NOTICE OF MEETING
TAG’S SUGGESTED CONSULTATION RESPONSES
Heathrow Expansion Consultation prior to Development Consent Order
Proposed third runway, expansion and increased flights
Residents are encouraged to respond to the consultation, even if they feel that their responses will be to no avail. Responses will be considered by the Development Consent Order Planning panel. No response = no representation and is to Heathrow’s advantage.
The questions put by Heathrow in the consultation are replicated below. If you respond online, these are the only questions that you can answer, and all feedback has to be in answer to these questions.
This consultation web page is at https://aec.heathrowconsultation.com/
Instructions on how to respond are at https://aec.heathrowconsultation.com/how-to-respond/
Paper response forms can be applied for at the “Contact” web page at https://aec.heathrowconsultation.com/contact-us/ . Alternatively, they can apparently be obtained at one of the consultation events (details below). No postal address other than a freepost address is given on the website for a paper response. A “Feedback Form” as a pdf document for completion can be downloaded from the Consultation website at https://aec.heathrowconsultation.com/wp-content/uploads/sites/5/2019/06/3907-%E2%80%93-HRW-June-2019-Feedback-form-20pp_ONLINE2.pdf . This contains the topics covered in the online response. The completed form can be sent to Heathrow at “Freepost LHR AIRPORT EXPANSION CONSULTATION” or scanned and sent by email to the email address below.
You can respond by email saying whatever you want at email@example.com.
You can respond online at https://aec.heathrowconsultation.com/topics/ . This is done by topic area and each response is limited to 5,000 characters. It is clearly the method that Heathrow want us to use but that does not mean that we should necessarily do so – particularly if a topic is going to take more than 5,000 characters. Online is a little confusing in that not all topics can be responded to. Only those topics marked with a star * have the facility for a response. Thus “climate change” has to be responded to via the “Environmental Introduction” section. If you respond online, you will be required to submit some personal information such as address and whether you are responding on your own behalf or that of an organisation. Confusingly, the personal information is not required until you have completed the online consultation and are ready to submit it. There is the facility of saving your response and coming back later. You will need to give your email address for a code. You are strongly advised to keep a back-up of what you have posted as the saving facility does not always work!
Public Consultation dates and venues can be found at https://aec.heathrowconsultation.com/types/public-consultations/ .
Some of the forthcoming Consultation events are at:
23 AUG Chiswick
2pm–8pm : Chiswick Town Hall, Turnham Green, London, UK
24 AUG Windsor
10am–4pm : Windsor Youth and Community Centre, Alma Road, Windsor, UK
27 AUG Kingston Upon Thames
2pm–8pm : Kingston University London Penrhyn Road Campus, Penrhyn Road, Kingston upon Thames, UK
28 AUG Richmond
2pm–8pm : Richmond Adult Community College, Parkshot, London, UK
29 AUG Slough
2pm–8pm : The Curve Slough, William Street, Slough, UK
30 AUG Twickenham
2pm–8pm : York House, Richmond Road, Twickenham, UK
31 AUG Southall
10am–4pm : The Dominion Centre, Southall, UK
Document inspection locations where the Heathrow Expansion documents can be inspected are at:
Twickenham Library, Garfield Road, Twickenham
Richmond Reference Library, Old Town Hall, Whittaker Avenue, Richmond
Kingston Library, Fairfield Road, Kingston upon Thames
Below are the questions in the consultation with the draft responses of the Teddington Action Group
Consultation Questions reproduced in italics;
Suggested responses in bold type
Airport Masterplan Expanding Heathrow is about more than building a new runway. To operate a three-runway airport, we also need to build passenger facilities, infrastructure and relocate or replace some existing buildings and land uses. Our Preferred Masterplan sets out our plans for the future expansion of Heathrow. It has been developed taking into account feedback from previous consultations, as well as community, consumer and stakeholder engagement events and our ongoing design and assessment work. 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:
- increase noise impacts and create a noise sewer in Twickenham, Teddington and Strawberry Hill
- Have adverse effects upon the health of people within a large diameter of the airport
- 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 increase congestion
- increase pressure on housing, schools, doctors, hospitals, water and sewerage
- has, according to DfT, negligible economic benefit (Net Present Value of between -£2.5 bn to +£2.9 bn, and that excludes costs of climate change). The latest forecasts show that regional airports will suffer a reduction in destination choice because Heathrow will take more of the international destinations. Tourist traffic, which is a substantial part of Heathrow’s traffic, is a net cost to the Country since more people go abroad than come to the UK with a shortfall difference of some £22.5 billion per year. Increasing the outgoing tourist traffic is a net cost to the Country rather than a net benefit
Airport Masterplan The expansion of Heathrow will require a number of existing buildings and community facilities to be moved, such as the Immigration Removal Centres at Harmondsworth and Colnbrook. Please tell us what you think about the sites we have identified for buildings and facilities we are proposing to move.
