TAG lodges its response to the CAA consultation on the Airspace Change Masterplan


The CAA are consulting on a strategy to “respond to the Government directing the CAA to ‘prepare and maintain a co-ordinated strategy and plan for the use of UK airspace up to 2040, including modernisation’ [link on the icon to the left]. Some will have noted that this consultation is to be designed around the premise that “Airspace modernisation is expected to support the Government’s objective to increase capacity, including through the development of a northwest runway at Heathrow as outlined in the Airports National Policy Statement” [para 4 page 3].

The Court of Appeal have, of course, declared the Airports National Policy Statement unlawful. In addition we have the lockdown as a result of Covid-19 and some people think that it will be several years before air travel is back to the levels that it was pre Covid-19.  It is therefore more than a little surprising that the CAA should deem it appropriate to be consulting on airspace concentration to get more planes in the air at this time. In addition the ICCAN (Independent Commission on Civil Aviation Noise) has suspended its work on studying noise metrics at this time – something that is highly relevant to the CAA consultation. We have however filed a response giving reasons why we consider that this consultation should be either abandoned or at least postponed. The response is set out below and can be found on the CAA website under response number 290061704 at https://consultations.caa.co.uk/policy-development/airspace-change-masterplan-criteria/consultation/view_respondent?uuId=290061704 . Unfortunately, the CAA portal cannot take images nor weblinks on footnotes, so sections of our response are not visible on the CAA portal. We have sent a hard copy version to the CAA. Here is a complete version of what we have said:


The following responses are made on behalf of Teddington Action Group (TAG)

Questions 1-7 – who you are etc 

This response to CAP 1887 is submitted by Stephen Clark MA(Cantab), David Gilbert BSc, PhD, MBA, Joan McIntyre and Neil Spurrier BA(Hons) Solicitor on behalf of Teddington Action Group (TAG). TAG is a founder member of Heathrow Community Noise Forum; its members have presented to the Transport Select Committee and the All-Party Parliamentary Group on Heathrow and are on ICCAN’s stakeholder board for its review of SoNA.

The following questions (8-11) all have response boxes

Question 8. CAP 1887 details the proposed criteria to be used to inform whether to accept the Airspace Change Masterplan, which is being created by the Airspace Change Organising Group (ACOG), an impartial team in NERL. Do you have any general comments you would like to share on the proposed criteria for assessing and accepting the Airspace Change Masterplan? 

We understand the desirability of making best use of new technologies and in particular the safety and efficiency benefits these could potentially bring. However, fundamentally for a range of reasons (set out in this submission) the master plan design of future airspace and the evaluation process is not based on reliable foundations. On this basis the current consultation on the proposed criteria for assessing and accepting the Airspace Change Masterplan should be suspended or withdrawn, until the necessary policy framework and evidence base has been established.

This conclusion has been reached for the following reasons:

