Aviation Strategy

WRITTEN EVIDENCE FROM CRAWLEY BOROUGH COUNCIL (AS 43)

Executive Summary

1. Crawley Borough Council is the Local Planning Authority for Gatwick Airport and therefore has a significant interest in the development of the Government’s Aviation Strategy.

2. The Borough Council puts forward the following comments for consideration by the Committee:

· The relationship between the Aviation Policy Framework and the work of the independent Aviation Commission needs to be clear to ensure that all options regarding airport capacity are given full consideration and assessment.

· In making best use of existing capacity at airports in the short term, the environmental impact associated with increased passenger throughput needs to be managed.

· Proposals relating to capacity at one airport could have a knock on effect on the role of other airports and it is important that this relationship is fully understood and assessed as part of the development of national aviation policy.

· There needs to be clear guidance to local planning authorities on the role of safeguarding and protecting areas from "incompatible development" where there are potential options for future runway development.

· Greater consideration needs to be given to assessing the surface access implications associated with airports and increases in capacity.

· Guidance relating to the onset of community annoyance from aircraft noise needs to be based on more detailed evidence.

Written Evidence

The Benefits of Aviation

3. The importance of aviation to the economy is recognised both at a national, regional and local level. The proximity of Crawley to Gatwick Airport means that around 1 in 7 of Crawley’s residents work at the airport, or in its associated services and industries.

4. The principle of making best use of existing capacity to meet demand in the short term is supported as it is efficient in terms of maximising the use of the existing facilities. However, it should also be recognised that there is an environmental impact associated with increasing passenger throughput using existing capacity and it is still important to ensure that the environmental impact of this growth is mitigated. The existing S106 agreement between the local authorities and Gatwick Airport Limited is based on these principles and sets out various ways in which the environmental impact of the airport will be managed as it grows towards 40 million passengers per annum (the maximum capacity of Gatwick with a single runway).

Airport Capacity

5. This is an issue of fundamental importance to the local area as the implications of any additional runway capacity wherever it is located in the South East will have a significant impact on Crawley Borough. Additional capacity at Gatwick could increase jobs and benefit the economy, but there would be considerable environmental impacts. Alternatively, if another location is identified for growth in hub capacity, there will be long term impacts for all the other airports including Gatwick as airlines potentially re-organise their operations. This could have a detrimental effect on the local economy. The Borough Council and other partners are preparing to undertake an assessment of the impacts of various scenarios of providing additional airport capacity on local and sub-regional employment in the Crawley area and Gatwick sub region. It is hoped this evidence will be useful in formulating the Borough Council’s contribution to the work of the independent commission dealing with maintaining the hub capability of the UK.

6. There has been uncertainty about future runway development at Gatwick for a number of years, with land currently safeguarded and therefore prevented from being used positively to meet local development needs. It is, therefore, important that the Government keeps to its latest timescales for assessing the issue of long term airport capacity in the UK. This will help give confidence to local and national economies and local communities to plan for the future. The draft Aviation Policy Framework, which is due to be published well in advance of the findings of the independent commission, should make it clear that all options for the long term are to be considered, including the balance between hub capacity and point to point to ensure that all decisions are made in light of all the available evidence.

7. The overall importance of surface access links to airports that is highlighted in the APF is welcomed. There is a particular focus on High Speed Rail 2 being an alternative to domestic and short haul flights but the importance of the role of rail not on High Speed Routes in enabling airports such as Gatwick to achieve their point to point function effectively, is not sufficiently highlighted. There is some reference to working with partners to identify further opportunities to improve rail services but it is important that this ultimately delivers improvements to services and overcomes capacity constraints on the rail network.

Climate Change Impacts

8. Addressing climate change issues at a global level is important to ensure that the whole of the aviation industry addresses the issue irrespective of where they operate from.

Noise and other local environmental impacts

9. The draft Aviation Policy Framework sets out a range of initiatives to manage the impact of airports on noise and other environmental issues. The following paragraphs represent the Borough Councils views on the proposals set out in the Framework.

10. The overall objective "to limit and where possible reduce the number of people in the UK significantly affected by aircraft noise" is reasonable as the principle of this objective is appropriate. The relationship of the "to reduce" part of this objective needs consideration in light of the assessment of the need for additional hub capacity in the UK including the contribution which could be made through increased size of aircraft, noise can be reduced with quieter engines.

11. In the APF the Government recognises that the 57dB LAeq 16hr contour no longer truly reflects the onset of community annoyance. It is therefore not appropriate to continue to use this contour. The Government should examine other indices to measure community annoyance as frequency of flights plays a major part in community annoyance. There is no conclusive evidence as the government has commissioned very little research into the subject. Community annoyance could also vary from urban to rural areas and this needs to be examined in more detail by the government. The daytime 57dB contour also fails to include the impact of night flights.

