Penshurst Parish Council’s Response to Airports Commission Appraisal Framework Consultation

Penshurst Parish Council’s Response to Airports Commission Appraisal Framework Consultation
Members of Penshurst Parish Council have strong views on such issues as noise impact and the visual intrusion inflicted on the parish by the activities of Gatwick Airport.   These are based on years of experience of living with the daily pressure inflicted by the service provided by Gatwick.    
Contrary to the biased view, ie that a third runway will be built in the South East, Penshurst Parish Council believes this is not in fact the case.  
     ·         the environmental disadvantages of all three options will make them unacceptable;
·        increased effective use of all the runways in the South East will come about through the   introduction of larger aircraft;
·         the fact that Gatwick had fewer flights in 2013 than in 2000 indicates that a new runway is not an urgent requirement;
·         the additional cost per passenger of a new runway will cause airlines to move to other airports;
·         the completion of HS2 from London to Birmingham will make Birmingham airport as attractive to those living north of the Thames in London as Gatwick;
·         if the growth in passenger numbers is as anticipated, the demand will be more direct flights from airports such as Birmingham and Manchester ;
·         it will be found that it does not make economic, environmental or commercial sense to build a new runway at Gatwick while Stansted is forecast to have spare capacity until the late 2040s; 
High Weald Parish Councils Aviation Action Group Response to Airports Commission Appraisal Framework Consultation
The whole Appraisal Framework is predicated on the assumption that another runway will be built in the South East, and that the choice lies between two options at Heathrow and one at Gatwick.  HWPCAAG believes no new runway is needed:
Much of the appraisal information will be supplied by the runway promoters.  They have a clear commercial interest in magnifying the advantages and minimising the disadvantages.  We are glad that the Commission will be taking final responsibility for the appraisals.  We are concerned, however, that this process is likely to concentrate on ensuring a fair comparison between the options, rather than on removing an overall pro-aviation bias.
While the commission intend to involve the Highways Agency and Network Rail to assess the road and rail requirements, it is not clear what role the local authorities and councils will have in assessing the environmental impacts.
Furthermore we wish to restate our position that the group believes that night flights are not necessary.
Finally there should be some provision in the consultation for the enforcement of flying at the maximum height in accordance with CDA in order to minimise noise and visual impact.  This would mean aircraft at above 4000 feet through the group area.
The Appraisal Framework
1.         Are the objectives stated in Table 3.1 suitable for assessing the short-listed options?  If not please explain why not, and suggest any alterations you feel would make them more suitable.
            They are not suitable.  The objective “To maximise wider economic benefits…” does not recognise the fact that in the Gatwick area there is a comparatively low level of unemployment.  Thus the economic expansion associated with a new runway would tend to suck in labour from other parts of the UK or the EU.  Maximising the economic benefits of the Gatwick area would thus tend to worsen the North-South divide and worsen the problems of immigration. 
            The objective should be revised to read ‘To maximise wider economic benefits without attracting substantial inward migration…’
            Leaving this objective as written has the potential to exacerbate the serious public concern over immigration from Europe .  It is evidenced in many public opinion surveys and the success of the United Kingdom Independence Party at recent council elections.
            The objective “To promote employment …” is also inappropriate for the same reason.  If it could be shown that the Gatwick area is likely to suffer serious unemployment during the coming decades, the objective might be correct.  But in fact the Gatwick area is one of the most prosperous in Britain .   Promoting large scale extra employment would only create a shortage of housing, and pressure on all aspects of local infrastructure.
            HWPCAAG believe the objective should be revised to read;  “To maintain employment and to promote sustainable economic growth in the local area and surrounding region.”
            The objective “to minimise impacts on existing landscape character and heritage assets”  is extremely welcome but is not nearly strong enough and is not given enough prominence.  It reads as if it applies only in the immediate vicinity of the airport.   A major concern in the Gatwick area is that a new runway and the associated development would cause widespread and unwelcome urbanisation.  The countryside of Surrey , Sussex and Kent, much of it protected by AONB or Green Belt or Conservation Area designations, is all beautiful and much valued.  Although preventing urbanisation is mentioned later, so far as Gatwick is concerned it should be a prime environmental objective.
The objective should be revised to read; “To prevent urbanisation of the countryside, to minimise impacts on existing landscape character and heritage assets.”  
The objective “To actively engage local groups in scheme progression, design and management.” is one that we distrust.   Local experience is that GAL ignores or misrepresents their views.  At Gatwick recently a local group was closely involved with GAL for a year or so in planning noise reduction measures, only eventually to find that virtually all their ideas were rejected, causing widespread anger and resentment. 
The objective should be revised to read “To keep local groups fully informed of the scheme progression and design, and to take note of any representations they may make.
2.         Are there any other objectives that the Commission should consider, and if so what are they?
The Appraisal Framework is a comprehensive document, and we have no other objectives to add.
3.         Will the appraisal modules described in Appendix A be sufficient to analyse the short-listed options against the stated objectives? If not please explain why not, and provide examples or evidence to support your answer.
·         Local Economy.  We have suggested above that this objective should be amended, to take account of local concerns about migration of labour from elsewhere in the UK and from the EU. We welcome the assurance in paragraph 3.6 that the Commission’s analysis will include urbanisation impacts, such as pressure on local services, facilities and amenities.  We welcome Table A3.1 showing the impact of catalytic development on housing and land use.  It also needs to show the impact of catalytic expansion on local road traffic both as regards journeys to work and commercial traffic (see below).
 