We are strongly opposed to the planned destruction of communities for a purpose that is not justified in the light of the environmental damage that is going to be caused. The Net Present Value of the scheme over 60 years may, on the Government’s forecast, be less than zero. That amounts to plain vandalism
Airport Masterplan The boundary of an expanded Heathrow will be carefully designed to improve the overall appearance of the airport and help it blend into the surrounding area. 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.
We have no further views on this over our response to the noise and environment sections. The 260,000 extra air traffic movements will have a very substantial detrimental effect upon the environment. It is the wrong place to have an expanded airport for the effects of noise, pollution and safety. Safety has been an overlooked aspect in the light of the Boeing 737 Max 8 events
Surface Access Introduction Do you have any other comments on our Surface Access Proposals?
There will inevitably be extra traffic upon an infrastructure that is overstretched
Public Transport Proposals Our proposals for public transport at an expanded Heathrow are based on: Making best use of existing public transport; Supporting committed improvements; and Developing new public transport routes. Please tell us what you think of our proposals and how we could further encourage or improve public transport access to the airport.
The cost and demands upon public transport have been greatly underestimated. TfL have made submissions on this and we endorse these
Road User Charging Proposals We are proposing to introduce a Heathrow Ultra-Low Emission Zone by 2022, which will help us to manage emissions and encourage passengers to consider other modes of transport or cleaner vehicles. We are also proposing to use charging to supplement improvements to public transport and encourage its use, this is known as the Heathrow Vehicle Access Charge. This would be introduced from the opening of the new runway. 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.
Encouraging people to take forms of transport other than road use is to the good. However, Heathrow have grossly over-estimated the effects of their actions and grossly under-estimated the ability of public transport to cater for the increased needs generated by expansion. Public transport upgrades had already been planned for, without the added pressure of Heathrow expansion.
The M25 is a major artery around London and charging passengers in an ultra-low emission zone will not affect that. In addition, road traffic is the only option for freight that Heathrow handles, and again that will not be restricted. The net effect will simply be more traffic, more pollution, and more cost to the people who are levied with extra charges for the ULEZ. Clearly TfL and the London Assembly are of the same view, judging by their responses
Managing the effects of construction The expansion of Heathrow will require careful planning to ensure that it is successfully delivered in a way that considers the effects of construction on local communities, the environment and the transport network. Please tell us what you think of our construction proposals and the ways we are proposing to minimise effects on communities and the environment.
We have no comment on this
Runway Alteration In response to our previous consultation, we have developed a combined runway alternation and night flights scheme which prioritises respite for communities closest to the airport in the evening, night and early morning periods. As part of our plans for runway alternation, we are proposing four runway operating patterns. We would rotate between these patterns at either 2pm or 3pm and again at midnight each day. The sequence of these patterns will be repeated every four days. 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, potentially, give some daytime and night-time respite for communities. But this is a meagre benefit and below the amount of respite that is available now. The fact of the matter is that daytime respite will be reduced to about one third for many communities that currently get one half (whether this be per day or over a period of 4 days). Communities that are not overflown 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 with a false impression of a net benefit, thereby giving a totally misleading picture of the noise impacts.
