london city airport report by 3L55a6Er


									                                                              planning report PDU/1471a/01

                                                                              14 March 2008

                                                        London City Airport
                                                    in the London Borough of Newham

Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999; Town
& Country Planning (Mayor of London) Order 2000.

The proposal
Application under Section 73 of the Town and Country Planning Act 1990 to vary conditions 13
and 15 of the outline planning permission no. N/82/104 dated 23 May 1985, as previously
varied by the Secretary of State on the 26 September 1991 and by the London Borough of
Newham on 21 July 1998 and 11 July 2007, to allow up to 120,000 total aircraft movements per
annum with related modifications to other limits including noise factored movements.

Strategic issues
The key strategic issues considered in this report include: the contribution the airport makes
towards the regeneration of the area; the constraints the continuing presence of the airport will
have upon the potential development capacity of the area, noise impacts, impact upon the blue
ribbon network, air quality impacts, climate change and transportation.

That the Head of the Greater London Authority’s Planning Decisions Unit endorses the position
set out in the conclusions of this report.

                                                                                        page 1
1      On the 24 August 2007 Newham Council consulted the Mayor on the above proposals,
and on the 8 January 2008 informed the GLA that it had received additional information on
the application as a result of a Regulation 19 request for further environmental information.
On the 30 January 2008 the borough advised the GLA that they were intending to report the
application to their 12 March 2008 Development Control Committee. On the 7 March 2008
Newham Council advised that additional material had been requested and as a result the
application was now likely to be determined in April or May 2008.

2      The application is not referable under the terms of the Mayor of London Order 2000,
hence the Mayor is only a consultee on the proposals and has no powers to direct refusal.
Furthermore, as it is a not a referred application, the Mayor’s response will be provided by the
Head of the GLA’s Planning Decisions Unit, whose comments will be made available on the
GLA website

Site description
3      London City Airport is located in the Royal Docks, between King George V Dock to
the south and Albert Dock to the north. The Airport is approximately 3.2 km east of Canary
Wharf, and situated some 800m south of the Excel Exhibition and Conference Centre.

4      The application site is 48.5 hectares and currently comprises a single runway, an 'apron'
area (where aircraft park to embark and disembark passengers), a main passenger terminal, a
Jet Centre, and various operational buildings. The runway is surrounded by the water of the
Royal Albert Dock and the King George V Dock. See Figure 1.0 below.

5      Since 2005 the airport has been served by the Docklands Light Railway (DLR), which
provides direct access to the Airport's main passenger terminal.

Planning history
6       The airport was originally approved by the Secretary of State in 1985, and has been the
subject of a number of subsequent additional approvals and amendments. Of substantive
significance to this report, is a permission granted in 1998 that established a limit or cap of
73,000 scheduled Air Traffic Movements (ATM’s). This cap was maintained, but adjusted to
allow a different weekly operating pattern by a consent granted by Newham Council on the 11
June 2007. There are currently no restrictions on general aviation movements such as
corporate jets.

7        The passenger terminal building provides check-in and baggage facilities, ticket desks,
security, a departure lounge, immigration and customs, shops, a business centre and catering
outlets. The first floor departure lounge was reconfigured and expanded in 1997, and in 2001
the terminal building was extended westwards to provide additional accommodation and

8      The airport currently has fourteen aircraft stands, ten of which are served by a
dedicated pier, with buses serving the remaining four. In 2001, London City Airport was
granted planning permission by Newham Council to build a holding point and five additional
stands that are currently under construction.

                                                                                         page 2
9       As set out above, the existing planning permissions permit 73,000 Air Transport
Movements (ATMs) per year, plus an unregulated number of general aviation movements,
mostly comprising corporate jets from the corporate aviation1 building (known as the "Jet
Centre"). In 2006, there were approximately 56,000 general aviation aircraft movements, and
13,700 aircraft movements from the Jet Centre, (62% of which were outside of the current
restrictions); giving an overall total of 79,616 recorded flights.

10      The applicants propose to unify these two different types of aircraft operations under a
single regulatory cap of 120,000 movements per year. This represents an increase of some 50%
on the 2006 level of activity.

11     The applicant also proposes to vary other planning restrictions including an increase in
the number of daily, weekly and bank holiday movements. However, they have confirmed that
they are not seeking to change the current hours of operation, so that the 24 hour 'no-flight'
period at weekends would be preserved, and flights would not be allowed after 10.30pm, or
before 6.30am on other days, barring exceptional circumstances2.

12      This increase is presented as an initial phase of growth that would integrate general
aviation within a new movement cap, and would involve no new built infrastructure beyond
that already in place or approved. The applicants anticipate new applications would submitted
to provide facilities to the meet longer term physical growth of London City Airport which
would be judged on their own merits.

The 2006 Masterplan
13      The Government’s 2003 White Paper on the future of Air Transport in the UK set outs
its strategic approach to airport capacity, and encouraged a number of airports to prepare
masterplans that would take account of the White Paper’s conclusions, set out their
development ambitions, and inform future development plan documents.

