Heathrow Statutory Consultation on the third runway – closes 13th September 2019

The featured image compares the noise environment for 2013 2 runway and 2035 3 runway.

The critical issue for Englefield Green and Virginia Water is that the 2013 (blue line) flight path that now flies over Staines (26% of all Heathrow departures on the Detling route) is moved by the time the 3rd runway opens (blue filled), to fly directly over Englefield Green. So this image depicts the 2035 noise flight paths directly flying over Englefield Green, combined with the Midhurst route (15% of all Heathrow departures), results in 41% of all Heathrow departures flying over the whole of Englefield Green.

A pdf showing some of the key source documentation and our analysis can be seen here

EGAG’s Statutory Consultation Response page with pdf submission

Should I be worried?

Heathrow’s aircraft noise improvement forecast is 4 times the average that industry acknowleges has been achieved over the last many decades, with the industry expecting a similar noise improvement which is 4 times less than Heathrow’s forecast.

Heathrow’s noise forecast for 2035 is based upon a noise improvement that has never been experienced before. In fact from now until 2035 Heathrow’s forecast noise improvement/annum is four times the average, that industry acknowledges has been achieved over the last many decades i.e. 0.1dB/annum, compared with Heathrow’s 0.4dB/annum forecasts. Heathrow have been asked to provide the assumptions that is is based upon, but so far has not responded.

Heathrow’s Statutory Consultation closes on 13th September 2019, and will be used as a basis for the Development Consent Order (DCO) to build the third runway.

The consultation documentation (over 17,500 pages!) can be found here

A number of organisations have provided suggested responses to the Heathrow consultation, which are helpful:

The No 3rd Runway Coalition have put a suggested set of responses which can be found at here. Have a look at the suggested responses and they would like you to show them what you have said so that they can keep a record of the key issues raised. The Coalition do a lot of work in making people aware of the huge adverse environmental consequences of expanding Heathrow. EGAG is an active member of the No 3rd Runway Coalition

If you would rather not respond to the questions but put your response in your own way (perhaps because you think that the questions put by Heathrow presuppose the building of a third runway), the London Assembly has put a superb letter to Heathrow, which they have published here. You will see that Caroline Russell, chair of the Environmental Committee of the London Assembly, sums up the response by saying

“The crux of our response is that the London Assembly opposes the construction of a third runway and any increase in air traffic at Heathrow airport. This committee has reported many times on the air pollution, noise pollution and carbon emissions grounds for limiting air traffic.”

EGAG will be sending in our response and will post to this website our views on how this will affect our area of Englefield Green and those close by.

Teddington Action Group (TAG) have suggested answers posted below – EGAG are heavily indebted to the TAG team, who we work closely with.

This is a brief outline of the online questions in the order they appear below, and feedback must be in answer to these questions. Consultation web page is https://aec.heathrowconsultation.com and instructions on how to respond are at https://aec.heathrowconsultation.com/contact-us

If you choose you could respond by email saying whatever you want at [email protected]

Or by topic area: https://aec.heathrowconsultation.com/topics and we advise keeping a back up copy of what you have posted in case the saving facility does not work. [ED] We have heard from a number of people that, as at the last consultation, work gets lost and people have to start all over again.

If you’d like to respond via a paper feedback form, these are available at each of the events (events have now closed) or upon request via the Contact form details on Heathrow’s website. You can also respond by letter. Both can be sent by addressing the envelope to “FREEPOST LHR AIRPORT EXPANSION CONSULTATION”.

TAG Suggested responses:

Q.    Please tell us what you think about any specific part of our Preferred Masterplan…..

A.    We are opposed to expansion because it will:

  1. Increase noise and create a noise sewer in Twickenham, Teddington and Strawberry Hill. [ED] and enormously in Englefield Green, with upto 8 times more aircraft over the WHOLE of Englefield Green, by moving one of the 6 departure routes, which currently carries 26% of all departures out of Heathrow, from the Detling route which is currenly over Spelthorne and skirting North East Runnymede Borough to the North West of Runnymede Borough, combining it with the Midhurst route (15% of all Heathrow departures), to directly fly over the whole of Englefield Green village and on to Virginia Water.
  2. Adversely affect the health of people within a large area around the airport
  3. Increase air pollution
  4. Make it impossible to achieve the UK’s climate target of zero emissions by 2050
  5. Require large taxpayer subsidies for surface transport and/or increase congestion
  6. Increase pressure on housing, schools, doctors, hospitals and sewerage
  7. Produce negligible economic benefit according to the DfT (Net present value of between -£2.5bn and +£2.9bn and that excludes cost of climate change – or properly reflecting health impacts

Q          Please tell us what you think about the sites……

A.        We are strongly opposed to the destruction of long established residential communities and in addition the widespread environmental damage expansion will cause

Q.        Please tell us what you think of our boundary design proposals…..

A.       260,000 extra flights will have a massively detrimental effect on the environment. It is the wrong place to put an expanded airport because of noise, pollution and safety. [ED] it already significantly affects more people than the 7 noisest European airports combined.