  1. The Government was elected in December 2019 with a commitment to rebalance the national economy away from London and the South East. There is now a very different context for establishing Future Airspace Strategies in UK. Having regard to this, it will be necessary to reassess the overall aviation strategy in the context of national economic policy, something which in any event (even before this significant shift in national economic strategy) was not done either by the Airports Commission or within the ANPS. Previous iterations of aviation strategy are now obsolete and will need comprehensive review in the light of the new national policy agenda
  1. This is particularly important having regard to climate change considerations and the commitment of the UK Government to international legally binding carbon limits. It is clear there is very limited spare aviation capacity that can be shared around nationally and FASI needs to be established within this constraint. As the national aviation strategy and in particular the Airspace Change Masterplan (as referred to in CAP 1887) has the ANPS as a centre piece (which the Court of Appeal found to be unlawful as the Secretary of State had not considered the UK’s climate change obligations), it follows that it too must be potentially challengeable in the courts. This is a natural consequence of the February 2020 Court of Appeal decision on the ANPS, which the Government has stated it will not appeal. FASI needs to be based on a foundation of working within realistic national overall carbon limits for aviation. The UK now needs to establish its airspace masterplan priorities in line with national economic needs, and crucially within the constraints of overall carbon limitations. The CAA has given no evidence or suggestions of how this is going to be done.
  1. Further, the presumption that Heathrow will expand which underpins CAP 1887 makes it appear that a third runway is a ‘done deal’. This is far from the case. The CAA’s consultation document is based on a prejudgement of the outcome of the DCO enquiry, thereby breaching natural justice and the ‘Gunning Principles’ in relation to both CAP 1887 and the outcome of the DCO itself
  1. The Transport Select Committee made 25 recommendations in relation to the ANPS and (in securing Parliamentary approval) the Government gave commitments to review many of these in detail at the DCO stage. The Government’s legal team followed the same line of argument to avoid qualitative consideration of the shortcomings of the ANPS at the judicial review proceedings. At the court hearings the judges made it clear they would limit their decision to a strict and narrow interpretation of legal issues, on the basis that the robustness of the qualitative evidence would be considered fully at the DCO stage. Whilst the final wording of the ANPS may state it has primacy at DCO (potentially intending to limit the scope of the enquiry), this is in conflict with commitments given in Parliament and by the Government’s legal team to the courts
  1. In relation to the DCO, Appendix A to this submission sets out a TAG paper on air quality and climate change. The flaws in the noise case used for the ANPS are highlighted in the next section of this response. There are also major unresolved issues about whether Heathrow can (or should) be allowed to recover its ‘Early Costs’ (through passenger fees) which have been the subject of a recent consultation (CAP1871). It is now evident that Heathrow’s third runway is not running to programme – and in all probability, budget. This is especially the case as the Government has given a commitment that Heathrow expansion will be entirely privately financed and there is no agreement concerning the enormous disparity between Heathrow and TfL (and other infrastructure providers) in relation to paying for surface access costs (the provision of this infrastructure being integral to the sustainability and carbon assumptions made in the ANPS). The difference of opinion on cost liability is reputed to be between £1bn (Heathrow) and £15bn (TFL). These gaps are unbridgeable
  1. The Covid-19 crisis is also likely to have a very significant impact on future demand for aviation in the UK for years to come and there will need to be a new economic plan for recovery. It is inappropriate to set up a decision-making framework within the context of a constrained masterplan before the position has stabilised (both nationally and internationally). Until trading projections, economic recovery and growth plans, environmental constraints and aviation demand have been comprehensively reviewed, it is premature to develop an airspace masterplan strategy or the criteria for assessing or accepting changes associated with this.
  1. Finally, the Masterplan strategy referred to in CAP 1887 does not reflect changes in the aviation model, which is moving away from the hub and spoke concept (on which the Masterplan approach is predicated) towards new plane types which can efficiently fly short, medium and long distances on a point to point basis. In order to optimise economic benefits – and reflect consumer preferences – a more dispersed approach is required and competition between airports is preferable to domination of the UK market by Heathrow, creating in effect a private sector monopoly
  1. For these reasons, and because CAP 1887 refers repeatedly to Heathrow expansion and the ANPS, which upon the present judgement of the Courts are unlawful, it is self-evident that the envisaged masterplan – and the airspace change processes associated with it (including criteria for assessment and acceptance) – now require fundamental review.

Question 9. Are the proposed criteria detailed in CAP 1887 the right criteria to enable acceptance?


About right 

Minor modifications needed 

Significant modifications needed    X

Don’t know



Question 10. Chapter 3 of CAP 1887 details the policy considerations that are relevant to the Airspace Change Masterplan. Are there examples of where further policy may be required to guide trade-off decisions? 


