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1. Scottish Executive makes the following representations to BAA on the Edinburgh Airport Outline Master Plan. We would be happy to discuss these. This response incorporates comments from Scottish Executive Planning Division, Transport Group (including aviation, roads policy, trunk road construction, trunk road network management, major transport projects), Solicitors and Environment and Rural Affairs Department. We are grateful for the extension to the deadline for representations to enable us to bring these responses together into a single Scottish Executive response for you to consider.
Guidance on the Preparation of Master Plans
Department for Transport / Scottish Executive
2. Department for Transport published jointly with Scottish Executive "Guidance on the Preparation of Airport Master Plans". We have considered whether the outline Master Plan has fulfilled the requirements of the above document, published in July 2004. We have therefore structured our comments in line with the requirements set out there. We have considered the questions posed in the Master Plan, but are of the view that the concerns of Government can better be served by relating our comments to the guidance requirements.
3. Master plans are "a mechanism for airport operators to explain how they propose to take forward the strategic framework in the form of airport-specific proposals". Benefits include:
- an indication of an airport operator's plans for infrastructure development;
- inform long term resource planning for local and regional players;
- make clear at an early stage the key milestones of their development project;
- provide a consistent and publicly recognised vehicle for the Government, Devolved Administrations and their agencies to assess progress being made in delivering the White Paper at each airport;
- demonstrate the range of costs and benefits of airport growth; and
- enable airport operators and others to assess local social and environmental impacts and provide an opportunity to develop preliminary proposals on how those impacts should be mitigated.
4. Master plans should reflect a balanced evidence based approach to airport planning. For development proposals that are likely to be brought forward within the time horizon of strategic land use and transport plans, especially where a significant planning application is expected in the next 5 to 10 years, the White Paper makes clear a fuller treatment is expected. Master plans should address the following core areas:
- infrastructure proposals
- safeguarding and land/property take
- surface access initiatives
- impact on people and the natural environment
- proposals to minimise and mitigate impacts.
5. The extent of coverage should be discussed with a master plan steering group to reach agreement. We note that the draft Master Plan has been prepared totally within the BAA Group environment, and that no Master Plan Steering Group has been involved in its drafting. We would find it helpful, and we would hope beneficial to BAA, if a short series of meetings including Scottish Executive interests could be involved in taking the draft to finalised stage taking into account views received from consultation and other matters such as transport modelling.
6. In appraising the Master Plan we have given particular consideration to the following issues:
Convergence of BAA forecasts with White Paper forecasts, or reasoned justification for differences
7. The White Paper Central Case forecasts showed Edinburgh with an additional runway as achieving between 21.6M and 23.4M passengers in 2030 depending on other assumptions. BAA annual passenger forecasts (millions) are as follows:
8. The conclusion therefore is that BAA forecasts are convergent with Government forecasts. These figures would result in a growth from 104,000 passenger air transport movements in 2004 to 212,700 in 2030, 33 to 63 peak runway movements per hour, and from 29 to between 58 and 69 aircraft stands dependent on aircraft size. Cargo and mail tonnage forecasts go from 56,600 tonnes in 2004 to 106,500 tonnes in 2030.
9. Direct employment at Edinburgh Airport is forecast to grow from 2,300 in 2002 and 3,200 in 2005 to 5,700 in 2013 and 9,000 by 2030.
10. One aspect that has been raised is the assumptions on aircraft size and occupancy at Edinburgh in future forecasts. While the passenger figures are not in dispute, variations in aircraft size and occupancy could result in quite different numbers of aircraft with different characteristics, and therefore affect runway and terminal requirements. Some scenario planning to scope the outer parameters of what could happen would be useful as a basis for discussion. The result would be that the Master Plan would not just be a view based on a central forecast of all the factors, but would be a more robust document fairly accurately based on not only a central case, but illustrating the effects of extremes around that central case. That could give confidence that reality is very unlikely to be outside that range, as distinct from just not knowing.
The nature and timing of BAA airport infrastructure proposals, and their relationship to forecasts taking into account reasonable assumptions on aircraft size, operational characteristics, etc
11. We consider that the Outline Master Plan does not give sufficient precision or clarity to fulfil the objective of informing long term resource planning for local and regional players. While it adopts key dates of 2013, 2020 and 2030, it does not give clarity to key milestones of airport development; in our view more will need to be done to give a consistent and publicly recognised vehicle for stakeholders to assess progress in delivering the White Paper.
