Airports Commission’s findings simply don’t add up


  • Airports Commission’s findings are inconsistent and flawed
  • Traffic forecasts don’t even take into account its own night flight ban
  • Gatwick today has published a full, detailed, and thorough response

Gatwick Airport today published a full and detailed response to the Airports Commission Final Report pointing out key errors, omissions, and flaws as Sir Howard Davies’s recommendation for Heathrow expansion continues to unravel.

Just one of the key flaws in the report surrounds Sir Howard’s proposed ban on night flights at Heathrow. This would inevitably mean fewer services if applied, but this was not factored in to the Airports Commission’s own traffic forecasts for Heathrow.

The restrictions would impact on the number of long haul flights to and from growth markets in the Far East – the issue at the heart of the decision to recommend Heathrow – further calling into question the robustness of the Commission’s analysis.

Gatwick CEO Stewart Wingate said:

We expected a well-considered examination of all options, but instead the final report contains so many omissions and basic errors that its reliability as the basis of aviation policy must be called into question. The findings of this report simply do not add up.

Britain is in danger of losing out once again if we repeat mistakes of the past – Heathrow has failed time and again and the Airports Commission report and the conditions placed on expansion have not solved the huge obstacles confronting it.

“In recent weeks, it has become abundantly clear that Heathrow won’t meet these conditions, nor will they pay for the £6 billion in surface access improvements needed, and Heathrow’s airlines have shown they don’t want to pay for the runway. The recommendation for Heathrow is unravelling by the day.

"I remain confident that when all the risks and benefits are properly considered, Gatwick will still represent the best option for UK airport expansion.”

The Commission used its traffic forecasts to calculate the potential economic benefits each airport would deliver and Gatwick’s response lists several fundamental assumptions that dramatically underplay traffic at Gatwick and overplay predictions for Heathrow, including: 

  • expecting Gatwick to reach 40 million passengers in 2024 whereas the airport will reach that number this year
  • estimating that Gatwick will generate only two million passengers in the first year of operating with a second runway; in reality Gatwick grew by 2.7 million passengers last year with a single runway
  • predicting that, after five years with a second runway, Gatwick will have an additional eight million passengers – less than it assumes Heathrow would have after one year with a third
  • between 2025 –2030 Heathrow is assumed to grow by 36 million passengers compared to only 9 million at Gatwick.

In addition to drawing attention to the Commission’s flawed traffic forecasts, Gatwick’s full response highlights a range of other flaws in the Commission’s analysis, including:

Economic benefits: the Commission’s own economic analysis, following Treasury guidelines, shows that the economic value of each scheme is virtually the same. The Commission, however, emphasises and widely quotes the conclusions of PwC analysis, despite the Commission’s own expert panel urging caution about attaching significant weight to these results, stating that care is required in assessing its “robustness and reliability”.

Costs: Heathrow’s costs are multiples of those for Gatwick and yet the Commission assumes airport charges will go up by the same amount for both - from £20 to £31 for Heathrow and £9 to £20 for Gatwick.  The Commission also disregards Gatwick’s commitment to enter into a binding obligation to cap charges at less than £15.

Financing: between 2023 and 2025, Heathrow’s plan requires as much as £6.76 billion to be spent each year on average, an average spend of more than £560 million per month. T5 construction only achieved a maximum spend of £85 million per month. Neither Heathrow nor the Commission present any evidence as to how the expenditure for this unprecedented scale of construction could be managed in practical terms and could actually be delivered.

Deliverability: the Commission confirms that there are no overriding environmental or other reasons to believe that Gatwick’s second runway could not be delivered by 2025. In contrast, while the Commission has outlined a massive quantum of work proposed for Heathrow in general terms, it has not adequately considered the detail, the considerable risks, or the cumulative impact and interdependency of the challenges involved, so is unable to say with any confidence that the work is actually deliverable by the 2026 – the date assumed by the Commission.

For example, the Commission’s assessment of the complex challenges of construction at Heathrow does not accurately portray the scale of construction impacts many of which are outside the control of the promoter and therefore pose serious impediments to obtaining planning consent. The risks to cost and programme are considerable due to the scale, complexity and cumulative effects of construction. Constructions risks arise from: 

  • putting the M25 into a tunnel and widening it
  • diverting the A4 and widening the M4
  • constructing the Southern rail link
  • constructing Terminal Six while maintaining access to T5
  • managing the impact over an extended period on M4, M25 and local roads
  • delivering a solution for the potentially toxic landfill on the site and moving and rebuilding the existing Energy from Waste plant, and
  • implementing a Congestion Charging scheme, the implications of which are not known.

Air quality: the Commission’s analysis of air quality issues at Heathrow does not withstand scrutiny as its conclusions are based on an incorrect interpretation of the law. Its analysis is also incomplete and inconsistent in several material ways and relies upon a notional Air Quality Plan that is yet undrafted and so cannot at present be assessed. The Commission’s analysis confirms Gatwick’s assessment that Gatwick’s new runway can be delivered without exceeding the legally binding air quality limits.

Noise: the Commission concludes that a three runway Heathrow will have a lower noise impact than a two runway Heathrow today. It also largely ignores the fact that Gatwick’s noise impacts would be an order of magnitude lower than Heathrow’s and has avoided meaningful assessment of Heathrow communities newly affected by noise.

Notes to Editors:

A copy of Gatwick’s full response to the Airports Commission report can be accessed here.


About London Gatwick

Gatwick Airport is the UK’s second largest airport and the most efficient single-runway airport in the world. It serves more than 228 destinations in 74 countries for 45 million passengers a year on short and long-haul point-to-point services. It is also a major economic driver for the UK contributing £5.3 billion to national GDP and generating 85,000 jobs nationally, with around 24,000 on the wider airport campus alone. The airport is south of Central London with excellent public transport links, including the Gatwick Express, and is part of the Oyster contactless payment network. Gatwick Airport is owned by a group of international investment funds, of which Global Infrastructure Partners is the largest shareholder.

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