Heathrow Airport Expansion Consultation

Response by West London Friends of the Earth

Introductory comment

We are strongly opposed to a third runway at Heathrow and to ‘early growth’ or other expansion proposals. Our responses to the consultation questions – particularly where preference is being sought on a range of options – should not be construed as support for the scheme.

Responses below are numbered in accordance with the questions in the main consultation document.

1. Please tell us what you think about any specific parts of our Preferred Masterplan or the components that make up the masterplan.

We are opposed to the totality of the scheme because it will: use up a large area of Green Belt increase noise impacts increase air pollution make it impossible to achieve the UK’s climate target of zero emissions by

2050 require large taxpayer subsidies for surface transport and/or will increase

congestion increase pressure on housing, school, doctors, hospitals, water and sewerage has, according to DfT, negligible economic benefit (Net Present Value of

between -£2.5 bn to +£2.9 bn in the UK, and that excludes costs for climate change)

not, according to evidence provided, reduce unemployment (creating some jobs does is expected to increase population and cause overcrowding, not reduce unemployment for those who live in the area)

2. Please tell us what you think about the sites we have identified for buildings and facilities we are proposing to move.

We do not wish to make comments on the details of buildings and facilities. But we are strongly opposed to the wholesale destruction of homes and businesses. We are particularly concerned for the people whose houses will be demolished.

Compensation does not make up for loss of home and community. In some ways, those whose are close to the edge of the third runway but will not be bought out are even worse off. They will not get the option to move out, but will have to stay and suffer the impacts.

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3. Please tell us what you think of our boundary design proposals to manage noise and the effects on views around the boundary of the expanded airport.

No comments at this stage.

4. Please tell us what you think about our development proposals and the measures proposed to reduce effects in these areas.

The measures proposed will in no way make up for or offset the increase impacts of noise, air pollution or congestion due to a third runway.

5. Please tell us what you think of our construction proposals and the ways we are proposing to minimise effects on communities and the environment.

No comments at this stage. 6. Please tell us what you think of our runway alternation proposals, in particular we would like to know if you think we should alternate the runways at 2pm or 3pm.

The runway alternation proposals will, insofar as we understand the proposals, give some daytime and night-time respite for communities. But this is a meagre benefit. The fact of the matter is that daytime respite will be reduced to about 1/3 for many communities that currently get ½. Communities that are not overflown, ie get 100% respite, will get noise for the first time. Only a few communities will be lucky enough to get less noise than with two runways. The overall noise impact will be much greater. These facts have been omitted from the consultation, thereby giving a totally misleading picture of the noise impacts.

We do not have a strong view on whether runways should be alternated at 2pm or 3pm. However, 2pm is more normally considered the start of the afternoon and it may help people’s planning if they can be assured of respite for the whole of the afternoon. Therefore alternating at 2pm , not 3pm.

7. Please tell us what you think of our preferred proposal for a ban on scheduled night flights, and/or whether you would prefer an alternative proposal.

We are pleased that there would be a slight improvement in the period for no scheduled flights. However, we note the proposed night flight ban is still only 11.30pm to 5.30am. 6 hours sleep is insufficient for adults and far too little for children. We also note that whole new group of people – those directly east and west of the third runway will be exposed to flights just outside Heathrow’s definition of night for the first time.

We believe there should be a night flight ban of at least 8 hours to enable a good night’s sleep.

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8. Please tell us what you think about our proposals for managing early growth.

We are strongly opposed to ‘early growth’. It is ‘growth by stealth’. The limit of 480,000 flights was imposed in order to limit impacts and Heathrow is seeking to jettison this protection. Unlike the third runway, where it can be argued there was political/democratic support for breaking the 480k limit, namely the NPS vote in Parliament, there is no such mandate for early growth.

We are also concerned that if 25,000 extra flights have become acceptable with two runways, extra flights will, by the same token, become acceptable with three runways. This would mean the actual intended capacity is 765,000 (740,000 + 25,000), not 740,000. Or perhaps 740,000 + 3 x 25,000 / 2 = 777,500.

9. Please tell us what you think of our proposals and how we could further encourage or improve public transport access to the airport.

If Heathrow were to be expanded it should not impact adversely, in particular not cause extra congestion, across West London and west of London. While a series of schemes are suggested, no evidence is given that these would be sufficient to prevent extra congestion. Extra congestion would have a significant economic cost, yet no cost was allowed for in the evaluation of the net economic benefit of expansion.

