Representation by Lee Howes Dip FD MBIFD MICRS MRAeS MIoL MNI
- Date submitted
- 15 November 2023
- Submitted by
- Members of the public/businesses
INTRODUCTION While the idea of using Gatwick Airport's standby runway full time may seem like a way to increase capacity and efficiency, it's important to consider the significant drawbacks of such a move. Gatwick has, and always will remain, the ‘number 2’ airport. Despite its claims to the contrary, it is filled predominantly by low cost carriers and those airlines that cannot get into Heathrow. In terms of its infrastructure it is ageing and it doesn’t offer the sense of ‘place’ that other significant airports offer. Allowing the airport to bring the standby runway into use will not resolve the ‘issue’ with airport capacity and other options relating to national transportation infrastructure should be considered. A SUB-OPTIMAL CONCEPT This concept has and always will be seen as a sub-optimal solution to the question of airport capacity. It benefits no-one apart from the airport’s majority owners who are seeking to recoup their inflated purchase price for to asset prior to the Covid-19 Pandemic. The Airports Commission was unequivocal in its findings regarding where additional airport capacity should be located. That said, given the UK is in a climate emergency, any increase in airport capacity must be challenged in light of the UK’s national and international obligations. Instead of expanding Gatwick through the standby runway, it may be more prudent to explore alternative solutions such as investing in high-speed rail connections between airports, development of rail infrastructure and making public transport affordable. The routine use of the standby runway at Gatwick to address airport capacity issues is a suboptimal remedy that presents environmental, efficiency, public opinion, and economic concerns. A more comprehensive evaluation of alternative solutions and their long-term impacts on national transportation infrastructure is warranted to ensure a well-informed decision regarding airport expansion. A FAIT ACCOMPLI Upon consulting the documents that Gatwick Airport Ltd has issued in support of this proposal and it’s communications prior to it, the airport has seemingly felt that this proposal is a ‘fait accompli’ given the fact it falls rather nicely into the governments fudge of “making best use of existing assets”. It is a matter of note that all of the local authorities have written to the CEO of Gatwick Airport Ltd expressing their “continued concern” about the approach the airport has taken in respect of engagement and consultation. This is probably due to the fact that Gatwick Airport Ltd will want to conduct these activities on a shoestring and feels it is unnecessary to engage and consult widely given their collective believe this proposal is ‘in the bag’ given the aforementioned government policy. It is a damning indictment on the airport that not only have its local authorities raised their concerns over the inadequate consultation and engagement plan, but all local Members of Parliament too have expressed their concern that “We are therefore veryconcerned to have been informed by by the ten Councils involved in the DCO process that they are unable to advise MPs of what the impacts may be, because their specialist advisers have not been able to assess them.” In usual circumstances, the scheme proposer would ensure local authorities are provided with sufficient financing to allow those authorities to scrutinise all documentation fully and if needs be, appoint external resource. Gatwick Airport Ltd had offered a paltry sum and therefore requires all taxpayers in the area surrounding the airport to pay for this. Once again Gatwick Airport Ltd is doing the absolute bare minimum in order to extract maximum gains. This is not how a business that considers itself to be a good and considerate neighbour conducts itself. NEGATIVE LOCAL CONSEQUENCES Utilising the standby runway full time would lead to a host of negative consequences, including environmental damage, increased noise pollution for nearby communities, and the disruption of ecosystems. Additionally, it could place an excessive burden on local infrastructure, leading to traffic congestion and potential harm to the quality of life for those living in the surrounding areas. Therefore, we must carefully weigh the potential benefits against the severe and far-reaching impacts before embracing this idea. LACKING IN COMMUNITY ENGAGEMENT Gatwick has never satisfactorily proven it is a force for good in the local community. The airport has grown significantly during the period since it was divested from BAA Airports Ltd however its investment in meaningful community relations and the concept of ‘banked goodwill’ has failed to materialise as it only engages when it wants something and tells local stakeholders why they should support it; plainly speaking, it has a woeful track record in managing community concerns with its operations. It he routine use of the standby runway at Gatwick to address airport capacity issues is a suboptimal remedy that presents environmental, efficiency, public opinion, and economic concerns. A more comprehensive evaluation of alternative solutions and their long-term impacts on the South East’s transportation infrastructure is warranted to ensure a well-informed decision regarding airport expansion. NOISE REMAINS AN UNRESOLVED ISSUE It is a matter of fact that its second iteration of its much vaunted Noise Management Board has, in common with the