Back to list Gatwick Airport Northern Runway

Representation by Tim North & Associates Ltd (Tim North & Associates Ltd)

Date submitted
27 October 2023
Submitted by
Members of the public/businesses

Introduction These representations are raised on behalf of my clients Holiday Extras Ltd, a leading UK distributor of on and off airport related car parking spaces. My client sells a range of holiday related products in addition to airport related car parking, including airport hotels, airport lounges, travel insurance and car hire. These products are sold directly to customers on their database which extends to approximately 6 million UK homes, as well as to a wide range of business partnerships and other travel related organisations. Representations were raised by my clients in November 2021 to the Autumn 2021 Pre-Application Consultation exercise entitled “Our Northern Runway: Making Best Use of Gatwick” with its underlying intention to bring the existing northern runway, currently restricted to use as a stand-by or for emergency purposes only, into routine operation alongside the main runway. Further representations were raised by Holiday Extras Ltd in July 2022 to the Consultation Document Summer 2022 “Our Northern Runway: Making Best Use of Gatwick – Highway Improvement Changes and Project Update”. Holiday Extras Ltd have sought at all times to support the Applicant in their underlying intention to bring the existing northern runway into routine operation alongside the main runway. They appreciate that what is now proposed will deliver significant socio-economic benefits both regionally as well as nationally. The publication “Beyond the Horizon – The Future of UK Aviation – Making Best Use of Existing Runways” (hereinafter referred to as MBU) published in June 2018, around the same time as the Airports National Policy Statement (ANPS), is a free-standing policy document updating the 2013 Aviation Policy Framework (APS). It confirms the Government’s support for airports beyond Heathrow making best use of runways, but this does not exclude DCO applications from being required to demonstrate a balance between economic benefits and environmental costs, including how the latter are to be mitigated. My client’s concerns surrounding the DCO application relate to the topic of airport surface access, with particular reference to on-airport passenger related car parking provision. Through their subsidiary company, Airparks Services Ltd, they have considerable experience in the provision of long term off-airport park and ride facilities, where customers cars are parked before they are transported by bus to and from the respective airport. A number of recommendations were raised by my clients in the two earlier consultation exercises which it would appear in a number of instances have not been addressed in subsequent documentation accompanying the current DCO application. Important Factors Surrounding Public Transport Provision The Applicant has limited control over external stakeholders involved in public transport provision, who pursue different policy objectives, and for which there is no coordinated procedure between different public transport providers. To this end the Applicant can only encourage new connections and services, as GAL is not the service provider, and neither does it control fares which are set by the public transport companies. In April 2018 the Government published a document entitled “Beyond the Horizon: The Future of UK Aviation – Next Steps Towards an Aviation Strategy” which took into account responses obtained from the Call for Evidence, as part of an early exercise in formulating an updated aviation strategy. It placed at the forefront of the aviation strategy the requirement to encourage aviation which it stated “helps to ensure that customers get the best deals and a quality of service”, with the Government committing itself to continue “to work with industry to make sure that the right level of competition exists to bring benefits to passengers.” The “Next Steps Towards an Aviation Strategy” document included six core objectives; paragraphs 6.42 and 6.43 being of relevance when examining surface access. The requirement for “surface access options to be developed in tandem” referred to in paragraph 6.42, requires in my client’s opinion, that an opportunity is afforded to lawful long term off-airport car parking providers to contribute to issues the proper remit of the Gatwick Airport Transport Forum, if only to ensure compliance with the Government’s overarching aim of placing consumers at the centre of its proposed Aviation Strategy. The phrase “surface access options” cannot be effectively considered at a time when long term off-airport car parking providers through the service they provide to airport passengers, are denied access to the Gatwick Airport Transport Forum, which in turn performs an important role in challenging and holding to account the Applicant in the delivery and monitoring of surface access impacts, alongside the provision of investment towards future sustainable transport infrastructure. The “challenge” referred to in paragraph 6.42 cannot be divorced from the fact that the Applicant considers that they should only expect to pay proportionately for transport schemes that have a direct and material impact on the airport, or which are triggered by the airport’s needs. In a similar way, improvements to the strategic road network, namely the M23 Motorway, can result in unintended consequences in terms of attracting less sustainable modes of access to the airport, i.e. “kiss-and-fly ”. These issues do not appear to have been addressed in the DCO application. To these considerations should be added the inherent contradiction between the Applicant’s understandable aim in its DCO application of focusing attention on public transport access to London Gatwick Airport; with the need to maximise revenue derived from passenger car parking income, itself an important component of non-aeronautical revenue for the Airport. Revenue received from forecourt charges paid by passengers; long term off-airport car parking operators and on-airport passenger car parking provision is the most important contributor supporting the Sustainable Transport Fund. It follows that the same revenue streams comprise important funding sources to the Airport Transport Forum in its consideration of future modal share, as well as allowing for investment in sustainable transport modes. Choice In December 2018 the Government published a Green Paper entitled “Aviation 2050 – The Future of UK Aviation” which comprised its draft Aviation Strategy, where the aim was to achieve a safe, secure and sustainable aviation sector that meets the needs of consumers and of a global outward-looking Britain. A number of long term off airport car parking applications have been found to occupy “sustainable locations” whilst at the same time offering “customer choice”. This is a matter confirmed in various Inspectors’ appeal decisions in Crawley Borough and Mid Sussex District Councils’ administrative areas, as well as in Case Officers’ reports granting planning permission for the same use outside the Operational Area of London Gatwick Airport . Clause 5.6.1 of the Section 106 Planning Obligation involving Crawley Borough Council, West Sussex County Council and Gatwick Airport Ltd, executed on 24th May 2022 has been reproduced below, from which it can be seen that the target of 48% of passengers travelling to the airport by public transport requires an assessment of combined on-and off-airport supply and not simply on-airport passenger car parking spaces. “5.6.1 