Gatwick Runway Consultation Ipsos MORI

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Dear Sir or Madam,

GATWICK AIRPORT LIMITED – RUNWAY OPTIONS CONSULTATION

This letter is the formal response of the Campaign to Protect Rural England Sussex Branch (CPRE Sussex) to the Runway Options Consultation held on behalf of Gatwick Airport Limited (GAL). CPRE Sussex is a charity covering East Sussex, West Sussex and Brighton & Hove, with 1,621 members comprising individuals and many local amenity groups. It is a branch of the national charity CPRE. Our objectives are:

• to promote the beauty, tranquillity and diversity of the Sussex countryside by encouraging the sustainable use of land and other natural resources in town and country;
• to secure appropriate and sustainable land use, farming, woodland and biodiversity policies and practice, and improve the well-being of rural
• communities; and
• to ensure the value and benefits of the Sussex countryside are given due consideration by decision makers on issues of planning, land use, rural affairs and transport.

1. Objection

CPRE Sussex strongly objects to all the options presented in GAL’s consultation document, and considers that any proposal for an additional runway at Gatwick Airport is unacceptable. We set out our rationale for this position as follows.

2. No need for a second runway

There is no airport capacity crisis in the UK and therefore no need for a second runway at Gatwick. The UK has more take-off and landing slots than it requires, and this is expected to remain the case until well into the future. Spare capacity exists at London Stansted, Birmingham and Manchester airports, more than sufficient to meet the country’s needs. [1]

The runway is in the wrong place to benefit most of the UK and to rebalance growth away from the South East. Providing a new runway in the South East would make it harder for airports in the Midlands and the North to support new routes operating from their existing runways.

We also highlight that the Channel Tunnel is running well below capacity, with proposals to upgrade the Ashford to Hastings rail line improving access to the continental high-speed rail network for thesouthern part of Sussex. There is significant potential for modal shift of journeys totalling up to 1000km to high-speed rail, and CPRE calls for modal shift from air to high-speed rail.

3. Gatwick is the wrong location for airport expansion

We understand that GAL is pursuing a second runway for its own commercial reasons, but do not consider that higher shareholder returns for GAL’s overseas owners outweigh the negative impacts on Sussex that a second runway would have. It is widely understood that GAL intends to sell the airport in the near to medium term.

Table 17 of the consultation document makes claims for future increases in employment resulting from Gatwick expansion, ranging between 7,400 and 17,500 jobs relative to base by 2050. The document does not acknowledge that the areas surrounding Gatwick effectively have full employment, and very unusually, that this position has remained constant even through recent recessions/downturns. Therefore the projected need for a larger workforce to support the expansion proposals must be reliant on a significant increase in the local population through new settlement, combined with a large increase in regular commuting over medium to long distances into the area, putting further demands on local infrastructure that is already operating at or beyond designed capacity.

Predictions by Berkeley Hanover Consulting Limited (BHCL) for the Gatwick Diamond business interest group estimate that a two-runway airport would significantly increase demand for labour on and off the airport, with up to 5,000 new jobs per year between 2020 and 2030 (i.e. circa 50,000 jobs). BHCL predicts that the “catalytic impact” of two runways would be “dramatic”, with “significant implications for housing and local infrastructure”. Yet the consultation documentation offers no explanation as to how these “significant implications” are to be addressed by the GAL scheme.

We therefore determine that when organisations such as West Sussex County Council talk about the “economic benefits” of a second runway, they do not mean benefits to local people, but instead to GAL and those from outside the area who would either move here or commute, simply in order to satisfy the increased demands of the airport.

A higher population in any locality will almost inevitably lead to a larger local economy (ceteris paribus). However, crucially, it does not follow there will be higher per-capita income or wealth, i.e. greater prosperity. Proponents of a second runway should differentiate between increased prosperity and a simplistic assessment of the impacts of a larger local population.

Given the already high housing cost in the region, if these new workers are to be net contributors to the economy rather than a net cost, their average wages would need to be substantially above the national average just to enable them to meet housing costs. Based on the numbers presented, it would seem that GAL are not predicting that incomes would be substantially above national average for the majority of these jobs and ignore the commensurate need for the state to subsidise many of these employees through tax credits and housing support (benefits).

GAL's case, and the reports by The West Sussex Independent Economic Commission and BHCL on which West Sussex County Council have relied in their decision to support GAL's promotion of the Gatwick second runway option, are based exclusively on economic benefits that this would supposedly bring, not least to GAL itself. GAL's case has no regard to the wider social and environmental implications, which are a fundamental consideration.

