Representation by Tandridge District Council (Tandridge District Council)
- Date submitted
- 20 October 2023
- Submitted by
- Local authorities
This relevant representation is being submitted by Tandridge District Council (TDC) in its role as a Host Authority for the Gatwick Northern Runway (NRP) Project Development Consent Order (DCO). Due to the short timeframe afforded to Host Authority to review and prepare their responses to the DCO application, TDC defers the following grounds to Surrey County Council: Principle of Development; Ecology and Nature Conservation including Habitats Regulation, Geology and Ground Water; Water Environment; Traffic and Transport; Climate; Greenhouse Gases; Socio-Economics; Health and Well-being; and Cumulative effects. TDC is very concerned that the development will have significant adverse impacts on local residents, businesses and the environment of Tandridge. Increased noise and air pollution are likely to reduce health and wellbeing outcomes of the local population, leading to poorer quality of life, increased mortality rates, cancer rates and respiratory diseases, increased anxiety and lower productivity and cognitive development. Both noise and air pollution will have a disruptive impact on the sensitive ecosystems of Tandridge and the special characteristics of its AONBs. TDC therefore identifies the following as the main issues relevant to this authority for consideration by the Examining Authority. 1 Economics 1.1 TDC believes the level of increase capacity attainable from the NRP presented by GAL is overstated, leading to an overstatement of demand forecasts and the wider economics benefits of the proposal. It is unclear that there is an economic case for the expansion of Gatwick. 2 Noise 2.1 TDC has significant concerns about the process of assessment and the potential noise impacts on the District due to the NRP. This relates to the increase in air noise and to a lesser extent road traffic noise and construction noise. 2.2 The assessment of impacts is based on monitoring, modelling and comparison of exposure against specific noise metrics. Amongst the concerns TDC has with this process is the lack transparency (and thus reproducibility and understanding); the accuracy of modelling which could have been improved through further studies; the assessment does not reflect the nature of the area; and disagreement with the focus on the use of the Leq as a tool to consider the effect on the local population whereas other metrics may be equally as important. 2.3 The proposal for the noise insulation scheme as primary mitigation for receiver buildings in the TDC area is too restrictive. We consider that factors such as extending the range of qualifying metrics (in addition to the Leq), basing the extent of qualifying noise contours on single mode operation and additional award to deal with overheating issues caused as a result of noise insulation need to be brought forward. The promoter also needs to pay for ongoing running and maintenance costs as well as renewal at end of life. All mitigation should be based on agreed predictive contours and installation commence with the decision for permission. 2.4 Mitigation can protect buildings but not impacts on outdoor space and use of land. Adequate compensation needs to be agreed as a separate payment. 2.5 There are substantial deficiencies in the Noise Envelope that need to be addressed before it is considered fit for purpose. It provides little incentive to stabilise or reduce noise levels using an appropriate range of metrics. There is no local accountability and no meaningful enforcement mechanism including sanctions and penalties. Rather than being responsive and preventative it is unresponsive and reactive. Provision must be made for local authority enforcement role including appropriate powers and full funding of the role by the airport. 2.6 TDC disagrees with the way aviation noise policy is being interpreted and the consequential effects these have on the proposals. In any regard we consider national policy as a minimum and as a good neighbour would expect the airport to seek to go further than this. 2.7 TDC is concerned that the impacts of FASI-South and the combined noise effects with NRP have not been considered. 2.8 TDC consider that there is insufficient validation of the mitigation and research to improve understanding of, for example, the effectiveness of the mitigation, the reliability and resolution of the noise contours, local attitudes to noise and cross correlation to the noise contours. The findings of such work then need to be reincorporated into an iterative noise management plan and systems and mitigation adjusted accordingly. 3 Air quality 3.1 TDC believes that the air quality enjoyed by its residents, businesses and natural environment will be significantly worsened by the proposal, including the impacts of construction and demolition activities leading to dust generation and emissions from construction vehicles, and the impacts of additional flights and traffic generate by the increase in airport users and suppliers. 3.2 The Environmental Statement (ES) is entirely set out against air pollution levels which, although legal in the UK, were set in 2005. The latest guidance from the World Health Organisation (WHO) is for those levels to be reduced, sometimes as much as quartered. Reducing the current air pollution to these levels will already be a difficult task and the expansion of the airport would only worsen the problem. 3.3 It is not possible for TDC to fully understand and verify the impacts of the proposal on the local population due to a lack of details on the inputs used in the assessment, including: a range of technical details, the definition of the road traffic study area, emissions ceiling calculations, the links between air quality results and specific receptor locations, application of model verification to receptor locations, and adequate justification for the exclusion of a number of air quality monitors. Without more details, TDC cannot confirm whether it agrees that the worst-case scenario has been assessed in the ES. 3.4 Information also needs to be provided on how the routes for construction traffic will be enforced, without such controls, the construction impacts on some road links could be higher than those predicted. 3.5 The ES does not provide any assessment of Ultrafine Particulates (UFPs) although acknowledges that they can result in adverse health impacts. The Council accepts that a fully quantitative assessment cannot be carried out, but questions whether PM2.5 is a suitable proxy for UFPs. Using PM2.5 as a proxy relies on the assumption that the proportion of PM2.5 and UFPs remains the same in all scenarios. However, the proposal adds significant extra emissions from aircraft sources which have different emission characteristics compared with road vehicles and are a known significant source of UFPs. It would therefore be reasonable to assume that the proportion of UFPs in PM2.5 will increase with the proposal. Evidence should be provided that PM2.5 is a suitable proxy for UFPs where additional emissions from aviation are being added. 3.6 No mitigation is proposed for UFPs despite it being acknowledged as having potential adverse health effects. The proposal should include measures that would minimise the possible increase in UFPs such as the use of lower sulphur aviation fuels and specific mitigation measures to minimise emissions of UFPs. 3.7 TDC does not accept that the human health effects have been correctly assessed in the construction impact assessment. The assessment has used the IAQM guidance but the standards for particulate matter are now much more stringent than those assumed in this document. As the particulate matter standards are more stringent, the sensitivity of the area can now longer be properly defined by Table 2.1.3 of Appendix 13.4.1. The conclusions in ES para 13.10.15 are not appropriate. The definitions of receptor sensitivity requires revision to reflect the new standards and the impact assessment updated. 3.8 The cumulative impacts of parallel ongoing of construction activities and operational activities and their related emission ceiling calculations do not seem to have been assessed. The scenarios provided in the ES do not provide a realistic worst-case assessment. 3.9 More information is needed on how sensitive predictions are to modal shift objectives not being achieved, to understand how much air quality may deteriorate if measures are delayed or unsuccessful. 3.10 The model verification approach has been split into 12 different zones with adjustment factors reported between 0.8 to 2.0 (although 1.0 has been used as the lowest adjustment factor). An explanation is required why the model would be expected to behave differently in each of these zones and why an overall adjustment factor would not be more appropriate. A sensitivity test should be carried out to confirm that the conclusions of the assessment would not change if a single adjustment factor were used. 3.11 Air Quality should be modelled to 2047. 3.12 An Air Quality Action Plan detailing monitoring, evaluation and enforcement is needed, alongside committed funding for monitoring to 2047. The proposed air quality action plan could be informed by local monetisation of air quality impacts. 3.13 The likely impact of FASI-South on air pollution should be considered. 3.14 No Dust Management Plan (DMP) is provided. The number of automatic monitors to be provided during construction is also not specified.