first iteration, failed miserably in its objective, presumably due to the fact that Gatwick Airport Ltd will not countenance anything that will affect flight numbers and revenue streams. While Gatwick Airport Ltd refuses to compromise on flight numbers, this will remain an issue. SHARING THE BENEFITS Gatwick Airport Ltd has also failed to set out how it will share the benefits of its increased use with local communities. It is suggested that a community levy should be imposed on all seats sold operating out of the airport that can be independently administered to benefit local initiatives. This levy would replace S106 monies, community funding and grants and could be used for funding access improvements, acoustic insulation, property blight schemes, independent environmental monitoring, public transport and awards and grants. The benefit of such a scheme is that if passenger numbers increase, so does the funding and where the reverse happens, such as during the Covid-19 Pandemic then the funding reduces accordingly. Should Gatwick Airport Ltd opt to implement such a scheme it would demonstrate once and for all how it takes its responsibilities to its local communities seriously. BIODIVERSITY ON THE AIRFIELD The area surrounding Gatwick Airport and indeed significant parts of the airport estate hosts a diverse range of ecosystems, including woodlands, grasslands, wetlands, and water bodies. Expanding airport operations, especially with the routine use of the second runway, poses a severe threat to these ecosystems, disrupting local flora and fauna. The plans will result in habitat destruction and fragmentation, which may harm wildlife populations. Many species of birds, insects, and mammals inhabit these areas, and the disruption of their habitats could result in local extinctions and imbalances in the ecosystem. The Gatwick area is home to several species of conservation concern, including bats and amphibians. The expansion could breach legal obligations for the protection of these species and their habitats, potentially leading to legal complications and environmental damage. Airport expansion is often associated with increased noise and light pollution, which can have detrimental effects on nocturnal and diurnal wildlife. These disturbances can disrupt breeding, feeding, and migration patterns, further impacting local biodiversity. Increased airport activity can lead to soil and water pollution due to runoff from runways and other paved surfaces. This pollution poses a risk to aquatic ecosystems, including streams, rivers, and ponds, affecting water quality and the species that rely on these habitats. WATER AND FLOODING The proposed expansion of Gatwick Airport by bringing the standby runway into routine use should be reconsidered and potentially halted due to the significant flood risk it poses. The region surrounding the airport is prone to flooding, and any expansion would likely exacerbate this issue. Increased urbanisation and construction, as a result of the expansion, may reduce natural drainage areas and increase surface water runoff, leading to a higher risk of flooding for both the airport and the surrounding communities. This flood risk raises serious concerns about the safety and sustainability of the expansion project, urging a thorough assessment of its potential impact on local flood vulnerabilities. It is a material fact that Gatwick Airport is constructed on a flood plain with no less than three significant watercourses in close proximity to it. As was witnessed over the Christmas Eve of 2013, the significant flooding of the aerodrome proved without doubt the vulnerability of this site to flooding. With the changes to the climate in the UK associated with climate change already materialising, such ‘freak’ flood events will become even more commonplace and given the fact that the airport estate isn’t increasing by any significant degree as part of this proposal, the ability of it to manage its surface run-off in times of prolonged heavy rainfall will reduce. DECENT HOMES Bringing the standby runway at Gatwick Airport into routine use is a concerning proposal, primarily due to the pressing issues of inadequate decent homes, strained public services, and underdeveloped key infrastructure in the region. A worrying trend in the area is the conversion of office buildings into residential dwellings, these sun-optimal conversations are indicative of a housing market where there is excessive demand than there is supply and such converted buildings could easily be classed as the slums of the future as they are located in non residential areas and the main building fabric was never designed to residential standards. Before considering increased aircraft movements and passenger figures at Gatwick Airport and the level of additional jobs it is claimed this will create , it's essential to address these fundamental needs: A significant portion of the local population struggles with finding suitable and affordable housing. The expansion of Gatwick Airport via using the standby runway full time could exacerbate the housing crisis, driving up property prices and rents, making it even harder for families to secure decent and affordable homes. PUBLIC SERVICES The area around Gatwick Airport is grappling with a stretched and overburdened state of public services. Rapid population growth and increased economic activity, including the airport's operations, have placed significant demands on services such as healthcare, education, transportation, and public infrastructure. The resulting