Provide sufficient but no more on-Airport public car parking spaces than necessary to achieve a combined on and off airport supply that is proportionate to 48% of non-transfer passengers choosing to use public transport for their journeys to and from the airport by end of 2024.” This clause contained in the most up-to-date Section 106 Planning Obligation clearly points to the need for a joint approach with long term off-airport car parking providers. The 2022-2030 Airport Surface Access Strategy published in October 2022 (hereinafter referred to as the ASAS 2022-2030) goes further than the recently executed Section 106 Planning Obligation, in that Target 1 seeks to achieve 52% of passenger journeys to the airport by public transport by 2030 under the scrutiny of the Transport Forum Steering Group, as part of meeting a target of 60% by sustainable modes and ultra-low or zero emission vehicles. No new ASAS accompanies the DCO application. The Applicant indicated in their supporting material to the application that the following legally binding surface access interventions are intended to comprise commitments in the DCO application, intended to come into force three years after the opening of the new northern runway. • A minimum of 55% of air passenger journeys to and from the Airport is to be made by public transport (rail, local bus, regional/express bus or coach or another commercially-operated shared transport service for public use). • A minimum of 55% of staff journeys to and from the Airport to be made by public transport, shared travel (a journey made by private car containing more than one person) and active modes (walking and cycling). • A reduction of air passenger drop-off and pick-up car journeys at the Airport to a mode share of no more than 12% of surface access journeys; and • At least 15% of airport staff journeys to work originating within 8km of the Airport to be made by active modes. There remains a question over the role of the Government in monitoring or enforcing the appropriateness, effectiveness and environmental impacts of these commitments through Airport Transport Forums; a matter referred to in paragraph 4.35 of the December 2018 document “Aviation 2050 – The Future of UK Aviation”. It is argued that neither the 48% figure set out in the May 2022 Section 106 Planning Obligation nor the 52% figure in the latest version of the ASAS, nor indeed the 55% figure expected during the period between 2029 and 2047 as part of the “With Project” scenario is considered to be a challenging target, given that in the fourth quarter of 2017 (October to December), CAA’s O & D reveals that a public transport modal share figure of 48.3% was achieved. On the contrary, no evidence has ever been produced by the Applicant in their DCO application to demonstrate that long term off-airport car parking has prevented the target modal share figure in favour of public transport from being reached, whether outlined in the current or previous versions of an ASAS, or the current or earlier version of a Section 106 Planning Obligation. The expected target figure of 55% referred to in the DCO application is, in all probability likely to be met, when it is realised that non-UK business and leisure passengers are always more likely to use public transport than those living and working in the UK, a factor which becomes evident from the contents of page 248 of Document APP-260 found in the Examination Library. The Current Policy Approach Governing On-Airport Passenger Car Parking The ASAS 2022-2030 mentions under the title “Parking”. “Gatwick’s approach to parking is linked to our Section 106 agreement, with West Sussex County Council and Crawley Borough Council, specifically in regard to accommodating future demand growth on-airport in accordance with the Crawley Local plan policies GAT3. Gatwick has increased capacity in recent years sufficient only to cater for growth, and will continue to do so where justified and allowing for mode shift to sustainable travel modes.” It is not simply not possible to reconcile the approach sought in this paragraph taken from the current version of the ASAS 2022-2030 with the contents of Obligation 5.6.1 set out in the latest executed Section 106 Agreement, referred to earlier in these representations, at a time when there has been no open and transparent dialogue between the Applicant and lawful long term off-airport car parking operators. Existing Policy GAT3 set out in the statutorily adopted Crawley Borough Local Plan 2015-2030 is concerned with “Gatwick Airport Related Car Parking” in which both limbs are required to be met before additional or replacement airport-related parking can be permitted on-airport. In this regard, limb 1 of Policy GAT3 states “The provision of additional or replacement airport parking will only be permitted within the airport boundary.”. Limb 2 says “All proposals must be justified by demonstrable need in the context of proposals for achieving a sustainable approach to surface transport access to the airport.” This policy which forms the foundation surrounding the topic of “Parking” in the latest version of the ASAS 2022-2030 is based on a false premise, being fundamentally flawed and taking no account of, or being inconsistent with the provisions of Schedule 2 Part 8 Class F of the Town & Country Planning (General Permitted Development) (England) Order 2015 (As Amended). The Applicant on “Operational Land ” can construct surface car parking or build multi-storey car parks in accordance with permitted development rights, for which no express planning permission is required and more importantly, without having to justify “… a demonstrable need in the context of proposals for achieving a sustainable approach to surface transport access to the airport.” In these circumstances, Policy GAT3 is unnecessary, serving no valid purpose; a position which appears to be accepted by the Applicant given the comment raised in a statement accompanying the planning consultation for a proposed Multi-Storey Car Park 7 (MSCP7) submitted to Crawley Borough Council under Application No. CR/2019/0878/CON, in which it is stated: “… development plan policies have no weight for permitted development”. That said, it is noted that the DCO application has triggered the need for an Environmental Impact Assessment (EIA) with the result that a planning application is required. Those acting on behalf of Holiday Extras Ltd can find no information in which the Applicant has sought to ensure that permitted development rights in accordance with Schedule 2 Part 8 Class F of the Town & Country Planning (General Permitted Development) (England) Order 2015 (As Amended) are to be applied as part of the DCO application, with no formal screening opinion confirming the same. In effect, operational development relating to car parking provision on-airport where it comprises part of the DCO application would not benefit from permitted development rights. No reliance has been placed on permitted development rights in the provision of proposed on-airport car parking forming part of the DCO application, with the consequence that no safety valve is available as part of the same proposals to meet unforeseen demand in terms of the need for additional airport related car parking provision. It is contended that lawful long term off-airport car parking proposals have an important role to play in airport related car parking supply, to the extent that without their involvement, GAL would face serious difficulties in accommodating all airport related passenger car parking needs on-airport, both now and into the future. The Applicant as part of