14      The White Paper made no recommendations in respect of City Airport, merely noting
that its forecasts showed that the airport was likely to grow steadily, that this growth would
not be significantly affected by the addition of runway capacity at the major London airports,
that it was well placed to serve a niche business, that several of the surrounding local
authorities supported growth, and that the airport operator believed that with some further
development a higher throughput could be achieved

15      London City Airport prepared a draft masterplan in March 2006. This document set
out the airport’s ambitions to expand to meet forecast demand, and envisaged increasing
flights at City airport from the then (2005) 61,000 Scheduled Air Transport Movements
(71,000 aircraft movements), to 100,000 movements per year in 2015, and 143,000 movements
in 2030.

16   On the 7 June 2006 the Mayor considered a report on the Draft Masterplan (ref.
PDU/1471/01). This report is attached as Appendix 1.

17      The Mayor concluded that:

1 Corporate aviation referring here to the ownership and operation of aircraft by individuals and companies in
conducting their business and therefore not for public hire or scheduled movements.
2 None Technical summary page 2.

                                                                                                         page 3
          The proposals contained in the draft masterplan would need to weigh the economic
           benefits of growth in London City Airport capacity to London’s economy – and that
           of the Thames Gateway in particular – against the disbenefits of amenity loss or
           diminution, environmental harm, and loss of development capacity in the London
           Thames Gateway area.

          Any planned extension in airport capacity should be demonstrably sustainable.

          Any adverse impacts on climate change, air quality and noise must be sufficiently

          Public transport access should be improved.

          The completion of Crossrail could prompt reconsideration of the future of London
           City Airport itself.

18      London City Airport published their revised Masterplan in November 2006. This
document summarised the results of the wider consultation it carried out and restated the
airport’s expansion ambitions. It better reflected London Plan policies and objectives in a
number of areas, but did not directly address the Mayor’s main concerns set out in the report
and his formal reply.

19     The Masterplan does not form part of the Development Plan, and hence there is no
presumption that its ambitions should be accepted or agreed, or that any planning application
should be approved as it would still need to be assessed and determined in accordance with the
development plan unless material planning considerations indicated otherwise.

Strategic planning issues and relevant policies and guidance
20     The relevant issues and corresponding policies are as follows:

          Economic development     London Plan; London’s Economic Development Strategy

          Housing                  London Plan; Housing SPG

          Regeneration             London Plan; London’s Economic Development Strategy

          Transport                London Plan; the Mayor’s Transport Strategy; PPG13

          Parking                  London Plan; the Mayor’s Transport Strategy; PPG13

          Employment               London Plan; PPG4

          Noise                    London Plan; Mayor’s Ambient Noise Strategy

          Air Quality              London Plan; Mayor’s Air Quality Strategy

          Blue Ribbon Network      London Plan

          Sustainable development London Plan; PPS1, PPG3; PPG13; PPS22; the Mayor’s
           Energy Strategy; Sustainable Design and Construction SPG

                                                                                       page 4
Airport policy
21     As set out above, the Government’s overall approach to airport expansion as set out in
its 2003 White Paper, made no specific recommendations for the future of City Airport.

22      Objective 5 of the consolidated London Plan (To improve London’s accessibility),
emphases the need to strengthen measures to reduce CO2 emissions and the negative impacts
of transport on air quality; whilst improving international, national and regional transport
access to London, including a sustainable and balanced London area airport system.

23      Paragraph 1.5 states that London requires excellent global communications to maintain
its world gateway city status and identifies the need for transport improvements and
significant additional airport and port capacity, located to serve spatial and economic priorities.
The Plan also recognises that mitigation of and adaptation to climate change will require co-
ordination of policies across the wider metropolitan area (para 1.20).

24     Policy 3C.5 (London’s international, national and regional transport links), commits the
Mayor to work with strategic partners to improve and expand London’s international and
national transport links, to support London’s development, to achieve the spatial priorities of
the plan, (especially to support growth in the Thames Gateway), and to achieve regeneration
benefits while mitigating adverse environmental impacts.

25     Policy 3C.6 (Airport development and operation) commits the Mayor to supporting the
development of a sustainable and balanced London area airport system, whilst recognising that
some further runway capacity in the South East will be required to meet London’s needs.

26     The Policy also recognises that airport capacity must be sufficient to sustain London’s
competitive position, but confirms that providing a level of capacity sufficient to meet
unconstrained demand is untenable, and that the aviation industry should meet its full
environmental and external costs.

27     Policy 3C.6 also confirms that airport operations should also give high priority to
sustainability, and take full account should be taken of environmental impacts when decisions
are taken on patterns of aircraft operation.

28      In February 2007 the Mayor published his Climate Change Action Plan setting out his
views, plans and proposals to address the impacts and causes of climate change. This document
specifically considered the impacts of aviation emissions on climate change, and noted that
aviation is one of the most environmentally damaging modes of transport, that per passenger
kilometre air travel is the most CO2 intensive form of travel, and that impact on the climate is
exacerbated by the release of CO2 and other greenhouse gasses high in the atmosphere, where
the negative impact of such emissions is more than doubled3.

29      The report identified two interrelated problems in respect of aviation. Firstly that the
real price of carbon emissions is not built into the price of air travel – meaning each air trip
causes damage that does not have to be paid for and which could only be dealt with by
including aviation within a comprehensive system of carbon pricing. And secondly that until
such a comprehensive system of carbon pricing is introduced, physical controls and/or
financial disincentives are needed to prevent unacceptable damage being done by the build up
of emissions from aviation.

