26, Warwick Road,

Bishop’s Stortford,

Herts

CM23 5NW

Tel: 01279 656482

26 June 2006 The Planning Department

Uttlesford District Council

London Road

Saffron Walden

Essex

CB11 4ER

Your Ref: UTT 0717 06 FUL

STANSTED AIRPORT

GENERATION 1 PLANNING APPLICATION

  1. I have been asked to write on behalf of the Bishop’s Stortford Civic Federation about this planning application. The Federation brings together the Civic Society and the Residents’ and Community Associations in the town into a body which represents over 6000 households.
  1. The Airport have applied to have the planning condition limiting passenger throughput to 25 mppa set aside and the condition relating to aircraft movements increased from 241000 ATMs to 264000 ATMs. We object to the variation of both conditions which has been applied for and thereforebelieve that the Council should turn down this application. Our reasons are set out in the following paragraphs.
  1. TheApplication Fails to Disclose its Full ImplicationsOur experience has been that in the past BAA has applied for planning permissions which would provide for facilitiesgrossly in excess of the traffic seeking to use the Airport. It is then able to portraythe effects of subsequent expansion as minor incremental developments rather than expansion on a scale which would lead to a major intensification of use. This is illustrated most easily by the terms of the planning permission granted by the Council to increase use of the Airport from 15 mppa to 25 mppa. The additional facilities granted in that permission were claimed at the time by BAA to be essential to allow the airport to expand to 25 mppa. The current application now suggests that they would be sufficient to support demand of up to 45 mppa– an airport three times as large as the one that existed at the time of their previous planning application. Had the Council known at that time that it was potentially sanctioning a threefold increase in size, it might well have treated that application differently.
  1. Although BAA now suggest that the variations in conditions applied for might lead to a passenger throughput of 35 mppa by 2014/15, inpractice agreeing to the increase in the ATM limit and removing the limit on passenger throughput could lead to a much higher level of passenger usage than 35 mppa with no mechanism left to the Council to constrain that growth. The Council should recognise that if it agrees to this application it will enable the airport to double in passenger numbers compared with thecurrent level of use. Doubling the amount of traffic at the Airport is not a minor variation but a major increase in use to which the Council should not agree unless it believes that the consequences are acceptable both to its own residents, and to those in neighbouring areas – particularly Bishop’s Stortfordwhich is the largest settlement to have been adversely affected by Airport expansion.
  1. Agreeing to this application would also pave the way for BAA’s plan to build a second runway. They would clearly find it more difficult to justify if the existing runway were not fully used and should not hide behind the smokescreen that a second runway is an entirely separate matter because it would be the subject of a separate application. The Council should recognise that since a second runway is part of BAA’s longterm plan for Stansted’s expansion, agreeing to this application is an essential stepping stone on the way to a second runway. Thus, a possible consequence of agreeing to the application now being considered is that it makes possible the expansion of Stansted into a two runwayairport whereas refusal could prevent it.
  1. The Application is Unnecessary at PresentBAA have accepted that no further facilities for which planning permission has not been granted are required to handle more than 25 mppa. On the evidence they have provided, they have not demonstrated the need for either variation.
  1. On the question of passenger throughput, the Civic Society has obtained confirmation from the Government that the current limit of 25mppa is an enforceable planning condition. Uttlesford presumably agreed to this limit not in the abstract but in the context of all the all the conditions attached to the expansion and the infrastructure in the surrounding area capable of supporting that level of passenger throughput. BAA have applied to have this condition set aside so that there would be no limit on passenger throughput. They have suggested no measures of mitigation to relieve the potentially adverse consequences of a potential doubling of the present number of passengers. And they have suggested no higher limit which could be justified as being compatible with all the other planning conditions and wider local circumstances. The Airport has not reached its current permissible limit. To remove this limit and have no equivalent constraint would simply leave Uttlesford with less negotiating capital in the event of any future planning application in respect of the Airport. Since BAA have not applied to have the limit replaced by a higher one, the Council is under no obligation to work out for them what, if any, higher limit might be acceptable. They should simply regard the present planning permission as a package such that altering one central condition undermines the whole permission. Since no case has been made for this part of the application, other than that the condition will soon begin to have some effect, it should be rejected.
  1. In the case ofthe limit on aircraft movements, their purpose is twofold. Firstly it is to cap the amount of disturbance which each such event causes. Secondly it is to modify the behaviour of airlines compared with the way in which they would behave if no such limit were in place. As the limit is approached, it forces airlines to carry their passengers in a smaller number of larger aircraft with higher load factors than they might choose to do if there were no limit in place. This has environmentalbenefits from the points of view both of reducing the number of noise disturbance events and the amount of air pollution generated per passenger carried. If the limit is relaxed every time it is approached so that airline behaviour in practice remains unregulated, then the potential benefit of a condition of this kind is surrendered. In 2005, Stansted had used only ¾of the ATMs sanctioned under its current planning permission. It is clear that many more passengers could be carried without any increase in the limit. In the absence of financial or other regulatory interventions to address the adverse environmental consequences of civil aviation, this is one of the few sanctions which works and should under no circumstances be relaxed. This part of the application shouldtherefore also be rejected.