their DCO application no longer seek to pursue the aim of providing additional on-airport passenger car parking spaces, as part of an intention to assist neighbouring authorities remove existing unauthorised off-airport parking in areas around London Gatwick Airport. This is in spite of this earlier aspiration lacking any agreed mechanism setting out how the desired aim was to be fulfilled. Factors Influencing Long Term Airport Related Car Parking It is relevant to indicate that Gatwick Airport Ltd have little influence over airport-related car parking demand, which is calculated by way of a series of assessments of how many passengers or movements can be handled over a busy hour. There is no simple definition of airport capacity. It is influenced by a range of individual capacities which themselves are derived from a number of separate parameters, including i) flight departure and arrival times; (ii) runway length; iii) apronage; iv) passenger terminal facilities; v) surface access, along with imposed restrictions governing environmental considerations. Airport related car parking demand in a similar way is also influenced by a considerable variety of issues, including availability of a private car; accessibility to public transport modes; price, with comparisons made with public transport, along with the particular parking product; the role played by low-cost carriers in route selection and journey frequency; intensity of hourly arrival and departures based on slot allocations; highway capacity; historic parking demand; and estimated non-UK leisure and business passenger throughput; to name some of the more important factors. Equally relevant is a wide variety of considerations falling under the umbrella of customer behaviour. These involve needs and attitudes in making air travel decisions encompassing matters such as safety, security and more recently the COVID-19 pandemic, to passenger catchment areas and route overlaps with competing airports. The ability and willingness of passengers to switch airports to suit their particular preferences, based for example on preferred flight departure and arrival times, depends in part on the extent to which the customer regards services at a particular airport as reasonably close substitutes, along with the cost faced in switching demand to the best alternative. This vast array of material considerations governing long term airport related car parking demand and supply requires a flexible approach to be taken, especially when it is appreciated that the current DCO application is to take place over a 24 year period, where levels of uncertainty are expected to impact on passenger throughput. It is for this reason that a collaborative approach should be adopted with respect to lawful long term off-airport car parking companies whose presence play an important role in future airport related car parking provision. The Relationship Between Airport Related Hotel and Passenger Car Parking Provision Historically there has been a relationship between off-airport hotels and long term off-airport car parking sites, where the former are situated in close proximity to London Gatwick Airport. It is contended that both existing and future car parking provision associated with off-airport hotels found in close proximity to London Gatwick airport cannot be adequately accommodated on-airport. This is due to the Applicant needing to satisfy all other passenger car parking products, including the needs of airport staff and the various special offers which GAL promotes to the local community. Recent applications seeking the growth of on-airport hotels reveal an absence of associated car parking provision for the particular on-airport hotel, resulting in additional pressure on existing on-airport passenger car parking provision. Application No. CR/2010/0692/FUL granted a change of use of Longbridge House, a former office building, to a hotel along with the construction of two further floors and changes to the external appearance of the building, with the hotel being opened in early 2014. The car parking associated with the same hotel amounting to 60 spaces to service 192 rooms was carved out of the staff car parking area known as Car Park M. It is GAL’s intention to redevelop what was previously known as Car Park M including the area used for car parking by the Hampton by Hilton Hotel, as a new Multi Storey Car Park 7 (MSCP7). A total of 60 spaces in the new multi storey car park was intended to be made available for parking use by the Hampton by Hilton Hotel. During the construction of MSCP7 it is understood that GAL will be making provision in either MSCP5 or MSCP6 (two existing multi-storey car parks situated at the North Terminal) for the hotel’s use. It is important to note the justification set out in the Case Officer’s Report for granting permission to remove Condition No. 3 attached to Application No. CR/2010/0692/FUL:- “The principal concern with the removal of this condition is that if the hotel has no parking then it won’t be able to meet its own operational requirements and that this in turn would adversely impact upon the operation of the roads around the airport. This in turn could result in parking in places that could affect highway safety or result in congestion. GAL has stated that it would provide 60 parking spaces within its existing car-parks for use by hotel visitors. This would however be outside the red-line of the application site and so would therefore be difficult to control through the planning process. The removal of this condition would therefore effectively result in GAL controlling the parking for the hotel as their public car-parks would be available in close proximity to be used by visitors. The application is therefore being considered on the basis that no specific parking will be provided for the hotel. It is recognised that the hotel is located immediately adjacent to the North Terminal with its existing multi storey car-parks and drop off and pick u p points. It is therefore considered that visitors to the hotel arriving by car can still be dropped off close to the hotel at locations already provided for these purposes, and specifically provided for all visitors to the airport and its associated uses such as the on airport hotels. It is recognised that whilst North Terminal is not quite as easy to access by public transport as the South Terminal, (where the railway station and main area of bus stops are located), the provision of the internal rapid transit system however results in there being good access to public transport for both South and North Terminals. It is therefore considered that Gatwick Airport, and this hotel within its boundary is a relatively sustainable location. The airport already provides approximately 40,000 on airport car-parking spaces for visitors, for both long and short term stays. There are also significant numbers of off airport car-parking spaces available. It is therefore considered that the existing stock of off and on airport car-parking spaces available could accommodate both the short and long term requirements of passengers using this 192 space hotel. The roads around Gatwick Airport are subject to extensive controls to ensure that there is no unauthorised parking, and there are also controls on the major access roads/dual carriageways/M23 restricting parking. The closest on street parking is therefore outside the airport (and Crawley Borough) boundary in Horley to the north-east and Hookwood /Povey Cross to the north. Given the overall scale of parking, and parking provision at Gatwick Airport, and the services available to hotel users, it is not considered that removing the 60 spaces from this hotel, in the context of approx. 