Environmental Audit Committee says government should not permit Heathrow runway without strict conditions
The EAC report’s conclusions say: “The Government should not approve Heathrow expansion until Heathrow Ltd. can demonstrate that it accepts and will comply with the Airports Commission conditions, including a night flight ban, that it is committed to covering the costs of surface transport improvements; that it is possible to reconcile Heathrow expansion with legal air pollution limits, and that an expanded Heathrow would be less noisy than a two runway Heathrow. In each case – climate change, air quality and noise – it needs to set out concrete proposals for mitigation alongside clear responsibilities and milestones against which performance can be measured. It should report regularly to Parliament, through this Committee and others, on progress. The Government should not avoid or defer these issues. To do so would increase the risks of the project: delay through legal challenge, unquantifiable costs resulting from unclear responsibilities, economic risks through constraint of other sectors to meet increased aviation emissions and longterm costs to public health from the impact of air pollution and noise.”
Government should not give go ahead on Heathrow until environmental conditions can be met
1 December 2015
(Environmental Audit Committee press release)
The report is at
The Government should not give final approval to Heathrow expansion until the airport can demonstrate that it accepts and will comply with key environmental conditions, MPs on the Environmental Audit Committee have said.
Environmental Audit Committee Chair, Huw Irranca-Davies MP:
“The purpose of this inquiry was not to reopen the debate over where extra airport capacity should be located or whether it should take place at all. It was to examine the implications of the Airports Commission’s recommendation for a third runway on climate-changing emissions, air quality and noise – and what Government and Heathrow should do about them.”
The MPs say the airport must demonstrate that: it can reconcile Heathrow expansion with legal air pollution limits; commit to covering the costs of surface transport improvements; commit to introducing a night flight ban; and show that an expanded Heathrow would be less noisy than a two runway Heathrow. Huw Irranca-Davies MP:
“The Government has a duty to reduce illegal levels of air pollution in London to protect the health and well-being of its population. The Communities living near to the roads around Heathrow already put up with noise and extra traffic, it would be quite unacceptable to subject them to a potentially significant deterioration in air quality as well. Increased pollution should certainly not be permitted on the grounds that other areas of London are even more polluted.”
On carbon emissions, the inquiry found a gap between the Government’s current policies and the policies modelled by the Commission to show expansion could be achieved within CO2 limits. The Government should set out its approach to international negotiations on aviation emissions and put in place a strategy to deliver aviation emissions no higher than 2005 levels by 2050 in line with the economy-wide target set by the Climate Change Act.
EAC Chair, Huw Irranca Davies MP commented:
“Planes are becoming more fuel efficient, but this alone will not keep aviation emissions in line with the Government’s climate change targets given the growth in passenger numbers. Even without expansion, aviation is on track to exceed its climate change target. We heard evidence that those targets might be met in theory, but at present there is a policy vacuum and evidence-based scepticism as to whether they can be met in practice.”
On air quality, the inquiry heard concerns that the Commission’s interpretation of the Air Quality Directive implied that significant increases in nitrogen dioxide (NO2) resulting from Heathrow expansion would be allowable because of worse performance elsewhere in London. The Committee said the Government should make clear that this is not the position it intends to take when assessing Heathrow’s compliance with the EU directive on air quality.
On noise, the Committee strongly supports a ban on night flights and calls on the Government to improve trust between local people and the airport by setting up within the year a Community Engagement Board. Ministers also need to establish and explain how noisy a future three-runway Heathrow would be relative to a future two-runway airport, and ensure that communities still receive predictable respite from planes flying overhead.
In each case – climate change, air quality and noise – the Government needs to set out concrete proposals for mitigation alongside clear responsibilities and milestones against which performance can be measured.
The Government should report regularly to Parliament on its progress through the Environmental Audit Committee and other committees. It should use the consultation period that would likely follow any decision to address the recommendations in the report, before seeking Parliament’s approval for the scheme.
Chair of the Environmental Audit Committee, Huw Irranca-Davies MP:
“To defer dealing with the environmental impact of a third runway would be irresponsible and could lead to legal challenges as a result of the potential damage to public health from increased air pollution and noise. If the Government decides to accept the Commission’s recommendation for a third runway in principle, we will seek assurances from the Secretary of State for Transport that environmental conditions will be met before it is given final approval.”
The Climate Change Act 2008 requires the Government to set a series of 5 year carbon budgets to reduce greenhouse gas emissions by 80% by 2050. The statutory Committee on Climate Change, which advises the Government on meeting these budgets, says its ‘planning assumption’ is that 2050 aviation emissions should to be around 2005 levels (i.e. 37.5 MtCO2).
The UK’s legal air pollution limits are set out in EU Directive 2008/50/EC on ambient air quality. The Directive limits values in respect of certain key pollutants – including an annual mean limit value of 40 μg/m3 NO2. Compliance is assessed through measurements carried out by “receptors” next to roads. The deadline for compliance was 2010 but a number of areas in the UK remain above the limit values, including Greater London.
