APPLICATION BY ROXHILL (KEGWORTH) LTD

THE EAST MIDLANDS GATEWAY STRATEGIC RAIL FREIGHT INTERCHANGE

- PINS Ref: TR050002

THE EXAMINING AUTHORITY’S FIRST WRITTEN QUESTIONS AND

REQUESTS FOR INFORMATION

WRITTEN REPRESENTATION AND RESPONSE ON BEHALF OF EAST

MIDLANDS AIRPORT – REF 10030207 - TO QUESTIONS 7.1, 7.2, & 7.3

Date: 05 March 2015

Table of Contents

1. Summary

2. Background & Introduction

3. East Midlands Airport

4. Question 7.1 – Aerodrome Safeguarding

5. Question 7.2 – Road Traffic

6. Question 7.3 - Public Transport Strategy

7. Conclusions

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1. SUMMARY

1.1 This document is submitted to assist the Examination of an application for a

Development Consent Order for the East Midlands Gateway Rail Freight

Interchange. This submission sets out the written representations made on behalf of

East Midlands Airport. It also seeks to address the Examining Authority’s written

questions and requests for information issued on 19th January 2015.

1.2 Questions 7.1, 7.2 and 7.3 specifically relate to East Midlands Airport.

1.3 East Midlands Airport have been accepted as an ‘Interested Party’ under the

Planning Act 2008 (as amended) and the Infrastructure Planning (Examination

Procedure) Rules 2010 (as amended)

1.4 A Statement of Common Ground (SOCG) has been prepared and agreed between

East Midlands Airport Limited and Roxhill Developments (Kegworth) Limited (the

Applicant). This Statement of Common Ground (dated 18th February) sets out the

areas of agreement between the two parties and has been submitted to the

Examination.

1.5 East Midlands is an important UK airport and in 2014 handled 4.5 million

passengers and 309,000 tonnes of cargo. The Airport plays a national role as the

UK’s largest express air freight hub as well as being a key regional airport serving

the East Midlands and parts of the East of England. The Airport makes a significant

contribution to the regional economy, with 6,730 people working on the site and

an annual contribution of £239m of regional GVA.

1.6 The Airport is forecast to grow substantially over the next 20 – 25 years and it has

the capability to handle 10 million passengers and 1.2 million tonnes of cargo a

year. The Airport’s forecasts are in line with those published by the Department for

Transport. The Airport’s development is also supported in national and in emerging

local planning policy.

1.7 The Airport is an officially safeguarded aerodrome. Aerodrome safeguarding is to

protect the safe operations of the aerodrome from developments in the vicinity. A

detailed safeguarding assessment has been undertaken to identify potential risks to

the Airport operation from the development of the East Midlands Gateway Strategic

Rail Freight Interchange (SRFI). A condition or protective provision must require the

preparation and agreement by East Midlands Airport (as the statutory Aerodrome

Safeguarding Authority) of a construction management strategy and the detailed

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landscape and drainage design (including proposed planting schedule) that

satisfies all the Airport’s safeguarding requirements.

1.8 The SRFI development is predicted to generate a large amount of car and HGV

trips that if unmitigated would have a significant and adverse road traffic impact in

the Airport and the local area. Therefore the SRFI development proposes

substantial works on the local road network. The Airport has concerns about the

assumptions made in the modelling of the future traffic impact of the SRFI

development in relation to the future growth of the Airport. The strategic traffic

model underestimates future Airport road traffic. A Sensitivity Test that includes

increased Airport traffic has been undertaken, but the Airport Company maintain

that it still underestimates Airport traffic, particularly in relation to the consented

development at the Pegasus Business Park. The traffic modelling should be

properly representative of the SRFI development and future developments

(including the Airport) in the local area.

1.9 A programme of improvements to the public transport network in the local area

has been included within the application documents. The Airport along with

partners has worked to develop a high quality (Skylink) bus network that serves the

main centres in the region. It is important that the proposed improvements to the

public transport network contribute positively to its development, avoid competing

with existing services and have a robust support and funding process in place.

1.10 It is important that the economic and employment opportunities presented by both

the growth of the Airport and the SRFI are secured for the local area and the region

as a whole and the development and operation of either development does not

compromise or impose restriction on the growth and development of the other.

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2. BACKGROUND & INTRODICTION

2.1 The primary areas of focus for East Midlands Airport in relation to the proposed

East Midlands Gateway Strategic Rail Freight Interchange (SRFI) are:

Aerodrome Safeguarding

Highways and Access

Public Transport

2.2 The proposed development and the application for a Development Consent Order

is for a SRFI and highway related development. The development is generally

referred to as the East Midlands Gateway. It is a Rail Freight Interchange, along

with associated highway works, railway works and large-scale storage and

distribution facilities. The proposals include:

An intermodal freight terminal accommodating up to16 trains a day and

trains up to 775m long including container storage and HGV parking

Up to 557,414 square metres of rail served warehousing and ancillary

service buildings

A new railway line connecting the SRFI to the Castle Donington Branch rail-

freight line

New road infrastructure and works to the existing road network

Demolition of existing buildings and structures and earthworks to create

development plots and the internal landscaping works

Structural perimeter landscaping and open-space, including alterations to

public rights of way and the creation of new publicly accessible open areas

A bus interchange to serve the development

2.3 The SRFI site is located on land that is immediately to the north of East Midlands

Airport, to the east of Castle Donington, south of Hemington and Lockington and

west of Junction 24 of the M1. The A453 forms the eastern boundary of the site.