strain on public services has created challenges, including longer waiting times, overcrowded schools, and congested transportation networks. Addressing these issues is crucial for maintaining the quality of life for residents and ensuring the sustainable development of the region. SURFACE ACCESS The existing infrastructure, including roads and public transport networks, is insufficient to accommodate the increased traffic and demands an expanded airport would bring. This could lead to congestion, longer commute times, and overall reduced quality of life for residents. Before these plans are considered, it is crucial for the government and local authorities to prioritise addressing these pressing issues. For long enough Gatwick Airport Ltd had benefited from public works without having to fully finance these works itself. Examples include the smart motorway on the M23, the station redevelopment at the airport and rail upgrades. If Gatwick is to become ‘bigger’ then the benefit of all of these measures is lost. Sustainable development that balances the economic benefits of the airport with the well-being and quality of life of the local community should be and must be the primary focus. GATWICK IS TOO COMPLEX Gatwick's existing single runway is known for its operational complexity, and the addition of another runway irrespective of when or how it is operated will further increase what is already a complex operation. Ideally, airport infrastructure should be made simpler not more complex. Operating two runways full time introduces complexities in scheduling, maintenance, and emergency procedures. It is imperative to thoroughly assess how Gatwick can effectively manage these challenges without compromising safety and efficiency. Gatwick Airport Ltd believes this scheme offers a way to increase capacity and efficiency, it does however pose significant concerns regarding the airport's already complex operations and the overall flying experience. As it stands today, the airport is complex for air pilots in terms of high frequency operations, airfield congestion, ATC procedures and noise abatement measures. Expanding Gatwick's operations by utilising the standby runway full time will undoubtedly lead to an increase in air traffic. This heightened complexity may exacerbate congestion, resulting in longer waiting times for takeoff and landing. For passengers, this means more time spent in the air or on the ground, which could negatively impact the overall travel experience. From a local perspective, it is ambiguous if the levels or go-arounds are attributable to the current complex nature of the airspace and aerodrome operations. Some people assert that Gatwick is making runway declarations that bear no resemblance to reality and that they are trying to accommodate more aircraft movements than what is achievable in real life. RESIDENTIAL AREAS Gatwick is situated in a region with significant residential areas nearby, areas of outstanding natural beauty, visitor attractions and the South Downs National Park. Increasing air traffic with the standby runway will invariably result in heightened noise pollution, negatively affecting the quality of life for local residents. Despite the talk of noise envelopes, fair and equitable dispersal, the use precision navigation and noise contours, it is an absolute fact that the tolerance of people to noise intrusion is decreasing more rapidly than the aircraft are becoming quieter. Moreover, the environmental impact of increased flights in terms of health, physical and mental both now and in the future must be considered. Gatwick's operations already have a significant impact on the quality of life of nearby communities, including issues related to noise, air quality, and traffic congestion. The full-time use of the standby runway would only intensify these problems, potentially causing local residents to bear the brunt of the airport's expansion. RESILIENT ATC NETWORK Expanding an airport is only part of the overall picture of increasing capacity. The other key player is the airspace aloft. For many years there has been pinch points in the air traffic networks in Europe that have knock on effects to UK airports and for an expanded Gatwick to function the airspace would require a significant redesign, something that is extremely contentious and difficult to implement. Until there is sufficient resilience in the air traffic system where there is minimal use of flow rates and aircraft running late into the night period, it is difficult to see how an expanded Gatwick would be able to maintain a stable operation where night flights are minimised. CARBON Using the standby runway at Gatwick in a full-time capacity indeed raises concerns regarding the UK's carbon emissions policy. The aviation industry is a significant contributor to carbon emissions, and any expansion of airport operations, such as using the standby runway full time, would likely lead to an increase in greenhouse gas emissions. This goes against the UK's climate change commitments and efforts to reduce emissions. The UK has set ambitious climate targets, aiming to achieve net-zero carbon emissions by 2050. Expanding airport operations at Gatwick without addressing the associated increase in emissions could hinder progress toward these targets. Gatwick can claim it is carbon neutral as it has pulled out its cheque book and paid to offset its own Scopes 1&2 carbon but it should set out a legally binding plan what it intends to regarding the carbon emissions from its Scope 3 emissions; the