Heathrow has said it will not contribute more than about £1bn to support new road and rail capacity. But the Airport Commission estimated that some £5bn was needed and Transport for London estimated up to £15bn. It is clearly Heathrow’s intent that the taxpayer should pay for most of the schemes, though this is not made clear in the consultation. We are strongly opposed to a taxpayer subsidy to support expansion.

The consultation resorts to “indicative” coach and bus links. No new rail links are mentioned in Section 6 of the main consultation document. This is totally inadequate. We need proper, funded, plans. Not vague, unfunded, ideas.

It is not sufficient and is not sustainable to simply “encourage” or “improve” public transport. There must be credible and concrete plans to actually meet the aspirations of modal shift, prevent extra congestion, etc.

For all these reasons, the surface access proposals are totally inadequate.

10. Please tell us what you think about our proposals for the Heathrow Ultra Low Emission Zone and Heathrow Vehicle Access Charge as ways to manage congestion and air quality impacts.

We support the introduction of a Heathrow Ultra Low Emission Zone (ULEZ) and Heathrow Vehicle Access Charge. But Heathrow is heavily polluted and congested

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now, even with two runways. A ULEZ and access charge should therefore introduced irrespective of a third runway.

11. Do you have any other comments on our Surface Access Proposals?

Yes. In the past, Heathrow has made great play of its intent to increase the modal share on public transport but has manifestly failed to achieve it. There has only been a 1% increase in the past decade and the figure currently is 41%. If this rate of progress continues, there will obviously be a large amount of extra traffic as the third runway fills up. We see there is now no mention of targets in Section 6 of the main document.

In order to approach sustainability, car traffic needs to be stabilised in absolute terms. This requires a massive increase in modal share of public transport. The lack of any plan to achieve that shift demonstrates that Heathrow’s plan for expansion is unsustainable.

Heathrow makes claims about the increase in freight resulting from a third runway. But this means there would be a large increase in lorries – the claims about modal shift apply only to passenger transport, not to freight. Lorries are more damaging and polluting than cars - Heathrow estimates that freight contributes around 36% of vehicle-related emissions, rising to 58% without mitigation.

Heathrow tries to downplay the issue with proposals for ‘freight consolidation’, but these are no more than good or hopeful ideas. There should be enforceable targets (ie expansion of freight is not allowed if targets are not met) for these ideas to have credibility.

12. Please tell us what you think about our proposals to manage the environmental effects of expansion.

Air pollution

On air pollution (euphemistically called “air quality”) there is only the vaguest commitment in the main consultation document: “ .. our surface access proposals [not plans] will minimise these efforts by increasing public transport use ..”.

Some 9,500 people in London die every year, legal limits of air pollution are commonplace around Heathrow and the courts have found the government’s air quality strategy is inadequate. Given these points, it is clear that a third runway must be demonstrably consistent with meeting air pollution standards. Good intentions are not good enough.

PEIR chapter 7 forecasts there would be only slight exceedances in air pollution exceedances. But this is achieved by claiming that emissions from aircraft more than 2 mile out from the airport don’t contribute appreciably to air pollution on the ground

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because it is dispersed. But if the pollution is dispersed it is, by the same token, spread over a wide area and affects a large number of people well away from Heathrow. These impacts are ignored in the consultation.

That pollution from aircraft is potentially significant well away from the airport is indicated by the Air Quality Expert Group of DEFRA which states in its paper on ultra-fine particles that: “For example a location such as Heathrow where aircraft tend to approach the airport from the east (flying over the London conurbation), there is potential for considerable exposure to ultra fine particles from aircraft”. It cites the Hudda study from Los Angeles, which states that: “Locations of maximum concentrations were aligned to eastern downwind jet trajectories during prevailing westerly winds and to 8km downwind concentrations exceeded 75,000 particles cm3, more than the average freeway PN concentration in Los Angeles.”

Heathrow’s statement “Aircraft flying into and out of the airport do not have a significant effect on air quality in the local area” is simply not believable. The DCO process must challenge such extraordinary claims - if it does not do so the entire process and the inspectorate will be brought into disrepute.

