Response by GACC to the Gatwick Master Plan 2011

 Gatwick Airport produced its draft Master Plan on 13th October. The consultation lasts till 13th January. GACC, the Gatwick Area Conservation Campaign, has produced a thoughtful, well researched and hard-hitting response, picking out the many areas on which the master plan is deficient, where information is left out and where assumptions and forecasts are made which are unrealistic. The response highlights issues such as the absence of consideration given to rising oil prices, and to the amount of money taken out of the UK by holiday makers travelling abroad – the tourism deficit – which cuts UK tourism employment. It also questions dubious economic figures, for which the airport cannot produce evidence.



Draft Gatwick Master Plan  2011

Response from Gatwick Area Conservation Campaign


GACC is the main environmental body concerned with Gatwick airport.  Founded in 1968, we have around 100 Borough, District and Parish Councils and amenity and environmental groups as members.   They cover an area of around 20 miles radius from Gatwick.  Our committee, elected at our annual meeting, represents all areas.

We would like to congratulate Gatwick Airport Ltd (GAL) on producing a well written and well produced master plan.  The provision of a clear explanation of how it is envisaged that the airport will develop is welcome.  It is a remarkable achievement to assemble so much information in one document.

It is, however, deplorable that the expansion of the airport is forecast to mean more noise and more climate change damage.  That is contrary to the aim set out by the former Secretary for Transport, Philip Hammond:  “aviation should be able to grow, but to do so, it must be able to play its part in delivering our environmental goals and protecting the quality of life of local communities.”[1]

In this response we start with the subject of noise, as that is the issue of most importance to local residents;  thereafter our comments follow the order of the master plan. 

[Gatwick Master Plan consultation is at ]


The master plan is based on the aim of increasing the number of passengers to 40.5 million a year, with an increased number of flights, averaging an extra 117 flights a day. 

On page 80 (Fig 9.6) the master plan admits that the effect of the extra flights will be to increase the number of people within the 57 leq noise contour (serious community annoyance) from 3,100 to 4,952 – a 60% increase. 

It is also admitted that the total number within the 54 leq contour will rise from 9,050 to 12,363.  Many people outside the 54 leq contour are annoyed by aircraft noise, and their number is likely to increase in proportion.  So well over 12,000 people will suffer extra noise.

Yet these key facts are not included in the executive summary!  They are glossed over in the text, for example in paragraph 9.5.11. They are nowhere mentioned in the leaflet distributed to thousands of homes around the airport, nor in the exhibitions held in local towns. That is not the end of the deception:

In his introduction the Chief Executive Officer, Stewart Wingate, refers to the need for the airport to be trusted by the local communities.  We are amazed that, a week before the publication of the draft master plan, Stewart Wingate agreed a statement prepared by a local community group that:  “GAL [will] make aviation-related noise a key theme in the draft Master plan consultation.”[2]    

In their 2010 document ‘A decade of change’ GAL stated:  “With operational efficiencies come environmental efficiencies, so the better we manage our facilities, the smaller our environmental footprint will become.”  Now proved untrue.

In their Sustainability Strategy GAL stated:  “By 2020 our plan is to ….  Reduce the impact of operational noise.”   Now proved untrue.

Trust will not be earned by double-talk, by creating false hopes, and by concealing embarrassing facts.

The statement in the master plan (9.5.18) that the increases in noise levels are likely to be less than 1 decibel, and are ‘unlikely to be noticeable’, is misleading.  The 1 decibel refers to the leq level, that is to the noise averaged over a 16 hour day.  The actual noise from each of the 117 extra flights each day will, of course, be far higher.

We accept the point (9.5.19) that average noise levels are forecast to be only slightly higher than in 2004 or in 2007.  But for years people have been told that aircraft are getting quieter: indeed GAL, as a member of ‘Sustainable Aviation’, has signed up to a pledge that by 2020 new aircraft will cause 50% less noise than in 2000.   The Gatwick Airport Consultative Committee were told that the expansion can be achieved without extra noise.  It will therefore come as a shock to many to find that Gatwick noise is to get worse.

