Richmond Heathrow Campaign response to Commission’s air quality consultation

The Richmond Heathrow Campaign (RHC) have submitted their response to the Airports Commission’s consultation on air quality. They comment on the inadequacy of the consultation, and the difficulty for lay people in understanding it. They say that with at least 100,000 people affected by a worsening of the air quality resulting from Heathrow expansion, plans, it is not realistic for the government to approve such a plan. The various possible mitigations for NO2 “may not be sufficient to avoid delaying compliance with standards that are already being breached. This will mean that if expansion were approved by the Government, it would knowingly be planning to continue breaching standards without a realistic plan to put this right.” The RHC put – in plain English – some of their concerns about the Jacobs study, done for the Commission, and the things it has left out. Just a few of these include: the date chosen to assess air quality is 2030, when a runway would only be perhaps 35% full; much of the anticipated reduction in air pollution is from a higher proportion of air passengers travelling to and from the airport by rail; the cost of the necessary enhancements of rail services would be a huge cost for the taxpayer; health impacts, especially of vulnerable groups, have not been assessed.  Richmond Heathrow Campaign Response to Air Quality Consultation


Responding to the consultation:

If people wish to respond to the consultation, details of how to do so at the bottom of this page.  We suggest you write a short, non-technical response, using some of the points below. The response by Clean Air in London is especially useful.

The Richmond Heathrow Campaign Response 

RHC Response to Air Quality Consultation 


Below are a list, in no particular order, of problems with the Airports Commission’s air quality consultation:

1. The consultation itself has been inadequate. There was no prior notice, the documents are too technical for a layperson to understand, the consultation period was only 14 working days, and another document was added half way through the consultation period. It appears that no effort has been made to present the information in a clear manner, so it can easily be understood.

2. The consultation only looks as far forward as 2030, and this ignores the significant growth in demand thereafter. Heathrow Airport Ltd (HAL) estimates Heathrow will have 570,000 flights a year by 2030 against capacity of 740,000 flights and by 2030 a third runway will be just 35% full. The assessment is therefore incomplete, as there is no indication that air pollution will be substantially reduced between 2030 and 2050. It is likely to increase.

3. The consultation documents presume that there will be lower emissions from surface transport in future, and that a higher proportion of passengers will come by means other than by car. Figures indicating lower air pollution are highly dependent on this assumption.

4. The area around Heathrow already has high levels of air pollution, and has struggled to bring this down in recent years. Whether it could meet the air quality targets by 2030 even without a new runway is uncertain. The addition of a new runway could only make that worse. Heathrow is covered by the London Air Quality Plan and it seems that adding a runway could slow down achievement of the plan.

5. Knowing the health impacts of air pollution, as confirmed by the Supreme Court decision, it would be inappropriate and perhaps illegal for the government to permit a development that would lead to serious deterioration in air quality for a large number of people.

6. London is growing very fast, and the consultation does not appear to take into account the growing numbers living in affected areas.

7. Much of the air pollution around Heathrow is from diesel vehicles. The anticipated improvements in NO2 emissions from diesel engines have been slower than expected, and it is likely they will continue to be high for years to come. The report makes optimistic projections about future car engine technologies reducing the levels of NO2 emissions from the road network. These are a gamble, with no guarantee the improvements will happen.

8. Most heavy lorries transporting freight, to and from the airport, burn diesel. They contribute markedly to local air pollution. Heathrow is keen to publicise the amount of freight it ships, and its value to the economy. It is less keen to talk about the diesel emissions that are associated. The Airports Commission consultation also does not deal with road freight.

9. For the airports to have the level of rail transport they would need to cut road vehicle emissions enough, there would need to be considerable public spending on railways. That would be at the expense of the taxpayer, and this is not considered in the consultation. The costs could amount to billions of ££s, at a time of public spending cuts. This may simply not be affordable.

10. EU air quality standards expect governments to improve air quality, and not let it deteriorate. Either runway proposal would only have the effect of causing a deterioration in air quality.

