Transport Committee demands serious changes to Government’s Heathrow case before any vote in Parliament
The Commons Transport Committee has produced the report on its inquiry into the Draft Airports NPS (ie. on the proposal for a 3rd Heathrow runway). The report states: “Once costs are considered, the net economic benefits for the NWR [North West Runway] scheme are relatively small at a maximum of £3.3 billion over 60 years and in fact, may be negative if future demand falls.” It highlights the absence of a large amount of necessary material from the Government’s draft NPS; it demands that evidence must be presented to show that the scheme is both affordable and deliverable – before any vote is put to MPs. The report contains a highly critical assessment of the cost to the taxpayers, passengers and airlines of expansion. There was also expression of major concerns about the lack of clarity on surface access proposals and costs on the rerouting of the M25, the methodology of calculating air pollution impacts and a considerably more radical approach on noise impacts. Though a NPS was expected to be put to Parliament before the summer recess in July, there must be evidence clarifying the number of areas of concern before MPs should be asked to vote. It is unlikely the necessary information could be obtained in time for an early summer vote – or even one in 2018.
The report is at
Transport Committee demands serious changes to Government’s Heathrow case before any vote in Parliament
23.3.2018 (No 3rd Runway Coalition press release)
The Committee has conducted a lengthy investigation, and had written and oral evidence from a number of experts. Its report is critical of the Heathrow scheme, and includes serious questions about whether the runway could ever actually happen.
Serious questions about whether Heathrow expansion can ever actually happen emerged following the publication of the House of Commons’ Transport Committee’s report on its inquiry into the Government’s draft Airports National Policy Statement (1).
The report highlights the absence of a large amount of material from the Government’s draft NPS and demands that evidence be presented that the scheme is both affordable and deliverable before any vote is put to MPs.
Cost: The report produced a highly critical assessment of the cost to the taxpayers, passengers and airlines of expansion and has demanded to see evidence that these concerns will also be met before any vote is put to Parliament.
Surface access, air pollution and noise: There was also expression of major concerns about the lack of clarity on surface access proposals and costs on the rerouting of the M25, the methodology of calculating air pollution impacts and a considerably more radical approach on noise impacts.
A final National Policy Statement (NPS) was expected to be put to Parliament before the summer recess in July. Yet many of the demands and other recommendations in the report would yield that timetable extremely difficult to adhere to.
The No 3rd Runway Coalition believes that the draft NPS underestimates the true noise impact of Heathrow’s proposals and that the actual numbers of people exposed to noise pollution would be revealed if Government implement the Committee’s recommendations in full.
Indeed, the TSC report highlights severe discrepancies between the NPS and the DfT’s own guidance on noise that raises doubts about the number of people to be impacted, as suggested in the NPS.
The report also questions the methodology applied to the monetising of air pollution costs and suggests that the assessment of the impact on the local populations was ‘overly rigid’ and potentially underplays the consequent increase in pollution that expansion would create.
In a further blow, the Committee also recommended that the Government’s preferred scheme be tested by the Civil Aviation Authority to ensure it is “both affordable and financeable” and that such a test “should offer an opportunity to halt the planning process if it is evident that the proposed scheme has no realistic prospect of being built.”
The Committee also identified that in its current form, the NPS would be a high risk of losing any legal challenges.
“The case for expanding Heathrow is getting weaker and weaker. This report highlights serious errors in the Government’s National Policy Statement that requires, on twenty-five different issues, to go back and think again.
“Heathrow have had years and years to come up with these proposals and yet still there is significant information missing from the proposals including a real plan to deal with air pollution and no knowledge as to whether [name area] will be affected by new third runway flight paths.
“If the Government implements all these recommendations then a parliamentary vote on the final national policy statement is unlikely to happen in 2018.”
- House of Commons Transport Committee, Airports National Policy Statement, HC548, published 23 March 2018 https://publications.parliament.uk/pa/cm201719/cmselect/cmtrans/548/548.pdf
TSC Report Recommendations & key points
- The report represents a significant climb down from previous committees’ pro-expansion stance.
