Analysis of Heathrow’s Response to the AC Final Report – May 2016

heathrow-airport-aerial-view-1300TAG analyses the response from Heathrow to the Airport Commission’s Final Report and highlights some of the discrepancies that Heathrow will be unable to promise.

Heathrow: “We will support a legally binding ban on night flights for six and a half hours from 11pm to 5.30am.”

The key word not mentioned here is ‘scheduled’; in April 2016, 258 flights were logged in the Night Shoulder period (23.00 till 23.30) of which 251 were not scheduled.1

Heathrow does not count these as night flights as it is their standard practice to let late- running planes depart after the last official scheduled departure time of 22.50. Too many planes are crammed into late evening slots and frequently run late, which suggests a ploy to get round night flight restrictions. Heathrow’s plan is to bring scheduled departures forward to 5.30am (half an hour earlier than present) as soon as the necessary airspace has been modernised (in advance of when a third runway would be completed). Very few people would welcome this change as it would be extremely destructive to sleep patterns and living conditions around the airport.

The World Health Organisation recommends an 8 hour night period and recent scientific research stresses the importance of getting 8 hours of continuous sleep to prevent amyloid build up in the brain which can cause Alzheimer’s.2

Heathrow: “We will support a clear and legally binding noise envelope and support the introduction of an independent noise authority.”

At present, despite considerable community representation and independent evidence, Heathrow fails to accept that a far wider area round the airport is affected by levels of noise above WHO guidelines. TAG has consistently challenged Heathrow, the CAA and the DfT on the way aircraft noise is measured and on the way planes are flown (which increases noise levels on the community). Independent studies have confirmed TAG’s claims.3

The concept of a Noise Envelope sounds good but that depends on how noise levels are assessed. The World Health Organisation advises that average noise contours should not be the only measure of aviation noise and that maximum noise levels and other metrics such as SEL (single exposure level which takes account of the period of each event) should be used in conjunction with yearly averages (which fail to reflect reality as they ignore the fact that our area only experiences noise from planes departing around 30-35% of the time). At present, the CAA and DfT use only average noise contours set at threshold levels far in excess of WHO recommendations. The result is that the DfT and CAA vastly under report the number of people seriously affected by aircraft noise – for example our area falls outside the Airports Commission’s ‘Study Area” and Teddington and the majority of Twickenham fall outside of all published noise maps.

Heathrow: “We will maintain more predictable periods of respite and publish a publicly available timetable so local people know when planes will fly over their homes.”

The key point is that respite has been used to provide some relief for communities (like Richmond and Kew) under arrival routes – but this is respite from a set of conditions which have been allowed to build up over time and would be totally unacceptable in any other field of human activity. At present these areas benefit from runway alternation and only experience extreme noise for 8 hour periods (which using the CAA and DfT’s averaging noise measurement systems greatly underplays the extent of distress caused when the areas are actually under the incoming flights.

The circumstances under departures – which our area experiences 30-35% of the time when the wind comes from the east – are quite different. Due to practices that have been allowed to build up for somewhat obscure historical reasons, our area suffers more or less continuous disruption for over 18 hours a day.

It should be noted that the Airports Commission have used assumptions concerning respite to justify an expansion of flights by over 50%. However its assumptions reduce the period of respite from 8 to 4-5 hours a day. This, taken with the inappropriate metrics referred to above, leads to a vast underestimate of the numbers of people who will be affected by the Commission. Further other unproven and untested assumptions about respite have been used to underplay the extent of the disruption from noise that would be caused by expansion. In particular, in the even more congested use of airspace above densely populated residential areas with expansion it will never be possible to achieve sufficient separation between flight paths to achieve acceptable respite.

In summary, whilst respite has helped protect some communities from the worst ravages of aviation, it should never be used as a tool to support (in conjunction with a flawed metric system) a massive expansion of Heathrow.

Heathrow: “We will introduce a scheme to ensure that airport users pay to compensate local communities for the impacts of the airport.”

There is a very narrow definition of local communities and no compensation will apply to residents of Teddington or Twickenham, which have been designated to be outside of Heathrow’s noise exposure contour (the area considered to be affected by noise).

Heathrow: “We will establish an independent Community Engagement Board, under an independent Chair, which will have real influence over how Heathrow meets these.”

Our experience, so far, of Heathrow’s attempts to engage with the community has been disappointing. Its Community Noise Forum has been meeting for over a year and no tangible improvement in the noise conditions around the airport has been achieved to date. How would this Board be selected and by whom?

Heathrow: “The UK Gov’t would need to act to create an Independent Noise Authority and Heathrow hope it would have statutory powers.”

TAG would welcome the creation of an independent Noise Authority as:

      • More people are affected by noise at Heathrow than at any other major European airport (approximately 30% of all people in Europe affected by unacceptable noise levels live around Heathrow)
      • A 3rd runway would affect millions of people (as noted the Airports Commission has vastly underplayed the impact due to the use of flawed assumptions, measurement bases and thresholds)
      • Loud aircraft noise affects blood pressure, even when asleep, and is linked to cardiovascular disease, strokes, dementia, and delayed learning in children 6

Another quarter of a million planes will not lessen the noise.

