Heathrow premature “consultation” demonstrates NOT how inevitable the 3rd runway is, but just how absent any details are

The Heathrow consultation (17th January to 28th March) is vague in the extreme. It purports to be a consultation about how the airport should expand with a 3rd runway. But no government permissions for this has even been given yet, with a vote in Parliament and several legal challenges to be undergone before there is any certainty there will be any 3rd Heathrow runway. The consultation’s main purpose appears to be to give the impression to politicians, business people, the public, the affected communities etc that the runway is a “done deal” and is definitely going ahead; Heathrow is just sorting out some details. That is NOT the case. As the consultation makes manifestly clear, rather than sticking to details of the recommendations of the Airports Commission (on noise increases, night flight curfew periods, location of runway, means of getting over the M25 and so much else) Heathrow is not sticking to this, but trying out other options – which were never part of the Commission’s scrutiny.  Far from making the runway look inevitable, the numerous areas in which there is no certainty of Heathrow’s plans demonstrate immense weaknesses. The consultation is aimed at trying to make the runway planning appear sensitive to public opinion. It is in fact far more underhand than that, and highly unlikely that consultation responses – other than endorsing what Heathrow wants – would even be given more than passing consideration.

This is what the Heathrow “consultation” says at the start: 



Consultation 1

1.3.3 Building on the Airports Commission’s recommendations we have been
working to further develop options for building the future airport.
This is where we are now and this consultation is a critical part of
expanding Heathrow. The feedback we receive will help us deliver all
of our commitments to expand in a sustainable way, while increasing
opportunities for people and businesses across our local communities.

Ongoing engagement

1.3.4 Between our consultations we will engage with our communities and
stakeholders to develop our proposals. The Community Engagement Board
will be a key part of this engagement to ensure local communities can
effectively contribute to the development of our proposals.

Consultation 2

1.3.5 We will consult on our preferred scheme that we intend to include in our
DCO application. This will include more detailed information on all aspects
of expansion including the likely environmental effects and the ways we
intend to reduce them.

Further engagement

1.3.6 After our second consultation, we will continue to engage with our communities and stakeholders as we prepare our DCO application.


and then:

Designing a three runway airport masterplan

2.1.1 The north west runway masterplan submitted to the Airports Commission and subsequently supported by Government was necessarily at a high level. It was always acknowledged that this would need to be subject to further detailed development. This requires us to thoroughly review all of the components of an expanded airport.

2.1.2 The principal components are as follows:

• runway and taxiways;

• terminals, satellites and aprons;

• M25 motorway realignment and junctions;

• A4, A3044 and other local road diversions; and

• river diversions and flood storage.

2.1.3 These components are key to shaping a preferred masterplan and determining its associated land requirements beyond the existing airport boundary


In the consultation document, the questions below are what Heathrow wants people to comment on. There is some minimal amount of text in the document to give a vague outline of the suggested options. NO details of note.

There are Heathrow’s questions:

  • Please tell us what you think about the options for the new runway. What factors do you think should be important in fixing the precise location and length of the runway?
  • What factors do you think should be important in deciding the location of new taxiways?
  • What factors do you think should be important in locating new terminal and apron space?
  • Please tell us what you think about the re-positioning of the M25.
  • Please tell us which family of options you prefer for the alterations to Junctions 14 and 14A and reasons why.
  • Please tell us which option you prefer for the diversion of the A4 and the reasons why.
  • Please tell us which option you prefer for the diversion of the A3044 and the reasons why.
  • Please tell us which option you prefer for the Stanwell Moor junction and the reasons why.
  • Please tell us what you think about the options to improve access to the Central Terminal Area?
  • Please tell us what you think about the options for the diversion of rivers and the approaches to replacement flood storage.
  • Please tell us what you think about the locations and sites that we have identified as being potentially suitable for airport supporting facilities.
  • Please tell us what you think about our approach to providing car parking and the potential site options we have identified.
  • Please tell us what you think about the sites identified for the relocation of the Immigration Removal Centres and if you have a preference please tell us why.
  • Do you have any comments on the land uses that will be affected by Heathrow’s expansion?
  • Do you have any views on how the demand for additional airport related development might best be delivered?
  • Please tell us what you think about the sites we have identified as potential construction sites and the approaches we are considering to manage the effects of construction.
  • Please tell us what you think about the locations and sites that we have identified as being potentially suitable for airport related development.
  • Please tell us how you think we should best bring the various components together to build our masterplan for the expansion of the airport and what factors you think should be most important in our decision-making.
  • Latest Heathrow consultation launched