The application site area is some 336 hectares. Some 27 hectares of this land are

currently within the Airport’s ownership and discussions are ongoing with the

Applicant.

2.4 The strategic road network is in close proximity to the SRFI site. This includes the

M1, Junctions 24 and 23A of the motorway, the A453, the A50, and the A42.

There are also local roads within Castle Donington and Kegworth and the A453

(under the control of Leicestershire County Council) forms the Airport’s southern

boundary. The majority of the Airport’s traffic (passenger, cargo, and staff) access

the Airport site from M1 Junction 23A and the A453. The Airport is a 24 hour

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operation and its accessibility is critical to its activity, its business and its existing

and future role in the UK’s aviation system.

2.5 The location of the Airport and the SRFI is strategically significant in relation to the

UK’s road network. Highway and transport infrastructure developments have been

proposed as part of the SRFI development to provide an access to the site and to

mitigate its impact on the transport network, local businesses, airport activity and

the community.

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3. EAST MIDLANDS AIRPORT

3.1 East Midlands Airport was developed by the County Councils of Leicestershire,

Nottinghamshire and Derbyshire and the city councils of Derby and Nottingham,

and it opened in 1965. Passenger traffic has grown over the years and a range of

extensions and improvements have been made to the Airport’s facilities. East

Midlands Airport is:

The 11th busiest passenger airport in the UK handling 4,508,00000

passengers in 2014

The UK’s largest pure cargo airport handling 309,000 tonnes in 2014

and the 15th largest cargo airport in Europe

The UK’s major air mail hub

The UK’s largest airport for express freight, with three of the major global

integrated freight airlines based at the Airport (DHL, UPS, TNT)

A significant local employment site

3.2 Aviation and the transport of passengers and goods is of national significance and

economic importance. The Airport provides international connectivity for the East

Midlands region and a wide range of leisure destinations. The global air freight

connectivity that the Airport provides is of national importance. In terms of UK

airport cargo throughput, East Midlands is the second busiest airport after London

Heathrow.

3.3 The Airport is in a strategic location in the centre of the UK with direct access on to

the national motorway system. The Airport’s location and its accessibility is an

essential element of its efficient operation and future growth

3.4 The Airport’s Operational Area extends to some 445 hectares of land. The site is

broadly rectangular, bounded by Donington Park to the west, the M1 motorway to

the east, filed to the north and the A453 to the south. The application site for the

SRFI is immediately adjacent to the Airport’s northern boundary.

3.5 The Airport site has a number of functional zones; the largest is the airfield with the

2,893m runway and clear areas for the runway’s protected surfaces; the Central

Passenger Zone contains the terminal and passenger apron; Cargo West the site of

the DHL Hub facility; Cargo East; the Aircraft Maintenance Zone; and the Pegasus

Business Park is in the eastern part of the site.

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3.6 Details of the Airport site and future developments are included in the Airport’s

Land Use Plan1 that is part of its Sustainable Development Plan.2

3.7 Aviation is a major driver of economic growth and East Midlands Airport makes a

significant contribution to the regional economy, particularly to Nottingham,

Leicester and Derby and to the district of North West Leicestershire. The Airport is

estimated to generate some £239m of GVA each year.

3.8 The Airport provides an important stimulus to the local and the regional economy.

The economic impacts of the Airport can be categorised as:

Direct employment and GVA – Employment and GVA that is wholly or

largely related to the operation of the Airport and generated within the

Operational Area or the immediate vicinity. This includes the Airport

Company, airlines, handling agents, control authorities, cargo operators,

hotels and on-site offices (including the Pegasus Business Park).

Indirect employment and GVA – Employment and GVA that is generated in

the chain of suppliers of goods and services to the direct businesses in the

Operational Area. This may include utilities, retailing, advertising, cleaning,

business services and construction.

Induced employment and GVA – Employment and GVA that is generated by

the spending of incomes that have been earned in the direct and indirect

activities.

Regional Economic Impact of East Midlands Airport in 20113

East Midlands Airport in the East Midlands

Region

Gross Value Added Impacts

Direct On-Site £153m

Direct Off-Site £0

Direct Total £153m

Indirect £43m

Induced £43m

Regional Impact £239m

1 Draft Land Use Plan. East Midlands Airport. March 2014

2 Draft Sustainable Development Plan. East Midlands Airport. March 2014 (includes a Community Plan, Economy & Surface Access

Plan, Environment Plan and Land Use Plan 3 The Economic Impact of M.A.G Airports. York Aviation LLP. 2011

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3.9 The Airport is a significant employment site (and the largest single employment site

in Leicestershire), with 6,7304 jobs, in 90 companies on the site in 2013. Airport

employees live in the local area with 42% living in Derbyshire, 23% in

Leicestershire and 23% in Nottinghamshire. An education and employment

programme is in place at the Airport that is being developed to target the benefits

of local employment and the support the site’s future workforce. The Airport

Academy has been developed to provide pre-employment training and a

recruitment service for local job-seekers and on-site employers.

3.10 The Airport prepares forecasts of future passenger, cargo and aircraft activity.

These provide a guide to the anticipated future scale of the Airport and its activity.

The Airport’s latest forecasts are included in its Sustainable Development Plan5. The

forecasts show that East Midlands Airport could achieve a passenger throughput of

10 million passengers a year in the period 2030 – 2040. This is in line with

national air traffic forecasts prepared by the Department for Transport and it is a

relatively cautious forecast with a combined annual growth rate of 3.4% over the

period 2013 – 2040.

