Air quality mitigations proposed for a Heathrow Third Runway are either too vague to be quantified or should be implemented regardless of expansion, a new Gatwick-funded report says.
On-airport mitigations proposed by Heathrow as part of its Third Runway plans should be considered the baseline and implemented regardless of any Third Runway permission, while those relating to road traffic sources lack sufficient detail to be properly evaluated, the report from Environmental Resources Management published yesterday finds.
And if Heathrow is serious about tackling road pollution generated by Heathrow it must go much, much, further.
The report says that for locations near the M4 the influence of the airport’s direct emissions (such as aircraft and apron vehicles) is minimal. The NO2 concentration is dominated by the contribution of road traffic, a significant proportion of which is related to the use of Heathrow. Meaningful mitigation measures must therefore focus primarily on reducing the contribution from road traffic.
“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.”
Heathrow Airport Ltd’s proposals to the Airports Commission suggest a range of mitigation measures related to the airside sources of NOx, such as incentivising aircraft with lower NOx emissions, a low emission operational vehicle fleet and providing all aircraft with fixed electrical ground power and pre-conditioned air when on stands. While these measures are potentially beneficial, they will have little effect on the risk of non-compliance with the NO2 limit value at locations near the road network. In any case, they should be implemented regardless, the report’s authors state:
“… such measures can be adopted in any event across the airport. As such they should form part of the baseline measures within any air quality plan and should not benefit only the expansion scheme.”
Mitigation measures currently proposed that might reduce the contribution to locations near the road network from airport related sources include the provision of incentives for access to the airport by zero or ultra-low emission vehicles and, as a last resort, the use of a congestion charge to drive down airport-only related road traffic.
But the measures lack the necessary implementation specifics to make them meaningful:
“HAL’s proposals do not describe how these mitigation measures might be implemented in detail, nor do they provide any quantification of the expected reduction in NO2 concentrations near the road network that they might afford. Neither do the proposals address the potential consequential effects on, for example, road traffic distribution in the wider area around Heathrow.”
Without more detail Heathrow could just push the problem somewhere else.
“It could well be that the introduction of these sorts of measures results in road traffic around Heathrow shifting onto other roads with a consequent increase in traffic flows on those roads and potentially increased congestion. Thus, it may be that the effect of the proposed road traffic mitigation measures could simply be to transfer the air quality problems to other areas.”
ERM says Heathrow needs to show that it is serious about tackling pollution.
It points to 2007 DfT consultation documents describing a number of potential measures to mitigate the possibility of not meeting the air pollution limits including:
- Additional rail and coach services with lower fares
- Charging for access to the airport
- Increased parking charges and reduced spaces for employees
- Closure or restricted use of eastbound slip roads on the M4
- A widespread motorway ramp metering strategy (where access is controlled by traffic lights on slip roads)
- Charging road users on the public network around Heathrow as they entered a cordon; and
- Charging HGV users to cross a cordon around Heathrow, including the M4.
The ERM report notes that a subsequent report found that requiring HGVs to pay a £3 charge to enter a cordon around Heathrow including the M4, and a proposed a £20 airport forecourt charge for passengers, would be the most effective measures.
None of which have been taken forward in Heathrow’s submission to the Airports Commission.
Read more analysis of the report on Colnbrook Views:
Or read the full ERM report here.
A few extracts from the ERM report:
The 2007 Surface Access report says: “…the most effective options were those that required HGVs to pay a £3 charge to enter a cordon around Heathrow, including the M4. One of these options also proposed a £20 airport forecourt charge; in effect a road charging scheme for airport passengers. ”
“Mitigation measures proposed in relation to the reduction of emissions from airport-related road traffic sources include the provision of incentives for access to the airport by zero or ultra-low emission vehicles and, as a last resort, the use of a congestion charge to drive down airport -only related road traffic.”
“The Heathrow Airport Limited submission states that,
‘we have committed to adding a third runway with no more airport related traffic on
the road than today and to increase the proportion of passengers who use public
transport to access the airport from 40% today to more than 50% by 2030. ….We
also outline that there may be a case for introducing a congestion charge for people
travelling to the airport once improvements in public transport have been delivered.’”
“The submission also states that,
‘As a result of our surface access strategy, there will be no more Heathrow related vehicles on the road than there is today. Those vehicles that are travelling to the airport will be cleaner. Combined with new aircraft technology, this means that levels of nitrogen dioxide would be within EU limits.’
“The only part of this latter statement that is unquestionably true is that vehicles will be cleaner in the future. The other points are simply assertive and without evidential foundation – they may well not prove to be correct.
“The prediction regarding numbers of passengers and workers arriving at Heathrow by car is particularly uncertain. It cannot reasonably be guaranteed, as it will depend on the acceptability of the proposed measures to local communities, as well as on the response and alternative actions taken by airport users to the dis-incentives applied. This is a key aspect of the proposed mitigation and warrants further consideration.”
“Mitigation measures proposed that might reduce the contribution to locations near the road network from airport related sources include the provision of incentives for access to the airport by zero or ultra-low emission vehicles and, as a last resort, the use of a congestion charge to drive down airport-only related road traffic. HAL’s proposals do not describe how these mitigation measures might be implemented in detail, nor do they provide any quantification of the expected reduction in NO2 concentrations near the road network that they might afford. Neither do the proposals address the potential consequential effects on, for example, road traffic distribution in the wider area around Heathrow. It could well be that the introduction of these sorts of measures results in road traffic around Heathrow shifting onto other roads with a consequent increase in traffic flows on those roads and potentially increased congestion. Thus, it may be that the effect of the proposed road traffic mitigation measures could simply be to transfer the air quality problems to other areas.”
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.
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.