Representation by Sophie Gordon
- Date submitted
- 19 November 2023
- Submitted by
- Members of the public/businesses
I am commenting as an individual, as a resident of Surrey. I fully support and endorse the comments made by Surrey Climate Commission and Gatwick Area Conservation Campaign (GACC), as outlined below. NEEDS CASE: The Airport National Policy Statement (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 Transport Analysis Guidance (TAG) . 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. The pay levels for new long-term jobs should be set out, and associated estimate of affordable housing demand for housing new lower-paid airport related jobs, against that for the current airport-related workforce. The impact of automation on future airport employment should be included, referencing historic trends. 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 around 5% of the UK’s carbon budget by 2038, subject to mitigations. Approving this DCO would require government to ignore its independent 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?C 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. The carbon emissions from additional surface transport journeys are not insignificant, and must be assessed separately against national road sector targets and policies, and local transport plans (LTP4) and climate strategies for Sussex and Surrey. Gatwick plans to reduce embodied carbon emissions for construction should be clearly set out, beyond the Carbon Action Plan’s high level target. This plan should include full surface access and flight emissions. Gatwick must set binding limits to constrain and reduce all GHG emissions associated with the airport. 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. 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: 1. 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. 2. Give communities certainty about future noise levels (APF para.3.29), contain any proposals to limit noise in the winter period, and allow future reviews to increase noise limits. 3. Incentivise airlines to introduce the quietest suitable aircraft as quickly as is reasonable. 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. 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. 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 (e.g. 2013/14 event) must be fully assessed. ECOLOGY: A landscape-scale approach is required to assess biodiversity impacts. This should address the effects on ecological networks in terms of habitat connectivity and function. For example, the loss of Riverside Garden Park on individual species (e.g. bats). This should include the overall impact on the surrounding landscape, including: fragmentation of habitat (e.g. by woodland removal); increased surface transport and its associated air pollution; and increased flood risk and any potential water extraction. Gatwick should confirm that BNG delivery is separate from and additional to requirements under the mitigation hierarchy, and will be fully implemented. The impact of the time lag between habitat loss and subsequent creation and maturity (e.g. woodland) and associated with the long construction period should be assessed and mitigated. Gatwick must clearly set out the type and total area of habitat being lost, delay in re-provision, subsequent mitigation and compensation, and on the proposed monitoring and management of newly created habitats. 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. TRANSPORT: 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). Gatwick should adopt mode share commitments without any increase in car use and all additional surface access via sustainable transport. 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 rail industry plans to accommodate rail demand growth without Gatwick expansion to 2029. No increased rail capacity is planned or funded. There should be clear proposals to prevent increased off-airport parking. Assuming the base distribution of off-airport parking spaces for all future scenarios is unrealistic. Sensitivity analysis of the impact of unconstrained (street, commercial) off-airport parking on the surface transport modelling should be completed. Proposals lack detail on facilities needed (e.g. parking, lockers, showers) for increased active transport and safety of the redirected Riverside Garden Park route. ASSOCIATED DEVELOPMENTS: The sufficiency of supporting infrastructure, including terminal facilities, needed to meet the forecast intensification of the current runway, and then use of the new runway is not assessed. The impact of building heights, particularly the new CARE facility incinerator (48m) and new hanger at the west of the site (32m). Lack of details to assess the impact of the ‘biomass boilers’ and air pollution from the CARE facility. Impact of net-zero on buildings and infrastructure. CONSTRUCTION IMPACTS: Lacks detail on: impacts of construction noise and their eligibility for insulation, access impacts (e.g. Woodroyd Avenue); and sequencing of construction works. The Outline Construction Management Plan, Material Transport Plan and Workforce Transport Plan are insufficient to support the statement that “No significant effects are likely to occur with respect to traffic and transport during construction and operation of the Project.”