DfT Consultations on Heathrow Third Runway and Airspace Modernisation

The DfT is keen to hear your views on Heathrow expansion and airspace modernisation.  All submissions need to be received by 25 May 2017. It’s really important that we all make our views known.

We’ve tried to make this easy. Below you’ll find a list of suggested points for each consultation; you might like to cut and paste the points that most resonate with you (and add to your own submission) and send to the DfT via the links given here.

Suggested points for the airports (Third Runway at Heathrow) consultation:

General observation: The consultation leaflet was not delivered to a significant number of local residents, and the consultation presentations seemed to be an elaborate PR exercise. The DfT website itself sets out benefits but none of the costs to local communities.

• The DfT has not provided proposed new routes for public consideration and comment. How can local residents be expected to comment when fundamental information that will affect their lives in the future has not been given?
• Aviation is clearly vital for the whole of the UK, however why should expansion be concentrated on the south east?  Job creation and boosting the economy would be better placed in other areas of the UK.
• The south east is already overheated in terms of infrastructure, housing and employment opportunities.
• Who will pay for the cost of road infrastructure? Heathrow have capped their liability to £1bn, yet the estimated costs range from £15 to £20bn? The taxpayer cannot be expected to pick up the bill!
• Heathrow currently breaches air pollution levels. To say that by 2030 air pollution will be less than now is based on hope over reality. 
• Heathrow will restrict competition at the expense of regional airports.
• London is overflown by a factor of three times more than any other European capital city – it is in the wrong place and a new runway at Heathrow would subject an additional million people (not currently affected) to air and noise pollution, which is clearly unacceptable.
  • No government concerned about the environment and people’s health should consider subjecting such an increase in population to the proposed substantial additional aircraft noise resulting from a third runway.
    • China now builds their airports away from areas of population.
    • Norway moved Oslo’s airport 20 miles away from Oslo due to the environmental problems.
    • Frankfurt, the next noisiest airport in Europe, affects less than a third of the number of people to significant aircraft noise annoyance.
      • The last runway built at Frankfurt 4 years ago regularly receives up to 1200 protesters a day in a week in the terminal building, protesting against the aircraft noise.
    • Sydney airport’s third runway, as outlined in a report by our own parliament, led to an immediate outcry from residents who found themselves significantly disturbed by noise, despite living outside the area designated as likely to be significantly affected during the planning process. The link to the website is here or to download the pdf here,
• There is incorrect ‘balance of weight’ to the aviation industry at the expense of the public interest (Helios report in 2016). The belief that the northwest runway at Heathrow is the best option is to surrender to corporate pressure
• The DfT state that some of the planning requirements for Heathrow to secure expansion are ‘advisory’. There is no force of law to ensure “robust safeguards” or significant commercial penalties if breached.
• There is concern regarding the relationships between the CAA, NATS, Heathrow, the DfT and the aviation industry: it cannot be regarded as unbiased.
• Aircraft noise already exceeds guidance levels set by the World Health Organisation.
• Aircraft noise has the potential to have significant impact on health with an increase in aggressive behaviours; increase in stress hormones and blood pressure levels, and a reduction in child development.  Expanding Heathrow by more than 250,000 aircraft movements per annum will inevitably increase noise pollution and the frequency of noise, which is deemed to be the major irritant.

Financial benefits

In its consultation materials, DfT has quoted a figure of £61 billion economic benefits.  This is totally misleading because it is a ‘gross’ economic benefit, that is benefits without the corresponding economic and financial costs being subtracted.  The proper basis for making a decision on an infrastructure project such as this is clearly NET economic benefit, where costs are subtracted from benefits.  Not cherry-picked gross benefit figures.  Infrastructure projects are routinely evaluated on this basis, using DfT’s own guidance, to give a ‘Net Present Value’ (NPV).

The £61bn is stated in the consultation leaflet as “expected economic benefits to passengers and the wider economy”. That figure is consistent with a figures derived from the DfT document ‘Further review and sensitivities report’ published Oct 2016.  ES2 (page 9) of that report shows “total benefits” as £59.2 to £61.1bn.  But crucially, that benefit figure is before all the costs are subtracted.

The same table shows that after costs are subtracted there is a NET economic benefit of £0.2 to 6.1bn (expressed as “Net Present Value”).  That is, a figure of one tenth or less!  If a single figure is to be quoted in the interest of simplicity, it has to be the Net Present Value.  To quote benefits of £61bn without costs is utterly misleading.

While it may still sound a lot, an NPV of £6.1bn is negligible in the context of the UK economy.  It is a benefit over 60 years and it is equivalent to just a fraction of the cost of a cup of coffee for each airport passenger.

Crucially this report was withheld to full cabinet, when the decision to go for Heathrow’s 3rd runway, was voted upon by the full cabinet.

Ref: https://www.gov.uk/government/publications/airport-expansion-further-review-and-sensitivities-report

On a local level:

• Englefield Green is some 235 feet above Heathrow i.e. the highest point in the vicinity and as such aircraft fly lower over this area: this should be taken into consideration when deciding on routes as local residents suffer greater noise pollution.
• Englefield Green has suffered a significant increase in flight activity over recent years (as indicated in an independent report by PA Consulting, commissioned by Heathrow).
• It is unacceptable that Englefield Green should should bear the brunt of increased noise as a result of the third runway (evidence provided by 3rd runway Noise Contour maps at DfT consultations Feb/March 2017).

Click here for the DfT site which gives more information (scroll down the page to make a submission online or to access addresses for email/letter submissions).

Suggested points for airspace modernisation consultation:

• Airspace modernisation may ‘improve operational efficiency,’ but at what cost to local communities?
• Airspace modernisation may ‘help manage the rising number of aircraft,’ but at what cost to local communities?
• Airspace modernisation may allow NATS to direct aircraft more precisely on direct routes that use less fuel, but at what cost to local communities?
• Airspace modernisation in which aircraft are directed down narrow corridors at increased frequency is of benefit to airports situated away from local communities, not an airport such as Heathrow which is located within heavily populated areas.
• Heathrow have maintained that airspace modernisation is not associated with airport expansion, however Martin Rolfe, chief exec of NATS has warned that ‘under the current system …expanded capacity, such as from a third runway at Heathrow Airport will not be used.’ Airspace modernisation is therefore part of a cynical plan to increase capacity and operations, benefitting airports, airlines and passengers, but at what cost to local communities?
• The underlying need to reduce noise will not be tackled as part of modernisation. Much vaunted new-age aircraft such as the A380, with heavier loads, struggle to reach steeper ascents and are therefore noisier over communities closer to the airport. Additionally ‘Any decrease in noise will have only a marginal impact given the likely increase in number of aircraft.’ Tim Johnson, AEF Director.
• Offers of compensation for communities (such as Englefield Green) that find themselves newly affected by increased noise levels will not be sufficient to make up for reduced quality of life.
• The Independent Commission on Civil Aviation Noise (ICCAN) body appears to have ‘no teeth’ or powers, not just to influence but to enforce. The data that ICCAN works from should be raw data rather than ‘processed’ data provided by Heathrow. ICCAN should report on airspace use compliance on a regular basis: monthly (for example), rather than, (for example), annually, which would ensure operators comply more rapidly.
• Some communities have the potential to become ‘noise sewers’ without robust safeguards to protect them from the adverse impacts of airspace modernisation.

Click here for the DfT site which gives more information (scroll down the page to make a submission online or to access addresses for email/letter submissions).