Heathrow NPS – summary of the main (probably) insuperable obstacles the runway faces

The government hopes to get a 3rd Heathrow runway approved, but it realises there are a large number of massive obstacles. The purpose of the NPS (National Policy Statement) consultation is to attempt to persuade the country, and particularly the MPs who must ultimately vote on it, that these obstacles can be successfully overcome.  At present, there are no apparent solutions to many of the problems. Below are some very brief outlines of what some of the insuperable hurdles are – and why the government is a very long way from resolving the difficulties.  The issues listed here are the three main environmental issues – noise, carbon emissions, and air pollution. The economics is complicated, but there is a note on that too.  When Chris Grayling makes bland PR statements about the runway, or the papers regurgitate undigested blurb from the DfT, it may be useful to remember how very thin some of these statement are, and how far the government would have to go, in order to find even partial solutions.

Heathrow NPS:   Policy – cart before horse

In a sensible system, it might be imagined that a government would first establish the policy it wants in some particular area – and then set about introducing specific developments. So it might have been expected that the government would set out, and consult, on details of UK aviation policy – on issues such as noise, carbon emissions, balance of airports across the country, taxation etc – before going hell for leather for a Heathrow runway.  What is actually now happening is that the NPS hopes to push through the runway, with no effective policy on aircraft noise, and how it is managed and distributed. There is no policy on aviation carbon emissions.  There is no policy on how much of the aviation industry in the UK is focused on the south east.  Instead, the intention is to get the Heathrow runway approved (in blind Brexit panic …) come what may – and then sort out the resulting problems afterwards.  For example, on carbon, Heathrow will have to take the lion’s share of the allocation allowed, and other airports will have to divvy out what is left among themselves.



The government has repeatedly said, as does Heathrow, that 50% more planes can be added without increasing the amount of noise.  The most generous assessment of this statement would be that it was over-optimistic, but in reality it is downright disingenuous. Even insulting to the public’s understanding.  What 50% more flights means is 50% more noise. True, in coming decades planes are likely to become a couple of decibels less noisy. Even then, they will not be “quiet”.  The new runway will need new flight paths – lots of them. The industry wants to use narrow flight paths, as this is the most “efficient” use of airspace (ie. fits the most flights into a small space).  Nobody plans to inform the public for at least a couple of years where these flight paths will go.  So nobody can have any certainty which new areas will be overflown for the first time. And there is absolutely no doubt that new areas will be overflown.  There is also certainty that even if some areas get “respite” from noise for parts of the day, those areas currently enjoying about half a day of “respite” would only get about 4 hours, with the new runway.

The government, and the CAA, have no clear idea at all how to deal with the problem of people who live under new flight paths, or newly noisier flight paths. There are increasing numbers of people who are not prepared to tolerate becoming the victims of levels of noise that not only reduce people’s quality of life, but may also interfere with their sleep, and therefore their health.  [See more below].


Carbon emissions

Chris Grayling and the DfT have now given up trying to make out that a Heathrow runway can be built, and fully used, and the UK can still stay within the carbon cap for aviation. The Committee on Climate Change (CCC) – which is the government’s official advisor on climate change – in 2009 set a recommended cap for UK aviation CO2 in 2050. This cap is 37.5MtCO2, which was the level in 2005.  The government has never formally accepted the CCC advice. Chris Grayling now admits that he is likely to ignore it – as otherwise the runway is not possible. Instead, the intention is to get the Heathrow runway built, and then try to find some fudge on the carbon.  If the government abandons any pretence of trying to keep UK aviation emissions below 37.5MtCO2, then either the UK will fail to meet its legally binding carbon target for 2050 – or else every other sector will have to make cuts in its CO2 to an extent the CCC does not believe possible.   Or else the UK becomes a pariah state, ignoring commitments on carbon, and not taking seriously its international responsibilities.  [See more below]


Air pollution

Areas around Heathrow have had levels of air pollution (NO2 and particulates) for many years. The problem is caused partly by the aircraft themselves, partly by vehicles on the airport, and mainly by road vehicles on the surrounding roads including the M4 and the M25. A large part of the pollution is from diesel.  There are no definitive figures for how many of the vehicles on the surrounding roads are associated with Heathrow. So when the government says there will be increase, it is not going to be possible to check – unless the baseline numbers are recorded.

