Representation by Plane Wrong (Plane Wrong)
- Date submitted
- 13 November 2023
- Submitted by
- Non-statutory organisations
Plane Wrong INTRODUCTION Plane Wrong is a community noise group, formed in 2013 in response to the noise impact caused when Gatwick introduced performance-based navigation departure routes. Our around 600 members reside in the primarily rural area along Gatwick departure routes 3 and 4, one of which is always in use, meaning that many of our members have no respite at all from aircraft noise. Route 4 is Gatwick’s busiest departure route. Much of this area is also blighted by Gatwick road traffic speeding through rural lanes. Approval of the airport’s proposals would cause very significant environmental harms and generate very limited net benefits. Gatwick should not be permitted to grow unless and until it is able to demonstrate that it could do so whilst at the same time reducing, in a proportionate and balanced way, all adverse environmental, noise and other impacts of any growth. We are concerned that the baseline for comparison is itself a massive increase in flights and passengers. A future baseline independent of any increase in passenger numbers at Gatwick should be provided and used to assess the impacts of the current future baseline and Project, for all aspects of the Environmental Impact Assessment (EIA) and improve clarity in communicating Gatwick’s expansion plans. Plane Wrong is a member of GACC and the Chair is a GACC committee member. We have drawn on GACC technical expertise for some elements of our representation. Our concerns include: TRANSPORT Our supporters reside in the mainly rural area between Gatwick and the M25 and increased road traffic and congestion, traffic noise and air pollution will be a major problem. Many roads and lanes in the area are unsuitable even for the current volume of Gatwick traffic. This level of traffic on rural roads brings noise disturbance particularly at anti-social times, safety concerns, air pollution, carbon emission increase and roadside littering. Nothing material is proposed in the application to fundamentally change the existing poor road and rail connectivity. The effect on local infrastructure and our community of any increase in traffic would be wholly unacceptable Gatwick’s proposals and mode share targets fail to prevent a significant growth in car use for surface access. Modelled increase in journey times includes unacceptable increases in highway traffic on the local network (e.g., on the A23, A24 and A217). Gatwick plans only limited investment in public transport. Gatwick should reprioritise its surface access investment to sustainable travel, which means public transport for most passengers. The project increases demand pressure on London-Brighton mainline trains, forecast to already become crowded. Modelled future rail capacity assumptions reflect industry plans to accommodate rail demand growth without Gatwick expansion to 2029. No increased rail capacity is planned or funded. NOISE Gatwick has not met the ANPS requirement that noise envelopes are “defined in consultation with local communities”, nor CAA guidance that noise envelopes are agreed with stakeholders. Gatwick: rejected community stakeholder requests to change the format and timetable for engagement to improve compliance; failed to provide additional data and analysis for effective engagement; and its proposals were not agreed as they excluded almost all stakeholder comments. Gatwick’s draft Noise Envelope Group Output Report fails to reflect community group views on Gatwick’s proposals or its engagement process. Gatwick’s proposals do not: • Meet government policy (APF 2013) that “Future growth in aviation should ensure that benefits are shared between the aviation industry and local communities [so] continue to reduce and mitigate noise as airport capacity grows.” Instead, the proposals would permit noise to increase substantially and potentially indefinitely, so benefits of growth accrue almost entirely to Gatwick and its customers. • Give communities certainty about future noise levels (APF para.3.29), nor contain any proposals to limit noise in the winter period, and allow future reviews to increase noise limits. Gatwick should be required to engage properly with community groups and councils, under agreed independent chairmanship, to develop new proposals that comply with policy and guidance. The proposal would create an unacceptable increase in noise over a very wide area around LGW outside of the area covered by the Noise Envelope, much of which is rural and contains large Areas of Outstanding Natural Beauty. The proposal makes no plans to mitigate this huge environmental impact on a very large population. With such a huge increase in flights it is inevitable that new routes will need to be used affecting many people who have previously not been. Departure Routes 3 and 4, one of which is always in use, affect many of our members who therefore have no respite at all from aircraft noise. Route 4 is Gatwick’s busiest departure route. Many of our supporters also suffer from the noise of Heathrow aircraft which are increasingly in numbers. A 35% increase in Gatwick aircraft numbers would be devastating for the residents this rural area. We are also not convinced that the larger aircraft size and higher load factors upon which Gatwick assume that they can accommodate a 70% increase in passenger numbers with a 35% increase in flights will prove correct. In which case an even larger increase in flights will occur. NIGHT FLIGHTS The ANPS requires a ban on scheduled night flights for a period of 6.5 hours, between 23.00-07.00 and requires airports to make particular efforts to incentivise use of the quietest aircraft at night. The ANPS should be considered important and relevant for any airport NSIP in South East England (not just Heathrow), including here. A ban on night flights should be a condition of any approval of the DCO. Gatwick 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. NEEDS CASE The ANPS requires airports seeking to expand (other than Heathrow) to demonstrate sufficient need, additional to (or different from) that met by provision of a Northwest Runway at Heathrow. Gatwick has not done this. Gatwick should also assess the need for increased use of its existing runway above 2019 levels, without development of the new Northern runway. This should be contrasted with historic growth rates of flights and passengers