Chrishall Parish Council

CHRISHALL PARISH COUNCIL Belinda Irons, Clerk to Chrishall Parish Council, 14 Crawley End, Chrishall, Nr. Royston, Herts. SG8 8QL Tel: 01763-838732 email: [email protected]

13th June 2006.

Uttlesford District Council, Council Offices, London Road, Saffron Walden, Essex. CB11 4ER

Dear Mr Mitchell,

Re: BAA, STANSTED: PLANNING APPLICATION: UTT/0717/06/FUL

Thank you for your letter regarding the above planning application. Chrishall Parish Council (CPC) has carried out a written consultation with all residents within the village. The Parish Council’s comments below are based on the responses received from local residents. A copy of the Parish Council’s consultation letter and individual written replies are enclosed.

Chrishall Parish Council objects to this application due to the detrimental effects that the proposed increase in flights will have upon our community in terms of noise pollution, air pollution, traffic congestion, aircraft carbon emissions, and over use of natural resources.

Before dealing with individual points in the consultation document CPC wishes to make a general comment that the application is fundamentally flawed because the majority of airport traffic at Stansted is artificially subsidised, therefore the projected increases in passenger demand are not economically sound. Furthermore, the application fails to take into account the likely effect of inevitable fuel price increases which cannot fail to increase the cost of air travel.

Section 1: BAA Introduction:

CPC is concerned that the ‘40mppa sensitivity test’ has used 2003 as a baseline for modelling predictions about surface access, waste, water, air quality, third party risk, employment, and economic effects. Whilst the Parish Council is not a scientific institution, it is quite obvious to the layman that the modelling comparisons made with an already polluted baseline will generate skewed results. In this report, BAA maintains that the impacts will be negligible. We believe the report should be subjected to a more robust scientific analysis.

of 6 Section 1: 2.2:

CPC is concerned that the specialist consultants and advisers for air noise, climate change and energy are in fact BAA PLC. The Parish Council would urge Uttlesford to seek advice on these aspects of the Environmental Impact Assessment from independent specialists.

Section 3: Approach To EIA

CPC is gravely concerned that STAL considered Uttlesford District Council’s request for a Quality of Life Assessment (as developed jointly by Environment Agency, English Nature, English Heritage, Countryside Agency) to be unnecessary. Parish Council would urge Uttlesford to insist that this evaluation is carried out correctly.

Section 3.5.7:

CPC is concerned to note that ‘there are no definitive measures of significance’ and that ‘there are various ways in which significance can be assessed with the descriptors and criteria used often varying between topics’. The Parish Council was alarmed by the statement that ‘asigning levels of significance of predicted impacts is essentially matter of judgement and not a finding of acceptability or unacceptability’. The Parish Council objects to the planning application because the environmental impact assessment is clearly not based on sound science. We believe that impacts which BAA may describe as acceptable would in fact be unacceptable to the people whose enjoyment of life below the flight paths and stacking circles is disrupted.

Section 3.6.2:

CPC objects to the application because it fundamentally contradicts the mitigation arrangements which are currently in place.

Section 5: Planning Policy Context:

Section 5.2.2:

CPC objects to the application because the documentation does not provide sufficient evidence that ‘the benefits that the expansion in air travel has brought to peoples lives and to the UK economy’ will be balanced against the environmental impacts of air travel. CPC note that expansion in air traffic is widely believed to be the largest growing contributor to CO2 emissions and therefore removing the limit on air traffic movement at Stansted would be negligent in view of Government concerns about climate change.

Section 5.2.4:

CPC notes that the Government supports making full use of the existing runway at Stansted. However, the document states that the Government expects the air port operator to seek planning permission in good time to cater for demand as it arises.

of 6 CPC believes that a high proportion of existing use is generated by artificially cheap flights which creates a false demand. CPC urges UDC to consider finding a mechanism to limit or even abolish the subsidisation of passenger air travel. 66 countries supported the Gleneagles G8 summit at which France proposed taxation of aviation fuel. Pressure should be applied to central Government to reconsider its position regarding this issue.

Section 5.3.3:

CPC firmly believes that the proposal to remove limits on passenger numbers at Stansted is completely at odds with the principle of sustainable development.

Section 5.4.10

CPC is concerned that the application will lead to over development in the Stansted/M11 sub region and will place additional pressure on housing, amenities, utilities and infrastructure.

Section 6: Forecasts and demand for further capacity:

CPC urges UDC to question the validity of BAAs assumptions concerning growth and the demand for air travel and particularly ongoing reductions in the price of flights. In addition, their comparison with Gatwick (80mppa on a single runway) leads Parish Council to believe that the non-compliance with condition MPPA1 and varying condition ATM1 will leave the way clear for BAA to attain Gatwick air traffic movement and passenger numbers at Stansted.

Section 8: Consideration of Alternatives

CPC objects to the application because there has been no consideration of alternatives as detailed in the 1999 Regulations. The proposal is based only on a Government White Paper which is not statute.

Section 9 Climate Change

Section 9.1.4

The document states that BAA and STAL have taken a proactive approach to addressing its contribution to climate change. CPC is unable to find sufficient evidence in the document to support this assertion. We are not convinced that development of a voluntary emissions trading system will be adequate to mitigate the environmental consequences of the proposed increases in air traffic. The proposed emissions trading system does not yet exist, therefore it cannot be included in any scientifically valid assessment.

Section 9.2.6:

CPC would urge Uttlesford District Council to require more detailed information concerning the development of new standards aimed at limiting aircraft emissions at Page 3 of 6 source.