- The report raises a number of significant concerns about insufficient information in NPS.
- The report demands a number of condition be met and incorporated into the NPS, before being brought to a vote in Parliament.
- The report raises concerns about financial viability of scheme.
The Coalition comments:
The real issue here is that the devil is in the detail – what the report highlights is the severe discrepancy between the National Policy Statement and the Department for Transport’s own guidance on noise.
The committee’s recommendation would help reveal the true number of the number of people impacted by noise from Heathrow expansion.
If the Government implements all these recommendations then a parliamentary vote on the final national policy statement is unlikely to happen in 2018.
The Committee have expressed major concerns about the lack of clarity on surface access proposals needed for a third runway and costs on the rerouting of the M25.
Heathrow have had years and years to come up with these proposals and yet still there is significant information missing from the proposals including a real plan to deal with air pollution, costs on surface access as well as the cost to passengers.
The committee produced a scathing assessment of the cost to the taxpayers, passengers and airlines and has demanded to see evidence that these concerns will be met before any vote is put to Parliament. Should such evidence not be produce, we expect the NPS to be thrown out.
The committee should undertake to hold a further inquiry to ensure its recommendations have been adhered to.”
On the cost of the 3rd runway:
The report accepts that cost accuracies will reduce as the project matures, but fundamental aspects of scheme design and surface access remain undefined, creating a perception of a cost risk that is high. There is only one mention of cost in the NPS. This is not a fair reflection of the legitimate concerns of airlines and passengers, who are likely to absorb much of the risk, about the cost of expansion
The report is critical of there being almost no mention in the NPS of the potential cost and investment risks associated with this scheme.
There is recognition that the Heathrow proposal would probably be the largest privately financed infrastructure project anywhere ever in the world.
Recommendation 11 of the report:
Before votes in Parliament to approve a final NPS, we would like to see evidence to demonstrate that the Northwest Runway scheme is both affordable and deliverable and that steps are being taken to address the valid concerns we heard in evidence about the high cost of the scheme and the significant risk that costs will rise.
The Coalition believes that should such evidence not be forthcoming, then the NPS should be thrown out.
On Air Pollution:
Recommendation 4 of the report:
We recommend that the population impact estimates be updated to reflect the air quality impacts from the increased number of aircraft movements and surface access traffic that will result from a Northwest Runway scheme. We also recommend the air quality monetisation modelling and results be published to clarify the monetised costs of poor air quality.
Recommendation 5 of the report:
We recommend the Government adopts a more stringent interpretation of air quality compliance than what is currently applied by the Department for Transport to support the NPS.
Recommendation 6 of the report:
We recommend that a condition be included in the NPS to the effect that development consent will only be granted if the Secretary of State is satisfied that the proposed scheme will: avoid significant adverse impacts on health and quality of life from air quality;
The report recognises that legal compliance is almost wholly dependent on measures introduced by Government, at the national level.
On Surface Access:
Recommendation 7 of the report:
We also recommend the Government clarify which schemes are needed to support current two-runway operations at Heathrow and which are needed to support an expanded Heathrow. As part of this, we recommend the Department for Transport’s updated surface access modelling be published so that the likely impact on road and rail congestion of a NWR scheme is known.
Recommendation 8 of the report:
We recommend that the surface access costs in the appraisal, and which support the NPS, be updated and included in the final NPS to reflect the indicative costs of those additional schemes required to deliver on the target of no more road traffic. We are concerned about the absence of detail on proposed changes to the M25. We recommend that the Government work with Heathrow Airport Limited to clarify the proposals and bring greater certainty to the development plans. A key part of this must be the arrangements for diversion of traffic during any works.
There is also considerable uncertainty as to what surface access schemes will be required to support the new runway, how much those schemes will cost and how those costs will be allocated between HAL and the public sector.
There are still significant cost risks associated with this scheme, particularly with respect to the M25 reconfiguration. The report expressed concern at the lack of design detail and the potential impact on local road networks from increased traffic.
On Regional Connectivity:
Given the uncertainty around the eventual domestic route offering at Heathrow, more needs to be done to reassure non-London regions that they will be offered this connectivity once a NWR scheme is delivered.
