AEF considers DEFRA’s updated air quality plan is insufficient to address Heathrow’s pollution challenge




Updated air quality plan insufficient to address Heathrow challenge

Air pollution around Heathrow has been in breach of legal limits for many years and could prove a significant barrier to expansion.  At the time of the Airports Commission’s recommendation this summer, the Government’s modelling indicated that breaches of the NO2 limit in London would continue until and perhaps beyond 2030. Under the Airports Commission’s plan a new runway could be operational by 2025, and would be likely to further worsen air quality in the Heathrow area.

Defra has, however, now published an updated air quality ‘plan’, drawn up in response to the Supreme Court ruling in April that the Government’s strategy would fail to achieve EU legal limits in the ‘shortest time possible’ and must be improved. Under the revised plan, NO2 would be within legal limits by 2025 throughout London.

But the difference compared with the earlier plan appears to relate almost entirely to new, more optimistic assumptions being made about emissions from diesel vehicles rather than to any new policies or strategies at a national level. The only significant new proposal relates to the formation by local authorities of Clean Air Zones, similar to the London Ultra Low Emission Zone, in which access to the most polluting vehicles could be restricted.

AEF considers both that the plan fails to demonstrate convincingly that the UK is taking sufficient action to meet legal limits, and that they will in any case need to be redrawn to take account of the emissions associated with Heathrow expansion, should Government give the project a green light. A decision on this is expected by the end of the year. We recently signed a joint letter to the Government about Heathrow expansion and air pollution.

We have submitted comments (some by way of the online form and some, given the limitations of this format, directly to the Environment Minister) arguing that Defra should:

  • Set out in detail why its previous forecasts for emissions from diesel vans were wrong and what gives it confidence that the new, much more optimistic, figures are accurate
  • Commit to redrawing the air quality plan to take account of the impact of Heathrow expansion should the Government give the project its approval.
  • Make clear that planning consent should not be granted to a project (a) that will worsen air quality in an area where breaches to either current or likely future air quality limits are already anticipated or (b) where there is a significant risk of it causing breaches to either current or likely future limits.



“Comments from the Aviation Environment Federation on Defra’s “consultation on draft plans to improve air quality: tackling nitrogen dioxide in our towns and cities” ” September 2015

6th November 2015



See also:

Defra air quality plan ‘in breach’ of court ruling

17.11.2015 (Air Quality News)


ClientEarth says it will have “no choice” but to take the government back to the Supreme Court unless “drastic and fundamental changes” are made to proposed air quality plans for the UK.

ClientEarth is threatening to take the UK government back to the Supreme Court over the air quality plan.

ClientEarth is threatening to take the UK government back to the Supreme Court over the air quality plan (photo - UK Supreme Court)

The environmental NGO yesterday (November 16) reiterated its threat of further court action in response to Defra’s draft plans to meet the EU’s legal nitrogen dioxide limits, on which a consultation closed earlier this month (November 6).

ClientEarth said that in “failing to come up with a proper plan to clean up air pollution” Defra was in breach of the Supreme Court’s order in April 2015, and it would therefore likely seek to take the government back to court once again.

Responding, a spokeswoman for Defra said today (November 17): “Tackling air pollution is a priority for this government, which is why we have invested heavily in green transport, committing £2 billion since 2011. We are reviewing submissions to our recent consultation and will report back in December.”

The culmination of the previous legal battle saw the Supreme Court order Defra to produce a new national air quality plan for submission to the European Commission by the end of 2015 that showed how the UK would reach compliance with NO2 limits “in the shortest possible time” (see story).

Clean air lawyer at ClientEarth, Alan Andrews, said: “The government’s response is a shambles. They were ordered to produce a final plan by the end of the year and they haven’t. What they have produced is a series of half measures and vague ideas which constitute no plan at all.”

Clean Air Zones

One of the key measures set out in the draft proposals are for a national network of local Clean Air Zones, which would see drivers of higher polluting vehicles being banned or forced to pay a charge to enter areas with high pollution.

However, echoing the strong criticism it made after the launch of the draft air quality plan consultation in September (see story), ClientEarth described Defra’s proposals as “a shambles”.

