What the DfT actually said about Heathrow possibly meeting air pollution standards, with 3rd runway
The Government announced on 25th October that it backed a Heathrow 3rd runway, and would set in train the process that could get it eventually built. A key stumbling block for the runway is air pollution. So what has the DfT come up with, to attempt to persuade those whose opinion counts that the problem can be resolved? In effect, just some very thin statements indeed, which are largely wishful thinking – nothing guaranteed. In their statement, the DfT says the scheme would not “cause nor worsen exceedances of air quality limit values.” … “the Government will review new and emerging evidence in relation to air quality to ensure that it is taking the right approach to achieving compliance for the UK.” … the government is supporting “the long-term transition to low emission vehicles and meet the Government’s target that by 2040 all new cars will be ultra low emission.” … lower emission vehicles by the UK vehicle fleet will lead to “tangible improvements in air quality ahead of the new runway beginning operation.” … “Heathrow has pledged that there will be no increase in airport-related road traffic with expansion.” … “Heathrow will encourage people to use public transport getting “at least 55% of people on to public and sustainable modes of transport by 2040” …. and “Providing new infrastructure for zero or low emission vehicles including charging and fuel facilities and priority parking.” And …”Ensuring that surface access plans are appropriately ambitious in their focus on improving air quality.” Job done!
Policy briefing note – put out by the DfT to go with the runway announcement:
“Airport capacity and air quality”
Air quality is a national health issue, which this government takes very seriously.
Transport has an important role to play in tackling emissions, and whilst the contribution
from aviation is relatively small, airports need to play their part.
This note adds further detail to the report ‘Air Quality Re-Analysis: Impact of New
Pollution Climate Mapping Projections and National Air Quality Plan’ on how airport
expansion could be compatible with our air quality obligations.
The Government has worked to understand the air quality impacts of expansion
The Airports Commission concluded in July 2015 that a new runway could be delivered
without impacting the UK’s compliance with air quality limit values for nitrogen dioxide.
We subsequently conducted further analysis to compare the conclusions of the Airports
Commission with the updated projections provided in the Government’s 2015 UK Air
This analysis concluded that, based on the Government’s Air Quality Plan, the
Heathrow and Gatwick schemes would neither cause nor worsen exceedances of air
quality limit values.1
Since this work was carried out, new international evidence on vehicle emissions
forecasts has been released. Further work is needed to understand the implications of
this evidence, but our initial assessment suggests that revised forecasts would be likely
to be within the range of scenarios already considered by our re-analysis.2
1. The air quality re-analysis acknowledges that, subsequent to the Airports Commission’s work and modelling on air quality, further iterations of surface access plans have been proposed by the promoter of the Heathrow Extended Northern Runway scheme. Most
elements of its plans have remained unchanged, but there have been some changes to road layout. Although these iterations have not been considered in the reanalysis, it is acknowledged that they were developed with one aim being to reduce air quality impacts
associated with the proposal considered by the Airports Commission.
2. The re-analysis also considered a ‘worst case’ scenario which assumed higher diesel vehicle emissions.
As we have made clear previously, the Government will review new and emerging
evidence in relation to air quality to ensure that it is taking the right approach to
achieving compliance for the UK.
Air quality is a national issue
The Government recognises that it could, if required, undertake supporting measures
over the next decade that could mitigate air quality impacts nationally, in London and at
Government is already taking action to improve air quality and ensure the UK can meet
its commitments as set out in the Government’s national Air Quality Plan. For example,
the UK is already delivering a programme of measures to support the long-term
transition to low emission vehicles and meet the Government’s target that by 2040 all
new cars will be ultra low emission.
The programme, which has been backed by £600m of investment from 2015-2020, includes measures to encourage uptake of cleaner vehicles, long-term support for developing low emission technology and funding for new electric and hydrogen buses. [But no diesel scrappage scheme, that had been suggested – as it would cost government too much. AW note].
Over the next decade, measures such as these will ensure a rapid transition to a
cleaner, low emission UK vehicle fleet, leading to tangible improvements in air quality
ahead of the new runway beginning operation. If necessary to meet air quality limit
values, the UK could consider further measures to encourage the uptake of cleaner
vehicles. [This paragraph demonstrates how flimsy the targets for improving air quality are. Words like “ensure”, “consider”, “encourage” …. are not strong assurances of definite firm future action. There is no policy associated with them to guarantee their delivery. AW note].