3.11 The Airport’s cargo forecasts assumes continued growth in the UK’s total air freight

demand growing from 2.3 million tonnes in 2012 to 4.4 million tonnes by 2040, a

combined annual growth rate of 2.3%. The forecast cargo throughput at East

Midlands Airport is for 618,000 tonnes in 2035 and 700,000 tonnes in 2040.

3.12 There is national and local policy support for aviation growth at the Airport. The

principal statement of national airport policy is set out in the Aviation Policy

Framework6. This replaced the Future of Air Transport White Paper7. The Future of

Air Transport White Paper recognised that the provision of adequate airport

infrastructure and capacity is important for national competitiveness, regional

development and for people’s ability to travel, quickly, easily and affordably. The

2003 White Paper also recognised the particular importance of air freight to the

national and regional economy and East Midlands Airport as the centre of these

operations. The White Paper supported the projected expansion of the air freight

activity, subject to the continued environmental controls.

3.13 The Aviation Policy Framework continues recognises the benefits of aviation and

sets a primary objective to achieve long-term economic growth. As aviation is a

4 Draft Economy & Surface Access Plan. East Midlands Airport. March 2014

5 Draft Sustainable Development Plan. East Midlands Airport. March 2014

6 Aviation Policy Framework. Department for Transport. March 2013

7 The Future of Air Transport white Paper. Department for Transport. December 2003

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major contributor to the economy its growth is supported in a framework that

maintains a balance between aviation benefits and costs; particularly the

contribution towards climate change and noise.

3.14 The other main objectives in the Aviation Policy Framework are to ensure that the

UK’s air links continue to make it one of the best connected countries in the world;

to ensure that the aviation industry makes a significant and cost-effective

contribution towards reducing global emissions; to limit and where possible reduce

the number of people significantly affected by aircraft noise; and to encourage the

aviation industry and local stakeholders to streamline the ways that they work

together.

3.15 The 2003 White Paper and its successor the 2013 Aviation Policy Framework,

recommends that airport operators continue to prepare master plans that set out

the long-term growth and development requirements for the airport. The master

plan does not have statutory status, but the Aviation Policy Framework makes it

clear that they should enable the future development of the airport to be

considered in local plans, to provide transparency and to contribute to the plans of

others. The Draft East Midlands Airport Sustainable Development Plan was

published for public consultation in March 2014 the final version of the

Sustainable Development Plan will be published in March 2015. There is support

for the growth and development across the East Midlands Region and the

economic impact of the Airport contributes to the delivery of the Strategic

Economic Plans developed by the two Local Enterprise Partnerships.

3.16 The Government has appointed Sir Howard Davies to lead a rigorous and

independent review of the options, scale and timing of any requirements for

additional capacity to maintain the UK’s status as Europe’s most important aviation

hub. The Commission is scheduled to submit its Final Report in the summer of

2015. The Commission’s interim report in December 20138 identified options for

additional runway capacity in the South East. It also recognised East Midlands

Airport as the UK’s busiest cargo airport after Heathrow.

3.17 East Midlands Airport and its surrounding area have been identified as a unique

central location for air passenger, air cargo, rail and road transport and their key

support activities. Although the Airport and the East Midlands Gateway SRFI are in

Leicestershire, they are in close proximity to Nottinghamshire and Derbyshire. All

three counties benefit economically from this area. The area of the Airport and its

8 Airports Commission; Interim Report. December 2013

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immediate surroundings (including the East Midlands Gateway SRFI, Donington

Park and the East Midlands Distribution Centre) is identified as one of five growth

areas in the Leicester and Leicestershire Enterprise Partnership’s (LLEP) Strategic

Economic Plan (East Midlands Enterprise Gateway)9. In respect of ’Place’ the LLEP

Strategic Economic Plan aims:

‘To invest in key development sites and connectivity to enable the efficient

transportation of people and goods.’

3.18 The LLEP’s Strategic Economic Plan identifies four Transformational Priorities. The

East Midlands Gateway SRFI is within the growth area, that includes the Airport and

it is one of the four Transformational Priorities that are intended to deliver new jobs

and drive economic growth.

3.19 The D2N2 Local Enterprise Partnership area covers Derby, Derbyshire, Nottingham

and Nottinghamshire. The D2N2 Strategic Economic Plan10 recognises that

economic, transport and housing infrastructure is fundamental to its economic

performance. In relation to the Airport the D2N2 Strategic Plan states:

‘East Midlands Airport (EMA), located just 15 miles from the centres of

Nottingham, Derby, is the UK’s 2nd largest air freight hub after Heathrow and is a

critical economic driver for the region.’

3.20 The Airport site is within the District of North West Leicestershire. The North West

Leicestershire Local Plan was adopted in 200211 and set out the planning policies

for the local area. In general terms, the Local Plan supported the growth of the

Airport and identified an Operational Area on the Plan’s Proposals Map to

accommodate growth with major development being directed towards the Central

Passenger Zone and the Pegasus Business Park.

3.21 The Local Plan also sought to develop the Airport’s public transport links and to

manage the impact of the Airport on the local highway network. It also included

policies to control development that could affect the operational integrity or safety

of the Airport, including proposals for wind turbines or developments that may

cause a bird strike hazard.. Although North West Leicestershire District Council is

preparing a Local Plan Core Strategy, there are several ‘saved policies’ from the

North West Leicestershire Local Plan. In relation to the Airport, these are Policy T19

9 Leicester and Leicestershire Strategic Economic Plan. Leicester and Leicestershire Enterprise Partnership. December 2013

10 Strategic Economic Plan. The D2N2 Local Enterprise Partnership. March 2014

11 North West Leicestershire Local Plan Written Statement. North West Leicestershire District Council. August 2002

10

East Midlands Airport – Public Safety Zones and T20 East Midlands Airport –

Airport Safeguarding.