aircraft landing, taxiing and take off cycles. The aviation sector has a responsibility to play its part in mitigating climate change. The expansion of Gatwick, without implementing any robust measures in advance, to prove it is a good corporate citizen and simply not implement ‘all the good stuff’ unless it gets this proposal passed, may appear contradictory to the UK's commitment to environmental responsibility. As environmental concerns become more prominent, public opinion increasingly supports sustainable and eco-friendly practices. Expanding Gatwick's operations in a manner that could contribute to increased carbon emissions may face opposition from environmentally conscious citizens. The UK is a signatory to international agreements aiming to reduce carbon emissions from aviation. Expanding Gatwick's operations without addressing carbon emissions could result in non-compliance with these agreements. Using Gatwick's standby runway in a manner that leads to increased carbon emissions is not aligned with the UK's carbon emissions policy and climate commitments. Any expansion at Gatwick should be carefully evaluated and accompanied by measures to mitigate its environmental impact and adhere to the country's carbon reduction goals. THE EXAMPLE SET BY THE FRENCH It is somewhat ironic that these proposals are being perused at a time where the airport is majority French owned. This is because the French government has taken the bold step to ban domestic flights in certain circumstances. This ban covers those flights where the journey could be done by train in less than two and a half hours. If such an approach were adopted in the UK then maybe expansion would never be needed. JOB CREATION The proposed expansion of Gatwick Airport by bringing the standby runway into routine use has been met with varying opinions and expectations regarding job creation. While the expansion may indeed generate employment opportunities, it is essential to critically assess the quality of these jobs. Will these jobs be high-quality, well-compensated positions or will they primarily be low-paid, precarious, zero-hours contracts? The expansion of Gatwick Airport is expected to create jobs, particularly in areas such as aviation, ground services, and hospitality. However, the sheer quantity of jobs does not necessarily guarantee quality. The concern is that many of these positions may be low-paid, offer limited job security, and lack adequate benefits. Zero-hours contracts have become synonymous with precarious employment, offering little stability and often low pay. There is a growing concern that the expansion of Gatwick could lead to an increase in these types of contracts within the aviation and service sectors, leaving workers in a vulnerable position. The nature of jobs created at Gatwick is critical. High-skilled, well-paying positions in areas like aviation and engineering are essential for local workforce development. The question is whether the expansion will prioritise these higher-skilled roles or predominantly create entry-level, low-wage positions. An expansion that results in a higher number of low-paid jobs could have adverse effects on the local economy. Workers with limited disposable income are less likely to stimulate local businesses and contribute to the region’s economic growth. Gatwick Airport, as a major employer, should consider its social responsibility. Creating high-quality, stable jobs with fair compensation and benefits reflects positively on the airport’s commitment to the well-being of its workforce and the local community. AVIATION IS A MARKET FAILURE Aviation is often considered a typical example of a market failure due to several inherent characteristics and challenges within the industry: Airlines and airports require significant infrastructure and investment in aircraft, terminals, and maintenance. These high fixed costs can lead to overcapacity in times of economic downturns, as airlines have already made substantial investments that they need to recover, even if it means operating flights at a loss. Aviation generates external costs, such as noise pollution, air pollution, and greenhouse gas emissions. These externalities are not typically considered in the price of air travel, leading to an overconsumption of flights. Passengers do not pay the full social cost of their travel, resulting in market inefficiencies. Many markets are dominated by a small number of airlines or even a single dominant carrier. This lack of competition can lead to monopolistic behavior, resulting in higher prices, lower quality of service, and reduced consumer choice. The aviation industry is highly cyclical and sensitive to economic fluctuations. During economic downturns, airlines often reduce capacity, leading to job losses and reduced connectivity, while during economic upturns, they expand capacity quickly, potentially leading to overcapacity in the long term. Passengers often lack complete information about the true cost and quality of airline services. This information asymmetry can lead to suboptimal consumer choices. Demand for air travel is often inelastic, meaning that changes in price have a relatively small impact on the quantity demanded. This can lead to airlines charging high prices without a significant loss of passengers, resulting in consumer welfare loss. Airports and air traffic control systems are often publicly owned and operated or are heavily regulated, introducing complexities and inefficiencies into the market. Airport capacity constraints can limit competition and