It not satisfactory to allow the use of a new runway based on just a computer simulation forecast made many years before. There must be a legally binding mechanism whereby the runway cannot be used unless the legal air pollution limits are consistently achieved.

The air pollution situation is interpreted mainly in terms of EU ‘Limit Values’. But these are just the (current) legal upper limits. There are impacts from air pollution, not just on humans but on structures and ecosystems. For this reason the World Health Organisation (WHO) has established a more wide-ranging and stringent set of values called ‘Guideline Values’. Full account should be taken of these in the PEIR, not just Limit Values.

Climate

The consultation claims that “Expansion at Heathrow is not considered to materially affect the ability of the Government to meet UK carbon reduction targets.” (https://aec.heathrowconsultation.com/topics/carbon/ , summarising PEIR Chapter 9). This is highly misleading.

Heathrow’s own data show the massive increase in CO2 emissions resulting from a third runway.

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Source PEIR Vol 1, Chapter 9, Graphic 9.7

This shows that emissions would be 8 to 9 million tonnes pa higher due to third runway. Heathrow states that the cumulative emissions of Heathrow flights would be 456 MtCO2 with two runways over the period 2022 to 2050, and 629 MtCO2 with a 3rd runway. That would mean a difference of 173 MtCO2 over the 28 years with a 3rd runway.

The consultation notes that international flights are by far the largest source of emissions” (compared with on-airport emissions and surface transport). (https://aec.heathrowconsultation.com/topics/carbon/#a-summary-of-the-effects-reported-in-the-preliminary-environmental-information-report-peir-2) It then seeks to sidestep the issue by claiming that an international ‘offsetting’ scheme will resolve the problem: “Growth in CO2 emissions from additional flights after expansion will be largely offset through CORSIA.” This is highly misleading because:

there no assurance that CORSIA will be implemented at all Major countries as India are not committed Most offset schemes do not work (that is, they do not achieve genuine net

reductions) As emissions worldwide are reduced in accordance with the Paris agreement,

there will be a rapidly shrinking source of emissions available to be offset against aviation.

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As if this ‘get out of jail free’ card is not sufficient, the consultation claims that international aviation emissions simply ‘don’t count’: “This comparison excludes greenhouse gas emissions from international aviation, which are not included in current UK carbon budgets or explicitly in the UK’s 2050 target. Heathrow’s contribution to total emissions from international flights departing the UK in 2050 remains comparable to today.”

In light of the Paris agreement the government has recently set a zero emissions target for 2050. Many commentators and most climate scientists believe zero carbon need to be achieved sooner.

The Committee on Climate Change (CCC) is clear that aircraft emissions must be counted. Given that there is no technological solution on the horizon, CCC has done some work to show how continued aircraft emissions of CO2 can be squared with zero emissions. It concludes that ‘carbon capture and storage will be needed and that, reasonably enough, the aviation industry should pay for it. But no tax or carbon has been proposed by Heathrow, the aviation industry or government.

The above demonstrates that Heathrow’s claims that third runway is consistent with climate targets is at best unsupported by evidence and at worst deceitful.

Against this backdrop, Heathrow’s proposed measures such a planting some trees or supporting restoration of a peat bog are a drop in the ocean. They are ‘greenwash’ – intended to make people think that the issue of climate is being addressed.

As if the issue of carbon emissions were not serious enough, the main consultation document fails to mention the effect of non-CO2 greenhouse emissions. These emissions include nitrogen oxides (NOx), particulates, sulphates and water vapour. Recent work by Professors David Lee and Piers Forster estimates these non-CO2 emissions to have an effect as great as CO2. So the total climate impacts are about double those of CO2 alone. But all the non-CO2 emissions are summarily dismissed in a supporting consultation paper: “There is, however, no scientific consensus on the effect of non-CO2 emissions at altitude at present.” (https://aec.heathrowconsultation.com/documents/peir-vol3-chap9-carbon/ para 9.4.6).

The DCO should show how a third runway would be compatible with the UK’s climate target. It should not accept Heathrow’s claim the emissions from international aviation ‘don’t count’.

Biodiversity

There is a considerable loss of habitat proposed, including some within the Colne Valley Regional Park, Staines Moor SSSI (Site of Special Scientific Interest) and a number of locally designated sites. This habitat loss will result in wildlife being lost

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from areas on which they have depended for foraging, sheltering or as movement corridors. .