3.22 The North West Leicestershire Core Strategy which was to partly replace the 2002

Local Plan was submitted in June 2013. However following advice from the

Planning Inspectorate the Council agreed to withdraw the Core Strategy (for

reasons of the approach to housing issues and the associated housing evidence

base) and the Council is now working on revised proposals. The Draft Local Plan

Core Strategy (2013) recognised the national significance of East Midlands Airport

for its passenger and cargo services, but that there is also the potential for global

and local environmental concerns that need to be addressed.

3.23 The Local Plan Core Strategy included a number of Strategic Objectives that were

intended to respond to the key challenges facing the District. Those related to the

operation and development of the Airport were:

‘Improve economic prosperity and employment opportunities.

Provide for the growth of passenger and freight operations at East

Midlands Airport having regard to improving access by sustainable travel

modes and impact on the environment.’

The Draft Local Plan Core Strategy also included policy in relation to the operation

and development of the Airport (Policy CS3):

‘The Council will provide for the operational growth of East Midlands Airport,

whilst having regard to its impact on local communities and the wider environment,

and the need to increase the number of employees and visitors travelling to the

Airport by means other than private cars;’

3.23 East Midlands Airport is an important regional asset and plays a national role with

the operation of its cargo services. The Airport has the capability for substantial

growth and development and this is supported in both national and local planning

and economic policy.

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4. QUESTION 7.1 - AERODROME SAFEGUARDING

4.1 The question is:

4.2 ‘The relevant representation from the MAG states that unmitigated, the SRFI

development would result in an unacceptable risk to the safe operation of aircraft

at East Midlands Airport. Please set out what mitigation additional to that set out in

the ES the airport operator is seeking.’

4.3 The Air Navigation Order requires that in the United Kingdom, most flights for the

public transport of passengers take place at a licensed of Government / Civil

Aviation Authority (CAA) aerodrome. Aerodromes are licensed by the CAA and this

process reflects the Standards and Recommended Practices of Annex 14 to the

Convention on International Civil Aviation to which the UK a signatory. East

Midlands Airport holds a Public Use Licence issued by the CAA.12

4.4 The Aerodrome Licence requires that the aerodrome is safe for use by aircraft

taking account of the physical characteristics of the aerodrome and its surrounding

area. The protection of the safe operation of the aerodrome and aircraft at or in

the vicinity is referred to as safeguarding.13

4.5 Because of its importance to the national air traffic system, East Midlands Airport is

an officially safeguarded aerodrome. This is to protect the Airport’s safe and

efficient operation from potentially hazardous development and activity at the

Airport and in the surrounding area. Legislative provisions regarding the

safeguarding process are set out in the Town and Country Planning (Safeguarding

Aerodromes, Technical Sites and Military Explosives Storage Areas) Direction 2002

(ODPM Circular 1/2003). In accordance with this Circular, East Midlands Airport

is a statutory consultee on all planning applications for developments that require

safeguarding to protect the Airport’s operation. Safeguarding maps (which are

issued to Local Planning Authorities by the Civil Aviation Authority) show the extent

of the safeguarded (approximately 13 kilometres for tall structures and bird strike

hazards) area and set out the requirements for statutory consultation with the

Airport.

4.6 Aerodrome safeguarding includes:

The protection of an aerodrome’s Obstacle Limitation Surfaces

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Details of the Aerodrome Licensing process are set out in CAP 168 Licensing of Aerodromes – UK Civil Aviation Authority 13

Details of the Aerodrome Safeguarding process are set out in CAP 738 Safeguarding of Aerodromes – UK Civil Aviation Authority

12

Protection of an aerodrome’s Air Traffic Control and communication

systems

Protection from developments in the vicinity that have the potential to

attract or increase the levels of bird activity in the local area

Protection from developments or activities that could confuse or distract

pilots flying to or from the aerodrome or operating in the surrounding area

Other aviation activity

Use of cranes and other temporary tall structures

4.7 In the vicinity of a licensed UK aerodrome there are a series of protected surfaces

that must not be penetrated by obstacles or other structures. Because of the

limitations on obstacles there are areas of the surrounding airspace that are

integral parts of the aerodrome environment. The protection of the obstacle

limitation surfaces is as important in the grant and retention of an aerodrome

licence as the physical requirements of the runways and adjacent strips. The

protected surfaces are determined in accordance with CAP 232 – Aerodrome

Survey.

4.8 The method of assessing the significance of any existing or proposed object within

the aerodrome boundary or in the vicinity of the aerodrome is to establish defined

obstacle limitation surfaces particular to a runway and its intended use. Initial

safeguarding discussions have taken place with the Applicant and the buildings of

the size and location shown on the Parameters Plan (Doc 2.10A-C) have been

assessed in relation to the obstacle limitation surfaces at East Midlands Airport.

These buildings have been found not to penetrate any of the aerodrome’s

protected surfaces.

4.9 It is anticipated that cranes and tall construction plant will be utilised during the

construction of the SRFI development. The risks from cranes and tall equipment are

addressed in Part 5 of the Construction Management Statement. However in order

to ensure compliance with regulatory documentation, a method of crane approval

will need to be agreed and instigated between the Applicant and the Airport. The

Aerodrome Safeguarding Strategy should include a process for Obstacle Limitation

Survey analysis and the issuing of Crane Permits undertaken by a qualified

safeguarding representative at East Midlands Airport.