60,000 predominantly on and also ff airport car-parking spaces already being available, would be likely to result in increased pressure on these neighbouring areas.” The following conclusions emerge from recent applications relating to on-airport hotel accommodation. • Firstly, recent applications seeking on-airport hotel development reveal an absence of any dedicated car parking. The suggestion that this situation will encourage sustainable access to the airport is unsupported by any evidence. • Secondly, the absence of dedicated car parking for recent on-airport hotel developments has meant that passengers are having to use existing on-airport passenger car parks, resulting in increased pressure being placed on available on-airport car parking spaces. • Thirdly, the absence of dedicated car parking associated with recent on-airport hotel development has the propensity to encourage the least sustainable mode of access to the airport, namely drop-off and “kiss-and-fly”. • Fourthly, the absence of dedicated on-airport car parking places reliance not only on existing on-airport passenger car parking spaces, but also off-airport car parking provision, which hotel customers are encouraged to use. The Applicant’s DCO application contains four separate locations forming part of the preferred options for hotel development on land at the South Terminal, to comprise in total 1,250 additional on-airport bedrooms. In contrast to the Summer 2022 consultation exercise in which three locations were proposed for hotel development on-airport, four locations for on-airport hotel development are proposed. Two of the preferred locations in the DCO application are commensurate with proposals in the earlier Summer 2022 consultation exercise, with one of the current four locations not forming part of the Summer 2022 consultation. The four locations are as follow: • A new hotel on existing Car Park H comprising up to 400 bedrooms known as Option G1 to form part of a mixed use development on the same land where a multi storey car park is also proposed to be sited catering for 3,700 spaces, along with office accommodation to include an addition 350 sq.m. to replace office floorspace lost through the conversion of Destinations Place to a hotel. This preferred option involves the loss of car parking which is expected to be provided elsewhere within the airport boundary. • A new hotel on the former car rental site comprising up to 200 bedrooms known as Option G3. This site is located within a flood plain, meaning that this option is not deemed fully compliant with policy. Its deliverability will be affected by the proximity to the South Coast Mainline railway between London and Brighton. No comments are raised on the relocation of the former rental car parking facility. • A new hotel adjacent to and north of Multi-Storey Car Park 3 (MSCP3) known as Option G4 accommodating up to 400 bedrooms. This site comprises an existing surface car park with it is said minimal flood risk, although the DCO application confirms further exploration of this factor is required. • A new hotel involving the conversion of Destination Place being an existing office building known as Option G5 and catering for approximately 250 bedrooms. The Applicant states that GAL will need to demonstrate the loss of office space which is not considered to be detrimental. The Importance of Technological Platforms In my client’s view, the DCO application has taken inadequate account of recent dramatic changes in passenger behaviour in accessing airports. Various players operate in this market, to the extent that it is too simplistic to assess airport related car parking through the prism of long term on-airport and long term off-airport provision. In recent years there has been a rise in a number of technological platforms which match drivers with car parking spaces through their websites and apps, representing part of what has been referred to as the “sharing economy”. JustPark is one example, which has as its mission to transform the way drivers look for parking spaces, whilst delivering cash to homeowners who rent out their driveways, enabling other businesses such as hotels to maximise their income from airport related car parking as part of “stay and fly” package. JustPark has claimed that over 23% of car journeys involve some kind of parking pain – that is, 190 million trips per month, with drivers suffering from both uncertainty (availability, prices, restrictions, etc) and inconvenience (full car parks, slow payments, fines) on a daily basis. It operates in the airport related car parking market, and has as its remit, amongst other facts, assisting hotels to maximise their revenue from their parking spaces by “driving new customers to your car park and optimising your yield through dynamic prices”. Its operation extends to over 300 hotels in the UK including the Marriott, Hilton, Premier Inn and Holiday Inn, managing their car parks more effectively and resulting in a 20% increase in parking revenue and a 96% customer satisfaction. The Significance to be Attached to Transportation Network Companies (TNCs) Another entrant extending choice in the airport related car parking market are Transportation Network Companies (TNCs) such as Uber, where vehicles are booked using ride hailing services. Insufficient attention has been paid to this mode in the DCO application, which is considered to be one of the least sustainable means of accessing London Gatwick Airport. It operates in the same way as historically AirBnB has helped people share their houses with holiday makers, with companies such as Uber and Lyft allowing drivers to share their cars with passengers. TNCs such as Uber comprise the first of a number of new mobility options which in time may include connected or autonomous vehicles (CAVs). TNCs generate substantially less revenue per passenger than on-airport parking, taxis or rental cars, effectively reducing the airport’s income, whilst at the same time adding to traffic congestion with the possibility of increased air pollution. Research relating to New Yorks’ three airports supports the view that TNCs have resulted in a sizeable reduction in on-airport passenger car parking. The growth of TNCs means that passengers are effectively trading down from a higher trading product or taxi service to a lower revenue, higher volume TNC product. London Heathrow Airport in its “Surface Access Proposals” published in June 2019 support this underlying theme, stating “The popularity of app-based ride-hailing services, such as Uber, has increased significantly in recent years, and they must now account for more than a quarter of all taxi and private trips made to or from the airport.” As a consequence, the significance to be afforded to private hire vehicle (minicab) mode of surface access has expanded, despite representing, along with “kiss-and-fly”, the least sustainable mode of access to the airport. It is considerations of the kind referred to above, which give rise to major concerns being raised by my clients over the extent to which changes in customer behaviour is likely to lead to unintended consequences, seen in terms of increasing the least sustainable modes of access to the airport. In these circumstances, factors associated with travel cost/price of on-airport car parking comprise components of passenger car parking demand which become increasingly significant in decisions reached by passengers on whether to rely on public transport to access London Gatwick Airport. Issues Relating to Passenger Profiling and Demand