BAA Consultation on R2 Options – Information Shortcomings
We regard the information provided in the BAA consultation document published in December 2005 as wholly inadequate for the purposes of members of the public making any meaningful assessment of the options presented, even on a comparative basis. The standard of information that has been provided by BAA falls far short of that provided by the Department for Transport (DfT) in its 2002/03 consultation on ‘The Future of Air Transport’ (the ‘SERAS’ consultation).
The opposite should have been the case because the SERAS consultation was for the purposes of determining a broad strategy -“looking at the UK as a whole and consulting in the broadest possible terms about how much airport capacity should be provided” (as acknowledged on p15 of the BAA consultation document) whereas this consultation is about specific Stansted runway options, each of which would have varying impacts – environmental and otherwise – upon the local community. BAA has failed – by a considerable margin – in its duty to provide sufficient information to enable consultees to make rational and informed judgements. The following list of information shortcomings is for example only and should not be taken to be exhaustive.
1) The Consultation provides no information on the impact of each of the options upon local air quality (for example projected levels of NO2, NOX, SO2, PM10, PM25, benzene and 1,3-butadiene) and the resultant implications for health. This is said to be the key issue with regard to any future development at Heathrow, yet the issue is simply ignored in this consultation. Projections for key LAQ indicators are needed for 2020 and 2030.
2) No information has been provided on the noise impacts upon communities for levels of noise below 57dBA leq and noise contours are only provided for 2030. Noise contours should have been provided for 54 dBA leq and for 50 dBA leq in line with the WHO recommendations, and all noise contours should have been mapped for 2020 as well as 2030. (SERAS provided 2015 projections as well as 2030; in this case, the interim projections should be in respect of 2020 in view of the timing of BAA’s plans).
3) The Consultation has only provided the '1 in 10,000' public safety risk contour for each of the options. SERAS provided the '1 in 100,000' and the '1 in 1,000,000' public safety risk contours. This is an important area of public concern and BAA should provide the same standard of information in this area as SERAS, again for 2020 and 2030.
4) BAA has provided no information on the planned investments in road and rail infrastructure which would accompany each of the options, nor on the timescale for delivery of the new road and rail infrastructure, nor any supporting data on road/rail traffic projections, mode share, capacity, etc. Since the options vary in scale from an additional 28 mppa capacity to an additional 41 mppa capacity (from a baseline of full use of R1) the requisite road/rail investments would vary from option to option.
5) No information has been provided on flight paths and whilst it is recognised that this is a CAA/NATS responsibility, BAA must have made some assumptions for the purposes of arriving at the noise contours that have been published. Similarly, no information has been provided on the possible location of any new or existing stacks. These issues are not even discussed in the consultation.
6) Further information should have been provided on the ATM projections for the various options, showing broad types of aircraft, separately for PATMs and freight and for 2020 and 2030. There should also have been an explanation of the impact of the projected traffic characteristics upon the noise projections, the traffic assumptions used by BAA in arriving at its noise projections and some sensitivity analysis thereof.
7) To ensure transparency, DfT published the SERAS appraisal framework which was used for ranking the appraisal criteria. Similarly, BAA should explain and make transparent the process it has used for assessing each of the options against its 5 criteria (economics, environmental performance, flexibility, operational performance and passenger experience), what weighting was applied to each of these criteria and the final basis for ranking/scoring the various options to arrive at its preferred option. BAA should also make clear whether, and if so how, it would revisit this process in the light of responses to the consultation.
8) The Consultation refers to a "thorough and complex" environmental analysis "involving 15 topics with independent specialist consultants advising on each". In the interests of transparency and allowing people to make their own judgements based on the best available information, BAA should publish this analysis in the same way that the DfT published the 65 background studies/reports which underpinned its main consultation document. (Apart from only very scant information being provided on the impacts upon wildlife, ecology, heritage, landscape etc, the impacts on archeological heritage do not even appear to have been assessed at this stage and yet even the SERAS consultation managed to include an assessment of the archeological impacts at Stansted.)
9) The Consultation should provide projections for the number of night flights and the associated noise impacts for each option. (In the absence of any statement to the contrary by BAA, it is reasonable to postulate that the number of night flights might be greater with the smaller capacity options, due to increased pressure upon daytime slots.)
10) In arriving at its projections for the amount of car parking for each of the options (up to 106,000 spaces), BAA must have made modal split assumptions for road, rail and bus/coach, for employees and for passengers. BAA should publish this information so that there is a clearer understanding of the surface access implications of each of the options.
11) BAA should provide projections for 2020 and 2030 for the additional employment generated by each of the option, shown as direct on-site, direct off-site and indirect,
and by type of employment. (SERAS provided staged employment projections.)
12) SERAS also provided projections for the additional housing that would be needed to support increases in the number of airport employees. BAA should also provide this information (which would vary between the options in view of the differences in scale) and explain how it would envisage that the additional housing needs would be met.
13) The Consultation should provide information on the impact of each option upon the
airport's water usage for 2020 and 2030. SERAS provided impact assessments for Stansted water usage and concluded that this would be a very difficult issue to resolve. It is incumbent upon BAA to provide water usage projections for each of the options and to explain how the increased water requirements would be met.
14) BAA should provide information on the impacts of each option upon carbon dioxide emissions arising from airport operations (including flights and surface access) for 2020 and 2030. Despite this being a key issue – many would say the key issue - for global, national and regional policy, BAA seeks to dismiss airport-related carbon emissions in a few lines, referring to the prospect of an EU emissions trading scheme which, at best, can only be part of the much wider action needed to achieve a 60% reduction in the UK’s carbon emissions by 2050. In addition, carbon emissions from road traffic generated by additional airport users is also a consideration and it is Government policy to achieve a radical shift towards public transport. BAA has not provided any road traffic projections for any of the options but has pointed to a need for 106,000 car parking spaces for its mixed mode options – a figure which suggests that BAA is not planning any significant modal shift towards public transport for any of the options. Far more information is needed in this area – including projected total carbon emissions for each of the options presented, so that the public can have a better understanding of the environmental implications and can make informed judgements.
Stop Stansted Expansion
31 January 2006