TAG responsE to the Heathrow Expansion DCO Consultation

Below is what we have sent to Heathrow. There is a Specialist Noise Paper to follow

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.

  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:

1.   increase noise impacts and create a noise sewer in Twickenham, Teddington and Strawberry Hill

2.   Have adverse effects upon the health of people within a large diameter of the airport


3.   increase air pollution

4.   make it impossible to achieve the UK’s climate target of zero emissions by 2050

5.   require large taxpayer subsidies for surface transport and/or increase congestion

6.   increase pressure on housing, schools, doctors, hospitals, water and sewerage

7.   even, according to DfT, bring negligible economic benefit (Net Present Value of between -£2.5 bn to +£2.9 bn, and that excludes costs of climate change). These figures are before the true health costs are factored in – which could add a further £8 – £10 billion of costs to the Net Present Value. 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

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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. For more information on our preferred masterplan please see section 3 of the Consultation document and section 7.8 of the Preferred Masterplan document.

2. 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, even on the Government’s forecast, be less than zero. That amounts to plain vandalism

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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.
For more information on the landscaping proposed please see section 3 of the Consultation document and section 7.9 of the Preferred Masterplan document.

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.

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

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Our Heathrow Expansion and Your Area documents set out our development proposals, their potential effects and how we propose to reduce them. The ten local areas covered are:
• Bedfont and Mayfield Farm;
• Brands Hill;
• Colnbrook and Poyle;
• Cranford, Hatton and North Feltham;
• Harlington and Cranford Park;
• Harmondsworth;
• Longford and Bath Road;
• Richings Park;
• Sipson; and
• Stanwell and Stanwell Moor.
For more information on the effects of the Project on these local areas please see the Heathrow Expansion and Your Area documents.

4. Please tell us what you think about our development proposals and the measures proposed to reduce effects in these areas.
(Please list the area you are commenting on followed by your response. If you would like to comment on more than one area, please use the notes pages at the back of this feedback form)

Local area – Twickenham and Teddington

Response –  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. At least the extent of the Local area and more will be subject to a noise increase of up to 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

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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.
For more information on our construction proposals please see section 4 of the Consultation document and the Construction Proposals document.

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.

We have no comment on this

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Future Operations

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.
For more information on our runway alternation proposals please see section 5 of the Consultation document and section 3 of the Future Runway Operations document.

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, 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. Even this noise reduction is on the basis of highly optimistic assumptions of quieter planes, a faster rate of renewal of fleets and a much slower take-up of capacity than assumed in the ANPS. 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.

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Section 5 of the Consultation document and section 4 of the Future Runway Operations document explains our preferred proposal for the length and timings of a ban on scheduled night flights. Our consultation materials also describe alternative options we have considered.

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 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 for adults – children more. Teddington and Twickenham will be exposed to more noise. The “Scheduled Time” is the time upon leaving the terminal and is shown to be up to 20 minutes prior to take off time. The last Scheduled flight take off will be up to 11.20pm therefore  

There is also a disturbing diagram in “Future Runway Operations” page 44 figure 4.9 showing the one-hour Recovery Time late at night and also the “early morning arrival” at 5.15am. The likely ban period will therefore run from up to 12.20 mid-night (inc. taxiing time) to 5.15am – less than 5 hours which is less than the current night-time quota period – and even that is not a curfew. It makes a farce of the stated 6.5 hours respite at night. It appears that Heathrow are juggling with runway alternation and gambling on people who hear noise from one runway not hearing noise from another runway. That is a false assumption since the flight paths from each runway will merge relatively quickly into the particular departure or arrival flight path. People will be affected by operations from all runways.

In an area such as around Heathrow there should be an eight-hour outright ban (curfew) on all flights on all days.

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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.
For more information on our proposals for early growth please see section 5 of the Consultation document and the Early Growth document.

8. 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 and no business case has been put forward. 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, which will be above, 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. The only escape route (which was used in those particular instances) would have gone straight into the flight path of approaching planes behind.  

