HIGH WEALD COUNCILS AVIATION ACTION GROUP (HWCAAG) Gatwick Master Plan consultation The High Weald Councils Aviation Action Group (HWCAAG) came into existence in September 2013 in response to the significant increase in both the noise and frequency of aircraft movements into Gatwick Airport and the possibility of a second runway at Gatwick. It comprises twenty-three Parish and Town Councils representing some 90,000 people from across the area to the East and South East of Gatwick. All 23 member councils have voted and formally adopted a policy that wishes to see maximum dispersal of flights across the radar manoeuvring area on all flights at Gatwick. Dispersal within NPRs for departures and a ban on night flights. This response has been discussed and approved by our member councils. The most significant and troubling issue is that the masterplan takes no account of the need to balance growth with a commensurate reduction in environmental impact. The effect of 60 ATMs/hr and the process of “peak spread” will be to reduce the ability of air traffic controllers allow aircraft to join the ILS closer to the airport, and a far greater number and in a more concentrated pattern will join between the 10 and 12 nm points on the ILS. It also increases the chances of spill over from the day schedule into the night period. This is not acceptable. We support sustainable growth at the airport. 45 ATMs an hour would allow for maximum dispersal, and growth based on year round use. 60 ATMs is a planned permanent change to the distribution of noise around the airport. A full airspace change should be required. For those under the path of 60 ATMs Gatwick must protect them from noise impact and compensate residents for the disruption and loss of amenity in a manner consistent with other transport infrastructure compensation. The environmental impact has not been balanced with growth. Kent, where most councils we represent are based provides 7.4% of passengers, gets virtually no economic benefit from jobs at the airport and yet suffers 70% of all arrivals traffic with no compensation or mitigation of the effect. That is not a sustainable equation for us to be able to support future growth. The further growth anticipated by the use of the emergency runway will only exacerbate these issues and make the issue of environmental noise impact, lack of adequate surface access, and air pollution even harder to solve. Use of the emergency runway creates additional safety concerns; not least if the main runway is out of action. QUESTION 1 Given the above, to what extent, if at all, do you support or oppose the principle of growing Gatwick by making best use of the existing runways in line with Government policy? Before answering, you will find it useful to read Chapters 4 and 5 in the full version of the draft Master Plan. Strongly oppose It is misleading to frame the question in terms of a single principle. There is nothing wrong with the principle in itself, we strongly oppose the proposal because it is not aligned to other equally important principles, also in government policy, such as that growth should be accompanied by a commensurate reduction in noise, and that there should be a reduction in those significantly affected. These have not been met and are not addressed in the masterplan. The increase in intensity of use to 60 ATMs an hour and for that peak capacity to be spread through the day will bring increased concentration of flights over an extended period making an already unsustainable situation worse for residents living in those areas affected. QUESTION 2 Given the draft Master Plan looks out beyond 2030, to what extent, if at all, do you agree or disagree that land that has been safeguarded since 2006 should continue to be safeguarded for the future construction of an additional main runway? Before answering, you will find it useful to read Section 5.4 in the full version of the draft Master Plan. Strongly disagree We strongly oppose the use of this land for an additional runway. Now the UK has decided on a hub at Heathrow and spoke model for aviation it should be used for other purpose. QUESTION 3 What more, if anything, do you believe should be done to maximise the employment and economic benefits resulting from Gatwick’s continued growth? Before answering, you will find it useful to read Section 5.6 and Chapter 7 in the full version of the draft Master Plan. The Towns and Parishes HWCAAG represents provide a tiny percent of passengers and get negligible benefit from Gatwick as an employer. Yet they take the whole burden of noise from Westerly arrivals. With disbenefit being so much greater than the benefit of current or future growth we look to the airport to propose a scheme that adequately compensates residents for this planned change to the distribution of noise around the airport through growth. QUESTION 4 What more, if anything, do you think should be done to minimise the noise impacts of Gatwick’s continued growth? Before answering, you will find it useful to read Sections 4.5, 5.5, 6.4 and 6.5 in the full version of the draft Master Plan. Much more needs to be done to minimise the noise impacts. HWCAAG have proposed a multiple route PRNAV scheme to provide a fair and equitable distribution of the noise over the current swathe. The aim of that was to affect more people but to reduce the number significantly affected. The proposal in the masterplan will result in fewer residents affected due to greater levels of concentration but those who are affected will be much more severely, leading to a substantial increase in those significantly affected. This change combined with that made in 2013 constitutes a 35% increase in overflight. The true issue with the level of noise is masked by using an annual average metric. Gatwick should adhere to WHO organisation levels of noise and where it cannot meet those recommended levels then it should provide a noise protection scheme through noise insulation for homes, and compensation for loss of amenity. We note that noise metrics are now likely to include an LDen measure but the increased use of the runway at peak times does not reflect the greater nuisance of aircraft noise in the evening and at night. The reduced redundancy and consequent lack of resilience in the proposed schedule makes evening and night noise more likely. QUESTION 5 What more, if anything, do you think should be done to minimise the other environmental impacts of Gatwick’s continued growth? Before answering, you will find it useful to read Sections 4.5, 5.5 and Chapter 6 in the full version of the draft Master Plan. Climate scientists are currently warning of the very short window of opportunity to reduce carbon emissions and prevent permanent damage to the planet. The masterplan does not recognise the severity or the proximity of that threat. It only seeks to mitigate the symptoms of that change. That seems irresponsible. To be a responsible organisation not only Gatwick needs to be Carbon neutral, but also the services it facilitates. It needs to be playing a clearer role in helping the government meet its carbon targets. QUESTION 6 Do you believe our approach to community engagement, as described in the draft Master Plan, should be improved, and if so, how? Before answering, you will find it useful to read Chapter 8 in the full version of the draft Master Plan. Yes. Gatwick’s engagement strategy has been to set up new forums to engage with the public, but then fail to act on what they are told. A few years ago Gatwick published a document that described what it thought a good neighbour would do. Unfortunately, much like the Pharisee in the parable the airport continues to hear and see the impact without doing anything to mitigate or compensate those negatively affected. The communities are collateral damage in the requirement for growth with no appropriate provision for residents negatively impacted by aircraft noise. QUESTION 7 If you make use of Gatwick, what areas of the passenger experience would you like to see improved? No comment. QUESTION 8 Are there any aspects of our Surface Access Strategy that you believe should be improved and, if so, what are they? Before answering, you will find it useful to read Section 4.4 in the full version of the draft Master Plan. Surface access to Gatwick is poor. Whilst our communities are not directly affected many of our residents use the M23 and M25 and Southern rail routes to London for work and leisure on routes that are already at capacity. Growth at the airport is not sustainable without considerably better surface access. The M23, M25 and the Brighton main line are not suitable to carry the number of passengers that increased growth in the number of flights especially at peak times that the airport envisages. Many of the infrastructure improvements that are listed in the masterplan are designed to deal with the recent increase in passenger numbers rather than future increases. QUESTION 9 Do you have any other comments to make about the Gatwick Airport draft Master Plan? Yes. See introduction. QUESTION 10 Which, if any, of the following applies to you? None.
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