Greg submitted his response to Gatwick's proposals to bring its emergency runway into routine use today.
In his letter, submitted as part of the airport's consultation on the project, Greg highlighted the three main areas of concern that have led him to object to Gatwick's plan.
- The increase in aircraft noise resulting from a greater number of overhead flights.
- The failure to reinstate the Tunbridge Wells to Gatwick rail service as part of the proposals.
- The environmental impact of more frequent flights.
Addressing his letter to Stewart Wingate, the Chief Executive Officer at Gatwick, Greg said:
I am writing to put on record my strong objection to Gatwick’s proposals to deploy its reserve runway for routine use.
Like most of my constituents, I want Gatwick to be successful. Many of my constituents use the airport for business and leisure travel, and some are employed directly or indirectly by the airport, airlines or other businesses that depend on it.
But recognising the value of a convenient airport does not mean that residents can be taken for granted and have to face the consequences that damage our quality of life and the environment.
The impact of aircraft noise on many of my constituents in Tunbridge Wells, Bidborough, Speldhurst, Langton Green, Rusthall, Ashurst, Groombridge and Southborough is already unacceptably high. As you know, for several years now I have been working with councillors and residents to improve this situation which significantly impairs the quality of life of many people.
This proposal, in seeking to make the impact of aircraft noise “no worse” than now, would bake in an existing level of nuisance that is already excessive.
Furthermore, the forecast of an impact that is “no worse” relies on a set of assumptions which may not be met, and if they are not, could make the conditions suffered by my constituents even worse than they are now.
The assumptions are that quieter engines during the decades ahead will allow more noise to be generated by more planes. But this means that, unlike residents under the flightpaths of other airports in the country, people under the Gatwick flight paths would not reap the benefit of any such advances in technology – the skies would not become quieter, because gains would be cancelled out by increased air traffic.
I am particularly concerned by the assumption in Gatwick’s analysis that (uncertain) reductions in the noise of some aircraft offset a 35% increase in the number of air traffic movements.
It is important to be clear that an increase in the frequency of aeroplane movements overflying an area makes a big negative difference to quality of life – noise goes from being frequent to being more or less constant, even if the ‘average’ number of decibels in a 24-hour period were to be less (though that cannot be relied upon).
The Consultation Document admits that what is proposed is an intensification of overflying, stating: “Consequently, any noise impacts of the Project would largely be the result of increases in noise due to the increased number of flights on the northern runway, rather than new noise impacts over areas previously unaffected.”
To add insult to injury, there are no commitments to provide new infrastructure which would allow Tunbridge Wells residents to access the increased number of flights that would overfly our homes. Until 2008 it was possible to travel from Tunbridge Wells, High Brooms and Tonbridge directly to Gatwick Airport station by train. This saved money for car parking or taxis, and saved CO2 emissions. It has been a source of great frustration that the ability to travel frequently and reliably by train has been removed. In this context it is astonishing that Gatwick would seek to expand flights by 35% without making any plans or investment available in restoring train links.
Had Gatwick established a track record in reducing overflying across the residential communities in my constituency, I and my residents may have appraised these plans with greater sympathy. But the opposite has been the case, Gatwick has shown no serious intention of alleviating the discomfort of thousands of my residents, and it should first address the existing noise problems from its operations over Tunbridge Wells rather than seeking to increase the volume of flights.
The answers to your specific consultation questions are as follows:
- Northern Runway proposals: overall
Q. We are proposing to bring the existing Northern Runway into routine use alongside our Main Runway. Enabling dual runway operations and supporting increased passenger numbers at Gatwick would involve other changes, including to airport infrastructure and some surrounding roads. We have included proposals to mitigate the effects of the Northern Runway Project and maximise the benefits, especially to local economic growth and new jobs.
To what extent do you support or oppose our proposals to bring the existing Northern Runway into routine use?
Answer: Strongly Oppose
Please explain your views
I strongly oppose Gatwick’s proposals. The Government has made clear, following the publication of the Davies review in 2015, that the focus of airport expansion in the South East should be at Heathrow, where there is capacity for more than 280,000 flights per year should the third runway be built. This satisfies any future regional growth requirement.
The impact of the Covid19 pandemic and greater use of virtual communications has reduced the need for travel, while there is growing concern in our communities about reducing carbon emissions. I believe this will reduce demand for air travel.
Gatwick Airport has also failed to demonstrate a need for additional capacity and that the project would have net employment or economic benefits. Expansion would result in more noise, more road and rail congestion and worse air quality for properties under flight paths.