3 The   Mayor’s 2007 Climate Change Action Plan, section 4.6 – Emissions from aviation.

                                                                                           page 5
30     As a result, the document commits the Mayor to challenge the need for further runway
expansion at UK airports, and to promote demand management mechanisms to limit
unsustainable growth in low-value flights.

31     The London Plan identifies the Royal Docks (within which City Airport is situated) as
a major opportunity area with substantial development potential (5,500 new jobs and a
minimum of 14,000 new homes between 2001 and 2026). Specifically, the Mayor’s vision for
the area anticipates substantial intensification and concentration of development to allow it to
become a model of high-density, well-connected and mixed development.

32      The Plan also commits the Mayor to work with the LTGDC, LB Newham and other
partners to develop a planning framework which will provide a clear overarching spatial vision
for the Royals including future land uses, a network of the local centres to accommodate
social/community infrastructure and public transport hubs, and a strategy to improve and
coordinate local movement and landscape infrastructure.

33      The Plan states that North East London should become one of London’s major
gateways to mainland Europe, building particularly on the Stratford International railway
station, but also on access to the City and Stansted airports, the Channel Tunnel and the Port
of London. Economic development should be geared for the long-term opportunities these

34     Material submitted with the application states that in 2006 City Airport provided some
1501 full time equivalent jobs, and supported an additional 470 FTE jobs. This provided an
income of approximately £59m (at 2004 values), and that 35% of these workers lived in
Newham with 68% living within five miles of the airport. The applicants also suggest that the
sought expansion would raise total employment at the airport to 2277, with an additional 612
indirect jobs.

35      Within this context it should therefore be recognised that the airport makes a
significant contribution towards the local economy, and that the airport is a major employer
within an area of relatively high unemployment, though the submitted material does not
provide an indication of employment potential from an alternative employment use for the site.

36     The Government’s Air Transport White Paper and the Mayor’s Ambient Noise
Strategy support implementation of the International Civil Aviation Organisation’s fourfold
approach to managing aircraft noise, namely

           Reducing noise emissions at certification stage (e.g. through aircraft design),

           Noise abatement operating procedures (e.g. through keeping to agreed routes)

           Operational restrictions (e.g. night bans); and

           Town planning (e.g. limiting the growth of noise sensitive uses, especially housing,
            in areas close to airports).

                                                                                          page 6
37      Historically, city authorities have tended to adopt short-term approaches, allowing
noise sensitive development on land around airports in response to immediate housing and
other pressures, while the airport achieves incremental expansion in its operations. This had
tended to maximise noise exposure and community conflict for any given level of aviation
capacity. This is one of the reasons behind the recommendation in the White Paper for airport
operators to produce Masterplans. These are intended to clarify growth ambitions, so that
local planning authorities can respond appropriately and seek to minimise land use conflicts.

38     London City Airport is close to existing residential communities, with some homes
within a hundred metres of the runway (notably to the south in Silvertown and North
Woolwich). Furthermore, the Lower Lea Valley Opportunity Area Planning Framework
anticipates between 2,000 and 3,000 homes being built in Newham Thameside West up till

The airport currently receives few noise complaints compared with many airports. It is open
between 6.30 am and 10 pm on weekdays and has limits on the number of flights in the
sensitive 6.00 to 7.00 am period. It is closed at night, and for a 24 hour period in the middle of
the weekend (12.30 midday on Saturday to 12.30 midday on Sunday). The current application
does not propose to change the current hours of operation of the airport.

39      The airport can only be used by aircraft able to demonstrate they can meet certain
noise limits. Aircraft are also required to land on a glideslope of 5.5 degrees (compared with 3
degrees at Heathrow and most other airports), which in turn reduces the extent of noise

40      The Airport’s Masterplan included maps showing calculated airborne aircraft noise
contours for 2005, 2015 and 2030, in 3 dB steps from 69 dBLAeq,16 hour down, to 57 dBLAeq,16 hour,
(noise levels ‘averaged’ over a typical 16 hour day, the latter generally being described as the
‘onset of significant community annoyance’, though noise is still audible and may annoy at
lower levels).

41     Future contours illustrated how the area affected by ‘averaged’ aircraft noise would
increase in extent, affecting residential communities currently outside the 57 contour, for
example, in Canning Town. The Masterplan did not however, provide estimates of the
projected increases in land area affected by spreading of the contours, nor of the existing or
future numbers of residents affected.

42     The projected contours also assumed that existing departure routes would be used (e.g.
currently aircraft turn north up the Lower Lee on westerly operations). The airport
Masterplan commented that these routes (based on current airspace control and aircraft
navigation technology) might have insufficient capacity by 2030. National Air Traffic Services
(NATS) is currently carrying out an airspace change consultation on some changes. Further
changes could be required if full expansion were to follow, though it is unclear exactly how
wider areas indicated in the London Plan and Local Development Plans for significant
population growth, including identified Opportunity Areas might be affected in future.

