Response* to Heathrow’s Consultation

General comments on the ‘consultation’

There has already been an official government consultation on the Airport National Policy Statement (NPS) which proposes a third runway at Heathrow. The responses are being analysed now. If the government decides to support a third runway, if it is supported by a vote in Parliament and if it survives a legal challenge, Heathrow Airport will then apply for a Development Consent Order (DCO). This is the equivalent of a planning application. There will then be another official consultation.
The current ‘consultation’ is being run by Heathrow is not an official consultation. It is not bound by rules of balance, transparency or impartiality that apply to government consultations. The recipient of the responses, namely Heathrow Airport, is under no obligation to take notice of any comments made or demonstrate that it has done so. This ‘consultation’, better called a ‘pseudo consultation’, clouds the issue of Heathrow expansion for the general public, who cannot be expected to understand that this is a partisan, non-official ‘consultation’ which will inevitably be used by Heathrow for public relations purposes.
Heathrow Airport is arranging a series of consultation exhibitions/events in West London and London. This greatly exceeds the official programme of events from the government (Department for Transport). By ‘out-gunning’ the government, Heathrow Airport hopes that its ‘consultation’ will drown out the more impartial government consultation. Principles of accountability and democracy are at stake here.

Heathrow’s trap

Heathrow’s ‘consultation’ is a trap! Heathrow wants people to think that a third runway is a done deal. The ‘consultation’ then leads them down the path of discussing various options for a new runway. This is colourfully illustrated in a tweet from Richmond & Twickenham FOE: “Heathrow consultation – here’s how it works:
Heathrow: would you prefer – i) having your finger cut off or ii) losing your whole arm? (no option to say neither)
Result: most people opt for i)
Heathrow press release “99% of locals said they’d support having their finger cut off”

Mis-information

The deceit and mis-information starts in the Forward by John Holland-Kaye on page 1. It says expanding Heathrow will create “up to £187 billion in economic benefits”. No evidence is given for this figure. The official estimate by the government for net economic benefit (expressed as ‘Net Present Value’) is a range of -£2.2 billion to +£3.3bn over 60 years. The net economic benefit is at worst negative and at best negligible (compared with the UK’s GDP of about £2 trillion pa, a benefit of £3.3bn over 60 years is negligible and invisible).
The deceit and mis-representation continues throughout the ‘consultation’. A few examples are hinted at in the suggested responses to consultation questions.

The prisoners’ dilemma

Communities concerned about expansion have a dilemma with the consultation. If they don’t respond, Heathrow will claim few people are bothered about expansion generally or the options for it. But if they do respond, Heathrow will just publicise how people preferred some options to others and ignore any responses that point to the fact that all their expansion options are negative in terms of land-take, Green Belt, homes, communities, noise, air pollution, climate change, congestion on road and rail, burden on taxpayer, etc.
A compromise approach is to respond to the consultation but to make sure you are not led into giving any answers which Heathrow can readily subvert and use in their propaganda. Suggested responses follow.
Before launching into suggested responses, a plea. Don’t spend too much time responding. Remember, this consultation has no official status – it is a public relations exercise run by Heathrow. Heathrow is under no obligation to take any notice of what you say. Please use your valuable time to support the campaign against a new runway.
If you do respond, keep a copy, particularly important if you respond online. Copies of your response (with covering note and maybe headlines) copied to your councillor, MP and the press are at least as useful as those to Heathrow.

Suggested responses to Heathrow’s question

Q1a. Please tell us what you think about Heathrow’s plans to expand the airport.

I am strongly opposed to a third runway.

Q2a. Please tell us what you think about the options for the new runway

All options have significantly adverse impacts in terms of land-take, Green Belt, destruction of homes and communities, noise, air pollution, climate change, wildlife and habitats, heritage, congestion on road and rail, burden on taxpayer, etc as compared with no third runway. There is not even, according to official government estimates, a significant net economic benefit of a third runway.

Q2b. What factors do you think should be important in fixing the precise location and length of the runway?

All the options have a range of adverse impacts of the types mentioned in answer to Q2a.

Q2c What factors do you think should be important in locating new terminal and apron space?

None of the options avoid the impacts mentioned in the answer to Q2a

Q2d What factors do you think should be important in deciding the location of new taxiways?

None of the options avoid the impacts mentioned in the answer to Q2a
Q3a Please tell us what you think about the re-positioning of the M25.

I am opposed to re-positioning the M25.

Q3b Please tell us which family of options you prefer for the alterations to Junctions 14 and 14a and reasons why.

I do not support any of the options.

Q3c Please tell us which option you prefer for the diversion of the A4 and the reasons why

I do not support any of the options.

Q3d Please tell us which option you prefer for the diversion of the A3044 and the reasons why.

I do not support any of the options.

Q3e Please tell us which option you prefer for the Stanwell Moor junction and the reasons why.

I do not support any of the options.

Q3f Please tell us what you think about the options to improve access to the Central Terminal Area.

I do not support any of the options because access is satisfactory with two runways.

Q3g Please tell us what you think about the options for the diversion of rivers and the approaches to replacement flood storage.

I oppose all the options, none of which are necessary with two runways.

Q4a Please tell us what you think about the locations and sites that we have identified as being potentially suitable for airport supporting facilities.

I am opposed taking up greenfield and brownfield land with more airport supporting facilities.

Q4b Please tell us what you think about our approach to providing car parking and the potential site options we have identified.