·         Surface Access.  This is not in HWPCAAG area of interest.  The only aspect of surface aspect we are concerned with is any change to the Tonbridge to Gatwick railway line.
 
·         Noise.   This is particularly important to HWPCAAG. We welcome the variety of metrics to be used to measure noise.  But they are all ways to measure noise, and do not necessarily measure annoyance or visual impact in conjunction with noise in an area of outstanding natural beauty, which is visited and enjoyed for its serenity and beauty not its aircraft.  The same level of noise is likely to cause greater annoyance in rural areas, partly because the background noise is lower, and partly because the expectation of peace is greater.  The International Standards Organisation recommends a 10 dB difference in the permitted noise level in rural areas and in urban residential areas. Any comparison between aircraft noise at Gatwick and Heathrow should include a 10 dB difference for rural areas.
The impact of noise at Gatwick stretches far beyond the 57 or even the 54 noise contours.  This is partly because Gatwick is surrounded by Areas of Outstanding Natural Beauty.   Runway promoters should be required to submit, with advice from NATS, illustrative flight paths to and from the new runway.  We welcome the indication in Paragraph 10.16 that such maps will be required, and request that they should be published as part of the Commission’s public consultation in the autumn.
We are sceptical about any attempt to put a money value on the annoyance and health impact of aircraft noise (paragraphs 5.28 -5.32).
 
·         Biodiversity.   We note that Sites of Nature Conservation Importance are not classified separately in the list in section 7.15.  Instead they are included in the catch-all heading for all non-statutory locations, ‘Local Wildlife Sites’. In our area this includes the Bough Beech Nature Reserve – a 45-hectare site of Nature Conservation Interest – which is a mix of open water, marshy grassland, willow scrub, ancient woodland, hedgerow and even a medieval orchard. It also understates the importance of the SSSI in our area; Polebrooke farm which should be protected from the pollution cause by low flying aircraft.  They are the nuts and bolts of British nature, making a vital contribution to delivering both the UK and Local Biodiversity and Geodiversity Action Plan targets and maintaining local natural character and distinctiveness. They provide important and widely distributed wildlife refuges for most of our fauna and flora and, through their connecting, stepping stone and buffering qualities, support other site networks. 
·         Cost.    A new runway at Gatwick would involve a substantial increase in aero charges (landing fees etc).  The appraisal should define the probable cost per passenger.  A comparison between the total cost of the Heathrow options and the Gatwick option would miss the point that the Gatwick cost would be borne by roughly half the number of passengers as the Heathrow options.
The appraisal will also need to take into account that the higher charges per passenger at Gatwick would allow Stansted and Luton airports to attract airlines away from Gatwick (as hinted at in paragraph 3.14), until such time that they are approaching full capacity – and Stansted is not forecast to be full until the late 2040s.  We therefore do not agree with the statement in the Interim Report that Gatwick could operate at 70% capacity in 2030. 
 
4.         Will the appraisal modules described in Appendix A be sufficient to construct business cases and sustainability assessments to enable the Commission to make recommendations and the Government to act on these? If not please explain why not, and provide examples or evidence to support your answer.
We consider that an attempt to construct a business case for a period of 60 years, as suggested in paragraph 5.20, would be meaningless.   A more normal business plan would write off an investment over a period of 20 years (indeed In their latest annual report GAL write off their capital expenditure over a period of 10 years).
5.         Are the five components of the updated scheme design set out in Appendix B suitable for understanding schemes’ potential performance against the stated objectives? If not, please suggest any modifications that you think would make them more suitable.
As stated above, we do not consider that promoting employment should be an objective, except to the extent that it can be achieved without causing inward migration.
6.         Is the level of detail in the components for the updated scheme design set out in Appendix B appropriate given the likelihood that some schemes may not progress to full stages of development? Please provide examples or evidence to support your answer.        
It is not for us to comment on this question.
 
Penshurst Parish Council, as a member, supports the response prepared by The High Weald Parish Councils Aviation Action Group as provided above, we have nothing further to add to this full and accurate report.
 
 
For and on behalf of
Penshurst Parish Council
John Cass
Chairman
 
Penshurst