The Airports Commission had, as its study area for the effects of Heathrow expansion, an area of just 2 kilometres from the boundary of the expanded airport. Chris Grayling wrote to the Chair of the Transport Committee on the 23rd February 2018 saying that this area “captures over 98% of additional emissions that could occur from expansion”. Teddington TAG asks if this figure of 98% emissions captured within 2 km of the boundary is true. They located air pollution data from the London Assembly, available by Borough. It apportions how much of the NOx in different areas is from vehicles, aviation and other sources. This shows that in Richmond Old Deer Park, according to the Data Apportionment Tool, about 77% of the NOx is from aviation. In Kew / North Sheen, 11km from touch-down, about 57% is from aviation. At Putney, which is under the flight path but is over 15 km from touch-down at Heathrow, about 33% of the NOx is from aviation. Putney is worse off than Kew as total emissions are greater. And all that is just from 2 runways! Aviation apportionment readings stretch back to Clapham Junction and beyond. So why did Grayling tell the Transport Committee that 98% was within 2km. Ignorance of the facts? Failure to be properly informed?
WILL HEALTH EFFECTS FROM EMISSIONS FROM HEATHROW EXPANSION BE FELT JUST WITHIN 2 KILOMETRES?
13TH OCTOBER 2018 (From Teddington Action Group)
The Airports Commission had as its study area, for the effects of Heathrow expansion, an area of just 2 kilometres from the boundary of the expanded airport. Chris Grayling wrote to the chair person of the Transport Committee on the 23rd February 2018 letter here saying that: “The DfT’s approach assessed the health impacts on populations living within 2km of the expanded airport using updated relationships between pollutant concentrations and mortality, published by DEFRA …………..The study area, which captures over 98% of additional emissions that could occur from expansion, was determined by the Airports Commission’s consultants to include those locations where expansion was expected to make a significant contribution to ambient pollution levels”Is this figure of 98% emissions capture within 2 km of the boundary true or false?Well; the London Assembly have collated a lot of air quality data, which has been in the public domain for some years. King’s College London have been instrumental in collating much air quality data. The data is available by Borough and as an “apportionment tool” to tell us the relevant sources (including aviation) of pollution at any spot in the greater London area. The website is athttps://data.london.gov.uk/dataset/llaqm-bespoke-borough-by-borough-air-quality-modelling-and-data?resource=e770d524-dd30-46db-bc2e-e8c4da8902a4Go into Richmond Old Deer Park and you might think that the majority of NOx there is from nasty smelly diesel lorries roaring down the A316 to the M3. You would be wrong. According to the Data Apportionment Tool, no less than 77.7% of NOx in Richmond Old Deer Park by the side of the A316 comes from aviation. So; let’s go a bit further away from Heathrow and see what happens:
Let us go to Kew / North Sheen, 11km from touch-down and look forward to 2020:
Put the co-ordinates into the tool and:
We are shown that 57.7% of NOx comes from aviation. There is a pie chart too:
The legal limit is an annual mean of 40 micrograms per cubic metre. There is a NOx map:
and a map of NO2 only
which show that in 2020 there will be areas particularly close to the roads that will breach the legal limits. That is with two runways at Heathrow and 57% of the NOx coming from aviation.
Let us go further away to Putney, which is under the flight path but is over 15 kilometres from touch-down at Heathrow:
Put in the co-ordinates to the calculation tool and:
We find that aviation is still contributing to 33% of the NOx emissions. Putney is worse off than Kew though because total emissions are greater and therefore the breaches are more severe. The total emissions, of which aviation contributes 33%, is bigger. The NO2 map is:
and the NOx map is:
Heathrow itself is way over the permitted limits and is predicted to be so in 2020 and 2030.
The 2020 map:
and the 2030 map is only a little better:
And all that is just from two runways!
Aviation apportionment readings stretch back to Clapham Junction and beyond
So Mr Grayling: why are you telling us and the Transport Committee that 98% of emissions from an expanded Heathrow would be captured within 2 kilometres of the airport boundary?
Grayling emissions omission admission: Heathrow air quality costs 2-4 times higher than previously thought
March 7, 2018
The Commons Transport Committee is currently assessing the Heathrow proposals for a 3rd runway. One of the issues in which they have taken a particular interest is whether the right numbers have been used for the cost to human health of air pollution, and if the costs of pollution beyond a 2km band around the airport have been properly considered. Chris Grayling, Transport Secretary, has now written to the Committee to clarify the government position, and has confirmed that the DfT omitted (in error) to consider the emissions beyond 2km. By contrast the DfT’s own impact appraisal had noted impacts well beyond this 2km boundary, in terms of additional vehicle traffic. The total figure for the extra cost to health, from Grayling’s admission, is now thought to be 2 to 4 times higher than the one published in the official appraisal document. That means the “net present value” of the scheme, previously assessed as minus £-2.2 to plus £3.3 billion over 60 years (so already potentially negative) could drop to as low as minus £-2.6 to plus £2.9 billion under the new estimate. The cost of the damage to human health from additional air pollution, associated with a new runway, is one of the two ways the DfT assesses the cost-benefit analysis of the proposal.
The Stay Grounded network has been officially launched. It now has over 130 signatories (including the No 3rd Runway Coalition, and others in the UK) and more than 80 member organisations. Stay Grounded aims to reduce the environmentally and socially damaging impact of aviation, by stopping its fast rate of expansion across the world. The industry has privileged status in many ways, including its out-of-control increasing carbon emissions. The Stay Grounded network has published a position paper outlining 13 steps for a transition towards a transport system that is more socially just and ecologically sustainable. Many non-violent actions took place in countries around the world, in a recent week of action. These were directed against airport infrastructure projects, many of them leading not only to rising CO2 emissions, but also noise and health issues, loss of homes, biodiversity and fertile lands. Around the world there are about 1200 airports planned to be built or being expanded. Stay grounded will also highlight the industry’s inadequate “greenwashing” strategies, which will lead to increasing pressure on ecosystems, local farming communities, and indigenous peoples, particularly in the Global South.
In the week of action, a total of 27 actions took place in 11 countries (3 continents) to counter airport expansion and to demand a just transport system. There is a video here and more on Facebook, Twitter
There are photos of theactions here. Stay Grounded is working to spread information and understanding about the illusion of “green growth” for the aviation sector. The movement needs to build pressure on our politicians, across countries, to cut the privileges of the aviation industry.
Press Release: Stay Grounded international network launched to counter aviation
1st-12th October – 2 weeks of protest events to be held around the world
Contact: Magdalena Heuwieser & Mira Kapfinger / coordinators of Stay Grounded
1st October 2018 – This week marks the official launch of Stay Grounded, a global network of organisations and activist groups working to curb the unrestrained expansion of the aviation sector that is causing ever increasing damage to the climate and local residents. Supported by more than 100 civil society organisations, like Friends of the Earth International, the network has published a position paper outlining 13 steps for a transition towards a transport system that is more socially just and ecologically sustainable.