I am opposed to taking up greenfield and brownfield land with new car parks. If Heathrow were not planning to increase the amount of car travel, and instead intended any growth to be taken up by public transport, extra parking would not be needed.

Q4c Do you have any comments on the land uses that will be affected by Heathrow’s expansion.

Yes, the changes are overwhelmingly negative.

Q4d 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.

No comments.

Q4e Please tell us what you think about the locations and sites that we have identified as being potentially suitable for airport related development.

The impacts on these locations and sites are overwhelmingly negative and would not be needed without a third runway.

Q4f Do you have any views on how the demand for additional airport related development such as hotels and offices might best be delivered?

There would not be demand for these without a third runway.

Q4g 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.

I do not consider a masterplan should be developed until if and when the government agrees to a third runway and until any conditions, such as limits on use due to air pollution, are finalised.

Q4h 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.

The impacts on these locations and sites are overwhelmingly negative and would not be needed without a third runway.

Q5a Please tell us what you think about our property policies.

No comments

Q5b. A noise envelope is a package of measures that can be used to reduce noise. Please tell us your views on the objectives of the noise envelope and the timeline for its development.

A noise envelope is NOT a package of measures. Therefore I cannot answer this question directly.
The objective should be to minimise the totality of noise for all those people overflown or close to flight paths, taking account of both the numbers of people in any location and the level of noise they experience.

Q5c. Is there anything further we should be considering to reduce noise?

The most effective means of minimising noise is to restrict the number of flights to the present cap.

Q5d. Please tell us what you think about our suggested approach to the provision of respite.

The consultation is highly misleading in that it emphases “predictable” respite while ignoring the amount of it. The reality is that with a third runway, respite would typically be reduced from half to one third. Such reduction in respite is more important than the occasional breach of the current respite.

Q5e. Please tell us what you think of our proposals for noise insulation and phasing of delivery.

I believe that in in addition to noise insulation, full compensation should be provided to all citizens affected by noise, whether they get insulation or not. (Insulation would reduce the compensation needed but not obviate it because noise insulation does not alleviate any problem outside the building.)

Q5f A 6.5 hour night flight ban on scheduled flights is required between 11pm and 7am. Our current preferred option for this is from 11pm to 5.30am. Please tell us when you think the night-flight ban should be scheduled and why.

A 6.5 hour ban is insufficient – adults and children need more than 6.5 hours sleep. The proposal, at face value for arrivals, is better than the current 4.30 am start time, but for departures it is 30 minutes earlier than current operations permit, i.e. departures currently start at 6.00am. There should be a complete ban on all flights from 10pm through to 7am apart from emergencies.

Q5g Please tell us what you think about the priorities and initiatives we propose to use to develop our surface access strategy.

The priority should be to ensure there is no increase in road traffic. This would mean no need for destructive new car parks or more road capacity.

Q5h Please tell us what you think about the options to use road-user charging to reduce emissions and to manage vehicular access to the airport.

Road user charging is not a matter over which Heathrow Airport has any control (except within the confines of its property). It should therefore be the subject of government consultation, not Heathrow’s.

Q5i Please tell us what you think about the measures proposed to manage emissions. Are there any other measures that we should consider?

The consultation document says: “Expansion can be delivered while meeting all relevant legal air quality obligations” (page 58). This is profoundly misleading and no evidence is given for the assertion. It has been determined by the courts that the government has no tenable plan to meet legal air pollution limits, even without a third runway. A third runway would make air pollution worse as compared with two runways.
There are no proposals that would make a significant difference to air pollution levels. Section 4.4 of the consultation document is unspecific and qualitative.
Airport ground-based sources contribute only a small proportion of the total emissions due to Heathrow. Aircraft have a vastly higher emissions, while emissions from airport-related road traffic are also considerable. To have a significant impact on air pollution, action would need to be taken on these sources.

Q5j Do you have any comments on our approach to limiting carbon emissions from the design, construction and operation of an expanded Heathrow?

The vast majority of carbon (dioxide) emissions are from the extra aircraft that Heathrow is promoting. I see no proposal that would appreciably offset this increase.
There is no mention of the impact of Heathrow expansion on the UK’s obligations in the Climate Act. The Committee on Climate Change advised government that it would probably be just possible for the UK’s target at 2050 to be met if UK’s aviation’s emissions were constrained to 37.5 million tonnes of CO2 pa. However, they noted that this would require other sectors to make even more stringent cuts – about 85% instead of 80%. This will place huge pressure and perhaps economic and financial cost on these sectors. Lack of mention of such issues in the section 4.5 of the consultation document is deceitful.
There is no recognition in the consultation of the significant greenhouse-causing emissions at altitude from the extra aircraft (NOx and H2O).

Q5k Please tell us what you think about our approach to natural environment issues.

I do not support an approach which where it is cynically planned to destroy habitat and therefore wildlife.

Q5l Are there any opportunities that the expansion of Heathrow could provide to enhance the natural environment?

I am not aware of any.

Q5m Please tell us what you think about our approach to historic environment issues.

I do not support an approach whereby heritage sites will be destroyed or adversely impacted.

Q6. Having considered everything you have read, do you have any further comments in relation to our proposals for the expansion of Heathrow?

The consultation should have made it clear that this is not a statutory consultation. It should have been explained clearly at the outset that statutory consultations on the NPS have been carried out and results are still being analysed. Furthermore, that statutory consultation will take place on the proposed Development Consent Order. Absence of mention means that respondents are given a misleading impression of the context and status of this privately promoted venture.

* Thanks go to Nic Ferriday of WLFOE.

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