43     The current application includes an Environmental Statement Addendum, covering air
and ground noise from aircraft, and road traffic noise. Average mode noise contours have been
produced on the basis of 66.7% of aircraft landing and take-off movements being towards the
west and 33.3% towards the east. The area covered by the 57 dB LAeq,16 hour contour, would
increase by 41% by 2010 compared with a 2006 baseline. The estimated residential population
within this 57 dBA contour would, taking account of approved or ‘allocated’ developments,
increase by 3.7 times, from 7,100 to 26,200 people.

                                                                                           page 7
44     Estimated changes at example locations around the airport are included in the
Assessment. For example, at the proposed Silvertown Quays development, levels as high as 65
dB are found now which is close to the PPG 24 boundary between Category B and C. In 2010,
with expansion, aircraft noise levels would increase by up to 2dB to 3dB, producing levels of
up to 68 dB LAeq,16h, at the proposed Silvertown Quays development, a significant level of
noise equivalent to PPG 24 Category C where noise mitigation is required, if planning
permission is not simply to be refused.

45       Single mode contours, to represent exposure when all movements in the modelled
period are in one direction, have been produced as a sensitivity test, though the population
figures presented for these modes only include existing, not approved or ‘allocated’
development. Westerly operations in 2010 with expansion would give rise to increases of up to
3dB in Silvertown compared with now. Easterly operations in 2010 with expansion would give
rise to increases of up to 3dB in departure noise in parts of Thamesmead. Sensitivity tests
varying the proportion of scheduled services and corporate aircraft movements show a small
effect on contour size.

46    Some hours in the day would experience greater changes than others, for example,
more movements in the sensitive 0600 to 0700 hour and 2100 to 2200 hour periods.

47       Fleet mix assumptions produced for ground noise modelling suggest that the
percentage of turbofans (jets) would increase from 30% in 2006 to 58% in 2010, while the
percentage of turboprops would fall from 52% to 21%. While turbofans are not necessarily, or
in all circumstances, noisier than turboprops (e.g. the latter can generate higher maximum
levels when taxiing), the change in character of the noise, combined with a 50% increase in
numbers of movements, over a short period of up to four years, combined with larger changes
in sensitive periods of the day, mean that ‘average’ estimates of the likelihood of increased
annoyance used in the Environmental Assessment may not fully reflect people’s responses to
the proposed expansion, i.e. adverse reactions among affected people can be expected to

48     The assessment uses noise contours down to 57 dB LAeq,16 hour, as has become common
UK practice deriving from the Aircraft Noise Index Study (ANIS) of 1982-5. Since then,
however, overall air traffic has grown significantly, while individual aircraft noise events have
become quieter, as older, noisier aircraft types have been replaced with more modern aircraft
with quieter engines and much improved climb performance. Attitudes to aircraft noise may
also have changed due, for example, to growth in personal income and environmental
expectations. The aircraft noise indicator (Leq) adopted after the ANIS study may thus be less
appropriate for present day conditions.

49       The study ‘Attitudes to Noise from Aviation Sources in England’ (ANASE), announced
by the Department for Transport (DfT) in 2001 and released in November 2007, included
examination of whether the current understanding of the links between reported annoyance
and aircraft noise levels still held. The Environmental Assessment analyses ANASE in such a
way as to suggest that existing guidance on likelihood of annoyance can still be used.
Controversy over alleged flaws in ANASE is likely to continue. However, independently of
this, it is reasonable to say that the sheer number of aircraft, as distinct from overall ‘averaged’
noise, is important to people.

                                                                                            page 8
50      There is though no way of fully mitigating the effects of such growth in numbers on
the affected areas, and the implications of such growth, and the further growth set out in the
Masterplan, if approved, would need to be taken fully into account in allocation of land for
noise sensitive uses, and in planning and design of development in affected areas.

51    It may therefore well be that housing development in the more affected areas should or
would need to be designed to be capable of migration to non-residential or short stay
accommodation to avoid unsuitable conditions for general family living.

52      Many detailed noise control issues will need to be addressed by Newham Council such
as screening of ground noise and operational practices. For example, the existing sound
insulation scheme for the airport covers a wider area (down to 57 dB LAeq,16 hour) than at most
other airports, but is relatively limited in nature.

53     However, the standard of the insulation package offered would need to be reappraised
for properties closer to the airport, as the area covered by noise at higher levels expands.
Changes in aircraft departure routes need to be clarified as soon as possible for planning and
design of noise sensitive development in areas extending beyond the 57 dB LAeq,16 hour, contour.

54      There are therefore a number of noise issues that could adversely affect amenity and
good living conditions for existing and planned residential communities in the vicinity of the

Blue ribbon network
55     The proposals do not seek permission to deck over or infill parts of the King George V
Dock, as at the moment LCY are only seeking permission for the principle of increasing the
number of flights that can use the airport. London City Airport are though currently
implementing an earlier planning permission that permits partial decking over of the Dock,
and London City Airport’s Masterplan envisaged that as part of its future expansion plans
further parts of the Dock would be built on to increase the amount of hard standing areas the
airport provides.

56      Any such proposal would be contrary to London Plan policy 4C.23 (Docks), which
requires boroughs to prevent the partial or complete in filling of docks and to promote their
vitality, attractiveness and historical interest. Under current Regulations though, as with this
application, any such application would not be referable to the Mayor.

Air Quality
57     Policy 4A.19 of the London Plan (Improving air quality) states that the “Mayor will
and boroughs should implement the Mayor’s Air Quality Strategy and achieve reductions in
pollutant emissions and public exposure to pollution”.