The simple maths shows this claim, of no more vehicles, is implausible.  If only about 42% or so of passengers now travel to/from Heathrow on public transport, and 55% will do so with the runway, the figures show this will still mean an increase. And the same goes for employees – not to mention all the extra people who may need to travel to other businesses etc attracted into the area.  The government is banking on car manufacturers quickly getting over the problems of diesel emissions, and the turnover of vehicles being rapid enough that all cars are petrol or electric by 2030 … which is scarcely likely.  Oh, and then there is the extra 50% more freight Heathrow hopes to handle – that all trundles around in diesel fuelled vans and lorries.  [See more below]


Economic benefits to all the UK

The Airports Commission came up with a range of figures for the alleged economic benefit to the UK of the 3rd runway.  The one they used most often was £147 billion.  But that was for the whole of the UK, over 60 years, and it used some highly questionable methodology.  In October 2016, the DfT recalculated this – taking out much of the double counting and unwarranted assumptions – to be £61 billion, over all the UK, over 60 years.

Many of the regions, the Chambers of Commerce, the MPs and Councils were wined and dined by Heathrow, and told of the huge economic benefits the runway would bring their region – and all the jobs. Those claims were made either based on the Airports Commission’s £147 billion figure – or else £211 billion that Heathrow itself often talked of.  With the (still probably exaggerated and unreliable) newer figure of £61 billion, the anticipated wealth for the regions needs to be recalculated. The regions, the MPs, the Chambers of Commerce etc, need to understand they were not given credible figures.

The cost to the UK Treasury each year, in revenue lost as aviation pays no VAT or fuel duty, is around £10 billion per year. The cost of the annual tourism deficit (more money spent by UK residents on trips abroad, over that spent by people from overseas on their trips to the UK) is around £15 billion per year.  The social and health cost of noise and health impacts of Heathrow are not properly quantified.  By contrast, the Heathrow runway is estimated to benefit the UK by £1 billion per year.  Impressive?  [See more below].



Below are a few items that give more information on why the government has huge problems with a 3rd Heathrow runway:


Chris Grayling’s evidence to the Environmental Audit Cttee on noise – in relation to Heathrow runway

Chris Grayling was questioned by the Environmental Audit Committee on 30th November 2016. Below are the parts of the questions, and answers by Chris Grayling and Caroline Low (DfT) on the subject of noise. Mr Grayling reveals only a very partial understanding of the problems, and of the noise levels – and a somewhat trusting belief in how “quiet” new aircraft are going to be. He says the UK should not impose restrictions on noisy aircraft of developing countries, as it would be unfair on them. He admits that people who currently get “respite” from Heathrow noise will get less, and there will have to be new flight paths – means unknown numbers of people will get noise for the first time, and not a lot of “respite”. His aspiration is for no scheduled flights for six and a half hours per night. He believes (mistakenly) that slightly steeper landings would help. He manages to repeat the mantra that despite 50% more flights “noise levels will be lower than they are at the moment.” He places unjustified trust in an “independent noise authority (or commission)” sorting out a lot of insoluble noise problems in future. Much that he could not give proper replied to depends on consultations in 2017. He will “look at” the issue of when insulation of affected homes is done – over up to 20 years, rather than right away. A worrying performance, for those affected by Heathrow noise.

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New EAC report highly critical of government lack on clarity on aircraft noise targets

The EAC has now published a follow up report to their November 2015 report, after the oral evidence given by Chris Grayling on 30th November. It is highly critical of the government on its assurances on noise targets and its low level of ambition in limiting noise in future. The EAC says: “We are concerned that the Government’s National Policy Statement has provided no further clarity on how predictable respite will be achieved or on the specific timings of a night flight ban.” … “The Government must carry out further work on respite which should form part of the NPS process, alongside plans for a live timetable of respite to be published beginning when the new runway is operational. We welcome the Government’s commitment to a 6.5 hour night flight ban. … it would appear inconsistent to reject its key recommendation on the precise timing of a night flight ban.” … and …”The stated goal of “fewer people […] affected by noise from Heathrow by 2030 than are today” shows a lack of ambition. Without Heathrow expansion, local communities would have seen a decrease in aircraft noise as new technology and airspace management techniques were developed.” … and “We are concerned with the inconsistency of the metrics used to measure noise attitudes. The Government has recognised that the level of significant annoyance has reduced and the number effected increased, yet it bases its conclusions on the out of date 57 dB LAeq 16hr contour.” And much more.