Management Passenger profiling techniques have not been explored in the DCO application in order to understand anticipated changes in customer behaviour. In this regard customer profiling means assessing the popularity of certain destinations, flying frequency, trip duration and trip frequencies as part of a greater understanding of the cyclicality of passenger parking demand throughout the year. Furthermore, no detailed consideration has been given to demand management measures including sensitivity testing particularly the extent to which variations in access charges for taxis/minicabs and “kiss-and-fly” modes, is likely to influence modal share to the airport especially at peak flight arrival and departure periods. Future On-Airport Car Parking Provision The additional on-airport passenger car parking capacity in the absence of “the Project” in the future baseline scenario, is set out at paragraph 3.6.70 of Chapter 3: Alternatives Considered of the Environmental Statement July 2023 to the current DCO application: • Reconfiguration of the existing Hilton Hotel to provide 50 additional bedrooms and 820 parking spaces • Multi Storey Car Park 7 (MSCP7) (North Terminal – 3,250 additional spaces) • Use of Robotics technology within existing long stay car parking areas to increase capacity, resulting in an addition 2,500 spaces. The proposed additional passenger car parking forming part of “the Project” is provided in Table 5.2.3 of Chapter 5: Project Description comprising part of the Environmental Statement July 2023 to the current DCO application, the details of which have been reproduced below:- • North Terminal Long Stay Decked Parking (the footprint of which is recorded at 7.9ha at a maximum height above ground level of 11m) (estimated 1,680 spaces). • Car Park J Multi Storey (the footprint of which is recorded at 1ha at a maximum height above ground level of 27m) (estimated 890 spaces) • Car Park Y Multi Storey ((the footprint of which is recorded at 1.9ha at a maximum height above ground level of 27m) (estimated 3,035 spaces) • Car Park H Multi Storey (the footprint of which is recorded at 1.5ha at a maximum height above ground level of 27m) (estimated 3,700 spaces) • At the Existing GAL Purple Parking Valet site the footprint of which is recorded at 2.9ha at surface level only) (estimated 700 spaces) It can be seen that the total proposed additional passenger car parking with “the Project” encompassed 15.2ha of land amounts to 10,005 estimated spaces. The numbers of existing on-airport car parking spaces in the Summer of 2019, the last full year pre-Covid, is provided at Table 4.2.2 set out in Chapter 4: Existing Site and Operation of the Environmental Statement 2023 comprising part of the current DCO application. Table 5.2.4 under the title “Car Parking Proposals” forming part of Chapter 5: Project Description of the Environmental Statement 2023 purports to show details of on-airport car parking spaces permanently lost; proposed replacement on-airport car parking spaces, and proposed additional on-airport staff car parking spaces. The Need for a Replacement Table 5.2.4 in Chapter 5 of the Environmental Statement 2023 My clients raised representations to Table 3.1 contained in the Summer 2022 Consultation Document “Our Northern Runway: Making Best Use of Gatwick – Highway Improvement Changes and Project Update” on the basis that it was considered to be incorrect and misleading. It remains my client’s view that the details set out in Table 5.2.4 under the title “Car Parking Proposals” forming part of Chapter 5: Project Description of the Environmental Statement 2023 replacing Table 3.1 in the Summer 2022 Consultation Document, are equally confusing, unclear and in certain cases simply incorrect. The only exception to this criticism is in the explanation afforded to the relocation of Purple Parking and the displacement of spaces concerning Car Park X, referred to in paragraphs 5.2.86 to 5.2.88 of Chapter 5: Project Description forming part of the Environmental Statement July 2023, What is required is a table replacing that found at Table 5.2.4 of Chapter 5 of the Environmental Statement July 2023. The replacement table should set out the numbers of existing and proposed passenger and staff car parking spaces for each on-airport car park. In this way it should include the three locations comprising the future baseline scenario in the absence of “the Project”, referred to in paragraph 3.6.70 of Chapter 3: Alternatives Considered, comprising part of the Environmental Statement July 2023, along with the five locations under the “With Project” scenario set out in Table 5.2.3 of Chapter 5: Project Description comprising part of the Environmental Statement July 2023. The same replacement table should have as its basis the contents of Table 4.2.2 Existing Car Parks found at page 4-5 of Chapter 4: Existing Site and Operations forming part of the Environmental Statement July 2023, together with Figure 5.2.1h found in Document APP-053. Three separate columns should be provided for each on-airport car park, including the sites referred to in the previous paragraph of these representations. These three individual columns should indicate (i) the number of existing passenger and/or staff car parking spaces retained; (ii) the number of new passenger and/or staff car parking spaces to be provided, and (iii) the resultant number of displaced passenger and/or staff car parking spaces as a result of either proposed additional passenger car parking provision comprising part of “the Project”; or as a consequence of other forms of development comprising an integral part of the same DCO application replacing the existing passenger and/or staff car parking spaces at the particular car park. Future Baseline Scenario in the Absence of “The Project” Reconfiguration of the existing Hilton Hotel to provide 50 additional bedrooms and 820 parking spaces In the case of the Hilton Hotel forming part of Future Baseline Scenario in the absence of “the Project”, planning permission was granted by Crawley Borough Council under Reference No. CR/2018/0337/OUT for the erection of a multi storey car park, in which all reserved matters were considered at the outline stage, with the exception of landscaping. Reserved matters for the landscaping were subsequently approved under Application No. CR/2019/0885/ARM. A subsequent application Reference No. CR/2020/0575/NCC was granted planning permission for variation/removal of Condition 3 (approved plans) and Condition 9 (amended building height) pursuant to Application No. CR/2018/0337/OUT. The Case Officer’s delegated report on Application No. CR/2020/0575/NCC added: “It should be noted that this standard [854 spaces for an 821 bed hotel] is not representative for a hotel at an on-airport location where guests often stay a night and travel from the airport, leaving the car. It is therefore proposed that demand for parking for Hilton Hotel users could be higher than the number of spaces proposed. However, demand can be accommodated on other airport parking sites although with the erection of this car park this is likely to be lower than is currently the case.” It can be seen that given the nature of this hotel directed at passengers using London Gatwick Airport has led to doubts being expressed as to whether the quantity of car parking spaces provided is sufficient especially during those busy periods of the year. The provision of an addition 50 bedrooms is likely to lead to further doubts being expressed on the sufficiency of car parking spaces, with added pressure placed on existing long term on-airport passenger car parking provision. This