Representation by easyJet (easyJet)
- Date submitted
- 28 October 2023
- Submitted by
- Members of the public/businesses
Gatwick Airport Northern Runway DCO application – easyJet’s submission easyJet carries 46% of the traffic through London Gatwick (LGW) and as a result easyJet’s passengers will be most impacted by Gatwick Airport Limited’s (GAL) Northern Runway proposal. easyJet’s view is that GAL is not best placed to deliver the Northern Runway Project and that airspace modernisation needs to be urgently addressed before this project goes ahead. 1. GAL is not best placed to deliver an increase in capacity at LGW given current performance. GAL’s performance is below the performance of other large airports in Europe. GAL is consistently ranked in the lower half of punctuality rating in relation to average arrival and departures of the 33 airports reported by Eurocontrol (see sources). GAL has provided sub-standard Air Traffic Control services in 2022 and 2023 demonstrating a clear inability to cope with the current levels of traffic, let alone an increase in capacity with a second runway. GAL failed to notify airlines of any issues in advance of this summer resulting in significant disruption to passengers. Whilst GAL are making plans to improve ATC services, we are yet to see any material improvement and these issues have been persistent for the last two years. easyJet therefore questions whether GAL would be in a position to manage the increased aircraft movements that the Northern Runway would bring. 2. Current infrastructure plans set out by GAL do not sufficiently account for increased capacity. The independent slot coordinator Airport Coordination Limited (ACL) has demonstrated that current critical infrastructure at LGW (including the North Terminal departure facility) is full or close to full during the morning peak hours. This makes it impossible to add more aircraft or up gauge to larger aircraft with more seats. easyJet is aware that GAL has initiated some conversations on improvements to terminal infrastructure needed for the Northern Runway Project, however these are at a concept / pre-planning stage. They are not included in GAL’s capital investment plan and were not submitted as part of the DCO process. easyJet is concerned that GAL has not shared any details relating to the plans, design, or scope of infrastructure needed to support the Northern Runway nor has it provided any timing for delivery or details regarding funding for supporting infrastructure. Without proper planning, operations at LGW will suffer. GAL suggests that the Northern Runway project “offers an affordable, sustainable opportunity to add significant capacity and resilience to the constrained London system and allow Gatwick to serve as many as 75 million passengers by 2038”. However, there is no mechanism within the current commitments framework for any required adjustment to be made to GAL’s investment commitment in the event that the Northern Runway project is permitted to proceed and the airport’s capacity (i.e. number of passengers served) increases. GAL has not explained how the proposed investment commitment would serve the needs of an increased number of passengers. Nor has GAL outlined how it will meet its service standards in having to commit expenditure to the Northern Runway, if approved. 3. UK airspace modernisation needs to be completed before airspace above London takes on additional traffic. Airspace constraints need to be addressed prior to opening a second runway. Failure to modernise the airspace coupled with increased traffic over London will result in delays for passengers, increased operating costs, and excessive fuel burn creating a sharp spike in emissions in the South East region. NATS has forecast that by 2030 passengers could face delays on average of 30 minutes on every 1 in 3 flights if no action is taken to modernise the UK airspace (see sources). This would be further exacerbated by additional capacity added through the Northern Runway if this problem is not addressed. 4. GAL’s current operations at LGW require significant review if GAL are to successfully support a second runway. LGW’s current operations have several underperforming elements which are struggling at current levels of traffic and would be exacerbated by increased traffic from a Northern Runway. These are: • Security: currently there is no capacity to expand on the current security infrastructure within LGW and no increase in security resources at peak times leading to long queues and delays. Whilst there is a mandated change of security protocol (next gen security), it is unclear how this will impact on current passenger throughput. Not having to remove liquids should improve passenger flow, but the additional passenger screening requirements are expected to counter any improvement gains. easyJet is not aware of any contingency that can be deployed should GAL need to expand the capacity of security areas beyond the current planned footprints. • Immigration: immigration is full at certain times in both terminals. This is driven by UKBF and there is no clear plan on how UKBF will support a significant increase in passenger numbers, nor if the current terminal infrastructure could accommodate further e-gates or immigration desks. • Stand capacity: aircraft stand and coaching gate capacity are at maximums during certain times of the day. Delivery of pier service levels in line with GAL targets is only made possible by an extensive programme of aircraft towing during first wave operations. It is not understood how GAL would mitigate against further ground delays as a result of more aircraft than stands/gates available. Only an extensive programme of taxiway work to improve airfield flow could mitigate this and we do not see this in GAL’s proposal. • Night Movements: are relied on by carriers that operate at LGW. Further traffic that increases congestion are likely to cause delay that further compound the night movement limitations with cancellations and disruption to passengers a likely risk. 5. The source of funding for the Northern Runway has not been made clear. GAL has not provided any details as to how the Northern Runway and any supporting infrastructure will be funded. easyJet is concerned that GAL may seek to acquire the capital required for the Northern Runway from current operating airlines. Potential impact on current operators and increased charges to customers should be considered. easyJet would prefer to understand how GAL intend to fund the project before it is approved. If GAL’s intent is to pass through all or a sizeable portion of costs sunk in developing the Northern Runway and associated infrastructure to airlines, this may unfairly impact current customers as it will undoubtedly influence pricing of flights touching LGW. Sources: https://www.eurocontrol.int/sites/default/files/2023-09/eurocontrol-european-aviation-overview-20230926.pdf https://www.eurocontrol.int/sites/default/files/2023-09/eurocontrol-european-aviation-overview-20230612_2.pdf https://www.eurocontrol.int/sites/default/files/2023-08/eurocontrol-european-aviation-overview-20230817.pdf https://publicapps.caa.co.uk/docs/33/UKAirspaceChangeMasterplanIteration2v2.2.pdf