Overall, the proposal seems highly dangerous, likely to bring misery to many people, and ill thought out. The same concerns apply to other areas with the other two IPA mode proposals

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Surface Access

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.
For more information please see section 6 of the Consultation document and the Surface Access Proposals document.

9. 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. We do not believe that the costs sharing has been agreed between Heathrow and the Public Purse and we don’t consider that the expansion proposals should proceed further until the scope and responsibility of cost is properly agreed and discussed publicly.  

It is noted that at PEIR 19.12 it is stated that “ The transport network user assessment is inherently cumulative as it uses modelled traffic data that has been adjusted to account for growth in future traffic flows. The modelling takes account of employment and housing projections, future infrastructure projects and development in both Development Plans and in the planning process. No additional cumulative effects assessment associated with road traffic has therefore been undertaken.” No additional assessment of road traffic is a significant omission in view of the likely affects upon M25 volumes. 260,000 extra flights, extra freight (which will be by road traffic) will have a very significant effect upon the M25, which is an already grossly overburdened part of the national road network

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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.
For more information please see section 6 of the Consultation document and the Surface Access Proposals document.

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.

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 mitigation 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. Freight traffic will inevitably increase. 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

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

There will inevitably be extra traffic upon an infrastructure that is overstretched. It is also admitted by Heathrow that there will be extra demands upon some areas such as along the south perimeter where there will be a second access into the airport to complement the existing one from the north.

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Preliminary Environmental Information and Managing the effects of Expansion

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.
For further information please see section 7 of the Consultation document and the Preliminary Environmental Information Report.

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

Climate Change

1.         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. Indeed, Heathrow airport may need to contract if we are going to contain warming to 1.5 degrees above pre-industrial levels or attain net zero emissions by 2050.

2.         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 with non-CO2 emissions. This is particularly important here. Non CO2 emissions are particularly significant with aviation since oxides of nitrogen and water vapour and consequent contrails can have significant global warming properties when emitted at high altitude. Heathrow say at para 9.4.7 of PEIR 9 that there is “no scientific consensus on the effect of non-CO2 emissions at altitude at present. The advice of the CCC (CCC, 2009 and CCC, 2012) is to consider only CO2 emissions from air transportation (irrespective of whether they are emitted on the ground or at altitude) until there is improved scientific evidence available”. That is not correct though. The CCC Technical Report of May 2019 states that “Planes can also create contrails (long trails of cloud caused by aircraft flying through supersaturated air) depending on the atmospheric conditions. As these clouds are high in the atmosphere, they have a relatively large warming effect on the climate. Overall, non-CO2 effects from aviation warm the climate and approximately double the warming effect from past and present aviation CO2 emissions”. Heathrow are not being honest with climate change. The truth is that Heathrow expansion will have a devastating effect upon mitigation and prevention of climate change.

3.         This is all notwithstanding that Parliament has declared a state of climate change emergency. In support of its stance in this consultation, Heathrow states that it has followed advice from the Committee on Climate Change (“CCC”) given in 2009, 2012 and 2017. That advice is out of date, and the current advice is contained in the CCC Net Zero Report of May 2019 as stated above. 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.

4.         However, CO2 emissions themselves are over the target – never mind non-CO2. 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%.

5.         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.

6.         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 (or the effects of any non CO2 greenhouse gases). Any reduction from 40.8 MtCO2 in 2050 is highly speculative and the Government should not be gambling with climate change in this way.

7.        Following the advice of the CCC that non-CO2 greenhouse gases will “ approximately double the warming effect from past and present aviation CO2 emissions”, we are looking at an equivalent of 80 MtCO2, a figure that is so way over the target figure that any mitigation following Heathrow expansion to comply with greenhouse gas targets will be quite impossible.

8.         CORSIA will not be an acceptable off-set. Firstly, mitigation (apart from carbon trading) will yield nothing like the required off-set. Trading, by getting poor nations to sell carbon credits and restrict their economic growth will not be acceptable in the long term. The CCC has specifically said that this practice should be banned and the Government (against the advice of the CCC) has stated that it will be permitted but only temporarily.

