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Representation by Keep Southwater Green (Keep Southwater Green)

Date submitted
19 November 2023
Submitted by
Non-statutory organisations
  1. The uninstrumented emergency/relief “northern runway” at Gatwick Airport is not a functioning operational runway and GAL’s application to make it one is therefore inconsistent with the Government’s aviation strategy of ‘making use of existing runways’, as well as with the National Policy Statement for Airports which states the Government’s approach is that any new runway for the South East of England should be at Heathrow Airport, not Gatwick. 2. The proposed expanison would be wholly incompatible with the UK’s commitments to reduce greenhouse gas emissions, which the Government’s own advisers on the Climate Change Committee have now warned cannot be achieved without curtailing airport expansion. It should be noted that though several new means of aircraft propulsion have been promoted as ‘Jet Zero’ alternatives to conventional aviation fuel, a recent report (‘Net Zero Aviation Fuels: Resource Requirements and Environmental Impacts’) by the Royal Society of Arts has found that none would offer a viable alternative for commercial airliners for the foreseeable future. 3. Increased air pollution would not only be generated by the additional flights themselves but by additional surface traffic travelling to and from the airport by road (a recent study by Imperial College showing there already to be dangerous exceedances). In its response to the 2022 Consultation, Horsham District Council (HDC) noted that ‘Clearly GAL anticipates a significant increase in traffic volumes accessing the Airport to justify such significant road improvements [in the Airport’s immediate vicinity] and it is therefore logical to conclude that adverse impacts may be experienced beyond the immediate locality into adjoining local authority areas, such as Horsham District, including key connecting routes and more rural roads’. 4. Although GAL claims that no new flightpaths would be needed as a consequence of using the “northern runway” and that airspace changes are not required to enable dual-runway use, HDC has pointed out that, due to the need to accommodate the growth at other airports across the South of England the increased use of the WIZAD SID 1 route will result in increased overflights of Horsham District. Updated WHO guidelines now warn that aviation noise can be harmful to community health at far lower decibel levels than previously recognised, and studies have found that in rural areas - such as those beyond Gatwick Airport – background noise can be intrusive at levels as low as 30 dB, so that increased flight movements across the sub-region would inevitably affect the well-being of many rural communities. 5. GAL claims its plans would add over £1 billion GVA to the local economy, but HDC has suggested that DfT comparisons show that GAL’s projected growth is almost double or 40% greater than the rate of aviation growth projected nationally 'implying a substantial increase in market share which would be at the expense of other airports and would need to be accounted for at the very least by displacement allowances in the economics assessment [but] beyond 2032 growth is slower than DfT’s assumed national growth rates [which] has the effect of bringing forward the benefits and skews the economic appraisal that is presented’.