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SSE Comments on the Draft East of England Plan
14 March 2005
Chapter 4. Policy SS1: achieving sustainable development
Observation
Summary
It is a legal requirement that development should be sustainable. The Sustainability
Appraisal Report which EERA commissioned makes it clear that in several respects the
draft Plan is not sustainable. It should therefore be withdrawn.
More detailed comments
Under S.39 of the Planning and Compulsory Purchase Act EERA, when drawing up its
Regional Spatial Strategy, must exercise this function ‘with the objective of contributing to
the achievement of sustainable development’, and for this purpose it must ‘have regard to
national policies and advice contained in guidance issued by … the Secretary of State’.
The Government has defined sustainable development as ‘a better quality of life for
everyone, now and for generations to come’, and has identified four key objectives which
have to be met at the same time if it is to be achieved. These are:
social progress which recognises the needs of everyone;
effective protection of the environment;
prudent use of natural resources; and
maintenance of high and stable levels of economic growth and employment.
The Sustainability Appraisal Report (SA Report), while commending many of the policies
contained in the Plan, concludes that the national policies for housing and employment
growth in the region will work against the achievement of sustainable development and that
any further major development would be unsustainable. Too much is happening too
quickly: ‘the rate and intensity of economic, housing and infrastructure growth envisaged
for the region, especially its southern parts, is intrinsically damaging to many aspects of the
environment and quality of life’ (p.62).
The national policies themselves do not appear to have been subject to any proper
sustainability appraisal. Indeed the SA Report states: ‘We suspect that growth would be far
less environmentally damaging in many other parts of the UK, especially the North of
England, because there is generally much greater environmental and infrastructure
headroom.’
With regard to Stansted Airport, the SA Report expresses its agreement with the conclusion
of an earlier study, that ‘airport expansion will be highly damaging to the environment and
quality of life’ (p. 73), and recommends that the Plan should not just include mitigation, but
‘consider in fact restricting airport growth where it is deemed that costs outweigh any
benefits of increased air travel’ (p. 183). We refer also to p. 283: ‘The environmental
caveats and conditions, and limitation to existing capacity at Luton and Stansted are
welcome. But the acceptance of growth at all, and the reference to an “acceptable balance”
between economic benefits and environmental and other considerations, still fails to grasp
the point that further growth in air travel provision is environmentally unsustainable.’ In
short, the draft Plan fails to make adequate provision for the protection of the environment,
especially in its proposal that the existing runway at Stansted should be used to its full
capacity.
These findings are not surprising. In our SERAS Response (Stansted – the case against
irresponsible growth) we argued that the Consultation Document which preceded the
White Paper was ‘flawed by the Government’s failure to observe its own principles of
sustainable development’, and we quoted the conclusion of the Government’s own
Sustainable Development Commission that the DfT’s proposals fell ‘seriously short of
sustainability’ in every basic respect (paragraph 1.1)
Even in terms of striking a balance we would argue, for the reasons given under ST5, that
the damage to the environment and quality of life far outweigh the so-called economic
benefits. There is a danger that benefits on which all can agree – the beauty and tranquillity
of the countryside, for example – get overlooked because they are so difficult to quanitify.
Being priceless, they are treated as worthless.
The comments that we have quoted and made so far relate mainly to the protection of the
environment, but we argue under ST5 that the development of Stansted Airport would run
counter to all four objectives of the Government’s sustainable development policy. EERA
has failed to think through the implications of this development, and it has failed to
demonstrate that the full use of the existing runway at Stansted could be achieved on a
sustainable basis. Throughout the Plan it should set out what it regards as sustainable and
consider the imposition of clearly defined and acceptable limits.
How would you like to see the East of England Plan changed (if applicable)?
The draft Plan should be withdrawn, and should then be amended to bring it into line with
the principles of sustainable development.
Chapter 4. Policy SS6: transport strategy
Observation
Summary
The expansion of Stansted Airport, as envisaged in the draft Plan, would be inconsistent
with the policy of ‘reducing the need, and hence demand, for travel’. If, however, the
airport is expanded, surface access must be improved.
More detailed comments
The expansion of Stansted Airport to the full use of its existing runway, and still more if the
second runway was to be developed, would be inconsistent with the policy of ‘reducing the
need, and hence demand, for travel’.
If EERA is persuaded by our submission and decides against any further expansion of
Stansted Airport, it follows that any improvements in road and rail provision that flow from
that expansion should fall away. If, however, EERA is not persuaded, and adheres to its
decision in favour of expansion, it is essential that the road and rail improvements in the
Plan should be sufficient to meet the needs of this expansion within the timescales laid
down. Allowing the airport to expand while failing to provide the adequate infrastructure in
terms of surface access would merely add to the congestion and inconvenience which the
local population is already experiencing. We note that in EERA’s judgement the
Government is failing to provide sufficient funding for the improvements set out in the
draft Plan. Unless that funding is provided there should be no question of implementing the
Plan and in particular of expanding the airport.
We enlarge on this argument in our comments on policy ST5.
How would you like to see the East of England Plan changed (if applicable)?
See under Policy ST5.
Chapter 4. Policy SS9: development in rural areas
Observation
Summary
The importance of tourism to the rural economy in the Region is rightly recognised but
there is no recognition that dramatically increasing the availability of cheap flights to
Europe will run counter to the objective of assisting the regional tourism industry.
More detailed comments
According to figures published by EEDA and the Regional Tourist Board, tourism is worth
over £5.1 bn to the East of England regional economy, provides 145,000 jobs and accounts
for about 6% of regional GDP.
As air travel expands, particularly low-cost air travel, there is a far greater stimulus to
outbound tourism than to inbound tourism. Inbound tourism has been almost static since
the mid 1990s, whereas outbound tourism has grown almost 50% over the same period.
Although the historic trend cannot automatically be extrapolated into the future, the pattern
has been consistent over a long period and there seems no reason why this should change.
A Plan which encourages very substantial expansion of air travel will therefore have the
effect of encouraging the transfer of tourism business, and therefore tourism jobs and
investment, from the Region to overseas tourist destinations. The draft Plan fails to address
the economic implications of this for the Region, particularly for rural areas which are
heavily dependent upon domestic tourism business.
The following table highlights some important characteristics of Stansted Airport which do
not appear to have been recognised in the Plan.
Stansted passenger data: East of England Region, 2003
EoE residents Foreign residents Total
visiting overseas visiting EoE
'000 '000 '000
Total trips 3554 1019 4573
of which:
Business 864 (24%) 235 (23%) 1099 (24%)
Leisure 2690 (76%) 784 (77%) 3474 (76%)
Source: CAA Passenger Survey, 2003 - Table 12 (excludes domestic trips)
Key points which can be derived from the above table, with respect to the East of England
Region, are:
the number of outbound tourists is 3.4 times greater than the number of inbound tourists
business travel accounts for only 24% of international journeys (in fact, this falls to 17%
when domestic journeys are also included)
The 2003 overseas tourism deficit for the East of England Region can be estimated at about
£905m by applying inbound (£469.9) and outbound (£473.2) average tourism spend data
provided by the Office of National Statistics.