The Stay Grounded network will organise protest events around the world in the coming two weeks to raise awareness of the ongoing massive wave of airport infrastructure expansion: They will take place in Denmark, the UK, Mexico, the Netherlands, Austria, Australia, the Philippines, Thailand, Belgium, Germany, Indonesia, Brazil, France and New Zealand.
“The actions are directed against airport infrastructure projects, many of them leading to noise and health issues, loss of homes, biodiversity and fertile lands”, explains Mira Kapfinger from Stay Grounded, pointing out a map of airport conflicts. Around the world, about 1200 airports are planned to be built or being expanded. The protests will also throw a spotlight on the industry’s inadequate “greenwashing” strategies, which will lead to increasing pressure on ecosystems, peasant communities, and indigenous peoples, particularly in the Global South.
Aviation Emissions and Greenwashed Climate Strategies The protests are just in time: At the end of October, International Aviation will decide on its climate strategy called CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation). It proclaims the goal to achieve “carbon neutral growth” after 2020 by buying cheap and ineffective carbon credits from offset projects in the Global South. These supposedly “green” projects have a record of fuelling land grabbing and human rights violations.
“Instead of assuming responsibility for the harmful impact of its reckless growth path, the industry is trying to buy its way out at the expense of vulnerable populations who are at risk of losing their livelihoods due to these offsetting projects”, Mira Kapfinger adds.
“CORSIA is not only a greenwashed cloth attempting to polish aviation. It is also being used as a diversion tactic to block any effective regulation of the sector”, explains Magdalena Heuwieser from Stay Grounded. The European aviation industry is recently trying to lobby EU officials to abolish existing regulation of aviation emissions, like the EU Emissions Trading Scheme and ticket taxes, by pointing to an alleged overlap with CORSIA.
Mira Kapfinger from Stay Grounded said: “This year’s summer of record temperatures, droughts and forest fires, has been another warning sign that it is now most urgent for us all to resist the growing greenhouse gas emissions from aviation.” Aviation is by far the mode of transport with the biggest climate impact, as well as being one of the fastest growing sectors in terms of greenhouse gas emissions.
Stay Grounded demands effective regulations on aviation
Stay Grounded rejects greenwashed aviation strategies like CORSIA, carbon trading and tanked biofuels and instead fosters effective solutions to the climate crisis and rising aviation emissions. “For decades, the aviation industry has enjoyed many privileges. For example, flight tickets and kerosene still remain untaxed, in contrast to car fuel or train tickets. Now is the time to wake up. “Techno-fixes” and offsets are illusions. Rather than fueling further expansion, air traffic urgently needs to be controlled and reduced, before we get locked in to their unaffordable emissions. This process needs to be socially just,” Mira Kapfinger concludes.
Stay Grounded will send their position paper together with an introductory letter to the ICAO (International Civil Aviation Organisation) on October 26th, just before the start of their next Council meeting. In this meeting they will decide on the criteria for carbon offsets and biofuels – the main pillars of the international climate strategy CORSIA, and hugely dangerous because they don’t help fight climate change and push land grabbing. Find more information on the current international policy debates and problems involved in this article and in the study “The Illusion of Green Flying” (GE, EN, FR).
Stay Grounded is encouraging people and organisations to write to their environment, climate change and transport ministries, asking that they make public their reservations about the ICAO CORSIA scheme, (which is a token scheme to give the impression of cutting aviation carbon emissions, while in reality doing the least possible, and not having an effective impact on aviation CO2 for decades). Letters should be sent before 1st December. Though it is unlikely that the CORSIA scheme will be stopped, or made effective, it is important that EU states express their concerns about CORSIA so it does not lead to the EU ETS regulation being stopped, and replaced by the (ineffective) CORSIA. Find here the contact details of EU ministers and a new CORSIA briefing by Transport & Environment, and find here some bullet points that can be used for your letter.
Research published in the BMJ indicates there is an increase in the chance of developing dementia. About 131,000 patients in London aged between 50 and 79 were followed for 7 years, with air pollution exposure estimated by post code. People over 50 in areas with the highest levels of nitrogen dioxide (NO2) in the air showed a 40% greater risk of developing dementia than those with the least NOx pollution, according to data from London. The observational study cannot establish that air pollution was a direct cause of the dementia cases, but the link between higher pollution and higher levels of dementia diagnosis could not be explained by other factors known to raise risks of the disease. Air pollution has already been linked with cardiovascular and respiratory disease, but this is one of the first studies to examine links with neurodegenerative illness. It is possible that perhaps 60,000 of the total 850,000 dementia cases in the UK may be made worse by air pollution. This adds to the body of research on the wide-ranging effects of air pollution, including evidence that particles of pollutants can cross the placenta – an evidence from China of a “huge” reduction in intelligence associated with breathing dirty air, equivalent to losing a year’s education.
If the UK government lets the 3rd Heathrow runway go ahead, it is almost inevitable that there will be far worse air pollution over a wide area – around the airport, and also near roads and flight paths used by Heathrow.
Duty of government is to protect its citizens – not condemn tens or hundreds of thousands of them to an incurable illness, that removes individuals’ abilities to live decent lives, causes immense suffering, and also imposes immense costs on society.
Air pollution may increase the chance of developing dementia, a study has suggested, in fresh evidence that the health of people of all ages is at risk from breathing dirty air.
People over 50 in areas with the highest levels of nitrogen oxide in the air showed a 40% greater risk of developing dementia than those with the least NOx pollution, according to the research, based on data from London.
The observational study, published in the BMJ Open journal on Wednesday, cannot establish that air pollution was a direct cause of the dementia cases. However, the authors said the link between higher pollution and higher levels of dementia diagnosis could not be explained by other factors known to raise risks of the disease.
The Kings College London study adds to previous research suggesting a link with dementia, but scientists warned that the results must be taken cautiously because the observational study could not closely track other possible causes such as lifestyle factors or the relative economic deprivation of the patients studied, or the amount of air pollution each was subject to individually.
Martie Van Tongeren, a professor of occupational and environmental health at Manchester University, who was not involved, said: “There is a growing body of evidence of the link between air pollution and brain health, including dementia and Alzheimer’s. This study adds to this body of evidence and fits with some of the previous studies. As most people in the UK live in urban areas, exposure to traffic-related and other air pollutants is ubiquitous. Hence, even a relatively small increase in risk will result in a large public health impact.”
The paper’s authors said a link between poor air quality and dementia could begin early in life. They wrote: “Traffic related air pollution has been [linked to] poorer cognitive development in young children, and continued significant exposure may produce neuroinflammation and altered brain innate immune responses in early adulthood.”
Campaigners called on the government to take urgent action on air pollution. Simon Alcock, head of UK public affairs for ClientEarth, which has repeatedly taken the government to court over its failures on air quality, called for a national clean air bill backed by an independent watchdog, and clean air zones in the most polluted areas. He said: “Air pollution is damaging our health from the womb to old age. It is unacceptable in 2018 for people to be risking dementia just by breathing.”
