Gatwick Airport & Aviation Issues Report to PPC November 2014

Report to Penshurst Parish Council on Gatwick Airport and other aviation matters for council meeting Monday 3rd November 2014.



There have been two major issues of this subject. The first is the increased aircraft movements during the summer over our area. It is now clear from information seen from Gatwick Airport Limited (GAL) that the increased flights were part of a program to maximise aircraft movements and enhance runway capacity to 55 aircraft movements per hour – one take-off or landing every 65 seconds. This programme was repeated from 2013 but was more noticeable this year as the predominant westerly winds, which are a feature of our area, returned to their normal direction.


Increased aircraft movements can only be achieved by reducing spacing variation and directing aircraft on a similar flight path further away from the airport. In other words GAL extended the path of inbound aircraft to a longer easterly arc producing a concentration of arrivals over the Borough of Tunbridge Wells, Bidborough, Fordcombe, Penshurst and Chiddingstone and their surrounding areas. This was known as the ACDM55 project. GAL admits that the reduction in spacing variations between aircraft to enhance runway capacity can only occur if aircraft are brought in on a similar path from further out: in other words a de facto concentrated flight path. Representations have been made on this point to GAL and the CAA.



The second issue on the concentration of flight paths was from the so-called consultation process earlier this year jointly sponsored by Gatwick Airport Limited and National Air Traffic Services (NATS). The proposals were for a Point Merge arrival system with aircraft drawn off for arrivals on RWY26L onto a single concentrated flight path over Langton Green, Fordcombe, Penshurst and Chiddingstone. Due to prevailing westerly winds this would have been for 70% of the time.


We and other town and parish councils together with residents and environmental actions groups challenged these proposals and the lack of integrity of the whole process. There appeared to have been  little or no respect for the vast majority of stakeholders’ responses and in some cases key stakeholders views had been misrepresented. The process lacked vital information for an instructive view to be taken and the procedure had all the hallmarks of a vested commercial fait accompli. It seemed that GAL and NATS were interpreting in their own way a European directive to use performance based navigation to use airspace more efficiently. In addition, they were suggesting that as it was government policy to reduce the number of people disturbed by aircraft nuisance then by using a single concentrated flight path this would achieve that objective. In neither the European directive or government policy was there acceptance that fewer people should pay the price for this by being disturbed more of the time by aircraft nuisance. Gatwick and NATS have now agreed to defer the introduction of a concentrated flight path until such times as GAL has been able to achieve the following:

Reflect further on the feedback received during local consultations
Undertake detailed analysis work on final route options
Undertake further work on the possibility to introduce more respite for residents most affected by noise (including between 4000 and 7000 feet).
Consider how Gatwick can engage better on any new flight change options, including by developing a more detailed programme of engagement through GATCOM

We believe that this is insufficient and that they will have to fully engage with all stakeholders including the public in a genuine consultation process rather the sham that was presented to us all last time. Further, we do not believe it would be productive to develop a detailed programme of engagement through GATCOM (or NATMAG) which many stakeholders consider are not independent consultation bodies.



In the absence of a positive response from either the chief executive of easyJet or British Airways the council has now written to individual directors of both companies drawing their attention to the debilitating whine of aircraft within their fleets such as the Airbus A319/320/321 series. We have requested them to use any influence they have to persuade their companies to accept that they have a social responsibility to mitigate the nuisance that their operations are causing to so many people, particularly as aircraft modifications are available to reduce this problem. We have been joined in this protest by many more local town and borough councils and have requested Kent County Council to also raise its voice in assisting the people of west Kent on this issue.


It is quite evident from the above graph produced from Gatwick Airport’s Flight Performance Report the impact that the Airbus A319/320/321 series of aircraft is having on flight movements; they dominate all operations. The theme of this problem is continued below.


The CAA has shown its limited powers on two fronts as far as the public is concerned. The first is its inability to adequately deal with the Airbus A320 series high pitched whine. When aircraft are first registered their sound energy volumes have to conform to standards laid down by the International Civil Aviation Organsiation (ICAO). Currently new aircraft are achieving Chapter 4 registrations, which also applies to the current series of Airbus A320 series. What is not measured is the frequency of sound and this is why we have this debilitating whine which causes such a nuisance to tens of thousands of people wherever this aircraft type operates. The CAA only announced the Airbus A320 series problem on 16 October 2013 yet it had known about the issue since 2005 – and in that time nothing had been down to mitigate the problem. We have lobbied members of parliament of this very issue and will continue to do so directly and together with action groups such as GACC, HWCAAG and GON (previously Planes of Penshurst).


The other area where we believe the CAA has failed in is the continued use of an arcane and irrelevant system to the wider public to monitor aircraft noise known as the ANCON (2) – 57 dBA Leq contour area. This records sound energy volumes close to airports from 57 decibels upwards based on a continuous 16hour day measure, referred to originally in ANCON-1 ‘as a predictor of annoyance.’ In assessing actual runway modal split the area deemed affected by aircraft noise around Gatwick Airport is calculated by the Environmental Research and Consultancy Department of the CAA to be 162 miles (412 km). The population enclosed within the contour is 3,650. In reality, the noise footprint of those disturbed by early morning and night flights and aircraft such as the Airbus A319/320/321 could be at least 14002miles (36002 km). Communities, in some cases over twenty-five miles from touchdown, are experiencing high volumes of jet engine and airframe noise (but less than the continuous 16 hour measurement) will not be shown within the contours. This will account for tens of thousands of people in the towns and villages around Gatwick Airport – if not hundreds of thousands.


