Airports Commission to carry out a new consultation on air quality impact of runway schemes

The Airports Commission has opened a new public consultation on the the impact of air quality of a new runway. It is thought that the Commission is keen to avert a potential legal challenge to their decision, if the runway would put air quality standards at risk. Only recently the UK Supreme Court ruled that as Britain is still not meeting EU air quality standards, it must quickly produce plans to limit pollution, especially NO2. The FT reports that the consultation would be a very quick, technically focused one, perhaps being completed by the end of May. It is not anticipated to involve any meetings with the general public. Sir Howard Davies is off to become Chairman of RBS, starting that job on 1st September. He joins the RBS board at the end of June. Therefore the runway decision was anticipated during June. If the consultation on air quality is to be thorough enough, and give those consulted adequate time to respond, getting an announcement by the end of June would be very difficult. Parts of the Heathrow area regularly breach air quality limits. Though Gatwick has less of an air quality problem, expanding it to the size Heathrow is now would risk breaching air quality limits – and the Commission should not recommend a development that would mean NO2 limits would be broken.


The consultation started on 8th May, and ends at midday on 29th May.

Links to the various documents are below:

Air quality consultation cover note  (2 pages)

Air quality assessment: detailed emissions inventory and dispersion modelling  (206 pages)

Air quality assessment: figures appendix (51 pages)

Air quality assessment: spatial maps  (10 pages)

Air quality assessment: airports backing data  (multiple spreadsheets)

On 18th May another document was added.

Stakeholder Air Quality Consultation Queries and Airports Commission Responses May 2015


The Commission is now inviting further comments on its analysis prior to midday on Friday May 29.

Comments can be submitted via email to or by post to:

Airports Commission
6 Floor
Sanctuary Buildings
20 Great Smith Street


Howard Davies ‘to launch new public consultation’ on Gatwick and Heathrow expansion

Chairman of the Airports Commission wants to hear the public’s opinion on how air quality will be affected by the two proposals

8.5.2015 (Telegraph)

By Andrew Trotman

The head of the commission in charge of deciding whether Gatwick or Heathrow should be allowed to expand is to launch a fresh public consultation, according to reports.
Sir Howard Davies, chairman of the Airports Commissio, will tell both airports today that he wants to hear the public’s opinion on how air quality will be affected by the two proposals before he makes his final ruling later this year.

The move is to ensure Sir Howard’s decision will not be subject to a legal challenge, the Financial Times reported.

However, there will be concerns that the commission, which was set up by David Cameron in 2012, will delay its report yet again.

Airport expansion plans have been unpopular with voters, who are concerned about increased noise and traffic on homes in the London area.

The timing of the release could be crucial as Sir Howard is due to take up a new role as chairman of Royal Bank of Scotland in September.

The commission has already concluded that a second runway at Gatwick would cost £9.3bn, plus a further £787m from the taxpayer to improve road and rail access. This compared with Gatwick’s own estimate of £7.4bn.

Building a third runway at Heathrow would cost an estimated £18.6bn, which would require £5.7bn from the taxpayer to improve access.


AirportWatch comment:

The Commission had left itself vulnerable to problems on air quality, because it had not carried out any adequate analysis.

Its consultation in November 2014 the Commission said not been able to complete full detailed modelling of the air quality impacts of new runways and further work was needed. Though the Commission have had a lot of time to get this done, it was not in time for the main consultation. The Commission said, in November 2014, that it intended to supplement the information on air quality “at a future date” with “more detailed dispersion modelling”. That means models to show how wind and weather disperses pollution.  That sort of modelling could always be questioned on its accuracy and reliablilty.

Airports Commission rushes out new technical consultation (for just 3 weeks) on air quality

The Airports Commission has, at the last minute, produced a very short (only 3 weeks) consultation on air quality. It says this was not done earlier due to the pre-election “purdah” period when there are restrictions on activities such as consultations by government. The timing, shortly after the ruling by the Supreme Court, that more has to be done by the UK on air quality may, or may not, be coincidental. The consultation ends on 29th May. The Commission aims to make its runway recommendation in June, before Sir Howard starts work at RBS (joining its board at the end of June). The consultation outline is given in a cover note, with one main document, an appendix document, 10 pages of maps, and databases of backing data – over 280 pages. All to be checked through in 21 days, including a Bank Holiday. The November 2014 consultation stated that dispersion modelling still needed to be done. That was not included in time for the main consultation. The Commission has now found some differences between the two Heathrow options. It has looked at a range of “mitigation measures” to reduce the level of NO2, and considers whether these would be enough to keep within legal limits. It is a technical consultation, very difficult for lay people – who are not expert in the area of air quality – to understand.

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Airports commission launches new review on runway expansion

7.5.2015 (Financial Times)

Jane Wild and Peggy Hollinger

Sir Howard Davies has decided at the eleventh hour to launch a new public consultation on the question of airport expansion, stoking fears of further delays to a politically sensitive decision.

In a bid to avert a potential legal challenge to the three-year review, the airports commission chaired by Sir Howard will tell Heathrow and Gatwick on Friday that it is seeking public comment on the impact of expansion on air quality.



