|The Planning Inspectorate
Room 4/04 Kite
Temple Quay House
2 The Square
|23 January 2007|
Appeal reference: APP/C1570/A/06/2032278/NWF
APPEAL BY BAA PLC AND STANSTED AIRPORT LTD
1. I am writing on behalf of the Bishop’s Stortford Civic Federation to register our objection to the appeal by BAA and Stansted Airport against the refusal of their application to vary two conditions in respect of their current planning permission for the airport, namely the limits on passenger throughput and on aircraft movements.
2. The Civic Federation brings together the Civic Society and all the active residents’ and community associations in the town into a partnership which represents over 6000 of the town’s households. It is the successor organisation to the Civic Society on whose behalf I wrote to Uttlesford DC to object to the airport’s planning application on 26 June 2006.
3. I shall first recapitulate the substance of our earlier objections which have not in any way been invalidated by this appeal, before dealing with the stated grounds of appeal.
4. The Application Fails to Disclose its Full Implications Our experience has been that the airport applies for permission to build facilities grossly in excess of those required to support a given level of passenger throughput. It then portrays subsequent expansion as a minor incremental change. BAA now argues that the facilities for which it already has permission would support a passenger throughput of up to 45 million passengers per annum (mppa) having previously claimed that they were necessary to permit expansion from 15 to 25 mppa. So the application for which they now have permission was in fact for an airport three times as busy as the one then in existence.
5. With this application, BAA have projected demand only to 2014/15 and have suggested that it might reach 35 mppa. However, the airport invests over a longer time horizon than 7 years, and is asking for the limit on passenger throughput to be removed altogether. The effect of this and the increase in aircraft movements for which they have applied could lead to an airport of 45 or even 50 mppa in the longer term – twice as busy as at present. Since BAA have not attempted to model the most intensive possible use of the airport with a single runway they cannot justify this application either by arguing that the adverse consequences are acceptable or that they can be mitigated to an acceptable degree.
6. The Application is Unnecessary at Present BAA have accepted that no further facilities for which planning permission has not been granted are required to handle more than 25 mppa. On the evidence they have provided, they have not demonstrated the need for either variation.
7. On the question of passenger throughput, the existing limit of 25 mppa has not been reached and it remains one of the few safeguards in the hands of the local planning authority which could be used effectively to protect the local community from the unacceptable consequences of airport expansion. As indicated above, BAA have not modelled the full potential consequences of removing the safeguard. They have proposed that it should be removed simply so as to avoid effective control in the future. Their application does not attempt to demonstrate why they should no longer be subject to such control and their appeal against refusal to remove it should be rejected.
8. In the case of the limit on aircraft movements (ATMs), their purpose is twofold. Firstly it is to cap the amount of disturbance which each such event causes. Secondly it is to modify the behaviour of airlines compared with the way in which they would behave if no such limit were in place. As the limit is approached, it forces airlines to carry their passengers in a smaller number of larger aircraft with higher load factors than they might choose to do if there were no limit in place. This has environmental benefits from the points of view both of reducing the number of noise disturbance events and the amount of air pollution generated per passenger carried. If the limit is relaxed every time it is approached so that airline behaviour in practice remains unregulated, then the potential benefit of a condition of this kind is surrendered. In 2005, Stansted had used only ¾ of the ATMs sanctioned under its current planning permission. It is clear that many more passengers could be carried without any increase in the limit. In the absence of financial or other regulatory interventions to address the adverse environmental consequences of civil aviation, this is one of the few sanctions which works and should under no circumstances be relaxed. This part of their appeal should therefore also be rejected.
9. Noise Residents of Bishop’s Stortford, particularly on the southern quadrant of the town, are the largest concentrated group of people to be affected by noise disturbance from the airport, especially because the south western route is the most frequently used take off path. Leq contours, whether at 57 db or any other noise level, are a wholly unsatisfactory way of measuring the real disturbance caused. This is because they average noise disturbance over times of day, days and weeks, whereas the reality experienced by people on the ground is of a series of individual disturbances at greater or lesser frequencies. The more frequent the number of disturbances, the less acceptable they become, and to argue that aircraft are becoming quieter is not a defence. The improvement will at best be marginal and quite insufficient to offset the increased frequency of the disturbance. This therefore provides added justification for rejecting the requested increase in the ATMs, particularly since there is the potential for an extra third more movements compared with the present within the current limit.