However it is unclear what, if any, real power the Noise Authority will have to influence industry practice. The DfT has so far resisted the ability for such a body to have effective powers of enforcement (e.g. through imposition of meaningful fines or banning orders).The current industry regulator – the Civil Aviation Authority – is funded by the aviation industry and has stated that it has no remit in improving the noise environment for residents.

Heathrow: “We will incentivise a major shift in travel for those arriving at the airport through measures including new rail infrastructure and including the consideration of a congestion or emissions charge…and to increase the routes of bus services serving local employees…there will be no more airport related traffic on the roads after the new runway….”

TfL said the airport and Airports Commission had “significantly underestimated” the cost of improving transport access; the Commission estimated £5bn whereas TfL believed it would be nearer £20bn. The population of London is growing at around 110,000 per year which will quickly absorb much of the extra capacity created.

Parking revenue was a major money-spinner for the airport at £108 million in 2015 – £8 million higher than 2014 and a brand new 800 space car park was opened in Feb 2015.8 At the end of the day, is it believable that there will be no increase in traffic resulting from another quarter of a million planes when the airport benefits financially from increased car use? We have already shown that there will be an increase to traffic accessing Heathrow.

Heathrow: “Additional operations at an expanded Heathrow will be contingent on acceptable performance on air quality and will be in accordance with air quality rules….we will create an ultra-low emissions zone for airport vehicles by 2025”

Heathrow has not managed well with its targets for its own vehicles so far

    • Carbon emissions from Heathrow Airport Ltd’s vehicles increased from 8,013 tonnes in 2013 to 9,804 tonnes in 2014
    • CO2 from aircraft on the ground, and during departure to 3000ft, increased from 1,235,869 tonnes in 2013 to 1,242,471 tonnes in 2014.9

If they can’t reduce the pollution they already cause, why should we believe their promises?

  • Premature deaths from Heathrow pollution would treble by 2030 if a third runway is built and due to prevailing winds in the UK, emissions would be blown over the whole of London.10
  • Air quality in Hounslow still does not meet EU recommended limits and London remains among the most polluted capitals in Europe.

Heathrow: “We will accept a commitment from the UK Government that will rule out any fourth runway.”

That sounds familiar…remember the Terminal 5 inquiry?

We have since repeated often that we do not want, nor shall we seek, an additional runway. I can now report that we went even further at the Inquiry and called on the Inspector to recommend that, subject to permission being given for T5, an additional Heathrow runway should be ruled out forever…

However they changed their mind soon after Terminal 5 was given the go ahead. Even if this government agreed, any future government could reverse the decision.


Heathrow: “Heathrow expansion will create up to £211BN in economic growth… up to 180,000 new jobs…across the country.”

Heathrow’s freight in 2014 was £101 billion, with exports of £48 billion – the rest is imports, which is not good for the economy.

But all those planes must be good for tourism? Well, no… they’re not.

In the year to Feb 2016, UK residents travelling abroad spent £39.2 billion compared with £21.82 billion spent by overseas visitors coming here.11

Most air travel takes money out of the economy and the loss of tourism jobs in the UK has a very detrimental effect on the regions.

Infrastructure for the third runway could cost anything between £15 and £20 billion – Heathrow has offered to contribute only £1.1 billion.12

Heathrow directors stand to gain a bonus for persuading the Government to back the third runway. The airport (90% owned by foreign investors) has paid just £24 million in corporation tax since 2006 despite paying out over £2 billion in dividends to its owners since 2012.13

Heathrow employed 6714 staff in 2015,14 333 fewer than in 2014 despite a 2.2% increase in passengers. Heathrow forecasts 179,800 new jobs by 2050, in direct/indirect employment across the UK, as a result of foreign investment and trade. There are, of course, no guarantees on this.


  1. Health costs

The Mayor of London’s report indicated expanding Heathrow would create health costs up to £25 billion over 60 years. 124 more schools and 43,200 more school-age children residents would be exposed to aircraft noise above 55 decibels.15

2. Climate Change

‘Aviation is one of the fastest-growing sources of greenhouse gas emissions. Someone flying from London to New York and back generates roughly the same level of emissions as the average person in the EU does by heating their home for a whole year. Direct emissions from aviation account for about 3% of the EU’s total greenhouse gas emissions. The large majority of these emissions comes from international flights. By 2020, global international aviation emissions….could grow by a further 300-700%.16

UK aviation emissions will exceed the maximum level of 37.5 Mt under the Climate Change Act, without any expansion at all. Regional airports would need to be capped if airports in the South East expand or there would have to be wildly unrealistic carbon capping elsewhere in the economy.

No amount of promises can change that.

11 Heathrow Operational Data April 2016


3 Teddington Flight Path Analysis Final Report’ PA Consulting 2015

6‘Aircraft noise effects on health’ Dr Charlotte Clark, Queen Mary University of London travel-to- airport

9 environmental-impacts/climate-change

10 Prof Steven Barrett, MIT laboratory for aviation and the environment


12 transport-links-could-cost-taxpayer-17bn-and-worsen-pollution/


14 Heathrow Airport Holdings Limited Annual report and financial statements year ended 31 Dec 2015



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