The forecast level of noise in 2020 shows that the much vaunted Noise Action Plan is inadequate.  It does contain a few useful measures to mitigate noise – which we welcome – but these are swamped by the increased number of flights. 

We request that in the revised master plan –

  • the increase in the number of people affected by noise should be included in the executive summary;
  •  paragraph 9.5.18 should be omitted;
  • a commitment should be made to provide more resources for the Flight Evaluation Unit in order to enable :
  1. a.     better responses to complaints – a real person, not an answer machine;  improved responses to regular complainants and to those seriously distressed by aircraft noise;
  2. b.     more, and more modern, mobile monitors; and
  3. c.     better analysis of the results from the mobile monitors to identify airlines which consistently make excessive noise, and to identify particular aircraft which cause unusually loud noise.

The forecast increase in noise adds strength to our recommendations for changes in national policy on aircraft noise  which we have made to the Department for Transport in response to the Scoping Document.  They are reproduced as Annex A.

We request that, in the revised master plan, GAL should express their support for all (or at least some) of these measures.

Ground noise .   We are disappointed to see on page 82 (Fig 9.7 and 9.8) that ground noise is forecast to increase substantially at sites 1 and 2 (Charlwood village) and at sites 7 and 8 (western edge of Horley), and that these increases will occur during the day, during the evening and at night, and when the airport is operating westerly or easterly.  The increases at night, an average of nearly 6 decibels in Charlwood, and 10 decibels in Horley Gardens Estate, are substantial.

The forecast increase in ground noise should be mentioned in the executive summary. 

The revised master plan should contain proposals, such as higher or extended earth bunds, or noise walls, or the re-arrangement of airport buildings, to prevent the deterioration in ground noise.

Traffic forecasts

We note the prediction (4.2.9) that the number of passengers will rise to 40.5 million in 2020/21 (with a range between 36.5 million and 43.2 million).  It would be helpful if the master plan could indicate whether this is a commercial aspiration or a purely statistical forecast.

In fact it matches the statistical forecast made by the Department for Transport but we have told the Department that their forecast may well be over-optimistic for several reasons:

  • the cost of oil may rise. It would be helpful if the revised master plan could state the assumption about the future oil price on which GAL base their forecasts;
  • action may be taken by the Government or internationally to limit the growth of air travel for climate change reasons;
  • the world recession may prove prolonged – and indeed this is recognised in the master plan low case forecast..

We note the statement (4.2.9) that ‘Gatwick has sufficient runway capacity until around 2023/24 …”   We suggest that the revised master plan should also include a reference to the DfT forecast that the London airports will not be full until 2030.

It is stated (Fig 4.8) that air transport movements will increase from 243,000 in 2010/11 to around 286,000 in 2020.  That will mean increased disturbance for many people up to twenty miles from the airport.  The revised master plan should recognise the disturbance caused by the sheer number of aircraft.

Surface access

We are pleased that the target of 40% passenger access by public transport has been achieved (7.1.5).  With the prospect of an improved railway station and an improved coach station, and the other improvements described in the master plan, it is time to set a new higher target.  We suggest that the revised master plan should set a target of 50% access by public transport by 2020.

Economic contribution

In paragraph 8.1.1 it is stated that:  “The aviation sector directly accounts for £53 billion (3.8%) of UK GDP.”  That figure is a serious exaggeration.   It is based on a report by Oxford Economics, a notoriously pro-aviation consultancy.  The report is not available on the internet but we have obtained a copy. 

It appears that the figure of £53 billion is inaccurate for two reasons:

1.  It refers to turnover instead of economic output (gross value added).  In the Department for Transport Scoping Document (March 2011) it was stated that: “The air transport sector’s turnover in 2009 was around £26 billion and the sector directly generated around £9 billion of economic output.”[3]   The £9 billion figure is the correct one to use when referring to the GDP.