The Plan fails to address the potential negative economic impacts on the Region of
encouraging the expansion of Stansted Airport to 45mppa. The economic benefit of
creating jobs at Stansted (in an area where it is already proving impossible to recruit
locally) would be substantially outweighed by the economic and employment losses in
rural parts of the Region which are heavily dependent upon tourism.
Finally, on the question of job creation, the Plan focuses purely on quantity and not on the
quality of jobs to be created. The vast majority of jobs created by airport expansion will be
low skilled, low paid jobs in areas such as retailing, catering, cleaning, maintenance,
baggage handling, warehousing, security, passenger check-in etc. Many of these jobs
require employees to work unsocial hours.
The Government aspiration for 50% of the next generation to go on to Higher Education
should be reflected in the Plan and it should seek to match demand and supply not simply
in overall job numbers but also in relation to the type of jobs. If this were done, it would be
readily apparent that, in the period to 2021, the priority was not increasing the number of
low-skilled jobs, but expanding job opportunities to suit a highly skilled workforce. This is
particularly so in Stansted, where employees to fill such jobs already need to be recruited
from North and East London, and indeed from overseas, because the local labour market
cannot provide the unskilled employees that the airport requires.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 4. Policy SS10: the regional economy
Observation
Summary
For the reasons set out under Policies SS9, ST5 and E14, the development of Stansted
would not be conducive to the development of the regional economy.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 4. Policy SS12: health, education and social inclusion
Observation
Summary
The expansion of Stansted Airport would have serious consequences for primary and
secondary health care, and would have adverse impacts in terms of climate change, noise,
air quality and various social factors.
More detailed comments
See under ST5 (section 3.5).
How would you like to see the East of England Plan changed (if applicable)?
See under Policy ST5.
Chapter 4. Policy SS13: overall housing provision
Oppose
Summary
The review of the Plan should not cover the expansion of Stansted Airport beyond
maximum use of the capacity of the existing runway.
More detailed comments
EERA has decided against the development of a second runway at Stansted. Although this
policy, SS13, refers to ‘long term pressures’, there is no reason why a second runway at
Stansted should be any more acceptable in the long term than it is in the short term –
especially as the review is due to take place within eighteen months, rather than the usual
five years. In any event, the ‘limited review’ referred to in paragraph 2.24 of the draft Plan
would be inadequate.
More generally we query the need for 478,000 new dwellings in the region, and for ease of
reference we repeat our comment under SS1: ‘The national policies themselves do not
appear to have been subject to any proper sustainability appraisal. Indeed the SA Report
states: “We suspect that growth would be far less environmentally damaging in many other
parts of the UK, especially the North of England, because there is generally much greater
environmental and infrastructure headroom.”’ We also draw EERA’s attention to the
House of Commons Environmental Audit Committee’s report, Housing: Building a
Sustainable Future, Volume I (2004), p. 4: ‘There is a serious risk that … the proposed
beneficiaries of housing growth will be the property development companies, whilst the
principal loser will be the environment.’
How would you like to see the East of England Plan changed (if applicable)?
The reference to ‘expansion of Stansted Airport beyond maximum use of the capacity of
the existing runway’ should be removed.
Chapter 4. Policy SS14: development and flood risk
Observation
Summary
Any increase in air travel would add to global warming, which in turn would add
significantly to the danger of flooding both through the rise in sea levels and through
unpredictable weather events.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 4. Policy SS15: the coast
Observation
Summary
The development of Stansted Airport would probably have an adverse impact on tourism at
the coast. See under SS9.
More detailed comments
The Plan recognises that the Region ‘has 723km of predominantly low-lying coastline that
is important for both the unique biodiversity it supports and its major contribution to the
economy of the region’. It also recognises the dangers posed by climate change. However,
the Plan ignores the fact that aviation is the fastest growing source of global warming and
does not appear to recognise the obvious contradiction between its support for doubling the
scale of traffic at Stansted Airport and its desire to protect the coastal environment and
economy.
The Government has made clear that Local Government must play its part in tackling
climate change. It is therefore incumbent upon EERA to address this issue in the Plan.
The failure of the Plan to do so is another example of the Plan claiming to address the issue
of sustainability but failing to do so.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 4. Policy SS16: quality in the built environment
Observation
Summary
The draft Plan rightly makes no provision for the development of a second runway at
Stansted. No doubt there will be pressure to include it, but if EERA were to yield to this
pressure it would have a very damaging effect on the built environment.
More detailed comments
The impact of a second runway on the built environment around Stansted is set out in our
response to Policy ST5, section 3.2. Very briefly, it would lead to the destruction of 2
Scheduled Monuments and 29 Grade II listed buildings – one of the greatest single acts of
heritage destruction since WW2.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 5. Policy NSR2: Norwich sub-region: promoting the tourism
sector
Observation
Summary
For the reasons given under Policies SS9 and ST5, the development of Stansted Airport
would be likely to have an adverse impact on local tourism.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 5. Policy NSR5: Norwich sub-region: transport infrastructure
Oppose
Summary
One of the schemes listed under this policy relates to the service to Stansted Airport.
Insofar as this relates to expansion at Stansted we oppose it.
More detailed comments
One of the schemes listed under this policy relates to the ‘East-West Rail Link with
services to sub-region and service improvement to Stansted’. If this relates to the
requirements of Stansted with no more than 25 mppa we support it. If it relates to any
development beyond 25 mppa we oppose it.
How would you like to see the East of England Plan changed (if applicable)?
The removal of any reference to Stansted under this policy if the proposed scheme relates
to any development beyond 25 mppa.
Chapter 5. Policy NSB1: the Norfolk and Suffolk Broads
Observation
Summary
Global warming presents a particularly severe threat to the Norfolk and Suffolk Broads.
This makes it all the more important to restrain the growth in air travel.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 5. Policy ST1: Stansted/M11: spatial strategy
Oppose
Summary
We are opposed to ‘the expansion of London Stansted Airport up to the maximum capacity
of its existing single runway’.
More detailed comments
The reasons for our opposition to the expansion of the existing runway to its maximum
capacity are set out under ST5. In the preceding text, paragraph 5.121, the draft Plan states
that ‘the Government announced in December 2003 that an additional runway will be built
[at Stansted Airport] by 2011/2012’. This is not the case. The White Paper, as the
Government itself has been careful to make clear, is merely a statement of policy, and the
Government will neither promote nor pay for the second runway. This will be the
responsibility of BAA and will be subject to normal planning procedures.
The development of Stansted Airport would also be inconsistent with another stated
objective of this policy, namely the protection of Hatfield Forest.
There appears to be some confusion about spatial strategies. We do not understand why
there should be a spatial strategy for the Stansted/M11 sub-region but not, for example, for
the Cambridge sub-region. And whereas the Cambridge sub-region includes Saffron
Walden, the Stansted/M11 sub-region includes the Uttlesford District, which includes
Saffron Walden.
How would you like to see the East of England Plan changed (if applicable)
See under ST5.
Chapter 5. ST2: Stansted/M11: employment generation and economic
regeneration
Observation
Summary
We support employment and economic regeneration, but only where appropriate, and they
should not be linked with or derive from the expansion of Stansted Airport.
Detailed comments
We are in favour of employment regeneration where it reduces or eliminates existing
unemployment and we are in favour of economic regeneration in specific depressed areas.
