Representation by Stephen Hugh McKenna
- Date submitted
- 19 November 2023
- Submitted by
- Members of the public/businesses
This submission has been prepared based in part on the response of others including Gatwick Area Conservation Campaign (GACC) and New Economics Foundation and in part on my own professional expertise as a Town Planner and Chartered Surveyor. GACC was actively involved in the DCO consultation process and Noise Envelope Consultation. The main critique is that there is a lack of a genuinely sustainable vision that recognises that whilst air travel may bring some short term economic benefits these are heavily outweighed by the costs to peoples health, to the environment generally and the well being of the planet. There can be no opt out for aviation. A vision of how to correct this imbalance needs to be developed and communicated as part of this application. The Climate Change Committee’s (CCC) annual Progress Report to Parliament states that this year the CCC has materially reduced its confidence that UK 2030 targets are achievable and that Government must act decisively and with ambition to turn this around. This confidence has been undermined by the lack of action to reduce energy demand, Government support for the Cumbrian coal mine and granting of North Sea fossil fuel licenses as just some areas of concern. It notes also that in landuse and agriculture there has been no progress at all recently, particularly with respect to tree planting and peatland restoration and that there is no strategy at all in this sector. In other sectors the plans to deliver net zero are fraught with risks and they cite the planning system as holding up necessary measures to deliver net zero. The assessments show that after 2030 the delivery of greater reductions in emissions will be required at a faster rate to make up for the slower changes in the current period if net zero is to be achieved by 2050. It is often the post 2030 period where most risks and scope for failure exists. In these circumstances the fact that aviation is seen as an area where growth apparently can be more supportable, as other sectors will deliver the real benefits, may be misguided. The Jet Zero Strategy assumes UK emissions for aviation will rise as passenger demand will go up by 70% on 2018 levels (482m). The potential Heathrow (assuming the Government’s preferred option of the Heathrow Northwest Runway) and Gatwick Airport expansions would add a further 71.6 million terminal passengers if applications were resubmitted and approved. If all applications were approved, this would increase terminal passenger capacity by 97.4 million compared to 2018 levels, bringing total capacity to 467 million. The Sixth Carbon Budget Balanced Pathway recommends that aviation demand can increase 25% on 2018 levels by 2050, which equates to 365 million passengers per year in 2050. The CCC’s Sixth Carbon Advice also recommended no net expansion in airport capacity as existing aggregate capacity (370 million passengers) could accommodate such demand growth. CCC recommends net airport expansion should only proceed if the carbon-intensity of aviation is outperforming the Government’s pathway and can accommodate this additional demand. It adds further that any additional airport capacity that would facilitate increased aviation demand should not take place unless corresponding reductions in capacity are made at other UK airports such that net UK airport capacity remains the same. If the risks post 2030 accrue significantly across the various sectors in such a way that achieving net zero seems to be drifting further into the distance, with all the consequences that follow, pressure may build to downgrade some key infrastructure schemes and those that are delivering increasing emissions may be seen as candidates for urgent action. There may be a risk of substantial cuts to projects increasingly viewed as “White Elephants” as has happened in the case of HS2 (albeit for different reasons). In this scenario some airports may need to be restricted to an extent in future that causes them to become non viable businesses and so the need for an urgent review of airports is evident. Again measures to explain how this will be achieved need to be set out in this application. Gatwick’s Proposals It might further be argued that in respect to airport development this should not be based on predict and provide but on what is the optimal level eg of passenger numbers and that once identified these should be controlled. The question as to whether planning for approx. 80 million passengers per annum is appropriate in the circumstances say of raging climate change past 2030 needs to be examined carefully. If airport improvements are approved a capping agreement on numbers should be put in place with thresholds set linked to net zero/GHG emissions. In other words it may not be prudent to allow numbers to grow past certain limits if climate change is speeding up before 2040 or even 2030. The DCO application understates the increased carbon emissions and underplays its significance. This is the largest planned increase in aviation-related emissions since approval of the UK Climate Change Act (2008). If expansion were permitted Gatwick alone would be responsible for around 5% of the UK’s carbon budget by 2038, subject to mitigations. Approving this DCO would require government to ignore its independent Climate Change Committee’s 2023 Progress Review recommendation to not permit any airport expansion without a UK-wide capacity-management framework being in place. I therefore strongly oppose this Gatwick Airport Ltd (GAL) DCO application for the following reasons: 1) Firstly apart from recognising that the proposals impact the environment in the vicinity, the impact on climate change is of far greater concern. Whilst economic growth may be one aspect to understanding the DCO application the sustainability of the project does not consider the wider picture. In reality by 2040 the pressure to change the uses on GAL land to those that are more climate friendly may be overwhelming and in this application it is absolutely relevant and compelling that the long term situation is analysed. After all this application asks us to accept that conditions in 2040 should be taken as read to justify the application. A proper review of conditions in 2040 must consider all issues including climate change as a material and paramount consideration and risk in this application. So for example by then whilst people may still be flying the travel to and from the airport by car may be completely unacceptable and the huge car parking areas may need to form part of the mitigation plan to help the Airport reach net zero such as solar arrays on GAL land and on beuildings, plus emerging technologies to remove carbon from the air and so forth. 