Revised Draft Airports Policy Statement: A Guide to Respond to Heathrow Expansion

Please add your voice against Heathrow expansion.

The Department for Transport (DfT) has launched another consultation on the Revised Draft Airports Policy Statement (NPS) with increased passenger forecasts and an updated air quality plan for airport expansion; it also covers noise, carbon emissions and surface access. The NPS needs Parliamentary approval before Heathrow Airport can submit a development consent application to the Planning Inspectorate. The consultation closes on 19th December so please add your comments. Here are some notes to help you answer each question in your own words, if possible:

Question 1 (about whether revised passenger demand forecasts and air quality assessments are complete and accurate)

Passenger forecasts

NO because the forecast model is based on growth in passengers using Heathrow’s preferred method of carbon traded Global Growth. Carbon trading just means paying to offset your carbon emissions so other parts of the economy must reduce theirs – just shifts the problem.

National statistics for UK greenhouse gases from aviation show that carbon dioxide emissions for international aviation have increased from 15.4 million tonnes (Mt) in 1990 to 33.3 Mt in 2015 while domestic aviation has remained the same at 1.5Mt.[1]

Emissions from aviation make up 6% of total greenhouse gas emissions and these have doubled since 1990, whilst economy-wide emissions have reduced by more than a third.[2] Carbon dioxide (CO2) lasts for hundreds of years[3] so what we are producing now will affect our children and grandchildren. Global warming is producing more extreme weather events, increasing the flood risk across the UK and the rest of the world at huge economic and human cost.[4] The best way to curb aviation emissions is to manage demand and stop airport expansion.

Passenger demand at all UK airports could only increase by 60% between 2005 and 2050 [5] to comply with the UK aviation emissions target of (37.5 million tonnes of CO2 by 2050) recommended by the Committee for Climate Change (CCC) – yet by 2015 it had already increased by 11% without a third runway at Heathrow. Expansion at Heathrow means regional airports need to contract.

Two thirds of passengers at Heathrow are flying for leisure not business, taking advantage of cheap tickets to the detriment of those living underneath flightpaths. 15% of people make 70% flights yet Government has decided aviation growth should take priority over the health and well-being of local communities and preserving our beautiful world. Last year, 22.7 million [6] (30%) of Heathrow’s passengers were just transfer passengers – spending in the airport shops and contributing to the profits of the airport’s mainly overseas shareholders. No benefit really to UK economy – we just get the added noise and pollution. The Mayor of London last year pointed out that expansion would mean an extra 200,000 Londoners, including 43,200 children, being exposed to an unacceptable level of noise every day, leading to health problems related to stress and sleep disturbance.[7]

There is no analysis of the impact of Brexit on passenger demand forecasts, which is surprising, given that around 40% of Heathrow’s 75 million passengers are from the European market and the EU Open Skies arrangement is governed by the European Court of Justice. A recent press article mentioned that the relocation of the European Medicines Agency, from Canary Wharf (to Amsterdam), would result in around 700 fewer London hotel rooms being booked and 1000 fewer air passengers, per week.[8]

Question 1 (continued)

Air Quality

NO because:

Keith Taylor, MEP, wrote recently about the detrimental effect Heathrow is already having on the air we breathe: “the Government estimates that 86% of the toxic air in the surrounding area is related to Heathrow flights and traffic – an increase from its previous estimate of just over 70%. At the same time, Nitrogen dioxide levels have risen at nine out of 12 monitors in west London within a 2km radius of the airport between 2015 and 2016. While sites in Hillingdon and Hayes already breach EU limits. Despite this and the clear warning from the Government’s own advisers that a third runway will see even more sites exceed EU air pollution limits, the Government still maintains that its feeble air quality plan – over which it is facing another legal challenge – will sufficiently bring down pollution levels across the country to allow Heathrow to pump out even more toxic fumes. It’s magical thinking, but, even if it wasn’t, the argument is a complete nonsense that assumes the only motivation for reducing air pollution elsewhere in the region is to allow the airport to pump more toxic air into our atmosphere.” [9]