But the Plan should not link these developments or derive them from the expansion of
Stansted Airport.
The SA Report is relevant here, particularly p. 67: ‘Whilst the region may not have a choice
whether to accept the significant expansion of air travel at Luton and Stansted in particular
(due to national aviation policy), … it is able to choose whether to support economic
development that feeds off and encourages the growth in air travel, or whether to seek
alternative forms of economic development that meets the needs of the region without the
environmental damage.’ It therefore recommends that a review should be carried out of
‘the policies for airport related development for their sustainability implications –
alternative forms of economic development should be investigated that meet regional and
local needs, but do not add to the pressure to fuel demand for air travel.’ There are two
points to note about this. First, it is not the case that ‘significant expansion of air travel’ has
to be accepted as part of ‘national aviation policy’. The Government has explicitly
acknowledged that it is open to a planning authority to reject airport development if it
regards it as environmentally unsustainable. Second, however, insofar as more jobs are
needed in the region – which we question, since there is so little unemployment - we agree
that alternative, less damaging, forms of economic development should be explored as an
alternative to the expansion of air travel. It should also be noted that a high proportion of
the jobs provided by the airport would be semi-skilled/unskilled. These comments, while
relating to the region as a whole, are particularly relevant to the Stansted/M11 sub-region.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 5. Policy ST3: Stansted/M11: Harlow regeneration
Oppose
Summary
While we broadly support Harlow regeneration the Plan should not link this or aim to
derive it from the expansion of Stansted Airport.
More detailed comments
One component of this policy is the development of Harlow as a key regional centre for
‘airport-related enterprises’, and there are two references to Stansted in the supporting text.
Since we are opposed to the expansion of Stansted Airport we are opposed to this particular
aspect of the policy. Any new housing development in Harlow should be sensitive to
considerations of noise and air quality.
How would you like to see the East of England Plan changed (if applicable)?
Remove the reference to ‘airport-related enterprises’ from this policy.
Chapter 5. Policy ST5: Stansted/M11: Stansted Airport
Oppose
Summary
We oppose the expansion of Stansted Airport beyond 25 mppa for the reasons that are set
out in our more detailed comments.
More detailed comments
1 Background
In its Air Transport White Paper (ATWP) the Government announced its decision that the
existing runway at Stansted (R1) should be used to its full capacity, and that a second
runway (R2) should be developed by 2012. In its draft East of England Plan EERA has
accepted the first of these decisions, but not the second. We oppose EERA’s acceptance of
the full development of R1. We support its refusal to make provision for R2. In the
following submission we set out our reasons for both of these positions, since there will no
doubt be other parties arguing for the inclusion of R2.
There is a terrible danger that EERA will regard the development of R1 to its full capacity
as a small step compared with the development of R2, as the lesser of two evils that has to
be accepted as a realistic concession to the voracious demands of the aviation industry. In
fact the expansion of R1 to its full capacity would be a major development, resulting in
more than 40 mppa, about twice as much as today’s traffic. Worse still, if it takes this
position, EERA will have fallen in with the insidious incrementalism that has marked
Stansted’s growth over the past half century. When, in 1984, Inspector Graham Eyre was
considering the expansion of Stansted to 15 mppa, he was warned that this would be
merely a stepping stone on the way to a second runway. He replied that he would regard
the development of an airport at Stansted, with a capacity in excess of 25 mppa and
requiring the construction and operation of a second runway, as ‘nothing less than a
catastrophe in environmental terms’, and that if he believed that giving planning permission
for 15 mppa would lead to such a development he would unequivocally reject the
application. Lulled into the belief that a second runway would never be allowed, however,
Eyre gave his approval to the more limited expansion that was then under consideration,
with the result that the area around Stansted is once again under the threat of a second
runway. It is not often that history’s lessons are so obvious, and EERA would be naïve not
to learn them.
It is often argued that, in view of the increasing demand for air travel, resistance to the full
development of R1 is ‘unrealistic’. In our submission the dangers of increased air travel are
so alarming, both to the global and the local environment, that any further expansion would
be profoundly unrealistic.
In view of this we submit that EERA’s opposition to the inclusion of R2 should be stated
more explicitly and more strongly, and that it should not be subject to review.
If, however, EERA adheres to the policy of expanding Stansted airport to its full capacity it
should make clear, under ST5, that this would be dependent on a number of demanding
conditions being met. We comment on these under Policy E14.
2 The environment: the global and national impact
The effective protection of the environment is one of the Government’s four key objectives
in its Strategy for Sustainable Development.
The dangers and costs of man-made global warming have been spelt out repeatedly and
there is no need for us to rehearse them in detail here. On ‘Green Monday’, 24 February
2003, the Prime Minister described the protection of the environment as a security issue, as
important as the fight against terrorism. In September 2004, referring specifically to global
warming, he declared that the heatwave in Europe in 2003 had cost 26,000 lives and $13bn.
In December 2004, in a speech on including aviation in a European-wide emissions trading
scheme, he said that his aim was to ring alarm bells of ‘urgency’ because the impact of
climate change was ‘irreversible in its destructive power’. In the same month Sir David
King, the Government’s Chief Scientific Adviser, warned that even the most ambitious
targets might not be enough to avert the worst effects of global warming. By 2050 CO2
emissions might have to be cut by 80% to avoid catastrophic events such as the melting of
the Greenland icecap, with a 2C to 2.5C increase in temperature that would raise sea levels
by more than 20 ft and put London under water. We have already pointed out that in the
Eastern Region the coastal areas and the Broads would be particularly at risk.
Aviation is the most highly-polluting form of transport. In particular it is the fastest
growing source of greenhouse gas emissions. The Government aims to reduce UK carbon
emissions by 60% by 2050. Aviation carbon emissions, however, increased from 4 million
tonnes of carbon (MtC) in 1990 to about 9 MtC in 2002, and on the basis of the
Government’s traffic growth projections they will reach between 19 MtC and 22 MtC by
2030 and between 40 MtC and 45 MtC by 2050.
It would be perverse and absurd for the Government to allow aviation CO2 emissions to
increase eightfold between 1990 and 2050 when over the same period it is planning to
reduce CO2 emissions from all other sources by 60%. On present projections, according to
the Government’s Environmental Audit Committee, UK carbon emissions from aviation
will have overtaken UK carbon emissions from road transport and will account for about
40% of all UK carbon emissions by 2050. (The Prime Minister gives this figure as 33%.) In
September 2004 the Committee Chairman, Peter Ainsworth, condemned the ‘glaring
inconsistency in the DfT promoting so large a growth in carbon emissions from aviation at
a time when we need to make huge cuts to minimise the worst impacts of global warming.’
The same message was given by Lord Renton, the chairman of the House of Lords
European Union Sub-Committee on Environmental Issues, in November 2004: ‘It is
extraordinary that on the one hand government is concerned with climate change and on
the other it’s encouraging a rapid increase in air travel.’
At Stansted there is an aggravating factor. Most of the flights to and from the airport are
short-haul flights, which are more damaging for each kilometre travelled than long haul
flights because of the fuel that is burnt on take-off and landing.
