Air Quality
News about aviation and air quality
Speculation about a congestion charge around Heathrow, to cut air pollution and deter traffic
The Airports Commission recommended measures such as a congestion charge on roads around Heathrow, in order to keep levels of air pollution at legal levels, and prevent traffic congestion gridlock with a 3rd runway. The Times reports that the congestion charge may be imposed, with the effect of forcing people to use public transport instead of cars. The central London congestion charge is £11.50 per day. What the money would be spent on is not known. The charge might be levied on some 80 miles of road, to keep NO2 and particulates down. The impact on road users who are not related to Heathrow is not known, or the costs to the local economy of this burden. The charge may have to be agreed through the development consent order process. Chris Grayling said, on 25th October, that the runway could be delivered "within air quality limits." But little in the DfT's documents gives any firm reassurances that measures will be put in place that could actually keep the levels of NO2 low enough. Further questions emerged last week when the High Court ruled that the government was failing to tackle air pollution quickly enough, and its air quality plan was based on over-optimistic forecasts. Heathrow insists that the number of public transport routes (which is is not prepared to pay towards) will increase, with new direct rail links helping Heathrow out. The worst air pollution in the area is near junctions 3 and 4 of the M4, where up to 16% of the traffic is related to Heathrow.
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Action to combat UK illegally high air pollution delayed again – judge will decide on timetable for action
On 2nd November, ClientEarth won its High Court case against the Government's slowness in tackling illegal levels of UK air pollution. Mr Justice Garnham ruled that the government’s 2015 Air Quality Plan was not adequate, and said it was “remarkable” that ministers knew they were using over-optimistic pollution modelling, based on flawed lab tests of diesel vehicles rather than actual emissions on the road, but proceeded anyway. It was agreed that both parties would return to court in a week to agree on the next steps. Now Ministers have rejected the court proposal to deliver an effective plan within 8 months, as ClientEarth suggested. The case will now return to court at an unknown future date, when the judge will determine what happens next. An earlier government plan to tackle air pollution was declared illegal in April 2015 and ministers were ordered then to produce a new strategy, which it did in December. But that new plan is the one that was found to be illegal on 2nd November. ClientEarth lawyer Alan Andrews said: “We are disappointed that we have been unable so far to agree on the timetable for the new plan, or on the future role for the court in overseeing compliance with the order. We have made our written submissions and await the court’s decision.” Defra said it would be setting out further measures next year.
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T&E highlights air pollution problem of particulates from petrol vehicles without correct filters
One of the most significant environmental problems of Heathrow, in relation to wanting to add a 3rd runway, is its ability to keep air pollution on local roads down to legal limits. We hear most about Nitrogen Dioxide (NO2) but there is also significant particulate pollution. The tiny particles, especially the smallest (PM2.5) can penetrate deep in to the lung and cause damage. Heathrow has local air pollution monitors, and regularly limits for PM10 and PM2.5 are breached. A recent report, by Ricardo, for the Heathrow area in 2015, said at the LHR2, Green Gates and Harlington sites 3 exceedances were recorded. At another site, Oaks Road, registered 5 exceedances. The AQS (Air Quality Strategy) objective is a daily mean limit value of 50 µg m-3 for PM10 should not to be exceeded. Now clean transport campaigners, Transport & Environment, say we could be on the verge of a "petrolgate" scandal, not unlike the "dieselgate" one, due to inadequate filters to prevent the emission of particulates from petrol cars. T&E say they have obtained documents showing that governments and car makers are delaying ensuring petrol cars have these €25 filters (most diesel cars have them). Governments are using theoretical particle emission, rather than the higher real world ones. T&E says the car industry is lobbying to be allowed to overshoot particle limits, and not to have to install filters.