2.  It includes the supply chain, so that for example the output of Scottish distilleries making whisky for sale in airport shops is included in the output of the aviation industry.  It also includes the spending of employees, so that for example when the worker in the distillery spends his money buying haggis in a Scottish supermarket, the haggis also is included.  Such bogus figures are never used in the official national statistics.

It is unfortunate that this inaccurate figure has been repeated in the leaflets widely distributed around the airport, and in the exhibitions held in various local towns.  An airport as large as Gatwick has a duty to get their facts right.

We request that in the revised master plan the figure of £53 billion is replaced by £9 billion, in order to bring it into line with DfT statistics.

Even the figure of £9 billion is too high.  As we have pointed out in our response to the DfT Scoping Document, it does not include depreciation.

The master plan goes on to state that ‘The airport … generates around £2 billion annually for the economy of London and the South East.’ (8.1.3)   That figure also looks suspect.  When we asked GAL about it they told us that:  “It refers to work that we commissioned from an consultancy called Optimal Economics.  It is based on the Gross Valued Add [sic]  (GVA) contribution of GatwickAirport to the economies of London and the South East, at  passenger levels we were supporting in 2010/11 financial year.”[4] 

Yet according to the Office of National Statistics the gross value added by all airports and air traffic control in the whole UKin 2009 was £3.6 billion.[5]  Thus it is not credible for Gatwick alone to contribute £2 billion.    Moreover as the master plan states (2.4), the Global Infrastructure Partners consortium bought Gatwick for £1.5 billion.   It is not credible to claim an annual output higher than the purchase price.

We asked GAL if we could see the report by Optimal Economics so that we could understand how the figure of £2 billion was derived.  They have refused to show it to us.  It is contrary to all normal government and academic practice to quote from sources which are then kept secret. 

We suggest that if the figure of £2 billion cannot be substantiated, it should be omitted from the final version of the master plan.


The master plan indicates that the rise to 40 million passengers a year will provide 1,700 additional jobs, and this claim featured large in the leaflet and the exhibitions.  Yet experience from airports around theUKshow that employment forecasts are regularly exaggerated in order to gain public support and impress local councils. Indeed that has been the case at Gatwick:  the Gatwick Sustainable Development Strategy published in the year 2000 predicted that by 2008 airport employment would increase by 7,000 – in the event it actually fell by 2,000.

We suggest that in the revised master plan a table is given showing previous forecasts and the actual level of employment over the past twenty years – as was done by BAA when they owned Gatwick.[6]

In Fig 8.2 statistics are given for ‘induced’ employment – jobs created in the local area when airport employees spend their money.  If some people employed at the airport spend part of their incomes at local hairdressers, then a proportion of the hairdressers are counted as deriving their employment from the airport. This is a dubious concept, and is not used in national statistics nor (recently) by the Department for Transport.[7]   

Even if it is accepted as a valid concept, the figure of 17,800 for induced employment in 2020 looks unrealistically high.  It implies that airport employees will spend 73% of their incomes on goods and services within the local area.   That contrasts with the fact that only 15% of Gatwick’s suppliers are situated within the Gatwick Diamond area (8.3.2).

We suggest that the statistics for induced employment are omitted from the revised draft. 


The master plan claims credit for facilitating inbound tourism (8.2.7) but it is surprising that no mention is made of outward-bound tourism.  We recognise, of course, that facilitating foreign holidays and foreign business trips is a valuable service, and that millions enjoy their foreign holidays.  Nevertheless when people travel abroad they spend their money there, not here.   Fig 4.2 shows that 76.6% of Gatwick passengers are UK residents travelling abroad.  Thus for every one job created by tourist expenditure in the UK, three jobs are created abroad.[8]

It is therefore incorrect to claim (8.1.1) that at Gatwick “£25.5 billion is provided through catalytic benefits through tourism” without mentioning that about three times as much economic benefit is lost to theUK.