Road traffic should be the focus of efforts to clean up our air, as it is the leading cause of the health problems, added Aaron Kiely, air pollution campaigner at Friends of the Earth. “Efforts to clean up our cars, vans and lorries must be put in the fast lane – we can’t afford to wait until 2040 for most new vehicles to be zero-emission,” he said. “Greater investment is also needed in alternatives to motor vehicles, such as safer cycling infrastructure, and affordable and convenient public transport.”
A Defra spokesperson said levels of air pollution, including NOx, had fallen and the government was taking further action: “By ending the sale of conventional new diesel and petrol cars and vans by 2040, we are acting faster to tackle air pollution than almost every other major developed economy.”
Labour slammed ministers for failing to address air pollution, which regularly exceeds legal limits in many areas, particularly in London.
Sue Hayman, shadow environment secretary, said: “It is simply not good enough for Michael Gove to shunt this problem on to cash-strapped local councils, publish strategies on wood burners and drag his feet on new legislation. [We] would bring forward a new Clean Air Act and a network of clean air zones to tackle the UK’s illegal levels of air pollution in the quickest time possible.”
Scientists have found the first evidence that particles of air pollution travel through pregnant women’s lungs and lodge in their placentas. Toxic air is already strongly linked to harm in foetuses but how the damage is done is unknown. The new study, involving mothers living in London, UK, revealed sooty particles in the placentas of each of their babies and researchers say it is quite possible the particles entered the foetuses too. A series of previous studies have shown that air pollution significantly increases the risk of premature birth and of low birth weight, leading to lifelong damage to health. A large study of more than 500,000 births in London, published in December, confirmed the link and led doctors to say that the implications for many millions of women in polluted cities around the world are “something approaching a public health catastrophe”. Scientists are increasingly finding that air pollution results in health problems far beyond the lungs. In August, research revealed that air pollution causes a “huge” reduction in intelligence, while in 2016 toxic nanoparticles from air pollution were discovered in human brains.
Scientists have found the first evidence that particles of air pollution travel through pregnant women’s lungs and lodge in their placentas.
Toxic air is already strongly linked to harm in foetuses but how the damage is done is unknown. The new study, involving mothers living in London, UK, revealed sooty particles in the placentas of each of their babies and researchers say it is quite possible the particles entered the foetuses too.
“It is a worrying problem – there is a massive association between air pollution a mother breathes in and the effect it has on the foetus,” said Dr Lisa Miyashita, at Queen Mary University of London, one of the research team. “It is always good if possible to take less polluted routes if you are pregnant – or indeed if you are not pregnant. I avoid busy roads when I walk to the station.”
A series of previous studies have shown that air pollution significantly increases the risk of premature birth and of low birth weight, leading to lifelong damage to health. A large study of more than 500,000 births in London, published in December, confirmed the link and led doctors to say that the implications for many millions of women in polluted cities around the world are “something approaching a public health catastrophe”.
The new research examined the placentas of five non-smoking women who all delivered healthy babies. The researchers isolated macrophage cells, which are part of the body’s immune system and engulf harmful particles such as bacteria and air pollution.
Using an optical microscope, they found 72 dark particles among 3,500 cells and then used a powerful electron microscope to examine the shape of some of the particles. They looked very like the sooty particles found in macrophages in the lung, which catch many – but not all – of the particles.
While further analysis is needed for final confirmation, Dr Miyashita said: “We can’t think of anything else they could be. It is very evident to us they are black sooty particles.” Earlier experiments have shown that particles breathed in by pregnant animals go through the bloodstream into placentas.
“We do not know whether the particles we found could also move across into the foetus, but our evidence suggests this is indeed possible,” said Dr Norrice Liu, also at Queen Mary University of London and part of the team. “We also know that the particles do not need to get into the baby’s body to have an adverse effect, because if they have an effect on the placenta, this will have a direct impact on the foetus.”
The research is being presented Sunday at the European Respiratory Society’s (ERS) international congress in Paris. “This research suggests a possible mechanism of how babies are affected by pollution while being theoretically protected in the womb,” said Prof Mina Gaga, who is ERS president and at the Athens Chest Hospital in Greece.
Unicef executive director Anthony Lake recently warned of the danger of air pollution to babies: “Not only do pollutants harm babies’ developing lungs, they can permanently damage their developing brains – and, thus, their futures.”
Separate research, also presented at the ERS congress, found that children with early onset and persistent asthma fared far less well in education than those without the condition. Asthma in children has long been linked to air pollution.
The study, conducted over 20 years in Sweden, showed that children with asthma were three and half times more likely to leave school at the age of 16 with only basic education and were also twice as likely to drop out of university courses.
Dr Christian Schyllert, at the Karolinska University Hospital in Stockholm, said: “This study suggests [these] children have worse life chances when it comes to their education and their future jobs.” He said one possible reason could be that children with asthma are known to have lower school attendance.
There is a widely held belief that Heathrow’s NO2 air pollution is largely due to road vehicles, and as long as measures can be taken to reduce these a bit, then a 3rd runway could be allowed. However, research indicates that the aircraft are producing even more NOx than the road vehicles, and there is far less that can be done to cut these emissions. Indeed, if there were to be almost 50% more Heathrow flights, the amount of NOx generated by the aircraft alone would mean a massive increase locally. That is not taking into account all the extra road traffic that would inevitably be generated by a larger Heathrow, including businesses etc that locate near the airport and all their traffic. The 2013 figures from a study for Heathrow, by Ricardo-AEA Ltd show the amount of NOx emitted from planes up to 1000 metres altitude was 2761 tonnes NOx/ year, and 1524 tonnes from aircraft on the ground (ie a total of 4285 tonnes/ year). Also 274 tonnes/year from other airport sources. Then 350 tonnes/year from Heathrow associated trips on main roads in a 11km x 11km area, and 1661 tonnes/ year from non-Heathrow associated traffic in that 11x11km area. (ie. a total of 2011 for all road traffic). So the amount from planes is way over twice the amount from road vehicles. And that ignores the NOx from planes in the wider area, over 1000 metres altitude.
There is a lot of detail in the paper, but below are a couple of quotes.
This report presents an assessment of air quality in the neighbourhood of Heathrow Airport in the year 2013.
It considers the impacts of the operation of the airport (including road traffic to and from the airport), as well as non-airport sources of air pollution, in order to estimate both the overall picture of air quality and the airport’s contribution to it.
Broadly speaking, near Heathrow there are three main categories of air pollution:
Road traffic, some of which will be travelling to or from the airport;
Heathrow Airport itself, especially aircraft engines and the ground support vehicles and equipment that service the aircraft;
Other sources both local and more distant, such as domestic and commercial heating, industrial processes, and other vehicles and equipment powered by combustion engines. The study was designed with these purposes in mind. The work falls into three main parts:
First, an emissions inventory is calculated to estimate how much of each pollutant is emitted from the different sources.
Second, dispersion modelling calculates how the emissions are carried through the air, due to meteorological conditions such as wind speed and direction, and the resulting concentrations of pollution in the air.
These modelled concentrations are then compared with monitoring data as a check on the accuracy of the model.
