Much Hadham Parish Council
The Red House
Much Hadham
Hertfordshire
SG10 6BU
Tel: 0127984 2705
Fax: 0127984 3960
8 June 2006
Dear Sirs
BAA's Application to Extend the Use of the Existing Runway at Stansted
Planning Reference UTT/0717/06/FUL (the "planning application")
On behalf of Much Hadham Parish Council I emailed Councillors Cant and Wilcock on 27 October 2005 with a copy of my letter of 27 October 2005 to BAA commenting on BAA's document "Growing Stansted Airport on the Existing Runway". BAA acknowledged my letter on 4 November 2005 and promised me a "written reply as soon as possible". I have heard nothing since.
I consider that most of the comments in my letter of 27 October remain as relevant to the planning application that BAA has now made and which BAA has disingenuously described as "purely" a variation of the current condition limits. I should, however, like to add some further points. In case it helps, I enclose a copy of my letter of 27 October.
Documents I Have Seen
I have not looked at all the documents submitted by BAA in support of the planning application, but I have read:-
- The Stansted Generation 1 Planning Statement produced by RPS Planning (the "PS")
- The Generation 1 Environmental Statement Non-Technical Summary produced by Ove Arup & Partners Ltd (the "Environmental Statement")
- The Generation 1 Environmental Statement Volume 12 Third Party Risk also produced by Ove Arup & Partners Ltd (the "Third Party Risk Statement").
Missing Documents
BAA have not, I understand, supplied all the documents in connection with the planning application which the Council said was necessary in its Scoping Opinion of 4 November 2004; in particular no Master Plan for Stansted has been supplied, and BAA has failed to provide an assessment of the impact of the proposed development and the resulting increase in flights on the UK contribution to global warming through the production of CO2 and other emissions. Since the board of BAA has recommended the offer, it seems likely that the Ferrovial Consortium will be successful. It is difficult to forecast what will be the effect of the takeover on the future management of BAA, but in view of the enormous borrowings that the Consortium will require to finance the acquisition etc, it is likely that BAA's future policy will be to maximise revenue from Stansted as fast as possible. It is therefore all the more important that before considering the planning application, the Council should insist on BAA providing all the documents mentioned in the Scoping Opinion, so that Council will have as much information as possible when considering the planning application.
General Comments
The PS plays down the prejudicial effects on the environment of the increased use of the existing runway and emphasises the perceived economic benefits. The effects on the environment are consistently described as "limited". The reality is that the additional flights will undoubtedly damage the environment whereas the "economic benefits" are not certain, particularly when the disbenefits of increased emissions from road traffic, increased traffic congestion and increased aircraft noise are taken into account. If the Council decides to grant BAA permission to increase the use of the existing runway, the Council must impose conditions to restrict environmental damage as far as possible.
BAA's Forecast of Passenger Numbers
BAA's justification for its application is its forecast of the growth in passengers using Stansted. There can be no guarantee of any forecast, and BAA's forecasts have in the past proved inaccurate. There are many factors, which could lead to BAA's forecasts proving unreliable. I shall comment on only two of them.
First, the effect of the CAA's decision on the charges BAA may make to airlines using Stansted in 2008/13. In its defence document to the possible takeover by Ferrovial Consortium issued on 3 May 2006, BAA has said (see page 11) that it will raise "prices to permitted maximum at Stansted from 2007". I am not sure how the reference to 2007 ties in with the fact that the CAA is currently consulting on the charging system to apply during the next price control period from 2008 to 2013, but it is known that Ryanair and Easyjet have negotiated substantial discounts on the maximum charges that BAA would currently be allowed to require Ryanair and Easyjet to pay at Stansted. The takeover of BAA increases the likelihood that BAA will in fact raise to the "permitted maximum" the charges it makes at Stansted to Ryanair and Easyjet and the other no frills airlines from 2007 (or 2008), and this could result in some airlines reducing their flights to and from Stansted or in their raising prices, both of which could reduce the annual number of passengers using Stansted and could in any event slow down the rate of increase in their number.
Secondly, the review of airport competitiveness recently announced by the OFT. BAA probably did not know about this impending review when it made the planning application in April. The table in para 2.2 of the PS shows that in 2004 BAA's three London airports handled nearly 93% of the passenger traffic at London's six "airports" (including Luton and Southend). The Parliamentary Transport Committee has called for BAA's monopoly of the London airports to be ended. It is possible that the OFT and the Competition Commission will reach the same conclusion. Heathrow is by far BAA's most profitable airport, and Gatwick is more profitable than Stansted. If BAA were required to dispose of one of its three London airports, it is likely that the new management of BAA would be in favour of disposing of Stansted. If so, BAA would clearly try to persuade airlines to make greater use of Heathrow and Gatwick, leading quite possibly to a reduction in the number of passengers using Stansted. The new operator of Stansted would no doubt attempt to bolster the use of Stansted, but with what effect is pure conjecture.