2. Economic benefits: jobs and skills
Q. We are proposing a number of measures designed to maximise employment and skills benefits resulting from the Northern Runway Project. Do you think we could do anything more - or differently - to maximise local and regional employment and skills benefits?
The volatile nature of the aviation industry, as demonstrated during the 2008 recession and Covid19 pandemic, means economic gain is limited during times of reduced demand for travel.
Oxera, Gatwick Airport’s consultants, state that they do not expect the proposed scheme to result in material net job creation at the national level. This work has also provided no detail of any evidence linking air travel growth with employment growth, while also failing to recognize that the job intensity of aviation has been falling for more than a decade given the drive to automate jobs at the airport.
In addition, the failure to ensure new travel links to and from the airport, particularly to the east and west, mean local and regional employment prospects in my constituency are limited.
3. Economic benefits: business and the economy
Q. We are proposing a number of measures designed to maximise benefits to business and the economy resulting from the Northern Runway Project. Do you think we could do anything more - or differently - to maximise benefits to business and the economy?
Gatwick’s documents assumed that Covid19 will not have an impact on long-term passenger demand. There is also an assumption of an extra 1.5 million business passengers from 2032 onwards, which I believe is unrealistic given the changes to working patterns. I am also concerned about the lack of commitment to green, sustainable jobs that will aid the Government to meet its climate objectives.
4. Airport supporting facilities
Q. We would need to change or relocate some facilities to accommodate the proposed alterations to the existing Northern Runway. Some new, additional facilities would also be needed. These changes would be largely within the current airport boundary. The current Central Area Recycling Enclosure (CARE) facilities would be relocated. We are considering two potential locations for the CARE.
1. Option 1: to the north of the cargo hall
2. Option 2: to the north west of the proposed Pier 7
Please explain your views.
5. Landscape and ecology
Q. Our proposals include keeping green space wherever possible, protection of important environmental and community assets, improved landscaping, provision of public open space and footpaths, and the creation of new habitats. What are your views on our landscape and ecological proposals?
Although the development will have no physical impact on my constituency, I am concerned that no reference is made to the Environment Act 2021 and the requirement for biodiversity net gain arising from the development.
6. Land use: overall
Q. We have aimed to develop the Northern Runway Project largely within the current footprint of the airport to minimise disruption to our neighbours and make efficient use of our land. Where we are planning to use land temporarily during construction, we are also proposing to restore it to its previous use once construction is complete. What are your views on our approach to land use?
7. Getting to and from the airport: our approach
Q. Almost half of Gatwick’s passengers already use sustainable modes of transport to get to the airport. To support the Northern Runway proposals, our transport strategy aims to continue increasing the overall share of passengers using public transport to get to and from the airport, deliver improvements to local highways and junctions, and encourage greater use of public transport and active modes by our staff. Do you think we could do things better, or differently, to ensure all passengers and staff have appropriate choices for accessing the airport?
Despite plans to increase the use of sustainable transport by passengers and staff, Gatwick proposes a series of highways improvements and additional 25,000 car parking opportunities. The total number of passengers driving by car would increase almost 40% between 2019 and 2047. Given Gatwick made a commitment to achieving 60% sustainable transport by 2030, this would remain unfulfilled by 2047.
Transport behaviour by passengers and staff remains unpredictable following Covid19 pandemic, but despite the additional highway improvements proposed there remains little detail around the public transport improvements proposed.
There is no commitment to additional services with local bus operators and there is no commitment to introducing new direct services by rail, especially the reintroduction of a direct rail service to Tunbridge Wells.
Consequently, I am of the firm view that the proposed transport mitigations are insufficient given there is no ambition to increase the figure of 42% of passengers who access the airport by rail.
8. Road improvements
Q. We propose to significantly enhance the roundabouts at North Terminal and South Terminal (including by raising the M23 Spur/ Airport Way to take through-traffic above the existing roundabout) as well as improving Longbridge Roundabout by widening lanes to provide extra capacity. These improvements are necessary even with our strategy to promote the use of public transport and will cater for both airport and general traffic growth. What are your views on our proposals to improve local junctions to support airport growth as well as provide capacity for local traffic? Please specify the improvements to which your comments refer.
I am of the view that too much weight is being placed on local road links, over the need for better rail and other public transport links to the airport.
9. Public and sustainable transport
Q. Our proposed target of 60% of journeys by sustainable transport to and from the airport by 2030 would be the highest for a major UK airport. We are proposing measures both to encourage public transport use and discourage unnecessary use of private cars by both passengers and staff. For our employees this includes promoting cycling and walking, car sharing and using zero emission vehicles where travelling by car is the only option. This describes our overall approach but there are specific things we propose in some areas, for example around Crawley and Horley. What are your views on how our proposals for increasing use of public and sustainable transport apply in your area? Please specify the proposals to which your comments refer and tell us if there are other things we could do that would be relevant to your journeys.
