Representation by Jennifer Helen Altamirano Smith
- Date submitted
- 11 November 2023
- Submitted by
- Members of the public/businesses
Introduction: I am deeply concerned about the impact that the Gatwick Airport Northern Runway project would have on greenhouse gas emissions and their contribution to climate change, and on air pollution including particulate matter, ultrafine particles and toxic substances such as nitrogen dioxide, which are harmful to health. I am particularly concerned about the harm that increased air pollution would cause to children, who are uniquely vulnerable. How can airport expansion be justified in the light of legally binding national and international carbon reduction targets (The Carbon Budget Order, 2021)? Moreover, how can airport expansion be justified in light of national Air Quality Objectives and Air Quality Standards Regulations (National Air Quality Objectives, 2023), as well as the recent WHO Air quality guidelines recommended levels and interim targets (2021) which have set lower target levels? Furthermore, how can airport expansion be justified given the legal duties on public bodies to safeguard and promote the welfare of children, (The Children Acts, 1989 and 2004), including contextual safeguarding and the assessment of environmental factors (Working Together to Safeguard Children, 2018)? Main Issues and Impacts: There has been no up to date scientific assessment of the impact that the proposal would have on the safety and welfare of the children who live near to Gatwick Airport and / or who attend school near to Gatwick Airport, especially those who live and attend school within the Air Quality Management Area No.3 (Horley), which is downwind of Gatwick Airport and is worst affected by air pollution (DEFRA, https://uk-air.defra.gov.uk/aqma/details?aqma_ref=228#638). In particular, there has been no assessment of the impact that increased levels of air pollution would have on these children's lung development. Children are uniquely vulnerable to air pollution and this concern is particularly urgent for those children with existing health conditions such as asthma, (Royal College of Physicians. Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP, 2016). Increased passenger numbers will increase surface level emissions from transport and housing, as well as emissions from flights. “The project would further increase Gatwick’s passenger throughput to approximately 75.6mppa (million passengers per annum) by 2038, an increase of approximately 13.2mppa (over the ‘without project’ projection of 62.4mppa).” (West Sussex County Council, Gatwick Northern Runway Project: approval of consultation response, November 2021). Gatwick Airport expansion means worse air quality for local people, including at risk groups such as children. In the report titled What About Our Air Quality, Gatwick Airport? CAGNE concludes that “It is therefore anticipated that the concentration of particles with a 2-runway airport will increase by 63% to 153,220 particles/cm3 throughout the day.” (CAGNE Supplement on Air Quality, April 2023). In 2015, the Gatwick Coordination Group of MPs stated, “Over 51,000 people living at about 21,000 properties would experience a deterioration in the air they breathe (in terms of annual mean NO2 concentrations). Most concerning is that there are 62 properties, home to 151 people, whose health would be put ‘at risk’ in the view of the Commission’s expert consultants by the poorer quality of air.” (The Gatwick Coordination Group Response to Airports Commission Consultation on Air Quality Assessment, May 2015). In 2023 and beyond, the numbers of people affected are likely to be higher due to population increase. Air pollution has been identified as causing significant physical and developmental harm to children. “Gestation, infancy and early childhood are vulnerable times because the young body is growing and developing rapidly. We know that the heart, brain, hormone systems and immunity can all be harmed by air pollution. Research is beginning to point towards effects on growth, intelligence, and development of the brain and coordination.” Royal College of Physicians. Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP, 2016. Air pollution has been identified as “a significant contributory factor” to one child death, Ella Adoo-Kissi-Debrah who died in 2013. In the Coroner's Report, Preventing Future Deaths, the coroner said, “The evidence at the inquest was that there is no safe level for Particulate Matter and that the WHO guidelines should be seen as minimum requirements.” and that, “During the course of the inquest the evidence revealed matters giving rise to concern. In my opinion there is a risk that future deaths could occur unless action is taken.” (The Coroner’s Report for Ella Kissi-Debra, Regulation 28: Report to Prevent Future Deaths). There is a risk of more child deaths if Gatwick expands and air quality deteriorates further. The Children Acts (1989 and 2004) and government guidance (Working Together to Safeguard Children, 2018) identifies that certain public bodies, including Local Authorities, have a duty to ensure that their functions have regard to the safety and welfare of children. “Environmental factors are intrinsic to the health and wellbeing of children, and their effective protection. This was referred to as ‘contextual safeguarding. In 2018, Contextual Safeguarding was overtly identified as an area of specific child protection work.” (Climate Child Protection and Safeguarding Team, Referral Guidance). The Planning Inspectorate must have regard for the duty to safeguard and promote the welfare of children “pursuant” to the duty of public bodies identified in the The Children Act, 2004. Section 11 of The Children Act, 2004, states that certain public bodies have a duty to “safeguard and promote the welfare of children”, including local authorities, district and borough councils and all childcare and education providers. The Planning Inspectorate is a public body and, although the Planning Inspectorate does not work directly with children, in making the decision over the Gatwick Airport Northern Runway Plans, it does provide a service “pursuant” to West Sussex County Council, Crawley Borough Council, Reigate and Banstead Borough Council and all the childcare and education providers within the vicinity of Gatwick Airport who discharge their duty to safeguard and promote the welfare of children. The likely impact of the Gatwick Airport Northern Runway Project on child safety and welfare needs to be assessed in line with the duty to safeguard and promote the welfare of children (The Children Acts 1989 and 2004, Working Together 2018), and with regard to legal duties in relation to air quality and greenhouse gas emissions. This impact assessment should include child safeguarding and air quality assessments, with specific reference to the potential impact on children, particularly those with existing health conditions such as asthma living within the Air Quality Management Area no. 3 (Horley). Conclusion: “Nothing is more important than children’s welfare.” Working Together to Safeguard Children, 2018. The aim of this representation is to centre the safety and welfare of children who are uniquely vulnerable to the impacts of Gatwick Airport expansion, including air pollution and climate change, both in terms of their physical development and their mental health and emotional wellbeing. I hope that this encourages you to centre the needs of children in your decision about whether to allow the expansion of Gatwick Airport. References: Sixth Carbon Budget, The Carbon Budget Order, 2021, https://www.legislation.gov.uk/uksi/2021/750/contents/made National Air Quality Objectives, 2023, https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update_20230403.pdf World Health Organization. (?2021)?. WHO global air quality guidelines: particulate matter (?PM2.5 and PM10)?, ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide. World Health Organization. https://iris.who.int/handle/10665/345329. License: CC BY-NC-SA 3.0 IGO. https://www.who.int/publications/i/item/9789240034228 The Children Act, 1989, https://www.legislation.gov.uk/ukpga/1989/41/contents The Children Act, 2004, https://www.legislation.gov.uk/ukpga/2004/31/contents Working Together to Safeguard Children, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942454/Working_together_to_safeguard_children_inter_agency_guidance.pdf Air Quality Management Area No.3, DEFRA, https://uk-air.defra.gov.uk/aqma/details?aqma_ref=228#638 Royal College of Physicians. Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP, 2016, https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-air-pollution West Sussex County Council, Gatwick Northern Runway Project: approval of consultation response, November 2021. The Gatwick Coordination Group Response to Airports Commission Consultation on Air Quality Assessment, May 2015. CAGNE, ‘What about our Air Quality, Gatwick Airport?, April 2023. The Coroner’s Report for Ella Kissi-Debra, REGULATION 28: REPORT TO PREVENT FUTURE DEATHS, https://www.judiciary.uk/wp-content/uploads/2021/04/Ella-Kissi-Debrah-2021-0113-1.pdf