Getting solutions right locally is also key to improving air quality nationally.
On 13 October the Government published its consultation on a framework for
implementing both voluntary and mandatory Clean Air Zones, a key measure towards
delivering the UK Air Quality Plan.
In London, the Mayor has set out his plans to improve air quality in the capital by
implementing an Ultra Low Emission Zone and is consulting on further changes to meet
his responsibility to deliver clean air in London.
DfT, Defra and the Treasury have also been working closely together to consider the
measures necessary to achieve a long-term reduction in emissions. This arrangement
will be formalised in a cross-government working group to continue to ensure that we
respond appropriately to the evolving evidence base in this area. We will respond
proportionately to any new evidence over the coming year if required. [ie. Defra is aware that data will be emerging to show higher levels of pollution than might have been expected, and may have to reconsider. AW note].
The airport must play its part
Heathrow is already taking action to reduce its air quality impacts, including:
• Improving infrastructure to allow continued improvements in the numbers of people
using public and sustainable modes of transport to access the airport; [But Heathrow has said it will only pay £1.1 billion towards surface access improvements, while TfL considers the whole cost might be up to £18 billion. AW note]
• Introducing low emission vehicles to their fleets; and
• Over half of the aircraft using Heathrow are of the latest emission standards.
[This paragraph illustrates just how little the levels of air pollution around the airport are under Heathrow’s control. It has no powers over road users around the area. Vehicles on the airport itself are probably a tiny proportion of the whole. It is building a new huge car park to accommodate more cars using the airport …. surely not assisting with the plans to get more passengers travelling by public transport. AW note]
An expanded airport will need to go even further
The new runway at Heathrow will be underpinned by further industry leading measures
to mitigate air quality impacts both during the construction and operation of the new
These will be determined through the National Policy Statement and the development
consent process and could include measures which an expanded Heathrow have
• Encouraging more people to use public and sustainable modes of transport to get to
the airport, with the airport committed to getting at least 55% of people on to public
and sustainable modes of transport by 2040;
• Providing new infrastructure for zero or low emission vehicles including charging and
fuel facilities and priority parking;
• Making all airport vehicles ultra low emission by 2025;
• Reduced landing charges to reward airlines for using cleaner aircraft;
• Supplying electrical power and pre-conditioned air to reduce emissions from aircraft
at the gate and incentivising reduced-engine taxiing; and
• Ensuring that surface access plans are appropriately ambitious in their focus on
improving air quality.
The airport will also need to consider what further measures may be required to
encourage cleaner vehicles to enter the airport boundary.
This includes the construction period
During construction of the new runway we expect the airport to use industry-leading
measures and best practice from similar large infrastructure projects, which could
• Developing a construction traffic management plan to control the times and routes
that construction vehicles use to access the site, including restricting or relocating
traffic movements around residential or ecological areas and introducing speed
controls on local roads;
• Using low emission construction vehicles with cleaner engines and fitting particulate
filters to older engines;
• Selecting construction materials to minimise transport distances and combining
loads off-site to reduce the number of lorries accessing the airport;
• A worker transport scheme to encourage construction workers to travel at less-busy
times and by less-polluting modes of transport;
• Connecting to the electricity grid to avoid running generators on site; and
• Using barriers to prevent the spread of emissions.
The airport will need to demonstrate compliance to receive development consent
To ensure the expanded airport is compliant with air quality limit values we will lay
before Parliament and consult on a draft Airports National Policy Statement that will
outline measures which Heathrow will have to consider in preparing its development
consent application. The final measures will be decided through the development
consent order process.
Final development consent will not be granted unless the Secretary of State is satisfied
that the scheme would comply with air quality legal requirements. [Very vague wording … AW note].