4. Where will people live?

Based on GAL predictions that there would be up to 17,500 additional jobs in and around Gatwick as a result of the second runway, a significant number of new houses would be required in districts that already have severe housing pressure. [2]

Predictions by BHCL show that two runways at Gatwick could generate demand for new housing of up to between 3,000 and 5,000 new units per annum in the Gatwick Diamond area, in addition to those already deemed necessary without a second runway. Every local planning authority around Gatwick is already struggling to identify suitable sites for housing development to provide a five-year housing supply, even before the impacts of any second runway have been taking into account, just to meet the numbers set out in the South East Plan. A second runway cannot be deemed sustainable given this situation. Using these data, we conclude that a second runway would cause a massive and unsustainable increase in demand for housing in Sussex, when the local countryside is already under siege from proposals for new housing development. A second runway would therefore be expected to transform Sussex into a largely urbanised area, at the expense of the beautiful countryside that is currently enjoyed by local residents and those from further afield, particularly the conurbation of Greater London to the north. GAL makes no attempt to justify this urban transformation or proposals as to how it would be managed or mitigated.

5. Negative environmental impacts

a. Ashdown Forest and wider biodiversity impacts

Gatwick is situated in close proximity to an area of high environmental sensitivity – the internationally protected Ashdown Forest. CPRE Sussex is greatly concerned at the potential for a second runway to damage this important habitat, which is a Special Protection Area and Special Area of Conservation designated under the EU Habitats Directive. The sensitive plant and animal species found in the Forest are at risk from road-vehicle pollution and the negative impacts of visitor pressure from new housing development.

We are astonished that GAL appears to have made no assessment whatsoever of the undoubted threat that a second runway would pose to the Ashdown Forest. It is already established that there would be the risk of substantial damage due to increasing numbers of vehicles crossing the forest and from visitors (from new households moving into the area as a result of Gatwick expansion) using it for recreational purposes. [3] CPRE Sussex calls for an urgent assessment of these risks. We would have expected GAL already to have carried out an outline Appropriate Assessment under the Habitats Directive, before conducting such a high-profile promotional campaign. [4]

More widely, we are concerned that GAL’s consultation makes no attempt to measure the impact of its proposals on land with special landscape value, both with respect to designated land (AONBs, National Parks, Registered Parks and Gardens, Green Belt and Metropolitan Open Land) [5] and other undesignated land (including fields, field margins, woodland, hedgerows, gardens, allotments and parks), [6] all of which also contribute to biodiversity. CPRE Sussex calls for such an assessment. 

b. Overflight and aircraft noise – impact on tranquillity.

Tranquillity is a highly valued characteristic of the English countryside and one of the most important indicators of its quality. Nationally, CPRE has championed research to define, map, protect and enhance tranquillity since the early 1990s, and very much welcomed the recognition given to the value of tranquillity by the Airports Commission as a resource associated with well-being and quality of life. Looking at the Air Noise Contour plans in GAL’s consultation document and the current 2012 baseline, it is clear that all three second runway options represent a significant increase in noise across a wider area of countryside. We emphasise the great extent to which the areas of countryside affected are considered a valuable resource in an increasingly dense and busy region. People need respite and local countryside is precious for this. This countryside is not just a valuable resource for local people, but also those living in London, as Sussex is the county with the most nationally designated landscape in close proximity and with good rail accessibility. Providing Europe's biggest city with accessible high quality countryside is important to the quality of life of its residents as well as its competitiveness.

It is extremely disappointing that GAL’s Runway Options Consultation document contains no accurate quantification of the increased number, size and location of flightpaths that would result from a second runway. Simply suggesting that these are a matter for the Civil Aviation Authority conveys the erroneous impression that greater flightpath noise will have limited impact. We emphasise that, while debate often centres on the presence of noise contours showing Leq 54 dB(A), the level and nature of ambient noise in rural areas mean that aircraft noise below 54 dB(A) is typically considered intrusive. This means that the tranquillity of the wider countryside around Gatwick, and notably designated landscape areas such as the High Weald AONB and the South Downs National Park, are already considered to suffer from intrusive aircraft noise. We also point out that the Environmental Noise Directive (END) seeks to protect areas where noise quality is already regarded as ‘good’, and this should be acknowledged.

c. Traffic congestion, noise and pollution

GAL claims that a second runway will result in the number of passengers using the airport more than doubling, from 35 million per year to up to 90 million, and that there will be 17,500 additional jobs. [7] The impact of such dramatic increases in passengers and workers requiring access to the airport are not properly assessed in the consultation document, but would inevitably result in extreme overload on the surrounding road network and rail infrastructure, when they are already operating above designed capacity. GAL’s public assertions that the runway will impact only 14,000 people are frankly ludicrous. We are concerned that the resultant increase in road traffic, in particular, will have a seriously deleterious effect on the quality of life for residents across Sussex. Road congestion is already a major problem across our area, and road traffic noise and pollution would undoubtedly increase significantly as a result of a second runway. Sussex could expect a significant increase in HGV traffic as a result of the scale of growth at the airport and from associated business growth, undermining rural character, tranquillity and health. Such increases in congestion also result in a considerable dis-benefit to the economy that is not acknowledged or calculated in the GAL prospectus.