9.         Off-setting by carbon capture, such as peat bogs and tree planting, should 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. Off-setting also has its own very serious credibility problems. Off-set an air aircraft journey with tree planting or bog creation, and the carbon capture takes 30 years to complete versus the 10 or so hours air travel journey. More carbon emitting journeys get made before the carbon capture operates and it goes on. Disturb the peat bog, burn down the trees or wood in the next 30 years (even dead branches converted into pellets for eco-friendly biomass boilers emit CO2), and the carbon capture operations become carbon emitters. In any case, regenerating a peat bog or replanting trees is putting back CO2 capture previously taken away rather than new offsetting for aviation.

10.       Off-setting is highly speculative and most likely will not produce the intended off-setting at all.

11.     The Committee on Climate Change in their Net Zero Report of May 2019 state: “ Our recommendation is also strong in its coverage (including international aviation and shipping) and its recommended implementation (without international offsets)” and “A net-zero GHG target is not credible unless policy is ramped up significantly. Most sectors will need to reduce emissions close to zero without offsetting; the target cannot be met by simply adding mass removal of CO2 onto existing plans for the 80% target”. This has not been addressed by Heathrow.

12.      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 to the airlines by having them off-set their aircraft emissions by purchasing off-sets.

13.      The first goes directly against what the CCC advises, so that aviation emissions must be within budgets and if specified reductions are not made by aviation, then other emitters must reduce CO2 emissions by a compensating amount. The second is unsupervised, pays for the most vulnerable countries to reduce expansion of their economies, does not operate until many years into the future and is highly speculative.

14.      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

15.      It is said by both Heathrow (e.g. in public consultations) and the Government (e.g. evidence of Chris Grayling to Transport Committee on the 17th July 2019), that we, the UK, cannot tackle aviation climate change emissions on our own since it is a global problem. We all need to abide by the agreed Paris Treaty obligations. The aviation industry is not above the law and should obey the law and the rules. Although international aviation itself is exempt, the effects of aviation are not. If excess emissions from international aviation cannot be absorbed by savings elsewhere, then those excess emissions should not be permitted.

16.    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(s) of similar or greater size has to close. Compliance with our domestic and international obligations is just not possible without this.

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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.
For further general information on air quality please see section 7.1 of the Consultation document and Chapter 7 of the Preliminary Environmental Information Report.

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?

1.         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 incorrect. Indeed, one of the fundamental flaws of the Air Quality Consultation is that emissions from aircraft off the ground are not considered. Without this, it is not possible to say that air quality will comply with either regulations or WHO guidance. The GLA London Datastore air quality information shows that it is estimated that by 2025 at Richmond Old Deer Park (9kms from the airport boundary), aircraft will emit 78% of the NOx and 18.6% of the PM2.5s

2.         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 of their test results 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.

3.         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.”      

That is quite simply wrong  

4.   Particles or particulates are grouped into three main sizes:
      
PM10s: These measure up to 10 micrometres (millionths of a metre) in diameter        PM2.5s: These measure up to 2.5 micrometres and are termed “fine particles”      
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 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
( https://www.qmul.ac.uk/media/news/2018/smd/first-evidence-that-soot-from-polluted-air-may-be-reaching-placenta.html ) .

5.         The World Health Organisation recommend maximum dosages of particulates and nitrogen dioxide which 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

6.         The GLA London Datastore air quality assessments for 2020 show that London and the areas surrounding Heathrow 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.

7.         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.

8.         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. 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 much higher readings 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.

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Health and Well Being
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.
The outcomes of our preliminary health assessments are explained in section 7.3 of the Consultation document and Chapter 12 of the Preliminary Environmental Information Report.

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?

It is not possible 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    

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Noise Insulation Scheme
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.
For more information please see section 7.4 of the Consultation document, the Proposals for Mitigation and Compensation document and the draft Noise Insulation Policy document.

15. 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 is needed at a level far above what Heathrow is offering.  

The anticipated cost of home insulation has been woefully underestimated (in Heathrow’s favour). The typical cost of home insulation to a standard required to insulate against the levels of noise produced by low flying aircraft is between £20,000 and £40,000 (people in Teddington suffering current low flying operations are considering this or have had work done and the range is based upon actual quotes)  

If Heathrow were catering for the concerns of local communities, they would be paying for noise insulation at a proper level 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.