and allowance made for impacts of Covid, global economic trends, increasing awareness and need for legislation to govern air travel’s climate impacts and shifts to how international business is conducted. It is likely that there will never be a need for any additional capacity at Gatwick and no need for the Northern Runway. ECONOMY AND JOBS (drawing on New Economics Foundation submission) The benefit-cost analysis should comply with latest TAG guidance. This includes revising the economic analysis so carbon appraisal values for traded and non-traded carbon emissions are valued equivalently and assessment of non-carbon effects included. Impacts of inbound flights should be included as they are changed as a result of the project. Sensitivity analysis should set out the economic impacts of not achieving the assumptions in Jet Zero High Ambition scenario or underpinning the Transport Decarbonisation Strategy. Analysis should assess the impact of induced increases in road transport movements associated with highway investments. The user (passenger) benefits appear overstated compared to earlier estimates by the Department of Transport (2017) and the Airports Commission, particularly the 90% of benefits estimated from business passengers. Gatwick assumes a significant increase in business travel, whereas CAA surveys and IAG’s statements show a reduced share of business travel post-Covid: still less than the 2006 peak. Sensitivity analysis and up-to-date aviation evidence should be provided to support the claimed uplift due to “output change in imperfectly competitive markets” as required by TAG. Analysis should distinguish how much business travel: benefits UK against non-UK residents, is displaced from other UK airports; is constrained (as opposed to leisure travel) in the baseline case. The negative impact of the increased UK tourism deficit from expansion, described as a ‘key diagnostic tests’ by the DfT (2018) should be estimated and included. CLIMATE CHANGE The submission understates the increased carbon emissions and underplays its significance. This is the largest planned increase in aviation-related emissions since approval of the UK Climate Change Act (2008). If expansion were permitted Gatwick alone would be responsible for over 3-5% of the UK’s sixth carbon budget, with or without Jet Zero mitigations. Approval would require government to ignore the Climate Change Committee’s 2023 Progress Review recommendation to not permit any airport expansion without a UK-wide capacity-management framework being in place. Gatwick should assess the cumulative impact of its plans against the global 1.5 ° climate limit and the UK government’s legal requirement to reach net zero by 2050. Gatwick needs to explain how expanding one of the hardest to decarbonise sectors of the economy is consistent with the radical decarbonisation required across all sectors to meet net zero. Gatwick must explain why it believes it is acceptable to expand to 80 mppa, which is inconsistent with the Making Best Use of Existing Runways policy. Later Jet Zero modelling assumes further capacity growth but lower emissions based on optimistic assumptions that are incompatible with climate limits, and subject to legal challenge. Gatwick’s submission should include the non-carbon impact of flying and overall climate impact of airport expansion (including inbound international flights which will increase emissions overseas). It is disingenuous to treat these as zero, in breach of the Precautionary Principle. In conclusion, no airport expansions should proceed until a UK-wide capacity management framework is in place to annually assess and, if required, control sector CO2 emissions and non-CO2 effects. WATER AND FLOODING The SESW’s water supply assessment should include identifying source(s) of additional water extraction, and its impact on water neutrality. This should assess impacts of extraction from aquifers and surface water, for water supply and biodiversity. Thames Water’s assessment should set out how increased foul and surface water impacts: Horley and Crawley SWTs; outflows into the river (including indirectly, via sewage treatment plants); and/or other pollution incidents. Both are required in advance so they are fully reflected in the EIA. The DCO should then clearly set out the measures required to restore the river Mole’s poor and declining water quality and reduce flood risk. This should include addressing impacts of existing road/parking run-off pollution and large volume outflows from firefighting on water quality. Monitoring of outfalls and diffuse pollution should be strengthened. Gatwick should not be allowed to understate the climate impact on flooding by selecting a shorter (40-year) runway design life. The full flood risk must be modelled, and mitigated. The impact of empirical date on how climate change is already increasing the frequency and severity of flooding must be fully assessed. AIR QUALITY The confidence of modelling projected for future years is severely undermined by substantial inaccuracies in modelled air quality concentrations (particularly NO2), demonstrated by the necessitated crude adjustments to align to the 2018 monitoring. Independent statistical review should assess the assumptions and adjustments to align the model to monitoring data. The modelling should therefore not be used to show that future impacts are not significant without: substantially increasing monitoring (frequency, locations); regular reviews of emissions inventories, assumptions; and revisions of the year-by-year air quality modelling. This must enable air quality impacts of the modelled baseline and superimposed project to be reassessed and refined. If the expansion is allowed conditions such as listed below should be put in place. • Ban on night flights. • Incentivising airlines to use the quietest aircraft. • Payments to local councils for roads and other infrastructure costs occasioned by the airport expansion. • Releasing the land outside of the current airport boundary currently held to build a second main runway. • No further expansion of the airport boundary. • No landings to be allowed routinely on the northern runway. • Dispersal of flight paths. • The impact on the value of people’s homes impacted by the increase in flights and the widening/moving of noise envelopes, should be compensated by GAL. in the same way that the DOT would compensate homeowners for noise blight when building a new motorway.