Recommendation 10 of the report:
We recommend that the Government provide a clear definition in the NPS of what constitutes a domestic route and that the Government outlines more clearly, in paragraph 3.34, how it intends to secure 15% of new slots for domestic connections, including the policy levers it will use to achieve this target. It should also include an explanation as to how the Government intends to deliver these slots in the immediate period after the third runway opens and how it will guarantee these slots are made available at suitable times spread across the day. The Government should also outline how it will enforce Heathrow’s domestic connectivity commitments once a NWR scheme is in operation.
A more revealing metric—which is not presented in the appraisal work supporting the NPS—is the gross number of people who will be newly exposed to significant levels of noise annoyance. 132 e evidence suggests that over 300,000 people could be newly affected by significant noise annoyance from an expanded Heathrow.
If the threshold of annoyance was extended down to the 51dB level, an extra 539,327 people would be captured in the annoyance footprint; taking the total number of people in the noise annoyance footprint to over 1.15 million.
It is impossible to know what the exact noise outcomes of a NWR will be without actual flight-paths; there are several uncertainties as to the scale of the noise impacts for people living in and around Heathrow.
Recommendation 14 of the report:
The evidence in the NPS shows that a Northwest Runway (NWR) scheme could have a seriously damaging effect on communities living under and adjacent to flight-paths. Until actual flights paths are known the actual noise distributions resulting from the NWR scheme cannot be known. We believe that the approach taken by the Department for Transport has resulted in an analysis that tends towards the lower end of the range of possible noise impacts. It is right that Parliament and the public have a fair view of the range of possible noise impacts from a NWR scheme.
We recommend the noise modelling be updated to reflect a range of possible flight-path scenarios. e results from this modelling should also be presented using a range of metrics and across the full range of thresholds recommended in the latest guidance. We believe it would be helpful if the Department for Transport published the evidence base supporting their assumptions about future fleet mix.
Full report at
The section of the Transport Committee report on costs and economic benefit is copied below:
Economic case 23.
The DfT’s appraisal shows little separates the economic cases of the three schemes. The economic benefits over the appraisal period are now marginally in Gatwick’s favour, which is forecast to deliver £74.1 billion in gross benefits; compared with a Heathrow NWR at £72.8 billion and £61.7 billion with a ENR.50 [Footnote 50 These figures are for the lower range presented in the DfT’s appraisal. We also recognise the point made by the ENR scheme proponents about their ability to deliver a high capacity than is assumed in the appraisal. This is addressed later in the report.]
Once costs are considered, the net economic benefits for the NWR scheme are relatively small at a maximum of £3.3 billion over 60 years and in fact, may be negative if future demand falls.51 [Footnote 51 Department for Transport, Updated Appraisal Report—Airport Capacity in the South-East, October 2017]
The net economic benefits for the other schemes are also relatively small. The draft NPS does not reflect the DfT’s appraisal stating simply that “ … overall the Heathrow NWR scheme is considered to deliver the greatest net benefits to the UK.”52 [Footnote 52 Department for Transport, Revised Draft Airports National Policy Statement, p 32 ]
24. The balance of economic costs and benefits is sensitive to the methodologies and assumptions employed in the appraisal. The DfT and the Secretary of State insisted they had taken a conservative approach in their appraisal.53 [Footnote53 Qq466–67, Qq476–77, Q488, Q500, Q503, Qq505–06, Q512, Q565, Q568, Q575]
We have identified several factors in the appraisal that could increase the risk of a successful legal challenge at a later stage of the planning process. These should be corrected or clarified before the NPS is designated:
• The DfT assumed new capacity at a NWR would fill-up within two-years of opening in 2026. Several witnesses considered this to be a highly optimistic assumption. For example, the airlines considered the mobilisation of new aircraft and crew within that timeframe as unrealistic.54
It is also opposed to HAL’s own commercial plans.55 If the forecasts were developed according to a more realistic profile of growth, the present value passenger benefits by the scheme would be reduced.56
• The modelling also assumes that Gatwick, even with a second runway, will continue operating as a point-to-point airport, with limited long-haul connectivity. Gatwick Airport, which had 11 daily long-haul routes in 2016, is forecast to see a decline in daily long-haul routes to 7 in 2030 with a second runway and will not recover to its 2016 levels until the end of the appraisal period. This is inconsistent with recent growth in long-haul connectivity at Gatwick with a capacity constrained single runway.57 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/674749/uk-aviation-forecasts-2017.pdf Other UK airports expressed concern about the accuracy of the forecasts as they related to their airports.58 [Footnote 58 Q 126 http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/transport-committee/airports-national-policy-statement/oral/76066.pdf ]
• We acknowledge the concerns expressed by the proponents of the ENR scheme that the appraisal has been completed assuming a capacity lower than they believe their scheme can deliver.59 [Footnote 59 Heathrow Hub Ltd (NPS0087) http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/transport-committee/airports-national-policy-statement/written/78344.pdf ] We do not have the technical expertise to make a formal judgement on whether the 740,000 movements for the ENR scheme are viable but we are concerned by what we have heard and the absence of a proper justification from the DfT.