We recommend that all references to the economic benefits of inbound tourism are omitted from the revised master plan.

Climate Change

We note that on page 75 Fig 9.3 shows a 20% increase in carbon emissions between 2010 and 2020.  At a time when all other industries and all individuals are being exhorted to cut their emissions that must be a matter of great concern. 

It is not a small matter:  total greenhouse gas emissions in 2020 are shown at 860,000 tonnes of CO2 equivalent.   That is more than all the emissions ofCrawley– factories, houses, cars, lorries etc.

This is another important issue which is not mentioned in the executive summary or in the leaflets or exhibitions.

Moreover, the figures on page 75 which show Gatwick in 2020 producing 860,000 tonnes of CO2 seem a serious under-estimate.  The Department for Transport forecast CO2 emissions attributable to Gatwick as 3.8 million tonnes in 2030.[9]   The difference may be because, as in the Gatwick 2009 climate change report, GAL have only counted aircraft emissions up to 1,000 feet.   

We suggest that the revised master plan should contain an explanation of why its figures differ from those given by the Government.

A new runway?

The foreword by the Gatwick Chief Executive recognises that ‘the current Government’ has ruled out a second runway at Gatwick, and that the Government has begun work on a new aviation policy.  Nevertheless the draft master plan reproduces the runway plan as contained in the 2003 Air Transport White Paper while stating that other runway location options may be considered (10.3.4). 

We do not intend to comment on this section of the master plan, and have made it clear that if any new runway were to be seriously suggested it would be strenuously opposed by GACC with, we believe, support from hundreds of thousands of people inSurrey,SussexandKent.

We have made a detailed submission to the Department for Transport explaining why no new runway could be built at Gatwick without causing unacceptable environmental damage, and why Gatwick would never succeed as a hub airport.[10]    Our submission sets out why the new white paper should carry forward the ‘no new runways’ policy.   We also point out that the climate change forecasts indicate that, in the absence of other measures to restrict the growth of air travel, aviation can only be kept within the limits recommended by the Climate Change Committee, set up by Parliament, if the no new runway policy is extended to 2050.[11]


We repeat our request that the master plan consultation process should be fully transparent, with all responses published or made available for examination.  That would be in line with best practice in government and in local authorities. 



 GACC recommendations for policies relating to noise to be included in the new White Paper due to be published in spring 2012. [12]

The following recommendations made to the Department for Transport are given added weight and urgency by the increase in noise forecast in the master plan.

1. The new White Paper should announce a reduction in the maximum noise limits for departing aircraft, with a timetable for further reductions in future years.

2. The level of penalties for infringements of noise limits, which has not been increased since 1993, should be increased.

3. A study should be initiated into noise limits on approaching aircraft, based on the annual average per airline.

4. The aim of securing international agreement on steeper approaches should be supported.

5. Proposals for increasing the effectiveness of CDA approaches should be included. 

6. Guidance about flying over National Parks and Areas of Outstanding Natural Beauty should be reviewed.

7. The new White Paper should contain an undertaking that the DfT and Defra will ensure that the next round of airport Noise Action Plans, due in 2014, will be more rigorous.

8. Minimum standards for airport complaints systems should be established, and an Airport Ombudsman should be set up.

9. The new White Paper should contain an impartial and expert assessment of the impact of aircraft noise on health.

10. Higher charges should be imposed on the noisier / more polluting aircraft with the extra revenue going to compensate local residents.

11. A continuing gradual reduction in the night-time noise quotas would have many advantages:  it would encourage aircraft manufacturers to design quieter aircraft; it would encourage airlines to purchase, and use, quieter aircraft;  it would give local residents the assurance that the noise climate at night will gradually improve. 

 12. The new White Paper should also recognise the desirability of reducing the number of night flights.

 13. Noise insulation schemes should be extended to cover the whole 55 Lden contour.

 14. A levy should be imposed on all night flights.


[1]   Foreword to Developing a Sustainable Framework forUK aviation: Scoping Document.  March 2011

[2]   Executive summary of  joint working group of GAL and ‘Gatwick can be quieter’.