58     London City Airport submitted an assessment of the impact of the proposals on air
quality as part of their Environmental Impact Assessment (prepared by Air Quality
Consultants Ltd). It assumed 95,000 scheduled airline movements, plus a further 25,000
unscheduled movements, with approximately 3.9 million scheduled ATM passengers per
annum (mppa).

                                                                                         page 9
59      The assessment focused on two pollutants with potential human heath effects -
nitrogen dioxide and particulate matter (PM10). Consideration was also given to the potential
effects of odour nuisance. The study assumed there would be unlikely to be any significant
effects arising from emissions of benzene, 1,3-butadiene, carbon monoxide, lead or sulphur

60     Emissions of NOx and PM10 may arise from a number of Airport sources including:

          Aircraft on stand, taxiing to and from the runway, and during takeoff and landing;

          Airside vehicle movements - e.g. baggage handling and catering;

          Stationary sources - e.g. boiler plant.

61      The submitted material concluded that predicted concentrations in 2010 would be
higher should the proposals go ahead due to the increased traffic flows on the local road
network, but that predicted concentrations of both nitrogen dioxide and PM10 would remain
below the objectives at all receptor locations, and hence would be so small as not be a
significant consideration.

62     However, officers are of the view that this statement could not be verified as the maps
in the Masterplan did not indicate the locations of the nearest housing and other sensitive
receptors (for example hospitals and schools) in relation to the airport and planned new

63      The Masterplan identified limitations in modelling, but did not commit to any
improvements. Significant work has gone into modelling at Heathrow and this could be used
to inform modelling at London City Airport. Emissions modelling needs to be improved and
more detailed source apportionment work for the emissions from the airport should be carried

64      Even though the operational size of the airport would still remain below the threshold
criterion for which a detailed assessment of direct airport sources of pollution would be
required, the future changes to the footprint of emissions and the likely overall increase in
emissions needs to be more accurately predicted and modelled to ensure protection of nearby
residents and other sensitive receptors.

65     In terms of odour, the consultants conclude that the additional movements associated
with the proposed scheme are unlikely to produce a significant change in the frequency of
complaints from the currently exposed residential areas, provided that management
procedures to control this impact are maintained.

66     The London City Airport is situated within the largely decommissioned and re-
developed Royal Docks basin, alongside the River Thames. Part of the airport is within a non-
statutory Site of Importance for Nature Conservation (at Borough level); the Royal Docks, the
primary biodiversity interest of which is for breeding and wintering birds.

                                                                                       page 10
67      In a wider zone of potential impact there is one statutory protected site; the Inner
Thames Marshes Site of Special Scientific Interest, part of which (Rainham Marshes) is now
managed as a nature reserve by the Royal Society for the Protection of Birds. This site is 7.5
km east of City Airport). There are also several further non-statutory SINCs in this wider zone
of potential impact.

68     Currently the presence of the airport acts as a constraint on the potential biodiversity
value of the Royal Docks SINC. This is because of the requirement for management to limit
the presence of roosting birds due to safety issues. Increased capacity at the airport may
increase this concern and limitation management in response.

69     Potential indirect impacts on biodiversity involve degradation and disturbance of
constituent habitats and species in protected sites within the vicinity of the airport and there
could also be a corresponding loss of amenity value for people appreciating wildlife at these

70     It is therefore recommended that a full ecological impact assessments are undertaken to
address these issues and a mitigation strategy proposed to address potential impacts. This may
involve the dedication and management of an area of non-operational land for biodiversity
conservation purposes, for example a nature reserve or similar .

Climate Change
71      In the Mayor’s comments on City Airport’s 2006 draft Masterplan, he concluded that
to help mitigate against any increase in carbon emissions from increases in the numbers of
flights from the airport, London City Airport should make a clear commitment towards
promoting a ‘Greener Airport’. The measures suggested were:

          To use sustainable construction techniques for any the new buildings.

          To evaluate the feasibility of the use of Combined Heat and Power (CHP).

          To ensure maximum use of public transport to the airport and to develop clear
           public transport targets through the production of a ‘Green Travel plan’.

          To offset aviation emissions.

72     A draft travel plan has been included in the submitted material which is considered in
the transport section below.

73     The application also material includes a Sustainability Appraisal and Carbon Analysis
Report that addresses energy and sustainability issues. However, it focuses primarily on
current management practices and commitments that LCY has already implemented to reduce
energy consumption, such as purchasing electricity from accredited renewable sources and
reducing energy use through increased staff awareness. It also anticipates that any future
application to seek consent to develop the Airport to 2030 would be accompanied by a
comprehensive assessment of energy demand and usage and be accompanied by an Energy
Strategy that would include proposals for on-site renewable energy sources, CHP or Tri-

                                                                                         page 11
74     The proposals therefore have not responded adequately to the Mayor’s comments on
the draft Masterplan and have not committed to use sustainable construction techniques or
submitted an evaluation of the feasibility of using Combined Heat and Power.

75    On carbon emissions, the applicants submission places great weight on the fact that the
Governments Air Traffic White Paper, and concludes that:

       “The best way of ensuring that aviation contributes towards the goal of climate
       stabilisation would be through a well-designed emissions trading scheme”.