It should also be borne in mind that the impact of aviation’s CO2 emissions on the climate
is tripled by its emissions of nitrogen oxides, water vapour, condensation trails and cirrus
clouds.
International (as distinct from domestic) flights are not covered by our obligations under
the Kyoto Protocol to cut back on greenhouse emissions, but their continued expansion
would be inconsistent with the overall objectives of that Protocol. In June 2002 Margaret
Beckett told a National Consumers Council conference:
People will gradually focus on the impact of aviation freight and air travel on the
environment. Air transport will stick out like a sore thumb as other pollution is
tackled.
The Government has already admitted that it will miss its target of reducing CO2 emissions
to 20% below 1990 levels by 2010, and this is blamed largely on the boom in air travel and
in the rapid increase in the number of vehicles on the roads.
There is no way in which the effects of unconstrained growth in air transport can be
effectively mitigated by new technologies.
Sustainability is not just a question of protecting the environment. One of the other key
objectives of the Government’s policy is the prudent use of natural resources. According to
the Government’s 2003 Energy white Paper, Our Energy Future: Creating a Low Carbon
Economy, ‘Globally, conventional oil reserves are sufficient to meet projected demand for
around 30 years’ and ‘there is the potential for oil reserves to last twice as long.’ In view of
recent developments in the global economy, particularly the growth of China and India,
these forecasts begin to appear optimistic. With apparently no realistic alternative energy
source for aviation on the horizon the aviation industry can be expected to survive only one
or two more generations unless its growth rate is tempered, halted or reversed.
Two passages from the SA report commissioned by EERA are particularly relevant. First,
p. 65: it notes that the Plan accepts airport related development at Stansted and declares:
‘This could help to fuel demand for air travel, one of the most environmentally damaging
modes of transport (globally and locally), rather than dampening down demand. Second, p.
283: ‘The environmental caveats and conditions, and limitation to existing capacity at
Luton and Stansted are welcome. But the acceptance of growth at all, and the reference to
an “acceptable balance” between economic benefits and environmental and other
considerations, still fails to grasp the point that further growth in air travel provision is
environmentally unsustainable.’
The lessons are clear. Global warming is a major threat to the future of the planet. Aviation
is playing an increasingly large role in man-made global warming. It would therefore be
irresponsible to sanction any further growth in aviation.
3.1 The environment: the local impact: introduction
In our SERAS Response (Stansted – the case against irresponsible growth), Part 4, we
spelt out the potential impact on the area around Stansted of the various options put
forward in the SERAS Consultation Document. We began by describing what was at stake
– the quiet and distinctive beauty of the area, and the richness of its vernacular architecture.
We shall not repeat all that we said in our Response, merely the comment of John
Betjeman: ‘The very fact that this country is so gentle, unobvious and typical of the best of
England makes it all the more important that, being so hear to London, it is preserved from
noise and ‘development’.’ We would also add the judgement of the SA Appraisal (p. 21),
that a ‘combination of high quality historic settlements in rolling countryside makes this
one of the most environmentally attractive parts of the region. Uttlesford District has more
listed buildings than any other …. The comparative lack of change in the middle part of the
LSC [London-Stansted-Cambridge] corridor, as well as the good state of conservation of
the historic environment, makes the area particularly special.’
We have already quoted Inspector Graham Eyre, who wrote in 1984 that he would regard
the development of an airport at Stansted, with a capacity in excess of 25 mppa and
requiring the construction and operation of a second runway, as ‘nothing less than a
catastrophe in environmental terms’. When, in December 2003, the Secretary of State for
Transport presented the Air Transport White Paper to Parliament he was asked to state the
basis on which he was riding roughshod over Eyre’s judgement. He replied that Eyre’s
statement was no longer relevant, since there had been such an increase in the demand for
air travel since 1984. The only interpretation that can be placed on these words is that a
second runway would still be an environmental catastrophe but the Government regarded
this as less important than the need to satisfy demand.
3.2 Land, heritage and ecology
The main impact on land, heritage and ecology would come if R2 were added to the
airport. This would result in the loss of 111 properties, 700 hectares of agricultural land, 2
km of the Harcamlow Way National Path; 450 hectares of the so-called Countryside
Protection Zone, 4 km of ancient species-rich hedgerow, 29 Grade II listed buildings, 2
ancient monuments, 700 hectares of high archaeological potential., and more than half of
East End Wood SSSI and Philipland Wood. There would also be the losses arising from the
development of road and rail infrastructure. As indicated already under SS16 above, all this
would constitute an act of heritage destruction on a scale seldom seen since the Second
World War.
For further details see Stansted – the Case against Irresponsible Growth, SSE’s Reponse to
the Second Edition of the DfT’s Consultation Document (June 2003), pp. 22-28 (referred to
hereafter as Response to the SERAS Consultation Document).
EERA’s prescriptive approach to the location of Stansted airport related development risks
usurping the role of the local planning authority. Uttlesford District Council may consider
it more appropriate in some circumstances for certain airport related developments to be
located outside the airport boundary (e.g. offices, car parking/car hire, hotels etc) and
should have the flexibility to decide these matters on their merits through the normal
planning processes.
3.3 Noise pollution
Our detailed arguments on noise pollution were set out on pp. 32-45 of our Response to the
SERAS Consultation Document. We were critical of the inappropriateness and
incompleteness of the 16 hour Leq metric, which the DfT had used in its calculations. We
argued that, if the 16 hour Leq metric was to be used, the choice of 57dBA Leq as the level
marking ‘the approximate onset of significant community annoyance due to sudden aircraft
noise’ was inappropriate, and we pointed out that the levels identified by the World Health
Organisation were much lower. The WHO recommended that to prevent serious annoyance
to most people in the daytime the outdoor sound pressure level should not exceed 55 dBA
Leq, and that to protect most people from moderate annoyance during the daytime it should
not exceed 50 dBA Leq. (The equivalent level for ‘moderate’ annoyance, according to the
DfT, is 63 dBA Leq, a sound intensity level 25 times greater.) The WHO noted that most
countries in Europe had adopted 40 dB LAeq as the maximum allowable level for new
developments, and concluded that this lower value ‘should be considered the maximum
allowable sound pressure level for all new developments whenever feasible.’ We also
pointed out that aircraft noise was particularly disturbing in a rural area, like that of
Stansted, with low ambient noise, and we drew attention to other methodological
weaknesses, such as the use of averaging and the failure to take modal splits fully into
account.
Since the DfT set its benchmark of significant community annoyance so high it grossly
underestimated the area and the number of people who would be disturbed by the
expansion of Stansted Airport. There are many methodological problems, but on p. 42 of
our response to the DfT’s Consultation Document we set out two bar charts showing the
predicted area and the predicted population suffering noise annoyance at 57 dBA Leq and
50 dBA Leq. With the level set at 57 dBA Leq the area affected by the full use of R1 by
2030 was 50 square kilometres and the area affected by the development of R2 by 2030
was 127 square kilometres. The comparable figures with a level at 50 dBA Leq were 149
and 340 square kilometres respectively. Similarly, with the level set at 57 dBA Leq, the
population affected by the full use of R1 by 2030 was 6,000 and the population affected by
the development of R2 by 2030 was 14,000. The comparable figures with a level at 50 dBA
Leq were 18,000 and 44,000.