4.10 Major development such as the SRFI has the potential to increase the bird hazard

and the bird strike risk at a location immediately adjacent to the Airport’s runway.

This will require mitigation and active management of the bird strike hazard to

remove features that have the potential to attract birds; the management of

earthworks and the elimination of any standing water on the site; the development

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of passive measures to deter birds on the site; the control of ponding and surface

water; the design of landscaping, new habitats, site management and house-

keeping; active bird monitoring and dispersal. This has formed the basis of the

safeguarding strategy. The control of bird activity at a major construction site

adjacent to an active airport requires active, comprehensive and co-ordinated bird

hazard management. This is an important safety requirement as part of the

construction phase of the development.

4.11 The potential bird strike risks associated with the construction of the SRFI can be

summarised as:

Works Phase Potential Bird

Attraction

Species Likely to

be Attracted

Likely Severity

Earth moving,

regarding,

consolidation,

cultivation and re-

seeding

Opportunity for

feeding, resting and

roosting for flocking

open-country

species normally

deterred by long

grass. A refuge from

airfield bird control

measures.

Exposure of insects,

earthworms etc. to

feeding birds.

Food discarded by

contractors.

Ponding.

Lapwings, golden

plovers, gulls.

Corvids, gulls and

possibly starlings.

Corvids and gulls.

Mallard, terrestrial

birds, particularly

woodpigeons

May be very severe.

Local and short-term

(hours after excavation).

Daylight hours only.

Typically a low-level

nuisance, but may

escalate to moderately

severe if site house-

keeping is lax.

Dependent on area and

duration of ponding.

Mallard may breed

where persistent

ponding occurs, even if

the areas are small.

Mallard are moderate to

low strike frequency but

a high damage risk

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species.

Re-seeding Availability of grass

seed to birds.

Stock doves and

feral pigeons,

possibly

woodpigeon and

collared dove.

Linnet, house

sparrows and other

small seed feeders.

Short-term (a few days)

but may be widespread.

Initial stages of

grass growth or

weed growth on

exposed soil

Opportunity for

feeding, resting and

roosting for flocking

open-country

species normally

deterred by long

grass. A refuge from

airfield bird control

measures.

Lapwings, golden

plovers, gulls.

May be very severe (see

below).

Subsequent to the

above

Establishment of

undesirable weed

species, including

germination of weed

seeds contained in

topsoil, providing

food to herbivorous

species.

Persistent ponding,

SuDS and water-

features.

Woodpigeon,

stock dove,

partridge, finches.

Mallard and

terrestrial species –

see above.

Potentially widespread

and persistent, and

medium to long-term

(months to indefinite), by

day only.

See comments re

ponding above.

4.12 A detailed risk assessment by bird species has been provided to the Applicant.

4.13 Detailed bird mitigation must be provided in respect of this development. This

mitigation must include:

Passive deterrents

The control of ponding

Site housekeeping rules and procedures

Active bird monitoring and dispersal

4.14 It is highly likely or near certain that the construction phase of the SRFI

development will increase the bird-strike hazard at East Midlands Airport unless the

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risks are anticipated and the necessary means to minimise these risks are put in

place. No single strategy is appropriate, and a combination of close monitoring,

passive deterrence, control of ponding, site rules and active detection and dispersal

of birds from the site (the latter closely co-ordinated with the Airport’s Bird Control

team) will be necessary. Some birds are susceptible to passive deterrents in the

short-term, but these need to be varied and reinforced, and their effectiveness

monitored closely. No viable passive deterrent that can be deployed near an

airport, other than properly deployed Line of Sight interference systems deployed

against lapwings and golden plovers are likely to be effective for more than a few

days.

4.15 A detailed condition or protective provision will be required for the development of

a detailed bird hazard management plan to protect the safe operation of East

Midlands Airport. This bird hazard management plan must be agreed with East

Midlands Airport as the statutory safeguarding authority.

4.16 The development site lies in close proximity to essential airport navigation and

communication aids. As a result of this an aerodrome safeguarding assessment

must be undertaken of all on-site electro-magnetic sources. These are expected to

be predominantly radio communication equipment and GPRS/GSM survey

equipment. It is important that there is no interference with essential aviation

systems. The requirement for such assessments and their approval by the

Aerodrome Safeguarding Authority for East Midlands Airport must be included

within the aerodrome safeguarding conditions or protective provisions for the SRFI

development.

4.17 There will be numerous activities associated with the SRFI development that will

require notification to the wider aviation community. These include, but not limited

to crane operations, wildlife activity warnings, special lighting information,

frequency amendments and temporary operating instructions. There may also be a

requirement for a variety of safeguarding assessments for other construction

activities. These could include, but not limited to site lighting, emergency response

and foreign object debris. The requirement for such assessments and their approval

should be included within the aerodrome safeguarding conditions or protective

provisions for the SRFI development.

4.18 A detailed construction management strategy that addresses all the aerodrome

safeguarding requirements of East Midlands Airport is required. Initial discussions

have been held with the Applicant and a condition or a protective provision is

16

required to ensure that the Applicant complies with the construction management

strategy and addresses all of the Airport’s safeguarding requirements.

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5. QUESTION 7.2 – ROAD TRAFFIC

5.1 The question is:

5.2 ‘The relevant representation from the MAG concerning East Midlands Airport states

that the outputs from the road traffic modelling and assessment of future junction

and link capacity are not agreed. Please provide detailed appraisal of the TA which

leads to these conclusions.’

