Representation by Transport for London (Transport for London)
- Date submitted
- 27 October 2023
- Submitted by
- Other statutory consultees
TRANSPORT FOR LONDON GATWICK AIRPORT NORTHERN RUNWAY DCO RELEVANT REPRESENTATION 26 OCTOBER 2023 1. Introduction 1.1 This relevant representation is provided by Transport for London (TfL) on behalf of the Mayor of London. The Mayor of London recognises the economic and connectivity benefits that airports, including Gatwick, bring to London – but also that the environmental and health impacts of aviation must be fully acknowledged and addressed. 1.2 Though Gatwick Airport lies outside London, it is an integral part of the London airport system. It is London’s second airport and a significant proportion (42%) of Gatwick’s passengers are travelling to and from London – and as such, a holistic approach is required. The Mayor and TfL have an interest in this application with regard to its wider environmental implications – noise, carbon and air quality – as well as impacts specifically within the London area in terms of surface access and its emissions. 2. Summary of the Mayor’s position 2.1 The Mayor of London has reservations about the environmental impacts associated with the development of the Gatwick Airport Northern Runway, particularly with regard to the carbon emissions resulting from the increase in air traffic movements (ATM), as well as the emissions from increased highway trips. On this basis, the Mayor is unable to support the proposed development. 2.2 The aviation sector needs to play its part in meeting UK climate change targets. The Applicant has failed to set out how an increase in flights can be in line with the requirement to reduce carbon emissions. Moreover, projected emissions are overly reliant on the rapid development and take up of Sustainable Aviation Fuels (SAF). Even with the Applicant’s optimistic assumptions about the rapid take up of SAF, the proposed development falls far short of Government targets for carbon reduction from the aviation sector by 2050. 2.3 It is important that the Applicant also demonstrates how it intends to fully address the noise and air quality impacts that arise from the proposed development – with regard to the latter, both from aircraft and from surface travel to and from the airport. 2.4 Securing sustainable surface access for both passengers and staff is essential to reducing the carbon and air quality impacts of the proposed development. Not least given Gatwick’s location directly on the Brighton Main Line, with frequent rail connections to multiple locations across the South East, the sustainable surface access targets need to be much more ambitious. The proposed development should not entail any increase in car trips or car parking and the Applicant should make use of all levers available to achieve this – including a wider sustainable transport fund and demand-side measures. 3. Carbon 3.1 The climate emergency requires significant and co-ordinated effort if greenhouse gas emissions are to be drastically reduced to keep global warming under the proposed 1.5ºC or 2ºC limits. Aviation constituted 7% of total UK emissions in 2018, with the sector needing to drastically reduce its emissions if it is to contribute to achieving binding climate change targets. The proposed development entails an increase in ATMs of 36% compared to 2018, with emissions reaching 17% above 2018 levels. A further 1 MTCO2e is forecast to be emitted in 2038 compared to the future year baseline. It is also worth noting that the baseline bakes in a very substantial increase in winter flights (i.e. with much less seasonal variation compared to today) – which risks overstating the baseline and so underestimating the impact of the proposed development. 3.2 The Government’s Jet Zero policy requires a 50% aviation emissions reduction by 2050 compared to 2019 levels. Projections for the project scenario, with increased air traffic, suggests a 27% reduction by 2050 for the northern runway project compared to 2019 levels. The project should, at a minimum, meet the obligation as laid out by Jet Zero, which current projections do not. 3.3 The Applicant is also placing a heavy reliance on SAF to reduce emissions from the increase in flights. In the Environmental Statement, for greenhouse gases, the calculations for emissions from flights are based upon the high ambition SAF scenario. We support ambitious emissions reductions but are concerned about the optimism of these assumptions. Should the high ambition SAF scenario not be met, emissions from aircraft will significantly increase, putting even the forecast 27% reduction out of reach. Many of the underpinning technologies are yet to be proven and as such, these figures should be treated with caution. 3.4 The Applicant should set out concrete plans for reducing the emissions of aircraft, including detailed measures to increase use of SAF and encourage newer, lower emission aircraft. Plans should also include achieving level 4+ of the Airport Carbon Accreditation (ACA) scheme. 3.5 Carbon emissions from surface access must also be considered, given the increase in passengers travelling to and from the airport. All levers available to the Applicant should be exercised to increase the proportion of those travelling to their airport by sustainable modes. 4. Surface access 4.1 Given the critical importance of securing sustainable mode shift, we want to see greater ambition from the Applicant. With sustainable mode share currently 45% for passengers and 31% for staff, the target of 55% sustainable mode share for passengers and staff – the latter also including car sharing – needs to be increased if environmental impacts are to be addressed. Gatwick can count on exceptional access to the rail network, with fast and frequent connections to London and a wide range of destinations. Expansion of capacity should not be underpinned by any increase in highway trips. Yet, vehicle kilometres are projected to increase by 25.6% from 2019 to 2047 with the proposed development. Linked to this is a proposed increase in parking spaces of around 7,700, 10% of the total current on- and off-site parking. This runs completely counter to the sustainability of the proposed development and the need to minimise its associated emissions. 