We drew attention to the particularly disturbing effect of night time noise. Since our
response was written the Government has decided that Stansted should not become a
second hub airport in addition to Heathrow, but that its expansion should be used mainly by
the so-called No Frills Carriers (NFCs). For such operators the use of flights in the early
morning and late evening are particularly important, since they try to cram as many flights
into the day as possible. There are also proposals to use Stansted more extensively for
cargo flights. In October 2004 we submitted our response to Part One of the DfT’s
consultation on Night Flying Restrictions at Heathrow, Gatwick and Stansted. In this we
welcomed the Government’s acceptance of WHO guidelines for night noise, but deplored
its intention to delay adherence to these until 2030. We stressed the importance of bringing
the so-called shoulder periods, 0600-0700 hours and 2300-2330 hours, within the night
flight restrictions, and we urged the Government to move as quickly as possible towards a
total ban on night flights.
3.4 Air quality
Our detailed arguments on air quality are set out on pp. 45-57 of our Response to the
SERAS Consultation Document.
When permission was given for airport capacity to increase to 25 mppa air quality
predictions showed that there would be breaches of the EU and UK nitrogen dioxide levels
at two places outside the airport boundary. Subsequent very limited real time measurements
suggested that these predictions might be unduly high and permission was granted for the
expansion with a S.106 agreement that BAA set up a limited air quality monitoring scheme
for the airport and boundaries. To date relatively little real time monitoring has been carried
out. The review of air quality in 2003/4 did not lead to the establishment of an Air Quality
Management Area (AQMA) at Stansted at the present time but recognised that the
situation would be reviewed after the S.106 agreement had been fully implemented and
reviewed.
The Air Transport White Paper predicted that with one extra runway there would be
breaches of the air quality levels for nitrogen dioxide but these would only affect a few
houses and that mitigation was possible. The Minister accepted that development could not
proceed (as at Heathrow) if it was shown that such breaches could not be prevented. At the
time further measurements and sensitivity tests were carried out at Heathrow and Gatwick,
and it was accepted that further development at Heathrow would not be possible without
breaching the AQ Directive. No similar comprehensive survey was carried out at Stansted.
Hatfield Forest is situated just of the airport. Nitrogen deposition had already occurred even
before the present level of 21 mppa was reached. Levels of deposition over those
recommended of 17 kgms per hectare have also been reported by the National Expert
Group on Transboundary Air Pollution (Negtap) on land around the airport. Investigations
are continuing at the present time in the ancient Hatfield Forest, which should be protected
from inappropriate development by policy ST1.
To date, no comprehensive real time air quality survey has been carried out in and around
the whole airport. The main A120 road has been moved and now passes through the airport
and along a different route. The situation will have changed significantly since the
predictions for the 25 mppa application.
It is therefore very probable that any further development of R1 and the building of R2
would give rises to breaches of the AQ regulations and the EU Directive. This should
strengthen EERA’s resolve not to support R2. On no account should support be given for
the full development of R1 until such time as the issues of future air quality and nitrogen
deposition on Hatfield Forest have been investigated and cleared.
3.5 Health
Our detailed comments on health are given on pp. 57-67 of our Response to the SERAS
Consultation Document. See also our comments on SS12.
1 Primary and Secondary Care. EERA rightly draws attention to the need to work with the
health, education and social sectors and to the implications for Primary Care and the ability
of Community Hospitals to meet the considerable extra demands that would arise from the
implementation of the Plan. We would emphasise in particular to the needs of those who
would move into the area because of the development of Stansted Airport. Reassurance
needs to be given that Primary Care and Community Hospitals would be adequately
resourced. With the use of the existing runway being extended to its full capacity, the
inflow of those seeking employment at the airport or in associated developments would add
significantly to the demands on hospital services, including maternity and paediatric
services. In general, it is now not difficult to recruit General Practitioners, but recruiting
and retaining staff at District General Hospitals continues to present severe problems.
Currently, local ambulance services are stretched and have poor response times.
2 Climate Change. We have commented above on climate change, and on the part played
by aviation. Here it is sufficient to note that rapid climate change will have profoundly
damaging effects on the well-being of people throughout the world.
3 Noise. We comment on noise above. In the context of health we would repeat that the
noise contours employed by the Department for Transport (DfT) are inconsistent with those
recommended by the World Health Organisation and other authorities, and that for this and
other reasons the DfT grossly underestimates the nuisance and suffering that would be
caused by airport expansion. It is well established that primary school children exposed to
noise have reduced cognitive performance. The term ‘jet pause’ is well known to those
teaching in schools near major airports. Schools may be unable to recruit and retain staff
and children may have to travel further to school. Adults repeatedly disturbed by noise
suffer sleep loss, fatigue and accidents from concentration failure. [Sentence relating to
Schiphol omitted.] Stress responses such as increased histolic blood pressure and higher
levels of stress hormones have been reported in those exposed to chronic airport noise.
4 Air Quality. We comment on air quality above. National improvements in air quality are
not maintained near large airports, aircraft pollution being augmented by road and rail
traffic and industrial emissions. Over 150 epidemiological studies have reported
associations between particular concentrations and ill health. The model for assessing air
quality at airports in the Air Transport White Paper (Atmospheric Dispersion Model
System 3) was developed for industrial sources, not airports, and is therefore entirely
inappropriate.
5 Social Factors. Increasing urbanisation may cause social disruption and loss of social
capital, damaging the local population’s health as well as that of the incoming population.
There may well be an increase in psychosomatic disease and depression, like the ‘New
Town Blues’ which once afflicted Harlow.
To safeguard the health of the community an integrated approach is needed, with
significant contributions from the Government departments dealing with transport, health,
education and technology, supported by good independent research. We question whether
the rather bland statements about health in the draft Plan are consistent with the proposals
to develop Stansted Airport.
References:
1 Uttlesford NHS Primary Care Trust, ‘Rapid screening for health impact of expansion at
Stansted Airport’, internal working document draft 6, 2002.
2 The Royal Commission on Environmental Pollution, The environmental effects of civil
aircraft in flight, November 2002: http:/www.rcep.org.uk.
3 Banatvala, J. ‘Unhealthy airports’, Lancet 364, 21 August 2004.
3.6 Employment
In June 2003, on pp. 68-71 of our Response to the SERAS Consultation Document, we set
out our projections, based on the work of Berkeley Hanover Consulting (BHC), of the
numbers of employees who would be required under the various SERAS options. Unlike
SERAS, BHC took into account induced and attracted employment as well as direct and
indirect employment. Based on the information that was then available BHC calculated
that, taking 25 mppa as the baseline, about 5,000 extra jobs would be created by 2030 by
the expansion of R1 to its full capacity, and about 68,000 extra jobs by 2030 by the
development of R2. In view of the decision that Stansted should not be developed as a
second hub airport, but as an airport used largely by NFCs, these figures are questionable
and we have not yet commissioned any new calculations.