Conditions attached to the 2003 Planning Permission
BAA has suggested that the conditions attached to the 2003 planning permission should be changed by varying Condition ATM1 (which imposes restrictions on the number of annual air transport movements) and by removing Condition MPPA1 (which restricts the number of passengers to 25 million in any twelve month period). BAA has said that "there is no need to replace the current Condition MPPA1 with a new passenger limit" (para 1.13 of the PS), but the PS contains no, or at any rate hardly any, argument to support this proposal. I trust that you will not agree to the removal of any restriction on the number of passengers using Stansted in any twelve month period.
Passengers have to travel to and from the airport, and as passenger numbers increase there will be increasing pressure on roads and trains. The sensible course is clearly to place an upper limit on annual passenger use and to judge as time passes what is the effect of that use on the environment, roads and trains. This is particularly the case if, as at present, over 60% of the passengers using Stansted continue to arrive and leave by car, so that there will be increasing pressure on the local roads with all the attendant increased traffic congestion and pollution. BAA has argued that current road and rail facilities are sufficient to cope with the increased number of passengers, but this sweeping generalisation is probably made because BAA does not want to pay for the cost of any upgrading. BAA's argument is not improved by the bland suggestion (see, for example, para 5.148 of the PS) that adequate train seating capacity may be available around 2014 if the DfT persuades the train operating company to strengthen to a 12 car formation; anyone who regularly uses the existing Cambridge/Stansted rail link to Liverpool Street knows that it is already overcrowded, and not just at rush hour.
For some reason (see para 5.161 of the PS) BAA has refused to produce an updated Airport Surface Access Strategy as part of the planning application and has only offered to do so following the grant of permission. It is essential that you should see the upgraded ASAS when considering the planning application.
BAA has only been able to generate the present level of passenger numbers at Stansted by offering discounts on airport charges to no frills airlines. It will only be in 2007/8 that we shall know the CAA's decision on the pricing regime to apply from 2008 to 2013. I consider that BAA's application is premature and that it should only be made when that pricing regime and its effects are both known. I appreciate that, as the planning authority, you have no control over the timing of BAA's application, but if it is to be granted, then I consider that the permitted maximum number of passengers using Stansted should at this stage be limited to 30 million in any twelve month period. In para 1.7 of the PS BAA has said that it expects to reach the current permitted limit of 25mppa by 2008, so if a restriction of 30mppa were placed on the use of the existing runway, this would not curtail its use until at least, say, 2010/11. Sometime after 2008 BAA could then, if they wish, submit a further application when the outcome of the CAA (and OFT and the Competition Commission) reviews are known and everyone is in a better position to judge their effect on passenger numbers.
BAA has suggested varying Condition ATM1 so as to allow a new upper ATM limit of 264,000 flights per annum. There is no reason why this upper limit should immediately be agreed; a lower limit could be imposed, with BAA of course being free to apply for it to be raised as and when necessary. The PS says nothing about QS levels or about a split between (a) day ATMs (07.00 hours to 23.00 hours), (b) night ATMs and (c) shoulder period ATMs (06.00 hours to 07.00 hours and 23.00 hours to 23.30 hours). The DfT's recent announcement following the review of restrictions on night flights is a grave disappointment to the residents of Much Hadham (and no doubt to other local residents). If you decide to grant BAA permission to increase the use of the existing runway and if you have the power to impose conditions restricting night flights at Stansted, then I urge you to do so.
General Comments on BAA's Planning Application
I should like to make three points.
First, the Third Party Risk Statement contains no mention of the only fatal crash (the Korean Airlines flight) that has so far occurred of an aircraft taking off from Stansted. This is, to put it no higher, odd.
Secondly, the PS and the other documents I have read contain no reference to any work being required by NATS to redesign flight paths to cater for BAA's proposed increase in the number of flights taking off and landing at Stansted. This is also odd. The sky around Stansted is already busy at certain times of the day, with planes arriving and taking off from Stansted and Luton and with planes in a holding pattern in the Heathrow stack to the south of Stansted. I expect that if there are to be more flights using Stansted, then NATS will have to redesign some flight paths. This is no doubt difficult. The Third Party Risk Statement is silent about the risk of aircraft colliding in the vicinity of Stansted. Clearly the planning application can only be granted if you are satisfied that safe flight paths are currently available for the additional flights for which BAA is seeking permission. BAA must produce satisfactory evidence that safe flight paths are available for the proposed increase in flights..