Latest Heathrow Consultation Launched

25.1.2018 (Richmond & Twickenham Times)

By Grainne Cuffe (Lead reporter – Richmond & Twickenham Times and Surrey Comet)

The latest consultation on the Heathrow expansion has been published and one plan could move the M25 west by 150m.

Proposals for a third runway at the international airport have been in the making since 2012.

On January 17, the airport unveiled a number of new proposals such as tunnelling the M25, the location of expanding terminal facilities and three options for the length of the new runway varying between 3,200 metres and 3,500 metres.

Richmond and Twickenham Times: The three runway options

The third runway was due to cost £16.8 billion, but Heathrow claims it could cut that figure by £2.5 billion.

According to one option, the M25 could be lowered by seven metres to create a tunnel between junction 14 and 15, with the runway over it.

Heathrow claims its target is to operate “zero carbon airport infrastructure” by 2050, but Twickenham MP Sir Vince Cable told the Commons on Wednesday that the damage to air quality from expanding Heathrow was a matter of “human health and mortality”.

He said: “Heathrow is a far more damaging option than the alternatives: it is more polluting, it is noisier and it is the most expensive.”

No flight plans have been included in the first stage of the two-part consultation, which relates to physical changes on the ground, and many believe an informed decision cannot be made until they are put forward.

The second stage will deal with airspace.

What are Heathrow’s arguments for the expansion?

• Heathrow says its runways are operating at 98% capacity and that airlines have not been able to grow as a result

• It argues Britain is losing out to European competitors in the “global race” for foreign investment and trade

• Heathrow claims the new runway will add up to £211 billion in economic growth while creating 180,000 jobs  [These figures are outrageous – totally exaggerated, taken out of context, and out of date !  AW comment]

• It says passengers and UK businesses will have access to up to 40 new long-haul destinations along with new domestic routes

• Heathrow intends to make improvements to its rail connections and claims this could increase the number of passengers using public transport to get to the airport by 60 per cent

But the proposed runway has been met with condemnation from councils, residents, and environmental campaigners.

What issues do people have with the proposed expansion?

• The airport has allocated a compulsory purchase zone, which involves 750, to the surrounding area

• Heathrow promises to pay 25% more than the market rate, but homes have already lost value due to the proposed expansion

• Noise and air pollution from the construction are major concerns

• The build will be on greenbelt land

• The cost of the expansion

• Some believe Gatwick would be a better choice and would cost significantly less at £7.4 billion

Although Heathrow CEO John Holland-Kaye said the airport was “determined to reduce its environmental impacts” by cutting emissions and bringing in “cleaner, quieter” aircrafts, people are not convinced.

Rob Barnstone, coordinator of Stop Heathrow Expansion, said the proposal to build on greenbelt land was “deeply disappointing and worrying for our local environment”.

He added: “There is a great irony in pledging to have no additional cars using an expanded airport compared with now, then wanting to build a huge new car park on green belt land site. The pledge is now simply laughable.”

Four councils, Richmond, Wandsworth, Hillingdon, and Windsor and Maidenhead, have been campaigning against the expansion since it was proposed.

Richmond Council leader Paul Hodgins said the new consultation is “similar to what they’ve put out before” and doubts the claims in it that passengers using public transport would “increase by 60 per cent”.

Heathrow has said because of planned transport improvement there will be no increase in traffic to the airport.

He said: “I don’t believe those claims.

“Richmond and Twickenham are very close to Heathrow but the transport links are terrible.

“Residents would still be driving to the airport.”

He added “massive rail investment” would have to be made to avoid an increase in car traffic.

The council leader believes Gatwick, which would cost significantly less, is a much better option.