The final total concentrations are also compared with the air quality limit values to see if there is a risk of them being exceeded.
They conclude on NOx:
Aircraft make a dominant contribution to the airport NOx emissions. It should be borne in mind that this is for aircraft emissions in the LTO cycle (so cruise emissions are excluded because they have no impact on local air quality), and road network emissions are presented only on major roads within the 11 km × 11 km area around the airport. Choosing a larger road network area would change the balance of calculated emissions.
On PM10 particles :
Focusing on airport-related sources, emissions from airport-related traffic on the road network are roughly equal to aircraft emissions, in contrast to NOx where aircraft emissions were dominant. However it should be repeated that choosing a different road network area would change the balance of calculated emissions.
A group of local authorities has formally notified the Secretary of State for Transport that it intends to seek judicial review of the Government’s decision to give policy support in the Airports National Policy Statement (‘NPS’) for a 3rd Heathrow runway. The councils are challenging the Government on the grounds of air quality, climate change, and strategic environmental assessment (SEA) including failing properly to deal with the noise consequences and surface access impacts. On air quality they say, amongst other things, that the Government has misunderstood and misapplied the law on air quality. On surface access the councils say, amongst other things, that the NPS fails to recognise the scale of the challenge to accommodate additional trips without unacceptable effects on the transport network and unacceptable effects from traffic pollution. The Government must now respond to the councils’ formal letter before action. If the Transport Secretary does not agree to quash the NPS, the local authorities will bring judicial review proceedings.The Boroughs taking the legal action are Hillingdon, Wandsworth, Richmond, Windsor & Maidenhead Council, and Hammersmith & Fulham.The group has also been joined by the Mayor of London and Greenpeace.
Councils set for court challenge on Heathrow decision
19 July 2018 (Richmond Council)
A group of local authorities has today formally notified the Secretary of State for Transport that it intends to seek judicial review of the Government’s decision to give policy support in the Airports National Policy Statement (‘NPS’) for a third Heathrow runway.
The councils are challenging the Government on the grounds of air quality, climate change, strategic environmental assessment including failing properly to deal with the noise consequences and surface access impacts.
On air quality they say, amongst other things, that the Government has misunderstood and misapplied the law on air quality.
On surface access the councils say, amongst other things, that the NPS fails to recognise the scale of the challenge to accommodate additional trips without unacceptable effects on the transport network and unacceptable effects from traffic pollution.
Councillor Gareth Roberts, Leader of Richmond Council, said:
“The Government has misunderstood and misapplied the law on air quality despite having been taken to court and lost many times. Its decision in favour of the third runway should therefore be quashed.”
Councillor Ravi Govindia, Leader of Wandsworth Council, added:
“The councils have shown extraordinary patience. We have given the Government numerous opportunities to address our concerns and answer our questions. All the evidence shows that a new Heathrow runway will be bad for the environment in our boroughs and bad for the health of our residents.”
The Government must now respond to the councils’ formal letter before action. If the Transport Secretary does not agree to a quashing of the NPS, then the local authorities will bring judicial review proceedings.
The local authority group comprises of the London Boroughs of Hillingdon, Wandsworth, Richmond, Windsor and Maidenhead Council, and Hammersmith and Fulham.
The group has also been joined by the Mayor of London and Greenpeace.
Councils, Sadiq Khan and Greenpeace to legally challenge decision on Heathrow Airport Expansion
Hillingdon, Hammersmith & Fulham, Richmond and Wandsworth councils are all part of the legal challenge
By Qasim Peracha (Get West London)
19 JUL 2018
A group of councils, the Mayor of London and Greenpeace have formally notified the government of their plans to challenge Heathrow expansion in the courts.
The Airports National Policy Statement, which includes the approval of the plan to build a third north-west runway at Heathrow Airport was voted on by MPs on June 25.
However, several local groups and environmental charities were opposed to the scheme, including Hillingdon Council and Hammersmith & Fulham Council .
A coalition of the councils, environmental pressure group Greenpeace and Sadiq Khan are now going to seek a judicial review of the government’s decision to back Heathrow as the site for airport expansion in the south-east.
Heathrow had been selected by the government as its preferred choice for expansion in October 2016, ahead of rival bids from other airports including Gatwick.
The coalition is proposing its challenge on the grounds of air quality, climate change and strategic environmental assessment including failing properly to deal with the noise consequences and surface access impacts.
They also allege that the government misunderstood and misapplied the law when it comes to air quality. On surface access, they argue that it is impossible to accommodate additional traffic movements “without unacceptable effects on the transport network and unacceptable effects from traffic pollution”.
Councillor Ray Puddifoot , Leader of Hillingdon Council, said: “We have given the Government numerous opportunities to address our concerns and answer our questions and they have demonstrably failed to do so.
“The Government has misunderstood and misapplied the law on air quality, despite having already lost recent legal challenges on this issue.
“The evidence of unacceptable damage to the environment and the health and wellbeing of many thousands of people is untenable in both law and common sense.”
The only way for the government to avoid legal action on its NPS statement is to quash its policy, the coalition warned.
Other members of the group include Wandsworth and Richmond councils.
Paul McGuinness, Chair of the No 3rd Runway Coalition, said: “London’s determination to kill off this environmentally ruinous and highly disruptive scheme is growing, so it’s no surprise that the Mayor has joined the cross-party group of councils in their legal action.
“With the confidence of their lawyers high, the courts could be ruling out the third runway, once and for all, long before Heathrow have even had a chance to launch their campaign for a fourth”.
A Heathrow spokesperson said: “We will support the Department for Transport in its response.
“We are confident in the process that has taken place so far, meaning that legal challenges are unlikely to be successful: the Airports National Policy Statement is supported by extensive evidence prepared by both the Department for Transport and the Airports Commission and has been subject to multiple rounds of public consultation and Parliamentary scrutiny.
“Judicial reviews are a completely normal process in infrastructure projects of this size and our work on our planning application continues, to ensure the timeline for the delivery of an expanded Heathrow is not affected.”
Legal challenges against Heathrow runway plans – first chance for proper assessment of the NPS details – plans delay inevitable
Date added: July 21, 2018
Although MPs voted to back the Heathrow 3rd runway, lawyers say legal challenges are likely to substantially delay – by at least a year – the start of construction, even if they cannot prevent it. As well as the legal challenge by 5 London councils, and the Mayor of London, that has now started, there will be one by “Heathrow Hub”, the rival runway scheme. The challenges will go to the High Court and could take up to 6 months. The losing party could then appeal to the Court of Appeal, and even if they lose there, they could then appeal to the Supreme Court. The legal process is the first opportunity for Heathrow expansion opponents to take the proposal for a 3rd runway to the High Court, and have all the issues properly assessed – not merely depending on information provided by and for the Department for Transport. There will also be a second opportunity to challenge the plans after the development consent order (DCO) is completed. Under the current plans, Heathrow intends to lodge its development consent order with the secretary of state in 2021, ahead of a 2025 completion date – but that could be delayed due to the legal challenges. Then there must be a General Election by 2022, which Labour might win – with no guarantee they would not oppose the runway plans.