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Carbon emissions:

Government likely to ignore climate advice by CCC, turning just to carbon trading, to try to push Heathrow runway through

Chris Grayling and the government plan to ignore the assessment of the government’s own independent climate advisers, the Committee on Climate Change, on how to manage the CO2 emissions from a 3 runway Heathrow. The Environmental Audit Committee wrote to Grayling on 19th December, asking how he planned to square the CO2 emissions and the CCC advice with DfT plans. His response shows there is no way it can be done, and building the 3rd runway means not meeting the UK aviation cap – recommended by the CCC – of 37.5MtCO2 by 2050, meaning about 60% passenger growth above 2005 level. Grayling says ministers “have not taken a view on whether to accept the CCC’s planning assumption,” ie. rejecting the advice. He goes on to note that “a future global carbon market would allow emissions reductions to be made where they are most efficient across the global economy”. Then he says “measures are available” even if the aviation sector grows by more than 60%. This goes against the CCC’s own calculation that these levels of growth would mean “all other sectors will have to prepare for correspondingly higher emissions reductions in 2050.” Grayling hopes carbon trading will cut emissions – but in reality there are no effective carbon trading mechanisms that would do this well enough.

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New EAC report says government must provide clarity about its intentions on Heathrow CO2 emissions

The EAC has now published a follow up report to their November 2015 report, after the oral evidence given by Chris Grayling on 30th November. It is highly critical of the government on its assurances that the runway will meet carbon limits. The EAC says: “The Government claims that Heathrow expansion can be delivered within “the UK’s climate change obligations”. The Government has not set out what it means by “obligations”, let alone how it will meet them. It has not decided whether to accept the Committee on Climate Change’s recommendation on limiting emissions from international aviation. It has not decided on whether to follow the CCC’s advice on offsetting. The Airports Commission told us the appropriate body to make recommendations on managing aviation emissions is the CCC. It would not be a credible position for the Government to claim that it can deliver Heathrow expansion within emissions limits whilst rejecting independent advice as to what those limits should be and how they should be met.” … The EAC says though Chris Grayling said told them the Government had not decided whether it intended to work towards the planning assumption [of limiting UK aviation to 37.5MtCO2 by 2050], when asked if he “had consulted other Ministers or sectors over the higher emissions reductions that they might be required to make if the planning assumption was not met. He said he had not yet done so.” And much more ….

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Air pollution:

Government backed Heathrow 3rd runway ‘using old air pollution data’

Transport Secretary Chris Grayling has admitted the Government backed a 3rd runway at Heathrow without fully understanding the implications of ground-breaking new evidence on vehicle emission standards. Ministers insist Heathrow can expand within EU limits on air pollution, which are currently being widely breached in the capital. But a study for the Government, supporting its third runway decision, was not based on the latest international analysis by experts, which showed emissions from some diesel vehicles are worse than previously claimed. Mr Grayling is to appear before the EAC on 30th November to give evidence on Heathrow and its environmental issues. In a letter to the Environmental Audit Cttee (EAC), Mr Grayling said: “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 [on air quality].” However, EAC chairwoman Mary Creagh said: “We will want to hear from the minister how the Government can meet air quality standards given what we now know about real-world emissions, which are higher than used in the Government’s business case [for a third runway]. We are also concerned that the plans for low-emission vehicle uptake and improvements in public transport are over-ambitious.”

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New EAC report says government has given no guarantees that air quality targets will be met with Heathrow 3rd runway

The EAC has now published a follow up report to their November 2015 report, after the oral evidence given by Chris Grayling on 30th November. It is highly critical of the government on its assurances that the runway will increase air pollution. The EAC says the government’s air quality analysis is over-optimistic. “The effectiveness of the Government’s new air quality plan will be integral to determining whether Heathrow expansion can be delivered within legal limits. We are concerned that the timing of the draft National Policy Statement consultation means the Government will be unable to carry out a comprehensive re-analysis of the air quality impacts, using the new air quality plan, before the [NPS] consultation process is complete.” … “The Government must publish such an assessment alongside the final NPS, it must work towards a scenario in which all road likes affected by expansion have predicted concentrations below the limit value. Whilst the health impact assessment is a step in the right direction, the Government must carry out work to reduce the significant health impacts identified, before construction of the third runway begins.” ….”Since the Government intends to withdraw the UK from the EU before April 2019, there is no certainty about what our legally binding air quality limits will be after 2019. We are disappointed that these limits are not clearly laid out in the Draft NPS.” And there is much more ….