d. Development pressure on open spaces

As acknowledged in the consultation document, a second runway would require a dramatic increase in support and ancillary services in the vicinity of the airport, including long-term parking, overnight accommodation, and airline support activities. These would be expected to spill out into the surrounding areas, creating pressure for commercial and industrial development in important gaps between local settlements. GAL should be aware of the strength of local feeling towards the need to keep towns and villages (e.g. Crawley, Copthorne, Crawley Down and East Grinstead) as discrete settlements, despite the best attempts of central and local government to override local support for “critical gaps” and opposition to inappropriate development.

Furthermore, we are concerned at the quality of development associated with airport support activity, which is typically wasteful of land (e.g. long-term car parking), of poor visual quality (e.g. warehousing) and supportive of lower value employment.

6. Quality-of-life impacts

Many currently living close to and around Gatwick Airport are concerned about their already-declining quality of life. Pressure on the local housing stock, principally from those moving out of Greater London to Sussex, is causing rising prices and increased pressure for housing development, in an area where high prices and urbanisation have already taken their toll. Further concerns include the availability of school places, appointments at General Practice surgeries, and the performance of local Accident & Emergency departments at local hospitals. All of these concerns would be combined with already congested roads and commuter rail lines operating beyond designed capacity. It is unfortunate that GAL has failed in its consultation document to address any of these key quality- of-life issues that are not only important to local people, but also have significant implications for the region’s economic competitiveness as against similar regions elsewhere in Northern Europe.

7. Nature of GAL’s consultation

While we welcome GAL’s decision to consult on its proposals, we are very disappointed with the superficial way in which it has approached the consultation, particularly given the vast resources at its disposal.

Instead of the current document that asks respondents to make a false choice between three false runway options, when only Option 3 is being considered by the Airports Commission, GAL should have undertaken a proper assessment of the community and environmental impacts of a second runway, and at the very least should have taken the trouble to provide a full list of resources/references used to create its consultation document. Anecdotally, we understand that many people find GAL’s approach to local consultation to be simplistic, verging on the disingenuous, a view with which we concur. Furthermore, it is perplexing that even before the current “consultation” exercise on their original scheme has finished, we now find that GAL is promoting a revised proposal, [8] which apparently argues that “expansion at Gatwick would attract new businesses creating an additional 120,000 jobs across London and the South East.” This only serves to reinforce our argument that Gatwick is the wrong place for airport expansion, as such an unsustainable increase in job numbers in an already overheated region would have wholly negative impacts on everyday life here.

Yours faithfully,

Justin French-Brooks

Trustee
on behalf of CPRE Sussex Countryside Trust

Notes

1 The sifting report undertaken for the Davies Commission interim report (December 2013) notes that Stansted is expected to have unutilised capacity until 2040. 

2 The numbers suggested by GAL in response to questions have varied widely. In the absence of a reliable or consistent figure from GAL, we note that in drawing up their local plans nearby authorities have assumed a ratio of 1.3 workers per home, suggesting a figure of 13,500 homes to support the 17,500 jobs. GAL offers no indication where these are expected to be built.

3 Evidence demonstrating the negative impact of development on Ashdown Forest required that the recently adopted Wealden Local Plan be based on a housing target significantly below that set in the South East Plan.

4 We note the very substantial weight that the Davies Commission interim report places on compliance with the EU Habitats Directive.

5 Including those covered by (a) European Legislation: SACs, SPAs, Ramsar sites, European Protected Species, sites identified as essential for compensatory measures to mitigate adverse effects on SACs, SPAs and listed Ramsar sites; (b) National Legislation: National Nature Reserves; Sites of Special Scientific Interest; Ancient Woodlands; Marine Conservation Zones; species protected under the Wildlife and Countryside Act; and priority habitat and sites holding priority species; and (c) Regional and Local Legislation or Action Plans: Local Wildlife Sites; Local Nature Reserves; and habitats and species listed in the Red Data Book.

6 Fields (arable and pasture), woodland (including designated ancient woodland) and hedgerows provide important habitats for diverse flora and fauna, including protected species, and should therefore be included in the impact assessment.

7 Although we note that GAL’s Chief Executive in media interviews (13 May 2014) was claiming that the total “catalytic effect” of the second runway is now predicted to be 120,000 additional jobs rather than the earlier 40,000.

8 Not available on the GAL website but referred to in the GAL press release dated 13 May 2014 and claimed by the Chief Executive in his round of media interviews on 13 May 2014