Ban on scheduled night flights 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 note the proposed night flight ban is still only 11.00pm to 5.30am. 6.5 hours’ sleep is insufficient for adults and far too little for children. 8 hours is the required amount of sleep. We also note that a 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. Teddington and Twickenham will be exposed to more noise.
There is also a disturbing diagram in “Future Runway Operations” page 44 figure 4.9 showing the one-hour recovery time and the “early morning arrival” a 5.15am. The likely ban period will therefore run from 12 mid-night to 5.15am – five and a quarter hours which is less than the current night-time quota period.
In an area such as around Heathrow there should be an eight-hour outright ban (curfew) on all flights on all days.
Early growth We plan to increase the number of arrivals and departures at Heathrow prior to the new runway opening, to respond to the urgent need for additional airport capacity. Please tell us what you think about our proposals for managing early growth.
We are strongly opposed to the early growth proposals. They were not in the Airports National Policy Statement. The environmental consequences of an extra 25,000 air traffic movements over the existing 480,000 ATMs within the two-runway structure with in-bound and out-bound flights over both sides of the airport will be very severe. With incoming flights and departing flights going over the same sides of the airport, respite will be greatly reduced. Looking at the noise envelopes, the arriving planes will keep the departing planes beneath excessively low increasing the noise even further.
Nothing like this has been done in an area this densely used by aircraft over so many people. There are also serious safety implications in having approaching planes immediately above departing ones and then turning sharply into the final approach. A straight approach to a landing is far safer. The safety concerns were amply demonstrated by two events on the 11th August in which 2 planes had to abort their landings both veering off to the left over Teddington. Were the Independent Parallel Approach arrival mode IPA A2 in operation as proposed, the aborting planes would have had nowhere to go and might have flown straight into incoming planes on the circle over Teddington. Overall, the proposal seems highly dangerous and ill thought out. The same concerns apply to other areas with the other two IPA mode proposals
11. Local Neighbourhoods Our Heathrow Expansion and Your Area documents set out our development proposals, their potential effects and how we propose to reduce them. Please tell us what you think about our development proposals and the measures proposed to reduce effects in your area.
There is no proposal for Twickenham and Teddington even though the area will be very substantially affected according to the noise maps. The area will be affected by both inward and outward bound air traffic and will become a noise sewer. The area will be subject to a noise increase of 3 – 6 dB LAeq, which means a doubling or quadrupling of the number of planes in an area that is already subject to dreadful noise
12. Environmental introduction Our Preliminary Environmental Information Report carefully considers the effects that expansion may have on the environment and provides measures to reduce them or improve the current environment wherever possible. Please tell us what you think about our proposals to manage the environmental effects of expansion.
- We say that Heathrow expansion is not possible within the greenhouse gas limits set down by either the Paris treaty or our own domestic legislation.
- The assessment does not relate to any other greenhouse gases. The ANPS states that “The applicant should quantify the greenhouse gas impacts before and after mitigation to show the impacts of the proposed mitigation”. This has not been done.
- In support of its stance in this consultation, Heathrow states that it has followed advice from the Committee on Climate Change (“CCC”) given in 2017. That advice is out of date, and the current advice is contained in the CCC Net Zero Report of May 2019. Further advice from the CCC specifically on aviation is due by the end of December 2019. It is nonsensical to make plans for a project such as this without the advice of the CCC and without the inclusion of non-CO2 greenhouse gases in the light of the climate change emergency.
- The projected CO2 emissions, stated in Chapter 9 PEIR, for departing Heathrow planes are 20 MtCO2 in 2021 and by 2050, having peaked at over 25 MtCO2 per year in intermediate years. Current Total Air Traffic Movements (ATMs) throughout the year in the UK are 2,500,000 approx. Heathrow ATMs per year (now) are 480,000. Therefore, Heathrow’s proportion of ATMs of the whole is 19.05%.
- The Committee on Climate Change agreed that the target 80% reduction overall requires aviation CO2 emissions to be 37.5 MtCO2 by 2050 (which is 100% of the 2005 total). The proportion of Heathrow CO2 emissions to the target by 2050 was therefore 20MtCO2 ÷ 37.5MtCO2 = 53.33% of the total CO2 UK aviation emissions budget.