11. The health of people especially vulnerable to pollution exposure does not appear to be considered by the Airports Commisison reports. There is no mention of children, of those vulnerable to asthma, or to sections of the population with increased susceptibility.

12. The Jacob’s report for the Commission does not appear to include the impact of the UK’s Supreme Court decision at the end of April 2015 that the UK is in breach of its obligations for air quality. It was written earlier. The Supreme Court said the UK must produce updated plans by the end of 2015 and secure compliance as soon as possible.

13. The Jacobs report also ignores the extra road traffic due to the increase in catalytic employment (ie businesses which are attracted to the area by the prospect of the new runway).  The staff of these new firms, and of existing firms which would grow in size, would need to travel to and from work, mostly by car.  In addition, the new or expanded companies would create a large increase in road movements by HGVs and a plethora of white vans.

14. The air pollution forecasts also ignore the extra road traffic created by induced employment. The increased number of workers at the airport, or indirectly employed (eg in local hotels), plus the extra workers in the new firms attracted to the area, will all spend a proportion of their incomes locally.  This will create additional induced jobs, and thus additional road traffic.  The report’s suggestion that there will be no extra traffic on local roads after a huge increase in number of flights, number of passengers and number of freight operations is neither credible nor realistic.

15. The increase in air pollution, from the extra road vehicles, does not appear to be consistent with the stated objective of the Airports Commission’s Appraisal Framework: to improve air quality consistent with EU standards and local planning policy requirements.  Nor with the EU Air Quality Directive, the Preamble to which states that: Air quality status should be maintained where it is already good, or improved.  Article 1 states that the Directive lays down measures aimed at the following: ….. maintaining air quality where it is good and improving it in other cases.

16. Air pollution affecting areas under flight paths is not considered. Though much is dispersed by wind, areas under concentrated flight paths, with aircraft only at an altitude of only a few thousand feet, may have higher levels of some pollutants. People living under flight paths are concerned about this.

17.  Pollution impacts are depressed by the inclusion of a series of controversial and untested mitigation measures, like congestion charging zones (or in the case of Heathrow, re-routing of the A4). These schemes have not been developed in detail and may not be possible.

18.  Even after the ultra low traffic levels and futuristic clean engines are factored in the report still projects an increase in pollution levels – for the Heathrow north-west runway – of around 47,000 homes, compromising the health of around 121,377 people and costing £10.8m [Jacobs report Page 173] through increased numbers of hospital appointments. This is far too high a price.

The equivalent figures for the Heathrow Hub northern runway are around 39,000 homes, compromising the health of around 100,389 people and costing £4.2 million through increased numbers of hospital appointments. This is far too high a price.

The equivalent figures for a second Gatwick runway are around  21,000  homes, compromising the health of around 51,328 people and costing £4.0 million through increased numbers of hospital appointments. This is far too high a price.




The response to the consultation by Clean Air in London:

Clean Air in London respond to Commission consultation – Heathrow or Gatwick runway would breach air pollution laws

Clean Air in London (CAL) has made its response to the Airports Commission’s air pollution consultation (ends 29th May). They make 2 key points – that either runway at Heathrow would cause aggravated breaches of the NO2 annual limit value, in 2030 (and perhaps other timescales) and therefore be unlawful; and that a runway at Gatwick would not be consistent with sustainable development, as it would worsen air quality. The Airports Commission expects the Heathrow north west runway scheme would mean worse air quality, (in terms of annual mean NO2 concentrations) at about 47,000 properties, and 39,000 for the Hub ENR runway scheme; and at about 21,000 properties for the Gatwick runway. For Gatwick to do this would not be consistent with the duty on Member States under Directive 2008/50/EC to maintain the levels below the limit values. Under Directive 2008/50/EC NO2 limit values must not be exceeded once attained; and where air quality is ‘good’, Article 12 of the directive applies i.e. Member States shall not only maintain the levels below the limit values but also “endeavour to preserve the best ambient air quality compatible with sustainable development”.

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The launch of the air quality consultation:

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

It is reported that the Airports Commission is now intending to carry out 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.

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How to respond to the Airports Commission consultation


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