Yes   X


Don’t know

  1. Crucially, neither the DfT nor the CAA have access to the necessary evidence base to assess health and quality of life impacts of a significant restructuring of UK airspace. For this reason, there is no realistic, reliable or objective basis for evaluating the ‘trade offs’ referred to in CAP 1887. The CAA is perceived as being an integral part of the aviation industry with a key remit to expand traffic movements. It does not have the necessary independence, objectivity or expertise to make impartial decisions on trade-offs that impact public health
  1. Further – and in terms of whether the general public is even aware of the issues CAP 1887 seeks to consult on – unless communities have actually experienced the radical changes in noise environment which Airspace Modernisation necessarily entails, such as concentration, new flight paths and/or significant changes in the use of existing flight paths (with increased intensity of overflight), they will have no idea of the significant changes in living conditions they are going to be subject to. Those who experienced Heathrow’s PBN departure trials in 2014 will never forget how their lives were made intolerable over that summer by changing the use of established routes and concentrating them. This trial had to be abandoned early in the face of enormous public protests. The impacts are documented in Anderson Acoustic’s 2015 trials report commissioned by Heathrow. Anderson were unable to explain the impacts through the use of average metrics LAeq, which was the primary metric used by the CAA in assessing the ANPS, and which the webTAG cost benefit tool is based The impacts of the trials were also felt at far, far lower levels of noise than levels considered by the CAA as being significant and lowest observable thresholds. The impact of these trials heightened the sensitivity of those impacted and this raised awareness has not gone away six years on; the complaints continue.
  1. Given the knowledge that the CAA must have had, as the Government’s aviation noise experts, about the 2014 Heathrow departure trials and legal action at Gatwick, it is astonishing that the CAA’s 2014 SoNA survey didn’t look below 51 dB, the government’s LOAEL level. Likewise, the CAA did not address the change effect which international acoustic experts agree makes circa 6-9 dBLAeq difference to public annoyance. There is not a question about the existence of the change effect (recognised by both ICAO and Public Health England); the only area for discussion is exactly the level of impact and whether or not it will reduce over time. Given this background there is no confidence within communities in the CAA’s ability to discern impacts or quantify the effects of significant change on physical and mental health as part of any trade off process. Trust in authorities (in this case the CAA, Heathrow and the DfT) is accepted as a significant non-acoustic factor (see subsequent section). If non- acoustic factors such as the change effect and trust are not fully understood the Government should act responsibly and follow the precautionary principle – especially as the airspace changes envisaged in CAP 1887 represent the most fundamental change in the use of UK airspace ever – and probably in the World. The Government is likely to face mass protest if these issues are not understood and addressed before major airspace changes are permitted.
  1. The Independent Commission of Civil Aviation noise (ICCAN) was established in 2019 and despite initial DfT opposition it included a review of SoNA 14 in its first year’s workplan. ICCAN’s overview study concluded that a new survey was necessary. The DfT now apparently welcomes ICCAN’s review and has agreed its recommendation for a fundamental review. Until this work has been undertaken and key government departments such as Health, PHE and DEFRA have impartially considered the implications there is no way of measuring or considering the impact of the very major changes in the use of airspace envisaged in the current consultation
  1. It is worth highlighting what the CAA and the DfT should already know about the introduction of significant changes to the use of existing flight paths (but ignored when SoNA 14 was adopted as the basis of establishing aviation noise policies). The slide below has been presented to Heathrow’s Community Noise Forum (HCNF) and has not been contested by the airport or industry representatives.

  1. The slide below (also presented to the HCNF) sets out what Heathrow stated in a response to a European consultation on the introduction of new technologies in 2016:

7. More recently ICAO’s 2019 white paper on aviation noise impacts (never referred to or mentioned at the HCNF by the CAA or Heathrow) makes specific reference to change, non-acoustic factors and the appropriateness of judging changes in regard to average Laeq and Lden noise metrics (our comments are marked in red on the second slide).


8. The serious adverse impacts of trying to introduce radical changes to flight paths, involving highly concentrated PBN routes are already clear from international experience, particularly in the US. No one in the UK aviation industry has addressed this experience. Consideration of the impact of introducing PBN had been promised by Heathrow as part of its DCO application but, based on the draft report we have seen (so far it has not been presented in final form to the HCNF), the document ignores outcomes – instead it only covers very high-level governance processes applicable in other countries

  1. The introduction of PBN, aka Next Gen in the US, has effectively stalled due to its impacts and US politicians have raised very serious concerns. Please see Appendix B for the link to the report and the politicians’ response. It is difficult to understand how the DfT and the CAA can be contemplating the introduction of new concentrated routes without assessing and addressing US and other international experience. This evidence, which has not been addressed by the DfT or the CAA, is extremely relevant to the consideration for assessing or accepting airspace changes and the Masterplan
  1. Given the CAA’s lack of knowledge of key impacts of aviation’s environmental impacts, it is impossible for it to make judgements on ‘trade-offs’ in relation to airspace change proposals. Regarding noise, relevant information won’t be available at the earliest until ICCAN has completed the review of SoNA, and the results assessed by the Department of Health, Public Health England and DEFRA
  1. All work on the Masterplan and the processes associated with airspace changes should now be suspended until this work has been done and the outcome consulted on.

Appendix A;

DCO Risks – TAG assessment of latest evidence in relation to air quality and carbon limits Air Quality

The effects of aircraft (as opposed to land vehicles going to and from the airport) are not assessed properly by Heathrow, the CAA or the DfT. A huge problem and illegal levels of air pollution are being disguised. Heathrow state in their DCO Consultation that

“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”[1]

That is manifestly untrue.