is in spite of the 820 spaces including the provision of undercroft car parking. A more realistic figure of available car parking spaces in the baseline scenario is 811 as referred to in Application No.CR/2020/0757/NCC Multi-Storey Car Park 7 Application No CR/2019/0878/CON sought consultation from the Local Planning Authority on the erection of Multi-Storey Car Park 7 in which it was stated that the footprint of the building would be commensurate with existing surfaced Staff Car Park M. Application No. CR/2019/0878/CON sought permission for a seven-storey building 25-30m high, constructed on land previously used as Staff Car Park M, along with car parking dedicated to the Hampton by Hilton Hotel. The supporting statement to the same application stated “The main purpose of the development is to provide increased passenger parking at the airport in line with Gatwick’s Car Parking Strategy which sets out Gatwick Airport Limited’s (GAL) forecasts and investment plans for providing additional on-airport car parking”. (my emphasis) A total of 463 surface car parking spaces are provided in Car Park M, as noted in Table 4.2.2 Existing Car Parks comprising part of Chapter 4: Existing Site and Operation comprising part of the Environmental Statement July 2023. The supporting documentation to the same application stated that “The proposed MSCP7 development will not have parking spaces allocated for staff and the existing 450 staff car parking spaces at the current Staff Car Park M will be reallocated within other staff car parks including Y, B, H and Z.”(my emphasis) Application No. CR/2020/0707/NCC granted planning permission on 26th April 2021 sought the removal of Condition No. 3 pursuant to Application No. CR/2010/0692/FUL, itself granted planning permission for the original Hampton by Hilton Hotel, along with two further floors and changes to the building’s external appearance. The covering letter of support to Application No. CR/2020/0707/NCC referred to 60 standard car parking spaces along with four blue badge spaces used in connection with the hotel, being provided within what was known as surface Staff Car Park M, before adding “I can advise that on completion of the planned MSCP7, it is intended that 60 of its parking spaces will be made available for parking use in connection with the hotel.”(my emphasis) The PEIR Chapter 4: Existing Site and Operations September 2021 Appendix 12.9.1: Preliminary Transport Assessment Report (PTAR) paragraph 8.5.15 states “Staff car parking provision in Car Park M is expected to become a new multi storey car park for passengers, with parking provision for staff moving across to Car Park H in the Future Baseline Scenario, and Car Parks X and V in the With Project Scenario, with the additional closure of Car Park Y to staff.” (my emphasis) PEIR Chapter 4: Existing Site and Operations September 2021 Appendix 12.9.1: Preliminary Transport Assessment Report (PTAR) paragraph 8.5.15 reveals that Car Parks X and V are found on the southern side of the airport. The same area is referred to in Figure 5.2.1h comprising part of Examination Library Document APP-053 as Car Park X where Purple Parking is to be re-provided. The contents of paragraph 5.2.86 to 5.2.88 of Chapter 5: Project Description forming part of the Environmental Statement July 2023 refers to the relocation of the Purple Parking facility to the eastern section of the existing Car Park X, which will displace 1,125 on-airport car parking spaces from Car Park X, which in turn will be accommodated on the re-used existing Purple Parking site. The former Purple Parking decking will be demolished and in its place surface parking to cater for 700 car parking spaces, partially providing for the displaced 1,125 spaces from Car Park X. The remaining 425 spaces from Car Park X are to be accommodated through an increase in capacity in the North Terminal Long Stay Car Park. Three important conclusions arise from the reallocated Purple Parking provision. Firstly, what is referred to in the PEIR September 2021 consultation outlined above as Car Parks X and V are not available to accommodate any relocated staff parking from elsewhere on the airport. Secondly, not all the car parking to be provided at the North Terminal Long Stay Car Park will be proposed additional spaces, as 425 of the spaces will be those decanted from Car Park X. Thirdly, there is no evidence found in the current DCO application that Multi Storey Car Park 7 is to accommodate any parking spaces for the exclusive use of the Hampton by Hilton Hotel. The proposition that staff car parking decanted from Staff Car Park M as a direct result of its redevelopment as a multi storey car park, will be reallocated to Staff Car Parks Y, B, H & Z equally lacks any sound basis, as explained below. Firstly, PEIR Chapter 4: Existing Site and Operations September 2021 Appendix 12.9.1: Preliminary Transport Assessment Report (PTAR) paragraph 8.5.15, a document of recent origin, reveals no intention to relocate staff car parking to Staff Car Parks Y, B, and Z. Secondly, Staff Car Park Y is to be redeveloped as a new Multi-Storey Car Park Y on the same site, catering for 3,035 additional passenger car parking spaces to cater for the development the subject of the current DCO application. No information is provided in the current DCO application confirming that staff car parking decanted from Staff Car Park M, is to be provided in Multi Storey Car Parks Y. Thirdly, Staff Car Park H is to be redeveloped for mixed use purposes including office accommodation, a new 400 bedroom hotel and additional multi-storey passenger car parking with a complement of 3,700 spaces. It is to provide additional passenger car parking to cater for the development the subject of the current DCO application. No information is provided in the current DCO application confirming that staff car parking decanted from Staff Car Park M, is to be provided in Multi Storey Car Parks H. Fourthly, Staff Car Park B accommodates 414 car parking spaces as set out in Table 4.2.2 of Chapter 4: Existing Site and Operations forming part of the Environmental Statement 2023. It operates at full capacity, as evident from aerial photographs, being an important component of staff car parking, and to this end it is not feasible that Staff Car Park B could accommodate the 463 staff car parking spaces to be lost from Staff Car Park M. It is noted that the contents of paragraph 5.2.89 of Chapter 5 Project Description of the Environmental Statement 2023 reveals:- “5.2.89 No increase in car parking for airport staff is proposed and where staff parking is located may change as a result of the Project works. Historically Gatwick had around 7,200 spaces for staff. However, as staff car mode share has decreased, GAL has taken steps to reduce this by over 1,000 spaces in the last five years. GAL is currently reviewing the optimum allocation of spaces and location for these staff spaces, taking into account an increase in staff numbers and the changing work patterns but alongside promoting use of more sustainable travel to work, including car sharing and active travel. Overall, it is proposed to continue to reduce the total number of spaces provided per 1,000 employees across the airport.” The conclusion to arise from this section found under the title “Multi Storey Car Park 7” is that the Examining Authority are provided with no information of where the Applicant’s staff car parking will be provided on-airport in the future, and at what quantity. This is an important consideration given what has been stated in this section regarding possible locations for staff car parking in