Representation by Gatwick Obviously Not (Gatwick Obviously Not)
- Date submitted
- 9 November 2023
- Submitted by
- Non-statutory organisations
Gatwick Obviously Not (GON) is a community group that campaigns on behalf of people living in west Kent and surrounding areas whose health, wellbeing and quality of life is adversely affected by Gatwick Airport. GON strongly opposes Gatwick’s proposals. Expansion would blight the areas in which GON operates and cause huge wider environmental damage. This representation focuses on the climate and noise aspects of Gatwick’s proposals. However, we also oppose the application on other grounds including: a. Gatwick has not put forward a policy compliant needs case. The ANPS requires airports (other than Heathrow) that are seeking to expand to demonstrate sufficient need for their proposals, additional to (or different from) the need which would be met by the provision of a Northwest Runway at Heathrow. Gatwick has instead assumed that there will be no development at Heathrow. b. The airport has substantial surplus passenger and ATM capacity without the proposed development. In our view there is no current or policy compliant need for development. c. We dispute the Gatwick’s assessment of the economic and employment benefits of the project. d. We are concerned about the effects of the project on local roads and air quality near the airport, on water supply and flooding and on congestion on the rail and trunk networks which airport traffic uses but which are vital for communities much more widely. Baseline We are not confident that Gatwick’s ATM and passenger volumes baseline is achievable. If baseline conditions are not achievable, environmental and noise effects of the project will be understated. Climate impacts Gatwick’s proposals are incompatible with global and national climate change commitments and the government’s objective and policy for aviation emissions. They are also inconsistent with CCC advice that no airport expansions should proceed until a UK-wide capacity management framework is in place to assess and, if required, control sector emissions and non-CO2 effects. The Government’s objective is to ensure that the aviation sector makes a significant and cost-effective contribution towards reducing global emissions. Gatwick’s proposal would materially increase emissions and is therefore incompatible with the government’s objective. The ANPS states that an increase in carbon emissions that would have a material impact on the Government’s ability to meet its carbon reduction targets would be a reason to refuse development consent. In our view Gatwick’s proposals clearly have the potential to have such a material impact. Prior to mitigation CO2 emissions attributable to Gatwick in 2038 are forecast to be 2.5 million tonnes pa higher than in 2018, an increase of nearly 50%. Emissions attributable to Gatwick would grow from less than 1% of total UK emissions to over 5.5% of the CCC’s recommended total UK emissions in 2038. Much of this is attributable to the project. An increase in emissions of this magnitude would plainly be so significant that it would have a material impact on the UK’s ability to meet its carbon reduction targets. We recognise that some emissions mitigation may be possible. However, there are presently no proven measures by which emissions on the scale forecast by Gatwick could be mitigated. IEMA guidance requires assessments to consider the certainty of mitigation proposals and whether they are realistic and achievable. Gatwick’s mitigation assumptions do not meet these tests. For these reasons Gatwick’s assumption that the emissions reductions modelled in Jet Zero will be achieved is neither reasonable nor consistent with the precautionary principle and IMEA guidance. Jet Zero outcomes are “illustrative scenarios”, not a set of policies that can be relied on to reduce aviation emissions. Gatwick should recognise the uncertainty and high risk in Jet Zero and model alternative scenarios. Gatwick has also failed to quantify the non-CO2 effects of the project. These should be costed and presented for consideration. In addition to the impacts of this proposal, the planning process should assess the scale and impacts of emissions from all proposed UK airport expansions against global and national targets and commitments. Noise Gatwick’s noise assessment is limited to people within the government’s lowest observable adverse effect level (LOAEL) contours. This materially understates the impact of the proposal on communities. Gatwick should be required to prepare new analysis showing noise impacts using the limits recommended by the World Health Organisation and equivalent noise frequency measures. Noise envelope The ANPS requires noise envelopes to be “defined in consultation with local communities”. CAP 1129 states that “… it is essential that full agreement is achieved between all stakeholders on the envelope’s criteria, limit values and means of implementation and enforcement”. Community groups repeatedly requested changes in Gatwick’s noise envelope engagement process to align it with CAA guidance and the ANPS. For example we asked for: a. the terms of reference to be changed to comply with CAP 1129 b. the process to be independently chaired c. additional time to allow issues to be explored in necessary detail d. independent technical advisory support. Gatwick refused these requests. We also requested additional data and analysis that was essential to effective noise envelope engagement and which only Gatwick was able to provide. This was also refused. We made clear that the lack of additional data and analysis precluded informed engagement and meant that GAL’s process would not be able to generate policy-compliant outputs. Gatwick rejected the overwhelming majority of our comments on its proposals. It also rejected most of our comments on its Noise Envelope Group Output Report which does not reflect community group views. Gatwick has therefore failed to engaged on its noise envelope proposals in a meaningful or policy compliant way. It should be required to engage properly, under independent chairmanship, to develop new noise envelope proposals. Government policy states that “as a general principle, the Government therefore expects that future growth in aviation should ensure that benefits are shared between the aviation industry and local