- 53.33% is considerably more than 19.05%. Therefore, Heathrow already (before expansion) has very substantially more than its share of the CO2 budget – indeed it will have over half of the budget even though it currently has less than one quarter of the UK air traffic movements. Although Heathrow has more long-haul flights departing, so needs an extra proportion of the CO2 budget, no calculations have been given on what that proportion should be or how it is justified in the light of ATMs of other airports (which also have declared expansion plans). Certainly, people are entitled under the Aarhus Convention to this information. We do know from the report of the Department for Transport entitled “Beyond the Horizon” of June 2018 that predicted CO2 is likely to be 40.8 MtCO2 in 2050 having peaked at 43.4 MtCO2 in 2030. Thus, aviation, with Heathrow expansion, will fail even on an 80% reduction over 1990 values – never mind a 100% reduction. Any reduction from 40.8 MtCO2 in 2050 is highly speculative and the Government should not be gambling with climate change in this way.
- CORSIA will not be an acceptable off-set. Firstly, mitigation (apart from carbon trading) will yield nothing like the required off-set.
- Secondly, off-setting by carbon capture, such as peat bogs and tree planting, needs to be available for industry and activities as a whole. It cannot be monopolised by just one industry such as aviation, which already enjoys more climate change and tax concessions or exemptions than any other industry.
- Heathrow appears to claim that either it is not within the climate change targets at all or, in the alternative, it can effectively subcontract its obligations by the airlines paying others to off-set its emissions by purchasing off-sets.
- Off-setting involves unsupervised activity and pays for the most vulnerable countries to reduce expansion of their economies in return for the sale of carbon credits.
- Heathrow itself clearly anticipates substantial climate change effects as set out in PEIR Chapter 10. Preparations for increased flooding, storms, droughts and heat are provided for. Para 10.10.6 refers to anticipated increases in temperature of 3°C by 2080 and 4.1°C by 2099
- If Heathrow expansion, which is the equivalent of a new airport the size of Gatwick being annexed to it, is permitted, then an existing airport of similar size has to close. Compliance with our domestic and international obligations is just not possible without this.
13. Air Quality Our surface access proposals will help us manage airport-related emissions and our Preferred Masterplan has been designed to reduce the impact of the airport on local air quality. Chapter 7 of the Preliminary Environmental Information Report, published as part of this consultation, sets out in detail the work we have done to assess the effects on air quality from the construction and operation of an expanded Heathrow. 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?
- Under the Heathrow 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”.
This is not only incorrect. Indeed, one of the fundamental flaws of the Air Quality Consultation is that emissions from aircraft off the ground are not considered.
- 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 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”.
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:
- Yet the PEIR chapter 7 document describes 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.”
All particulate emissions are dangerous, but the fine particles and ultra-fine particles are particularly dangerous. They penetrate deep into the lungs and blood stream and 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
- 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.
- The annual mean readings for PM2.5s at the 4 receptors 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. When the wind changes direction to due north or south, it only blows 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 maxima are even higher. Those readings should be less than 25 mg per cm3 to be within the WHO limits – and this is with only 2 runways. The likelihood is that these emissions receptors would give readings much 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. Over 28,000 people per year in the UK die from air pollution at current levels. Do not make it worse.
14. Health The health and well-being of our passengers, colleagues and neighbours is important to us and we have carefully considered the effects expansion may have on them. 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?
It is highly unlikely that this project could be carried out without there being harm to the health and wellbeing of a significant number of residents within the area. The previous planning conditions and cap on current operations are testament to that. Noise and air quality have not been addressed properly. Noise metrics and limits are either not adequate or the limits are too high as explained elsewhere
15. Noise Noise is one of the biggest concerns for communities living close to airports. We are proposing to introduce new and improved ways to manage noise at an expanded Heathrow such as introducing a 6.5 hour scheduled night flight ban, utilising runway alternation and developing a noise envelope. 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.