Hillingdon, Wandsworth, Windsor &Maidenhead, and Richmond Councils have accused the government of misleading MPs on the Heathrow runway plans (the Airports NPS). They say the government has only incorporated 3 out of 25 of the recommendations by the Transport Select Committee (TSC) recommendations into the final NPS, while trying to give the impression it has taken far more account of them. Chris Grayling told the Commons (5th June) that 24 of the 25 recommendations had been “acted upon” and that expansion at Heathrow had been agreed by the Cabinet. The 4 councils are calling on Mr Grayling to return to Parliament and explain to MPs why the TSC advice has been brushed aside. The Councils need to see a definition of an acceptable maximum number of people newly exposed to plane noise, by a 3rd runway. Among their demands, they want assurance that planning approval would only be granted if the target for no more airport-related traffic can be met. Also a more stringent interpretation of air quality compliance including ‘headroom’ to manage future increases in pollution – and clarity on how the requirement for 15% of new slots will be secured for domestic connections, rather than just warm, woolly wording.
Government accused of ignoring select committee recommendations in final Heathrow expansion policy
Hillingdon Council, alongside Wandsworth, Windsor and Maidenhead, and Richmond have accused the government of misleading MPs
By Qasim Peracha (Get West London)
9 JUNE 2018
A coalition of anti- Heathrow expansion councils have accused the government of only incorporating three out of 25 select committee recommendations in its Heathrow plan.
Hillingdon Council , alongside Wandsworth, Richmond , and Windsor and Maidenhead have been opposed to the third runway being added to Heathrow Airport and have in the past launched legal challenges against expansion.
Following the publication of the National Policy Statement on Airports, the councils have accused the government of not including recommendations made by the Transport Select Committee (TSC).
The coalition of councils say that of the 25 recommendations, the government omitted 22 in its final report published on Tuesday (June 5).
After the report was published, Transport Secretary Chris Grayling told the Commons 24 of the 25 recommendations had been “acted upon” and that expansion at Heathrow had been agreed by the cabinet.
The coalition is now calling on Mr Grayling to return to parliament and explain to MPs why, after months of scrutiny by the select committee, its recommendations were not included in the final National Policy Statement (NPS).
According to the councils, recommendations asking for a definition of an acceptable maximum number of people newly exposed to noise and for planning approval to be granted only if the target for no more airport-related traffic can be met are missing from the final statement.
A vote is due to be held in the coming days, where MPs will be given a final decision on expansion.
Transport Select Committee recommendations allegedly omitted by the government include:
more detail on the evidence on environmental, health and community impacts on all three short-listed schemes
updated population estimates to reflect the increased number of air traffic movements from a northwest runway scheme
a more stringent interpretation of air quality compliance including ‘headroom’ to manage future increases in pollution
planning approval to be granted only if the target for no more airport-related traffic can be met
a clear definition of how the requirement for 15 per cent of new slots will be secured for domestic connections
updated noise modelling to reflect a range of flightpath scenarios
a definition of an acceptable maximum number of people newly exposed to noise
a condition that planning consent would only be granted if the Secretary of State was satisfied that the scheme would avoid ‘significant adverse impacts on health and quality of life from air quality’.
Cllr Ray Puddifoot , leader of Hillingdon Council, said: “It is a disgrace that the government has failed to address the TSC’s significant concerns regarding exposure to noise and pollution in its final NPS report, showing little regard or protection for those people whose lives will affected by increased noise and air pollution from a third runway at Heathrow.
“There is not even any attempt to consider a range of different flight path options so that people could have some idea if they will be affected by Heathrow expansion, and for how long each day they will be subjected to aircraft noise.
“This once again demonstrates what a flawed and ill thought through project this is.”
The cabinet has given the go-ahead for a new third runway at Heathrow Airport (Image: PA)
However, the coalition has been attacked by pro-expansion group Back Heathrow, which said the councils were “disingenuous” and “at it again”.
Parmjit Dhanda, Back Heathrow executive director and former government minister under Gordon Brown, said: “The ink is barely dry on ballot papers and these four local councils are at it again.
“They have already wasted over a million pounds of tax-payers money over the last decade on legal challenges, when they could have spent it on local services.
“They are now shaping up to waste even more money on legal challenges if don’t get their own way when MPs vote on expansion in the coming days.
“We have now seen council leaders in Hillingdon, Richmond, Wandsworth and Maidenhead & Windsor putting out press releases that appear to be part of a ‘softening up exercise’ to spend even more of your money opposing a democratic decision, if Parliament backs a new runway.”
Back Heathrow Executive Chairman Parmjit Dhanda (left) with Ealing Southall MP Virendra Sharma at a pro-Heathrow reception (Image: Back Heathrow)
The group says it has the support of more than 100,000 residents who believe the airport’s expansion will bring jobs and prosperity to west London and the Thames Valley.
Mr Dhanda added: “The councils have been disingenuous on this. The government says it has accepted 24 out of 25 recommendations, but many of these recommendations will be incorporated in to the planning stage of the process and that includes important measures on air quality and noise.
“The councils haven’t said that, and are only looking to delay and confuse, which will ultimately delay creation of 77,000 jobs for local people.”
A Department for Transport spokesman said: “The committee was clear when they published their report that they accepted the need for airport expansion in the south east and that the Heathrow Northwest Runway scheme is the best option for delivering it. We have welcomed and have acted on 24 of their 25 recommendations.
“Where appropriate we have done this through amendments to the National Policy Statement. In other cases we have confirmed that these are issues best addressed later in the planning process, once detailed proposals are developed, or through the national Aviation Strategy, which we are taking forward this year.”
Comment by the AEF on the government’s attempt to ignore CO2 emissions due to Heathrow 3rd runway
Date added: June 9, 2018
In the final version of the NPS, together with updated versions of the draft of papers and analysis that accompany it, the DfT claims to have implemented 24 out of the 25 recommendations of the Transport Committee, which provided official parliamentary scrutiny of the proposals. But it is hard to spot much change in the final NPS than the earlier version – especially on the key environmental challenges to expansion. The AEF comments that the climate change impact of Heathrow expansion was not even mentioned in Grayling’s statement to the House of Commons. Yet the project is in fact no easier to reconcile with climate change targets now than it was in 2010, when a court ruled that it would be “untenable in law and common sense” for the Government to continue to uphold its policy to build a third runway without showing how this would be compatible with the climate change legislation passed in 2008. While current plans to achieve the Climate Change Act are built around an assumption that aviation emissions will be no higher than 37.5 Mt by 2050, with a 3rd Heathrow runway CO2 emissions nationally would be over 40 Mt, under the DfT’s policy of support for growth at other airports. The Government has just ignored the advice of the Committee on Climate Change.
