AXO’s comments to Southampton City Council

Re: 19/02021/CONSUL Airport expansion planning application
Since almost all of the harm resulting from expansion is to be borne by residents of Southampton, mostly those living near the airport or under the flight path, we believe the City Council must scrutinise the economic case very closely to determine whether the benefits to the city are in proportion to the costs. We believe they are not. The Council also needs to scrutinise the environmental assessments of the dis-benefits to ensure they have been fully represented in the EIA. We believe they have not. In particular we wish to point out that the economic benefits are assessed on the assumption of 5m passengers per year but the transport assessment is based on only 3m.

ECONOMICS The claimed economic benefits are based on the 2017 report by Steer Davies Gleave (Appendix 6.1). The headline figure of cumulative £18.1bn by 2037 is based on Appendix 6.1, which states (5.8)
“The expansion of air services following the Masterplan is assumed to commence in 2019, at which point the baseline and vision scenarios diverge. A full Masterplan timetable is assumed to be in operation from 2022.”
This is patently not possible since the runway extension cannot be built before 2021. The key graph (Appendix 6.1 figure 5.3) shows a large step change in economic benefit between 2019 and 2022. The underlying passenger numbers on which this is based are not stated but since the top of the “step” takes the economic benefit far above the value for the “Future Baseline” 2037 value based on 3.3mppa this must reflect more passengers than that. The graph on p32 of the Surface Access Strategy https://www.southamptonairport.com/media/4689/surface-access-strategy.pdf has the same shape as figure 5.3 and indicates that the number of passengers in 2022 is assumed to be 3.7m This is simply not credible, firstly because the road network cannot take this number, and secondly because the ES claims that exceeding 3mppa is not possible without terminal building developments, which are unlikely by 2022.

Local economic benefit is unclear: It is not made clear exactly how much of the claimed financial benefit is local to the Solent area rather than UK wide. Employment due to the airport is divided into direct, indirect and induced jobs. 73% of the direct jobs are held by people who live within the Solent LEP area. The assessment of indirect jobs assumes these are created by non-wage spend (total £64m in 2015) by the airport and businesses based on site. It is stated (Appendix 6.1 para 4.6) that only 32% of airport non-wage spend is in the Solent area (see also figure 4.3 for details). Figures for the other businesses, which provide the majority of non-wage spend (ie £54m), are not given. But since para 4.8 states that this was dominated by Flybe, most of whose spend was aircraft-related, it is unlikely that much was local. Appendix 6.1 para 4.6 states that approximately 50% of the airport’s non wage expenditure was on “manufacturing and construction”. (See also figure 4.2, which shows that only half of that spend is local.) Aside from construction work (estimated to last 34 weeks) that would result from the planning application being approved, it is hard to imagine that such a level of expenditure on construction will be maintained.

Induced effects not primarily local: Induced jobs are obtained by using a multiplier (25%) of the direct and indirect jobs. Appendix 6.1 states (4.11):
“Since a majority of employees at the airport campus are resident within the study area (73%), a significant proportion of induced impacts will be experienced within the immediate vicinity of Southampton Airport.”
This is a false assumption because induced jobs are assumed to be 25% of the direct plus indirect jobs – and as previously stated the indirect jobs come from non-wage expenditure, of which local spend is only 32% or less. So the maximum number of local induced jobs must be 25% x [73% x direct jobs plus 32% x
indirect jobs]. We estimate on this basis that the total number of current jobs local to Solent LEP (direct, indirect and induced) is only 1387 of the total 2900 jobs.

Future scenario assumptions are flawed :We also challenge the assumptions on which the future scenarios are based. For the “Future Baseline” scenario, Appendix 6.1 states (5.4)
“Economic activity is assumed to grow proportionately with terminal passenger throughput. For direct impacts, this assumes that there is no increase or decrease in the level of efficiency at the airport through time.”
This seems unlikely as all employers constantly work to increase efficiency, and there will always be economies of scale. The method for estimating extra economic benefit in the “Future Vision” scenario is not stated, but the resulting numbers (para 5.7) suggest that the same assumption has been made.
ES chapter 6 (p24, table 6.5) gives the number of additional jobs predicted under the future scenarios:

Based on the same analysis that we used above for current jobs, we estimate the number of these additional jobs that are local to Solent LEP would be:

This is not a large number of jobs given the land area occupied by the airport. (For comparison, on a much smaller footprint the old Ford site directly employed 4000 local people and the Mountpark site that has replaced it is predicted to employ 1500.) We would also like to point out that previous promises of extra jobs have failed to materialise. The Airport’s 2006 Masterplan promised an additional 537 jobs on top of the existing 1004 by 2015. In fact there were only 950, a net loss of 54.