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The report’s Conclusions and recommendations
5 Conclusion (Page 26)
89. The Government should not approve Heathrow expansion until Heathrow ltd. can demonstrate that it accepts and will comply with the Airports Commission conditions, including a night flight ban, that it is committed to covering the costs of surface transport improvements; that it is possible to reconcile Heathrow expansion with legal air pollution limits, and that an expanded Heathrow would be less noisy than a two runway Heathrow. In each case – climate change, air quality and noise – it needs to set out concrete proposals for mitigation alongside clear responsibilities and milestones against which performance can be measured. It should report regularly to Parliament, through this Committee and others, on progress. The Government should not avoid or defer these issues. To do so would increase the risks of the project: delay through legal challenge, unquantifiable costs resulting from unclear responsibilities, economic risks through constraint of other sectors to meet increased aviation emissions and longterm costs to public health from the impact of air pollution and noise.
1. The Government has said it will set “a clear direction” on airport expansion by the end of the year. If the Government is minded to go ahead with the Commission’s recommendation, it is likely that this will be followed by a further period of consultation. The Government should use this period to address the recommendations in our report, before making a final decision on whether to go ahead with the scheme and seek the approval of Parliament through a National Policy Statement or Hybrid Bill. (Paragraph 4)
2. The Government, when making a decision, will need to consider its carbon emissions mitigation against the full range of demand scenarios modelled by the Commission. (Paragraph 10)
3. The former Airports Commissioners told us they relied heavily on the work of the Committee on Climate Change when undertaking their work. They denied that their modelled carbon prices and policies were policy recommendations – feeling that the CCC were better placed to take on this role. Governments have in the past been reluctant to accept CCC policy recommendations on aviation. The Government cannot credibly rely on the Commission’s analysis as evidence that Heathrow expansion can be delivered within the limits set by the 2008 Act if this continues to be the case. We recommend that the Government give the CCC the opportunity to comment on the Commission’s forecasting of aviation emissions and the feasibility of its possible carbon policy scenarios. The Government should act on any recommendations they make. (Paragraph 14)
4. The Commission’s indicative carbon prices and policies were not intended as recommendations. Nonetheless, they give an indication of the scale of intervention likely to be required to bring aviation emissions within 2005 levels by 2050. Before making any decision on Heathrow expansion, the Government should publish an assessment of the likely impact on the aviation industry – particularly regional airports – and wider economy of measures to mitigate the likely level of additional emissions from Heathrow. (Paragraph 17)
5. The Government should consider developing a policy framework to advise industry about how to prioritise trade-offs between noise and carbon pollution when adopting biofuels thus giving guidance on priorities. (Paragraph 20)
6. The Commission, industry and Committee on Climate Change envisage biofuels playing a limited role in controlling aviation emissions. However, the use of biofuels is not without its own risks and uncertainties. The Government must either examine the options to encourage aviation to move to advanced fuels that are sustainable across their entire life cycle (including indirect land use change and impacts on food supplies) or identify ways in which corresponding emissions reductions will be achieved. (Paragraph 21)
7. The Government should set out its approach to the International Civil Aviation Organisation negotiations as the previous Government did ahead of the COP 21 negotiations in Paris. It will need to demonstrate either that the agreement it is seeking can incentivise the absolute carbon emission reductions required to meet the planning assumption or what measures it is prepared to take and to what timescale in order to make up the shortfall. (Paragraph 25)
8. There are some areas of the Commission’s work on operational and technological improvements that are still the subject of significant disagreement. We urge the Government to produce and publish its own thorough evaluation of the forecasts, including its assessment of whether take-up is likely to be sufficient without Government intervention. (Paragraph 28)
9. We draw four conclusions from the evidence we heard on carbon emissions. Firstly, because the planning assumption requires additional decarbonisation from other sectors, passenger growth in aviation cannot be seen in isolation from the progress on emissions reduction made by the rest of the economy. Secondly, the industry has taken steps to reduce its carbon emissions and, in areas such as fuel efficiency, market incentives are likely to ensure further progress. Thirdly, these measures in themselves are highly unlikely to achieve the planning assumption and further measures, including demand management, will be required. Finally, there is a significant gap between the theoretical models of how a mixture of these measures might allow the planning assumption to be met and the proposals currently on the domestic and international policy tables. (Paragraph 29)
10. We recommend that any Government decision on airport expansion should be accompanied by a package of measures to demonstrate a commitment to bringing emissions from international aviation within the economy-wide target set by the 2008 Act. They should also, as a minimum, commit to accepting the Committee on Climate Change’s advice on aviation in relation to the fifth carbon budget, introducing an effective policy framework to bring aviation emissions to 2005 levels by 2050 no later than autumn 2016 and pressing for the strongest possible international measures at the International Civil Aviation Organisation next year. (Paragraph 30)
11. Before the Government makes its decision, it should make its own assessment of the likely costs of preventing an adverse impact on health from expansion at Heathrow and publish it. (Paragraph 33)