3.7 Housing
BHC’s housing projections were set out on p. 71 of our Response to the SERAS
Consultation Document. With the development of R1 to its full capacity BHC estimated
that 8,000 more houses above 1998 levels would be required by 2030, and with the
development of R2 64,000. Again, as with the figures for employment, these figures need
to be reviewed. We note that Buchanan estimated that the development of R1 to its full
capacity would not require any additional dwellings above the 478,000 provided for in the
draft East of England Plan, and that the development of R2 would require only 1,100 more.
In the time available, and with the resources available, we have not been able to
commission any further work on this subject. But the Government itself acknowledges that,
because of the resulting urbanisation, the nature of the area around Stansted would be
significantly changed, and this is also the finding of the SA Report commissioned by
EERA (p. 64).
3.8 Impacts on the road and rail networks
Expansion of Stansted Airport to the full use of R1, as proposed in the draft Plan, would
mean up to 45 mppa by 2021 – far more than the 35 mppa referred to in the Plan. This
would substantially increase both the need and the demand for travel within the Region.
Airport employees are increasingly being drawn from further afield and this trend will be
accentuated as the airport expands. Already the airport’s demand for unskilled employees
outstrips the available of such employees in the local labour market, and already airport
employees are focusing their recruitment efforts on North and East London. With
employees accounting for about one third of all journeys to and from the airport, this has
significant implications for the demand for surface travel.
The airport’s passengers are also being drawn increasingly from further afield. In 2003 only
22% were from the East of England Region compared with 24% in 2002. Essex residents
accounted for only 8.1% of in 2003 and Hertfordshire residents for just 3.1%. The 2003
figures for the other four countries in the Region were Cambridgeshire 4.4%; Norfolk 2%;
Suffolk 3.3%; and Bedfordshire 1.3%. (CAA Passenger Survey Report, 2003.)
With over 70% of passengers and over 90% of employees travelling to the airport by road,
expansion of the airport to full use of R1 would place increasing demands upon the local
road network. The Plan does not address the enormous pressures which would be placed
upon surface access infrastructure if the airport were to be allowed to expand to the full use
of R1.
On a passenger throughput of 45 mppa, Stansted would generate almost exactly the same
demand for surface access as Heathrow generates today at 63.2 mppa. This is because, as a
major international hub, 37% of Heathrow’s passengers (23.1m in 2003) are transfer
passengers and so do not require surface access transport. Stansted is not intended to
develop as an international hub. It is projected that only about 10% of Stansted’s
passengers would be transfer passengers in 2020, by which time the airport could be
handling 45 mppa on R1. On this basis, 40.5m Stansted passengers would require surface
access by 2020/21 - slightly more than the 40.1m. Heathrow passengers who required
surface access in 2003.
To put this into context, London Underground carried 5.6m passengers to/from Heathrow
in 2003 and the Heathrow Express carried 3.6m. When Terminal 5 is completed together
with associated rail and London Underground improvements, it is projected that a
combined total of about 15m passengers could be handled by the Heathrow Express and
London Underground. The draft plan makes no attempt to explain how the local road and
rail network would cope with an increase to 45 mppa (or even 35 mppa) by 2021.
In addition to these journeys to and from the airport there are many others that would arise
indirectly from the development of the airport, such as the journeys to and from the work of
non-airport employees, leisure trips and journeys to and from schools and shops.
If EERA continues to support expansion to the full use of R1 it must, at the very least,
explain the implications with regard to surface access infrastructure, make clear that its
support its conditional upon specified improvements to surface access infrastructure being
put in place in time to cater for this level of airport expansion, and demonstrate how all this
can be achieved consistently with its statutory obligation to work towards the achievement
of sustainable development.
Finally, on SS6, the Plan would benefit from some imaginative thinking on ways of
reducing the need and demand for travel, for example:
encouraging the migration of City jobs to the Region as a means of reducing
commuting into London. ‘Back office’ jobs in particular can effectively be
relocated out of London.
encouraging the trend towards ‘home-as-office’ working.
developing a number of state-of-the-art video conferencing centres in the Region,
which local companies could rent as an on-your-doorstep alternative to overseas
trips or lengthy domestic journeys.
While it is important that any development of the airport should be matched by suitable
developments in the road infrastructure, the main point we want to stress is that the
provision of more roads and the generation of extra traffic are in strong contradiction to the
Government’s sustainable development strategy. In particular we note that with the
development of R2 the Government was proposing a new dual carriageway linking the
M11 with the A120 trunk road. This would leave the M11 just south of Henham and pass
directly through Pledgdon Green, Broxted, Great Easton and Little Easton before joining
the A120 to the west of Great Dunmow. This major route would be driven through unspoilt
countryside to the north of the airport, ruining the quality of life in at least five villages.
Furthermore BAA is proposing that a railway link should be provided running from
Harlow Mill to the airport, cutting through the invaluable heritage of Hatfield Forest. Even
if a tunnel were built it would almost certainly be a cut and cover operation, thus destroying
a wide swathe of the forest.
For ease of reference we repeat our comments on policy SS6. If EERA is persuaded by our
submission and decides against any further expansion of Stansted Airport, it follows that
any improvements in road and rail provision that flow from that expansion should fall
away. If, however, EERA is not persuaded, and adheres to its decision in favour of
expansion, it is essential that the road and rail improvements in the Plan should be
sufficient to meet the needs of this expansion within the timescales laid down. Allowing the
airport to expand while failing to provide the adequate infrastructure in terms of surface
access would merely add to the congestion and inconvenience which the local population is
already experiencing. We note that in EERA’s judgement the Government is failing to
provide sufficient funding for the improvements set out in the draft Plan. Unless that
funding is provided there should be no question of implementing the Plan and in particular
of expanding the airport.
3.9 Water
On pp. 79-81 of our Response to the SERAS Consultation Document we explained our
concerns about flooding, water supply, sewage disposal and the impact on catchments
downstream. EERA is acutely conscious of the difficulties relating to water, especially
water supply, and in this document we merely wish to reiterate that the development of
Stansted and all the accompanying developments would add considerably to the demand
for water.
3.10 Waste
There is already great pressure on landfill sites in Essex. The expansion of Stansted
Airport, and all the associated developments, would add significantly to this pressure.
3.11 Energy
The expansion of the airport, whether to the full capacity of R1 or with the addition of R2,
would lead to a large increase in the use of energy. Even at the 25 mppa level the total
energy to be used at the airport will be equivalent to that used by 10,000 typical homes.
3.12 Air Traffic Control (ATC) and safety in the air
The difficulties for air traffic control were described on pages 81-82 of our Response to the
SERAS Consultation Document. We are concerned that, even with improvements in
technology, the development of air travel on the scale envisaged would further complicate
the tangled mass of flight paths in the South East with inevitable consequences for both
safety and efficiency. Since that Response was submitted the head of Eurocontrol has
stated that in ten years’ time the skies of Europe will be full.
4 Economic considerations
The damage to the environment, and to the quality of life of people living locally, would be
so great that any further expansion at Stansted should be ruled out. It is being justified,
however, by arguments relating to economic development. In our view these arguments are
misguided, and we deal with them under two headings – the national economy and the
regional economy.