4.2 The surface access strategy needs to be matched by sufficient commitment on the levers to be used to increase the proportion of sustainable trips to the airport and prevent an increase in car journeys. There should be clarity on the use of demand-side measures to change travel behaviour. At the same time, it is essential that there is a committed plan for measures to encourage sustainable trips. 4.3 Serious consideration should be given to how a sustainable transport fund of a suitable scope and quantum in the DCO, would, combined with more ambitious mode share targets, help drive substantial mode shift. Focused on sustainable surface access to Gatwick from across its wider catchment, it could allow for flexibility in the interventions to be pursued, responding to particular challenges and depending on the schemes coming forward. Rail schemes which could benefit could include: Network Rail’s Croydon remodelling – providing much needed capacity on the Brighton Main Line; a direct service from Gatwick to Kent via Redhill; and earlier morning trains on additional corridors to match early shifts and flights. We welcome the Applicant investigating potential new coach services to locations away from the Brighton Main Line, including those in Southeast and Southwest London. There are also opportunities to improve local bus services and active travel infrastructure. Securing a substantial sustainable transport fund sufficiently broad in scope would help provide assurance that the Applicant is moving beyond aspirations and was committed to taking concrete steps to deliver mode shift. 4.4 We seek further clarity on the modelling of capacity on rail services. This includes the need for more detail of the impact on the Brighton Main Line corridor of baseline growth, including Gatwick demand, in addition to the proposed development – and the ability of this to be accommodated, including at times of perturbation in airport or railway operations. It is a concern that perceptions of high levels of crowding will reduce the propensity to take the train, undermining sustainable mode shift. 4.5 We are also concerned that the highway model only includes a small proportion of South London in the ‘detailed modelling area.’ The rest of London is modelled as part of the ‘Fully Modelled Area’, but with fixed speeds, as taken from the South East Regional Transport Model (SERTM). Given the significant number of projected highway trips between Gatwick and London – including the areas not covered by the ‘Detailed Modelled Area’ – it is a concern that the full impacts across wider areas of London have not been assessed. The demand calculation of highway trips to and from London for both baseline and project scenarios needs to be provided. 5. Air quality 5.1 The severe impacts of air pollution on human health are a key concern for London. The Applicant must demonstrate how it is addressing emissions including from aircraft take offs and landings as well as from airside operations and increased traffic levels. As such, ensuring that passengers and staff are encouraged to travel by more sustainable means will have benefits for air quality. 5.2 The Applicant’s assessment is largely limited to the Gatwick area. However, we are concerned that the Applicant has not sought to understand the potential air pollution impacts within Greater London. London remains a key origin/destination for Gatwick airport passengers and the large volumes of traffic moving to and from the airport could lead to reduced levels of air quality for boroughs closer to key traffic corridors, such as the A23 and M23 – particularly those areas already experiencing high levels of air pollution. 6. Noise 6.1 Though the populations affected are generally outside London, we would expect the Applicant to fully assess and address the noise impacts of the proposed development. There is no escaping the increased noise exposure for local communities as a result of the increase in the number of flights, both in the baseline and project scenarios. It is positive that Gatwick has highlighted properties exceeding noise limit values from both construction and the additional flights, but it should be noted that whilst noise impacts for construction are within legal limits, these will nonetheless exceed the World Health Organization (WHO) Europe guidelines, as detailed below. 6.2 Assessment of a suite of noise metrics to better understand the impacts is critical and we welcome the Applicant’s efforts in this regard. It is also worth noting the WHO Europe guidelines which reflect the latest scientific evidence. For aircraft noise, it recommends 45 dB Lden for average noise exposure and 40 dB Lnight for average night noise exposure as the limits above which there are adverse health effects. 6.3 The greatest noise impacts of the proposed development appear to relate to the night-time period. Given the particularly negative health impacts associated with sleep disturbance from aircraft noise – the Applicant needs, in particular, to set out its commitment to limit night-time movements. As noted in the Environmental Statement chapter 14, there is a significiant population – around 19,000 people – for whom night time noise will exceed the WHO recommended levels. 6.4 Air noise insulation is a part of the mitigation strategy; the Applicant needs to consider whether the proposed thresholds are sufficient to include all those experiencing substantial noise exposure – and whether residents will be able to fund their share of insulation when only eligible for a contribution from the Applicant. 7. Conclusion 7.1 We request that the Examining Authority considers the points raised in this representation and investigates these during the DCO examination process. We will welcome the opportunity to expand on these points at later stages in the process.