76      Attention is then drawn to the Governments Progress Report which in their view
reaffirms the Government’s policy for tackling the climate change impacts of aviation, where
paragraph 2.10 states:

       “The Government continues to believe that this can be done by emissions trading. This
       mechanism – which already operates across the EU in other sectors – should be
       extended to the aviation sector at the earliest opportunity. Inclusion of aviation in the
       emissions trading scheme is the most efficient and cost effective way to ensure that the
       sector plays its part in tackling climate change. This approach was endorsed by Sir
       Nicholas Stern’s recent report on the economics of climate change, which strongly
       supports carbon pricing to ensure that economic decisions fully reflect social and
       environmental costs.”

77      The airport’s consultants also suggest that the greenhouse gas emissions under the
direct influence of the Airport are anticipated to be minimally affected by the expansion plans,
and are therefore considered neutral for the purposes of the assessment. They also advise that
the airport is in the process of developing a comprehensive carbon management strategy to be
applied to emissions both within and outside of the Airport’s direct control which once
completed and implemented would enable the airport to achieve objectives to minimise
greenhouse gas emissions. No details of this are though provided.

78     Finally the consultants argue that the wider issue of climate changes effects of
increased aviation are addressed through fiscal central government initiatives, and that this
would be achieved primarily by including aviation in the EU Emissions Trading Scheme -
which will place a price on carbon emissions.

79      The European Commission proposal (supported by UK Government) provides for
aviation to be brought into the EU ETS in two steps. From the start of 2011, emissions from
all domestic and international flights between EU airports will be covered. One year later, at
the start of 2012, the scope will be expanded to cover emissions from all international flights -
from or to anywhere in the world - that arrive at or depart from an EU airport.

80      Therefore, while Government and the EU’s intention is clear, there is as yet no
concrete guarantee of a scheme that would fully account for the external environmental costs
of environmental damage arising from the greenhouse gas emissions from aviation. One reason
for added concern is the lack of a commercially available, low carbon aviation technology that
might avoid the emissions associated with any expansion. The proposed expansion would
therefore inevitably result in an increase in greenhouse gas emissions.

81     Given the risk of irreversible climate change occurring in the near future, any such
increase would be of great concern, particularly as the greenhouse gasses the proposals would
generate would be emitted at high level in he atmosphere, thereby increasing their adverse
impact still further.

                                                                                         page 12
Transport issues
Thames Gateway Bridge (TGB)

82      London City Airport has confirmed that that the current application makes no
changes to the ‘Safeguarded and Obstacle Limitation Surfaces London City Airport Aerodrome
Standards Department Safety Regulations Group, Civil Aviation Authority, 2004.’ On this
basis there are no objections from a TGB perspective.

Public Carriage Office

83      Clarification was requested regarding terminology, as much of the “taxi” discussion is
about hackney carriages, but some text in the Transport Assessment suggests that minicabs
are included in this term. Chauffer services are discussed with private vehicles but in
legislation and regulations, there is a distinction between taxis (hackney carriages/ “black
cabs”) and private hire vehicles, which include minicabs and most chauffer services. Additional
information regarding taxi terminology and provisions has now been received from the
applicant’s transport consultants.

Buses and Coaches

84     It should be noted that route 474 will shortly be altered to operate 24-hours, with half-
hourly overnight service. This will provide a public transport link to the airport at times when
the Docklands Light Railway is not running. It is recognised that the local bus network is
most important for staff travelling to and from the airport. With staff numbers increasing by
50% this will put further demands on the bus network and this additional pressure should be
more carefully considered in the future.

85      Clarification was requested regarding the mode share targets and forecasts in the
Airport Masterplan (Section 7.4) as compared with the interim planning application, i.e., it is
unclear how the Masterplan’s expectations of an increase in bus share to 3% by 2015 and an
increase in staff by 50% by 2015 relate to the current application. Based on the July Transport
Assessment’s Chart 4.5, this increase could be 15-20 passengers in the peak periods in terms of
air passengers alone. Route 474 is operating close to capacity in this area and London Buses
will conduct surveys on routes 473 and 474 at the airport and at nearby North Woolwich to
determine airport demand levels and future capacity requirements, which will be discussed
with the applicant.

86       There are no immediate bus priority measures needed as a result of the proposed
increase in air passenger throughput. However, if the airport continues to expand, future
traffic levels will increase and any subsequent expansion will need to consider the impact on
the capacity and efficiency of bus routes servicing the airport.

87     It is understood that the airport is primarily a gateway for business travellers; however,
given the expected increase in passenger numbers it is logical to expect some group travellers,
particularly during the run up and over the duration of the Olympic and Paralympic games.
The airport should consider an increase in coach parking facilities that are in line with
increased future passenger movements. Confirmation is welcomed that there is an existing lay-
by on Hartmann Road that is able to accommodate two 15m vehicles, and that the airport is in
discussion with the Olympics Delivery Authority about its use during the Olympic and
Paralympic Games.