I have mentioned before that this historic arcane and unproven measurement of sound energy emissions is an anathema in the twenty-first century. It is riddled with subjective formulae which hold no place in correct modern-day scientific analysis. There, in my opinion, the DfT, the CAA, the airports and airlines have failed in a ‘duty of care’ to the public to use environmental metrics that accurately reflect the full nuisance of not only sound energy volumes but frequency or pitch. There is no measure to heed the continuing warnings from recognised bodies such as the World Health Organisation on the effects that excessive noise and disruptive sleep patterns can have to health and well – being. This has to be pursued further.



We have seen from Gatwick Airport’s own figures that complaints are recorded and can have an impact on influencing advisory and politically thinking but not only must the momentum be maintained but increased by all those affected by aircraft nuisance. In the first six months of this year, the latest period for which this information is available, complaints to Gatwick Airport increased from a total of 2,645 in the full year ending 2013 to 11,311 for just the first six months of 2014.

We would hope that with the formation of environmental action groups such as GON (previously Planes over Penshurst) and the success of the High Weald Councils Airport Action Group this figure should grow exponentially. Main areas for aircraft nuisance complaints are: too loud, low flying, early morning, increased flights, track keeping and night flights. Complaints should be made in the first instance to Gatwick Airport by email to: with c.c. to



We should not forget that effective protests have to reach to the heart of government and this has been achieved with contacts by our own member of Parliament Sir John Stanley who has lobbied long and hard on our behalf. An additional strength Sir John has is being part of the Gatwick Coordination Group of like-minded MPs who are robustly protesting against any plans to develop a second runway at Gatwick Airport. In a letter last week to Stewart Wingate, chief executive of Gatwick, Crispin Blunt and the other members of the Gatwick Coordination Group – Sir Paul Beresford, Sir Nicholas Soames and Charles Hendry stated “Heathrow’s plan for a third runway and attendant infrastructure improvements are, at least, plausible. The sooner this damaging pipe dream [of Gatwick’s second runway] is abandoned, the better for its neighbours, and the real answer to the future of the UK’s aviation capacity can be reached.” Gatwick’s application “lacks any serious proposals” on providing the transport infrastructure needed to support a second runway, suggesting that passenger numbers could treble from the current levels.”

They also claimed that Gatwick’s forecast of 22,000 new jobs on site and another 100,000 in the local area by 2050 “ignores the stark reality” that there are a limited number of people claiming jobseekers’ allowance in the local area, and there is a “desperate” shortage of housing. Gatwick’s blithe assumption that the additional housing need would be met by local authorities existing development plans is wholly incredible”. This is the theme Penshurst Parish Council took in its last response to the Airports Commission, as did the vast majority of key council stakeholders with the exception in Kent of Kent County Council (KCC), which strongly supported Gatwick Airport’s second runway proposal while being aggressively against the Estuary Island alternative. With an outpouring of criticism over this levelled at Paul Carter, leader of the council, KCC’s position has now apparently changed. This was mentioned by its representative Matthew Balfour at a recent meeting of GATCOM. Although this had already been indicated to us verbally KCC has been requested to write directly to the Airports Commission to make this known. The Airports Commission’s final recommendation for additional runway capacity in the south east is expected any day now.

An interesting publication of Gatwick Airport’s taxation affairs highlighted recently by Margaret Hodge, head of Parliament’s Public Accounts Committee, said the airport should pay its “fair share” if it wants its runway campaign to be credible. Apparently the airport’s Guernsey-based parent company IVY MIDCO LIMITED invested in a £437 million Eurobond which charges the airport 12 per cent interest which critics say is designed to avoid tax. Accounts for the past four years for Gatwick Airport Limited (GAL) show pre-tax losses of £322 million and a tax credit of £192 million, but despite these losses it has paid dividends to its overseas shareholders of £436 million.



This is my final report to the parish council. In the last year since being asked by John Cass to assist the council with aviation matters, mostly new to me, events have moved fast. We have seen other parish councils recognising the threat to the well-being and way of life of their residents by the continued and future plans for the expansion of airports such as Gatwick. Parish councils as elected bodies have the legitimacy as the voice of the people and can use this effectively. Added weight was given to this last year with the formation of the High Weald Councils Aviation Action Group of which Penshurst Parish Council was a founder member. Membership of this group now numbers 13 councils representing around 50,000 people with a number of other councils expected to join.

More recently we have seen the emergence of our own environmental action group under the leadership of Martin Barraud which I have assisted in the same capacity as with the parish council. This group was originally formed under the name ‘Planes over Penshurst’ but now with a change to ‘Gatwick Obviously Not’ (GON). Action groups such as GON are not constrained by the same rules and regulations as local councils and have greater freedom to act financially and critically of those they are campaigning against. This approach has been very effective and GON now represents as the umbrella group many of the action groups to the east of Gatwick Airport. Its web site is continually updated with latest news and other information and advice on how to make complaints known to Gatwick Airport and the Civil Aviation Authority etc. Gatwick Airports Conservation Campaign (GACC) is another environmental action group important to us. GACC has campaigned against the continued expansion of Gatwick Airport since 1968, has a membership of around a hundred District and Parish Councils, amenity groups, individual members and supporters.


All these groups need our support and financial contributions to carry on their good work in all our interests – please join them.

Penshurst Parish Council’s involvement with aviation matters and the wider area of its many other responsibilities are regularly updated on its web site – see below.

Web addresses:

Gatwick Obviously Not (GON) – 

High Weald Council Aviation Action Group (HWCAAG) –

Gatwick Airports Conservation Campaign (GACC) –

Penshurst Parish Council –


Michael Knowles OBE, 27th October 2014

Swaylands, Penshurst.