Representation by Gatwick Airport Consultative Committee (GATCOM) (Gatwick Airport Consultative Committee (GATCOM))
- Date submitted
- 27 October 2023
- Submitted by
- Non-statutory organisations
As the airport’s statutory independent consultative body, The Gatwick Airport Consultative Committee (GATCOM) welcomes the opportunity to register as an interested party and make its relevant representation on Gatwick Airport Limited’s (GAL’s) proposals to bring the existing Northern Runway into routine use alongside the main runway. GATCOM consists of members from local authorities, business, airlines and environment and community groups. This inevitably results in many differing views. In the pre-application consultations GATCOM neither supported nor opposed GAL’s vision for growth, nor attempted to document every view expressed by individual members, but instead highlighted areas where members reached a common view or understanding and made representations which encouraged steps to minimise adverse impacts, mitigate their effects and secure appropriate infrastructure. Where views are from a minority of members this is noted. Many GATCOM members are expected to submit relevant representations on behalf of their own particular organisation. The Committee understands GAL’s desire to make best use of its existing runways. The Committee also recognises the importance of the airport as a significant asset that contributes to the regional and local economy but is also firmly of the view that any proposals for growth need to be achieved responsibly, sustainably, and with a focus on the well-being of communities around the airport and with mitigation to address the negative impacts of the airport’s operations. GATCOM appreciates that there will always be a need to strike a balance between the important priorities of economic development, environmental sustainability and the local community’s well-being. In this relevant representation GATCOM has reviewed issues previously highlighted and tried to ascertain whether GAL have addressed those issues in the proposals submitted to the Planning Inspectorate. It is acknowledged that GAL have addressed within their proposals many of the issues previously raised, but GATCOM continues to have some concerns that are detailed below and included in the attached issues tracker, which lists the views previously expressed by GATCOM and, includes both a GAL response and the related PINS reference. Surface Access Many of the proposed mitigation measures are to be delivered after the Northern Runway opens. GATCOM is concerned that communities may suffer the negative impacts of growth before the mitigation measures, such as highways improvements works and improvements to walking and cycling infrastructure, are delivered. In respect of promoting active travel, many GATCOM members believe more could be done to bring forward active travel improvements as part of the Northern Runway project. GATCOM thinks that the mode share targets are considered to be ambitious and there appears to be insufficient evidence to demonstrate how the target mode share percentages for staff and passengers can be met. The behavioural choices by passengers and airport staff are still uncertain following the COVID-19 pandemic and industrial action on the railways. GATCOM believes that the predictability of mode share needs further examination to test the modelling and assessment of the impacts of airport expansion in a range of scenarios, which should reflect the recent trends and latest forecasts in use of and shift to public transport and sustainable surface access modes. Specifically, the consequences for local communities of lower mode share transfer to sustainable sources should be further examined and additional mitigations proposed if appropriate. GATCOM has mixed views about the level of car parking provision. Of key importance to GATCOM is the need to ensure there is sufficient car parking provision to accommodate those who need to travel by car to the airport where there are no suitable alternative sustainable transport modes (active travel, bus, coach or rail) and that the airport is incentivised to take all reasonable steps to encourage and facilitate sustainable transport modes. There continues to be a need to address the problem of approaching traffic from the surrounding road network in Surrey, West Sussex, East Sussex and Kent. Pre-pandemic, the local road network, including country lanes, was already being commonly used to access the airport with traffic volumes exacerbated when there is disruption and congestion on the M25 and M23. As part of GATCOM’s response to the draft Airport Master Plan the A22, A264, A24 and the possibility of a Crawley western link road were highlighted as potential routes needing improvement where financial contributions to local authorities towards improvements may be needed. Most GATCOM members feel strongly that local road improvements need to manage the increased traffic levels should be funded by GAL or Central Government and not a burden on the local Council Tax. We are aware that GAL has discussed the possibilities of direct rail services to Kent with Network Rail but that such services would not be considered to come forward as part of the assessment, which is disappointing. GATCOM does welcome that GAL has identified enhancements to the regional coach network to target areas that currently have a low public transport mode share but generate significant numbers of trips to and from the airport. These areas include: Sevenoaks and the Medway Towns, East Grinstead and Uckfield, Tunbridge Wells, Horsham and Worthing, Bexley and outer east London. Noise GATCOM notes that no commitments have been made in respect of future levels of night flights. GATCOM questions why GAL is not committed to limiting the simultaneous use of the northern runway for the full 8 hour night period 23:00 – 0700. Whilst the airline representatives view the period 06:00 to 07:00 as important to maintain the resilience and efficiency of route networks, GATCOM reiterates the comments made in its response to previous consultations that there should be no increase in ATMs on the main runway from 2018 levels during the night period 23.00 – 07.00 as well as giving a commitment to not to operate the Northern Runway during the night period 23.00 – 07.00 except when the main runway is non-operational. GATCOMs Airline representatives do not support this view, but some other GATCOM members are seeking further reductions in night noise. However, GATCOM does understand this is an issue for the secretary of state as Gatwick is a designated airport. Noise Envelope GATCOM acknowledges that some members continue to express serious concerns about GAL’s engagement mechanism for the Noise Envelope and that it did not follow the process set out in CAP1129. As a result, GATCOM is not persuaded that stakeholder views have been sufficiently fully reflected in the noise envelope proposals including in respect of metrics, limits and policy compliance. GATCOM would therefore like to see further engagement on this key issue and new proposals brought forward. Given the advice of the Planning Inspectorate to the GATCOM Secretariat that “The statutory consultation required under the Planning Act 2008 (PA2008) is not set out in guidance such as CAP 1129, however if a developer is applying this guidance to its noise assessment, it is best practice to follow that guidance unless another appropriate method is applied”, GATCOM understands that the appropriateness of GAL’s chosen engagement mechanism will be a matter for the Planning Inspectorate to consider. GATCOM is pleased that GAL have stated they will consider introducing a Noise Envelope even if the DCO does not proceed and that it would form part of the next Noise Action Plan and therefore be subject to review by GATCOM via NaTMAG. Clarity is needed regarding regulation of a Noise Envelope and the assignment of a responsible party for such regulation. Several Local Authorities members wish to have a regulatory role in the Noise Envelope that would involve reviewing and approving submissions and would allow action to be taken in the event of a breach. GATCOM previously highlighted the need for the frequency of overflight to also be taken into account in the Noise Envelope. It is the frequency of overflight that is of greatest concern to local communities affected by aircraft noise. We appreciate that GAL has included a series of secondary noise metrics that consider frequency of overflight, but some GATCOM members consider that these need to form part of the quantified noise envelope itself, not merely be reported. Climate Change and Emissions GATCOM does have concerns about the significant increase in greenhouse gas emissions and impacts on climate change and understanding how airport expansion can be achieved in the light of national and international carbon reduction targets. GATCOM does appreciate that GAL are undertaking significant works to reduce airport emissions and as part of the Airport Carbon Accreditation process will be publishing a stakeholder plan for reducing the wider scope 3 emissions. GATCOM continues to wish to see a carbon reduction trajectory set for airport related emissions and a process by which progress can be monitored and remedial action taken in the event that reduction targets are not being met. Also please see the issues table referred to at the start of this relevant representation. It can be found at this link: [REDACTED]