[3]   See also . – Economic Benefit

[4]   email from GAL public affairs department.25 October 2011

[5]   Office of National Statistics.  Annual Business Survey 2009.

[6]   2005 Gatwick Outline Master Plan

[7]   For instance, it does not appear in the Scoping Document on the new aviation policy.

[8]   Assuming that inbound tourists spend the same as outward-bound.

[9]   Table H.5.

[10]   No New Runways


[12] . – Noise and Health



see also

GACC finds Gatwick Master Plan contains serious misrepresentations and is deeply flawed

Date added: October 24, 2011

The GACC committee finds the master plan contains several serious misrepresentations. It conceals the increase in noise that will occur from a rise in number of flights by 60%. It says the aviation industry contributes £53 billion to UK’s economy per year, while the DfT gave the figure of £9 billion. They have committed the elementary economic error of using gross turnover rather than net output. It omits mention of jobs exported due to outward-bound tourism and makes over optimistic jobs claims.   Click here to view full story…



Gatwick master plan consultation launched, with runway in prospect after 2020

Date added: October 13, 2011

The new Gatwick master plan, published today, contains plans for a possible new runway some time after 2020. “If that were ever to become a serious threat it would be fought tooth and nail by GACC, with support from hundreds of thousands of people throughout Surrey, Sussex and Kent, said Brendon Sewill, GACC chairman. “But we believe it will never happen. It is Government policy that no new runways should be built in the South East. The official forecasts show that the London airports will not be full until 2030, and it would make no commercial or environmental sense to build a new runway while there is still unused capacity. If oil prices rise the date may well be much later.” Click here to view full story…



Master Plan consultation

 The Gatwick Master Plan consultation is at

It closes on 13th January 2012.

and the full document is over 24 MB – so too large for many people to download
easily. It is summarised on the Gatwick Airport website with the Executive Summary

This includes these statements:

S8 Gatwick is the busiest single runway airport in the world. We believe that small
increases in peak hour movements may be possible, and that there are opportunities
to grow traffic in the existing off-peak periods when existing runway capacity
is not being fully utilised. Combined with an expected gradual growth in average
aircraft size, we believe Gatwick can realise significant growth through more
efficient use of its existing infrastructure.

S9 By making use of the full potential of the single runway we believe we will
grow to 40mppa with 286,000 aircraft movements by around 2020/21.

Looking further ahead, we think Gatwick, with a single runway, has the potential
to grow up to 45mppa by 2030.

S10 In moving towards this level of growth, we will make every effort to maintain,
and, where possible, improve the sustainability of our operations. We will seek
to ensure that the airport remains affordable to airlines and their passengers,
that service levels remain high, operations are resilient to the effects of disruption
and that adequate airspace and surface access infrastructure is in place to support
the growth we envisage.

S17 By 2030 Gatwick could be handling up to 45mppa but, with a single runway. This
means we will be operating at full capacity.

S18 A large proportion of this growth would be accommodated by making use of currently
unused capacity outside the peak periods. We expect that the amount of new infrastructure
needed to support it will be relatively small. However, some redevelopment will
be necessary, for example, in order to comply with any new statutory requirements
for security and border control, deliver enhanced passenger service or improve
energy efficiency at the airport. All airport developments other than surface
access improvements should be contained within the existing airport boundary.

S19 We think that further improvements to some of the key road junctions around
the airport may be needed – but this is largely driven by the forecast growth
in background traffic.

S20 We have no current plans for a second runway at Gatwick. The scenarios outlined
above are based on Gatwick remaining largely the same size – with a single runway,
two terminals and within its existing boundary.

S21 At the same time, like any business, our plans need to cater for all eventualities.
We do need to anticipate that, in the long term, a second runway at Gatwick may
be needed.

S22 This means that, we will continue to safeguard land for future expansion because
we believe it to be sensible business practice and it supports current Government