12. Closure of runway 12/30 after 2013 was rejected for various reasons including that it would accelerate the need for the new second main runway. The expectation of the White Paper is that runway 12/30 would be closed and land released only once the new second main runway was operational. There is no convincing argument in the draft Master Plan for retaining the land at that stage, which could otherwise potentially contribute to economic development.
13. Sections 9.5 and 9.6 cover aircraft apron and passenger terminal facilities after 2013. While certain arrangements of facilities may need the configuration of land shown on Drawing 5, it is stated that actual configurations could be different. We understand that BAA have working hypotheses which underly these configurations in more detail. This is one example where a Master Plan Steering Group could have aided our understanding of the degree of robustness of the proposals, and been better able to weigh them against other interests. This is for example critical to arguments on land take proposals from the RHASS.
The extent and timing of land/property take in relation to airport infrastructure proposals, arrangements for safeguarding prior to need, and degrees of absolute need for specific land for specific purposes
14. BAA Edinburgh intend to match additional capacity closely to passenger demand in an incremental development pattern. Where demand is faster or slower than forecast, land take may vary from that stated. This has potential implications for the position stated regarding RHASS land, namely that it will not be required before 2013. In particular the 34 hectares required from RHASS land holdings between 2013 and 2020 requires some more detailed consideration. If it goes ahead it renders the Showground unusable as the land indicated includes all the recent high value investments including the main hall. However, if the use for which the land is required could be reconfigured to longer east-west and shallower north-south, RHASS would be prepared to relinquish the land currently their north car park in its entirety; this would have the effect of giving them security of tenure till at least 2020. If this accommodation cannot be reached, then in effect BAA Edinburgh would have to acquire the whole Showground at 2013 or at some agreed date between 2013 and 2020, and RHASS would have to be in a position to take occupation of an operational new site at that date. Lead times make this an issue which has to addressed now.
15. In Chapter 6 on land use in 2013 areas of land are allocated against contingencies even though it is admitted that users have not indicated any demand for facilities. It is for consideration whether this degree of contingency planning is compatible with the expectations of the Master Plan process for a degree of certainty especially where land outside the current boundary may ultimately be required. In other words is it acceptable for land within the boundary to be underutilised while other demands may require acquisition of land outwith the boundary. Again some scenario planning would help understanding here.
16. While we appreciate that after 2013 there must be some uncertainty, we would find it useful to see more detailed land use configurations for different scenarios representing the range of air traffic growth and of its nature for key milestone dates. The ideal solution would be a more robust forecast of demands for cargo, maintenance, ancillaries, etc at 2030, and allocation of land for these uses at that time, with an expectation that development would take place from within-boundary sites to outwith-boundary sites as demand arose.
17. We would also find it useful to have an indication for "ancillary facilities" which are essential for airport operation and what locational parameters there are on those, and which such as hotels are only desirable and may have more flexible locational parameters. There is no justification given for on-airport hotels, and prima facie hotels in the general vicinity with adequate courtesy transfer services would seem acceptable
18. Section 9.4 covers procedures for safeguarding in relation to future development. Maps will be issued based on most likely scenarios, applications will be filtered and developers informed of the situation so that they can decide the risks in developing against future possible land needs by BAA Edinburgh. BAA would subsequently buy out any developments which happen to conflict with subsequent decisions on actual airport development proposals. While any development required at the time of airport expansion would be acquired, and developers would be made aware of the situation when they applied to develop, this does not seem to me to be good planning practice, and seems to stem from a desire not to have to pay compensation or acquire land till the latest possible time. It could be expected that with a robust development plan, BAA would acquire land as it became available, possibly find some temporary use for it, and have it on their books when they need it.
Proposed arrangements for seeking planning approval for airport expansion including attributing operational land status and achieving permitted development and compulsory purchase rights
19. We acknowledge that you intend to apply for planning permission for any aviation use of land currently outside your defined operational land. We would advise you to take legal advice regarding your access to powers for compulsory purchase of land and for entitlement to permitted development rights in respect of operational development on operational land.
20. The process of gaining planning permission for any airport expansion gives the planning authority and its public sector partners in theory a considerable degree of control, including over BAA making financial contributions to necessary infrastructure, for example for surface access enhancements (see below).