5.3 The Airport’s principal access is from the strategic highway network, M1 Junctions

23A and 24, and the A453. As an important regional passenger and national

cargo airport, this accessibility must be protected.

5.4 The road network around the Airport and the SRFI development site, particularly

the M1 between Junctions 23 and 25 are of strategic importance to the East

Midlands region, and it is recognised that the area suffers substantial congestion

issues particularly at peak times. This delays traffic accessing the Airport, which

potentially affects the operation and attractiveness of the Airport to users.

5.5 The Airport has invested heavily in public transport services to encourage their use,

and reduce travel by car, with significant success. Nevertheless, the car is, and will

remain the key mode of transport for accessing the Airport in the short and medium

term future. The Airport’s road traffic tends to be spread across the day rather than

concentrated at the peak hours, but still generates a substantial amount of traffic at

the highway peak times. These traffic flows will increase with the forecast passenger

and freight growth of the Airport and it is important that the growth of the Airport

and surrounding developments on the strategic road network is fully taken into

account in the impact analysis.

5.6 The SRFI development is predicted to generate a large number of car and HGV

trips that if unmitigated would lead to a significant adverse road traffic impact in

the local area. This is described in the Transport Assessment and its supporting

documents. The Development Consent Order documents therefore include

substantial works to the strategic road network in the vicinity of the site.

5.7 The proposed highway works, in summary, include the following key elements:

A new road between the A50 eastbound and the M1 southbound

carriageway to provide a direct link between these routes.

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Removal of the southbound A50 carriageway between Junction 24A and

Junction 24 with traffic re-routed via the A50 / M1 link to the M1

southbound slip-road to Junction 24. The existing road will provide a local

access to Lockington.

Removal of the roundabout at Junction 24A.

Removal of the Pinchpoint scheme at Junction 24 that will link the A50

with the southbound A453.

The widening of the M1 southbound carriageway to four lanes between

the new A50 slip-road and the Junction 24 on-slip.

The signalisation of both of the A453 approaches to M1 Junction 24.

A segregated left-turn lane from the A453 (southern arm) to the A50

north-bound carriageway at Junction 24.

A ban on HGV movements via the A6 through Kegworth (except for

access).

The A6 Kegworth By-Pass linking the A6 with the SRFI access roundabout.

5.8 The estimated vehicular trip generation (PCU) for the fully developed SRFI is:

Time Period Arrivals Departures Total

AM Peak (08:00–09:00 866 340 1,206

PM Peak (16:00-17:00) 529 960 1,489

It is estimated that the SRFI would generate 1,206 PCU’s in the AM peak and

1,489 in the PM peak. The transport modelling has been reviewed by East

Midlands Airport (and / or their advisors) and the development’s traffic generation

figures used for the assessment of the SRFI have been accepted as part of the

Statement of Common Ground. Within the traffic modelling, the assessment of the

traffic impact and the proposed mitigation for the development, there is a need for

the Examination to understand the effects of the development on the strategic and

local highway network in the future. This analysis has taken some account of

growth including consented developments, core strategy sites and an allowance for

the Airport. However, the Airport’s forecast future growth is underestimated and

needs to be properly considered due to its close proximity to the SRFI, and

therefore more significant influence on the operation of the road network local to

the SRFI.

5.9 Detailed discussions have taken place between the Applicant (and specialist

advisors) and the Airport and specialist consultants. These discussions have

focussed on the highway modelling used in the application material, and in

particular how the operation and future development of the Airport is taken into

19

account. There are concerns about the assumptions made in the traffic model in

relation to existing and future Airport traffic levels.

5.10 It is considered that the traffic model that has been developed to support the

application and the Transport Assessment under-estimates the existing and the

future traffic assigned to the Airport (including the Pegasus Business Park). In 3 key

areas:

Future Airport growth

Airport employment

Permitted commercial development

5.11 The assumptions used in the traffic model in relation to the Airport were taken from

a note prepared by North West Leicestershire District Council in 201114 and a

Technical Note prepared by David Simonds Consultancy15.

5.11 Using the input assumptions provided in the above notes, it appears that the

forecast Airport traffic in the modelling scenarios are based on employee growth

and this is then used to represent future passenger and staff traffic movements. It is

estimated that, in terms of traffic movements, this represents the Airport handling

some 5 to 5.5 million passengers a year by 2031. This is a substantial

underestimate and is inconsistent with both the Airport’s and the Department for

Transport’s forecasts of the Airport’s air traffic growth.

5.12 It is also unclear how the Airport’s staff numbers have been forecast. It appears

from the input notes, that on-site employment has been forecast by increasing

employment at the rate of growth of Air Transport Movements. Given our concerns

about the use of incorrect forecasts this growth is drawn from an incorrect base,

and the forecast suggests that the on-site employment at the Airport in 2031 would

be 9,581 compared to 6,730 in 2013. On-site staff numbers could be in the

region of 14,000 by 2035 – 2040.

5.13 The Airport Company has been working with the Applicant to understand the traffic

modelling in relation to the Airport. A Sensitivity Test was run using revised levels of

future Airport activity. These revised traffic levels which were provided by the Airport

were based on the Airport handling some 8.5 – 9 million passengers a year in

14

Leicester and Leicestershire Integrated Transport Model. Addendum to Technical Note 23; Future Employment Levels at east Midlands Airport. December 2011. 15

Leicester and Leicestershire Integrated Transport Model. Technical Note 52. East Midlands Airport – Adjustments to the Economic Scenario. David Simmonds Consultancy. January 2012

20

2031, but did not include the consented development at Pegasus Business Park,

which forms part of the Airport site.