Most passengers are outbound: The majority of passengers live in the Solent area, and according to the airport’s 2019 Masterplan 78% of flights begin as outbound flights by UK residents rather than by people from outside the region travelling in. ES Appendix 6.1 claims (1.9) that this is important because
“The economic benefits of air travel (particularly for those travelling in the course of business) are largely experienced where the trip itself originated”.
While this is indeed probably true for business travel, we do not believe it is true of non-business travel, where (apart from purchases made at the airport prior to departure) expenditure would generally be in the destination country. Therefore for non-business travel only 22% of passengers are likely to contribute to our local economy through, for example, tourism. The 2006 Masterplan reported that business accounted for 39% of trips, but the latest Masterplan quotes only 29%. Even for business travellers, as airline costs rise (which they must, if any form of carbon-offsetting or carbon credits is introduced), use of other methods such as virtual meetings may become more common.

Demand may not rise as predicted: ES (chapter 8) states that the expansion plans are a response to rising demand. The 2006 Masterplan stated that 2005 passenger numbers were 1.84m a year, and it forecast 3m in 2015 and 6 million in 2030. https://southamptonairport.com/media/1051/Southampton_masterplan_final.pdf
The DFT forecast for current Southampton passengers was 2.66m but the actual figure is 2m. There is no evidence in the data presented that passenger numbers are rising – in fact they have fallen recently. Also ES chapter 6 (paras 6.2.40 and 6.6.20) admits that passenger growth may be optimistic as no account has been taken of Brexit effects nor of the potential development of a third Heathrow runway.
It is more likely that the intention is to stimulate demand by increasing capacity. Even this may be optimistic given recent airline bankruptcies. Flybe has even stated its intention to withdraw from routes that are better served by rail. The Committee on Climate Change has said that we cannot achieve carbon neutrality without restraining aviation, which by 2050 will be the single largest emitting sector in the UK. Leisure trips are far more likely to be sensitive to increases in price or perceptions that flying is environmentally harmful (eg “flight-shaming”).

Economic harm not considered: Finally, the economic assessment contains no reference at all to any dis-benefits such as reductions in price of homes under the flight path. This is important because under the proposed development over 10800 households (25200 people) will be exposed above 54dB LAEQ ,16 hour (ES chapter 11, table 11.3).

TRAFFIC
Alone among the EIAs the Transport assessment is based upon 3m passengers per year. All others – including, crucially, the economic impact assessment – are based upon 5m in order to “assess effects associated with 2037 actual (brought forward to 2027) as a theoretical consequence of the proposed development” (ES Chapter 3, 3.1.4). The Transport scoping report (reproduced in Appendix 8.1 p 65 Appendix A para 3.7.2) promised:
“The scenarios assessed will include the following: Scenario 1: 2019 Baseline Year (assuming 2m passengers), Scenario 2: 2020 Construction … Scenario 3: 2027 Future Year (assuming 5 million passengers to reflect predicted 2037 activity)” (our emphasis).
However the current Transport assessment does not deliver this. ES chapter 5 says (5.4.34)
“The EIA assesses the Proposed Development based upon the following scenarios: … Baseline + Operation of the Proposed Development with 3 million passengers per annum landside and 5 million passengers per annum airside (based upon predicted 2037 Airport activity set out in the SIA Master Plan)…” (our emphasis)
Since it is not credible that 2 million passengers per year can pass through Southampton airport (“airside”) without either embarking or disembarking (“landside”) at Southampton, it is hard to escape the conclusion that these numbers have been chosen because the assessment would otherwise have shown significant impacts on the road network. But basing the transport assessment on 3mppa means that the ES has only studied the impact of the number of passengers estimated by the economic impact assessment (chapter 6) to occur by 2037 without the proposed development taking place!

Modelling assumptions may not occur: The modelling assumptions “Do something (DS3)” are initially based on the DfT Aviation forecast (2013) of 2.66mppa. The modelling scenarios include not only planned highway improvements, but also additional highway mitigation improvements (5.2.13) and improvements to bus services (5.2.14). It is not clear how/whether these improvements will take place, especially since the bus services are run by independent companies and the ES notes (7.6.17) that “investment will be required by rail and bus operators”. Should such investment not be forthcoming, further modal shift away from cars may not take place, and without the infrastructure improvements the figures given in the detailed tables are likely to show bigger changes with the proposed development. Given that four of the studied junctions are already over capacity the claim that airport expansion has little impact must be questioned.

