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Response to Airports Commission Consultation A Second Runway for Gatwick Response to Airports Commission Consultation 3 February 2015 Airports Commission: London Gatwick 180 Table of Contents Question 1: Conclusions in respect of the short listed options ..................................................... 3 Executive Summary: A second runway for Gatwick ....................................................................... 4 Question 2: Suggestions for how the shortlisted options could be improved ............................ 21 Question 3: Comments on how the Commission has carried out its appraisal .......................... 37 Question 4 and 5: Comments on modules including factors not fully assessed ........................ 43 Module 1: Strategic Fit ....................................................................................................................... 45 Module 1: Strategic Fit – Part B: Other Issues ................................................................................... 59 Module 2: Economy Impacts .............................................................................................................. 69 Module 3: Local Economy Impacts .................................................................................................... 85 Module 4: Surface Access ................................................................................................................. 91 Module 5: Noise ............................................................................................................................... 105 Module 6: Air Quality ........................................................................................................................ 119 Module 7: Biodiversity ...................................................................................................................... 125 Module 8: Carbon ............................................................................................................................ 129 Module 9: Water and Flood Risk ...................................................................................................... 133 Module 10: Place ............................................................................................................................. 139 Module 11: Quality of Life ................................................................................................................ 143 Module 12: Community .................................................................................................................... 145 Module 13: Cost and Commercial Viability ....................................................................................... 151 Module 14: Operational Efficiency .................................................................................................... 183 Module 15: Operational Risk ............................................................................................................ 193 Module 16: Delivery ......................................................................................................................... 197 Question 6: Comments on Sustainability Assessment ............................................................... 207 Question 7: Comments on Business Cases ................................................................................ 215 Question 8: Any other Comments ................................................................................................ 221 Response to Airports Commission Consultation 1 Table of Technical Appendices Appendix 1 ICF International Technical Report – Traffic & Forecasts Appendix 2 InterVISTAS – The Importance of Airport Competition on Air Fares Paid by Consumers Appendix 3 GAL – Supporting Traffic & Competition Analysis Appendix 4 CTAIRA – Supply side issues and the London market Appendix 5 RPS – Fit with wider spatial and socio-economic development strategies Appendix 6 Oxera – Economy impact analysis Appendix 7 RPS/Optimal – Local Economy Report (Employment & Housing) Appendix 8 Arup – Surface Access Reports Appendix 9 ERM – Air Noise Report Appendix 10 Ian H Flindell & Associates – Ground Noise Report Appendix 11 Arup – Air Quality Report Appendix 12 RPS – Biodiversity Report Appendix 13 GAL – Development of an indicative habitat & landscape plan Appendix 14 RSK – Carbon Technical Report Appendix 15 CH2M Hill – Water & Flood Risk Report Appendix 16 RPS – Place: Heritage Report Appendix 17 RPS – Place: Landscape, Townscape & Waterscape Report Appendix 18 RPS – Place: Land Use & Land Cover Report Appendix 19 Helistrat – Place: Waste Report Appendix 20 RSK – Heathrow NWR Landfill Report Appendix 21 ERM – Quality of Life Report Appendix 22 RPS – Community Report Appendix 23 EC Harris – Cost & Commercial Technical Report Appendix 24 Arup – Operational Efficiency & Passenger Experience Report Appendix 25 Reid Aviation – Air Space & Operational Concepts Report Appendix 26 DFS – Fast-Time Simulation Report Appendix 27 Arup – Operational Risk Report Appendix 28 Bechtel – Construction Delivery Report Appendix 29 Bechtel – Project Execution Plan Appendix 30 Bechtel – Second Runway Construction Animation Appendix 31 EC Harris – Heathrow NWR Critique Appendix 32 ERM – Sustainability Assessments Review Appendix 33 Arup – Energy & Utilities Report Appendix 34 ERM – Geo-environmental Report Appendix 35 GAL Pledges to the Local Community Appendix 36 GAL Runway Options Consultation – Report of Consultation, July 2014 Appendix 37 GAL Further information on Gatwick's revised phasing strategy (including Programme) Appendix 38 Farrells – Place-Based Economic Benefits Report Appendix 39 GAL – Momentum Grows for Gatwick Appendix 40 GAL – Connecting the UK’s Regions to the Future, Faster Appendix 41 GAL – Response to CAA Draft Runway Policy, December 2014 2 Response to Airports Commission Consultation Response to Question 1 Question 1: Conclusions in respect of the short listed options Q1: What conclusions, if any, do you draw in respect of the three short-listed options? Key points 1.1 The Consultation Document supports our view that Gatwick is the best overall choice for the site of new runway capacity in the South East. It shows that Gatwick is the most cost effective proposition to meet future demand for air travel and to provide the connectivity that London, the South East, and the UK needs, and we remain of the view that Gatwick can meet those needs sooner than any of the other schemes. 1.2 Nonetheless, the Commission’s assessment of the schemes would be even more favourable to the Gatwick proposal if a number of issues were corrected. 1.3 In the case of Gatwick, one key issue is that the forecast level and rate of growth in air traffic at the airport does not reflect either existing or emerging industry trends, with consequential effects on the assessed economic benefits that a second runway at Gatwick would generate. 1.4 There are also a number of flaws in the Commission’s assessment of the Heathrow schemes. In particular, the additional runway capacity postulated by the proposers has not been subject to necessary critical review and little substantive work has been done on downside risks, with the consequence that the benefits of these schemes have been substantially overestimated. 1.5 Our conclusions are set out in detailed answers to the Commission’s questions in its Consultation Document, and are summarised in an Executive Summary which is set out on the following pages. Response to Airports Commission Consultation 3 Executive Summary Executive Summary: A second runway for Gatwick 1. The Commission has a very important task a) The UK is the best connected country in Europe, and London is the best connected city in the world. b) This has been achieved through making the most of our geographical advantages in serving the world’s major aviation trunk routes, particularly the Trans-Atlantic market; through the enterprise and abilities of our aviation sector; and through consistent Government policies favouring liberalisation and competition. c) These policies have meant that, for more than thirty years, the UK has led the way on the liberalisation of air transport. d) Our efforts on liberalisation led, within the EU, to the growth of Low Cost Carriers (LCCs), to greater competition and to lower fares; and then to more competitive world markets, through the gradual development of liberalised EU air service agreements with other major regions, such as the USA, though the benefits to consumers on US routes has been restricted through the granting of anti-trust immunity to the three main airline alliances. e) In the airports sector, the break-up of the BAA monopoly and its replacement by a London airports system under a variety of owners has led the way towards competition between London’s airports and more generally to the enhancement of competition in the air transport market through multiple airline/airport combinations. f) Passengers are already seeing the benefits of this change through a wider range of airline business models, routes, fares and other innovations from London’s airports as well as having a choice of airports outside of London for flights to many destinations, thus continuously improving air connectivity for London and the rest of the UK. g) Greater operational efficiency and lower airport charges should continue to flow from this competitive dynamic. h) But the achievement of the full range of benefits is constrained by the long-standing difficulty in the UK context of securing approval to increase runway capacity and
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