Hudda et al in 2014[2] found that emissions blew downwind from airborne approaching and departing aircraft so that there was detected at least a 2-fold increase in particulate concentrations over baseline concentrations during most hours of the day, in an area of about 60 km2 that extended to 16 km downwind, and a 4 to 5-fold increase to 8–10 km downwind. The synopsis of the report stated that

“These results suggest that airport emissions are a major source of particulate number concentration in Los Angeles that are of the same general magnitude as the entire urban freeway network. They also indicate that the air quality impact areas of major airports may have been seriously underestimated”.

Particulates, which are tiny particles of soot emitted from the combustion process, have been found to be particularly harmful to humans. The Hudda study also showed elevated levels of NO2 downwind from aircraft as well, contradicting evidence of our Department of Transport

Keuken et al in 2015[3] took measurements at Adamse Bos, located 7 km from Schiphol, Amsterdam, and in 2012 at Cabauw, a regional background site 40 km south of Schiphol. Particulate concentrations increased during periods in which the wind direction was from Schiphol: at Cabauw by 20% and at Adamse Bos by a factor of three, from 14,100 (other wind directions) to 42,000 cm3 between 06.00 and 23.00. The size distribution of Schiphol- related particulate number concentration was dominated by ultrafine particles, ranging from 10 to 20 nano metres

Riley et al in 2016[4] found a similar situation at Hartfield Jackson airport Atlanta.

Hudda[5] in 2018 did another study at Boston finding that jet engine exhaust is a significant source of ultrafine particles, and aviation-related emissions can adversely impact air quality over large areas surrounding airports.

In 2019 Zhou et al[6] in China did a study finding that civil aircraft emissions during landing and take-off are important air pollutant sources, but have been given insufficient attention in China.

In 2019 Austin et al[7] from Washington state university led a study which found that communities underneath and downwind of jets landing at Sea-Tac Airport at Seattle are exposed to a type of ultrafine particle pollution that is distinctly associated with aircraft

In June 2019 Roy Harrison[8] from Birmingham University led a study of air quality in London scanning particulate sizes in London and found an elevation in nucleation mode particles associated with winds from the west which was concluded to result from emissions from London Heathrow Airport, despite a distance of 22 km from the central London sites

In 2019 Kings College London[9] published a report on ultrafine particles being blown downwind from 4 international airports including London, finding particulates being blown in significant quantities from Heathrow into central London

The specialist air quality unit of DEFRA recognises the risk of particulates from aircraft saying in their 2018 report to DEFRA that

“at a location such as Heathrow Airport, where aircraft tend to approach the airport from the east (flying over the London conurbation), there is potential for considerable exposure to UFP [ultrafine particles] from aircraft”.[10]

Heathrow themselves “monitor” air quality around Heathrow (but not further into London). They have four sites; Harlington, Bath Road (LHR2), Longford and Oaks Road. They are all directly to the north or the south of the runways – none are underneath a flight path. The last annual published results are for year-end 2018; they show PM 2.5s at an annual mean of less than 10 micrograms per cubic metre. However, look at the hourly maxima and the level goes up to over 60 micrograms and with Harlington to over 76 micrograms per cubic metre[11]. While expecting hourly maxima to be greater, this level of difference gives a serious indication of the prevailing wind blowing particulates well away from the receptors with only a temporary change of wind blowing them over the receptors when the wind changes. If the receptors were put underneath the flight path, the annual mean results would most likely be very much increased – to an annual mean probably well over 20 micrograms, the permitted amount under the EU Regulation 2008/50 and way above the WHO recommended limit of 10 micrograms. The EU Regulation 2008/50 also provides that there must be a target year on year reduction of PM2.5s. At a level of 20 micrograms per cubic metre the target yearly reduction is 20%. Any operations or alterations that lead to an increase in PM2.5s are unlawful, therefore. At present neither Heathrow, the CAA nor the DfT nor any other government department have tested for emissions under the flight paths of aircraft landing or departing from Heathrow. This is an extraordinary state of affairs.

The devastating effects of fine particulates in the air are all too easy to see from the research carried out. Fine particulates alone kill some 29,000 people in the UK per year[12]. Research at Queen Mary’s University[13] has found that particulates have been present in the placentas of expectant mothers and effect the unborn foetus, thus passing on the effects to the next generation. The University of Bern investigated the effect of exhaust particles from aircraft turbine engines on human lung cells[14] stating

“As a result, scientific research of the particulate matter from air traffic is important for the development of environmental standards in the aviation sector. When inhaled, these nanoparticles — like those from other combustion sources – efficiently deposit in the airways     if the inhaled particles manage to overcome these defence mechanisms, due to their structure or physico-chemical properties, there is a danger for irreparable damage to the lung tissue.”