                                                                                        page 13
Docklands Light Railway (DLR)

88      Given that the DLR has achieved a 48% mode share of trips to and from the airport4, it
is considered that any future airport growth should be met with an obligation to ensure that
the airport, along with the DLR, will make efforts as far as are reasonably practicable to
increase DLR mode share to a target of 80%. This would improve the sustainability of any
airport growth and help to reduce the growth in road-based generated traffic. Should the
application be approved, an obligation should be secured to commit to achieving this mode
share through measures to be outlined in the Airport’s Surface Access Strategy.

89     Docklands Light Railway Limited (DLRL) has assessed the impact of the airport’s
growth against the capacity that will be available on the network. It is recognised that over the
coming years large scale development is to be built along the DLR line (e.g., Silvertown
Quays, Minoco Wharf, and Barrier Park East). In addition, future services departing from
King George V will be accommodating demand from Woolwich Arsenal. Therefore, the
impacts of the airport and its increased patronage must be viewed in the context with the
cumulative demand from other trip generating sites.

90      Discussions are ongoing with the transport consultants regarding reasonable worst-
case scenarios for the DLR network. DLRL worst-case analyses indicate that crowding ratios
could increase to 1.5 on some links from the airport to Canning Town, such that heavy
crowding and unpleasant journeys on the DLR and could result in some users being crowded
off the system and using less sustainable alternatives. Even at a mode share of 65% (one that is
likely to be achieved by 2010), crowding ratios of more than 1.3 would be anticipated.

91     The worst-case scenario considered in the Addendum underplays the impact of the
application. The DLRL assessment has demonstrated that there would be a clear need to
increase train capacity through the addition of a third rail car to 5 of the trains per hour,
preferably on the Woolwich Arsenal to London City Airport line in order to benefit the market
that the airport serves as fully as possible.

92     The addendum notes that even without growth at London City Airport , DLR
modelling forecasts crowding on the line. This is due to the cumulative impact of new demand
from Woolwich Arsenal station, and the impact of Royal Docks developments. DLRL
recognise the impact that these respective developments will also have on the line and would
require contributions to provide further 3-car services, beyond the 5 trains per hour that would
be provided with a contribution from the airport towards procurement of 4 additional rail cars.

93      The addendum’s statement that crowding on the line is typical and reasonable for
travel in London causes concern. It is assumed that, given the nature of airport travel which
typically includes baggage, the airport seeks as comfortable a journey for its passengers and
staff as possible. It is considered that the way to achieve this is to ensure that the capacity on
the line does not create crowded conditions, enabling passengers, including those with
luggage, to travel without experiencing or causing negative impacts.

    See London City Airport Extension Monitoring Report Year One, DLR.

                                                                                           page 14
94      DLRL have determined that London City Airport should make a significant
contribution towards the provision of additional rail cars if the application is to be approved.
The 2007 Transport Assessment incorrectly states that DLR are increasing capacity on the
London City Airport line from 2-car to 3-car trains. The Phase 1 and Phase 2 capacity
enhancements do not apply to the London City Airport line as it was built with the ability to
accommodate 3-car trains. The capacity enhancements that DLRL will undertake will enable
3-car trains to run from London City Airport to and beyond Canning Town. However, whilst
the infrastructure is in place, DLRL do not have the spare rail cars or funding to enable 3-car
trains to be run on the London City Airport line.

95     A contribution of £9m towards the procurement of 4 new rail cars is considered to be
appropriate to enable DLRL to meet the demand that could be generated by the airport with
increased traffic movements. Discussion is ongoing regarding the airport’s potential impact on
the network and its capacity should the proposals be approved, which should be secured
through S106 planning agreement.

Travel Demand Assessment

96      There are a number of points regarding the Transport Assessment and modelling that
have required clarification and discussion with the transport consultants. Specifically,
modelling is needed at Gallions Roundabout to assess the impact of development at the
airport. A transport/ highway strategy for the Gallions Roundabout and associated highway
network is being developed by TfL in partnership with LB Newham, the LDA and LTGDC
and an assessment toolkit has been developed for assessing future development scenarios and
transport options.

97      The first output is an AM peak model using VISSIM and it is envisaged that a PM peak
model will be needed and a consideration is to extend the model to include the airport.
£50,000 would be an initial contribution estimate to extend the model to the airport and to
test airport specific scenarios in discussion with the airport's consultants. This will help to
define any necessary improvements and contributions alongside other area contributions
anticipated to ensure the continued safe operation of the SRN and TLRN.

98      It should be noted that should this application be granted planning permission, this
does not discharge the requirements under the Traffic Management Act 2004. Formal
notifications and approval may be needed for both the temporary works and permanent

Car Parking

99      TfL welcomes the exclusion of additional parking to support the increased airport
operations as well as contributions towards LB Newham’s proposals for parking control on
local streets.

Pedestrians and Cycling

100 Provision of additional information on pedestrian facilities is welcome. Confirmation
has been received that 30 cycle parking stands are provided beneath the DLR line. Monitoring
should be used to determine whether additional spaces are required. TfL supports the Travel
Plan’s intention to extend the availability of showering and changing facilities to employees of
all companies on-site and to promote walking and cycling to all staff; further information on
these measures should be provided, potentially as part of the Travel Plan. .