VW scandal

Furthermore, ClientEarth said that the government had also “failed to react” to the Volkswagen emissions fixing scandal which erupted in September by appointing the Vehicles Certification Agency to investigate – an agency “that gets funding from the motor industry”.

Mr Andrews said: “This is sadly typical of the government’s response to this public health crisis. Tens of thousands of people are dying early because of air pollution in this country and countless more are being made seriously ill.

“Without drastic and fundamental changes to these plans, we will have no choice but to take the government back to court.”



See also

Respondents cool on ‘unambitious’ Defra air quality plans

Defra has been urged to overhaul its draft strategy for improving the UK’s air quality as it “lacks ambition” according to respondents to a government consultation.

The London Assembly, London Councils and environmental professionals’ organisations IAQM and CIWEM have published responses to the government’s consultation on updated plans to meet EU nitrogen dioxide limits throughout the UK.

The consultation was launched on September 12 2015 in response to the Supreme Court’s ruling that new plans must be submitted before the end of 2015 (see story). The consultation closed last week (November 6).

The responses vary in the strength of their criticism of the plans, but all four largely agree that more measures need to be set out by the government in its air quality plans to tackle emissions from road transport at national, rather than just local authority, level.

Measures such as introducing a scrappage scheme to encourage drivers away from older diesel cars, as well as changes to vehicle excise duty to include air pollution as well as carbon incentives, are called for in several responses, while Defra is also criticised for the lack of technical information supporting the draft plans.

London Assembly

The London Assembly said the draft plan “requires considerable revision” as the proposals “lack ambition and initiative and seem unlikely to fulfil the statutory requirements”.

It is estimated in the draft plan that London will reach compliance with EU nitrogen dioxide limits by 2025, but the Assembly believes the aim should be to achieve compliance around five years earlier than this in 2020.

And, the Assembly said Defra’s proposals “fail to question the real emissions of Euro 6 diesel vehicles”, despite widespread concern that many car models certified as compliant are emitting “several times” the amount of nitrogen oxides permitted on UK roads.

According to its response, London has more than 1,000km of road which exceeds the EU legal nitrogen dioxide limit, which is 43% of the entire UK total.

In addition, the draft plan is not supportive enough for local authorities, the Assembly states, and “unless it shows how local authorities can and why they would, implement the measures envisaged, the plan lacks credibility”.

More specifically, the Assembly makes the following recommendations:

  • a diesel scrappage scheme and further incentives for ultra-low emission vehicles
  • reform to fiscal incentives including Vehicle Excise Duty and fuel tax and a new system of road pricing taking into account vehicle emissions and local pollution levels
  • a central zone incentivising near-zero emission vehicles.

The Assembly’s consultation response was compiled by its environment committee and “is the view of a majority of the committee”, which is chaired by Green Party AM Darren Johnson.


Commenting on Defra’s draft plans, Mr Johnson said the 2025 compliance date for London was “too long to wait when we know that 9,500 people a year are dying due to the dangerously high levels of pollution in London alone”.

CIWEM (Chartered Institution of Water and Environmental Management)

Also publishing its response this week (November 11), the Chartered Institution of Water and Environmental Management – a professional body for environment and water professionals – criticised the government for “lacking ambition on air quality”.

According to CIWEM, Defra’s draft plans to cut NO2 rely too heavily on “unfunded” clean air zones and “unproven” vehicle emissions standards.

It also slams Defra for the publication of the consultation – which it says was “buried” during the announcement of the Labour leadership election on September 12 – “without the supporting technical information needed to scrutinise the draft plans”.

“Without this evidence it is not possible to assess how the wish-list of emission reductions has been quantified and accounted for in the modelling,” CIWEM adds.

According to CIWEM, the many current uncertainties around vehicle emissions mean it is “extremely difficult to judge is the measures will be enough to achieve limit values”, while Defra’s own analysis shows that if Euro emissions standards do not perform as modelled, it could results in up to 22 additional UK zones failing to comply with EU limits.


Chief executive of CIWEM, Nigel Hendley, commented: “It is imperative that Defra recognise that the EU limit values for all pollutants are limits and not targets. There is no minimum concentration below which exposure to nitrogen dioxide is considered safe and every reduction in exposure will be beneficial in terms of health benefits. The final plans must go further to control air pollution, not only to achieve compliance with the Directive, but to protect human health and the environment.”