This shown by the ‘Preliminary Environmental Information Report Non technical Summary’ which says: “Significant negative effects are predicted at:

Staines Moor SSSI, due to land take and land cover change resulting in habit land or degradation.

On local designated wildlife sites and Local Nature Reserves. Also on veteran trees, due to land take and land cover change. On rivers and standing water. Various species of fish and otters, kingfishers, various bat species, barn owls

and badgers. Some breeding and wintering bird assemblages.

Due to increases in NOx, designated sites including:

The South West London Waterbodies Special Protection Area (Ramsar site) Staines Moor and Wraysbury Resevoirs, SSSIs.

Land quality

Up to 958ha of good quality agricultural land is present within the Site"

Heathrow has committed to providing an overall increase in biodiversity as part of the DCO project. We see no evidence that this will happen. The limited measures proposed to enhance or create habitat do not make up for the huge losses, thereby leaving a net loss of biodiversity

13. Please tell us if there are any other initiatives or proposals that we should consider in order to address the emissions from airport related traffic or airport operations?

There should be emissions-related charges for all aircraft using a third runway and other runways at Heathrow, covering both air pollution and greenhouse gases. There are well-established figures for the economic cost of CO2 (published by BEIS) and air pollutants (Committee on the Medical Effects of Air Pollutants) which would enable the charges to be worked out.

This would be a win-win situation. Because there would be a financial/economic impact, airlines would be incentivised to use less polluting and more efficient planes. And to the extent that planes still continued to emit, there would be charges consistent with the Polluter Pays Principle. The charges could be used to mitigate emissions elsewhere and/or pay compensation to those affected. Emissions-related charges would tick all the boxes – social, environmental and economic.

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There is an issue as to how compensation should be dispensed, for example by a reduction in Council Tax. However, this can be resolved later (by 2025). The key issue for now is to ensure the right levels of charge are set so that the correct economic signals are given to the airport, the airlines and aircraft manufacturers.

14. Please tell us what you think about our proposals to help health and well-being. Are there any other proposals that you think we should consider to address the effects of the Project on the health and wellbeing of our colleagues, neighbours and passengers?

A third runway will produce more noise, more air pollution, more congestion, loss of Green Belt and more climate change. These will have an adverse effect on health and well-being.

We are not clear what benefits for health and well-being there would be. We note the ‘claim of last resort’ used by Heathrow on health, frequently used by proponents of damaging schemes, namely that the scheme will make people richer and if you are richer you are healthier: “The economic and employment benefits of the Project are expected to have a long-term and major positive benefit for health ..” (top of third column on page 73 of the main consultation document). This is an extremely questionable argument, but even if it were generally true, it would not be valid for Heathrow expansion. The reason being that the net economic benefit (estimated by DfT) is negligible and the jobs created will not appreciably reduce unemployment.

15. Please tell us what you think about our noise insulation schemes.

The small scale of noise insulation is hidden from the main consultation document which simply refers to “eligible properties”. The ‘proposal for mitigation and compensation growing sustainably’ document proposes noise insulation only for properties exposed to daytime noise above 63dB Leq, reducing to 60db. Given that many people are affected at noise levels down to 51dB and below, there is a good case for providing insulation at properties exposed to aircraft noise down to 51dB.

Noise insulation is obviously only useful when one is indoors. Outside, noise cannot be mitigated (other than by using less noisy aircraft). It is therefore reasonable that residents should be compensated for outdoor noise. A noise compensation scheme could also support those who are below the noise insulation criteria but who are nonetheless affected by aircraft noise.

16. Please tell us what factors are most important as we develop our proposals for noise management, in particular our proposals for the design and implementation of a noise envelope.

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Government policy now recognises some people can get annoyed when noise averages out over the year at 51dB. The World Health Organisation (WHO) considers that the level is even lower – 40dB at night and 45 dB day. Heathrow should commit to using at least the 51LAeq contour to frame the envelope but to review this every 5 years in the light of any new evidence that a lower figure would be more meaningful.

It is the sheer number of planes overhead that really disturbs and this is not fully taken into account with the Leq metric. For example, ‘N60’ would indicate the number of planes passing overhead in excess of 60 decibels.