- The Consultation Document states in chapter 7.4 that noise has reduced over a number of years and an illustrative map is produced. That map is produced upon modelled assumptions, which almost certainly do not consider the current low altitude flying adopted by Heathrow since 2014.
- The Consultation Document states that
“…a large number of people experiencing a reduction in exposure to aircraft noise.”
This is misleading. The current voluntary restrictions are more substantial than the 6.5 hour ban on scheduled flights (see para on night-time ban, in which, it is stated that the 6.5 hours might be 5.25 hours with the Recovery Period and the Early Morning Start). The full three runway use will give LESS respite than now. Inevitably, 740,000 ATMs per year will be noisier than 480,000 ATMs. It is disingenuous to suggest otherwise.
- The World Health Organisation (WHO) Guidelines have been ignored. It is said in PEIR Ch 17 that the
“WHO guidelines themselves state that ‘data and exposure–response curves derived in a local context should be applied whenever possible to assess the specific relationship between noise and annoyance in a given situation’. The 51dB LAeq,16h LOAEL for day-time is derived from exposure-response curves derived from a UK study”
The WHO statement is in connection with the exact determination of the health risk. The previous sentence of the WHO Guidelines 2018 states
“It is therefore not possible to determine the “exact value” of %HA for each exposure level in any generalized situation” (see section 5.5 Methodological guidance for health risk assessment of environmental noise, WHO Guidelines 2018)”.
Heathrow have not done an independent health risk assessment so cannot properly use this distinction. The WHO Noise Guidelines at 40db Night and 45db Day are much stricter than the Government propose or in the Government Guidance. It is scandalous that:
“‘The government is considering the recent new environmental noise guidelines for the European region published by the World Health Organization (WHO). It agrees with the ambition to reduce noise and to minimise adverse health effects, but it wants policy to be underpinned by the most robust evidence on these effects, including the total cost of action and recent UK specific evidence which the WHO report did not assess’” (page 17.23).
If cost is being put against people’s welfare, then a proper assessment should have been done before the DCO.
- This high LOAEL is partly due to the SoNA report published by the CAA, which is deficient. It was a study produced following the Government’s refusal to accept the prior ANASE noise report produced by MVA Consultancy for the L.B.Hillingdon. ANASE showed more sensitivity to noise than SoNA, which was simply an IPSOS Mori poll of noise of just 2,000 respondents. SoNA was a static study of people already affected by a particular level of noise with no consideration of the effects of change with no tests for noise levels below 51dB, a level way above that recommended by the WHO. The ANASE study for Hillingdon included any resident inflicted with more than 65dB Lmax thus countering the “averaging” of noise upon the residents which is, in truth, fraudulent. The WHO provided detailed medical research and a survey of 37,000 respondents in 10 EU countries compared to the 2,000 for SoNA.
- The Noise Expert Group (NERG) of Heathrow should be viewed with suspicion in view of the conflict of some of its members. It is possible that expert members have been compromised to endorse findings in favour of Heathrow that they would not otherwise endorse, were they not in a retainer of Heathrow. Thus, member Dr. Charlotte Clark said in her report to the Airports Commission that
“For populations around airports, aircraft noise exposure can be chronic. Evidence is increasing to support preventive measures such as insulation, policy, guidelines, & limit values. Efforts to reduce exposure should primarily reduce annoyance, improve learning environments for children, and lower the prevalence of cardiovascular risk factors and cardiovascular disease”.
Yet, now we see Dr Clarke employed by Ove Arup and Partners advising exclusively Heathrow and HS2 on the implementation of their construction projects. Member Professor Stephen Stansfeld of Queen Mary University had said in an interview with the BBC that:
“In the UK, a 5 decibel increase in noise was equivalent to a 2 month reading delay compared to the average reading age, and also we’ve found in several studies now that hyperactivity symptoms seem to be related to aircraft noise exposure. I think the levels of aircraft noise around Heathrow are not good for your health and not good for children’s health”.
Yet we see Teddington marked for a noise increase of up to 6dB and Professor Stansfeld has accepted a position with NERG assisting Heathrow expansion.
