HEATHROW D.C.O. CONSULTATION AND AIR QUALITY

In their Consultation Local Overview on Air Quality, Heathrow say:

“Aircraft flying into and out of the airport do not have a significant effect on air quality in the local area. This is because aircraft are so high that emissions are dispersed before reaching on the ground”

Is this correct? We say that it is not correct.

The Air Quality Expert Group of DEFRA state in their 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”.

One of the fundamental flaws of the Air Quality Consultation is that emissions from aircraft off the ground are not considered.

One of the many studies referred to by the Air Quality Expert Group of DEFRA (Hudda in Los Angeles) 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”

Yet Heathrow say in their consultation that aircraft do not have any significant effect on air quality!

A map in the Hudda study shows the indicated plumes and concentrations under the inward flight path  to Los Angeles Airport with a westerly prevailing wind – very similar to Heathrow:

Nitrogen dioxide followed the same pattern as PM2.5s and Black Carbon:

Yet the PEIR chapter 7 document seems to just brush over this describing the “Increased emission from aircraft, airfield activities and road traffic that could increase concentrations of PM, at receptors (residential, schools, medical facilities)” in Table 7.52 as “Not significant” and by way of comment that:

“Overall effects are considered to be not significant as no exceedances of the relevant AQOs [Air Quality Objectives] are predicted, the majority of receptors will experience negligible impacts and no moderate or substantial adverse impacts are predicted in any assessment year.”

We are simply being conned that there will be no significant increase in harmful emissions. Basic logic says that the installation of an expansion the size of Gatwick airport in a built-up residential area is going to increase the amount of harmful emission in the air. We need a proper independent assessment of the amounts and the effects of extra emissions.

What are these PM2.5s or ultra-fine particles, and do they cause harm? There is a full explanation in the TAG article at http://www.teddingtonactiongroup.com/2019/06/26/are-emissions-from-aircraft-harmful-or-not/ Particles or particulates are fine particles of matter, mostly carbon but can be metal, that are emitted. There are three main sizes:

  1. PM10s: These measure up to 10 micrometres (millionths of a metre) in diameter
  2. PM2.5s: These measure up to 2.5 micrometres and are termed “fine particles”
  3. Ultra-fine particles: These measure up to 0.1 micrometres or 100 nanometres.

They are all dangerous, but the fine particles and ultra-fine particles are particularly dangerous. They penetrate deep into the lungs and blood stream are also transmitted onto the next generation. They have been found in the placentas of expectant mothers and then affect the unborn foetus. There is a report of Queen Mary’s University Hospital on this.

The World Health Organisation recommended maximum dosages of particulates and nitrogen dioxide are:

PM2.5: 10 μg/m3 annual mean; 25 μg/m3 24-hour mean

PM10: 20 μg/m3 annual mean; 50 μg/m3 24-hour mean

NO2: 40 μg/m3 annual mean; 200 μg/m3 1-hour mean

The NOx and PM2.5 maps of the Greater London Air Quality assessments for 2020 are below and show:

They show that London and the areas surrounding Heathow are unlikely to be compliant with the WHO Guidelines or, in the case of NOx, the EU Regulations of 2008. They should have been compliant by 2015 under the EU regulations. It is contrary to the law (not to mention very contrary to the health of humans) to carry out activities that will cause further breaches of the air quality regulations.

The air quality monitoring by Heathrow is interesting. There are four Heathrow monitoring sites and they are all at the side of the airport rather than under the flight paths. They are neither in the “line of fire” of the jet exhaust of arriving or departing planes, nor are they in the line of the prevailing wind. They clearly do get some wind in their direction since the wind does blow from due north and due south for some of the time.

The Heathrow Airport air monitoring sites are illustrated below:

The records for PM2.5s recorded by the Heathrow air quality monitoring organisation for 2018 are below:The annual mean readings in the first column are all below 10 mg per cm3 and so below the WHO recommended limit (albeit by not a huge margin and only with 2 runways). The 24 hour and hourly maxima are a different matter altogether though. The  hourly maxima are shown with the green outlining and the 24 hour ones by red outlining. When the wind changes direction to due north or south, it may only blow for a limited period of time, blowing the particulates into the receptors. The daily maxima of PM2.5s are all well above 40 mg per cm3 and in one case over 60 mg cm3. The hourly ones are even higher. Those readings should be less than 25 mg per cm3 and so are far and away above the WHO limits – and this is with only 2 runways. The likelihood is that these emissions receptors would give readings hugely higher if they were put under the flight paths, but we do not have this data. This is a huge omission and one that should be rectified before any DCO is considered, let alone granted.

The Air Quality concentration levels are set out in PIER at Table 7.18. Those levels are not in accordance with WHO levels and are:

Firstly, we see that the PM2.5s limit is two and a half times the level recommended by the WHO. Secondly, we see that Heathrow are not operating any hourly or daily maxima of PM2.5s. Thirdly, neither Heathrow nor the Department for Transport test at all for ultra-fine particles even though they come within the legal definition of PM2.5s (because they are smaller than 2.5 micrometres)

Looking at this in more detail, we can go back to the London Air Quality modelling. Below are the readings from the Richmond Old Deer Park just next to the A316 (the main artery into the M3) where much heavy ground traffic, including lorries, travels. Below the map are the readings from the program. These are modelled readings for 2025. It can be seen that no less than 78% of NOx and 18.6% of PM2.5s at that point are from aircraft. Now, it will be said that the modelled emissions are up to 1,000 metres from the ground so will not fall at that point in Richmond. That is true, but they will fall downwind as seen from the studies referred to above, and so land at some point. The prevailing wind is from the west so most will fall over London at some point.

We see that far from aircraft not having a significant effect on air quality, they will have a very substantial effect all over London. We are being given false information and the consequences could be very substantial.

The Heathrow Consultation Document PEIR Chapter 7 Air Quality and Odour figures show the extent of the reported odours from the airport. On the basis that odours mean emissions, the figures make grizzly reading. Reports go as far east as Swanley and as far west as Reading. The map is below:

The London Air Quality Management forecasts show that parts of the area around Heathrow will not be compliant for NO2 emissions even in 2030

PM2.5s are forecast to still be well above WHO recommended levels in 2030 as well

Go back to the ANPS Appraisal of Sustainability and the risk of breach of the air quality regulations was assessed as a “High risk”. Look at the documentation produced for the DCO consultation; it is at least that, if not a certainty. Look at the reality of vastly increased traffic (surface access is another topic in itself) and see whether the extra traffic is likely to further breach air quality.

Air Quality is in competition with noise. The DfT “Aviation 2050 – The future of UK aviation” Consultation of December 2018 has, as a supplement, a report from the Institute of Sound and Vibration Research of Southampton University. The report is called “Technology’s Influence on the Levels of Environmental Emissions from Aircraft and the Trade-Offs Involved – Review and Future Prospects”. In order to reduce emissions including CO2, the design of jet engines is going to have to change. Details are given by Southampton University, but they state clearly that “Noise is unlikely to be any greater than equivalent future turbofan aircraft, but importantly, is unlikely to be quieter as is often supposed.” The claim in the PEIR Volume 3 Chapter 17 para 2.4.6 that the noise Quota Count (based on noise from each aircraft and air traffic movements) is likely to reduce from some 350,000 today to just 150,000 by 2050 is almost certainly false on the evidence of Southampton University.

So; when Heathrow say that air quality rules and guidelines can be complied with or that “Aircraft flying into and out of the airport do not have a significant effect on air quality in the local area”, don’t believe a word of it.

Share this post!

Be First to Comment

Leave a Reply

Your email address will not be published.