Proposed surface access initiatives related to forecasts, with clear relationships derived from mode share targets for airport passenger and staff travel, and setting out BAA contributions to surface access initiatives at different volume and mode share thresholds
21. One of the areas dealt with in some detail in the guidance is surface access, where some emphasis is put on modal split, and on consideration of the extent to which infrastructure and services are shared with users other than airport-related traffic. Appropriate analytical techniques should be used, including if necessary the use of appropriate transport models.
22. Edinburgh Airport Surface Access Strategy (2002) sets mode share targets to 2007. There are no targets set beyond that. This aspect is almost wholly ignored on the basis that the Review of the West Edinburgh Planning Framework land use transport modelling and modelling being done for tram and rail links by tie will pick up these issues and indicate suitable mode shares at different stages of airport development. While there is some benefit in pooling resources and avoiding duplication, it would be useful if BAA could provide on the basis of CAA comparative European data, indications of mode split at comparator airports, with details of the nature of public transport on offer, and of other factors affecting the mode split. The Surface Access Strategy will we understand be reviewed in 2007.
23. If BAA do not propose to do their own modelling, and Scottish Executive acknowledge the access to BAA data already provided, then a contribution to the costs of WEPFR land use transport modelling would be welcome. This could for example be on the basis of funding extra tests based on observed origins and destinations of air passengers leaving from and arriving at the airport, or in respect of modelling specific road links. We also acknowledge the contribution offered of Faber Maunsell involvement in assessing the work of MVA in adapting the Transport Model for Scotland ( TMfS) to this exercise. We are happy to discuss further the basis of BAA involvement in the modelling exercise.
24. The Master Plan also stresses the importance of regional road capacity given the disparate nature of passenger demand and the limited capability of public transport to serve such a geographically dispersed customer base. The road network around the Airport is considered by BAA to be at or approaching its practical capacity at peak times. The issue for BAA Edinburgh is general traffic congestion in its immediate surroundings unconnected with the Airport. The White Paper states that rail and tram together with improvements to the road layout including the possibility of additional access points to the A8 could help to address potential congestion problems in the period to 2013. Beyond 2015 there may be a need to improve the capacity of the strategic road network as well as access from it to the Airport.
25. BAA consultants have proposed a new link to the A8 (the Eastern Access Road) in response to acceptance that most passengers will continue to arrive by car. Timing of a further link direct from the Airport to M8 is to be informed by WEPFR modelling. BAA Edinburgh consider this link is justified by current passenger volumes. Any new road link (or other new transport infrastructure required by BAA) will require to be subjected to Scottish Transport Appraisal Guidance ( STAG) procedures if it requires any approval or funding from Scottish Executive.
26. The Master Plan refers to surface access schemes in an intuitive manner, assuming that any reasonable person would see the case for specific schemes at specific times. This is not sufficiently robust. What will be required is a proper analysis of demand, with robust mode share targets set at the outset based on modelling and benchmarking with comparators across Europe. It is thought that such benchmarking would suggest achievable targets significantly higher than 25% public transport share. Given the obvious geographical constraints on building more roadspace, the higher a public transport mode share the better.
27. Some proper modelling of the implications of different mode shares at different time horizons of airport development taking into account availability of tram and rail at relevant dates is required to assess the overall picture. This will not only demonstrate the issues, problems and solutions, but should demonstrate the extent to which BAA Edinburgh need each element of infrastructure and should therefore be prepared to contribute to it.
28. Reference is made to unspecified ongoing surface access studies and analysis of long-stay car parking demand prior to the final Master Plan. Car parking supply and demand is clearly a significant part of the transport equation and as WEPFR modelling work progresses we should keep parking levels under close and critical scrutiny. These matters should form part of ongoing discussions between Scottish Executive and BAA Edinburgh.
Consideration given to potential impacts on people and the environment and proposals to minimise and mitigate such impacts
29. Chapters 8 and 10 deal with managing external impacts over the period to 2013 and beyond to 2030. A comprehensive range of environmental factors are discussed. However, although both chapters deal with noise, neither makes reference to the EC Environmental Noise Directive. This will require inter alia for noise mapping to be undertaken at Edinburgh, Glasgow and Aberdeen airports for the first time in 2007 and every 5 years thereafter. If the mapping exercise shows that there are noise hot spots thereafter in 2008 and every 5 years thereafter appropriate action plans have to be drawn up. In addition to the requirements explained above any major new development at any of the airports will be subject to an extra mapping and if appropriate action plan process. The way we are implementing the Directive both here and in the rest of the UK will make the airport authorities "competent authority" for both the mapping and action plan aspects. BAA Scotland are well aware of END and indeed commented in our recent END implementation consultation exercise. Therefore reference of END and how it might affect developments at Edinburgh should be inserted at the appropriate points in the text. Can I suggest that this might be best at chapters 3, 8 and 10 but would expect BAA Edinburgh to come up with the appropriate form of words. It would be very useful if thought could be given to making the Master Plan cycle in line with what is required under ENDi.e. every 5 years from 2008 for the Action Plans.
