Director of Development
Uttlesford District Council
|28 June 2008|
Your refs: UTT/0400/08/FUL UTT/0401/08/OP UTT/0402/08/FUL UTT/0403/08/FUL
Stansted Airport Generation 2 Application to Build a Second Runway and Associated Developments
I am writing on behalf of the Bishop's Stortford Civic Federation to object to these applications. The Civic Federation brings together the Civic Society and all the active residents and community associations into a partnership representing over 6000 households. Bishop's Stortford, a town of over 35000 inhabitants, is the largest settlement close to the Airport to be adversely affected by its activities. The remainder of this letter sets out the grounds of our objection.
a. At the time of writing, BAA’s appeal against the refusal of permission for its G1 application has yet to be determined. Nor has the Inspector’s report following the public inquiry into the appeal been published. We do not therefore know what weight was attached to any of the evidence submitted by BAA in support of its G1 appeal or what the outcome will be. Yet BAA relies on G1 permission being granted in a particular form to create the baseline against which to compare the effects of its G2 application.
b. The range of possible outcomes to the G1 appeal includes refusal of permission; granting of permission at 35 million passengers per year (mppa) on condition that no further expansion in the capacity of the Airport should be applied for or sanctioned; or granting of the appeal as originally requested without limit on the passenger throughput. Any of these outcomes would make the G2 applications redundant. The first would represent a return by the Government to its previous commitment that Stansted’s capacity should not be allowed to expand beyond 25 mppa. The second would indicate that 35 mppa should be the absolute limit on the capacity of the Airport, in which case, no second runway would be needed. The third outcome, even if accompanied by a temporary limit of 35 mppa, would allow BAA to make full use of the existing runway. Various estimates have been made of what this would be but it seems likely to be in the region of at least 45 mppa – double the current level of usage. Government policy in the Air Transport White Paper is that full use should be made of existing capacity before additional runway capacity is provided. If granted permission for G1 in terms which might in due course permit full use of the existing runway, BAA’s next step should be to consider how, if at all, to exercise that permission. Applying for permission for a second runway now is both unnecessary and contrary to Government policy.
c. National Air Traffic Services (NATS) are carrying out a consultation exercise on the redesign of air space capacity over the whole of the North London area. Noise from the south westerly BUZAD take off route from Stansted is one of the main adverse environmental impacts on the town of Bishop's Stortford. NATS’ proposals to bring that route closer to the town would exacerbate the existing problems of noise disturbance and the Civic Federation has therefore objected (see letter). If the G2 proposal were sanctioned on segregated mode, the problem would become continuous and intolerable whenever that route was used – whether or not the changed trajectory proposed by NATS was confirmed. BAA’s noise projections take no account of the NATS proposals.
d. The NATS proposals look ahead only to 2014. It is not clear therefore whether further changes in routes will be needed after that date or indeed whether there will be sufficient air space capacity to accommodate further expansion at Stansted as well as at Heathrow for example. If the air space capacity were full, a second runway at Stansted would be a white elephant.
e. The G1 application relied on a package of surface access improvements, and in particular the operation of longer, 12 coach trains on the rail service. The G2 applications assume that these enhancements will have taken place, and that a more frequent airport rail service will operate which will require additional track capacity to be reinstated between Broxbourne and Tottenham Hale. At present these assumptions cannot be substantiated, particularly as regards timing.
a. As has occurred on previous occasions, BAA have chosen as the base case the most environmentally adverse view of what the G1 application might deliver, in order to present the G2 applications in the most favourable light. As explained at 1b. above, if the Airport’s capacity were limited to 35 mppa in perpetuity, a second runway application would not be entertained. Yet this is the base case which BAA have chosen against which to evaluate G2. As a base case, it is both fanciful and irrelevant.
b. A more relevant comparison, indeed the one which one would expect to be used for an application such as this, would be to compare the impact of G2 at some point in the future when it is fully operational with the impact of the current level of activity at the Airport, or, alternatively, when the Airport has reached its currently permitted limit of 25 mppa. No such comparison has been made and no evidence has been presented which would enable such a comparison to be made.
c. Alternatively, BAA might have made a comparison between G2 and full use of the existing runway. Presumably they have chosen not to do so because it would rapidly be concluded that a second runway could not be justified on demand grounds for many years to come.
d. Even within the base case which BAA have chosen, assumptions have been made which present G2 in an inexplicably favourable light. For example, BAA assume in the base case, that transfer passengers will increase from 8.4% of the total now to 16.9% by 2015 but fall to 4.9% by 2030. The G2 application assumes that transfer passengers will rise 13.3% of the total by 2015 and 16.6% by 2030. These arbitrary movements in transfer passenger shares are unexplained. However, if the G2 assumption for 2030 were the same as in the base case (much more likely in the light of recent trends) the demand for surface access to the Airport would be nearly 8 mppa higher.