Gatwick’s proposed increase in passenger numbers significantly outweighs the proposed increase in sustainable travel use. As referred to above, the plans for sustainable public travel for the additional tens of millions of passengers are unambitious and insufficient.
10. Construction: managing impacts
Q. We are committed to being a good and responsible neighbour throughout the construction phase, giving consideration to both the local community and managing the environmental impacts of construction activity. While still to be finalised, we have included indicative details of anticipated construction methods, timings and phasing. These will be refined throughout the Environmental Impact Assessment process, but we will seek to incorporate best practices. Are there any particular measures or activities for managing construction impacts that you would like us to consider including in our proposals as construction details are defined?
The M23, recently made a Smart Motorway, is due to be at capacity by 2040, before Gatwick expansion is even considered. This could result in traffic from
my constituency being forced onto minor roads that are unsuitable for increased volumes.
A new station will have an impact on the capacity, but this is not for the benefit of passengers travelling from Tunbridge Wells.
11. Construction: transport
We are proposing a package of measures to manage construction related traffic following best practice. This includes the routes vehicles take, the time they travel and measures to reduce the number of vehicles by re-using materials on site as much as possible. Our aim is to minimise the impacts of construction on local roads, keeping traffic on the strategic road network wherever possible. What are your views on our construction transport proposals?
See answer to question 10
12. Managing and mitigating effects: climate change and carbon
Q. We are proposing to mitigate increased greenhouse gas emissions associated with the Northern Runway Project with improvements in design and other measures. We are also developing a Carbon and Climate Change Action Plan that will demonstrate how we will continue to reduce carbon emissions from the airport and ensure Gatwick does not compromise the net zero UK carbon target. Do you have any comments on our approach or suggestions for specific measures to be incorporated into the Action Plan?
If consent is granted then CO2 emissions from Gatwick will be 50% higher than they are at the moment. It would mean that emissions attributable to Gatwick would grow from less than 10% of the total UK emissions in 2018, to over 5.5% of the total recommended UK emissions in 2038.
The documents acknowledge that there are currently no proven measures which can be taken by the industry which would better mitigate emissions, with electric and hydrogen aircraft likely not to make a significant impact for at least two decades.
The Transport Decarbonisation Plan commits to achieving net zero aviation by 2050, but there is no detail about how Gatwick will achieve this with its proposals for expansion. There is also no detail about the non-CO2 climate impacts of its proposed growth, or detail about whether a reduction trajectory is possible and can be independently enforced.
13. Managing and mitigating effects: noise envelope
Q. We are proposing to introduce a ‘noise envelope’ to set limits on noise from future operations at Gatwick. The noise envelope would come into effect at the start of a dual runway operation, giving residents certainty that the noise limits it prescribes would not be exceeded. This envelope would then be tightened in the future, giving residents further certainty that air noise levels would have to be lower than they were in 2019 for the full capacity of the Northern Runway Project to be realised.
Do you think the proposed noise envelope is:
Please explain your views.
Gatwick’s analysis of noise impacts of its proposed expansion is misleading. Its noise envelope is inconsistent with CAA guidance and the metrics and limits do not comply with Government policy and lack adequate enforcement arrangements.
14. Managing and mitigating effects: noise mitigation
Q. In addition to the Noise Envelope, we are proposing other measures to mitigate the noise effects associated with the Northern Runway Project, including an enhanced Noise Insulation Scheme, the noise envelope, a new noise barrier at the western end of the Northern Runway, and noise barriers to support changes to the highway network. What are your views on our approach to noise mitigation? Please specify the measures to which your comments refer.
I am concerned that while Gatwick has plans to mitigate the impact of noise upon residents within the Leq 8hr night 55dB and Leq 16hr 54Db noise contours, this is the extent of noise mitigation. I represent communities significantly further away that are also affected by noise arising from aircraft overflights. This means the plans will result in a worsening of aircraft noise for residents and businesses who will not be eligible to benefit from the noise insulation scheme but will still see increases in the number of overhead flights.
15. Consultation process
For this consultation we have made details of our proposals available in a number of ways, including in hard copy documents, on our project website, in a virtual exhibition and by providing opportunities to speak to members of the team. We welcome your feedback on how you have found the consultation process. Please let us know if you have any comments about the consultation process.
With best wishes