Nearly 10,000 Londoners die each year from polluted air and London’s population is expected to grow to 11million by 2050 [10] which will increase traffic and air pollution. Heathrow’s public pledge that it can add another quarter of a million planes a year without increasing airport traffic is laughable, particularly as it makes so much money from parking – up again to £58 million in car parking revenue for the first 6 months of this year. Currently around 19 million (40%) of Heathrow passengers use public transport and if the airport is to increase this to 45% by 2019 [11], that will add well over 2 million passengers a year to an already overcrowded transport system. Don’t forget that Heathrow also plan to double freight to 3 million tonnes by 2040 much of it going back and forward on local roads, as well as local motorways M25, M3, M4 and M1, which are already full . Many current transport improvements were planned to cope with population growth rather than airport expansion and surface access is a major contributor to airport related pollution – yet there is no agreement about the costs between the Government, Transport for London and local authorities.

The Health Impact Analysis concluded that a 3rd runway at Heathrow would result in increased noise, increased emissions from aircraft and road traffic, and poor air quality. It also said the threat to housing conditions could increase respiratory disease and depression. A 2nd runway at Gatwick was judged to have a lower detrimental impact on health. The report also recommended that a specific Health Impact Assessment should be undertaken. In the 2017 Plan Update to Air Quality Re-Analysis, the DfT passes the problem to cash strapped councils and the Mayor of London to introduce low emission and clean air zones then uses projections of benefit as a justification for expanding Heathrow, cancelling out any benefit to the air we breathe.

Question 2 (Whether changes to NPS based on clarity/intention and or Government Policy since Feb 2017 are suitable)

The impact of noise.

The impact of noise will be very much worse with a third runway at Heathrow and the NPS assumes extreme concentration of flight paths in its modelling. Yet, we are being deliberately kept in the dark about where these ‘noise sewers’ will be, although Teddington is likely to be impacted. Respite will not work in this densely populated area as the flight paths are too close together. Flight path concentration using Performance Based Navigation (PBN) is part of Government’s commitment to modernise airspace but they are pushing ahead with airport expansion because they know that wherever PBN has been introduced there have been protests and legal challenges. People from Frankfurt [12] to airports across USA, like Phoenix, have been forced to move or have their lives ruined by incessant noise.[13] Many are taking legal action against the FAA (aviation authority) and hundreds of protestors have marched through Frankfurt airport, almost every week, since 2011.

Dense Population

The boroughs around Heathrow are much more densely populated than the national average and well over three quarters of a million people are already subjected to excessive noise impacts from the airport. Government estimates that approximately 585,600 people around Heathrow are currently affected by noise at/over average levels of 54decibels: the threshold at which Government now concedes people become significantly annoyed, and by their own reckoning this will increase to around 653,900 by 2030 with expansion. TAG views Heathrow’s noise mitigation plans with scepticism and we already object to the way Government measures noise (by averaging it out over a 16-hour ‘day’ period and where the reported level is suppressed using quiet periods when areas are not overflown to hide the real impacts when they are), disguising the true numbers affected. Heathrow proposes compensation of up to £3000 for acoustic/noise insulation for residential property from 55 to 60 dB LAeq (16hr) contour but many thousands will fall below 55dB and not be eligible at all.

Inflated job promises

The Airport Commission report stated that the Heathrow 3rd runway would lead to 59,000 – 77,000 local jobs, yet, after a further review, the DfT concluded that the number of jobs might be 37,740 by 2030 and 39,100 by 2050, rather than the 78,360 forecast by the Airports Commission.[14] Now it seems that the DfT has applied its own magic formula and come up with a figure of between 57,000 and 114,000 local jobs by 2030 and 39,000 and 78,000 by 2050. Heathrow has nearly 10 million more passengers today than 8 years ago, yet the number of direct/indirect staff is about 600 fewer at 76,000. Passenger growth does not always equal job growth.