• The NPS states that “in monetary terms, the environmental impacts of all three schemes are small when compared to the size of the benefits, or considered over the 60-year appraisal period.”60 [Footnote 60 Department for Transport Revised Draft Airports National Policy Statement, p 28 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/654123/revised-draft-airports-nps-web-version.pdf ]
We are concerned that this only appears to be the case because the methods used by the DfT appear to underestimate these environmental costs. The full detail of these estimates is outlined later in report and in the annexes. It is beyond the scope and capability of the Committee to estimate the precise impact this could have on the economic case. Indicatively, several billion pounds of environmental costs have been omitted from the appraisal.61
25. The benefits and costs the NWR scheme are finely balanced. Even small changes in assumptions or methodology could mean that the monetised costs of expansion via a NWR would outweigh the benefits. There are wider economic benefits that are not monetised as part of the economic case and need to be considered; equally there are several other environmental and social costs that are not monetised and are only assessed qualitatively, including loss of community and quality of life for nearby residents.
54 See Annex A for discussion.
56 See Annex B for discussion.
57 Department for Transport, Aviation Forecasts, October 2017 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/674749/uk-aviation-forecasts-2017.pdf
59 Heathrow Hub Ltd (NPS0087)
60 Department for Transport Revised Draft Airports National Policy Statement, p 28
61 See Annexes F, H and I for full detail on these monetised environmental costs.]
26. Perhaps the greatest factor affecting the economic case is deliverability. We were told about several factors that might prevent the delivery of a NWR scheme, including:
• the scale and complexity of the scheme and associated capital expenditure and financing requirements;
• property and infrastructure acquisition and relocation on a significant scale;
• hurdles in reaching agreement on scope and funding of surface access schemes;
• the lack of a safety case and uncertainties around implementing the complex and politically challenging airspace changes; and
• potential legal challenges, particularly on the grounds of air quality compliance.62 [Footnote 62 For full discussion, see Annex D ]
27. The economic case of the NWR scheme is grounded on it being delivered by 2026 and at capacity by 2028. These are essential considerations. If the NWR cannot be delivered to the capacity and timeline assumed, because of, say, airfield design pinch points or planning issues, there will be considerable knock on effects to the economic business case of the scheme.63 [Footnote 63 Airports Commission, Business Case and Sustainability Assessment, July 2015 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/440315/business-case-and-sustainability-assessment.pdf ]A two-year delay to the scheme’s delivery would result in £16.3 billion of benefits being removed from the economic case.64 [Footnote 64 Department for Transport, Further Review and Sensitivities Report, October 2016 https://hopuk.sharepoint.com/sites/hcc-Transport/Papers/Further%20Review%20and%20Sensitivities%20Report ] Similarly, there are significant economic costs from not proceeding at this point with the NWR scheme. In making its decision, Parliament needs to consider these opportunity costs, such as additional demand moving to competitor airports in other countries.