Climate Change Impact

Gatwick’s CO2 emissions in 2038 are forecast to be 2.465 million tonnes per annum higher than in 2018 (7.575m tonnes in 2038 vs 5.11m tonnes in 2018).

This represents an increase in CO2 emissions of nearly 50%. 

An increase in emissions of this (or any) magnitude would be inconsistent with the Government’s objective “to ensure that the aviation sector makes a significant and cost-effective contribution towards reducing global emissions”. 

Gatwick needs to explain how expanding one of the hardest to decarbonise sectors of the economy is consistent with the government’s net zero legal commitment for 2050 and the international commitment to staying within the 1.5C global warming limit. 

Gatwick’s emissions would grow from less than 1% of total UK emissions in 2018 to over 5.5% of the Climate Change Committee’s recommended total UK emissions in 2038. 

The increase in carbon emissions would be so significant that it would have a material impact on the UK’s ability to meet its carbon reduction targets. It would therefore be inconsistent with the Airports National Policy Statement.

The consultation acknowledges that there are presently no proven measures by which Gatwick’s emissions could be mitigated and that the trajectory of the aviation industry to net zero emissions is unclear. It asserts, however, that a combination of aircraft/airspace technology and efficiency, “sustainable” aviation fuels and electric or hydrogen (or hybrid) aircraft and offsets will provide a route to Net Zero for the industry.

Seeking to justify Gatwick’s growth on the basis of unsupported assertions on the impact of future technologies is reckless and irresponsible.

The consultation claims to adopt a worse case assessment of climate impacts but fails to quantify the non-greenhouse gas and radiative forcing effects (e.g. from contrails) of Gatwick’s growth, although the government’s own greenhouse gas emissions reporting (used by GAL to assess everything else) includes these. The current scientific consensus is that these are far greater than the CO2 impacts.

The Gatwick Consultation Documents

 Consultation Documents:- HERE  

The Gatwick consultation summary document:- HERE  

The Gatwick consultation overview document:- HERE  

Preliminary Environmental Information Report Appendix 15.4.1:
Climate Change and Carbon Technical Appendix  [lots of numbers on carbon emissions]:- HERE   

Responding to the consultation

The question, in the Gatwick questionnaire (there are 14 questions in total) is:
Question 12. Managing and mitigating effects: climate change and carbon
  1. "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?"

GACC suggested short response

Expansion at Gatwick would increase the airport’s CO2 emissions by nearly 50%.  Emissions from Gatwick alone would grow from less than 1% to over 5.5% of total UK emissions.  An increase in emissions of this scale would have a material impact on the UK’s ability to meet its carbon reduction targets and is therefore inconsistent with government policy. The airport has no credible plans to mitigate these emissions because

credible low carbon technologies do not currently exist for commercial aviation.  Gatwick has also failed to assess or quantify the non-greenhouse gas effects of its proposed growth, and must do so based on best available scientific evidence.  It must also monetise and report its emissions using latest government figures. 

GACC suggested longer response

If the project proceeds, Gatwick’s total CO2 emissions in 2038 are forecast to be 2.465 million tonnes per annum higher than in 2018 (7.575m tonnes in 2038 vs 5.11m tonnes in 2018).  This represents an increase in the airport’s CO2 emissions of nearly 50%.  An increase in emissions of this (or any) magnitude would be inconsistent with the Government’s principal objective in this respect, which is “to ensure that the aviation sector makes a significant and cost-effective contribution towards reducing global emissions”. 

Gatwick’s emissions would grow from less than 1% of total UK emissions in 2018 to over 5.5% of the Climate Change Committee’s recommended total UK emissions in 2038.  An increase in emissions of this scale would plainly be so significant that it would have a material impact on the UK’s ability to meet its carbon reduction targets.  It would therefore be inconsistent with the Airports National Policy Statement.

The consultation asserts that a combination of aircraft/airspace technology and efficiency, “sustainable” aviation fuels, electric or hydrogen (or hybrid) aircraft and offsets will provide a route to Net Zero for the airport and the wider aviation industry.  However, it acknowledges that there are presently no proven measures by which Gatwick’s emissions could be mitigated and that the trajectory of the aviation industry to net zero emissions is therefore unclear.  

Gatwick’s Action Plan must set out the measures the airport will take to achieve Net Zero emissions, the effect of those measures, their timing and the resulting emissions trajectory.  It must provide evidence that the measures are achievable and would have the impacts claimed.

It should propose a firm emissions reduction trajectory together with enforceable monitoring arrangements.  Any failure to meet the emissions trajectory should constitute a breach of planning consent, if it is granted, and trigger enforcement action including a reduction in permitted traffic. The Action Plan must also quantify the non-greenhouse gas and radiative forcing effects (e.g. from contrails) of Gatwick’s growth, based on best available scientific evidence.  It should set out the measures the airport and the wider industry will take to eliminate these effects, the expected impacts of those measures, their timing and the resulting trajectory of non-greenhouse gas impacts.  It must provide evidence that the measures are achievable and would have the impacts claimed.  It should propose a firm reduction trajectory together with enforceable monitoring arrangements.  Any failure to meet the trajectory should constitute a breach of planning consent, if it is granted, and trigger enforcement action including a reduction in permitted traffic. 

In addition to the above actions, Gatwick must, as required by government policy, monetise and report the increase in emissions caused by the project using the revised approach to valuing greenhouse gas emissions in policy appraisal published by the Department for Business, Energy & Industrial Strategy (BEIS) on 2nd September 2021. It must also monetise the non-CO2 effects of the project and the impacts it would have overseas (i.e. including arriving flights, which Gatwick has currently excluded from its analysis) in line with guidance on the Valuation of Energy Use and Greenhouse Gas published by BEIS in July 2021.

Submitting a response

Responses can be done through the questionnaire: HERE

or else by email, to 

feedback@gatwickfutureplans.com

or by letter to  FREEPOST RTRB-LUUJ-AGBY  

PROTECTING THE GATWICK  AREA

 

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