The European Commission is stepping up its enforcement against 7 Member States who have breached agreed EU rules on air pollution limits. It has now referred France, Germany, Hungary, Italy, Romania and the UK to the Court of Justice of the EU for failing to respect agreed air quality limit values and for failing to take appropriate measures to keep exceedance periods as short as possible. The Commission is also issuing additional letters of formal notice to Germany, Italy, Luxembourg, and the United Kingdom on the grounds that they have disregarded EU vehicle type approval rules. On NO2 pollution the UK, in 16 air quality zones, among them London, Birmingham, Leeds, and Glasgow air pollution limits were exceeded (with annual concentrations reported in 2016 as high as 102 µg/m3 in London). In total, there are 13 NO2 level infringement cases pending against Austria, Belgium, the Czech Republic, Germany, Denmark, France, Spain, Hungary, Italy, Luxembourg, Poland, Portugal, and the UK. Today’s decision on Germany, France and the UK are the first ones to be referred to the Court. Suggestions to improve air quality are air quality standards, national emission reduction targets, and emission standards for key sources of pollution such as vehicles and industry.
Heathrow has a very serious problem with air pollution already, which would inevitably get worse with a 3rd runway, about 50% more planes, and about 50% more passengers getting to and from the airport, as well as staff, people working in allied businesses etc. Neither Heathrow nor the government has any real idea how to deal with this problem that a 3rd runway would cause.
Air quality: Commission takes action to protect citizens from air pollution
Brussels, 17 May 2018
The Commission is standing up for Europeans’ need to breathe clean air.
The Commission is providing national, regional and local actors with practical help to improve air quality in Europe, and stepping up its enforcement against 7 Member States who have breached agreed EU rules on air pollution limits and type approval for cars.
Commissioner for Environment, Karmenu Vella said: “The decision to refer Member States to the Court of Justice of the EU has been taken on behalf of Europeans. We have said that this Commission is one that protects. Our decision follows through on that claim.
“The Member States referred to the Court today have received sufficient ‘last chances’ over the last decade to improve the situation. It is my conviction that today’s decision will lead to improvements for citizens on a much quicker timescale. But legal action alone will not solve the problem. That is why we are outlining the practical help that the Commission can provide to the national authorities’ efforts to promote cleaner air for European cities and towns.”
Commissioner for the Internal Market, Industry, Entrepreneurship and SMEs Elżbieta Bieńkowska added: “We will only succeed in fighting urban air pollution if the car sector plays its part. Zero emissions cars are the future. Meanwhile, complying with emissions legislation is a must. Manufacturers that keep disregarding the law have to bear the consequences of their wrongdoing.”
In a Communication entitled ‘A Europe that protects: Clean air for all’, adopted today, the Commission outlines measures available to help Member States fight air pollution. The Commission also underlines the need to step up cooperation with Member States by engaging with relevant authorities in new ‘Clean Air Dialogues’, and by using EU funding to support measures to improve air quality.
In addition, the Commission is today referring France, Germany, Hungary, Italy, Romania and theUnited Kingdomto the Court of Justice of the EU for failing to respect agreed air quality limit values and for failing to take appropriate measures to keep exceedance periods as short as possible. The Commission is also issuing additional letters of formal notice to Germany, Italy, Luxembourg, and the United Kingdom on the grounds that they have disregarded EU vehicle type approval rules.
Measures to fight air pollution
The measures proposed by the Commission today rest on three main pillars: air quality standards; national emission reduction targets; and emission standards for key sources of pollution, for example from vehicle and ship emissions to energy and industry.
To address air pollutant emissions from traffic, the Commission will further strengthen its work with national, regional and local authorities on a common integrated approach for urban vehicle access regulations, under the EU Urban Agenda.
In addition, the Commission has led a wide-ranging reform to ensure that air pollutant emissions from vehicles are measured in real driving conditions (see FAQs).
Stepping up enforcement
6 Member States referred to Court
The Commission is taking action to address the significant and persistent exceedances of limit values for two key pollutants with health impacts: nitrogen dioxide, which is mostly a result of road traffic and industry, and particulate matter, which is mainly present in emissions from industry, domestic heating, traffic, and agriculture.
The Commission decided to refer France, Germany, and the United Kingdomto the Court of Justice of the EU for failure to respect limit values for nitrogen dioxide (NO2), and for failing to take appropriate measures to keep exceedance periods as short as possible. Hungary, Italy, and Romania are referred to the Court of Justice over persistently high levels of particulate matter (PM10). The limits set out under EU legislation on ambient air quality (Directive 2008/50/EC) had to be met in 2010 and 2005 respectively.
This step follows an Air Quality Ministerial Summit convened by Commissioner Vella, on 30 January 2018, as a final effort to find solutions to address the serious problem of air pollution in nine Member States. The 6 Member States in question did not present credible, effective and timely measures to reduce pollution, within the agreed limits and as soon as possible, as required under EU law. The Commission has therefore decided to proceed with legal action.
As regards the Czech Republic, Slovakia, and Spain the measures being put in place or planned, as communicated to the Commission following the Air Quality Ministerial Summit, appear to be able to appropriately tackle the identified gaps, if correctly implemented. For this reason the Commission will continue to closely monitor the implementation of these measures as well as their effectiveness in redressing the situation as soon as possible.
Infringement procedures escalated for 4 Member States
The Commission is taking further steps in its infringement procedures against 4 Member States on the grounds that they have disregarded EU vehicle type approval rules. The Commission decided today to issue additional letters of formal notice to Germany, Italy, Luxembourg, and the United Kingdom.
EU type-approval legislation requires Member States to have effective, proportionate and dissuasive penalty systems in place to deter car manufacturers from breaking the law. Where such a breach of law takes place, for example by using defeat devices to reduce the effectiveness of emission control systems, remedial measures – such as recalls – must be ordered and penalties must be applied (Articles 30 and 46 of Directive 2007/46 and Article 13 of Regulation 715/2007).
The Commission opened infringement proceedings against Germany, Luxembourg and the United Kingdomin December 2016 with regard to Volkswagen Group and sent complementary letters of formal notice in July 2017 requesting further clarifications.
Today, the Commission is sending additional letters of formal notice to request more information on the national investigations and legal proceedings related to these infringements. In addition, following the discovery of new cases of engine-management irregularities in several diesel cars (Porsche Cayenne, Volkswagen Touareg and several Audi A6 and A7 vehicles) the Commission asks Germany and Luxembourg, as the competent type-approval authorities, which remedial measures and penalties are envisaged. The Commission is also requesting clarifications from the United Kingdom on planned national legislation.
In May 2017, the Commission launched an infringement procedure against Italy for failure to fulfil its obligations under the EU vehicle type-approval legislation with regards to Fiat Chrysler cars. In the meantime, Italy took corrective measures by ordering the Fiat Chrysler Automobiles group to conduct a mandatory recall in the EU. Today, as part of the ongoing exchange, the Commission requests additional information on the concrete corrective measures taken and penalties applied.
An additional letter of formal notice constitutes an official request for information. The Member States now have two months to respond to the arguments put forward by the Commission; otherwise, the Commission may decide to send a reasoned opinion.