  1. Noise Whilst the arguments above should be sufficient in themselves to persuade the Council to reject this application, there are some matters of more specific concern to Bishop’s Stortford residentswhich lend weight to this conclusion. Residents,particularlyon the southern quadrant of the town, are the largest concentrated group of peopleto be affected by noise disturbance, especially because the south western route is the most frequently used take off path from the Airport. Leq contours, whether at 57 db or any other noise level, are a wholly unsatisfactory way of measuring the real disturbance caused. This is because it averages noise disturbance over times of day, days and weeks, whereas the reality experienced by people on the ground is of a series of individual disturbances at greater or lesser frequencies. Moreover the research on which current standards are based was carried out in the 1970’s and 80’s and provides no guide to the acceptability of this form of pollution today. The more frequent the number of disturbances, the less acceptable they become, and to argue that aircraft are becoming quieter is not a defence. The improvement will at best be marginal and quite insufficient to offset the increased frequency of the disturbance. This therefore provides added justification for rejecting the requested increase in the ATMs, particularly since there is the potential for an extra third more movements compared with the present within the current limit.
  1. Surface Access As well as failing to disclose up front the doubling of passenger throughput which granting of this application would allow, BAA have been similarly evasive about the surface access implications of expansion on this scale. Their approachhas been to argue that if everything else stayed the same, the extra demand on road and rail infrastructure could be accommodated without any increases in capacity – presumably to avoid paying for any of the additional capacity which might be regarded as a consequence of the expansion of the Airport. There are two flaws in this argument. Firstly, everything else will not be staying the same. And secondly, it depends on no significant shift away from private cars and towards public transport to enable the Airport to operate in a more sustainable manner in future.
  1. Taking the first point, a significant increase in road transport in the area is bound to happen. Road traffic has grown by 1 or 2% a year in recent decades and car ownership has been increasing. There are no Government policies to alter that trend other than allowing congestion on the infrastructure to moderate it. In this region pressure will be increased by Governmentpolicies for significant housing development. Stansted expansion, without modal shift, will be a further generator of road traffic. For BAA to pretend that congestion is down to these other factors and nothing to do with their expansion plans is simply disingenuous.
  1. The general increase in traffic congestion also spills over into Bishop’s Stortforditself. Our road infrastructure is already stretched to breaking point and cannot support a doubling in passenger numbers at the Airport, with all the additional off site traffic which that will generate. Moreover, we already suffer a problem from off site fly parking and Airport park and ride schemes and expansion will only make matters worse.
  1. On the second point, if BAA were serious about sustainability, they would be trying to achieve a public transport modal share of surface access well above the current 40%. If that were to happen, the rail network in particular would not be able to support the demand generated. Even with no change, it is clear from BAA’s own evidence that local rail users are suffering at the expense of Airport passengers. BAA shows that if the current timetable is maintained and there is no modal shift, Airport demand can be met by 8 or 12 coach trains whereas non airport services will be overcrowded. It is not clear whether other planned development along the corridor has been factored into this calculation. However, BAA airilydismisses the problem as not being of its making because the overcrowded services do not call at the Airport.
  1. However, the reality is rather different. What the forecasts show is that the timetable does not allocate resources properly. Airport services will get more seats than they need and other commuter services will not get enough. This arises because four regular Airport express services per hour receive first priority in timetable planning, with the other services having to be fitted into the remaining slots around them. Platform lengths mean that longer trains cannot be run to other destinationsand the infrastructure constraints of a two track railway mean that more frequent services cannot be run, unless the Airport service was curtailed in the peaks. In short, regular users are penalised to satisfy the demands of the Airport. Moreover, BAA are also assuming that if Airport demandgenerated a requirement for 12 coach trains, somebody other than BAAwould have to pay for them. Unfortunately, a more likely scenario is the one which has occurredbefore. As the Airport expresses become fuller, the intermediate stops at Bishop’s Stortfordand Harlow will be removed, so that they too would suffer a worse service. Of course, if BAA were serious about modal shift, they would be volunteering to fund extra capacity on the West Anglia route (as they did to Heathrow) to reduce the conflicts between Airport and other services.
  1. Conclusion We believe that our grounds of objection, set out above, provide sufficient justification for Uttlesford to turn down this application and that this is what they should do. There are other considerations arising from the doubling of the size of the Airport, such as the impact on global warming, which go beyond our remit as a Civic Federation to comment. Uttlesford may feel that such wider issues go beyond their remit too. Indeed they may reasonably feel that any impact which goes beyond their boundaries and the interests of their residents is beyond their competence. If that is the case, and they feel unable as a result to determine the application, then their only proper course of action is to ask the Secretary of State to call it in for decision. That would at least have the benefit of ensuring that the arguments were properly tested at a Public Inquiry.
  1. Finally, for the avoidance of doubt, I should make it clear that Ihave no connection with the John Rhodes who appears to have submitted BAA’s application.

JOHN RHODES

CHAIRMAN