12. Consideration should be allowed for both a lowering of the finite 57 dB(A) band in tandem with alternative or complimentary ratings such as C weighting due to the noise type and intensity to allow better modelling of the likely community response where noise sensitive premises are exposed to high levels of aircraft movements.

13. There should be a move to the Lden as this reflects the relative impact of evening and night noise. There should also be further examination of LAmax contours, especially at night where regular sleep arousal can adversely affect health. Contours showing the number of events over 60dB LAmax for night noise would capture this.

14. The use of noise envelopes can be an effective method of controlling noise and can encourage the use of quieter aircraft to increase overall capacity. However as discussed above the frequency of flights can contribute as much to ‘annoyance’ as the actual overall average noise levels, so all envelopes will depend on local conditions. Any envelope agreement must be clearly defined and come with an effective method of control.

15. It is difficult to put one environmental issue above another as all environmental factors need to be considered and given the relevant weight depending on their relative impact on health.

16. The Government should continue to designate the three airports for noise management purposes. There are many conflicting interests surrounding airports and it would be difficult for one authority to independently exercise adequate controls, unless these controls are clearly set out in legislation.

17. Any noise designated airport which has residents adversely affected by noise should be forced to establish and maintain a penalty scheme.

18. The current night quota at Gatwick is under utilised. With Gatwick aiming for 45 mppa this additional headroom is likely to be used as the daytime slots fill up resulting in a substantial increase in night flights. This will presumably be made up of additional holiday/leisure flights. Therefore charging more for night flights may only result in larger profits for the airport and no benefit to residents. To protect residents from the worst aspect of aviation, namely night flights, the Government should aim to reduce night flights incrementally over a period of time.

19. During the day differential landing fees should be introduced as it follows the principle of the ‘polluter pays’ and will encourage quieter aircraft.

20. The present compensation schemes are the minimum that should be offered. The offer to cover the costs of moving only results in one household replacing another and doesn’t recognise that noise at that level could have a significant adverse effect on health. Research is clearly demonstrating that high levels of noise can cause long term health problems and compensation schemes should ensure that those properties suffering high levels of noise are purchased and are no longer used for residential purposes in the future or until noise levels reduce again. The level at which this should happen should be around the 69dB LAeq16hr or 60dB LAeq8hr for night time noise.

21. The offer to cover the cost of moving should also be available to those who have experienced a significant increase in noise due to changes in airport operation or expansion and are exposed to higher noise levels, for example a property exposed to levels above 63dB by changes in airport operation (i.e. new runway/changes in NPRs). Sound insulation only improves the internal noise environment of a home (with windows closed) and not private gardens or the surrounding neighbourhood. The impact of the loss of residential properties on the supply of housing in an area where demand already outstrips supply also needs to be taken into consideration.

Air Quality

22. The APF highlights the impact that airports can have on air quality and that the policy is to seek improved international standards to reduce emissions from aircraft and to work with airports and local authorities as appropriate to improve air quality.

23. The S106 agreement between Gatwick Airport Limited, Crawley Borough Council and West Sussex County Council signed in 2008 contains a number of obligations concerned with mitigating the environmental impact of the growth of the airport. It has been a useful mechanism for working with the airport on a range of environmental matters and whilst it recognises the role of meeting national regulations and targets (e.g. air quality standards) in managing the operation and growth of the airport, it does also give greater reassurance to the local authorities and others of the actions and activities which are being undertaken in order to help meet these targets.

Planning

24. The draft Aviation Policy Framework only touched on planning issues concerning the development of the airport. However, this issue is particularly important to Crawley Borough Council as the local planning authority for Gatwick Airport. As part of its response to the Scoping Document which preceded the publication of the draft policy framework, the Council sought clarity on the issue of safeguarding land for a second runway at Gatwick. Although the airport operator indicates that amount of land that is required to be safeguarded, this does not have any statutory basis unless it is included in the Local Plan.

25. It is felt that this section of the draft policy framework provides a clear steer that land for a second runway should continue to be safeguarded through the Local Plan until conclusions have been reached regarding the potential for future provision of a hub airport in the south east. It is presumed that this will now be provided by the findings of the independent commission which has recently been set up to examine the issue of a hub airport rather than through the Call for Evidence which is referred to in the document. Where airport expansion is a possibility then safeguarding should remain in place until a final decision is made.

26. Given that it has been indicated that the aviation policy framework will be published in advance of the report on hub airports, it is important that the framework continues to provide clear guidance on the issue of safeguarding and that possible options for any required hub capacity are not precluded until there has been a comprehensive examination of the issues through the Independent Commission. The Borough Council is currently preparing its new local plan to cover the period to 2029 and will need to reflect the latest guidance on safeguarding land.

27. It is also felt that further details on the meaning of "incompatible development" would be useful in formulating planning policies for the safeguarded area in order to give an indication of what sort of development is appropriate in the safeguarded area.

19 October 2012