Far from pollution of the air with fine particulates improving, it is reported that Public Health England recorded the fraction of mortality in London due to particulates actually rose from 6.4% to 6.5% from 2016 to 2017 and from 5.6% to 6.4% from 2015 to 2016[15]. Ranzani[16] et al have reported that ambient fine particulate matter air pollution was associated with low bone mineral content and bone mineral density. This is likely to be transferred from one generation to the next where pregnant mothers are exposed to particulates. Professor Mina Gaga, President of the European Respiratory Society has said:

“This new research suggests a possible mechanism of how babies are affected by pollution while being theoretically protected in the womb. This should raise awareness amongst clinicians and the public regarding the harmful effects of air pollution in pregnant women. We need stricter policies for cleaner air to reduce the impact of pollution on health worldwide because we are already seeing a new population of young adults with health issues.”[17]

It is abundantly clear, we suggest, that neither Heathrow, the CAA, nor the Department of Transport have even scratched the surface of researching the health effects of expanded Heathrow operations. This not only includes a third runway but includes any airspace change that will lead to an increase in the number of flights in and out of the airport.

Some Londoners – and not just those close by – will be given a death sentence by Heathrow expansion.

Climate Change

The Committee on Climate Change and others have written much on the requirements to reduce the combustion of fossil fuels in order to reduce the emission of greenhouse gases, the most notable one being carbon dioxide (CO2).

Heathrow claims that it will be “carbon neutral” by 2050 but then in the small print we realise that the statement excludes all aircraft operations. Airlines are sufficiently worried to say that they will be carbon neutral by 2050[18].

However, this depends on substantial offsetting, which is something that the Committee on Climate Change (“CCC”) have specifically advised against[19]. Lord Deben, the chair of the CCC has specifically advised the Government on behalf of the CCC that expansion of Heathrow leaves very little room for expansion of any other airport[20]. The problems of offsetting have been recited many times before by many people. There is no guarantee that the program of capture (e.g. tree planting) will be completed. The carbon capture may well be required for other activities (e.g. offsetting emissions generated for power supplies). The carbon capture occurs over some 30 to 50 years whereas the emissions from aviation occur in one flight.

The plants, peat bogs, trees might become damaged (they could burn down or die or be cut down). In the event that they are damaged, they become carbon emitters causing more damage as they emit the carbon that they have captured over the years.

No assessment of how Heathrow operations compare to national aviation emissions, either expanded or not, has been made, notwithstanding that Parliament has declared a state of climate change emergency. In support of its stance in the DCO consultation, Heathrow stated that it had followed advice from the Committee on Climate Change (“CCC”) given in 2017. That advice is way out of date, and the current advice is contained in the CCC Net Zero Report of May 2019. Following that the CCC has reported to Parliament and advised on aviation (footnotes 19 and 20).

The projected CO2 emissions, stated in the Heathrow Consultation Chapter 9 PEIR Volume 1[21], 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 nation is 19.05%.

The Committee on Climate Change agreed that the previous target 80% reduction overall required 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). 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.

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 only be permitted temporarily.

Off-setting by carbon capture, such as peat bogs and tree planting, should 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 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. Off-setting is highly speculative and most likely will not produce the intended off- setting at all.

Aviation causes particular damage by contribution to climate change. Not only are there the traditional greenhouses gases like CO2, but other gases when emitted at high altitude, cause a greenhouse effect and contribute to the warming of the planet. One of the most notable is water, which exists in the jet engine exhaust. Condensation occurs and droplets form to act as magnifying glasses for the heat. Water vapour disperses relatively rapidly and certainly more quickly than CO2, but it is continually replenished from jet engine exhausts. The estimate is that the non-CO2 emissions from aircraft double the greenhouse effect of aircraft over just CO2 alone[22].

Electric aircraft are not expected to become operational to any great extent until well after 2050 – after the date by which we need to become net zero. Heathrow Airport through its director of sustainability, Mr Matt Gorman, supported a paper entitled “The Flight to Net Zero” published by Green Alliance[23] in which they state that “Notably, reducing the number of flights is the only way to address the significant non-CO2 climate impacts of aviation, such as contrail formation and NOx emissions. These are estimated to cause as much atmospheric heating as the CO2 emissions, and are not currently accounted for” [page 19]. The CCC have specifically advised that offsetting will not be possible[24] and yet the industry still pretends that it can go on without change and expand. Quite simply, it can’t.