2) The ANPS requires airports seeking to expand (other than Heathrow) to demonstrate sufficient need, additional to (or different from) that met by provision of extra capacity at Heathrow. Gatwick has not done this. Gatwick should also assess the likely overall growth for airport passengers using the wider airports market as a whole and distributing any growth between them including Heathrow, taking into account their own proposals. This would establish the potential ceiling on numbers that could potentially use Gatwick. It is essential that double counting of passengers is avoided. 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 and allowance made for impacts of Covid, global economic trends, increasing awareness and need for legislation to govern air travel’s climate impacts and shifts to how international business is conducted. It is likely that there will never be a need for any additional capacity at Gatwick and no need for the Northern Runway. 3) The need argument also needs to reflect on sensitivity analyses regarding the specific growth levels over time. The need for the expansion of airport facilities at Gatwick is subject to many assumptions regarding sustainable growth such as rising passenger numbers, including business travel, freight, travel to and from the airport, infrastructure capacity and so forth. It is stated inter alia that passenger numbers may double by 2040 according to GAL and this growth trajectory is the justification for the proposals in the DCO which is already far in excess of the Climate Change Committee’s cautious approach ie 25% growth. However the question must be asked - can this expansion, which is reliant upon improvements to an emergency runway, really deliver an increase in capacity sufficient to cope with 80 million passengers? This needs to be explained and tested in detail. 4) Although other south eastern airports may have been considered in the overall analysis by GAL, it is clear that Gatwick is not a hub airport in that passenger numbers are tied to markets similar to those underpinning regional airports eg charter holiday companies. Indeed Airports like Manchester have expanded precisely to draw passengers who previously would otherwise have travelled to major airports in the south east. Heathrow as a hub airport is less prone to these potential risks to its business model. Thus a proper whole market analysis for air travel is necessary including airport capacities, growth plans and so forth. 5) One scenario therefore is that over time the anticipated growth projections at Gatwick do not happen for instance as travel by other means becomes cheaper and more convenient as well as ethical behaviour. Indeed this may be a risk factor that has influenced the decisions to promote the re- engineering of the emergency runway rather than invest in a much more expensive new purpose built runway. 6) Indeed whilst a larger purpose built runway being accommodated elsewhere on or off GALs landholding may not be practicable at this time, there is no doubt it would be far more controversial in planning terms than a modest change to the existing emergency runway. Yet in principle if passenger demand is encouraged there will be significant impacts on air quality and other forms of pollution. Mitigation to enable expansion may for instance necessitate a significant reduction in accessing the airport by car, utilising the freed up areas for net zero re-purposing. So arguably this DCO scheme presents far less risk for GAL especially when airport growth assumptions may be subject to huge variation and a potentially less supportive policy climate if net zero is less deliverable after 2030. It is not clear for instance how Governments in the EU (which includes many short haul flight destinations) will react if the climate situation becomes untenable. They may take more drastic measures to reduce capacity and if these start to roll back abroad this will inevitably impact domestic airports like Gatwick. 7) However the amount of infrastructure proposed may be similar to that for a purpose built runway scheme so we need to understand with some certainty what is the minimum needed to support the current proposals only. Are the infrastructure enhancements really necessary to support such a modest amendment to an existing runway? 8) The baseline case set out in the immense quantity of documentation also states that without this application GAL would continue to grow although at a more sustainable rate of circa 10% during the same period. In my view this would allow more time to consider more nuanced approaches to address sustainable growth, to plan and utilise existing resources more effectively at a time when climate change, nature depletion and zero carbon efforts are ever more critical issues. As a major landowner in the area GAL can do a lot more to deliver zero carbon and reverse nature depletion. The phasing of the operations eg hotels by 2032, suggest that GAL is also taking a cautious approach to providing this supporting infrastructure which will only happen when and if the numbers of passengers are delivered in line with projections. At the same time overall revenue projections based on associated business opportunities arising from car parking, from rents and land sales from new commercial opportunities would normally be regarded as beneficial in servicing the needs of extra passengers ; however, in this application the potential need for mitigation measures to reduce emissions and achieve progress towards net zero should be tested as these might require substantial areas of land for repurposing. An assessment of the footprint Gatwick needs, to achieve these complex inter-related objectives, is essential in this application. 