Representation by Charles William Drake
- Date submitted
- 19 November 2023
- Submitted by
- Members of the public/businesses
I live under the flight path. The UK parliament's own Climate Change Committee has said there should be no expansion of airport capacity until flying can be sustainable. There is no prospect of that being the case. 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.