Nitrogen dioxide (NO2):
Germany – in 26 air quality zones, among them Berlin, Munich, Hamburg and Köln; annual concentrations reported in 2016 were as high as 82 µg/m3 against a limit value of 40 µg/m3 (in Stuttgart);
France – in 12 air quality zones, among them Paris, Marseille and Lyon; annual concentrations reported in 2016 were as high as 96 µg/m3 (in Paris); The United Kingdom– in 16 air quality zones, among them London, Birmingham, Leeds, and Glasgow; annual concentrations reported in 2016 were as high as 102 µg/m3 (in London).
In total, there are 13 infringement cases pending against Member States (Austria, Belgium, the Czech Republic, Germany, Denmark, France, Spain, Hungary, Italy, Luxembourg, Poland, Portugal, and the United Kingdom).
Today’s decision on Germany, France and the United Kingdom are the first ones to be referred to the Court; all three cases follow Reasoned Opinions communicated in February 2017.
Holidaymakers who drive to Heathrow could soon be hit with a congestion charge, as the airport needs to try to persuade tourists – those going on holiday or visiting friends and family – to leave their cars at home, in order not to make local air pollution any worse. Critics have said the proposed move is unfair because as much as 80 miles of roads, in the Heathrow vicinity, could be impacted. This would inevitably have a very negative impact on road users who are not associated with the airport, going about their usual activities. The level of the proposed charge is unknown – it would have to be quite high in order to sufficiently deter travellers, (up to £15 perhaps?) for whom air travel demand is “inelastic” ie. not much affected by price. Reacting to this proposal, Robert Barnstone, Coordinator of the No 3rd Runway Coalition, said: “This latest additional Heathrow charge simply highlights a critical problem with expanding Heathrow: air pollution targets would be so difficult to meet that the airport will have to whack travellers and families with a £15 charge for accessing the airport by car.” Without drastic measures to restrict road traffic in the areas, significantly worsened air pollution is likely – where limits are already regularly beached.
Transport for London (TfL) estimates perhaps a £50 fee per passenger car and taxi trip would be needed for the airport to meet its own promise that road journeys would not increase with expansion. ( Source – AEF – Aviation Environment Federation).
Drivers may face £15 Heathrow Airport congestion charge
By Steven Swinford, deputy political editor (Telegraph)
29 APRIL 2018
Heathrow may impose a £15 congestion charge on holidaymakers driving to the airport in a bid to meet emissions targets, The Telegraph has learned.
Motorists will face the charge on the 82 miles of road surrounding the airport in a bid to encourage millions of passengers to leave their cars at home.
The airport is consulting on plans for a “low emissions zone” which would charge all vehicles based on their emissions, but views it as a “last resort”.
However Whitehall sources said Chris Grayling, the Transport Secretary, believes it is the only realistic way that the airport can meet stringent emissions targets.
The third runway will accommodate 740,000 flights a year, about 50 per cent more than the current limit, with passenger numbers expected to almost double to 130million a year by 2050.
Increased traffic too and from Heathrow is seen as one of the biggest barriers to meeting emissions targets.
Pollution on the M4, north of the airport, is already up two thirds higher than the legal maximum.
Ministers believe that the airport will be able to meet the targets with the help of an increased number of public transport routes, including a new direct rail link from Reading and another south of the airport into Waterloo station.
A station for London’s east-west Crossrail line will also be opened, bus routes will be extended and more electric vehicles and car sharing clubs for airport staff will be promoted.
Ed King, President of the AA, said: “Many people go by car to the airport for good reason – they have heavy baggage and children with them. It’s not always practical to go by train or coach. For many people access by car is essential.
“We would be worried that this would be the thin end of the wedge and it could expand elsewhere. In effect the price of getting to the airport and parking might overtake the price of fares. It’s a crazy situation, particularly for families on low incomes.”
Tim Alderslade, chief executive of Airlines UK, the industry body representing UK-registered carriers including British Airways and Virgin Atlantic, said: “It is also not fair on passengers who have no other realistic way of travelling to the airport. Charging should not be introduced until all planned improvements to the public transport network have been completed.
“Investment in surface access should be the priority – not pricing people off the roads – and the Government should now come forward and use its upcoming National Policy Statement to set out which road and rail schemes it intends to support including much-needed clarity on the funding of these projects and an accompanying plan for delivery.”
A spokesman for Heathrow Airport said: “We have an ambitious plan to treble our rail capacity by 2040 and enable 30 million more passengers to use public transport.
“If needed, we have said a congestion charge could be another way to reduce road journeys and support our sustainable transport plans as part of our “triple lock” guarantee.”
Driving to Heathrow ‘could soon cost you an extra £15’ as congestion charge considered for 82 miles around airport
Critics have labelled the proposed move unfair as airport bosses weigh up how to meet emissions targets
By Dave Burke (Mirror)
30 APR 2018
Holidaymakers who drive to Heathrow could soon be hit with a congestion charge in a move branded ‘unfair’ by critics.
Airport bosses are considering the measure to try and persuade tourists to leave their cars at home and help meet strict emissions targets.
It has been reported that more than 80 miles of roads around the transport hub would be affected – but critics claim it would unfairly impact on passengers with no other way of reaching Heathrow.
According to reports, drivers could be hit with a £15 charge – but airport bosses say they “don’t recognise” this figure.
The move is currently considered a ‘last resort’, The Telegraph reports.
But the newspaper says Transport Secretary Chris Grayling is in favour of the low emissions zone, believing it is the only way to meet emissions targets.
Officials hope that improvements to rail links serving Heathrow, including a new Crossrail station which will link it with Berkshire and East London, will encourage more people to take the train instead of driving.
It comes amid concerns over pollution levels on the nearby M4, which is currently two thirds above the legal cap.
Tim Alderslade, chief executive of Airlines UK, the association of UK airlines, have branded it another tax on passengers.
In a statement he said: “Airlines remain opposed to what in effect will be another tax on air travel at a time when the Government continues to penalise passengers through sky-high levels of Air Passenger Duty, and passenger charges at Heathrow remain the highest in the world.
“It is also not fair on passengers who have no other realistic way of travelling to the airport.
He continued: “Investment in surface access should be the priority – not pricing people off the roads – and the Government should now come forward and use its upcoming National Policy Statement to set out which road and rail schemes it intends to support including much needed clarity on the funding of these projects and an accompanying plan for delivery.”
A Heathrow spokesman said this morning: “We don’t recognise the 82 miles or the £15 quoted.
“We have an ambitious plan to treble our rail capacity by 2040 and enable 30 million more passengers to use public transport.
“If needed, we have various options to apply emissions based charging to vehicles travelling to and from the airport – for example, using drop off charges based on vehicle emissions as other UK airports do – which could be another way to reduce road journeys and support our sustainable transport plans.”
Reacting to the news that Heathrow customers face a £15 car charge in order to tackle emissions targets, Robert Barnstone, Coordinator of the No 3rd Runway Coalition, said:
“This latest additional Heathrow charge simply highlights a critical problem with expanding Heathrow: pollution targets would be so difficult to meet that the airport will have to whack travellers and families with a £15 charge for accessing the airport by car.
