Representation by Wealden District Council (Wealden District Council)
- Date submitted
- 27 October 2023
- Submitted by
- Members of the public/businesses
I write on behalf of Wealden District Council to register its Relevant Representation to become an Interested Party in the Application for a development consent order by Gatwick Airport Limited for the Gatwick Airport Northern Runway project (Ref. TR020005). The following comments address the issues that are both supported and objected to by the District Council. AGREE WITH • Enhancement to on-site facilities to ensure sufficient cycle storage, changing facilities, lockers and showers are available supporting the aim of encouraging more staff to walk and cycle. (Para 5.2.6 Environmental Statement: July 2023 Appendix 5.4.1: Surface Access Commitments) • Aspirational mode share targets set out in paragraph 7.1.3 of the Environmental Statement: July 2023 Appendix 5.4.1: Surface Access Commitments. However, Wealden District Council would ask that a further commitment is given to increasing these targets if modal shift exceeds planned expectations. • Increased levels of EV Charging facilities • Supports approach to work with Bus and Coach operators to offer a more frequent and regular sustainable transport option including the provision of a new peak time hourly bus route from Uckfield to Gatwick. • The Travel Plan for construction workers which includes staggered shift start and end times to reduce peak period pressure as well as provision of dedicated bus services including those to park and ride sites and to specific locations where construction workers live (12.9.22) DISAGREE WITH • The limited levels of intervention proposed to improve public transport (Uckfield only) links between main towns within Wealden, East Sussex, and Gatwick Airport. The public transport proposals described in the ES Appendix 5.4.1: Surface Access Commitments (Doc Ref. 5.3) and in Section 12.8 only include new coach routes between Gatwick and Kent and do not indicate any mitigation for Wealden other than the new peak time hourly bus route from Uckfield to Gatwick, which reverts to two hourly off peak failing to accommodate travel by public transport for shift workers and individuals wishing to travel to • Within Table 12.3.2 of Environmental Statement: July 2023 Chapter 12: Traffic and Transport it is noted that the response to Wealden District Council points towards ES Appendix 5.4.1: Surface Access Commitments (Doc Ref. 5.3) to provide answers for additional sustainable transport provision options. It is however noted that the options outlined in this document do not in fact provide a solution for the many residents of Wealden that travel to and from Gatwick as a place of work. • Staff method of travel to work surveys every two years – Frequency should be annual to monitor change and ensure early intervention if levels of travel by car increase. This information should be reported in the AMR annually and not every other year. • The Council disagrees with the proposal that the first AMR will be produced no later than six months before the commencement of dual runway operations. Methods of travel to and from work should also be monitored and reported through the construction phase to monitor and therefore manage the number of employees travelling to and from work by public transport or active travel as opposed to by motor vehicle. MAIN ISSUES Wealden District Council seeks to ensure that any development that it supports makes significant progress in delivering both the Government’s and the Council’s net zero goals. To do this the authority supports the delivery of a sustainable built and natural environment; the transition to a low carbon society through the minimisation of greenhouse emissions and the reduction in energy consumption including effective use of resources. Furthermore it would seek to see the increase in the use of renewable and low carbon energy sources whilst protecting and ensuring the sustainable use of our natural resources. Key to the delivery of these ambitions is the effective implementation of modal shift from the use of the car to public transport or active travel. Whilst the District is on the outskirts of the impact zone identified it remains critical for the residents of our extremely rural district to have a viable alternative to the car to travel to and from the airport. Public Transport and Modal Shift The Council remain concerned that there is only very limited support for public transport providers such as Bus companies for the provision of additional appropriate services from any location within Wealden. Table 1 related to commitment 5 of the Environmental Statement: July 2023 Appendix 5.4.1: Surface Access Commitments does not identify a route that will pass through Wealden to support the travel of both passengers and staff to the airport from within the District. Thereby leaving the only reasonable option to access the airport as a road journey by car or taxi. As a particularly rural district with limited direct rail access to Gatwick travel by bus is the most viable option for modal shift. The Council would seek additional support for East Sussex County Council to be able to provide or enable additional direct and express bus services to Gatwick from the main towns within the District. Climate Change Although no high or very high risks were identified within the Climate Change Resilience (CCR) assessment or the In-Combination Climate Change Impact (ICCI) the decision not to monitor these indicators during the construction period (Para 15.12.5 and 15.12.8 Environmental Statement: July 2023 Chapter 15: Climate Change) would appear to be short sighted. Climate Change, as an ever escalating issue requires continuous monitor at all levels to ensure that mitigation can be adjusted and delivered in advance of adverse outcomes. While it is accepted that current risk indicators are low or medium, the ongoing and escalating impact of climate change should be monitored to ensure that the CCR and ICCI any additional further mitigation can be applied as necessary. In terms of carbon emissions, Wealden District Council is aware that the Northern Runway Project and the associated increased in capacity at Gatwick Airport will result in increased carbon emissions arising primarily through additional flights as set out in the Autumn 2021 consultation documentation. This is likely to negatively impact on targets aimed at reducing harmful emissions and the wider Government’s aim of reaching net zero by 2050. Gatwick Airport Ltd should also ensure, as requested by the High Weald Joint Advisory Committee, that the High Weald AONB Management Plan has been fully considered in determining the mitigation for climate change, net zero carbon and noise levels. It is the duty on all public bodies and statutory undertakers set out in Section 85 of the Countryside and Rights of Way Act (CROW) 2000 to have regard to ‘the purpose of conserving and enhancing the natural beauty of AONBs’.