9) Might infrastructure improvements also support development opportunities on land outside GALs boundary as much as they are to service the airport operations? In other words there may a degree of speculative insight in terms of the design of roads and access to land in the area such as Horley Business Park and Gatwick Green. Indeed whilst there may be a promise of jobs long term with this application there may also be a considerable amount of additional short term pain for local communities. This “jam tomorrow” argument should not stand for a major and controversial piece of infrastructure like this. 10) All of this is contrary to zero carbon objectives, with new car parking and a lack of other infrastructure adding to poor air quality and other adverse impacts on top of what local people already experience. No improvements to rail are proposed despite an estimated near doubling of flights/passenger movements by 2040. If this were a major new runway proposal it might be expected if not required to provide convenient, safe public transport routes to London. The capacity on the rail network may be difficult to extend, we just don’t know, as this has not been assessed. In this case why not a rapid transit tram to reach a better connected location potentially linked with Crossrail, this would have been a more strategic solution and would have provided benefits for residents over a wider area. A wider assessment of strategic transport infrastructure in the south east including links with Crossrail , Heathrow and other routes, by rail, LRT, etc is needed as a result. Manchester Airport expansion provided a new railway line and station as well as an LRT direct to the city centre. More locally the connection between the local rail network and the airport can be far better. Gatwick station itself is on the main London line but capacity may be improved by improving connections by rapid bus transit links from rail stations on the Gatwick -Reading line and to stations further east in Kent. This is due to severe waiting times at Gatwick station itself which are unlikely to be improved. In reality improvements to rail capacity combined with cheaper fares will encourage non parking at Gatwick and lesser capacity on the road network. 11) GAL should additionally provide opportunities for better safer and cleaner air access by foot and cycling to deter car useage into the airport by staff and contractors (Travel Plans) and the public to support active travel and healthy living from nearby residential areas such as Horley and Crawley. If GAL services can enable direct pick up and collect from convenient places near the airport in these communities such as from local rail stations this integrated approach would reduce the traffic and reduce emissions locally. Surface transport is one area where Climate Change Committee see the need for much more progress. Electric charging points for parking will also encourage electric vehicles with a mini congestion/ULEZ in the airport to discourage petrol cars. These could be used for renewable energy capacity, rewilding for nature and air quality improvement technologies. Deterrence of car use will improve air quality in local communities. This should also question the need for improved highway connections in and around the airport. 12) On the so called other benefits these seem remarkably “thin” when considering the adverse impacts. This part of the south east is already heavily congested and more innovative measures are essential to mitigate the adverse environmental impacts of the current operations, notwithstanding the planned expansion of the Airport. Bearing in mind policy on airports benefits should be targeted in a more formal way towards addressing the issues where the Airport expansion impacts GHG emissions and uses more electricity. For instance will all these new buildings and facilities be powered by 100% renewable energy and will other potential indirect developments on other sites in the area such as Gatwick Green or Horley Business Park benefit from renewable energy generated from GAL’s estate. This would help address not only Scope 1 and 2 but Scope 3 as well. Long term projections for new employment directly at the airport should be heavily discounted as digital technology will become a more significant component of all processes including check ins, luggage movements, security, cargo and so forth. Many construction jobs will be short term and once the extra capacity is delivered at the airport the extra jobs may be seen to be more limited. New developments for associated business space including logistics should be researched in terms of what contributions to employment these sectors offer as the expansion occurs and should be based upon the baseline case as well as the proposed expansion of GAL. A more up to date independently tested assessment of benefits is necessary as a result. 13) Whilst it is recognised that GAL could potentially provide more jobs over time, locally, my experience is that job creation analyses whether direct or indirect should be treated with significant degrees of caution. FTE jobs may be the gold standard but in reality many jobs might not equate to FTEs. They may also not be there very long in that over time Airport linked employment may be impacted by new technology. Construction jobs are also short term and the local economy will not benefit from these in terms of any long term benefits. Many may not also emerge until several years into the phased programme of works. The DCO application deals at length with environmental impacts and mitigation. Jobs from indirect sources such as in logistics may be heavily automated as well over time. Genuine green jobs based upon the Circular Economy and re-utilisation of the vast quantities of materials used and disposed of at the airport could play a significant role on land in the vicinity of the airport. Tree planting on a large scale could also help deliver zero carbon targets but this will probably require land off site to be used so other green field sites could initially be subject to habitat restoration allowing in time high quality environments to be created for local people to work and play. A future baseline independent of any increase in passenger numbers at Gatwick should be provided and used to assess the impacts of the current future baseline and Project, for all aspects of the Environmental Impact Assessment (EIA) and improve clarity in communicating Gatwick’s expansion plans. In addition and in more detail, my concerns include: 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 underpinning the Transport Decarbonisation Strategy. Analysis should assess 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: benefits UK against non-UK residents, is displaced from other UK airports; is constrained (as opposed to leisure travel) in the baseline case. The negative impact of the increased UK tourism deficit from expansion, described as a ‘key diagnostic tests’ by the DfT (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 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 Making Best Use of Existing Runways policy. Later Jet Zero modelling assumes further capacity growth but lower emissions based on optimistic assumptions that are incompatible with climate limits, and subject to legal challenge. 