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 It should therefore be withdrawn.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 residentsvisiting overseas
'000 / Foreign residents visiting EoE
'000 / Total
'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.