Another metric that has been proposed a single-mode contour. This means that the noise in any particular area is only measured on the days when the planes are flying over, i.e. excluding the days when there are no planes because of wind direction. It is a more meaningful measure in places such as Hanwell (Borough of Ealing) and Osterley Park (Borough of Hounslow) where planes are only a problem during easterlies. When the very considerable noise during easterlies is averaged with no noise during the westerlies the average is lower such that is claimed there is no significant annoyance. But there most certainly is annoyance when people want to enjoy their parks and gardens in summer (the time of most easterlies).

Rather than use multiple metrics, we propose that the currently recognised metrics (Leq, N60, etc) are combined into a single metric. There are standard statistical techniques which can be used to weight and combine individual metrics so that the extent to which each of the metric is an ‘explanatory variable’ of annoyance is allowed for within a single overall metric. This would simplify presentation, communication and estimating compensation.

Noise reduction is conspicuously absent from Heathrow’s proposals. Efforts should be made to reduce the noise from individual aircraft. This can be achieved by regulation, simply banning the nosiest aircraft from Heathrow. Or, as noted below, by noise-related charges. The great advantage of these approaches is that they benefit everyone who suffers (or will suffer) from aircraft noise.

Alternative designs of noise envelope and re-arrangements of flight paths, including respite and runway alternation, do not reduce noise overall. They can benefit one area, but only at the expense of another.

As noted in Q15, sound insulation is only available for a small proportion of people affected by noise. For the many others affected by noise, there should be compensation available.

There are already noise-related landing charges at Heathrow and, by extending and rationalising these, it would be possible to finance compensation. DfT/CAA have a

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methodology (spreadsheets) which enable the economic cost of noise to be calculated for any particular fight path scenario.

This would be a win-win situation. Because there would be a financial/economic impact, airlines would be incentivised to use less noisy planes. And to the extent that planes still continued to be noisy, there would be charges consistent with the Polluter Pays Principle. Noise charges would tick all the boxes – social, environmental and economic.

There is an issue as to how compensation should be dispensed, for example by a reduction in Council Tax. However, this can be resolved later (by 2025). The key issue for now is to ensure the right levels of charge are set so that the correct economic signals are given to the airport, the airlines and aircraft manufacturers. 17. Please tell us what you think of our proposals for maximising new jobs and training. Are there any other ways that we can maximise skills and training opportunities to benefit our local communities?

The main consultation document says: “Heathrow is a cornerstone of the local economy and we are one of the largest single-site employers in the country. Expansion will provide a range of new employment and training opportunities.”

Heathrow is undoubtedly a large employer, but this is not a justification for trying to expand the number of jobs. Heathrow is significant part of the local economy but that, too, is no justification for expansion. Indeed, there is a good case for diversifying the local economy, not concentrating it on aviation. Relying on about the most damaging and unsustainable sector of the economy is a high risk strategy.

“Maximising new jobs” sounds superficially attractive. But analysis suggests otherwise. Unemployment is low in the area around Heathrow. The causes of unemployment are deep and complex. They include the state of the national economy, the economic cycle, education, skills, social factors, regional differences and demographics. There is no evidence that unemployment would be helped by building a new runway at Heathrow.

The Airports Commission recognised that extra jobs locally would be achieved by increasing the population: “The additional employment supported by Heathrow’s expansion would lead to a significant requirement for additional housing. The Commission’s analysis indicates this would total between 29,800 and 70,800 houses by 2030 within the local authorities assessed as part of the local economy assessment. This additional housing and population growth would also require substantial supporting infrastructure including schools and health care facilities.”

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West London and areas beyond are already struggling with a shortage of school places, hospitals close to breaking point, overcrowded transport, green spaces being built on and even pressures on water and sewerage. The last thing councils, communities or the NHS need is even more pressure. Especially when they will have to foot the bill for any enhancements to infrastructure.

In conclusion, we agree there would be some extra jobs as a result of a third runway. But this does not translate into a reduction in unemployment. The local economy would be a little bit bigger as a result of a third runway. But because the economy would be distributed among more people, there is no reason to think people would be better off. Councils and local communities would bear the social burden and pay the resulting costs of a new runway.

If there was policy to try and increase jobs in the aviation sector – and WLFOE is not suggested there should be – it would be more sensible to encourage expansion outside London and the SE. The Heathrow area is already overcrowded and overdeveloped with an economy that is overheated and suffering a skills shortage. It would seem much more sensible to try and stimulate economic activity outside the SE.