Individual junction issues downplayed: The overall summary of junction modelling ignores some of the individual results, for example (table 7.5) mean queue lengths at the A335 arm of the M27 J5 signalized junction double from 5 to 9 (am peak) and (table 7.6) mean delays (am peak) at the Wide Lane/Bassett Green Rd/Stoneham way signalised junction increase from 172 to 202sec (12% increase). If delays worsen at these over-capacity junctions it is possible drivers will start to use other routes, increasing delays on other approach roads. There is no evidence that the modelling takes account of this.

Assessment does not correctly model “Do Minimum”road usage: Because the proportion of people currently arriving by public transport is higher in reality than the SRTM
model used assumes, ES chapter 8 concludes (8.2.28) that modelling undertaken for the “Do something” scenario at 2.66mppa can be taken to reflect results for 3mppa because this better matches the actual number of arrivals by road. This is then compared with the model run for 2mppa to reflect the “Do Minimum” situation where the runway extension does not take place. However for the same reason, modelling 2mppa actually reflects actual results for a higher number of passengers – therefore this is not a true comparison with the actual number of road vehicles expected under “Do Minimum” scenario and underplays the impact of 3mppa.
In summary, ES chapter 8 has neither assessed the impact of the number of passengers anticipated by the airport’s Masterplan “vision” nor demonstrated that there will not be major impacts on the local road network.

NOISE
ES chapter 11 assesses the impact of aircraft noise in relation to threshold of 57dB, “above which is the onset of “communities becoming significantly annoyed by aircraft noise” (as identified in the Aviation Policy Framework 1982) and 54dB (government survey, 2004).

Large numbers of Southampton residents adversely affected: Already noise affects 3100 people above 57dB LAEQ ,16 hour and 9000 54dB. These numbers are expected to rise significantly to 8,800 and 18,700 respectively by 2021 and 11,900 and 25,200 by 2037 (ES chapter 11, table 11.13). Although most of the rise in number is due to population growth the conclusion of chapter 15 (15.6.8) that this is an increase of only 1.4% in the proportion of residents affected should not be used to obscure the fact that very large numbers of people will be exposed to noise. In addition the number of people exposed above 63dB (currently zero) will be 350 by 2021 and 1550 by 2037 – when there will even be 50 households exposed above 66dB. The airport proposes to offer noise insulation to these latter groups, but this will only help if they wish to stay in their homes with windows closed!

WHO recommendations ignored: The World Health Organisation has found adverse health impacts, especially on children, at aircraft noise levels above 45dB and recommends noise is kept below these levels. 57dB is more than twice as loud as the 45dB recommendation and 66dB is more than four times as loud. ES chapter 15 discusses human health impacts, but simply ignores the WHO evidence on the grounds that “These are recommendations rather than requirements and therefore not used in this assessment.” (15.2.17). While this distinction is clearly relevant to statutory requirements placed upon the airport, it is not grounds for ignoring findings in terms of health impacts, and undermines the conclusion of chapter 11 that noise impacts are not significant. No figures are given for the number of people affected at above 45dB but clearly it will be much larger than the 25200 to be exposed at 54dB.
The impact on those experiencing noise under the flight path is dismissed (chapter 16 para 16.1.14) in comparison with the socio-economic benefits
“… the socio-economic impacts are beneficial in nature and may serve to reduce the negative effects experienced as a result of other impacts. For example, the sensitivity of occupiers in nearby properties experiencing noise impacts may reduce (ie they become more tolerant of environmental noise) in the context of the socio-economic benefits that the proposed development will bring.”
This seems to demand an unrealistic degree of altruism from many thousands of people, few of whom will personally experience these socio-economic benefits. Especially since ES chapter 15 finds (15.6.7) “…the economic effects of the Proposed Development are deemed to be of neutral significance” in the context of human health and (15.6.4) “the magnitude of personal circumstances impacts from the Proposed Development is considered to be negligible.”

CLIMATE
Southampton City Council was among the first to declare a climate emergency and its response to this proposed development is the first opportunity for the Council to show that it intends to put its words into action.
The ES estimates (chapter 13, 13.6.6) that there will be an average annual increase of 350,000t carbon emissions during the operational phase. For comparison, according to BEIS homes and industry in the entire City of Southampton (excluding the port) emitted 534,000t CO2 in 2017 (https://data.gov.uk/dataset/723c243d-2f1a-4d27-8b61-cdb93e5b10ff/emissions-of-carbon-dioxide-for-local-authority-areas). Efforts to reduce Southampton’s carbon emissions as part of the Green City Charter will be undermined by all these extra emissions resulting from the expansion of the airport, a Charter signatory.