4.1 The national economy
The economic benefits and ‘disbenefits’ of the aviation industry were considered in our
SERAS Response (Stansted – the case against irresponsible growth), pp. 7-9. In summary,
we argued that there was no clear link between air travel growth and economic growth; that
if air travel was not expanded the result would not be a reduction in new jobs, but a
different distribution of jobs; that UK business would not suffer if aviation growth was
constrained; that the tourist industry had an adverse impact on the UK balance of payments
(an argument which we have developed further under policy SS9); and that there were
further trade deficits in aviation services and civil aircraft.
4.2 The regional economy
Some of the more local benefits and ‘disbenefits’ of expansion at Stansted were outlined on
page 69 of our SERAS Response. We drew attention to a substantial increase in airport-
generated employment, a large number of companies moving into the area, labour and skill
shortages, housing shortages, and the effect on house prices. Under policy SS9 we have
spelt out the effect on the local tourist industry. See also our comments under E14.
5 The demand for air travel
The alleged need for more runway capacity is predicated on the increasing demand for air
travel. In its SERAS Consultation Document the Government forecast that between 2000
and 2030 unconstrained passenger demand would almost treble, rising nationally from 181
mppa to 501 mppa, and in the South East from 117 mppa to 301 mppa. In the light of this
the Secretary of State for Transport, Alistair Darling, said that doing nothing was not an
option and in the ATWP the Government decided that, as a matter of policy, R1 at Stansted
should be developed to its full capacity and R2 should be constructed.
In a witness statement which constituted part of the Government’s defence in the recent
judicial review, Mr. Ash, the Deputy Director and Chief Planner in the Town and Country
Planning Directorate in the ODPM, stated that these statements of policy could not pre-
empt a decision on an application for planning permission, but provided a policy
framework within which such decisions could be taken as expeditiously as possible. ‘The
government’s view is that where need is established by a national policy statement, a
planning inspector at a planning inquiry should not have to consider whether a need for the
development exists ….’ This does not mean ‘that an inspector, and ultimately the decision-
maker, will be precluded from considering the need for the proposed development, but this
will be done in the context of what is said about need in the national policy statement.’
There have, however, been several developments since the publication of the ATWP, and it
must be open for planning authorities to take these into account. On the one hand demand
has increased more rapidly than expected. In paragraph 5.139 of the draft Plan it is stated
that the figure of 25 mppa is likely to be achieved by 2010. In fact it will be achieved by
2006. On the other hand the increase in demand is now slowing down. According to the
Chief Executive of Ryanair, Mr. O’Leary, the market for No Frills Carriers (NFCs) is
reaching saturation point. This will have a particular impact on Stansted, where future
growth is predicated on the increased use of NFCs. The pressure from increased demand
may therefore be less than predicted in the ATWP.
6 The potential for demand management
Demand management lies outside EERA’s powers, but it would be unreasonable of the
Government to authorise, or indeed encourage, a development that would lead to severe
environmental damage without a proper consideration of the possibilities of demand
management. In our response to the SERAS Consultation Document (3.6.3) we made
several suggestions - the imposition of aviation fuel for domestic flights and for journeys
between member states of the EU where bilateral agreements have been reached, an
increase in Air Passenger Duty, and realistic market prices for landing slots. It has been
demonstrated, using the DfT’s own SPASM model, that a realistic tax on air fares would
result in such a substantial fall in demand that no new runways would be needed in the
South-East (Brendon Sewill, The Hidden Cost of Flying, Aviation Environment Federation,
2003).
In January a European-wide carbon emissions trading scheme was introduced for
manufacturing and other heavy industries. Aviation is currently exempt, but the
Government will be seeking to include intra-EU aviation in the scheme during its EU
presidency this year. If this is successful airlines will be given a baseline level of permitted
emissions, and will be required to buy carbon credits from other airlines or industries if
they need more. How much this will add to air fares will depend on the baseline levels that
are fixed and the prices that have to be paid for carbon credits. If, however, the
Government is serious in trying to reduce aviation’s carbon emissions these levels should
be extremely low and the prices accordingly high.
Furthermore at a meeting of the G7 finance ministers in London in early February several
countries, including German and France, indicated that they favoured a kerosene tax as a
way to raise revenue. The Chancellor of the Exchequer has said that he is prepared to
consider such a move.
We mention these potential changes, not because we believe that they can affect the draft
Plan directly, but because it seems reasonable for EERA to draw attention to them when
resisting the Government’s pressure for airport expansion.
How would you like to see the East of England Plan changed (if applicable)?
Replace the first sentence of ST5 with the following: ‘Expansion of Stansted Airport
beyond 25 mppa is not accepted.’ The rest of this policy then falls away.
Chapter 5: ST6: Stansted/M11 sub-region: transportation
Oppose
Summary
Insofar as any of these improvements relate to the increased use of R1 at Stansted Airport
we are opposed to them. Insofar as they relate to improving access to the Airport with a
limit of 25 mppa we support them.
More detailed comments
ST6 sets down a list of "priorities" for transportation improvements. Since we are opposed
to any expansion at Stansted Airport beyond 25 mppa it follows that we are opposed to any
improvements which are designed to cater for this expansion. However, the list as written
comes nowhere near to recognising the scale of increased pressure upon the regional road
and rail infrastructure if Stansted were to be allowed to double the present number of
passengers handled. In some instances, the "priority" identified in ST6 is a mere "study".
For the Plan to support the expansion of Stansted Airport to 45mppa without clearly
specifying – or even properly assessing – the surface access improvements which will be
required to support this is putting the cart before the horse.
How would you like to see the East of England Plan changed (if applicable)?
The omission of any improvements designed to cater for any expansion at Stansted Airport
beyond 25 mppa.
Chapter 5: ST7: Stansted/M11 sub-region: implementation of delivery
Observation
BAA should be required to make an appropriate contribution to the costs of delivery.
Chapter 6: E4: provision of strategic employment sites
Oppose
Summary
Our opposition to the expansion of Stansted Airport entails our opposition to the reference
to Stansted Airport in this policy.
How would you like to see the East of England Plan changed (if applicable)?
The reference to the expansion of Stansted Airport should be omitted.
Chapter 6: E13: tourism
Observation
Summary
For the reasons given under SS9 the development of Stansted Airport would have adverse
effects on local tourism.
More detailed comments
The first bullet point of E13 sits uncomfortably with the Plan's support for a doubling of the
scale of Stansted Airport. As explained under SS9 and ST5, such a scale of expansion
would be likely to damage the regional tourism industry and would damage the natural and
built environment both in the local vicinity of Stansted and more widely as a consequence
of the global implications for the environment of the expansion of air travel.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 6: E14: regional airports
Oppose
Summary
We oppose the expansion of Stansted Airport beyond 25 mppa.
More detailed comments
There is a presumption here that airport expansion will bring net economic and employment
benefits but no evidence is provided to support this statement. The ODPM 'Buchanan Study', in
August 2004, concluded that the economic impact of expanding Stansted Airport was "very much
open to debate". (A Study of the Relationship between Transport and Development in the London
Stansted, Cambridge and Peterborough Growth Area, ODPM, August 2004, para 11.2.5)
There is considerable evidence to suggest a negative economic impact upon regional
tourism and it is clear also that the type of jobs that would be created by airport expansion
are not what the Region requires. If net economic and employment benefits are to be
asserted, evidence needs to be provided to support this assertion.