hinder the efficient allocation of slots. Airlines often operate in hub-and-spoke networks, where the value of the network increases with the number of destinations served. This can make it challenging for new entrants to compete with established carriers, as they may not have access to the same extensive network. These characteristics collectively contribute to market failures within the aviation industry. Since 2008 Gatwick has seen a number of airlines operating at the airport go out of business. Government and regulatory bodies often need to intervene to address these issues, through measures like environmental regulations, competition policies, and subsidies to ensure the industry operates in a manner that best serves the public interest. TAXATION UK airlines not paying enough tax is a complex issue influenced by several factors, and the overall perception of their tax contributions can be a matter of debate. The aviation industry benefits from various tax exemptions and reduced tax rates on specific items like aviation fuel. These policies are often designed to stimulate economic activity and maintain the competitiveness of UK airports. However, critics argue that these incentives result in reduced tax revenue for the government. In the UK, domestic flights are exempt from VAT, while international flights are zero-rated. This means that passengers do not pay standard VAT rates on ticket purchases. While this benefits consumers, it can result in lower tax revenue compared to other industries that are subject to standard VAT rates. Like in many industries, tax avoidance can occur in the aviation sector. Some airlines and airport operators may engage in complex financial structures and international operations to minimise their tax liabilities, which can reduce their overall tax contributions. Airlines often use transfer pricing to allocate costs and profits across different countries and subsidiaries. This practice can be used to shift profits to lower-tax jurisdictions, reducing the tax payable in the UK. Exemptions for International Agreements: Many international agreements and conventions, such as the Chicago Convention, restrict the ability of countries to impose certain taxes on international air travel. While these agreements are important for international relations, they may limit the taxation options available to individual countries. The aviation industry operates on thin profit margins, and factors like intense competition, fluctuating fuel prices, and economic downturns can affect the financial health of airlines. In such circumstances, airlines may prioritise financial stability over tax payments. Governments may choose to offer tax incentives to airlines to encourage job creation and stimulate economic growth. The argument here is that the economic benefits of a thriving aviation industry, including employment opportunities and tourism, can outweigh the loss of tax revenue. There is an ongoing debate regarding imposing higher taxes on the aviation industry to address its environmental impact. Some argue that airlines should contribute more to environmental protection, while others believe it may hinder the industry’s growth. The perception of UK airlines not paying enough tax is a contentious issue. While there are valid economic and competitive reasons behind certain tax policies in the aviation industry, critics argue that the overall tax contribution may not align with the environmental and social costs associated with air travel. The balance between industry growth and tax revenue is a complex challenge that policymakers must carefully consider. GATWICK’S COMMITMENTS Any commitments made by Gatwick Airport Ltd as part of this process must be subject to scrutiny to assess its likely benefits and be legally enforceable. Furthermore there should be ongoing oversight of the environmental and societal impacts of the airport at the present time and any mitigation measures the airport of offering should this DCO application be passed should be implemented now. CONCLUSION In conclusion, this submission highlights a multitude of compelling reasons why Gatwick Airport should not be allowed to bring the standby runway into routine use. The expansion of the airport in this manner poses substantial concerns, including environmental impact, noise pollution, safety considerations, and the potential disruption to local communities. Preserving the environment and mitigating the harmful effects of aviation on climate change and biodiversity is of paramount importance. The expansion would risk exacerbating these issues, making it difficult for the region and the aviation industry to meet their environmental responsibilities. Furthermore, the proposed expansion could lead to increased noise pollution, jeopardising the quality of life for those residing near the airport. Safety issues, such as those associated with air traffic control and runway operations, must also be thoroughly addressed to prevent accidents and incidents. Balancing economic interests with the well-being of local communities and the environment is a challenge that policymakers must carefully navigate. In this case, the potential costs, risks, and implications of expanding Gatwick Airport by bringing the standby runway into routine use weigh heavily against the perceived benefits. The submission underscores the importance of safeguarding the long-term interests of all stakeholders and making informed, responsible decisions that prioritise sustainability, safety, and the quality of life for local communities.