5.14 The Pegasus Business Park traffic forms part of the overall Airport traffic levels, and

the employment in the existing development is included in the on-site employment

level. There is substantial (consented) development that is still to be built at the

Pegasus Business Park. It appears that the 2012 Technical Note excludes the

consented area for the Pegasus Business Park.

5.15 The 2012 Technical Note acknowledges the risk of double-counting the

employment land (and therefore its traffic) at the Airport. To overcome this, the

Airport’s inputs excluded both the existing and the proposed floor-space at the

Pegasus Business Park. This is development that is both allocated and consented.

Whilst it is agreed that any potential double-counting should be avoided it is

unclear how much of the Pegasus Business Park traffic has been included in the

traffic modelling and the Airport Sensitivity Test.

5.16 When the total Airport trip generation in the base case 2023 Mitigation Scenario is

compared with the Airport’s estimate of the future Airport traffic generation

including the consented Pegasus Business Park development, it would appear that

the airport traffic in the modelling is some 44% to 55% lower. In the Airport

Sensitivity Test, the traffic generation would appear to be around 26% to 33%

lower than the Airport’s estimate of total future Airport traffic, which is in part due

to Airport traffic having been incorrectly entered into the traffic model. This has

been raised with the Applicant and their specialist advisors.

5.17 In summary the base case seriously underestimates Airport traffic. The Airport

Sensitivity Test adds some additional Airport traffic to the base case; but still leaves

a shortfall of some 30%. As the Sensitivity Test results show that the road network

would be operating at or above capacity, a proper inclusion of Airport traffic would

result in the SFRI adding extra traffic and a increasing the predicted queues and

delays, which could adversely affect the accessibility of the Airport. If the Airport

traffic included in the model is on the low side, it is likely to be underestimating the

queues and delays that could be present in the future, and which may raise other

issues on the road network.

5.18 The queries and concerns in relation to the traffic model inputs have been detailed

and raised with the Applicant and their specialist advisors over a period of months.

If a proper assessment of Airport traffic can be established, the Airport Company

would be able to agree a single set of traffic forecasts that are representative of the

SRFI and the future growth and development of the Airport. These traffic flows

21

could then be used in both the strategic and the local traffic models to confirm the

impact of the proposed SRFI and the effectiveness of the proposed mitigation.

5.19 The highway works proposed as part of the SRFI development are substantial and

aim to achieve a nil-detriment position. But to achieve this, requires that the

modelling of future traffic flows is properly representative of allocated and planned

developments at East Midlands Airport and that the network continues to provide

the capacity and capability for the Airport’s operation and development.

.

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6 QUESTION 7.3 - PUBLIC TRANSPORT

6.1 The question is:

6.2 ‘The relevant representation from the MAG states that the proposed public

transport strategy for the SRFI must not compromise the development of such

services to the East Midlands Airport.’

6.3 East Midlands Airport works to help deliver a good quality and reliable transport

infrastructure for both passengers and on-site staff. This includes the development

of improved sustainable travel choices such as the use of public transport and car-

sharing. The enhancement of the Airport’s surface access network is intended to

increase the efficiency of the Airport by providing an alternative to private car

access, making Airport journeys easier cheaper and more reliable and providing

alternative travel modes for on-site staff

6.4 Given the relatively rural location outside the Three Cities, the private car will

continue to be the primary mode of Airport access. The Airport has set itself mode-

share targets for both passenger and staff access. These targets are:

To seek to achieve 15% of passengers using public transport to access the

Airport – 2013 – 9%

To seek to achieve an employee mode-share of 65% Single Occupancy

Car Use – 2012 – 71%

The achievement of these mode-share targets will only be possible in the event that

there are real improvements to the public transport network. These may be

achieved by working with the service operators as well as working collectively and

developing partnerships with other businesses and employers in the local area.

6.5 For over ten years, the Airport has been very active in developing and investing in

public transport from the main centres in the Airport’s catchment area. These

include Derby, Leicester, Nottingham, Loughbrough, Long Eaton and Coalville.

Over this period, a total investment of £4.9m has been attracted to support high

quality, frequent bus services that operate 24 hours a day, 7 days a week. Of this

investment, the Airport’s direct contribution has amounted to over £2.4m.

6.6 The bus is the principal public transport travel mode to East Midlands Airport. The

usage of the network of Skylink services has grown over the past ten years from

around 200,000 bus users in 2004 to over 1.7 million passengers in 2013/14.

Around 9% of on-site staff use the bus as a means of travelling to work.

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6.7 In the long-term it is necessary for public transport services, including those that

serve the Airport, to be commercially viable. However, it is often necessary to

provide funding to enable new routes or service improvements to become

established. There has been an established strategy of financial support for ‘pump

priming’ new services that has resulted in the existing network, the majority of

which now operate on an entirely commercial basis.

6.8 The Airport wishes to see the continued development of the bus network. This will

include both new routes and service and frequency improvements. The Airport has

identified its targets for new routes and service improvements in the Economy and

Surface Access Plan that is part of the Sustainable Development Plan. The Airport

will work with the operators and local transport authorities. These targets are:

Increase in frequency on the Skylink services to Derby, Nottingham,

Leicester, Loughbrough and Long Eaton

A service from the Airport to Ilkeston as an extension of the existing my15

route

A service to Coalville via Shepshed with an increase in operational hours to

include 03:00 – 04:00 staff start-times and 23:00 – 00:00 finishes

Airport to Ashby-de-la-Zouch with extensions to swadlincote and Burton-

upon-Trent

Airport to Clifton Park and Ride via East Midlands Parkway and Kegworth

Coach links to Birmingham

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Other links to the local area are to be explored include East Leake,

Gotham, Melbourne and Heanor

6.9 The public transport strategy set out as part of the SRFI development focusses

specifically on local bus services and it builds on the existing high quality and

frequent bus network that has been developed to serve East Midlands Airport.