the future elsewhere on-airport, at a time when the Applicant confirms there will be an increase in staff numbers. Furthermore, future staff car parking provision has to be looked at in the context of Table 5.2.3 set out in Chapter 5 Project Description of the Environmental Statement July 2023 which is specifically concerned with proposed additional passenger car parking provision in connection with “the Project. Use of Robotics technology within existing long stay car parking areas to increase capacity, resulting in an additional 2,500 spaces. Application No. CR/2018/0935/CON was a consultation by GAL relating to a robotic car park pilot project to take place on part of Car Park B and to last for a period off three months, following which a decision was to be taken on whether the same robotic parking product offered a viable future car parking alternative for London Gatwick Airport. The Examining Authority has been given no information on how much space will be taken up by these cabins, how many cabins are expected to be provided on-airport in Car Park B, and to what extent the existing the introduction of robotic parking provision. Additional Passenger Car Parking forming “The Project” North Terminal Long Stay Decked Parking The Examining Authority have not been provided with any information, and hence do not know how many car parking spaces in Zones U, X, Y, Z and parts of Zone V and W comprising the existing North Terminal Long Stay Car Park area are to be retained, where they remain unaffected by the proposed decked car park over part of the same area. No information has been provided by the Applicant of the number of passenger car parking spaces attributable solely to the decked parking in the North Terminal Long Stay area. Furthermore, no information is provided to the Examining Authority, who are in the same position as my clients, over how many passenger car parking spaces are to be retained, where they remain unaffected by the proposed decking in the North Terminal Long Stay Car Park area. No information is provided of the impact of the proposed realignment of Larkins Road and the relocation of the motor transport facility on the number of passenger car parking spaces to be retained in Zones V and W. In short, the approximate figure of 1,680 car parking spaces to form part of the proposed additional car parking in Table 5.2.3 does not indicate to the reader how many existing passenger car parking spaces are to be retained in the North Terminal Long Stay area; and how many existing passenger car parking spaces in the North Terminal Long Stay area are to be lost by the decking due to ramps, lighting, circulation space etc. The manner in which existing, proposed and displaced passenger/staff car parking information is provided for each of the selected areas in Table 5.2.4 is important to the Examining Authority as well as to those making representations to the DCO application. At present, there is simply no indication of how the figure of 2,465 permanently lost spaces in the North Terminal Long Stay and Flying Pan has been derived in Table 5.2.4 of Chapter 5 Project Description forming part of the Environmental Statement to the DCO application. Multi Storey Car Park J Similar circumstances arise in respect of Multi Storey Car Park J in which Table 5.2.3 refers to an approximate number of additional passenger car parking spaces amounting to 890. The same table takes no account of the fact that Multi Storey Car Park J lies in the same location as existing surface Staff Car Park J where, in accordance with the details provided in earlier consultation applications, a total of 361 spaces are expected to be lost. No information is provided by the Applicant confirming the number of staff car parking spaces in Car Park J, with no indication given where any of these displaced staff car parking spaces or a proportion of the same are to be provided on-airport. It is misleading to state that Multi Storey Car Park J will involve 890 proposed replacement spaces as set out in Table 5.2.4 Car Parking Proposals, given that what is intended in this location is a reduction of 361 surface level staff car parking spaces. That said, Table 4.2.2 Existing Car Parks set out in Chapter 4 Existing Site and Operation of the Environmental Statement July 2023 makes no reference to Staff Car Park J. Multi Storey Car Park Y The circumstances surrounding the displacement of staff car parking in the location of Multi Storey Car Park J equally applies to the location of Multi Storey Car Park Y. Table 5.2.3 indicates that there will be approximately 3,035 additional passenger car parking spaces in Multi Storey Car Park Y, but this takes no account of the fact that the same location is used for surface staff parking and where, according to Table 4.2.2 Existing Car Parks found within Chapter 4: Existing Site and Operations comprising part of the Environmental Statement July 2023, there will be a loss of 916 spaces. No information is provided as to where any of these lost staff car parking spaces or a proportion of them are to be accommodated elsewhere within the Airport’s boundary. In this way, what is proposed in this location is a reallocation of existing surface staff car parking with a new multi-storey passenger car park accommodating 2,074 net additional spaces. Multi Storey Car Park H In accordance with Table 5.2.4 proposed Multi Storey Car Park H is expected to provide for an additional 3,700 passenger car parking spaces. Table 4.2.2 Existing Car Parks set out in Chapter 4: Existing Site and Operations of the Environmental Statement July 2023 refers to the fact that Car Park H currently comprises a total of 1,170 staff car parking spaces. The area taken up by former staff surface Car Park H is to accommodate office floorspace lost through the conversion of Destination Place to a hotel; along with a new 400-bedroom hotel, together with a proposed multi storey passenger car park catering for an addition 3,700 spaces. It can be seen that what is proposed is a net additional 2,530 spaces. Other Permanently Lost Car Parking Space Provision Summer Special Historically, two sub-areas relating to the Summer Special on-airport passenger car parking site can be recognised. A northern sub-area previously known as the Summer Special Car Park, consisting of a rectangular shaped area situated to the south of Zones V and W comprising part of the Northern Terminal Long Stay Car Park area, This area lies contiguous to an area referred to as the Summer Special (South) Car Park, which was the subject of an application submitted to the Local Planning Authority under Reference No. CR/2007/653/CON seeking the refurbishment of the car park; although Crawley BC appear to have no record of its original use as a car park. Later extensions situated to the west of Zone W, also comprise part of the Summer Special Car Park area. Table 4.2.2 Existing Car Park found within Volume 4 Existing Site and Operation of the Environmental Statement July 2023 records the Summer Special Long Stay Car Park as accommodating 5,277 spaces which is a figure lower than that in a car park update presented to a meeting of the Gatwick Airport Consultative Committee on the 26th January 2017, at which time a figure of 5,956 spaces was recorded, even though there has been no further consultation applications lodged with Crawley BC regarding this car park over the past six years. It is evident from details outlined in the Environmental Statement forming part of the DCO application and a comparison of Figures 4.2.1c and 5.2.1a that the area consisting of the Summer Special (South) Car Park is to be removed in its entirety