18. Please tell us what you think about our approach to addressing effects on the historic environment, including any particular proposals you would like us to consider.

Places as diverse as Hampstead Heath, the Tower of London, Hyde Park, Fulham Palace, Windsor Castle, Wimbledon and Royal Botanic Gardens Kew are likely to get more noise (than with two runways). This will reduce the attractiveness of London to Britons and also, ironically, to the very people Heathrow wants to attract, namely foreign tourists.

19. Please tell us what you think of our proposed approach to manage the future growth of the airport within environmental limits. Is there anything else we should consider as we develop the framework and its potential limits?

Our views on air pollution and climate change area are explained in Q12. As we show, there are no genuine enforceable limits set out, either for air pollutants or greenhouse gases.

Our views on noise are set out in Q16.

20. Please tell us what you think about our proposals for the Fund, including what it is spent on, where it is spent, and how it should be funded and delivered.

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We do not have comments on the specific question asked. However, we wish to make it clear that the Community Fund must in no way be regarded as a substitute for full and proper compensation for those affected by noise, blight, air pollution, congestion, loss of green space, loss of amenity and climate change

21. Please tell us what you think about our interim Property Policies, including our general approach to buying properties and land and our approach to compensation, including our discretionary compensation offers.

We have no comments at this stage.

22. Do you have any comments on what we think will need to be contained in our DCO and do you have any views on anything else the DCO should contain?

We understand that is an indemnity was offered to Heathrow so that if a future government did not support expansion (and this could include for example not paying for surface access, not reversing the whole NPS decision in Parliament) Heathrow would be reimbursed by the government. This is a large potential public subsidy to Heathrow. It should have been highlighted in the consultation and must be taken account of in the DCO because it could well colour consultees’ overall view of the scheme and thus their responses to the consultation.

The impacts only take account of a third runway. But, according to Heathrow, the airport would be full again by about 2035. Applying the same arguments that were deployed for a third runway (trade, jobs and the economy), Heathrow will undoubtedly start lobbying for a 4th runway. The claim that they do not want a 4th runway should not be believed – any more than their denials of a third runway were believed at the time of Terminal 5 public inquiry. There is no national policy to cap Heathrow at 3 runways. For these reasons, a 4th runway would follow logically on from the 3rd in about 2035. Since impacts up to 2050 (for climate) are being considered, the DCO process needs to take account of a 4th runway.

We see nowhere in the main consultation any comment on public safety/danger (deaths and injuries of people on the ground as a result of a crash). Heathrow is already by far the most dangerous airport in the country in terms of total societal impacts. This is due to the largest number of the biggest planes flying over the largest population. A third runway would increase societal risk by about 50% (because movements and passengers are increased by about 50%). The DCO process should address this issue of public safety.

It is essential that the DCO process decides what the pertinent issues for consideration are, not just rely on those raised in the Heathrow application. Otherwise key issues such as a 4th runway and public safety/danger could be ignored and Heathrow would be controlling the agenda rather than the Inspectorate.

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23. Do you have any other comments in response to this consultation?

We have no comments that are not already covered in the preceding Q&A.

24. Please give us your feedback on this consultation (such as the quality of the documents, website and events).

We, along with other groups and even more so with the public we spoke to, found the volume and complexity of the consultation documents daunting. (There are, we understand some 7,000 pages.) This places the general public at a huge disadvantage compared with Heathrow and its well-resourced supporters. It is essential therefore that DCO process scrutinises and challenges the evidence and veracity of Heathrow’s claims, irrespective of whether particular issues have been raised or statements challenged by respondents to this consultation.

We recognise that with a project of this scale and complexity there will inevitably be a large volume of printed/online material. For this reason it is essential all the key issues are mentioned and information is presented in an understandable and balanced way in the summary documents and the consultation boards at the events. This was manifestly not so – the reality of the impacts was systematically played down and key issues ignored.

Indeed, it would have been hard for Heathrow to do otherwise. To give a truthful and balanced picture would require messages contrary, and very obviously so, to those of Heathrow’s huge public relations (propaganda) campaign, including that of Back Heathrow. The DCO must therefore take account of the way that responses to the consultation would have coloured by bias and selectivity in the consultation documents.

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