16. Noise insulation We are proposing to introduce three noise insulation schemes for eligible local residents to address the effects of noise from an expanded airport. These will open in stages and prioritise properties in the highest noise areas. Please tell us what you think about our noise insulation schemes.
The noise insulation schemes are totally inadequate. The claim in Heathrow’s proposals for mitigation that
“As part of the process of designing the expansion project, we have engaged extensively to learn as much as we can about the concerns of local communities and other stakeholders. We explain here the robust and iterative process which we are going through in order to design our mitigation and compensation proposals”
is disputed. The proposal that noise insulation is only for properties exposed to daytime noise above 63dB Leq, reducing to 60db, is quite inadequate. The Government LOAEL is 51dB LAeq for the day and 45dB LAeq for the night and the WHO LOAEL is 45dB Lden for the day and 40dB Lden for the night. These figures indicate home insulation far above what Heathrow is offering
If Heathrow were catering for the concerns of local communities, they would be paying for noise insulation for homes within a radius of at least 20 miles from the airport.
Noise insulation or other mitigation schemes are useful for interior occupation but confine people to the indoors. The development will restrict people’s enjoyment of their properties with or without noise insulation e.g. people outside in their garden, in parks, children at school in the playground, sleeping at night with the window open, and the list goes on.
17. Socio economic and employment 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. 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?
Heathrow is a significant employer in the area. However, west London is not an area in which there is significant unemployment compared to other areas of the Country. There is already significant pressure on housing, local schools and hospitals. Further pressure will be detrimental (including raised property prices putting housing more out of reach of young people). Increased employment would be far more beneficial elsewhere.
18. Historic environment The expansion of Heathrow presents both challenges and opportunities for the historic environment and for the historic buildings and features which may be affected. We have set out in the Preliminary Environmental Information Report a series of historic environment principles that are informing the design and development of the expansion of Heathrow and have included a number of measures within the scheme design to minimise effects on the historic environment. We are proposing four historic environment strategies that will address effects on the historic environment. 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.
We are not in a position to comment
19. Climate Change; respond in (12) Environmental introduction
20. Community Fund We are proposing a new Community Fund to help address the positive and negative effects of the Project and to improve the quality of life in the area around the airport. 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.
We are not in a position to comment
21. Property and compensation People who live in or own property near Heathrow airport could be affected by its expansion. We will need to acquire areas of land which currently include residential, commercial and agricultural properties. We have prepared the interim Property Policies to explain our general approach to buying properties and land and set out the discretionary compensation offers available for eligible properties. These discretionary offers are intended to enhance the terms available under the Statutory Compensation Code for eligible properties, but do not change your statutory rights. 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 are not in a position to comment
22. Growing within environmental limits We are proposing to operate an expanded Heathrow within a set of strict environmental limits which would be monitored and enforced by an independent body. 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?
The proposed Independent Parallel Approach is likely to cause very serious noise and health issues since it inflicts noise upon both sides of the airport at the same time. Respite is therefore likely to be further diminished. There are serious safety concerns as set out above. There is also a danger that the temporary growth will become permanent if the expansion project becomes too expensive – something, which appears highly likely in view of the application to the CAA for funding proposal approval. Our responses under “Noise” and “Early Growth” are repeated.
23. Development consent order To get permission for our expansion proposals we will need to apply for a specific type of permission called a Development Consent Order (DCO). The DCO will contain the legal powers we need to build and operate the expanded airport. It will also place certain constraints on us, including obligations to minimise and reduce the effects of expansion and to pay compensation for land that has to be compulsorily acquired. 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 have nothing further to say at this stage
24. Comments and feedback Do you have any other comments in response to this consultation? Please give us your feedback on this consultation (such as the documents, website and events)
The Consultation was excessively complicated and very difficult to follow. The documentation was too long, arranged in too many ways and duplicated at different points. As an example appendices and maps were in different documents to the main text. The online response facility was even more complicated by the fact that responses could be given to only some topics. For example, not to be able to respond to Climate Change but only put a response under environmental introduction is quite extraordinary. As Albert Einstein said “If you can’t explain it simply you don’t understand it well enough”. This consultation has failed Einstein’s test