West London currently has low levels of unemployment compared to Birmingham, Newcastle, Merseyside or Glasgow [15] and Hounslow, where many airport workers are based, has a significant shortage of housing with 10,000 households on its waiting list and 1,086 in temporary accommodation in April 2016.[16] There are already high rates of overcrowding in Ealing, Hounslow, Slough and Hillingdon. The 3rd runway will lead to a demand for 300 to 500 additional homes per local authority per year as well as extra school spaces, 2 additional health centres (14 GPs) and 2 primary care centres per local authority to 2030. Depending on the scenario, expansion at Heathrow might attract up to 71,900 additional households to the area by 2030 yet 1072 residential properties could be demolished for airport construction and surface access. Meanwhile there will increased flood risk, loss of wildlife habitat and a historic village will be split in two, with intolerable conditions for those remaining.

Unfounded economic benefits

The economic benefits, originally mooted as £211billion by Heathrow’s PR, were revised downwards to £61 billion by the Airports Commission. However, the total net benefit for 3rd runway, to the UK over 60 years, was just £1.4 billion in the carbon capped scenario. The figure has now been bumped up to £74 billion (with carbon trading) for Heathrow 3rd runway and £75 billion for Gatwick 2nd runway, after the revised passenger forecasts. Now the NPS predictions for the Heathrow scheme (i.e. after costs are accounted for) are between minus £2.2 billion to plus £3.3 billion – so either a LOSS of £0.57 per head of population or a gain of just £0.87, over 60 years. Not even enough for masks and earplugs.

Infrastructure costs

Heathrow shareholders received £188 million in dividends in the six months ending 30 June 2017, yet the contribution the airport has offered to the cost of infrastructure is £1billion with increasingly bizarre suggestions of planes using ramps over motorways to save cash. TFL estimated the infrastructure costs could be £15 to £20 billion – so who’s going to pay?

Other points to consider

No further airport expansion should take place: the hub model is outdated and people prefer to fly direct. There’s plenty of capacity across the five London airports and Government should be encouraging more sustainable forms of transport.

Heathrow’s ‘much valued’ offer of a six and a half hour scheduled night flight ban between 11pm and 7am is to be determined after consultation so could be from only 11pm till 5.30am – giving us well short of the 8 hours sleep recommended by the World Health Organisation.

There have been so many wildly varying predictions for both benefits and mitigation that there is little public trust in many of the modelled statistics which seem to alter according to the required conclusion. One thing hard to mitigate against is the increased risk of terrorism.

The Airport Commission cannot be considered independent when it was chaired by Sir Howard Davies, who was an employee to one of Heathrow’s biggest shareholders at the very time of his appointment.

Here’s the link to respond:

You can do it online, email or write.

Revised Draft Airports National Policy Statement: new runway capacity and infrastructure at airports in the South East of England October 2017 (88 pages)




[4] Stefan Rahmstorf, professor of Ocean Physics, Potsdam Institute for Climate Impact Research (PIK)




[8] Evening Standard 13 Nov 2017









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One Comment

  1. Jean Scott
    16th December 2017

    Why, oh why are these people I still insisting on a 3rd Runway for Heathrow,. West London is already a heavily congested area for traffic, and the population around Heathrow is very densely populated.
    Surely Gatwick deserves a SECOND Runway. All outbound flights give way to incoming traffic (obviously), but why not provide a second Runway to provide further capacity, and divert some flights away from Heathrow.
    Another option is to expand Birmingham. Has this even been considered? Many passengers fly from Northern regional airports in order to fly long-haul from Heathrow. My sister , for example!! Thus increasing pollution, noise and air quality. Why does London always take priority over northern cities? More businesses should be given tax incentives to relocate to northern cities, which desperately need a boost to their economy. The north/south divide needs to decrease, and more should be done by government and large businesses to actively decrease this inequality.

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