Heathrow’s bid for expansion has been criticised given that the roads surrounding the UK’s largest airport already breach EU air pollution limits. A previous government decision to allow a third runway at Heathrow was overturned by the courts in 2010 on environmental grounds. Gatwick has always claimed that expansion at Heathrow could again be challenged legally.

The commission’s decision to seek further public comment will be an extra safeguard against any judicial review. “It could be vulnerable unless they do something,” said one person close to the bidders.



Transport for London

In addition, Transport for London commented about the impact of more freight, and the air pollution from the lorries, in their response to the Airports Commission consultation, in February 2015.  They said:

2. The Commission’s assessment underestimates surface access demand, in part by omitting growth in freight and additional catalytic airport activity

2.1. It is clear that the Commission has not taken proper account of freight demand, despite the envisaged increase in air freight reported in its economic case for airport expansion. Extra freight will add to pressure on the road network and have a disproportionate impact on air quality. Freight access will also rely on the aforementioned billions of pounds of highway upgrades not included in the Commission’s surface access appraisal.

2.2. The Commission has not taken into account the increase in transport demand generated by the additional catalytic airport-related business activity – and associated employment and population growth – that they predict in their economic case for airport expansion. This potentially large increase in transport demand should be taken into account in their surface access appraisal.

The Mayor of London’s response to the Airports Commission consultation on shortlisted options.    Surface Access. Supplementary Note 04. February 2015



See earlier:

Airports Commission consultation shows air quality problems with new runways, but no adequate data yet

The Airports Commission consultation document is aware that air quality is a major obstacle for a new Heathrow runway.  It says expanding either Gatwick or Heathrow would have a negative impact on air quality, with all proposed schemes requiring expansions to local road networks to accommodate increased road traffic. For both the Heathrow runway options the Commission says “Both local Air Quality Objectives and EU limit thresholds are at risk of exceedance at a small number of monitoring sites in the local area under this scheme. While in some cases these exceedances are also forecast to occur in the do minimum scenario, there is clearly a substantial negative impact of the scheme on air quality, unless forceful mitigation measures are implemented.” But they have not been able to complete full detailed modelling of the air quality impacts of new runways and further work is needed. This unfortunately is not in time for the consultation.  The Commission intends to supplement this at a future date with “more detailed dispersion modelling”. That means models to show how wind and weather disperses pollution, and it could be questioned how much faith should be placed on sufficient wind speeds in coming years.

The actual wording in the Nov 2014 was:

2.56 The high-level air quality modelling presented for consultation enables a comparison to be made of the scale of impacts and risks associated with each option. Prior to reaching any final recommendations, the Commission intends to supplement this with more detailed dispersion modelling, as set out in its Appraisal Framework, which will provide greater assurance in respect of the air quality implications of each proposal and the scope for mitigation. The range of inputs required and the complexity of this work mean that it has not been possible to carry it out in advance of consultation.  [Page 29. Link ]



Why the ruling by the Supreme Court on air pollution could stop plans for a new SE runway

The Supreme Court has ruled that the Government must produce a new action plan by the end of this year for bringing air pollution within legal limits. A decision to allow another Heathrow runway could be legally challenged unless the Government’s new plans are sufficiently ambitious to reduce emissions of a 2 runway airport below the legal limit – and also leave enough headroom to accommodate the negative impact of a 3rd runway. There is only pure speculation on how it could be achieved. The court ruling also suggests that the cost-benefit analysis for adding a runway will need to be revised, as the Government has previously claimed that complying with air quality law would be too expensive. And this does not only affect Heathrow, but Gatwick too. Gatwick is keen to claim it does not have a poor air quality problem. But EU regulations require not only that poor air quality must be improved but also that good air quality should be protected. A 2nd Gatwick runway would mean local air pollution hotspots, with a risk of breaching the legal limits. The Airports Commission has a duty to the public not to recommend a project that would significantly damage people’s health. It would also be a poor use of taxpayer’s money to make recommendations that invite a legal challenge.

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Landmark air pollution ruling by Supreme Court could scupper 3rd runway at Heathrow due to high NO2 level

The UK Supreme Court has quashed the Government’s ineffective plans to cut illegal levels of air pollution in Britain and ordered it to deliver new ones by the end of the year. The Supreme Court Justices were unanimous in their decision, saying: “The new Government, whatever its political complexion, should be left in no doubt as to the need for immediate action to address this issue.” This could have implications for a 3rd runway at Heathrow, as areas around the airport continue to be stubbornly above the EU legal limits. That is due both to air pollution from the planes in addition to the huge amount of traffic on the M4 and M25. In their verdict, 5 judges ordered the Secretary of State at DEFRA to consult on strict new air pollution plans that must be submitted to the European Commission by 31 December 2015. The EU Air Quality Directive demanded the UK brought pollution down to legal limits by 2010 or apply for an extension by 2015. But the government in 2011 said that a number of areas, including London, would be unable to comply by 2015 and instead argued the law allowed it to comply “as soon as possible”. The judgement marks a victory for the campaigning legal firm ClientEarth. HACAN commented: “This is a potential show-stopper as far as a 3rd runway is concerned.”

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