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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.
For further general information on noise please see section 7 of the Consultation document and Chapter 17 of the Preliminary Environmental Information Report.

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.

This response is a preliminary response of the Teddington Action Group. A more detailed response in a specialist noise paper will be given before the Consultation closes. In the meantime, we say as follows:  

1.         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 lower a plane is the louder it will be. This is very well illustrated by the Airbus A380 versus the older Boeing 747. The A380 is more modern but is flown lower out of Heathrow and is louder on measured Lmax noise events from the Heathrow noise monitors.  

2.         The Consultation Document states that “…a large number of people experiencing a reduction in exposure to aircraft noise. These reductions are associated with mitigation such as the proposed 6.5 hour ban on scheduled night flights…”. 
This is incorrect. The current voluntary restrictions are more substantial than the 6.5 hour ban on scheduled departures (see para on night-time ban, in which, it is stated that the 6.5 hours might be less than 5 hours with the Recovery Period and the Early Morning Start). The assumption of “reduction in exposure to aircraft noise” also depends upon an unjustifiable assumption of progressive reduction in aircraft noise. Heathrow in Volume 3 PEIR 17 state that a “likely” Cumulative annualised noise reduction will be 0.4dB per year. That is 400% more optimistic than the Airports Commission were advised by Jacobs in their Local Area Assessment of Noise stating of future aircraft estimation “an assumed forecast of -0.1dB per annum improvement in noise emissions for these aircraft is adopted in the Sustainable Aviation Noise Road-Map” (para A.1.4 of Appendix A Jacobs Local Noise Assessment 5). When cumulative, the effect of the over optimism of Heathrow is simply staggering.
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.  

3.         The World Health Organisation (WHO) ENG 2018 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 referred to is in connection with the exact determination of the health risk. The UK study was not a health assessment but the SoNA survey. The previous sentence of the WHO Guidelines 2018 states:

“It is therefore not possible to determine the “exact value” of %HA [Human Annoyance] 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. A SoNA night-time study of noise effects has been promised by the CAA for some time but has never materialised. SoNA has been widely discredited and the ICCAN (Independent Commission on Aircraft Noise) has stated in its corporate strategy that by December 2019, it will review SoNA and make recommendations to the Government.

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 Heathrow is basing its plans on the principle 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.  

4.         This high LOAEL is partly due to the SoNA report published by the CAA, which is deficient in significant respects. 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.  The WHO provided detailed medical research and a survey of 37,000 respondents in 10 EU countries compared to the 2,000 for SoNA. SoNA was a static study of people already affected by a particular level of noise with no consideration of the effects of change. No tests or questions were carried out for noise levels below 51dB, a level way above that recommended by the WHO. One of the notable aspects of the ANASE study for Hillingdon was their study area included any resident inflicted with more than a 65dB Lmax noise event (being a single maximum noise point rather than LAeq, which is the average or equivalent noise over a period of time).  

5.       The refusal of the Government to accept the ANASE report is suspicious. Hansard shows that on 6th February 2008, Justine Greening “asked the Secretary of State for Transport when she was informed of the Non-Stated Preference peer review findings in relation to the Attitudes to Noise from Aviation Sources in England [ANASE] report; and if she will make a statement”. The response was that “The specification for the project did not specify whether the UK Aircraft Noise Contour Model (ANCON) or the U.S FAA’s Integrated Noise Model (INM) should be used by the successful contractor, as both models are used in the UK for noise modelling purposes. In July 2002 MVA informed the Department that their preference was to use the INM model because it is publicly available at low cost and meets all the technical requirements of the study”. ANASE was subsequently scrapped by the Government and the contract given to the CAA (funded by the aviation industry) for SoNA. According to Hansard, the Non Stated Preference elements of the ANASE Study, which was then scrapped, were peer reviewed by Stephen Turner, whose firm went on to co-peer review the CAA SoNA study. It must raise some eyebrows  that the same person is in part responsible for recommending cancelling one supplier contract only to have a financial interest in peer reviewing the award of the contract to a substitute supplier. Stephen Turner is also now serving on the Heathrow Noise Expert Review Group  

6.         Some members of the Noise Expert Group (NERG) of Heathrow have substantial conflicts of interest. The stated objects of NERG are:

“NERG will advise Heathrow in the development of its operational noise mitigation measures and the preparation of the noise envelope, in light of guidance from ICCAN”.