Cllr Hodgins said: “This is an emotional argument in favour of a hub airport for London on the international stage.  Heathrow is ‘trophy’ airport.   From the Government’s own calculations Gatwick is the best economic option.   We need more homes. We need massive investment across London and not just concentred at Heathrow.”

Emma Gilthorpe, Heathrow’s executive director of expansion, said: “When the government announced its support for Heathrow expansion it made a clear commitment to keeping Britain open for business.

“We want an expanded Heathrow to be the world’s best airport, ensuring that our country and its future generations have the infrastructure they need to thrive.

“We need feedback to help deliver this opportunity responsibly and to create a long-term legacy both at a local and national level. Heathrow is consulting to ensure that we deliver benefits for our passengers, businesses across the country but also, importantly, for those neighbours closest to us.”

The consultation is open for 10 weeks from January 17 to March 28, to have your say go here.

If the scheme is approved, Heathrow will submit a planning application after consulting local communities on detailed proposals.

The airport hopes to begin construction in early 2021, with the runway completed by the end of 2025.

Time scale of proposed expansion

2012: Independent Airports Commission set up by Government

2013: Heathrow submits Long-term Hub Capacity Response to Airports Commission

2014: Airports Commission publishes interim report outlining three options

2014: Heathrow submits ‘Taking Britain Further’ Technical Submission to Airports Commission

2015: Heathrow submits ‘Consultation Response’ to Airports Commission

2015: The Airports Commission unanimously recommends Heathrow

2016: Government endorses Airports Commission and backs Heathrow third runway

2017: Government consultations on draft Airports National Policy Statement (ANPS)

2018: Heathrow launches Expansion Consultation (this consultation)




Heathrow opens Public Consultation on proposed third runway

By the AEF (Aviation Environment Federation)

Why are they consulting?

Before it can proceed with construction, Heathrow needs to submit an application to the Planning Inspectorate for a Development Consent Order (DCO). This can only happen once Parliament has approved the National Policy Statement which is currently expected to be voted on by MPs in the second quarter of this year. If it is approved, and it remains a big if, it is likely that Heathrow will submit its DCO application in early 2020. Heathrow’s public consultation lasts for 10 weeks and seeks to inform that final application by asking the public and stakeholders for their views on options and possible mitigation, including:

  • Three options for the new northwest runway, with length varying from 3,200 to 3,500 metres;
  • Potential locations to expand terminal infrastructure: east of Terminal 2, west of Terminal 5, or a new satellite terminal next to the new runway;
  • Proposed alignment of the M25: repositioning it approximately 150 metres to the west, lowering it by seven metres in a tunnel, and raising the runway height so it passes over the M25.

The airport is also asking for the public to review its plans to manage the effects of expansion on local communities and the environment.

On noise

Heathrow’s goal: to expand its airport while affecting fewer people with noise compared to the number currently affected

What does it propose?

NOISE ENVELOPE (‘A package of measures used to reduce noise’): to form a Noise Envelope Design Group (NEDG), made up of community members, stakeholders and noise experts) to define and implement a noise envelope.

RESPITE: to provide predictable respite from noise through the design of flightpaths (addressed in Airspace Principles Consultation).


  • ‘Inner Zone’: to provide full acoustic insulation for residential properties within the 60dB LAeq noise contour of an expanded airport;
  • Outer Zone’: contribution of up to £3000 for noise insulation of residential properties within 57dB LAeq or 55dB Lden noise contours of the expanded airport;
  • Community buildings: noise insulation and ventilation for community buildings within the 60 LAeq noise contour.

NIGHT FLIGHTS: six and a half hour night flight ban between the hours of 11pm and 7am. Heathrow expresses a preference for between 11pm and 5.30am.

On air quality

Heathrow’s goal: to play its part in improving local air quality and managing emissions from airport-related sources

What does it propose?

TRIPLE LOCK GUARANTEE to (1) meet its existing commitment to target no increase in the amount of airport-related vehicles and by supporting improved surface access (2) ensure further measures are ready to be introduced, if required, to reduce road journeys and encourage more sustainable forms of travel (3) guarantee new capacity will only be released when it is clear the airport’s contribution will not delay the UK’s compliance with EU air quality limits.