communities. This means that the industry must continue to reduce and mitigate noise as airport capacity grows.” Gatwick’s noise envelope proposals do not achieve these policy principles. For the first noise envelope period the benefits of growth would accrue almost entirely to the industry, which would benefit from a 62% increase in passenger capacity while communities suffer substantial increases in noise. For the second noise envelope period the noise impacts on communities would continue to be substantially greater than in 2019 once account was taken of the frequency of aircraft, a key measure of community annoyance. Thereafter, the proposed review process would allow noise to increase above the 2019 base year level on any measure. Rather than the airport reducing noise as capacity grows, noise would increase very substantially and potentially indefinitely. And rather than the benefits of growth being shared, benefits would flow almost entirely to the industry. The APF also requires noise envelopes to give communities certainty about future levels of noise. Gatwick’s proposals do not do so. There are no restrictions on noise in the winter and future noise envelope reviews could increase noise without limit. Policy additionally requires noise envelopes to incentivise airlines to introduce the quietest suitable aircraft as quickly as reasonably practicable. Gatwick’s slow fleet transition proposals would remove any incentive for airlines to introduce quieter aircraft at Gatwick, and might motivate them to do so at other airports first. New noise envelope proposals must comply with policy. Specifically, noise should reduce as capacity grows, at a pace that achieves a genuine sharing of the benefits of growth between industry and communities. New proposals should cover all periods of the year and reflect a best-case fleet transition that incentivises airlines to introduce quieter aircraft quickly. Metrics Gatwick’s proposed noise envelope uses a single, average noise, metric, Leq. It is widely accepted that Leq does not portray aircraft noise as experienced by communities, and all relevant policy and guidance advises against its use as a sole metric. The APF says “… we recommend that average noise contours should not be the only measure used when airports seek to explain how locations under flight paths are affected by aircraft noise. Instead the Government encourages airport operators to use alternative measures which better reflect how aircraft noise is experienced in different localities, developing these measures in consultation with their consultative committee and local communities. The objective should be to ensure a better understanding of noise impacts and to inform the development of targeted noise mitigation measures”. CAA guidance recommends using a “combination of parameters” and states that “where unilateral agreement cannot be achieved using standard metrics, consideration should be given to designing envelopes using other metrics provided that they are scientifically valid and robust”. The ANPS requires noise envelopes to be tailored to local priorities and to be defined in consultation with local communities. An envelope based solely on Leq metrics does not meet either of those tests. We note Gatwick’s assertion that use of Leq is supported by the CAA’s 2014 Survey of Noise Attitudes, but do not believe the evidence supports that claim. ICCAN’s stated that SoNA was not designed to consider the change in noise attitudes caused by an airport undergoing a period of volatility in its operation, such as expansion. ICAO is clear that exposure-response relationships are not applicable to assess the effects of a change in the noise climate, for instance where a new runway is opened and that common noise exposure variables (such as Leq) only account for about one third of community impacts. In our view SoNA provides no evidence that Leq is a reliable indicator of community impact over a period in which an airport is growing in the way Gatwick proposes. Gatwick’s proposal to report secondary metrics is irrelevant because no limits would be set for those metrics and they would impose no obligations on the airport. Revised noise envelope proposals should include a suite of metrics and limits to be agreed with all stakeholders. Noise envelope reviews Gatwick has proposed noise envelope review, compliance and breach arrangements that are wholly one sided and do not comply with policy. New review, compliance and breach arrangements should be developed and agreed. Noise objective We do not support the regulation 598 noise objective Gatwick has proposed because it selectively omits key elements of government policy. It should be amended to refer to and reflect all relevant government policy. Night flights The ANPS requires a ban on scheduled night flights between 11pm and 7am. In addition, outside the hours of a ban, the Government expects applicants to make particular efforts to incentivise the use of the quietest aircraft at night. The ANPS is clearly stated to be an important and relevant consideration for applications for any airport nationally significant infrastructure project in the South East of England, not just Heathrow. Gatwick has not proposed a ban on night flights or any other limitation on night flights. It has also not explained what efforts it would make to incentivise the use of the quietest aircraft at night outside the hours of a ban. A ban on night flights and a comprehensive package of measures to incentivise the use of the quietest aircraft at night outside the hours of a ban should be conditions of any approval of the DCO. Conditions There should be no expansion at Gatwick. However, if consent for the development was granted it should be conditional on a wide range of additional measures including: • A ban on all night flights for a full eight-hour period every night. • A noise envelope agreed with local communities which achieves the government’s policy requirements that noise must be reduced and mitigated as capacity grows and the benefits of growth shared. • A enforceable, progressive and material reduction in the emissions and total climate impacts attributable to the airport from a 2019 baseline. • No increase in road traffic to the airport. • A legally binding commitment that there would be no further runway, terminal or associated development at Gatwick including no full new runway.