Representation by Climate Emergency Policy and Planning (CEPP) (Climate Emergency Policy and Planning (CEPP))
- Date submitted
- 9 November 2023
- Submitted by
- Non-statutory organisations
From: Dr Andrew Boswell, Climate Emergency Planning and Policy I am an independent environmental consultant. I object to the Gatwick Airport Northern Runway: (1) The Examining Authority is respectful invited to consider this question as central to its examination: ‘to what extent does the project contribute, or undermine, securing the Net Zero Strategy (“NZS”) and the net zero target when it is contextualised within a robust risk assessment framework of the related policy delivery, and a robust assessment methodology of the significance of the greenhouse gas emissions (“GHGs”)?” (2) The 2023 Progress Reports from the Climate Change Committee (“CCC”) shows that the success of the NZS, now the Carbon Budget Delivery Plan (“CBDP”), is by no means secured and no weight can be given to the proposition that it is. Far from it, CCC say “The rate of emissions reduction will need to significantly increase for the UK to meet its 2030 NDC and the Sixth Carbon Budget. If the UK is to achieve its NDC, the rate of emissions reduction outside the electricity supply sector must almost quadruple, from 1.2% annual reductions to 4.7%.” (3) The same climate policy delivery risk was highlighted by the High Court judgement in 2022 Net Zero Strategy case (A), and a second on-going Net Zero Strategy case. (4) At Figure 10.9 on the 2023 Progress Report, CCC highlight that there is significant risk to 5 million tonnes of CO2 emission reductions required in the Aviation sector for the sixth carbon budget (B). How does the Environmental Statement deal with this highly risked issue for the project? (5) Beyond “climate impacts”, I am concerned about: a. Wider environmental impacts including noise and air pollution. b. Surface transport impact and failure to provide for and promote more sustainable transport modes - the targets for sustainable transport are not that challenging and not in line with the need to reduce road traffic on emissions grounds. c. Cumulative impacts not considered with wider development that will be needed to support such an application and growth at the airport, such as housing, schools, hospitals, water and sewage systems, etc. (6) We are in a climate emergency, and it is a crisis of ever-increasing dimensions. Creating new construction emissions and operation emissions from the scheme is not consistent with a risk aware, and precautionary principle, approach to achieving the UK carbon budgets and targets. The emissions from this scheme would have a very real material impact on meeting UK carbon budgets and targets and cannot be justified within the planning balance. (A) R (Friends of the Earth) v Secretary of State for Business Energy and Industrial Strategy [2022] EWHC 1841 (Admin) (B) Climate Change Committee : Progress in reducing emissions : 2023 Report to Parliament