News about aviation and air quality
Councils notify Secretary of State that they will seek Judicial Review of Government’s decision to approve Heathrow 3rd runway NPS
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.
Government accused by Councils of ignoring Transport Select Committee recommendations in final Heathrow NPS
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.
European Commission takes action to protect citizens from air pollution – referring UK to the European Court of Justice
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.
Drivers for miles around Heathrow could face £15 congestion charge, to TRY and keep to legal air pollution limits
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.
AEF comment on the DfT’s Aviation Strategy – environmental impacts must be central to policy, not an add-on
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.
Reality Check: Why politicians should reject the 3rd Heathrow runway. By Sally Cairns and Carey Newson
For a masterful summary (2 pages with all references) of the reasons why the UK government should not be persuaded into allowing a 3rd Heathrow runway, see this briefing by Sally Cairns and Carey Newson, from Transport for Quality of Life. They sum up all the ways in which the business case for the runway is flawed and the environmental case rests on hugely optimistic assumptions. They list these as: "planes will get cleaner and quieter at a faster rate than has previously been expected; cars and vans will also get dramatically cleaner; freight movements will somehow be optimised; the latest National Air Quality Plan will deliver all anticipated air quality improvements; the fledgling international aviation carbon offsetting scheme will generate a high enough carbon price; the national Aviation Strategy (not yet written) will come up with cost-effective mechanisms for constraining aviation emissions further; the new Independent Commission on Civil Aviation Noise will prove effective; a review of airspace (that has not taken place for over 40 years, as it is so controversial) will take place soon; HS2, Crossrail and the Piccadilly line upgrades will attract air passengers and airport staff in sufficiently large numbers; funding will be found for Western and Southern rail access; etc. It seems very unlikely that all of these will fall into place."
DfT publishes Aviation Strategy, with focus on growth and helping passengers – little on environmental impacts
The government has published its Aviation Strategy, which the DfT says "will set out the longterm direction for aviation policy to 2050 and beyond." The first phase of its development was the publication of a call for evidence in July 2017. The Aviation Strategy says it will now "pursue 6 objectives, which are unchanged following the consultation." It is very much focused on the passenger, the passenger experience, helping the aviation industry, expanding aviation and "building a global and connected Britain." The Strategy "sets out further detail on the challenges associated with these objectives and some of the action that the government is considering and which will form part of further consultation later in the year." The DfT says: "The government will continue the dialogue that has already begun on these issues. The next step will be the publication of detailed policy proposals in a green paper in the autumn of 2018. This will be followed by the final Aviation Strategy document in early 2019." There is mention of the environmental problems (carbon, noise, air pollution) but they are given scant attention, and it is presumed they can all be reduced - even while the sector has huge growth. A new runway at Heathrow is assumed to happen.
Mayor of London Transport Strategy opposes Heathrow runway, unless there are firm assurances on air pollution, noise and surface access
The Mayor of London has published the Transport Strategy for London, which sets out the Mayor’s policies and proposals to reshape transport in London over the next two decades. The Strategy is firmly opposed to a 3rd Heathrow runway. Its section on Heathrow states: "The demand generated by the current airport combined with local traffic already place considerable strain on the roads and railways serving the airport and contribute to levels of NO2 that are well in exceedance of legal limits. The Mayor considers that, as a result of the additional flights and associated traffic, any expansion at Heathrow would significantly impair London’s ability to meet international air quality obligations in the shortest possible timescale and would contribute to an overall worsening of air quality relative to the situation without expansion. Heathrow already exposes more people to significant aircraft noise than its five main European rivals combined, and the proposed increase in flights cannot avoid many people being newly exposed to significant noise. Moreover, it would be unacceptable if the air quality gains secured by the Mayor and the potential noise improvements as a result of new technologies were not allowed to accrue to local communities to improve public health, but were instead used to enable expansion of Heathrow airport."
“If the government wishes to get serious on clean air, by adopting stronger measures … a 3rd Heathrow runway simply can’t proceed”
The Cross-Parliamentary EFRA Committee report on Improving Air Quality, released on 15th March, calls on the Government to bring forward legislative proposals on clean air that unify and update existing laws in a new Clean Air Act. This includes whether to adopt WHO air quality guidelines for all pollutants. The report also states that the latest air quality plan will not “deliver improvements at a pace and scale proportionate to the size of the challenge." The High Court agrees. Significant improvements to the plan, and to the Government’s wider approach to air quality, are needed to protect the public from toxic air and that the Government’s forthcoming action plan “must ensure air quality policies are properly aligned with public health and climate change goals.” Reacting, Paul McGuinness, Chair of the No 3rd Runway Coalition said: “If the government wishes to get serious on clean air, by adopting stronger measures ... a 3rd runway at Heathrow simply can't proceed. As it is, Heathrow already regularly exceeds Nox and particulates targets. And even the government's best-case scenario for an expanded Heathrow expects there to be a "high risk" that air quality targets will be breached. If the government wishes to signal a purer intent on air quality, abandonment of this project would at least represent a meaningful start.”
Grayling emissions omission admission: Heathrow air quality costs 2-4 times higher than previously thought
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.