Section 9.2.10:

This section states that growing industries which include aviation, are to be catered for within a reducing CO2 total. CPC would urge UDC to consider imposition of a local environment tax which could be used to mitigate the environmental impacts of the airport by funding energy reduction initiatives within the district. This would provide a measurable means of mitigating the CO2 emissions generated by the aircraft. For example, a tax of £100 per flight multiplied by 274,000 flights would provide £27,400,000 to supply and install, for example, solar water heating, photovoltaic cells, ground source heat pumps and /or micro-generation wind turbines throughout the district per annum. Alternatively, a toll system at the entrance to the airport could be used to charge airport users directly.

Section 9.2.21 BAA quotes UDC Local Plan, stating that the proposal should not be refused on grounds of increased carbon emissions. This being the case, CPC demand that UDC review the policy in the light of scientific evidence.

Section 10: Summary of Environmental Effects

Section 10.1 Air Noise

CPC is not expert in the field of air noise. However, we would urge UDC to challenge the data presented within the report using expertise from environmental health resources. CPC objects to the application because a number of complaints have been made by local people about the noise from air traffic. Overhead aircraft noise is already widely perceived as an intrusion into the enjoyment of private homes and gardens throughout the village. CPC would be vehemently opposed to further increases in air traffic.

Section 10.2 Air Quality

The cumulative effect of air pollution is not considered in the report. Chrishall is under the flight paths, turning circles and stacking circles for Stansted, Luton, Cambridge, Duxford, military aircraft, private jets and helicopters. An increase in the number of flights both at Stansted and Luton will increase the air pollution which Chrishall will be subjected to.

CPC strongly urge UDC to implement independent assessment of the cumulative effects of air pollution on air quality, water quality and ground pollution from overhead flights outside BAA study area.

In addition, BAA state that the increase in individual pollutants is relatively small. NOx at 14%, NO2 at 9%, benzene at 9%, SO2 at 12% plus PM10 at 1% and PM25 at 2 %, equates to an overall increase of 47%. The synergistic effect of a combination of pollutants has not been assessed.

of 6 Section 10.4 Economic Effect:

The economic basis of the report is questionable as the cost of air travel is artificially maintained at a low level through subsidisation and lack of taxation on aviation fuel. Also in question is the tourism deficit created by people travelling to other countries. This is not balanced by incoming tourists.

Section 10.5 Employment Effects

Uttlesford currently has a very low rate of unemployment. The non-technical report states that the focus of employment recruitment will be north and east London. Therefore, the majority of the new work force will be travelling to Stansted from London. This will have a direct negative effect on highways, public transport and pollution levels.

Section 10.6 Energy

Section 10.6.7

This point intimates that BAA will ensure ‘there is a commitment at all levels in STAL to positively influence energy consumption’. However, the caveat is ‘at an acceptable financial return’. Renewable energy will be kept under review subject to cost benefits to BAA. This demonstrates that BAA is not committed to reducing climate change emissions unless it has no negative costs to the organisation. This is not consistent with section 9.1.4 of the report, where BAA state they will utilise renewable energy sources to mitigate air craft emissions.

Section 10.10 Surface Access

BAA states that there will be no need for financial investment in infrastructure as there will be ‘minimal’ effect. More than 80% of employees and 65% of passengers arrive at the airport by car or taxi. This trend is unlikely to change given the lack of investment in public transport. This will, based on BAAs own statistics, lead to 3040 more employees travelling by car to work, and 7.8 million passengers travelling to the airport by car or taxi. Even with significant car sharing, this would produce approximately 2 million additional vehicle movements. This does not include deliveries to the airport or ancillary services. This is a significant effect and requires further research concerning road infrastructure.

There are no contingency plans for road traffic accidents on the M11, A14, A505, A120, A10. An accident on any of theses roads may result in Chrishall and neighbouring villages being used as a ‘rat run’ to the airport. Contingency plans must be in place before any agreement is made.

If, as BAA states, there will be no noticeable difference to the road or rail infrastructure, why do they need so many additional parking spaces?

Section 10.10.74 It has been noted that due to the poor railway services between

of 6 Cambridge and Liverpool Street, the Cambridge commuters use Kings Cross service instead because it is quicker despite being a longer journey. The Environmental Statement proposes longer trains between Stansted Airport and Liverpool Street as the solution for airport rail services. The Environmental Statement fails to address the fact that the Liverpool Street line is inadequate for the current volume of passenger transport. The Liverpool Street line would require major investment to cope with the increased passenger numbers identified in the report.

Section 10.11 Third Party Risk

An increase in numbers of aircraft must result in an increase in third party risk. As previously stated, Chrishall is on the flight path for Stansted, Luton, Cambridge, Duxford, military, private jets and helicopters. Again, the cumulative risk to Chrishall and surrounding villages has not been adequately investigated or properly assessed.

Section 10.13 Water

Essex is already the driest county in the UK. The Hadleigh centre has forecast a reduction of 19% in Essex rainfall by 2050 as a consequence of climate change.

BAA maintains that an increase in passenger numbers will have minimal effect on water conditions locally. This contradicts the 2003 environmental impact assessment conducted by Halcrow, undertaken on behalf of DfT, which highlighted water supply as a major environmental issue in relation to Stansted expansion. It concluded that Essex water resources were virtually fully committed without expansion of the airport; that large increases in passenger numbers would significantly increase airport demand for water; that even with supply and demand water management and water saving technology, it may be difficult to meet demand. BAA does not state an intention to utilise water saving technology in the existing or proposed new buildings.

In conclusion, the Generation 1 Environmental Statement appears to pay lip service to the concept of sustainable development but fails to deliver credible and robust solutions to the environmental impacts which the proposed increase in air traffic movement and passenger numbers would undoubtedly create.

Chrishall Parish Council would urge UDC in the strongest possible terms to refuse variation of Condition ATM1, and enforce Condition MPPA1.

Yours sincerely

Belinda Irons Clerk to Chrishall Parish Council