as a consequence of the northerly extensions of Taxiways Lima and Unicorn along with the construction of Pier 7 and stands. In a similar way, the extension of the Summer Special long term passenger car parking area found to the west of Zone W is to be removed as a consequence of the construction of a new aircraft hangar for Code E aircraft; the relocated motor transport facility and the Rendezvous Point North, the latter comprising a large area of hardstanding for external emergency vehicles (police, ambulance and fire services) required as a holding position in the event of a notified aerodrome incident. The only part of the Summer Special to be retained for long term on-airport passenger car parking comprises the northern rectangular sub-area lying to the south of Zones V and W. Table 4.2.2 Existing Car Parks found within Chapter 4 Existing Site and Operation, reveals a total of 5,372 spaces comprising the existing Summer Special car parking area, with paragraph 5.2.84 indicating that 3,345 spaces will be permanently lost as a consequence of “the Project”, resulting in the retention of only 1,932 spaces. This figure however is not readily apparent from Table 5.2.4, since it does not indicate the total amount of on-airport passenger car parking on all the land comprising the Summer Special area, nor more particularly, does it reveal the residue spaces in the Summer Special area expected to be retained for long term on-airport passenger car parking purposes, as they will remain unaffected by “the Project”. North Terminal Long Stay and Flying Pan Reference has already been made in these representations to the North Terminal Long Stay car parking area and the difficulties confronting the Examining Authority on the numbers of passenger car parking spaces currently provided on the same site; the numbers of new passenger car parking spaces to be delivered as part of the proposed decking, and the numbers of displaced passenger car parking spaces, resulting either from the proposed additional car parking provision comprising “the Project”, or as a consequences of other development forming part of the DCO application. No reason has been given for combining the long stay passenger car parking area known as North Terminal Long Stay, with the separate area known as the Flying Pan, which has been used for valet car parking purposes. The contents of paragraph 5.2.84 of Chapter 5 Project Description forming part of the Environmental Statement July 2023 reveals that in the North Terminal Long Stay and Flying Pan areas, there will be a loss of 2,465 spaces, although there is an absence of any information as to how this figure of permanently lost on-airport car parking has been derived. All passenger on-airport car parking on the Flying Pan site is to be removed as the same area is to be redeveloped as a Central Area Recycling Enclosure consisting of a biomass boiler, a waste processing building together with a compound area and bin store, along with a flue extending to 50m in height above existing floor level. The Examining Authority will no doubt wish to understand how many long term passenger car parking spaces will be lost from the Flying Pan as part of the overall loss of long term passenger car parking spaces from the combined area incorporating the North Terminal Long Stay and Flying Pan areas. Staff Car Parking W, B & H The contents of Table 5.2.4 found in Chapter 5 Project Description comprising part of the Environmental Statement July 2023 reveals that 1,150 staff car parking spaces will be lost on Staff Car Parks W, B and H, but this figure does not accord with the totals relating to the same staff car parks found in Table 4.2.2. of Chapter 4 Existing Site and Operation. No explanation is provided explaining the difference in the figures relating to the combined car parking spaces associated with these three sites. Other Material Considerations Relating to On-Airport Parking Provision An area known as Valet MA-1 comprises a long stay passenger car park on the southern side of the airport accommodating 5,372 cars. The Annual Gatwick Airport Long Term Car Parking Monitoring Statement, in referring to Valet-MA-1, have sought to amalgamate a number of car parks on the southern side of the airport. The writer can find no consultation application having been submitted by the Applicant to the Local Planning Authority relating to Car Park MA-1, casts doubting on its lawfulness, in the light of the provisions of Schedule 2 Part 8 Class F.2:- “Development is permitted by Class F subject to the condition that the relevant airport operator consults the local planning authority before carrying out any development unless that development falls within the description in paragraph F.4.” No information is available which confirms that the valet parking taking place on land known as MA-1 was “urgently required for the efficient running of the airport”, in accordance with paragraph F.4. The consultation process relating does not give rise to planning permission as defined in the Town & Country Planning Act 1990 (As Amended), and to the end, doubts must be expressed as to whether Car Park MA-1 is capable of being granted retrospective planning permission in accordance with Section 73A of the same Principal Act. It is noted that the area referred to as Car Park MA-1 is to become the main contractor compound forming part of the current DCO application. It follows that this area will, for the duration of the project, be unavailable for its current purposes of long term passenger car parking, and therefore should be deleted in any revised Table 5.2.4. In addition to the main contractor compound found in Valet Park Area MA-1, a number of satellite contractors’ compounds are to be provided on-airport, as part of the “the Project”, which includes long term on-airport passenger Car Park Z situated on the south side of the airport, which at present accommodates 570 spaces. This car park is expected to provide a staging and laydown area, offices and welfare facilities, parking for 20 cars, 2 vans and HGVs, a mobile crusher and a warehouse. Similarly, Staff Car Park Y found to the north of the airport located off Northgate Roundabout, is to be used for a material storage area with a processing plant, storage and laydown areas, a wheel washing facility for HGVs, site offices and welfare facilities, a mobile crusher and loader and a warehouse. Conclusions It can be seen that the supply of land on-airport is severely restricted, resulting in considerable losses of both existing passenger and staff car parking areas, as a consequence of being either redeveloped or remodelled to satisfy alternative requirements of “the Project” including the necessary compound facilities. The Examining Authority is required to satisfy itself that the DCO application in its current format will meet the reasonable expectations of passengers seeking long term on-airport car parking facilities into the future, along with the needs of increased levels of staff, at a time when passenger throughput associated with “the Project” is expected to rise from 46mppa in 2019 to 80.2mppa in 2047. In the opinion of Holiday Extras Limited the DCO application is deficient in providing a positive response to these two important aspects, due to either inadequate information being provided, or an absence of supporting evidence. It follows that the Examining Authority and the respective Secretaries of State cannot be assured that the adverse impacts arising from “the Project” concerning the two significant issues set out in these representations have at the present time been adequately addressed in the DCO Application.