The government statement on 25th October merely said:
“Heathrow has pledged that there will be no increase in airport-related road traffic with expansion and committed to a target of more than half of passengers using public transport to access the airport.” Link
Even with 55% of Heathrow passengers using public transport there could be 15 million more passenger trips per year by car by 2040 than now
The government claims Heathrow can meet air quality standards in future, even with a new runway and 50% more passengers, because it will (among other changes) ensure that there are no more road vehicles than now – and by around 2031 about 55% of passengers would use public transport. So is that likely? Looking at passengers only, not freight, and the work done by Jacobs for the Airports Commission, it seems that (2012 data) there were about 70 million passengers, about 20 million of whom were transfers (ie. they did not leave the airport). That meant slightly below 50 million passengers travelled to and from the airport, using surface transport. In 2012 about 59% of these travelled by car (ie. about 29.5 million), 41% came by public transport (28% by rail and 13% by bus or coach). But by 2030 with a new runway, there might be around 110 million passengers, and around 33% would be international transfers. That leaves around 74 million passengers, and if 55% of them use public transport, that means about 34 million using cars. By 2040, the number using cars might be about 45 million (ie. about 15 million more per year than now). And about 9 million using bus/coach – which is of course also on the roads. There would have to be dramatic increases in electric vehicles and improved engine technology to ensure no higher emissions in the Heathrow area. And that is not counting freight vehicles. Or staff. Or other increased vehicle traffic associated with the 3rd runway.
Difficult to see how Heathrow could prevent rise in staff road trips to/from airport with 3rd runway
Heathrow has told the DfT that there would be no higher a number of car trips to and from the airport with a 3rd runway than now. But is that actually credible? Neither the DfT nor Heathrow produce easy-to-find figures, but they be located with a bit of digging. There are probably about 76,000 staff at the airport at present. The October 2014 Jacobs report done for the Airports Commission said: “Headline employee commuting mode share was assumed to be 43% public transport and 47% private vehicles (ie. about 35,700 came by car, and Jacobs states: “with the vast majority of those undertaken as single occupancy car trips.”) …” and of the 43% using public transport, about 35% used bus and 12% used rail. There are various estimates of how many on-airport staff there might be with a new runway. The Commission’s Carbon Traded Assessment of Need scenario anticipated the number of staff to be around 90,000, and their highest growth scenario anticipated about 115,000 staff. Heathrow said by 2030 trips by both staff and passengers to the airport will be 53% by public transport, and still 47% by car. Nowhere is there anything to indicate that below 47% of airport employees would get to and from work by car. With 90,000 staff at Heathrow, if 47% travelled by car that would be 42,300 people, (or if 43% came by car it would be 38,700). If there were 100,000 on-airport staff, and 47% came by car, that would be 47,000 people (and if 43% came by car, 43,000). Those numbers are higher than today. This is not including people travelling to newly increased numbers of jobs in the area.
Heathrow Airport expansion: The environmental challenges
One key question is whether building a third runway will attract so many new cars, buses, lorries and cabs that the local area will keep breaking EU pollution laws.
Heathrow says it’s got plans to attract far more staff and passengers onto public transport – things like charging people to drop off by car, car sharing and cheaper train tickets.
The airport boss promises no more cars as a result of expansion. Transport for London scoffs at the claim, saying it could lead to an additional 40,000 road journeys.
Critically, the government has to work out how you decide what cars and lorries are there because of a new runway. Is a traffic jam on a road two miles away worse because of Heathrow?
Vans might not be going directly to the airport but what if they are delivering to a business that uses a business that relocated because of the expansion?
A recent report by the Environmental Audit Committee (EAC) says deciding why people are there could have major legal ramifications. If an area is breaching EU pollution limits from extra traffic, who do you fine? The council? The airport? The lawyers will be licking their lips.
There’s a lot at stake – Hounslow council told the committee that poorer air quality could cost it between £2.8-10.8m in additional medical appointments.
Already, the air quality hotspots near Heathrow are at illegal levels. But a Greenpeace investigation found that a third runway at Heathrow would see a drastic rise in air pollution with increased traffic. Hounslow council have claimed that poorer air quality could lead to millions of pounds worth of expenditure in extra medical appointments, too. It would also push Nitrogen Oxide levels further outside of official EU compliance rules. After Brexit, of course, there will be no legal requirement to meet these rules, amendable by the Great Repeal Bill. But was this the kind of independence from bureaucracy that green Leave voters were hoping for?