                                                                                        page 15
Travel Plan

101 It is understood that the Travel Plan has been agreed with LB Newham. In general, the
travel plan is welcomed as it understands the need to reduce car dependency of the staff and
support sustainable transport for staff and passengers. From TfL’s perspective, more detail is
needed in most sections to ensure that the plan will deliver a definite change based on the
increase in operations. Detailed comments on the Plan have been provided to the transport

102 The Plan’s objectives detailed are considered to be comprehensive and specific to the
site; the inclusion of both workforce and passengers is welcomed. The target to reduce
workforce car use from the current level is also welcomed; however, there should be
complementary targets to increase use of more sustainable modes. Passenger targets are
lacking in detail. The management of the travel plan is considered to be very good and the
implementation of a travel plan coordinator with the encouragement of existing businesses to
include a similar role, with requirements of participation for new and renewed leases, is
welcomed. The Travel Plan should include identification of its funding and marketing
measures are acceptable for employees, but more consideration of passengers should be
included. Measures involving the main airport website, ticketing and joint programmes with
the airlines to market sustainable arrivals and departures should be identified. Information on
measures, whilst sufficient in some areas, should be more specific.

103 The season ticket loan scheme should be a mandatory requirement for any new or
renewed leases or business contracts. This should be included as a requirement within the
Travel Plan. There is no mention of parking management; introduction of parking charges or
other disincentive measures, either at a user of corporate level, and these need to be identified
and included in the plan. The inclusion of car sharing is welcomed, but the commitment needs
to be stronger. Taxi sharing would assist in the reduction of taxi trips and support
sustainability. Further work is needed on incentives that will encourage people to take up
sustainable measures.

104 Regarding monitoring, the baseline survey will be a valuable tool in the monitoring
programme, as will annual surveys. However, the Travel Plan does not detail the extent of the
monitoring activity; surveys should continue for 10 years after the baseline. Monitoring needs
to be iTRACE and TRAVL compliant. TRAVL monitoring should occur in years 3, 5, 7 and
10 with iTRACE in the intervening years.

Freight and Servicing

105 The 2007 Planning Statement refers to an increase in servicing movements associated
with the delivery of fuel and other goods to the airport as well as movement of waste. It is
noted that in the Addendum’s Section 4 there is further information provided related to the
servicing of the airport and associated deliveries. Whilst some trips may naturally increase
(including fuel delivery), the statement has not identified anything to mitigate impacts of this
increase and improve upon current levels, such as the movement of fuel by water. Due to the
hazardous nature of the load, this fuel would ideally come by water. It is understood that this is
something that the airport have been investigating and it is unclear why this has not come
through in any documentation. TfL seek maximised use of out of hours deliveries and the use
of the water network to deliver fuel and potentially move waste and discussions to progress
this with TfL should continue.

                                                                                         page 16
Comments of Transport for London
106     Comments of Transport for London have been incorporated into this report.

Comments of the London Development Agency
107 The LDA has significant landowner interests in the airport and has therefore not been
consulted on these proposals.

Local planning authority’s position
108 It is believed that the application will be presented to Newham Council’s Development
Control Sub Committee on the 12 March 2008.

Legal issues
109 The application has been made pursuant to Section 73 of the Town and Country
Planning Act 1990 to vary a condition attached to an earlier permission relating to the number
of flights that are allowed from City Airport each year. The referability of the application has
been considered and it has been concluded that the applications not referable under the
provisions of the Mayor of London Order 2000.

110 The Mayor has however been consulted on the application and may make comments to
the planning authority that must then be taken into consideration when a decision is made on
the application.

Financial considerations
111     There are no financial considerations at this stage.

112 When the Mayor considered the 2006 draft Masterplan, he concluded that application
of the Mayor’s strategic policies to its proposals would need to weigh the economic benefits of
growth of London City Airport to London’s economy, against the disbenefits of amenity loss
or diminution, environmental harm, and loss of development capacity in the London Thames
Gateway area.

113 Furthermore, he concluded that any planned extension in capacity at the airport should
be demonstrably sustainable, that public transport access be improved, and any adverse
impacts on climate change, air quality and noise be sufficiently mitigated.

114 The Mayor also concluded that a decision to proceed with the construction of Crossrail,
which will improve public transport accessibility between the Royal Docks and the rest of
London (including Heathrow Airport), could prompt reconsideration of the future of London
City Airport , and that it would be appropriate for the Government to consider this in its
forthcoming review of the Air Transport White Paper5.

5 There has been no such Government review.

                                                                                       page 17
115 The submitted material does present some information about these matters, however,
as set out above, this is considered to be deficient in a number of areas.

116 It is therefore recommended that the applicants be asked to withdraw their proposals
until there is a much clearer picture of what level of additional airport expansion (if any) might
be sustainable across London and the South East, and where any such growth might be best
accommodated. Furthermore, the full environmental and economic impacts of any such growth
should be better articulated and examined as part of this process.

117 Should London City Airport not agree to defer their proposals until such assessments
have been carried out, it is strongly recommended that the application be refused by Newham
Council on the following grounds:

                  Environmental and climate change impact.

                  Lack of clarity about noise impact on adjoining and nearby residential areas.

118 Finally, should Newham Council not agree to refuse the application, it is recommended
that the Secretary of State be asked to call in the application and convene a Public Inquiry
where such matters of clear strategic concern could be properly and fully explored.
For further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email
Lyndon Fothergill, Case Officer
020 7983 6591 email

                                                                                           page 18

To top