Q.      Do you have any other comments on our Surface Access Proposals?

A.      Will cause even more traffic in an already congested area

Q.      Please tell us what you think of our proposals….to improve public transport access to the airport?

A.      We believe Transport for London’s submission that the cost and demands on public transport have been greatly underestimated

Q.      Please tell us what you think about proposals for Heathrow Ultra Low Emission Zone (ULEZ) and Heathrow Vehicle Access Charge as ways to manage congestion and air quality impacts.

A.     Heathrow has grossly overestimated the effects of these suggestions and underestimated the ability of public transport to cope with increased needs generated by expansion. The M25 is a major artery round London and charging passengers in a ULEZ will have little effect. Heathrow’s proposals to double freight to 3 million tonnes will further clog existing roads and increase air pollution.

Q.     Please tell us what you think of our construction proposals and ways….to minimise effect on communities and environment

A.     We have no comment on this

Q.    Please tell us what you think of our runway alternation proposals….if you think we should alternate runways at 2pm or 3pm

A.     We have significant doubts that the runway alternation and respite proposals as set out in the consultation documents can work in practice. In any event, whilst these proposals could give some daytime or night-time respite, for many communities daytime respite will be reduced from half a day to a third and some communities will get noise for the first time. The overall noise impact will be much greater.

Q.    Please tell us what you think of preferred proposal for ban on night flights and whether you prefer an alternative

A.    The proposed ban is only from 11.00pm to 5.30am. Six and a half hours is far too little sleep for adults and children. The World Health Organisation recommends 8 hours. We also note that those directly east and west of the airport will be exposed to flights just outside Heathrow’s definition of night for the first time. Teddington and Twickenham will be exposed to more noise. There is also a disturbing diagram in ‘Future Runway Operations’ showing the one-hour recovery time and the ‘early morning arrival’ at 5.15am – this is only five and a quarter hours – less than the current night-time quota period. This is totally unacceptable. We believe there should be a full 8 hour curfew on all night flights between the hours of 11pm and 7am.

Q.   We plan to increase the number of arrivals and departures..prior to the new runway opening… Please tell us what you think about our proposals for managing early growth

A.   We are strongly opposed to early growth proposals. They were not in the Airports National Policy Statement. The environmental consequences of 25,000 more flights in addition to the existing 480,000 will be severe, with incoming and outgoing flights going over the same areas (for the first time), greatly reducing respite. Concentrations of arrivals early in the morning (between 6 and 7 am) will cause particularly significant impacts to sleeping patterns. Looking at the noise envelopes, the arriving planes will keep the departing planes beneath excessively low, increasing the noise even further. We are very concerned about the safety implication of doing this in such congested airspace over millions of people.

Q.   Local Neighbourhoods. Please tell us what you think about our development proposals and the measures proposed to reduce effects in your area

A.   There is no proposal for Twickenham and Teddington even though the area will be substantially affected, according to the noise maps. Noise is projected to increase by between 3 and 6 dB LAeq, which is equivalent to a doubling or quadrupling of the number of planes in an area already subject to dreadful noise. However, the impacts could be far worse as these projections have been made using Heathrow’s highly optimistic assumptions concerning fleet transition which may not be achievable in practice. Even if the fleet transition assumption is correct, the numbers of planes overflying our area will be substantially more than twice or four times; there is strong evidence to suggest annoyance is caused by the number of overflights rather than average noise levels. Average noise metrics are incomprehensible to the public and the DCO Consultation documents should have shown numbers of noise events – the public are being misled through this approach.

Q.  Please tell us what you think about our proposals to manage the environmental effects of expansion

A.  Parliament has declared a state of climate emergency and we say that Heathrow expansion is not possible within the greenhouse gas limits set by the Paris agreement or within our domestic legislation. Instead Heathrow airport may need to contract if we are to contain global warning at 1.5 degrees or attain net zero emissions by 2050. If Heathrow expands it will take up 53% of the total CO2 (carbon dioxide) aviation budget of 37.5Mt (million tonnes) but its share of the UK’s air traffic movements now is only 19%. Aviation, with Heathrow expansion, will fail even on an 80% reduction over 1990 values never mind 100% and Government should not be gambling with climate change in this way. The suggestion that this huge quantity of aviation carbon can be offset by carbon capture, such as peat bogs and tree planting, would have the effect of reducing the budget available for other industries when aviation already has far more than its share. Radical action is needed to curb aviation and road transport emissions now. If Heathrow expansion is permitted, then an existing airport of similar size must close.

Q.   Air Quality. Please tell us if there are any other initiatives or proposals that we should consider…to address the emissions from airport related traffic or airport operations

A.   We disagree completely with Heathrow’s assertion that aircraft flying in and out of the airport do not have a significant effect on air quality and that aircraft are so high that emissions are dispersed before reaching the ground. Studies done in Los Angeles and elsewhere have shown concentrations of fine particulate matter under the inward flight path: Heathrow’s air quality monitors are not in positions to capture this and readings would be much higher if they were. Ultra-fine particles are particularly dangerous as they penetrate deep into the lungs and blood stream and may be implicated in the development of dementia. When over 9,000 Londoners die prematurely from air pollution each year, it is scandalous that any plan which will knowingly worsen air quality is even being considered.

