Advice to Gatwick Area Conservation Campaign
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- From
- Gatwick Area Conservation Campaign
- Date advice given
- 8 November 2021
- Enquiry type
In relation to the baselines Gatwick has proposed for the project in its consultation (which we note have changed from the baselines proposed in its Scoping Report), you say: "they are not matters that we can take a view on prior to submission as the Inspectorate has no role in confirming whether a baseline level proposed by an Applicant is appropriate." We understand from this that PINS does not intend to form a view on Gatwick's proposed baselines prior to submission of the application. You also say: "at the point of submission during the acceptance stage, the Inspectorate (on behalf of the Secretary of State) will have to decide whether or not the application meets the standards required to be accepted for examination". We would like to understand what work you plan do once the application has been submitted to confirm that the proposed baselines levels are appropriate. We believe that PINS and other intertested parties will only be able to be confident that the adverse impacts (and any benefits) of Gatwick's proposed growth have been scoped and assessed accurately if it has tested the baselines robustly. We would therefore be grateful if you could tell us: • what "the standards required" to be accepted for examination are as regards the proposed baselines; • how PINS will judge whether those standards have been met, that is what specific work it will do; and • what would happen if the standards required were not met. In summary, our view is that PINS will need to review in detail whether Gatwick can achieve the baseline levels it proposes without any of the works for which it seeks consent through the DCO process. We note that paragraph 3.3.7 of the Scoping Opinion says "The Applicant should be careful to ensure that the ‘future baseline’ is established relevant to suitably robust assumptions and is fully representative of the likely outcomes in the absence of the Proposed Development". In this context we would also like to understand whether PINS expects to assess and take into account the cumulative adverse impacts of all the airport's proposed growth (both growth generated by more intensive use of the main runway and that generated by routine use of the standby runway if consent was granted) or just the adverse impacts of proposed standby runway growth? We note that paragraph 3.3.5 of the Scoping opinion says "Where ... works do not specifically form part of the DCO application, the ES should ensure that they are adequately assessed as part of the baseline (and future baseline) conditions or within the cumulative effects assessment where significant effects are likely to occur". My email of 9 September also asked whether, if the need for the development was shown to be low and the adverse impacts high, as we believe will be the case, the Inspectorate can propose caps on Gatwick's growth below the proposed baseline level and potentially below the actual level of traffic achieved in 2019? Your response did not address this question and we would be grateful if you could let us know the position.
Advice given
Please see attached.