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, in breach of the Precautionary Principle. The carbon emissions from additional surface transport journeys are not insignificant, and must be assessed separately against national road sector targets and policies, and local transport plans (LTP4) and climate strategies for Sussex and Surrey. Gatwick plans to reduce embodied carbon emissions for construction should be clearly set out, beyond the Carbon Action Plan’s high level target. This plan should include full surface access and flight emissions. Gatwick must set binding limits to constrain and reduce all GHG emissions associated with the airport. In conclusion, no airport expansions should proceed until a UK-wide capacity management framework is in place to annually assess and, if required, control sector CO2 emissions and non-CO2 effects. Noise 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 [so] 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), contain any proposals to limit noise in the winter period, and 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. The ANPS also requires a ban on scheduled night flights for a period of 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 should be considered important and relevant for any airport NSIP in South East England (not just Heathrow), including here. A ban on night flights should be a condition of any approval of the DCO. Gatwick should also be required to set out a comprehensive package of measures to incentivise the use of the quietest aircraft at night outside the hours of a ban. Environmental Impacts Water and Flooding The SESW’s water supply assessment should include identifying source(s) of additional water extraction, and its impact on water neutrality. This should assess impacts of extraction from aquifers and surface water, for water supply and biodiversity. Thames Water’s assessment should set out how increased foul and surface water impacts: Horley and Crawley SWTs; outflows into the river (including indirectly, via sewage treatment plants); and/or other pollution incidents. Both are required in advance so they are fully reflected in the EIA. The DCO should then clearly set out the measures required to restore the river Mole’s poor and declining water quality and reduce flood risk. This should include addressing impacts of existing road/parking run-off pollution and large volume outflows from firefighting on water quality. Monitoring of outfalls and diffuse pollution should be strengthened. The large areas of land currently used for car parking could be reduced to permit GAL to mitigate their waste water through re-using grey water and treating contaminated and waste water in new on site facilities rather than overload Thames Water sewage works. Gatwick should not be allowed to understate the climate impact on flooding by selecting a shorter (40-year) runway design life. The full flood risk must be modelled, and mitigated. The impact of empirical date on how climate change is already increasing the frequency and severity of flooding (e.g. 2013/14 event) 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. For example, the loss of Riverside Garden Park on individual species (e.g. bats). This should include the overall impact on the surrounding landscape, including: fragmentation of habitat (e.g. by woodland removal); increased surface transport and its associated air pollution; and 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 type and total area of habitat being lost, delay in re-provision, subsequent mitigation and compensation, and on the proposed monitoring and management of newly created habitats. Green infrastructure areas including biodiversity corridors should be set out to facilitate BNG utilising green spaces and redundant car parking facilities. Air Quality The confidence of modelling projected for future years is severely undermined by substantial inaccuracies in modelled air quality concentrations (particularly NO2), 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 used to show 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. Modelled increase in journey times includes unacceptable increases in highway traffic on the local network (e.g. on the A23). 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, being still reliant on surface car parks. Gatwick should reprioritise its surface access investment to sustainable travel, which means public transport for most passengers. The project increases 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. A bespoke transport strategy needs to be undertaken to consider all options to move people other than by private car, with scope to include LRT into London as well as rail improvements and bus rapid links to other stations so as not to overload the existing network. 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, commercial) off-airport parking on the surface transport modelling should be completed. Proposals lack detail on facilities needed (e.g. parking, lockers, showers) for increased active transport and safety of the redirected Riverside Garden Park route. Associated developments The sufficiency of supporting infrastructure, including terminal facilities, needed to meet the forecast intensification of the current runway, and then use of the new runway 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). Lack of details to assess the impact of the ‘biomass boilers’ and air pollution from the CARE facility. Impact of net-zero on buildings and infrastructure. Developments associated with logistics and green jobs arising from the Gatwick proposals need to be examined as part of the application, both within Crawley DC and inside Reigate and Banstead BC. Circular Economy principles should be applied to waste and recycling across the site and energy used for local community projects where possible. Construction impacts Lacks detail on: impacts of construction noise and their 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.”