Q.   Health. Please tell us what you think about our proposal to help health and well-being….

A.    We think that it’s very unlikely that this project could be carried out without severely harming the health and well-being of a significant number of residents. Noise and air quality issues have not been properly addressed with two runways.

Q.    Noise. Please tell us what factors are most important…for noise management, in particular our proposals for the design and implementation of a noise envelope.

A.    The World Health Organisation guidelines at 40dB Night and 45dB Day are much stricter than the Government Guidance as, although it agrees with WHO aim to reduce noise and adverse health effects, it wants to factor in cost. We believe that if cost is being balanced against welfare then a proper assessment should have been done before the Development Consent Order. The level of LOAEL of 51dB (lowest observable adverse effect level) was not considered by the SoNA (Survey of Noise Attitudes). SoNA was just a poll of around 2000 people already affected by noise; it took no consideration of the effects of change, the desperation of people newly affected by noise, or of the impact of noise under 51dB, whereas the WHO study relied on detailed medical research and a survey of 37,000 people in 10 countries. From the consultation we can see that Teddington may get an average noise increase of up to 6dB – we already get planes flying overhead registering up to 88dB causing massive disruption to Quality of Life. This level of noise has severe implications for public health. In relation to specifying noise envelopes, these should not be designed on the basis of aviation industry generated Quota Counts (QC); rather they should relate directly to noise on the ground. If noise caps are breached for this reason then flight numbers should be restricted until newer, quieter planes are proven and introduced. [ED] from the consultation, Englefield Green will receive an average of 6-9dB increase in aircraft noise, equivalent to 4-8 times the number of aircraft.

Q.    Noise Insulation. Please tell us what you think about our noise insulation schemes.

A.    The noise insulation schemes are totally inadequate as Heathrow only proposes this for homes exposed to average daytime noise of 63dB LAeq whereas the Government LOAEL is 51dB and the WHO strongly recommended threshold is 45dB. If Heathrow were truly concerned about local communities, they would be paying for noise insulation in a radius of 20 miles round the airport. The amounts allowed by Heathrow for noise insulation fall vastly below what it will cost to insulate the great majority of properties. Even so, this mitigation has little benefit as parks, gardens and just being outdoors will be impacted greatly by aviation noise.

Q.    Please tell us what you think of our proposals for maximising new jobs and training…

A.    West London is not short of jobs but is short of accommodation to house people as evidenced by the huge waiting lists for social housing in boroughs surrounding the airport. There is also significant pressure on local schools, hospital and GP practices.

Q.    Please tell us what you think about our approach to addressing effects on the historic environment.

A.    There are many nationally and regionally important historic buildings and parks that will be severely impacted by expansion. These include Bushy Park, Hampton Court Palace, Kew Gardens (a World Heritage site) and Richmond Park, which attracts 5 million users a year and which will be decimated under all the test cases. The noise impact analysis ignores parks which are a key component of Quality of Life around wide swathes of south west London. In this context the policy of concentrating flights over these areas is totally inappropriate.

Q.    Climate Change

A.    We believe expansion would prevent us meeting our climate change commitments and aviation must be curbed rather than allowed to grow at the expense of our planet. Please see response in Environmental Effects above

Q.    Community Fund. Please tell us what you think about our proposals…

A.    We are not in a position to comment

Q.    Property and Compensation. Please tell us what you think about our interim Property Policies, including our general approach to buying properties and land and our approach to compensation, including our discretionary compensation offers.

A.    Given that the WHO ENG 2018 identifies 10% of the population is ‘highly annoyed’ by noise levels as low as 45 dB, many noise sensitive people will feel compelled to move. Heathrow should meet all of their costs under the ‘polluter pays’ principle under a much wider compensation scheme.

Q.    Growing within environmental limits… Please tell us what you think of our proposed approach to manage the future growth of the airport within environmental limits.

A.    The proposed Independent Parallel Approach is likely to cause very serious noise and health issues since it inflicts noise on both sides of the airport at the same time – reducing any periods of respite. There is also a danger that this may become permanent if the third runway proposal becomes too expensive – highly likely after the recent application to the CAA for an increase of 100% of the early funding costs before the runway is even built.

Q.    Development Consent Order. Do you have any comments on..DCO…

A.    We have nothing further to say at this stage

Q.    Do you have any other comments in response to this consultation?

A.    We have nothing further to add at this stage

Published by Teddington Action Group   http://www.teddingtonactiongroup.com Twitter: @TeddingtonTAG                Facebook group: Teddington Action Group

1 comment on Heathrow Statutory Consultation on the third runway – closes 13th September 2019

  1. Building 3rd runway at Heathrow is completely mad! NO to Heathrow expantion!

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