permanently in favour of the private car. If this is the case, then the level of car parking provision should be reconsidered to ensure adequate provision is available. Furthermore, and perhaps of greater significance, is the proposed pricing structure of car parking at Gatwick. Essentially, if airport parking fees are set too high then the level of onsite parking is somewhat irrelevant as users will be forced to park in local streets. Again, HTC would question whether such passenger growth can be supported given the limitations for sustainable transport modes given the wide catchment area of travellers using the airport. AIR QUALITY The Horley AQMA includes an area of the southwest of Horley to the north of the airport, including Riverside Garden Park. The AQMA was designated for exceedances of the annual mean NO2 air quality standard. Whilst the ES would suggest that air quality will remain comparable to baseline levels, vehicle emissions across the UK are improving due to improvements in technology which has seen air quality dramatically improved – for example, we understand that air quality in Hooley, to the north of the borough (almost entirely caused by vehicles previously) has dramatically improved in the last couple of years. We feel it is unfair for Horley residents not to benefit from the improvements in air quality being enjoyed by almost all other parts of the UK as a result of these proposals which are merely seeking to keep air quality at or around existing baseline levels. We understand that at the time of writing the ES, no specific emission factors are available to allow quantitative assessment of ultrafine particles. While currently there are no regulations controlling ultra-fine emissions, there is growing concern that they are dangerous. We recognise that aircraft are a key source of ultra-fine particles and we understand that there are currently areas of Horley near the airport that have ultra-fine particulate levels in the air comparable to that seen in central London. We therefore consider that an assessment on ultra-fine particles should be included. We understand that the WHO published revised guidance on air pollution in September 2021, which recommends a reduction in annual average nitrogen dioxide concentration to 10ug/m3. Given that levels around the airport are anticipated to be significantly above this level, we request that GAL undertake further assessment and mitigation to address the revised WHO guideline value. Climate Change At its Full Council meeting held on 10 December 2019 Horley Town Council declared a Climate Emergency that requires urgent action. The recent COP26 Meeting reaffirmed the UK’s commitment to tackling climate change. The Glasgow Climate Pact ‘recognizes that limiting global warming to 1.5 oC requires rapid, deep and sustained reductions in global greenhouse gas emissions, including reducing global carbon dioxide emissions by 45 per cent by 2030 relative to the 2010 level and to net zero around mid-century, as well as deep reductions in other greenhouse gases’ (our emphasis). The DCO acknowledges that the GAL proposals will result in higher overall greenhouse gas emissions, which would appear contrary to the UK Government’s climate change ambitions of achieving carbon zero by 2050. The GAL proposals appear to place significant reliance on Sustainable Aviation Fuel (SAF) and we would question how achievable this is – will a supply of SAF be in place to meet demand? Notwithstanding this, the use of SAF raises its own climate change concerns as the majority are from plant-based sources associated with the potential destruction of rain forests to create more land for crop growing alongside competing for land growing crops for human consumption. If Gatwick's air traffic expands at the rate suggested in the DCO, Gatwick's CO2 emissions will contribute to a significant proportion of the Government's total aircraft CO2 emissions for the whole of the UK. This seems contrary to the Government’s “Levelling Up” Strategy whereby concentrating so much air traffic south of London could impact the economic and environmental sustainability of other UK airports, especially northern ones, if the broader Government target for aircraft CO2 emissions is to be taken seriously. Furthermore, it could be argued that not all CO2 emissions are equally important or valuable - if the UK Government are serious about achieving carbon net-zero by 2050, is there a justifiable need to be generating CO2 on non-essential short-haul flights vs. CO2 emitted to heat homes or for food production. Conclusions Horley Town Council supports the build back of Gatwick Airport and associated economic benefits associated with this. We would, however, question the demand forecast for such levels of passenger growth and whether airlines will grow back above pre-Covid levels, so thereby query the need for the Northern Runway proposals. Under permitted rights GAL have forecast that over 62 million passengers can be accommodated by more intensive use of the main runway. This alone could be considered a significant increase over the 2019 passenger numbers. Historically the Town Council has supported Gatwick’s growth based upon a one runway/two terminal approach and this remains the case. Ultimately the planning balance will fall between the environmental impacts versus the economic/employment benefits of the proposed development and Horley Town Council look forward to participating in the Examination process in due course.