By Email
Mr Michael Boniface Msc MRTP
The Planning Inspectorate
3/J Kite Wing
Temple Quay House
2 The Square
BS1 6PN 25 September 2020
Dear Mr Boniface

Application Reference: UTT/08/0460/FUL Manchester Airports Group’s plans for development at Stansted Airport including increasing the cap on passenger numbers

Your Ref: APP/C1570/W/20/3256619

I am writing on behalf of the Bishop’s Stortford Civic Federation about this appeal.

The Bishop’s Stortford Civic Federation is a registered charity. It was established as a partnership between the former Bishop’s Stortford Civic Society and the active residents’ associations in the town, particularly to make representations to the relevant authorities about development proposals affecting the town, or large parts of it, which extended beyond the remit of any individual member association. Each member association is entitled to nominate a representative on the committee of the Federation, and we estimate that, collectively, they represent some 7500 households.

This appeal by the Manchester Airports Group (MAG) against refusal of permission to expand Stansted Airport is just the sort of issue about which the Civic Federation was established to comment on. Bishop’s Stortford is the largest settlement, with a population of around 40,000, close to Stansted Airport. Whatever economic benefits it may bring to the local community, we are also the town which suffers most from its adverse impacts, including noise, air pollution (from both aircraft and additional local road traffic), traffic congestion, off site fly parking and pressure on local infrastructure such as housing, school places, public transport services, and medical facilities.

But, because we are over the border in East Herts, rather than in Uttlesford and Essex, the local planning authority had no duty to take our concerns into account and no power to require mitigation of the adverse effects of airport expansion on our town. We therefore asked for the application to be called in for national determination, but this was resisted by MAG, the local planning authority and the Secretary of State. It is disappointing therefore that MAG, having achieved the manner of determination it desired by means of a local authority decision, has chosen to appeal because it did not like the result. It does, however, mean that should you be minded to uphold the appeal, you will at least be in a position to require mitigation of some of the adverse impacts as they affect Bishop’s Stortford.

However, we hope that you will recommend that the appeal should be turned down. The impact of the Covid-19 pandemic has been devastating on the airline industry. Informed commentators have suggested that traffic will not return to 2019 levels for 3 or 4 years and some, including the recently appointed Chief Executive of British Airways, have suggested that the business may never fully return to pre pandemic levels. At Stansted itself, Easyjet, the airport’s second largest customer, has decided to close its base there (although it will still fly to the airport from other destinations).

Even before the pandemic, the application to increase the cap on passenger numbers was premature. The existing cap of 35 million passengers per year (mppa) exceeded the peak thoughput achieved at the airport by 6 mppa. We do not know by how much traffic will have fallen by the end of this year, but it is likely to leave a huge amount of headroom within the existing passenger numbers cap. MAG say that they are not requesting an increase in the cap on air transport movements (atms) but acknowledged in their own evidence that, with current load factors, they are unable to use the limit on atms in full. Raising the cap on passenger numbers would allow them to operate an extra 25,000 flights a year compared with the effective cap on flights brought about by the existing limit on passenger numbers. Compared to the baseline year of 2016 which MAG used in their application, exercising the new passenger limit in full would lead to a 77% increase in passengers and a 52% in crease in flights.

MAG are reluctant to acknowledge the impact of their activities on climate change, and look only at the effect of the operations of the airport itself rather than of the airlines which use it. However, in the case of Heathrow expansion, the High Court has ruled, and the Government has said it will not challenge, the verdict that the long term target for greenhouse gas reduction must take account of the impact of aviation on the ability to achieve it. MAG’s appeal plainly does not do so.

We therefore believe no need has been demonstrated to lift the cap on passenger numbers at the present time, and that to do so would send the wrong signal to the aviation industry about the impact it is having on climate change (and quite possibly the spread of the pandemic as well). We hope therefore that you will recommend that this appeal is turned down.

If however, the appeal is upheld, then, having regard to the adverse impact on Bishop’s Stortford, we hope that you will recommend conditions which will:

Achieve effective controls on airport related parking in Bishop’s Stortford.
Extend the boundaries to which noise insulation grants will apply.
Open more of the airport facilities for parking for rail commuters, (so that they rail head at the airport rather than Bishop’s Stortford).
Reduce and eventually eliminate night flights.
Yours sincerely

John Rhodes