12. Many of our witnesses interpreted the Commission’s interpretation of the Air Quality Directive as implying that significant increases in NO2 resulting from Heathrow expansion would be allowable because of worse performance elsewhere in London. This would make no sense in terms of protecting public health and wellbeing. The Government should make clear that this is not the position it intends to take when assessing the scheme for compliance with the Directive. (Paragraph 43)
13. Before the Government makes its decision, it will need to demonstrate that its revised air quality strategy can deliver compliance with legal pollution limits within the timescales agreed in the finalised plan to be approved by the European Commission. The Airports Commission Report: Carbon Emissions, Air Quality and Noise 29 It will also need to show that this can be maintained even when the expanded airport is operating at full capacity. Heathrow’s existing air quality strategy should also be revised to meet the new targets. Failing this, Heathrow should not be allowed to expand. (Paragraph 47)
14. The Commission recommended that the release of capacity at an expanded airport should be conditional on air quality standards being met. The Government should not approve expansion at Heathrow until it has developed a robust framework for delivery and accountability. This should have binding, real-world milestones and balance the need for investor certainty with assurances that a successor Government cannot set the conditions aside if they become inconvenient. (Paragraph 50)
15. Disaggregating the impacts of Heathrow on local traffic, and therefore air quality, is complex and contested by the airport and the local authorities. The Government must establish clearly delineated responsibilities for meeting air quality limits before deciding to go ahead with the scheme. We foresee significant legal and commercial risks further down the line if this is not done, for example, if central Government tried to hold local authorities to account for a failure to meet the targets that they attributed to airport expansion or to penalise the airport for pollution that it attributed to background traffic. (Paragraph 53)
16. The aspiration of moving the majority of journeys to public transport with no increase in road traffic is shared by all. Transport for London told us this would require large-scale modal shift of the scale seen in central London over the last 15 years. However, there is no agreement between them and the Commission over the extent of infrastructure improvements required to achieve this, the resulting costs or, by implication, the extent to which individual parties would meet those costs. Before the Government decides to go ahead with Heathrow expansion it should set out its assessment of what would be required in terms of infrastructure improvements, agreed responsibilities for funding and milestones for completion. This should be part of a wider transport strategy for West London to minimise the risk of unintended consequences. The Government must make a binding commitment that Heathrow will fund the infrastructure improvements necessary to accommodate an expanded Heathrow. (Paragraph 61)
17. The Commission highlighted the inadequacy of relying purely on averages when
measuring the impact of noise on communities. People living close to Heathrow do
not experience noise from flights into and out of the airport as a constant decibel
level throughout the day or night. So, although the measurement of average noise
experienced provides a helpful snapshot of noise over a short period, and a useful
historical comparison, it does not reflect a range of variables such as the type, height
or engine power of an aircraft. Nor does it account for peak noise events. And, if it
lacks detail, it may also ignore a swathe of people who are overflown infrequently but
loudly. The Government, when assessing the noise impact of an expanded Heathrow,
should do so against a full range of metrics and not just average noise experienced.
These metrics need to be measured against international standards such as World
Health Organisation recommendations and inform a change in Government policy
on aviation noise. (Paragraph 67)
18. The Commission recommended the establishment of an Independent Aviation Noise
Authority. This body will need a more up to date understanding of people’s attitudes to
noise if it is to be credible. One of the first tasks of such a body should be to undertake a
survey of people’s attitudes to aviation noise. The results of this survey should underpin
both its own work and future Government policy on managing noise. In particular,
they should form part of a piece of work to develop a set of metrics to assess noise
impact. (Paragraph 73)
19. For residents around Heathrow, noise is a major part of their day to day lives.
Understandably, they are deeply concerned about the impact of an expanded airport.
The Government needs to demonstrate that, in assessing the case for expansion, it has
based its decision on whether an expanded Heathrow would be noisier or less noisy
than a two runway Heathrow at the same point in time – taking into account respite
and the need for predicable relief from overflying. (Paragraph 81)
20. The Commission’s recommended ban on night flights was a key part of the package
proposed by the Commission. The Government should publish a plan, including a
series of binding milestones, to deliver the proposed ban as part of any announcement
to proceed with expansion at Heathrow as recommended by the Commission.
21. Levels of trust between Heathrow and the local community are an historical
and enduring issue which has impaired effective community engagement. If the
Government decides in favour of expansion it should put in place a framework to
ensure that mitigating measures are introduced promptly. The Airports Commission
also recommended the establishment of two bodies – an Independent Aviation Noise
Authority and a Community Engagement Board – to address this. As part of the efforts
to restore trust and effective community engagement, these should be introduced in
the next year, even if the Government decides against Heathrow expansion. One of
the first pieces of work for the Community Engagement Board should be to establish
the extent to which commitments made at the time of Terminal 5 have been met.
Full report at