Report by ERM shows Heathrow could not build a new runway and meet air quality standards

Gatwick Airport, keen to show up all the problems with a new Heathrow runway – attempting to promote its own scheme instead – has commissioned a study by ERM (Environmental Resource Management) on Heathrow air quality. The pollutant and averaging period of most relevance around Heathrow is the annual mean limit value for NO2, which is 40 μg/m3 of air. The Air Quality Standards Regulations 2010 say the Secretary of State must ensure that NO2 annual mean level is not over the limit value of 40 μg/m3 anywhere. Heathrow and the DfT predicted 10 years ago that diesel vehicles would emit much less NO2 by 2015 than they in fact do; diesel emissions from road vehicles have not fallen as fast as was expected. Heathrow is therefore not likely to meet the air quality standard, even without a new runway, till perhaps 2030.  The Gatwick-funded ERM report is critical of modelling submitted by Heathrow to the Airports Commission that continues to use outdated emission performance of vehicles.  The report says no detailed air quality impact modelling has been conducted since the DfT study 10 years ago. The Airports Commission has also not yet done adequate work on this, and said it would do “more detailed dispersion modelling”. This will probably not be available before the Commission’s (June?) announcement.
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Dodgy figures are the basis of Heathrow’s air quality claims, says report

17.4.2015 (Colnbrook Views)

Modelling supplied by Heathrow as part of its submission to the Davies Commission last year was based on emission figures which the airport would have known to have been out of date.

Predictions for Nitrogen Dioxide levels in 2030 prepared for Heathrow by AMEX last year (above) are remarkably consistent with forecasts prepared in 2007 indicating "that AMEC have used assumptions on emissions similar to those used ... which subsequently proved to be erroneous."

Predictions for Nitrogen Dioxide levels in 2030 prepared for Heathrow by AMEX last year (above) are remarkably consistent with forecasts prepared in 2007 indicating “that AMEC have used assumptions on emissions similar to those used … which subsequently proved to be erroneous.”

 

The Gatwick-funded report published yesterday [by ERM, Environmental Resources Management – a company with an OK reputation ….] says that Heathrow’s figures are based on ten-year old data on diesel emissions that has subsequently been discredited in the light of actual results.  Heathrow, it concludes, would have known better.

Modelling carried out ten years ago by the Department of Transport prior to the last expansion attempt had concluded that air quality would be reaching compliance by 2015.

The Project for the Sustainable Development of Heathrow (PSDH) had got its sums wrong because many diesel-fuelled vehicles still do not comply with new EU standards which continue to emit NOx at higher rates than expected.

“The situation has improved at some of the locations close to the airport itself, but many residential areas close to the M4, for example, are exposed to NO2 concentrations in excess of the Limit Value. The contribution to NO2 concentrations from the road network has clearly not reduced as expected.”

Those living adjacent to the M4 are expected to suffer most from the increase in road traffic during construction and once the new runway is open

Those living adjacent to the M4 are expected to suffer most from the increase in road traffic during construction and once the new runway is open

 

The report, by environmental consultants Environmental Resources Management is critical of modelling submitted to the Airports Commission in June last year that continues to use outdated emission performance of vehicles.

“… AMEC have used assumptions on emissions similar to those used for PSDH which subsequently proved to be erroneous.”

It is critical of Heathrow Airport’s submission which is “without evidential foundation” and “may well not prove to be correct”.

It concludes:

“There is significant evidence available that establishes that even without a Heathrow scheme coming forward the attainment of the limit value in the Heathrow area will not occur until after 2025 and will be difficult to achieve.

“The construction and operation of a Heathrow scheme would thus introduce additional sources of NOx into an area that is already struggling to attain the limit value.”

The study is also critical of the Airports Commission’s own analysis.

It says that no detailed air quality impact modelling has been conducted since the Department for Transport’s study a decade ago.   (See link). 

“To date, none of the documents submitted to the Airports Commission, or produced by the Airports Commission, quantify the effectiveness of the suggested mitigation measures and the question of their efficacy is still uncertain.

“As a result it is difficult to understand how the Commission can have reached the conclusions that it has in its Sustainability Assessment.”

Related links

Read more analysis of the report on Colnbrook Views:

Heathrow’s pollution strategy will “transfer air quality problems to other areas”

Road pollution would make a Colnbrook Runway undeliverable and illegal

Or read the full ERM report here.

or the dumbed down version (Gatwick infographic, pushing Gatwick) here.

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The Air Quality Standards Regulations 2010 say the Secretary of State must ensure that NO2 annual mean level is not over the limit value of 40 μg/m3 anywhere.

The pollutant and averaging period of most relevance around Heathrow is the annual mean limit value for NO2, which is 40 μg/m3 of air.


Some extracts from the ERM report

The report states:

“WHY EMISSIONS HAVE NOT REDUCED AS EXPECTED
The Euro emission standards for motor vehicles have become increasingly stringent for total oxides of nitrogen (NOx, which includes NO2 and nitric oxide which can go on to form NO2). The most recent set of standards is Euro 6 for cars and Euro VI for heavy duty vehicles. It is now clear, however, that NOx emissions from vehicles with diesel engines have not have not reduced in line with these progressively stringent Euro standards. Many diesel-fuelled vehicles do not comply with the standards in practice and are emitting NOx at higher rates than originally expected – and hence higher than previously modelled. Consequently, overall emissions in NOx are not reducing as might be expected and this explains, at least in part, why NO2 concentrations at many locations have not also declined, as was expected a decade ago.”
and
“Equivalent reductions were not achieved for other vehicles classes. Notably, diesel engines continued to be higher emitters. Not only do diesel engines emit at greater rates than a petrol equivalent with a three way catalyst, but some of the vehicles manufactured in the last decade have been shown to emit at significantly higher rates ‘on the road’ than implied by the type approval limit – which is to say that even when new, they are emitting certain pollutants at rates higher than the maximum allowable under the Euro standard.”
and
“The ‘Project for the Sustainable Development of Heathrow’ (PSDH) in 2004- 2007 was a major undertaking by the Department for Transport and included a review of techniques to model air quality around Heathrow. In the latter stages, a modelling study was carried out that examined the compliance issue, for both baseline (i.e. two runway) and third runway scenarios.”
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“The modelling carried out as part of PSDH in 2007 indicated that the NO2 concentrations around Heathrow would be approaching compliance with the NO2 limit value by 2015. However, measurements now show that this is not the case. The situation has improved at some of the locations close to the airport itself, but many residential areas close to the M4, for example, are exposed to NO2 concentrations in excess of the Limit Value. The contribution to NO2 concentrations from the road network has clearly not reduced as expected.”