Mitigation is not possible: There is no effective mitigation for the GHG emissions associated with the operational phase of the development. Mitigation is confined to the (already negligible) construction phase and to the airport’s own operations. The ES (13.9.2) states its intention to:
“Ensure that the airport’s direct operations become carbon neutral by 2030. Over the project reference lifespan, this is expected to lead to a saving of approximately 65,000 tCO2e.”
This is just 0.15% of the additional operational emissions, which ES 13.6.6 estimates as totalling 42,005,000 tCO2e over the reference lifetime (average 350,000tCO2e).
The ES discusses the impacts of CORSIA, concluding (13.9.4):
“CORSIA is not yet operational, it’s [sic] mechanisms to reduce emissions are uncertain, and its operation isn’t within the control of Southampton International airport.”
Electric planes will only ever be able to replace the smaller aircraft, not the larger jets the runway extension aims to attract, and carbon offsetting projects simply cannot be scaled up to offset all our current flights, let alone more. No airport expansion should take place until such time as genuine mitigation for all these emissions is shown to be feasible. The claim (reference as above) that the presence of a larger local airport will reduce carbon emissions from people driving to other airports is specious, comparing as it does two unsustainable methods of transport and ignoring the possibility of people using public transport or electric vehicles – or even (in the case of many European destinations) travelling to the destination entirely by rail.
ES chapter 13.13.2 states that the extra 350000t CO2 emissions is “moderate negative” but ES Summary (chapter 5) assesses the impact of greenhouse gas emissions to be “substantial” and negative. In Chapter 5 table 5.5 “substantial” is defined as being “generally associated with sites and features of national importance”. Given this, and in the context of climate emergency, airport planning decisions should be part of an overall strategy and not decided on a case-by-case by the local authority in which the airport happens to be sited. As already stated, the Committee on Climate Change has said that we cannot achieve carbon neutrality without restraining aviation.

Error in emissions data: We would also like to point out that the emissions table (table 13.3) states that road traffic contributes 766 ktCO2/year to airport-related emissions, more than half the 1238kt total and more than twice the total emissions due to road transport within Eastleigh Borough itself (289.5kt, table 13.4). No comment is made about this extraordinarily large figure and it is probably an error. That it has gone unnoticed rather undermines credibility of the assessment.

ECOLOGY
Should the development go ahead, the Chickenhall Lane link road to the proposed industrial park would need to be tunnelled under the extended runway. The knock-on effects of this should be considered, specifically the fact that due to the high water table, water will have to be pumped from the tunnel during both construction and use. The River Itchen is the obvious place for disposal of this water. This is seriously problematic given that, being an old railway works site, this water is highly likely to contain contaminants such as asbestos, arsenic and heavy metals. Should this water enter the river it would feed into a site of Special Scientific Interest (SSSI) and the breeding grounds of the Southern Damsel Fly – a protected species than could not be relocated.
ES chapter 9 says (9.6.40)
“The traffic modelling predicts that more than 50 AADT 24 hour traffic change as a result of the Proposed Development alone will occur on roads within 200m of the R. Itchen SAC… Therefore the potential for likely significant effects as a result of the pollution from traffic being added to aircraft pollution… cannot be ruled out.”
Similar comments are made about NOx concentrations (9.6.41) and nitrogen deposition (9.6.42). we have already discussed the likelihood that the transport assessment on which these calculations are based underestimates the impact of the proposed development.

AIR QUALITY
ES chapter 7 says (7.5.23) “The contribution to the total impact resulting from changes to traffic flows is less than that from airport emissions and at all locations. This reflects the fact that the traffic generation due to the proposed development is relatively low … and, with the exception of receptors on Wide Lane to the south of the Airport, the impacts from traffic generation are imperceptible in magnitude.” (our emphasis).
We have already criticised the assessment of traffic for modelling for under-reporting the effects of the proposed development. Therefore the impact on Wide Lane is likely to be worse than claimed.

Airport expansion would undermine Southampton’s efforts to improve air quality: Southampton City Council’s Transport Policy team wrote in October 2018 as part of its comments on the airport Masterplan https://axosouthampton.files.wordpress.com/2019/12/southampton-airport-masterplan-consultation-scc-transport-policy-response-final-oct-2018.pdf (page 5 para 2) :
“SCC is making significant effort to reduce emissions associated with road transport and this should not be viewed as an opportunity to generate further capacity for other sectors” (our emphasis).
Yet in contradiction of this, ES chapter 7 claims (7.5.16) that “… the increase in emissions from the Airport is more than offset by the reduction in emissions from other sources”

Aircraft NOx emissions: Finally, we would also like to point out that ES chapter 7 Table 7.15 shows an almost fourfold increase in total annual emissions from aircraft as a result of the proposed development (from 83.57 tonnes in 2018 to 320.96 tonnes by 2027).

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