Our case against the expansion of Stansted is set out under ST5. In the context of this
particular policy we would draw attention to the SA Report, p. 283:
The environmental caveats and conditions, and limitation to existing capacity at
Luton and Stansted are welcome. But the acceptance of growth at all, and the
reference to an ‘acceptable balance’ between economic benefits and environmental
and other considerations, still fails to grasp the point that further growth in air travel
provision is environmentally unsuitable. …. The requirement that airport
development should not lead to consequential pressures to exceed levels of planned
growth, infrastructure and service provision is laudable, but in practice will be very
difficult to manage.
We agree entirely with these comments
If however EERA is not persuaded by our arguments, and continues to support the
expansion of Stansted Airport to the maximum use of its existing runway, we would urge it
to be much more specific in the four conditions set out under E14 and to include them
under ST5. What exactly, for example, is meant by "effective and timely implementation
of other necessary infrastructure improvements" and what is the mechanism for the surface
access strategy being agreed [by whom?] and implemented? In their present form these
conditions are largely rhetorical. There is a need for clear conditions to be laid down, such
as no net increase in noise, in air pollution or in the number of private cars traveling to and
from the airport.
How would you like to see the East of England plan changed (if applicable)?
EERA should not support the expansion of the existing runways at Stansted and Luton
airports to their full capacity.
Chapter 8: T1: regional transport strategy objectives
Observation
Summary
The designation of Stansted Airport as a Regional Interchange Centre is questionable, since
it is not a population centre, and the linkage is mainly from air to road and air to rail. It
would be a mistake if population were concentrated in the area because it was an RIC. The
development of the airport is inconsistent with the stated aim of reducing the need to travel.
Chapter 8: T5: Airports
Oppose
Summary
This policy relates to access to airports. Insofar as it relates to the expansion of Stansted
Airport beyond 25 mppa we are opposed to it.
More detailed comments
This policy is based on the assumption that Stansted Airport will be expanded to the full
capacity of R1, which is estimated at 35 mppa. While 35 mppa may be the present capacity
of R1 BAA acknowledge that the future capacity will be in excess of 40 mppa. We are
opposed to any expansion of the airport beyond 25 mppa and if this accepted there will be
no need to provide access for more than 25 mppa. On the other hand, insofar as access has
to be provided, we fully support the provision of access by rail and bus/coach rather than
by car.
The supporting text suggests that the present access by rail to Stansted Airport is adequate.
This is not, however, the position.
How would you like to see the East of England Plan changed (if applicable)?
This policy should be amended to make it clear that EERA does not support the
development of R1 to its full capacity.
Chapter 8: T11: environment and safety
Observation
Summary
The extra strain which the development of Stansted Airport would place upon the transport
infrastructure would be bound to have adverse environmental and safety impacts. The
policy may seek to protect and enhance the natural, built and historic environment, etc., but
in practice it would probably be impossible to do so.
Chapter 8: T15: road user charging
Observation
Summary
A variant of road user charging must form part of any surface access strategy for Stansted
Airport.
More detailed comments
In order to encourage a switch from car use to other forms of transport for accessing the
airport. Consideration is currently being given to extending the London Congestion Charge
to include Heathrow Airport. A similar approach should be adopted for Stansted at the
earliest opportunity. The technology already exists to allow a Stansted Airport road
charging scheme to be introduced at any time. Early introduction of a scheme at Stansted
would provide a useful testing ground for the Region, allowing lessons to be learned before
the introduction of more complex road user charging schemes in other parts of the region.
Chapter 8: T16: parking
Observation
Summary
Significant constraints should be placed on airport car parking.
More detailed comments
As part of an overall strategy to reduce car journeys to Stansted Airport and thereby to
avoid the mistakes of Heathrow, where road traffic pollution is now considered to be a
greater problem than pollution caused by aircraft emissions, significant constraints on
airport car parking need to be applied. The Plan should provide strong support for such
traffic management measures.
Chapter 8: Table 8.3
Observation
Summary
No proper assessment has been carried out on the surface access transport implications of
allowing Stansted Airport to expand to the full use of the existing runway.
More detailed comments
The paucity and timing of the rail improvements identified shows that no proper
assessment has been carried out on the surface access transport implications of allowing
Stansted to expand to maximum use on the existing runway, for example:
Unspecified improvements to "E/W Rail – Bedford/Cambridge/Stansted/
Norwich/Ipswich, Phase 1" is scheduled for 2011/15 and Phase 2 for 2016/20.
Unspecified "further enhancements" to the West Anglia Route are scheduled for
2011/15.
The "Rail route from mid-West Essex, with link to Stansted" is scheduled for 2021+
The planned rail improvements are scheduled for implementation far too late in the day,
bearing in mind that BAA is expected to submit a planning application in
October/November 2005 and expects Stansted Airport to reach 35 mppa by about 2012.
If expansion to 35 mppa is permitted without the requisite rail improvements being in
place, how can this be reconciled with EERA's statutory obligation for sustainable
development or with the "effective and timely implementation of necessary infrastructure
improvements" condition set out in the Plan or with the Plan's commitment "to achieve
modal shift away from road-based transport towards public transport"?
Chapter 8: T17: investment priorities
Observation
Summary
Insofar as the proposals listed in table 8.3 relate to the expansion of Stansted Airport, and
if, in spite of our representations, EERA continues to accept expansion, BAA should be
called upon to make a fully appropriate contribution to their funding.
Chapter 9: environmental resources
Summary
The expansion of Stansted Airport, and in particular the development of R2, would be
wholly inconsistent with several of the principles set out in Box 9.1, and with several of
the policies put forward in this chapter, for example ENV2 (landscape character), ENV4
(woodlands), ENV5 (the historic environment), ENV7 (air quality), ENV8 (renewable
energy and energy efficiency), ENV9 (water supply, management and drainage), ENV10
(waste management), and ENV11 (management of waste arising within the East of
England). We are not commenting on each of these policies individually, with the
exception of ENV7, but point out that their aims and objectives strengthen the case for
changing policy ST5.
Chapter 9: ENV7: air quality
Observation
Summary
There is a strong probability that the expansion of Stansted Airport, as provided for under
ST5, would not satisfy the requirements of this policy.
More detailed comments
This policy gives expression to the statutory obligation on all Authorities to ensure that new
developments do not breach the current legislation on Air Quality – the Air Quality
(England) Regulations 2000 and EU Daughter Directive 1999/30.EC. It also requires local
development documents to ‘pay particular attention’ to pollution arising from new
development that might damage wildlife or Sites of Special Scientific Interest.
We support this policy, but there is a strong probability that the expansion of R1 at Stansted
Airport to its full capacity would be in breach of the legislation cited. Further investigations
should therefore be carried out. The development of R2 at Stansted Airport would make it
impossible for this policy to be fulfilled. Our detailed arguments are set out under ST5.
How would you like to see the East of England Plan changed (if applicable)?
See under ST5.
Chapter 11: implementation and delivery
One general comment on this chapter. Insofar as infrastructure is related to the
development of Stansted Airport, and insofar, in spite of our representations, EERA
continues to support such development, BAA should be required to make a fully
appropriate contribution to the costs of implementation and delivery. These costs should be
quantified.