IAQM (Institute for Air Quality Management)

The Institute for Air Quality Management (IAQM), which represents around 200 air quality professionals in the UK, said that

IAQM said it was “very obvious” that new and additional measures would be required to satisfy the European Commission and the Supreme Court, so it was therefore a “puzzle” that Defra’s draft plans “appear to contain no new commitments” beyond Clean Air Zones.

The UK’s air quality problem, IAQM argues, is “largely one arising from road transport emissions and from diesel engines in particular”, but Defra’s plans do not contain enough measures for addressing this.


It’s response concluded that “in summary, the draft plans proposed by Defra are unpersuasive as a means of achieving compliance with NO2 limit value in the shortest time possible”.

London Councils

London Councils, which represents all 33 local authorities in the UK capital, also criticised the draft plan for its “reliance” on local government action to tackle air pollution, while containing “very few” national-level proposals and policies.

The organisation’s response describes Defra’s plans as “disappointing”, adding that it is “vital that all levels of government tackle this issue as quickly as possible to remove this substantial public health risk”.

It calls for the government to undertake a full review across departments for ways to drive improvements in air quality, suggesting a number of national policies, such as a car scrappage scheme, changes to fuel duty, increased low emissions vehicles funding and a call for any decision on new airport capacity to avoid negatively impacting on the UK’s ability to comply with EU limit values.


Councillor Julian Bell, chair of London Councils’ transport and environment committee, said: “The government’s lack of consideration of what solutions it can contribute at a national level means that Londoners will be exposed to a further decade of poor air quality, resulting in unnecessary deaths.”


Much earlier: 

Study on air quality impacts of UK airport capacity expansion

13.10.2012  (MIT – Laboratory for Aviation and the Environment)

…(extracts) …

According to the U.K.’s Department for Transport, demand for air travel in the country will more than double by 2030, from 127 million to 300 million passengers per year.


The study, [by MIT] published this week in the journal Atmospheric Environment, has found that by 2030, an expanded Heathrow would add 100 early deaths from air pollution annually in the U.K.


Steven Barrett, an assistant professor of aeronautics and astronautics at MIT, says the numbers make sense from a geographic perspective.

“Heathrow is almost in the worst possible place because it’s in the middle of this populated area, and upwind of it,” says Barrett, the study’s lead author and director of the Laboratory for Aviation and the Environment at MIT.”


The findings are part of a wider assessment the team conducted on the health impacts of the U.K.’s 20 busiest airports. To determine the number of premature deaths from airport-related emissions, the team first tracked the number of flights coming in and out of each airport, using 2005 to represent the present day. The researchers also obtained projections from the Department for Transport of the number of flights expected in 2030 under scenarios where Heathrow is and is not expanded.

For each scenario, the team developed a model, detailed in a previous paper, to estimate emissions from aircraft, as well as ground support vehicles such as trolleys and tractors. The team then used a model called Weather Research and Forecasting to simulate wind patterns and other atmospheric conditions throughout the country. They plugged the aircraft emissions data into the model to see where the winds carried the pollution, and then used a simulation of chemical reactions in the atmosphere to understand conversion of emissions into fine particles. Finally, the group superimposed the fine-particulate data over population-density maps in the country.

Previous epidemiological studies have determined the health risk associated with long-term exposure to given concentrations of fine particulate matter. Barrett and his colleagues applied the health-risk data to their fine-particulate map to determine the number of premature deaths caused by a given airport scenario.

In a present-day scenario in which Heathrow operates under current demands, the researchers found the airport-related emissions cause 50 premature deaths throughout the UK.

If Heathrow undergoes no expansion, the number of early deaths would increase to 110 by the year 2030, possibly as a result of other UK. airports expanding to meet growing demand.

If officials decide to expand Heathrow, adding a third runway, the study projected, the resulting air pollution would cause 150 early deaths annually.



The team also found that the number of early deaths in all scenarios would decrease if airports adopted several key mitigation measures: removing sulfur from jet fuel, using one engine instead of two to taxi, converting ground transportation to electric power, and using preconditioned air from the airport terminal to cool aircraft cabins when their engines are off.


Full article (which finds air pollution far lower from an estuary airport) at