“Public transport use must be strongly encouraged at every opportunity, but if a hefty cost has to be imposed for driving to Heathrow, it just acts as evidence that expansion will mean an even pricier airport in reality”
The AEF (Aviation Environment Federation) has commented on the Government’s Aviation Strategy, produced on 7th. They say that while the UK aspires “to be a world leader in aviation when it comes to facilities and services, the same cannot be said for environmental protection, at least when it comes to climate change. A world-class package of environmental protection doesn’t currently seem to be on the agenda.” They say “The Aviation Strategy objectives should include an environmental objective that is not wrapped up in a commitment to growth, and the implications of this objective should be considered from the start.” AEF reiterate that aviation’s “unlimited growth is incompatible with achieving environmental commitments” and the DfT is not even questioning whether aviation growth was a positive outcome to aim for. Instead of the 3 separate consultations on aspects of UK aviation policy over the next 18 months, (with environment at the end) there will be a single Green Paper this autumn. The AEF hopes this allows for environmental impacts to be considered throughout the period of policy development and not as an afterthought (as it originally appeared). The DfT policy is focused on airline passengers and improving the service to them, but it should instead be in the interest of the whole population, including those affected by airports and aircraft.
Government publishes its ‘next steps’ towards an aviation strategy
13.4.2018 (Aviation Environment Federation)
On Saturday 7thApril the Government published the outcome of its call for evidence on the Aviation Strategy ‘Beyond the Horizon’. It’s not a particularly inspiring read in terms of environmental ambition. While the Government aspires for the UK to be a world leader in aviation when it comes to facilities and services, the same cannot be said for environmental protection, at least when it comes to climate change. A world-class package of environmental protection doesn’t currently seem to be on the agenda.
But the document does at least put many of the right issues on the table (including some, such as aviation’s non-CO2 impacts, that have long been neglected) and we plan to engage actively with the Government and others on the environmental aspects of the strategy between now and publication of the Green Paper. We’ve taken a look back at five points we argued in our response to the call for evidence, looked for evidence in the outcome document of any changes in the Government’s position on these, and set out what we’ll be calling for as the policy develops.
We said: The Aviation Strategy objectives should include an environmental objective that is not wrapped up in a commitment to growth, and the implications of this objective should be considered from the start
In our response to the call for evidence, we highlighted evidence that unlimited growth is incompatible with achieving environmental commitments, and that these objectives could not properly be dealt with together.
The outcome document notes that “Environment and community groups felt that the document gave insufficient prominence to carbon emissions and downplayed other environmental impacts as secondary to supporting growth, without questioning whether growth was a positive outcome to aim for.”
Nevertheless the Government plans to stick with its original wording for the objective to “support growth while tackling environmental impacts” with the justification that “the interdependencies of these issues has confirmed the Government’s view that they should all be addressed together as part of a single objective in the aviation strategy”.
Meanwhile, the plan to run three separate consultations over the next 18 months, with environment at the end, has been replaced by a proposal for a single Green Paper this autumn. We hope that this allows for environmental impacts to be considered throughout the period of policy development and not as an afterthought (as it originally appeared).
What we’ll be arguing for in the Green Paper
We’ll continue to present evidence for the need to keep environmental impacts within acceptable limits, whether or not they align with industry and government aspirations for growth.
We said: The commitment to put consumer interests at the centre of the strategy could prevent effective policy-making
The aviation strategy will be strongly consumer-focused and market-driven, the call for evidence had specified. We argued that government policy on aviation, including on its environmental impacts, should be in the interest of the whole population, not just consumers, including the half who don’t take a single flight in any given year.
The ‘market-driven’ language is less evident in the outcome document, but the consumer focus remains clear. In particular, the document makes clear that action on environment, and investment in new technologies, will be considered only if that’s not too costly for consumers and the industry. UK action on climate change could, for example, put our airlines at a competitive disadvantage and increase fares for passengers, the document argues, while the possibility of noise reduction will be considered “in the context of airport growth”. The possibility that environmental objectives should be met even if they conflict with direct passenger interests is not addressed.
What we’ll be arguing for in the Green Paper
AEF will continue to make the case that the Government won’t be able to meet its own aim of a sustainable aviation sector if its key test for all policy decisions is focused narrowly on serving direct consumer interests, and that Government policy should focus on the wider public interest.
We said: Heathrow expansion should not be decided till the strategy is in place
It makes no sense, we argued, for expansion of the UK’s biggest, noisiest airport (in terms of the number of people affected), and its biggest single source of CO2 emissions from any sector, to take place in the absence of national policy on environmental impacts. The outcome document has not acknowledged any concern about this issue.
Meanwhile some airports, such as Luton, have set out expansion plans that are large enough in scale to fall under the NPS process (the one being used for Heathrow expansion). It’s unclear at present how the Government plans to treat such applications – whether it would amend the current Airports NPS (which deals only with Heathrow) or draft new legislation.
What we’ll be arguing for in the Green Paper
Heathrow expansion is not yet a done deal and we’ll continue to argue that MPs should vote against the National Policy Statement in the absence of convincing evidence that it can and will be compatible with meaningful environmental limits.These limits should be set out or reflected in the Aviation Strategy, to ensure a common baseline for all UK airports, and to allow the impact of UK aviation as a whole to be considered.
We said: The proposal to take action to support airports where there is urgent need for growth, in advance of the strategy being finalised, is either meaningless, or a cause for concern
The call for evidence had an odd section on ‘Making Best Use of Existing Capacity’ that noted likely demand among airports to increase passenger throughput and argued that “Due to the recent rise in growth, the Government believes that this issue cannot wait until the publication of a new Aviation Strategy.”
We said that it was unclear what the proposal was, since applications would still need to go through the planning process and the Government doesn’t typically stand in the way. We would nevertheless strongly oppose, we said, a policy whereby these authorities were encouraged to approve any applications for growth in the absence of strategic guidance from Government on how to assess environmental impacts.
The outcomes document doesn’t shed any light, that we can see, on this issue. Some airports have been hoping that the strategy will include specific policy support for expansion at particular airports or in particular regions. There’s no evidence so far that the Government plans to get involved in this level of detail.
What we’ll be arguing for in the Green Paper
Airport development decisions taken at the local level should be guided by a strong policy framework on environmental impacts, which provides a common baseline, and takes into account cumulative impacts, where relevant, from more than one airport.
We said: The proposed ‘policy tests’, including that policy should be evidence-led, should be rigorously implemented
The Call for Evidence proposed that the Government’s approach to developing the strategy would be guided by a set of policy tests:
What is the rationale for action?
What is Government’s role?
What does the evidence say?
Have all of the options been considered?
What is the effectiveness of any proposed action?
We said that we fully supported the application of these tests. There is no mention of them, however, in the outcome document.
What we’ll be arguing for in the Green Paper
We’ll be making the case for effective, evidence-led government action on aviation’s environmental impacts, focusing on areas where the market won’t deliver what’s needed unless the Government gives the right policy steer.