a. The basis of BAA’s applications is that the Air Transport White Paper of 2003 asked BAA to bring forward proposals for a 2nd runway. BAA has relied upon the projections of demand in that White Paper without seeking to validate them in the light of more recent events. It therefore ignores the impact on demand for air travel of the credit crunch and the impact on the cost of supply of the rise in oil prices. These have led transatlantic carriers to withdraw from Stansted and Ryanair, the Airport’s principal customer, to announce that if oil prices stay at their current level, it will manage only to break even in the current year. The demand projections which underlie BAA’s applications seem unlikely to be fulfilled.
b. Whatever the merits of the arguments about the economic benefits of aviation generally, it is clear that those of Stansted are adverse to the UK economy. The dominant demand arises from UK residents taking holidays abroad – an activity which worsens the UK’s substantial trade deficit in tourism. The principal carrier at the Airport is Ryanair – a foreign domiciled airline for regulation and tax purposes.
c. BAA has not offered any evidence in support for this application from any of its airline customers and passenger numbers using the Airport from January to May of 2008 were 4.4% fewer than for the same period last year. Demand may have peaked within the currently permitted limit.
d. The Government’s Sustainable Development Commission recently reported that the economics of aviation and its contribution to global warning were matters of great concern which had not been properly investigated. It called for an independent inquiry into these issues before any further airport expansion was allowed. We agree with them.
1. Since its takeover by Ferrovial BAA have been reported as finding it difficult to arrange for the rescheduling of the loans taken out to secure the acquisition, partly as a result of the credit crunch referred to at 3a above.
2. BAA is currently in dispute with Ryanair about landing charges at Stansted. Ryanair accounts for some two thirds of the Airport’s business. The airline is withholding payment of the latest increase in landing charges which BAA tried to impose.
3. BAA’s monopoly of London’s airport capacity is currently the subject of a Competition Commission inquiry. Whether BAA will remain substantially unaltered as a corporate entity and whether Stansted Airport will continue in its ownership remain to be seen.
4. Taking these factors together, it seems that BAA (or an alternative owner) may have difficulty both in raising the capital necessary to fund the proposed investment and in securing the income from landing charges which would be needed to service the capital.
a. BAA envisages in its applications that the Airport would have a passenger throughput three times as great as today, with a commensurate increase in the number of aircraft movements. By assuming that the G1 application will be approved on terms which fall short of full use of the existing runway but which will nevertheless allow G2 to proceed, it portrays the incremental damage of G2 compared with this artificial base case as being relatively insignificant and the mitigation it proposes is similarly insignificant.
b. The Civic Federation on the other hand takes the view that, although there will not be a direct mathematical relationship, an Airport which is three times as busy as now is likely to cause three times as much nuisance as now.
c. At the G1 Inquiry the Civic Federation gave evidence against the application on the subjects of roads and parking, rail services, noise, and housing and community cohesion. Copies of the proofs of evidence are attached. The objections contained in them remain equally valid in relation to the G2 application.
There is no need for the G2 applications to have been made at this point in time, and strong arguments for concluding that they are both premature and, for all the volume of information, unsupported by relevant evidence. The longer term future of the Airport may become clearer after the G1 application has been determined, after the outcome of the NATS study of the redistribution of airspace is known, after the studies on rail enhancements (and also on the road network) commissioned by the Secretary of State for Transport have been published and after the Competition Commission has concluded its investigation. Even if these leave open the possibility of further expansion of the Airport the next step would clearly not be to do so by means of a second runway.
A better appreciation of the impact of the proposals could have been gained if BAA had based the application on a comparison with conditions at present. They have carefully avoided doing so but chosen instead an entirely artificial base case whose sole purpose appears to be to flatter G2 by apparently minimising its adverse consequences. BAA have presented no evidence of support from their customers for the proposals or of any urgent demand which could only satisfied by the G2 proposals. Indeed the current economic climate is bearing down heavily on demand for air travel while calling into question BAA’s ability to fund the G2 proposals if planning approval were obtained.
In these circumstances it is difficult to avoid the conclusion that these are frivolous applications, made without any serious intention of implementing them should permission be granted. Instead their purpose appears rather to be to weaken through exhaustion and depletion of resources, both the opposition to Airport expansion and the ability of Uttlesford District Council to give proper consideration to any future proposal for the development of the Airport. The right course of action would be to invite the applicants to withdraw their proposals until resolution of the matters I have listed above makes it clear whether such applications would ever be relevant in the future and, if so, at what time. Failing that, the applications should be turned down as soon as possible. To do otherwise would simply subject surrounding communities to unnecessarily prolonged blight.
Should any of the uncertainties referred to above be resolved within the extended period for comment which you have recently allowed, the Civic Federation reserves the right to make further representations to you.
I ought finally to say for the avoidance of doubt that these comments do not apply to the Transport and Works Act application to build a 2nd rail tunnel and 4th Airport station platform. Arguably, these are needed now even without further Airport expansion.JOHN RHODES