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Report conclusions

These are the conclusions of the:
(Gatwick Airport Limited funded)
“Current and Future Air Quality around Heathrow Airport – Implications for its Further Development Report”
19 March 2015
Prepared by: Roger Barrowcliffe (Clear Air Thinking) Gavin Bollan (ERM)
For and on behalf of Environmental Resources Management

Conclusions:

At many places in the UK, the trend is for concentrations of NO2 to decrease and air quality is improving gradually. However, the rate of any improvement has not been as high as previously expected, and non compliance with the requirements of the Directive is widespread, as exemplified by DEFRA’s acknowledgement that there are 43 ‘zones’ where action is required to achieve compliance as soon as possible.
It is against this background that the European Commission has initiated infraction proceedings against the UK Government for failing to meet the NO2 limit value by 2015, as originally intended.
This is unquestionably an important issue for UK Government and any nationally significant infrastructure project must be designed such that it does not cause non-compliance with, or delay the achievement of, the NO2 limit value in any way.
The issue of whether the expansion of Heathrow can be achieved without causing or giving rise to any such delay can be distilled into one aspect of its impact on local air quality.
The principal issue regarding air quality in the Heathrow area and the proposed Heathrow schemes is whether or not it can be established that they can be constructed and operated without delaying the attainment of the annual mean NO2 limit value for a longer period than would occur if those schemes were not constructed and operated.
There is significant evidence available that establishes that even without a Heathrow scheme [ie. runway] coming forward the attainment of the limit value in the Heathrow area will not occur until after 2025 and will be difficult to achieve.
The construction and operation of a Heathrow scheme would thus introduce additional sources of NOx into an area that is already struggling to attain the limit value.
The mitigations proposed by Heathrow, whilst potentially beneficial in relation to airside sources, are available in the baseline 2 runway situation in any event.
Mitigation proposed in relation to road traffic sources, which are the more important issue where compliance with limit values is concerned, is generalised in nature and its potential effects have not been examined or quantified in any detail.
There is no certainty that the annual mean NO2 limit value could be met with a Heathrow Scheme being constructed and operated.
There are no assurances that the construction and operation of a Heathrow scheme could be undertaken without delaying compliance with NO2 limits values.
Neither is there any certainty therefore that a Heathrow Scheme could be delivered and the UK’s legal obligations, under the 2008 EU Air Quality Directive and the 2010 Air Quality Regulations, still be met.
If the Commission was to recommend one of the Heathrow schemes, there is a significant risk that the scheme will prove to be undeliverable.
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Briefing by AEF asks whether a new runway would breach legal limits for air quality

The AEF (Aviation Environment Federation) has published a short, easy to read, briefing on air pollution in relation to a new runway at Heathrow or Gatwick. It considers the importance of air pollution and how far the Airports Commission has gone to address the issue to date. The Commission says a full assessment and modelling of the local air quality impacts has yet to be undertaken. AEF says because air quality is a key issue for a new Heathrow runway, as the area already breaches legal air quality limits, the Commission should publish the modelling it will carry out of the local air quality impacts, including damage to human health. AEF says the future Government should assess the Commission’s recommendations in terms of their impact on human health. They should assess the risks to air quality legal limits from runway plans, and only permit a runway if it can be shown that legal limits on pollutants can already be met consistently, and are falling. The Commission is aware that improvements in aircraft engine emissions may take a very long time to happen; that reducing the amount of air  pollution from road transport around Heathrow may take a very long time; and EU air quality standards may be tightened. 

http://www.airportwatch.org.uk/2014/12/briefing-by-aef-asks-whether-a-new-runway-would-breach-legal-limits-for-air-quality/

 

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Airports Commission consultation shows air quality problems with new runways, but no adequate data yet

The Airports Commission consultation document is aware that air quality is a major obstacle for a new Heathrow runway.  It says expanding either Gatwick or Heathrow would have a negative impact on air quality, with all proposed schemes requiring expansions to local road networks to accommodate increased road traffic. For both the Heathrow runway options the Commission says “Both local Air Quality Objectives and EU limit thresholds are at risk of exceedance at a small number of monitoring sites in the local area under this scheme. While in some cases these exceedances are also forecast to occur in the do minimum scenario, there is clearly a substantial negative impact of the scheme on air quality, unless forceful mitigation measures are implemented.” But they have not been able to complete full detailed modelling of the air quality impacts of new runways and further work is needed. This unfortunately is not in time for the consultation.  The Commission intends to supplement this at a future date with “more detailed dispersion modelling”. That means models to show how wind and weather disperses pollution, and it could be questioned how much faith should be placed on sufficient wind speeds in coming years.

http://www.airportwatch.org.uk/2014/11/airports-commission-consultation-shows-air-quality-problems-with-new-runways-but-no-adequate-data-yet/

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