Response of Stop Stansted Expansion to BAA's Consultation on the Siting of a Second Runway ("Stansted Generation 2: December 2005 Consultation")
31 January 2006
Mr T. Morgan,
Essex CM1 3BR
Dear Mr Morgan
You have invited our comments on your December 2005 Consultation about the siting of your proposed second runway at Stansted Airport. You have put forward four options, three of which are offered in either mixed mode or segregated mode.
All of these options are unsustainable and therefore unacceptable. In 1984 Inspector Graham Eyre concluded, following a lengthy public inquiry, that a second runway would be ‘an environmental catastrophe’, an ‘unprecedented and wholly unacceptable major environmental and visual disaster’. You have failed to make reference to this judgement, and you have failed to provide any evidence for departing from it. In fact a second runway would be an even greater environmental disaster today than in 1984. At that time it was thought that the capacity of a second runway would be about 25 mppa: now we know that it would be over 40 mppa. And we are now much more aware of the dangers of global warming, the part played by man-made carbon dioxide emissions, and the rapidly increasing contribution to this made by air travel. It is for these reasons that the East of England Regional Assembly has ruled out a second runway in its draft East of England Plan. Indeed the Sustainability Appraisal Report which it commissioned ruled out the full use of the existing runway.
You have asked for our comments on your method of consultation. We have two fundamental criticisms.
First, to consult about the position of a second runway in advance of your planning application would appear to compromise the planning procedure. If you are going to make a decision about siting at this stage will you then refuse to consider the matter at the planning application stage on the ground that you have already covered this aspect? And if not, what is the point of this consultation? If you were to deal with the siting of R2 at the planning application stage you would be obliged to provide a full environmental impact assessment (EIA) for each of the options, and this would have to include a full health impact assessment (HIA). Yet in your present consultation you fail to provide a full EIA or HIA even for your preferred option, not to mention the other options. In our view the siting of R2 should be dealt with at the planning application stage, since it has to be seen in an overall context and not as an isolated issue.
Second, however, this is only part of your failure to provide adequate information. Even for the limited purpose of choosing a site for the proposed runway your December 2005 document falls far short of the standards required for any effective consultation. We have already mentioned your failure to produce proper EIAs and HIAs for all the options, and in this context we would draw particular attention to the absence of any information about the impacts on carbon emissions and local air quality and the implications in respect of flight paths and surface access. You have also failed to make clear the basis on which many of your statements and judgements are made. I attach as an appendix to this letter a list of points on which further information should have been provided.
You may say that on some issues there would be no material difference in the impacts of the various options despite the differences in their scale and location. That is no argument for not putting forward the information so that those being consulted can form a proper impression of what would be involved and judge for themselves. If this information were to be put forward objectively and without any BAA spin most persons would quickly reach the conclusion that all the options you have put forward are unacceptable. Another option, of course, would be not to build a second runway at all. In the proceedings in the High Court in December 2004, the Government acknowledged that not building a second runway was a valid option, for example, in the event of an unfavourable EIA and of course the Chief Executive of BAA has repeatedly stated that a second runway at Stansted would not be built unless it was in the interests of BAA shareholders to do so.
We are told that there are to be future consultations on road and rail infrastructure, and then on flight paths. This disjointed approach will serve to prevent full and proper consideration of all the issues on a holistic basis and appears to be an attempt to pre-empt certain crucial aspects of the planning application. We regard this approach as wholly unsatisfactory.
At the outset of this letter, we set out our reasons for opposing all the options which you have put forward. But if you are seriously asking members of the public to choose between them, you should at least put forward sufficient information to enable a meaningful choice.
Finally, you ask how you can best talk and listen to people. When presenting this consultation in a television interview you stated that in previous discussions there was one message that stood out for you – that local people ‘want to have a say on what this runway looks like’. However, as you know very well, the overwhelming message which local people have given to BAA, time and again, is that they do not want a second runway at all. In the October 2002 poll carried out by Electoral Reform Services for the Uttlesford District Council, 69% of ballot papers were returned (a higher percentage than the turnout for the general election), and of those who voted 89% were against any additional runway at Stansted. The Government may have said that it supports the idea of a second runway at Stansted but it has not issued any instruction to BAA to build this; indeed, it is not in a position to do so and has acknowledged ("Governments don't build runways") that any final decision will depend upon a number of factors including BAA's commercial judgement and an assessment of the environmental impacts, as referred to earlier.
We have no confidence that you are listening to local people, but there is one simple way in which you would win such confidence – by withdrawing this pernicious proposal once and for all.
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.
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.
No information has been provided on the noise impacts upon communities for levels of noise below 57dBAleq and noise contours are only provided for 2030. Noise contours should have been provided for 54 dBAleq and for 50 dBAleq 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).
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.
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.
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.
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.
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.
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.)
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.)
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.
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.)
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.
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.
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.
Taken from www.stopstanstedexpansion.com/baa_consultation2.html. SSE have also collected here other responses from local parish councils.
Plans for Stansted second runway unveiled - press releases issued 9 December 2005 by BAA
BAA's "Stansted Generation 2: December 2005 Consultation" (Acrobat ® format, 4.8 MB)
www.stanstedairport.com/future - more BAA maps showing the various options proposed in the above consultation
Second Runway Plans Spell Environmental Disaster - press release issued 9 December 2005 by SSE, in response to the consultation
Response of Broxted Parish Council to the consultation - issued 2 March 2006