It is possible or even probable that members have been compromised to endorse findings in favour of Heathrow that they would not endorse were they not on a retainer of Heathrow. Thus, Stephen Turner is the chair of the NERG, notwithstanding that he or his organisation were part of the peer review of the rejection of the ANASE research and the adoption of the subsequent discredited SoNA report. Stephen Turner certified in his peer reviewing of SoNA that “ the detailed results and conclusions from SoNA 2014 can be used as a basis for the further development of Government policy in this area”; something that residents around Heathrow would hotly dispute.

Dr. Charlotte Clark and Professor Stephen Stansfeld are also members of the NERG.

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 Arup Group Limited and/or one or more of its group companies advising exclusively Heathrow and HS2 on the implementation of their construction projects.

Professor Stephen Stansfeld of Queen Mary University, one of the prominent noise experts in the Country, is now a member of the NERG. Professor Stansfeld 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, which is quite inconsistent with and in conflict with his prior expressed opinion.  

7.      Noise is in competition with air quality. The DfT “Aviation 2050 – The future of UK aviation” Consultation of December 2018 has a report from the Institute of Sound and Vibration Research of Southampton University. In order to reduce emissions, the design of jet engines is going to have to change. The report states 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 Annex G para 2.4.6 and following graphic table 2.5 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. Planes, quite simply, are not going to get a lot quieter if emissions regulations and targets are to be met.

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Economic Development
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.
For further information please see section 7 of the Consultation document and Chapter 18 of the Preliminary Environmental Information Report and the Economic Development Framework document.

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?

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.

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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.
For further information please on the effects on the historic environment please see section 7 of the Consultation document, section 7.10 of the Preferred Masterplan document and Chapter 13 of the Preliminary Environmental Information Report.

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.

We are not in a position to comment

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Environmentally Managed Growth

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.
For further information please see section 8 of the Consultation document and the Environmentally Managed Growth document.

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?

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 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

The Noise Envelopes are based upon the Quota Count ratings of aircraft and not actual noise outputs. This is covered in our specialist noise paper submitted separately

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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.
For further information please see section 9 of the Consultation document and the Proposals for Mitigation and Compensation document.

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.

We are not in a position to comment

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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.
Section 10 of the Consultation document and the Property Policies Information Paper set out a summary of the interim Property Policies.

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.

Absolutely no research into the Social Impact of PBN trials in the UK or an environmental assessment has been undertaken. Heathrow and the industry have simply buried their heads in the sand on an issue that will have devastating effects on overflown communities. It is difficult to comment on the “Policies”. There is reference to this in our specialist noise paper submitted separately

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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.
For more information about the DCO process and on what we think will need to be contained in our DCO, please see our ‘How do we obtain approval to expand Heathrow?’ document.

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?

A fully independent review of health factors, particularly noise and air quality. This should contain sensitivity analyses showing the impacts in the circumstances of Heathrow’s optimistic assumptions not being achieved

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General Comments

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

The documentation contains much misleading information and omits other key information (noise, air quality, climate change being prime examples). It is not an adequate basis for engaging the public in a statutory consultation. Simply vast amounts of detailed information have been provided, which do not address key issues

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24. Please give us your feedback on this consultation (such as the quality of 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 Consultation was held over the peak summer period when people are away, making far too short a time for people to assimilate the huge bulk of material. We say that this Consultation does not conform to the principles set out in R v London Borough of Brent ex parte Gunning (1985). This Consultation does not “include sufficient reasons for particular proposals to allow those consulted to give intelligent consideration and an intelligent response; and give adequate time for this purpose”  

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.

The Online response facility unreasonably restricted responses to 5,000 characters (which is why we are not using it)

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