30. There is a gap in the coverage of section 8.7 (Biodiversity). Some legislative requirements seem to be covered but others aren't. One that isn't referred to, but should be is the process under Article 6 of the Habitats Directive to assess potential impacts on Natura 2000 sites. The Conservation (Natural Habitats, &c.) Regulations 1994, which implement the EC Habitats and Birds Directives, place a statutory duty on planning authorities and other competent authorities to meet the requirements of the Habitats Directive. The process is outlined below but a more succinct form of words which acknowledges the requirements of Article 6 of the Habitats Directive should be drafted for the Master Plan.
31. When giving consideration to the issue of any consent or permission associated with a plan or project (either alone or in combination with other plans or projects), and not directly connected with the management of a Natura site, all competent authorities must seek the views of the statutory nature conservation adviser to Government (Scottish Natural Heritage) on whether the proposed consent/permission would result in a likely significant effect on Natura interests (Designated Natura sites, European Protected Species ( EPS) or effects on wider conservation status within a species/habitat's natural range).
32. If the advice is that there is likely to be a significant detrimental effect, then an appropriate assessment will need to be undertaken by the competent authority responsible for issuing consent/permission, although it is usual for the competent authority to request the necessary information from the applicant. SNH will be able to provide guidance on what the appropriate assessment should encompass (essentially often a tailored EIA). At this stage the competent authority may also choose to seek the opinion of the general public.
33. If the appropriate assessment is unable to determine that there will not be a damaging effect on the integrity of a Natura site and its conservation interests, then the competent authority must demonstrate that there are no alternatives that would allow the development to take place without, or with less, damage to the Natura interests. There are also licensing implications where the disturbance of EPS or other species protected under the Wildlife & Countryside Act 1981 may occur.
34. If there is no alternative then the competent authority must prove that there are imperative reasons of overriding public interest that warrant consent for the development to take place. These can be of a social or economic nature, except where a site has been designated for a European priority habitat or species. If a priority interest is involved, then consent cannot be legally issued unless the development is overriding for reasons such as public health or safety, or for other reasons that the European Commission consider justifying (written request necessary).
35. If all of the above can be justified, and the development is to take place, with resulting damaging effects on a Natura site, then the Member State must ensure that compensatory measures are taken to ensure the overall coherence of the Natura network is protected. This may consist of recreating habitat on a new or enlarged site, improving habitat on part of the site or another Natura site proportional to the loss due to the development, or in exceptional cases, proposing a new site.
36. Because the Directive requires the protection of the interests for which the area has been designated, the need for appropriate assessment extends to proposed developments outwith the boundary of the designated area (if this is what is required). Therefore, the assertion in para 8.7.4 (that the nearest designated site is 5 km away) is irrelevant.
37. The statement that the "Forth Estuary…has been assessed by the Government as being at low risk from aviation activities" seems odd to me and its insertion in this section (and in this context) might be wrongly interpreted as adequately dealing with the requirements outlined above for any plans or projects relating to Edinburgh airport. It should not be taken as inferring that, and it may be better to rethink this whole section to convey the necessary requirements.
38. Public Safety Zones relative to runway 06/24 are drawn up based on 2015 traffic projections. There are no PSZs related to cross-runway 12/30 as this runway is not used intensively enough to warrant this form of protection. These facts raise three issues:
- Should PSZs for runway 06/24 be updated either for revised forecasts for 2015 and/or for forecast 2030 traffic levels;
- Should runway 12/30 have PSZs prepared on the basis of its more intensive planned use between now and a second main runway being built post 2020;
- Should PSZs be created and used in respect of the planned second runway to avoid any sensitive development taking place in the meantime.
39. We would be happy to discuss any of these points further with you at the series of meetings referred to above.
Planning Division 4
Scottish Executive Development Department