Thirdly, the planning application makes it clear (see para 1.17 of the PS) that BAA is not seeking permission for any additional physical developments/facilities that do not currently have planning permission. It is clear from para 1.17, and particularly from the map at the back of the Environmental Statement, that BAA has a clear idea of the buildings etc it wishes to construct if the planning application is granted. It is difficult to understand why BAA does not propose to adopt the sensible course of applying now for the necessary permission for the buildings etc. Has BAA in mind that if planning permission is granted, the Council, as the planning authority, will find it hard to refuse permission for the buildings etc which BAA claims are necessary to operate the existing runway at the increased capacity that will have already been authorised?
Aircraft Noise
As I said in my letter of 27 October, aircraft noise is a prime concern for the residents in Much Hadham. They are mainly affected by the noise of aircraft using flight path BZDR (known as "Buzzard") on take off. They are also affected by the noise of aircraft landing at Stansted from the south west towards the north east where aircraft have been held in, or routed via, the Barley/Barkway stack and fly south to the west of Much Hadham before swinging north to land at Stansted towards the north east. The noise caused to the west of Much Hadham from aircraft landing at Stansted is less disruptive because, according to BAA, the south west approach is only used about 35% of the year, but when aircraft do land from the south west, the maps published by BAA in April 2006 show their height in the vicinity of Much Hadham at about 4000/3000 ft (or less).
Para 5.1.3 of the Environmental Statement makes it clear that BAA has based its assessment of air noise on current Government policy, that is on 57dBALeq contours, which iron out peaks. The 57dBLAeq contours published by BAA in connection with the planning application do not extend over Much Hadham. The 16 hour period over which the 57dBALeq contours are estimated runs from 07.00 hours to 23.00hours. This omits two periods when Stansted is exceptionally busy and when most residents in Much Hadham and in surrounding areas are trying to sleep or to get to sleep, that is the shoulder periods from 06.00 to 07.00 hours and from 23.00 to 23.30 hours. The 57dBLAeq contours also do not cover the period from 23.30 hours to 06.00 hours when most people are asleep and when aircraft noise is at its most disruptive.
Calculating noise pressure levels on the basis of average sound is absurd since nobody complaining about aircraft noise has ever complained about periods of silence when there are no aircraft overhead. The absurdity becomes more obvious when flights at night and during two of the busiest periods each day (that is the shoulder periods) are omitted from the calculation. Noise pressure levels should be calculated using the WHO guidelines, particularly for Stansted, which is in a predominantly rural area,
Since I wrote to BAA on 27 October, a report has been published by Applied Acoustic Design on 19 December 2005 comparing aircraft noise during three monthly periods in 2000 and 2004 over Much Hadham. I enclose a copy. The report was commissioned by BAA. It contains a comparison of aircraft noise monitored over two different three month periods at Hoplands House in Much Hadham in 2000 and 2004. The report shows that aircraft noise events measured at Much Hadham have reduced from 71.9dBA in the three month period in 2000 to 69.3dBA in the three month period in 2004, which is only a reduction of 2.6%; that in the three month period in 2000 there were 4152 separate noise events above 65dBA; and that in the three month period in 2004 there were 3762 noise events above 65dBA, a reduction of 9.4% compared with 2000. This is an improvement resulting, as the authors have explained, from the use of more modern and quieter aircraft, but in the three month period in 2004 there were still more than 1250 noise events above 65dBA on average per month. That amounts to a lot of aircraft disturbance for the residents of Much Hadham, which increased use of the existing runway is certain to make much worse.
The AAD report confirms the absurdity of the 57dBALeq contours, which do not show any noise disturbance over Much Hadham, when in fact there is substantial disturbance. The report also confirms the truth of what Mr Terry Morgan admitted at a meeting in Much Hadham, that it is the noise peaks that cause annoyance, not an average.
I do not know whether BAA has submitted a copy of Applied Acoustic Design's report with the documents lodged in connection with the planning permission, but I consider that if BAA has not done so, then it should have done. I also do not know whether BAA has commissioned similar reports at other sites, but if so, then those reports should also have been submitted in connection with the planning application.
I am sure that there are many other places where aircraft taking off and landing at Stansted would produce noise events similar to, or louder than, those shown in the AAD report. I consider that before considering the planning application, you should require BAA to commission reports at a number of such places and should then ask the local residents for their comments. I expect that the residents would be as vocal in their objections as the residents of Much Hadham and that they would also join in the condemnation of the ridiculous 57dBALeq contour approach.
Summary
The residents of Much Hadham would prefer that BAA's planning application should be rejected. The outcome would presumably be that the matter would be referred to a public enquiry, so that all local residents would have an opportunity to express their views. If the Council is, however, to grant permission, then this should only be done subject to the most stringent conditions, with BAA being required at regular intervals to provide evidence to the Council of compliance with the conditions and financial penalties being imposed on BAA in the event of the conditions being breached.