PRELIMINARY ENVIRONMENTAL INFORMATION provided at Consultation 2 which will begin the process of fully assessing environmental effects, including air quality, and will also include initial information on necessary mitigation.

LOW EMISSIONS DESIGN: positioning of realigned roads, layout of airfield and provision of flight facilities to reduce potential for emissions from traffic and aircraft to affect local air quality.

MANAGING AIR QUALITY DURING CONSTRUCTION through use of low emission construction vehicles, use of logistics hubs to combine deliveries and reduce number of individual vehicle trips, moving bulk materials by rail rather than road, and managing and coordinating traffic and workforce travel.

MANAGING AIR QUALITY DURING OPERATION through incentivising use of cleaner aircraft, more efficient operation of aircraft on the ground, and emissions-based charge for vehicles accessing the airport to encourage use of cleanest vehicles, sustainable and public transport modes.

On climate change

Heathrow’s goal: to ensure growth from the new runway, including flights, is carbon neutral.

What does it propose?

LOW CARBON DESIGN: to reduce potential taxiing distances and allow aircraft to taxi using only one engine, installing electric vehicle charging points and promoting and better integrating the airport with low carbon public transport.

LOW CARBON CONSTRUCTION AND MATERIALS: measures will be put in place to manage carbon emissions associated with construction, including minimising resources and use of off-site fabrication, construction and logistics hubs.

LOW CARBON OPERATIONS: Heathrow’s target is to operate a zero-carbon airport infrastructure (buildings and other fixed assets) by 2050.

To meet this target, the airport proposes to:

  • Use modern energy efficiency measures in new infrastructure;
  • Improve energy efficiency of existing buildings, assets, and other infrastructure;
  • Maximise use of renewable energy from on-site or local sources;
  • Purchase renewable energy from off-site sources;
  • Invest in low emissions vehicles and implement procedures to reduce aircraft taxiing; and
  • Develop an approach to offsetting carbon.

There is also proposed mitigation on the natural and historic environment.

AEF’s view

Heathrow’s consultation largely reiterates previous commitments, while many of the proposed mitigation measures have yet to be defined or elaborated upon.

On noise, the proposed ban is six and a half hours, with flights occurring before 6am. This falls short of the eight-hour sleep target recommended by the WHO and allows flights during the most sensitive period in terms of sleep disturbance. Meanwhile, the noise envelope, respite plans, and flight path locations remain unclear.

On air quality, the consultation includes a binding commitment that new capacity at an expanded airport will only be released when it is clear that the airport’s contribution will not delay the UK’s compliance with EU air quality limits. However, it uses the Airport Commission’s misleading framing of the objective (i.e. not delaying compliance as opposed to not worsening an existing breach, allowing Heathrow to be in breach as long as other areas of London are also above legal levels). Mitigation measures will not be proposed until the second consultation and the airport only commits to playing a part in improving air quality, reinforcing AEF’s view that the Government needs to demonstrate whether and how expansion at the airport can be compliant.

Finally, on climate, the airport’s goal remains an aspiration, which relies largely on ICAO’s offsetting measure to meet its carbon neutral runway ambition. This does not address the bigger challenge of whether the Government can develop an effective climate plan to show how expansion, when combined with forecast emissions from other UK airports, can remain within the Committee on Climate Change’s recommended planning assumption of 37.5Mt CO2 by 2050.

At the same time, Heathrow has also published a consultation on the principles to apply to future airspace design with a third runway. This includes asking respondents whether they have a preference for concentrating flight paths over the fewest number of people or dispersing them over a wider area, if reducing noise should be a higher priority than reducing emissions, as well as asking for feedback on how to treat newly overflown communities, open spaces and rural areas.

Should the NPS be approved by Parliament in the summer, Heathrow plans to issue a second consultation early next year revealing the areas that could be impacted by new or revised flightpaths following the application of the design principles on which it is currently consulting.


Both consultations remain open until 11.55pm on 28 March 2018. Responses can be made here.

Related articles

The NPS for Heathrow expansion: a brief tour

AEF launches new campaign: Why the third runway plan can’t fly

Comment from AEF on NPS reconsultation

AEF submits response to DfT consultation on revised draft NPS

Heathrow opens Public Consultation on proposed third runway