Representation by James C Mitchell
- Date submitted
- 14 October 2023
- Submitted by
- Members of the public/businesses
I strongly recommend that consent for the runway extension(s) should be refused for the following reasons - 1) Need - Gatwick’s overall case for expansion does not comply with the Airports National Policy Statement which requires airports (other than Heathrow) to demonstrate sufficient need to justify their expansion proposals, additional to (or different from) the need which would be met by the provision of a Northwest Runway at Heathrow. Surely, as the government supports (approved) expansion at Heathrow in effectively a competition with Gatwick, permission should not also now be granted for expansion at Gatwick via the back door. 2) Noise - Expansion of Gatwick would significantly increase aircraft noise both for those living near the airport and for those further away under flight paths and by way of additional vehicle noise. The number of noise events during take off and landing and on-airport manoeuvring are intrusive for local residents already and expansion of the airport would lead to the virtually constant high level noise emissions, which is an unreasonable burden to impose on local residents. These emissions are particularly intrusive on summer nights/early mornings when bedroom windows are open. 3) Climate change and air pollution - Expansion on the scale proposed would increase very substantially the CO2 emissions and other climate effects associated with Gatwick’s operations and flights, plus associated vehicle movements and construction activity. There are currently no proven technologies for reducing aviation emissions at scale. Expansion of Gatwick would therefore have a material negative impact on the UK’s ability to meet its carbon reduction targets and goes against the Climate Change Committee's recommendations and would surely breach the Climate Change Act 2008 (2050 Target Amendment) Order 2019. 4) Transport impacts - Gatwick’s targets to increase how many people use bus, train, walk and cycle to and from the airport are insufficient to prevent a massive increase in road traffic around the airport. This increase in traffic would increase congestion on the M25 and M23 to unsustainable levels and local roads and increase off-airport parking (including on-street in local villages and conurbations) and increase CO2 emissions. Gatwick is not providing any extra rail services, or offering to pay to improve rail infrastructure adequately i.e. at East Croydon, but the project will increase pressure on future train services, with the result that more passengers will have to stand on the mainline services between London Victoria and Brighton. 5) Economic case - The economic benefits of expanding Gatwick have been overstated by the Gatwick Airport Ltd. Significant economic, social and environmental costs have been ignored and/or understated. The economic benefits of air transport growth are subject to diminishing returns. In an already highly connected economy such as the UK, additional economic benefits from further expanding air transport are largely dependent on net inbound tourism and business travel growth. Both of these are absent in the UK today (more people fly on holidays overseas and business travel has flat-lined in the UK since 2006). When Gatwick's scheme costs, benefits, and the long-term societal risks are taken into account, the scheme’s economic case no longer stacks up and entails unreasonable levels of risk to local, national and international wellbeing. In addition, the proposed scheme by incentivising UK residents to spend more overseas, this project will cost jobs and economic activity at home, particularly in the poorest parts of the UK, contradicting the government’s levelling-up agenda. 6) Flood Risk - Over the years the River Mole and its tributaries have flooded, especially when the Airport and sewage treatment plants discharge water in extreme events. Climate change is making these extreme events more frequent and severe. Expansion of the Airport, and other developments locally, need to properly take this into account. We cannot allow private organisations to continue to impose unsustainable growth of airport infrastructure and airport noise and emissions on the (South East of) the UK. The planning regime is meant to prevent (control) such development as set out in the government's National Planning Policy Framework (NPPF.) The runway plans by the Airport breach the NPPF in various respects and similarly, they breach the government's Aviation Policy Framework as they are not sustainable and therefore the recommendation to government should be to completely reject the application. In the (unfortunate) event the Inspector is minded to recommend consent be granted then the following should be incorporated - A) Night flights - A ban on night flights should be a condition of any expansion at Gatwick with daytime operational hours being altered to 11pm to 6.30am to minimise locally disruptive noise events (including ground movements). In addition, the airport should also be required to set out a comprehensive package of measures to incentivise the use of the quietest aircraft at night outside the hours of a ban. Any flights taking place during the night hours should be fined and all proceeds passed back to local communities. B) Number of flights - these should be capped at an average of the last 3 year's actual day and night time flights as this is an opportunity to redress the excesses of the existing quotas. C) Suitable controls on emissions targets for the airport as a whole to be able to achieve 2050 net zero levels, with significant penalties if adequate progress on a set out path is not achieved. D) A material share of fees charged to airlines for use of the airport to be paid promptly annually to local communities to compensate them for the disturbance and emissions they have to suffer as a result of the airport's expansion. E) The airport must fund expansion to rail infrastructure to London and Brighton so the congestion is no worse than currently and also fully fund road improvements. F) The airport's proposals for other sustainability and community benefits must be imposed as planning conditions with appropriate timescales to be met. I commend these recommendations to you. James C Mitchell 14 October 2023