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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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How the government hopes air pollution will not be a block on a Heathrow 3rd runway
The Government has produced claims that adding a 3rd Heathrow runway would be compatible with air quality limits for NO2. The DfT statement on 25th October stated that the government had done more work, since the Airports Commission, and this "confirms that a new runway at Heathrow is deliverable within air quality limits, if necessary mitigation measures are put in place, in line with the ‘National air quality plan’, published in December 2015." That air quality plan has since been judged inadequate by the High Court ruling in the case brought by ClientEarth. The DfT also said: "Heathrow’s scheme includes plans for improved public transport links and for an ultra-low emissions zone for all airport vehicles by 2025. The government will make meeting air quality legal requirements a condition of planning approval."Lawyers Bircham Dyson Bell comment: "would you build, or invest in, a new runway if you weren’t sure it could be used?" Heathrow and the government hope that, by 2040, 55% of Heathrow passengers will be using public transport, but there is no guarantee whatsoever that legal air quality limits would in reality be met. Currently [2012 data] about 41% of Heathrow passengers use public transport (about 28% by rail and 13% bus/coach - on the road). Heathrow hopes 43% will use rail by 2030. That is estimated to mean an extra over 56 million passengers annually using public transport compared to around 29 million today, and 6 million more passengers travelling to and from the airport by car.
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ClientEarth wins air pollution case in High Court, that government action has been too slow
ClientEarth has won its High Court case against the Government over its failure to tackle illegal air pollution across the UK. In a damning indictment of ministers’ inaction on killer air pollution, Mr Justice Garnham agreed with ClientEarth that the Environment Secretary had failed to take measures that would bring the UK into compliance with the law “as soon as possible” and said that ministers knew that over optimistic pollution modelling was being used. In his ruling, the judge questioned Defra’s 5 year modelling, saying it was “inconsistent” with taking measures to improve pollution "as soon as possible.” Defra’s planned 2020 compliance for some cities, and 2025 for London, had been chosen because that was the date when ministers thought they’d face European Commission fines, not which they considered “as soon as possible.” The case is the second the government has lost on its failure to clean up air pollution in two years. In the judgment he handed down Mr Justice Garnham ruled that the government’s 2015 Air Quality Plan failed to comply with the Supreme Court ruling or relevant EU Directives and said that the government had erred in law by fixing compliance dates based on over optimistic modelling of pollution levels. Future projections of compliance need to be based on real emissions, not discredited lab tests.
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High Court win by ClientEarth on air pollution casts more doubt on the possibility of adding a Heathrow runway
The environmental law group, ClientEarth, has won its High Court case against the Government over its failure to tackle illegal air pollution across the UK. The judge agreed that the UK government had failed to take measures that would bring the UK into compliance with the law “as soon as possible” and ministers knew over optimistic pollution modelling was being used. AEF (the Aviation Environment Federation) says this failure by the government to get NO2 levels down discredits the air quality plan that formed the basis for the Government’s argument that a new runway at Heathrow would neither cause not exacerbate legal breaches in NO2 levels. Required to publish an updated plan for UK air quality, Defra produced one in December 2015. This brought forward the anticipated date of compliance to 2025 for London – just in time for the opening of a new runway according to the Airports Commission’s anticipated timeline. But the plans appeared to rely on new, more optimistic forecasts of emissions from diesel vehicles without presenting substantive policy proposals to actually deliver improvements. A new runway at either Heathrow or Gatwick would lead to higher levels of air pollution, and the new court ruling confirms that compliance should not be based on over optimistic modelling - and government needs instead to take action to cut pollution levels.
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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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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!
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Standard: “Official: Heathrow Airport expansion threatens to worsen London’s air quality”
The Standard reports that according to the government's own analysis, a 3rd runway at Heathrow threatens to worsen air quality in central London. The focus on whether a 3rd runway would worsen breaches of NO2 levels has been on the area around the airport. But a study (by Parsons Brinckerhoff) for the DfT highlighted that adding a runway risks increasing pollution in central London too. The impact would not be large, but it is more likely, in some scenarios, to push NO2 levels even closer to the legal limit or worsen breaches which may still be happening in 2025 due to traffic levels in central boroughs. This is because the wind is westerly for around 60 - 70% of the year in the south east. The new DfT study also raised doubts over whether another Heathrow runway could be opened in 2025 without breaching EU legal limits on NO2. Transport Secretary Chris Grayling has said that meeting air quality legal requirements is a condition of planning approval, but has no concrete proposals to indicate how this could be done. He hopes the 2015 Air Quality Plan by Defra, and new measures around Heathrow, would keep levels down. ClientEarth are currently embroiled in a Judicial Review against the Government on the plan, as it will not improve air quality fast enough (partly due to cost saving). The Defra study was before the truth the "dieselgate" scandal was fully appreciated, or new analysis showing NO2 from diesels is worse than had been thought.