Representation by Surrey Climate Commission (Surrey Climate Commission)
- Date submitted
- 19 November 2023
- Submitted by
- Non-statutory organisations
Introduction The Surrey Climate Commission is an independent body with the role of supporting and guiding the transition of Surrey to a carbon neutral future. This document accompanies the registration as an interested party in the DCO application. The Surrey Climate Commission comments correspond with those of the Gatwick Area Conservation Campaign (GACC), which the Commission supports. The Surrey Climate Commission strongly opposes the Gatwick Airport Northern Runway DCO application. Our concerns include the following points. Needs Case The ANPS requires airports seeking to expand (other than Heathrow) to demonstrate sufficient need, additional to (or different from) that met by provision of a Northwest Runway at Heathrow. Gatwick has not done this. Gatwick should also assess the need for increased use of its existing runway above 2019 levels, without development of the new Northern runway. This should be contrasted with historic growth rates of flights and passengers (including allowance for Covid impacts), global economic trends, increasing awareness and need for legislation to govern aviation’s climate impacts and changes in how international business operates. It is unlikely that any additional capacity or the Northern Runway will ever be needed. Economy and Jobs (drawing on New Economics Foundation submission) The benefit-cost analysis should comply with latest TAG guidance. This includes revising the economic analysis so carbon appraisal values for traded and non-traded carbon emissions are valued equivalently and assessment of non-carbon effects included. Impacts of inbound flights should be included as they are changed as a result of the project. Sensitivity analysis should set out the economic impacts of not achieving the assumptions in Jet Zero High Ambition scenario or those underpinning the Transport Decarbonisation Strategy. The analysis should include the impact of induced increases in road transport movements associated with highway investments. The user (passenger) benefits appear overstated compared to earlier estimates by the Department of Transport (2017) and the Airports Commission, particularly the 90% of benefits estimated from business passengers. Gatwick assumes a significant increase in business travel, whereas CAA surveys and IAG’s statements show a reduced share of business travel post-Covid: still less than the 2006 peak. Sensitivity analysis and up-to-date aviation evidence should be provided to support the claimed uplift due to “output change in imperfectly competitive markets” as required by TAG. Analysis should distinguish how much business travel: 1 Benefits to UK against non-UK residents; 2 Is displaced from other UK airports; 3 Is constrained (as opposed to leisure travel) in the baseline case. The net impact of the increased UK tourism deficit from expansion, described as a ‘key diagnostic tests’ by the DfT (Wider Economic Impacts of Regional Connectivity, 2018) should be estimated and included. The pay levels for new long-term jobs should be set out, and associated estimate of affordable housing demand for housing new lower-paid airport related jobs, against that for the current airport-related workforce. The impact of automation on future airport employment should be included, referencing historic trends. Climate Change The submission understates the increased carbon emissions and underplays its significance. This DCO would clearly have a material impact of the ability of the UK to meet its carbon reduction targets, and future carbon budgets. If expansion were permitted Gatwick alone would be responsible for over 3-5% of the UK’s sixth carbon budget, with or without Jet Zero mitigations. Approval would require government to ignore the Climate Change Committee’s 2023 Progress Review recommendation to not permit any airport expansion without a UK-wide capacity-management framework being in place. Planning must consider significance of emissions from all airport expansions not just on a case-by-case basis. Significance should be assessed against the 1.5C compliance trajectory as in IEMA guidance (Assessing GHG emissions and their significance, 2022). Gatwick should assess the cumulative impact of its plans against the global 1.5° C climate limit and the UK government’s legal requirement to reach net zero by 2050. Gatwick needs to explain how expanding one of the hardest to decarbonise sectors of the economy is consistent with the radical decarbonisation required across all sectors to meet net zero. Gatwick must explain why it believes it is acceptable to expand to 80 mppa, which is inconsistent with the Aviation Strategy: Making Best Use of Existing Runways (2018). It is not acceptable to simply assume later Jet Zero reductions can be achieved within climate limits. Gatwick’s submission should include the non-carbon impact of flying and overall climate impact of airport expansion (including inbound international flights which will increase emissions overseas). It is disingenuous to treat these as zero, or assume that all Jet Zero assumptions can be achieved without any evidence: both are in breach of the Precautionary Principle or IEMA guidance. The carbon emissions from additional surface transport journeys are not insignificant, and must be assessed separately against national road sector targets and policies, and Surrey and Sussex transport plans and climate strategies. Gatwick plans to reduce embodied carbon from construction should be clearly set out, beyond the CAP’s high-level target. The CAP should include full surface access and flight emissions. Gatwick must set binding limits to constrain and reduce all these GHG emissions. In conclusion, no airport expansions should proceed until a UK-wide capacity management framework is in place to annually assess and, if required, control aviation sector CO2 emissions and non-CO2 effects. Noise Gatwick has not met the ANPS requirement that noise envelopes are “defined in consultation with local communities”, nor CAA guidance that noise envelopes are agreed with stakeholders. Gatwick: 1 Rejected community stakeholder requests to change the format and timetable for engagement to improve compliance; 2 Failed to provide additional data and analysis required for effective engagement; and 3 Ignored almost all community comments. Gatwick’s Noise Envelope Group Output Report fails to reflect community group views on its proposals and its engagement process. Gatwick’s proposals do not: 1. Meet government policy (APF, 2013) that “Future growth in aviation should ensure that benefits are shared between the aviation industry and local communities …the industry must continue to reduce and mitigate noise as airport capacity grows.” Instead, the proposals would permit noise to increase substantially and potentially indefinitely, so benefits of growth accrue almost entirely to Gatwick and its customers. 