These services have been established and developed as a result of significant

financial investment and support by the Airport Company and other partners. The

public transport proposals for the SRFI include infrastructure improvements to

support local bus use, bus service integration and enhancements and supporting

measures to promote public transport options. The public transport strategy

consists of five phases that would evolve as the development progresses. These

phases are:

Phase 1: The delivery of a bus interchange at the entrance to the SRFI to

be served by existing Skylink services, along with an on-site shuttle bus to

transport staff to / from the bus interchange to the individual units within

the SRFI. Consideration is to be given to the extension of the Coalville bus

service to the SRFI (subject to commercial viability). A dedicated public

transport, walk and cycle connection would also be constructed from the

access via Ashby Road, providing bus priority for buses serving Kegworth,

Loughborough and Leicester.

Phase 2: The extension of the existing Trent Barton my15 service to the

SRFI site (potentially also extending to the Airport).

Phase 3: A contribution towards the through-running of the Trent Barton

my15 to / from Coalville (or the continuation of the existing Coalville bus

service).

Phase 4: A contribution towards the reinstatement of a bus service (1 or 2

per hour to meet demand) along the A453 from Nottingham. This service

could also be extended to the Airport to improve its commercial operation.

This would be in addition to the existing Nottingham Skylink, and link the

Airport, the SRFI, East Midlands Parkway, the Nottingham tram system

Park & Ride at Clifton and Nottingham City Centre.

Phase 5: A contribution towards increasing the frequency of services on

the Derby / Leicester Skylink to either every 15 or 20 minutes to meet

demand or as required

6.10 Any improvements need to complement and enhance rather than degrade the

existing high quality bus network that serves the Airport. East Midlands Airport

benefits from its bus network and has high quality and frequent services to the key

catchment areas for passengers and staff. The Airport performs relatively well in

terms of its passenger and public transport mode share (9% of passengers and

25

71% staff drive-to-work alone). It is important that the transport network serving the

Airport is not diminished by the SRFI development, and that the opportunities for

complementary public transport services serving the Airport and the local area are

fully explored.

6.11 A review of the proposed public transport provision has been undertaken on behalf

of East Midlands Airport and shared with the Applicants. A summary of the review

follows below.

6.12 Phase 1: The potential for additional patronage from the SRFI on the Nottingham

Skylink service and on the Derby / Leicester Skylink would be beneficial due to the

potential for an increased frequency or less financial support for off-peak services.

This is balanced by the service stopping at the SRFI Interchange, adding a slight

delay and additional traffic signals on the route.

6.13 An extension of the Coalville service is to be considered rather than included as a

commitment. Extending the service to the SRFI would bring the benefit of more

passengers on the service, but the impact of the increased journey time on the

frequency / timetable is not identified.

6.14 The dedicated public transport, walking and cycle connection would be beneficial

for cycle access to the Airport, particularly from Kegworth. The bus route would

only be beneficial if there is a service on the A453 to Nottingham which is

proposed in a later phase of the public transport development. An additional

Nottingham bus service would compete with the Nottingham Skylink for trips to /

from Nottingham City Centre.

6.15 Phase 2: The extension of the my15 bus service would be beneficial to the Airport

as there is no existing direct route to Ilkeston. This is also identified as an aspiration

rather than a commitment.

6.16 Phase 3: The extension of the my15 service to Coalville would place it in

competition with the existing (and extended) Coalville service. It appears doubtful

whether there would be sufficient passenger numbers for both services to be

commercially viable and to co-exist.

26

6.17 Phase 4: The proposed A453 service to Nottingham would compete with the

existing Nottingham Skylink. It would be more attractive for direct trips to

Nottingham and for connections to Clifton and to East Midlands Parkway.

6.18 Phase 5: A financial commitment towards increasing the frequency of the Derby /

Leicester Skylink would be beneficial to Airport users. This measure should be

implemented in an earlier phase of the public transport measures, especially as it is

suggested that the two largest units on the development site would constructed and

occupied as an early stage of the development.

6.19 It is important that there is a co-ordinated public transport strategy to serve the

application site and the local area. The Airport recognise the potential benefits to

the public transport network that the highway improvements will bring (subject to

ongoing discussions about the Airport growth assumptions in the traffic impact

assessment) and that the public transport proposals should enhance existing

services. Appropriate financial provision should be put in place to ensure that the

agreed public transport measures are delivered and contribute to sustainable

services. This should be an established obligation included in any conditions,

protective provisions or any associated Section 106 Agreements. Obligations

relating to the monitoring of public transport use should also be included.

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7 CONCLUSIONS

7.1 East Midlands Airport is an important transport and economic asset for the East

Midlands region, in particular the economies of Leicestershire, Nottinghamshire

and Derbyshire. There is national and local policy support for the growth and

development of the Airport. The opportunities and the scale of future growth is

identified in the Airport’s Sustainable Development Plan and its Land Use Plan

7.2 It is important that the economic and employment opportunities presented by both

the growth of the Airport and the SRFI are secured for the local area and the region

as a whole and the development and operation of either development does not

compromise or impose restriction on the growth and development of the other.