1 Heathrow Expansion Consultation PEIR Non-Technical Summary page 28

2 Hudda 2014 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4215878/

3 Keuken 2015 https://www.sciencedirect.com/science/article/abs/pii/S1352231015000175?via%3Dihub

4 Riley 2016 https://www.sciencedirect.com/science/article/abs/pii/S135223101630348X

5 Hudda 2018 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5822220/#!po=0.746269

6 Zhou in 2019 https://www.sciencedirect.com/science/article/pii/S0269749119306797

7 Washington state university 2019 https://deohs.washington.edu/mov-up

8 Roy Harrison, Birmingham University 2019 https://www.atmos-chem-phys.net/19/39/2019/ 9 KCL report on ultrafine particles 4 cities including London https://www.sciencedirect.com/science/article/pii/S016041201931832X?via%3Dihub

10 DEFRA Ultrafine Particles (UFP) in the UK https://uk-air.defra.gov.uk/library/reports.php?report_id=968 11 Heathrow Airwatch section 4.1 2018 Annual report http://www.heathrowairwatch.org.uk/documents/Heathrow_2018_Annual_Report_Final.html

12 Royal College of Physicians Every breath we take: the lifelong impact of air pollution https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-air-pollution And also the Committee on Medical Effects of Air Pollution (COMEAP)


13 Research of Queen Mary’s University Hospital https://www.qmul.ac.uk/media/news/2018/smd/first- evidence-that-soot-from-polluted-air-may-be-reaching-placenta.html

14 University of Bern https://www.sciencedaily.com/releases/2019/05/190516114627.htm

15 Report of Public Health England in the Evening Standard https://www.standard.co.uk/news/london/death- risk-from-londons-toxic-air-sees-utterly-horrifying-rise-for-second-year-running-a4167216.html

16 Ranzani https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2758211

17 See Research of Queen Mary’s University

18 See for example the report in the Guardian of the 4th February 2020 at https://www.theguardian.com/business/2020/feb/04/uk-air-industry-sets-zero-carbon-target-despite-70- more-flights

19 CCC report to Parliament 2019 at page 65 https://www.theccc.org.uk/publication/reducing-uk-emissions- 2019-progress-report-to-parliament/

20 Letter Lord Deben to Grant Shapps https://www.theccc.org.uk/publication/letter-international-aviation-and-shipping/

21 See Graphic 9.7 on page 9.52 of PEIR 9 https://aec.heathrowconsultation.com/wp-content/uploads/sites/5/2019/06/11-Volume-1-PEIR-Chapter-9-Carbon-and-greenhouse-gases.pdf

22 For example see Carbon Brief article at https://www.carbonbrief.org/explainer-challenge-tackling-aviations-non-co2-emissions

23 https://green-alliance.org.uk/The_flight_to_net_zero.php

24 See e.g. the July 2019 Committee on Climate Change report to Parliament at page 65 in which it is stated that

“In May 2019, the Committee recommended that the UK set a net-zero greenhouse gas emissions target for 2050. The Government and Parliament accepted this advice and on 27 June 2019 the target became law.

Consistent with the Committee’s advice, the Government were clear that net-zero emissions must be reached across the whole economy (including emissions from international aviation and shipping) and that the aim is to achieve the target entirely through action in the UK without recourse to international credits (or “offsets”)”. Reference to the evidence of the Government being clear that net zero include aviation is made in Hansard at https://hansard.parliament.uk/commons/2019-06-12/debates/A348AE4C-8957-42C8-8180-0F59E597E3EA/NetZeroEmissionsTarget. Greg Clark supporting the words of Rebecca Long Bailey “Achieving net zero before 2050 is necessary and affordable, and there is no need to rely on international offsets, which—let us be honest—does look like cheating.”


Appendix B; DCO Risks


Impact of highly concentrated PBN flight paths – US experience


Letter from US Congressmen and Senators to the FAA dated 20 December 2019


Question 11 Chapter 4 of CAP 1887 details the engagement expectations for the Airspace Change Organising Group (ACOG) to undertake. Do you have any comments on the engagement we are asking ACOG to undertake?

No further comment.

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  1. Michael Newman
    23rd April 2020

    Thank you for your diligence and commitment. The contrast between the logic of Heathrow’s – and for too long, the Government’s – proposals is stark. No-one yet has officially accused Heathrow’s owners and the CAA of corruption, but increasingly this is what it looks like. It might be helpful to identify the main individuals involved by name, and to document their financial and social benefits from pursuing Heathrow expansion.

  2. Gerald Morgan
    22nd April 2020

    Thank you for the thoroughness and excellence of this paper

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