Guidance from the No 3rd Runway Coalition on how to respond to the DfT 2nd NPS consultation. Ends Tues 19th Dec.
The DfT is consulting on its revised draft Airports National Policy Statement (NPS). This second consultation comes after an earlier one in February. The deadline for the revised draft NPS consultation is Tuesday 19th December. The No 3rd Runway Coalition (NoR3Coalition) has put together some simple guidance for people trying to respond. There are dozens of documents in the consultation, most hard to locate, making responses very hard indeed for non-expert laypeople. The consultation only in fact asks one question: “Do you have any comments on the revised draft Airports NPS or any of the documents set out in the table on pages 7 and 8?” In reality, there is a great deal more that people should respond to. The NoR3Coalition has set out some key points on the issues of air quality, noise, economics, surface access, regional connectivity, health and climate change. People are encouraged to submit a response, in their own words. This need not be long or complicated, but just express key concerns. Responses can be by the online form at https://runwayconsultation.dialoguebydesign.com/ or by email to RunwayConsultation@dft.gsi.gov.uk
No 3rd Runway Coalition Guide to responding to the DfT Consultation on the revised NPS
The consultation only asks one question: Do you have any comments on the revised draft Airports NPS or any of the documents set out in the table on pages 7 and 8?
Key Issues to mention in your response
- The revised NPS states that the proposal for a northwest runway at Heathrow has a ‘high risk’ of exceeding legal limits for air quality.
- The revised NPS also fails to model the impacts of the construction of a new runway on legal air quality limits.
- The Updated Appraisal Report states that an expanded Heathrow opening in 2026 would be operating at full capacity by 2028. This will lead to a greater impact on air quality in the first few years of the runway being in use. The NPS does not include any proposal to mitigate this fact.
- The revised NPS has not accurately reflected the risk posed by expansion to the continued breach of the UK’s air quality legislation. The Government’s air quality plan is still subject to legal challenge and no effective enforcement has proposed should air quality improvements not materialise as the Government expects.
- The revised NPS does not fully take into account the impact aircraft will have on people and communities that are newly overflown. The population exposure at high noise levels is 42% higher in 2030 in the new forecasts.
- The lack of information around detailed flight paths associated with a third runway at Heathrow is a significant flaw that undermines the credibility of the NPS.
- As a result of the new airspace policy the revised NPS now demonstrates that there is a lowering of the threshold at which significant community annoyance begins to occur. Nearly, 400,000 more people will fall within the noise contour considered to mark the onset of significant community annoyance in 2030.
- There is insufficient information in the revised NPS on the length of the respite period that communities will experience should a third runway become operational.
- The Updated Appraisal Analysis significantly undermines the evidence base and rationale for the Government’s support for the Northwest Runway at Heathrow.
- The Government has pursued a policy of support for expansion at Heathrow, primarily based on the economic benefits accrued to the country. However, the revised NPS fundamentally challenges this position as it is not clear that the preferred option of Heathrow expansion presents the most strategic case for expansion that delivers the greatest economic benefits.
- The revised NPS has not included any further analysis of the potential costs involved in providing the surface access improvements required to facilitate the operations of a third runway at Heathrow.
- The revised NPS has not calculated the financial or environmental costs of the proposed construction of the runway over the M25, nor assessed the potential impacts on the local road network.
- The revised NPS shows that airports outside of London will on average handle 8.5% fewer passengers in 2050 with a third runway at Heathrow.
- Table 3.3 demonstrates that the total number of destinations served will actually fall when compared to a no expansion scenario.
- The Airports Commission report assessed the effects of a third runway at Heathrow as moderately adverse for health outcomes (including mental and physical health) and majorly adverse for children’s cognitive development. The revised NPS has failed to give sufficient weight to these very serious impacts.
- Government should examining bringing the legal air pollution limits down to be in line with WHO recommendations.
- The revised NPS includes a significant reduction in CO2 emissions per passenger compared to previous Government forecasts in 2013, yet does provide any evidence to explain why the current predictions are accurate and the previous ones were incorrect.
- The revised NPS and Appraisal of Sustainability make clear that the Government has no intention of pursuing a carbon capped scenario but rather will allow expansion on a carbon traded basis. This will require a significant rise in the price of carbon that is currently not part of Government policy.
How to respond
Write to: Freepost RUNWAY CONSULTATION
Deadline for submissions is Midnight on Tuesday 19 December 2017.
DfT page on the “Heathrow expansion: revised draft Airports National Policy Statement”
and the DfT’s Revised draft Airports NPS
The main document is at
This revised draft Airports National Policy Statement builds on the February 2017 draft Airports National Policy Statement.
Some of the relevant documents are:
and there are many more at https://www.gov.uk/government/policies/aviation-and-airports