10. Surface Access By failing to disclose the full increase in intensity of use which granting of the application would have allowed, BAA have also failed to model the full surface access implications of expansion on this scale. Their approach has been to argue that if everything else stayed the same, the extra demand on road and rail infrastructure could be accommodated without any increases in capacity. There are two flaws in this argument. Firstly, everything else will not be staying the same. And secondly, it depends on no significant shift away from private cars and towards public transport to enable the airport to operate in a more sustainable manner in future.
11. Taking the first point, a significant increase in road transport in the area is bound to happen. Road traffic has grown by 1 or 2% a year in recent decades and car ownership has been increasing. There are no Government policies to alter that trend other than allowing congestion on the infrastructure to moderate it. In this region pressure will be increased by Government policies for significant housing development. Stansted expansion, without modal shift, will be a further generator of road traffic, but BAA propose no mitigation as a consequence of their own preferred development.
12. The general increase in traffic congestion also spills over into Bishop’s Stortford itself. Our road infrastructure is already stretched to breaking point and cannot support a doubling in passenger numbers at the airport, with all the additional off site traffic which that will generate. Moreover, we already suffer a problem from off site fly parking and airport park and ride schemes and expansion will only make matters worse.
13. On the second point, BAA should be trying to achieve a public transport modal share of surface access well above the current 40%. If that were to happen, the rail network in particular would not be able to support the demand generated. Even with no change, it is clear from BAA’s own evidence that local rail users are suffering at the expense of airport passengers. BAA show that if the current timetable is maintained and there is no modal shift, airport demand can be met by 8 or 12 coach trains whereas non airport services will be overcrowded. It is not clear whether other planned development along the corridor has been factored into this calculation. BAA dismiss the problem as not being of its making because the overcrowded services do not call at the airport.
14. However, in reality the forecasts show that the timetable does not allocate resources properly. Airport services will get more seats than they need and other commuter services will not get enough. This arises because four regular airport express services per hour receive first priority in timetable planning, with the other services having to be fitted into the remaining slots around them. Platform lengths mean that longer trains cannot be run to other destinations and the infrastructure constraints of a two track railway mean that more frequent services cannot be run, unless the airport service was curtailed in the peaks. In short, regular users would be penalised to satisfy the demands of the airport. Moreover, although BAA are proposing to relieve overcrowding by running 12 coach trains, they do not appear to be volunteering to support that increase in capacity financially. Our concern in Bishop’s Stortford is that a more likely scenario is one which happened previously. When the earlier generation of airport express trains became more popular, the intermediate stops at Bishop’s Stortford and Harlow were removed from the timetable, thus leaving regular users with a worse service than they had enjoyed before the airport expanded.
15. I now turn to the grounds of the appeal.
16. Make Best Use of Existing Runways at Stansted and Luton BAA have quoted this aspect of the Air Transport White Paper (ATWP) as being a statement of Government policy to which the planning authority should give weight. However best use is not necessarily synonymous with full use, and the ATWP is not the only statement of Government policy relevant to this issue. In particular, Government policies on climate change and the reduction in the UK’s greenhouse gas emissions, combined with the encouragement of more sustainable forms of travel would suggest that a different set of policy considerations is relevant to this appeal. In the absence of any other effective mechanism to regulate the growth in air travel (and the recent welcome given by some airlines – though not Ryanair – to the extension of emissions trading to EU civil aviation suggests that this will be ineffective), shortage of airport capacity should be used to regulate demand as it now is for other modes of transport in the UK. So ’best’ use of the runway at Stansted should mean ‘no growth’.
17. Economic Benefits of Expansion BAA have relied on assertions in the ATWP rather than making its own assessment of costs and benefits of expanding Stansted Airport. Passenger demand at Stansted is overwhelmingly leisure based. The UK has a large and growing balance of trade deficit in tourism which Stansted in particular feeds. This is because of the dominance of low cost airlines which serve a wide variety of holiday destinations in Europe but not the airports most conveniently located for business users. It is difficult to see how an expansion of this kind of activity will bring benefit to the UK economy.
18. The Planning Authority Should Have Imposed Relevant Conditions It did when agreeing to Stansted’s application to increase capacity from 15 to 25 mppa four years ago. BAA could easily have applied for a higher limit on that occasion but chose not to. The planning authority is entitled to regard the permission granted on that occasion and freely entered into by BAA as a package. BAA have not sought an alternative condition now, but the removal of the limit. The worst possible argument for removing this or any other planning condition is that it is beginning to have its intended effect.
19. Finally I should like to ask that the Federation is allowed to speak at the Inquiry to present our evidence and that we are notified in writing of the decision.JOHN RHODES