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Representation by Railway Pension Nominees Limited (Railway Pension Nominees Limited)

Date submitted
26 October 2023
Submitted by
Members of the public/businesses

Relevant Representation on behalf of Railway Pension Nominees Limited Railway Pension Nominees Limited (“Railpen”) is the freehold owner of the hotel operating as Radisson RED London Gatwick Airport, referred to in the Book of Reference as Land and buildings north of Church Road and east of Old Brighton Road, Lowfield Heath, Crawley, RH11 (“the Site”). Railpen is part of the Railway Pension group of companies, which administers the principal UK Railways industry-wide pension schemes. The hotel is leased to a hotel management company (Axcel Hospitality (Gatwick) Limited), who in turn manage the day to day operations of the Site. The operation of the Site, given its close proximity to the southern boundary of the airport, is inherently deeply affected by the operation of the airport. Therefore the Site is sensitive to changes in those operations. In particular, the Site’s proximity to both the operational southern runway and the northern runway which forms the focus of the proposals encapsulated in the DCO, means that it is particularly sensitive to the impacts arising from the noise, vibration, fumes, smell, smoke, and artificial lighting arising from the take-off and landing operations at the airport. The potential impacts of the operation of the new proposed Fire Service Facility which comprises Work 15 in the DCO also needs to be considered. As a result Railpen is currently working to understand the impacts of the proposed works, having regard to the various environmental statement documents provided by the applicant. This will inform an understanding of the likely impacts on the business of the hotel and those who visit and stay at it. Of course given the operation of the Site as a hotel, the noise impacts are particularly important as guests at the hotel will readily be put off by noise levels which are perceived by them to not be within acceptable bounds, particularly during night flight operations. Railpen’s understanding of the likely impacts has not been assisted by the Site seemingly not having been considered as a non-residential noise sensitive receptor, and the Site is also not within the area described as receptor area 9 within the Noise and Vibration chapter of the ES (see figure 14.4.2). As a result it appears on the face of the presently available information that the particular impacts of the DCO proposals have not been fully assessed in relation to the Site, and the limitations that the proposals could impose on its continued operations. Had Railpen been engaged with prior to submission of the DCO the nature of impacts and the information that Railpen required to understand the impacts better could have been discussed with the applicant. Unfortunately the applicant did not seek to engage with Railpen prior to submission. Therefore Railpen must object to the DCO proposals until such time as it is satisfied as to the impacts on the Site and its operations