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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.

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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.

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Economic benefits to the UK


Chair of Treasury Cttee, Andrew Tyrie, again asks Hammond and Grayling about unclear Heathrow economic benefits

An influential Tory MP has questioned the evidence behind Heathrow expansion, suggesting the Government may have gone to exceptional lengths to find a methodology that made the case. In a letter to chancellor Philip Hammond and transport secretary Chris Grayling, the chair of the Treasury Select Committee, Andrew Tyrie, said the Treasury has specifically requested the rarely used ‘net public value’ investment measure be included in its assessment. Mr Tyrie pointed out that of the 4 investment measures used to evaluate the 3 runway proposals, only this seldom-used “net public value” measure presents a clear case for a 3rd runway at Heathrow. He asked the ministers where this measure has been used before on major infrastructure. Mr Tyrie also said that the DfT document published on 25th October acknowledged that ‘the Net Present Values (NPVs) for some of the options could potentially be negative under some demand scenarios… ” but the DfT is only considering one scenario. And he asks that figures are produced for all the scenarios [but does not say if he wants carbon capped as well as carbon traded], not just one. He also says assessing demand growth for a period of over 20 years, or even 30 years, is ‘not in line with the guidance issued by the Department for Transport’. He asks that figures with demand capped at 20 and 30 years should be produced.

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DfT’s own study reveals just how tiny the possible economic benefits of Heathrow or Gatwick runway would be to UK

The economics figures by Airports Commission were always dubious, and their methodology was questioned by their own advisors. The Commission did not use the Webtag method that is normally used to cost transport projects. The Commission added in a range of possible future benefits for Heathrow, and for Gatwick – most purely speculative. Benefits of trade were added, even though these were effectively double counted as already taken account of by other sectors. The AC also counted in economic benefits to non-UK residents of flights to or from the UK. The recent DfT document entitled “Further Review and Sensitivities Report – Airport Capacity in the South East” has had to look more carefully at the figures. It has removed some of the wild claims of benefits from trade, and has looked at the benefits just to UK passengers. Its figures show little difference in the alleged future economic benefit to the UK between Heathrow and Gatwick, and that these benefits are actually tiny. Even when measured over 60 years. The DfT document mentions a large number of the aspects they looked at as being of “low analytic assurance”, meaning very uncertain.

The new DfT figures give the total benefit (NPV) of a Heathrow north west runway being just £0.2 – £6.1 billion over 60 years, and the figure for Gatwick being £3.1 – £4.5 billion. The equivalent figures by the Airports Commission were £11.4 billion and £10.8 billion. So current estimates are all even lower than before.

The new DFT figures give the NPV for all the UK of the Heathrow  north-west runway, excluding Wider Economic Impacts, are only from  minus (yes, minus) – £1.8 billion, up to plus £2.3 billion, over 60 years.  The NPV figure for a Gatwick 2nd runway would be plus £1.7 – £1.8 billion, over 60 years.

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Government publishes draft Airports National Policy Statement consultation, to pave the way for Heathrow runway

The government has announced the start of the DfT’s consultation on the draft “Airports National Policy Statement: new runway capacity and infrastructure at airports in the South East of England”. It is the necessary first stage in the process of getting consent for a Heathrow 3rd runway. The consultation will last for 16 weeks, and end on 25th May. The text associated with the draft NPS says little new, that we had not heard before. It is rich in statements like: “..proposals show this Government is not only making the big decisions but getting on with delivering them” and “…will ensure Britain seizes the opportunity to forge a new role in the world after Brexit ….” No real practical, enforceable constraints appear to be placed upon Heathrow, other than it will have to put in place “measures to mitigate the impacts of noise including legally binding noise targets, periods of predictable respite and a ban of six and a half hours on scheduled [note, scheduled only] night flights” … and “implementing measures to deliver on its commitments of no increase in airport related road traffic…” And that: “Planning consent will only be granted if the new runway can be delivered within existing air quality limits and climate change obligations.” The only noise body offered is the “Independent Commission on Civil Aviation Noise” – ie. a Commission, with no powers, not an Authority with powers.

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