750XL. EU Regulation 1107/2006 gives the airport the responsibility: vis
(6) To achieve these aims, ensuring high quality assistance at airports should be the responsibility of a central body. As managing bodies of airports play a central role in providing services throughout their airports, they should be given this overall responsibility.
and
Article 7
Right to assistance at airports
1. When a disabled person or person with reduced mobility arrives at an airport for travel by air, the managing body of the airport shall be responsible for ensuring the provision of the assistance specified in Annex I in such a way that the person is able to take the flight for which he or she holds a reservation, provided that the notification of the person's particular needs for such assistance has been made to the air carrier or its agent or the tour operator concerned at least 48 hours before the published time of departure of the flight. This notification shall also cover a return flight, if the outward flight and the return flight have been contracted with the same air carrier.
While they are allowed to contract it out, they retain responsibility under the regulation. If LGW wants to sue OCS (or whomever) to pay their fines, that's up to them - but they can't avoid responsibility.
also
(16) It is important that a disabled person or person with reduced mobility who considers that this Regulation has been infringed be able to bring the matter to the attention of the managing body of the airport or to the attention of the air carrier concerned, as the case may be. If the disabled person or person with reduced mobility cannot obtain satisfaction in such way, he or she should be free to make a complaint to the body or bodies designated to that end by the relevant Member State.
So it's the CAA that is responsible for ensuring the airports meet their obligations, but I will certainly make sure DG-TREN is aware of my complaint.
and
(18) Member States should lay down penalties applicable to infringements of this Regulation and ensure that those penalties are applied. The penalties, which could include ordering the payment of compensation to the person concerned, should be effective, proportionate and dissuasive.
The delay is irrelevant, there is no opt-out or 'extraordinary circumstances' provisions in this regulation.
Gatwick is responsible, has screwed up royally and is subject to the penalties in UK law.
The request for assistance was made in June 2013, and they provided it on the outbound flight.
The UK law in question (The Civil Aviation (Access to Air Travel for Disabled Persons and Persons with Reduced Mobility) Regulations 2007) simply sets out the penalties for breach of the EU regulation.
You know, it would have been nice if somebody said they were sorry …