2. Give communities certainty about future noise levels (APF para.3.29), because they do not contain any proposals to limit noise in the winter period, and would allow future reviews to increase noise limits. 3. Incentivise airlines to introduce the quietest suitable aircraft as quickly as is reasonable. Gatwick should be required to engage properly with community groups and councils, under agreed independent chairmanship, to develop new proposals that comply with policy and guidance. Night Flights The ANPS requires a ban on scheduled night flights for 6.5 hours between 23.00-07.00, and requires airports to make particular efforts to incentivise use of the quietest aircraft at night. The ANPS is stated to be important and relevant for any airport NSIP in South East England, including Gatwick. A night flight ban should be a condition of any approval of the DCO, as should provision of a comprehensive package to incentivise the use of the quietest aircraft at night outside the these hours. Water and Flooding The SES Water’s assessment should include identifying source(s) of additional water extraction and its impact on water neutrality and biodiversity. Thames Water’s assessment should detail how increased foul and surface water impacts: Horley and Crawley STPs; direct/indirect river outflows; and other pollution incidents. Both are required in advance so they are fully reflected in the EIA. The DCO should then set out the measures required to help restore the river Mole’s poor and declining water quality and reduce flood risk, including to address existing road/parking run-off pollution and large volume outflows from firefighting. Monitoring of outfalls and diffuse pollution should be strengthened. Gatwick should not be allowed to understate the climate impact on flooding by selecting a shorter design life for runways than for highways. The full climate uplift on flood risk must be modelled, and mitigated. The impact of empirical data on how climate change is already increasing the frequency and severity of flooding must be fully assessed. Ecology A landscape-scale approach is required to assess biodiversity impacts. This should address the effects on ecological networks in terms of habitat connectivity and function such as the loss of Riverside Garden Park on individual species (e.g. bats). This should include overall impacts on surrounding landscapes including: fragmentation of habitat (e.g. by woodland removal); increased impacts due to surface transport changes; increased flood risk and any potential water extraction. Gatwick should confirm that BNG delivery is separate from and additional to requirements under the mitigation hierarchy, and will be fully implemented. The impact of the time lag between habitat loss and subsequent creation and maturity (e.g. woodland) and associated with the long construction period should be assessed and mitigated. Gatwick must clearly set out the total area of each habitat being lost, delay in re-provision, subsequent mitigation and compensation, and proposed monitoring and management of newly created habitats. Air Quality The confidence of modelling projected for future years is severely undermined by substantial inaccuracies in modelled air quality concentrations (particularly NOx), demonstrated by the necessitated crude adjustments to align to the 2018 monitoring. Independent statistical review should assess the assumptions and adjustments to align the model to monitoring data. The modelling should therefore not be relied upon to claim that future impacts are not significant without: substantially increasing monitoring (frequency, locations); regular reviews of emissions inventories, assumptions; and revisions of the year-by-year air quality modelling. This must enable air quality impacts of the modelled baseline and superimposed project to be reassessed and refined. Transport Gatwick’s proposals and mode share targets fail to prevent a significant growth in car use for surface access. Modelling of the increased traffic volumes show unacceptable increases in local journey times (e.g. along the A23 corridor). Gatwick should adopt mode share commitments without any increase in car use and all additional surface access via sustainable transport. Gatwick plans only limited investment in public transport. Gatwick should reprioritise its surface access investment to sustainable travel, which means public transport for most passengers. The project will increase demand pressure on London-Brighton mainline trains, forecast to already become crowded. Modelled future rail capacity assumptions reflect rail industry plans to accommodate rail demand growth without Gatwick expansion to 2029. No increased rail capacity is planned or funded. There should be clear proposals to prevent increased off-airport parking. Assuming the base distribution of off-airport parking spaces for all future scenarios is unrealistic. Sensitivity analysis of the impact of unconstrained (street and commercial) off-airport parking on the surface transport modelling should be completed. Proposals lack detail on facilities for increased active transport and safety of the redirected Riverside Garden Park route. Associated developments The sufficiency of supporting infrastructure to meet forecast use, including new terminal capacity, is not assessed. The impact of building heights, particularly the new CARE facility incinerator (48m) and new hanger at the west of the site (32m), is not addressed. The DCO lacks details needed to assess the impact of the ‘biomass boilers’ and air pollution from the CARE facility or on how delivering net-zero will impact buildings and infrastructure. Construction Lacks detail on: impacts of construction noise and residents’ eligibility for insulation, access impacts (e.g. Woodroyd Avenue); and sequencing of construction works. The Outline Construction Management Plan, Material Transport Plan and Workforce Transport Plan are insufficient to support the statement that “No significant effects are likely to occur with respect to traffic and transport during construction and operation of the Project.” Acronyms ANPS Airports National Policy Statement (DfT, 2018) APF Aviation Policy Framework (DfT, 2013) BNG Biodiversity Net Gain CAP Carbon Action Plan CARE Central Area Recycling Enclosure EIA Environmental Impact Assessment GHG Greenhouse Gas IEMA Institute of Environmental Management and Assessment NSIP Nationally Significant Infrastructure Project STP Sewage Treatment Plant TAG Transport Analysis Guidance