Heathrow Consultation

Response* to Heathrow’s Consultation

Deadline – 11.55pm 28 March 2018

Our response

Runnymede Borough Council response

TAG response

No3R response

AN3V expansion response

AN3V airspace response

The AEF perspective

Responses can be made:

  • Write to : Freepost LHR AIRSPACE CONSULTATION;
  • To feedback on the expansion consultation send an email to [email protected]
  • To feedback on the airspace consultation send an email to [email protected]

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”


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.

Heathrow Consultation: Roadshow in Englefield Green: Wednesday 14 February 2018, 12pm-8pm: The Village Centre, Victoria Street, ENGLEFIELD GREEN TW20 0QX


Heathrow is promoting two consultations simultaneously, one in relation to Airport Expansion (new runway and terminal infrastructure); the other in respect of Airspace Principles (changes to airspace and flight paths to accommodate the new runway).

The consultation documents can be found at www.heathrowconsultation.com

The deadline for responses is 28 March 2018.

Status of consultations

Both consultations are, in EGAG’s opinion, premature. Parliament has yet to vote on the National Policy Statement (NPS) issued by the Department for Transport (DfT) that would be a precursor to Heathrow expansion. It will not consider the NPS until later this year – and crucially after the parliamentary Transport Select Committee (TSC) issues its report following detailed examination of the proposals. The TSC will then commence writing its report.

The timing of the consultations is regarded by EGAG to be part of a publicity initiative by Heathrow to give the impression that approval of a third runway is a formality. Whilst this is currently the Government’s preferred option, approval is not a foregone conclusion. The TSC has found many holes in the DfT’s evidence base for a third runway and Heathrow’s proposals (which now seem to differ from each other in a number of respects).

Consultation on Airport Expansion

This deals with the physical aspects of the third runway proposals. It is non- statutory and voluntary on the part of the airport and communities. It is recommended that if you oppose expansion of the airport that you base your response on this, making your opposition clear but otherwise not spending much time on it.

Consultation on Airspace Principles

This consultation could have more serious and far reaching implications for our community. Although Heathrow’s documentation states it applies to a third runway, actually it applies to airspace modernisation, which is something the Government has signed up to introducing across the UK – whether or not Heathrow is expanded. However Heathrow cannot expand without airspace modernisation as the South East is at capacity in terms of airspace.

People living in Englefield Green will have experienced the full horrors of PBN (performance based navigation – satnav technology) that was trialled in 2014. This met with massive protest – over 2,500 people signed the Englefield Green petition and EGAG grew out of this. Heathrow had to abandon the trials early. PBN involves extreme concentration of flights – making normal life for those living under flight paths impossible.

The consultation alludes to this ‘divide and rule’ approach which until recently has been official government policy (minimising the number of people ‘significantly affected’ using discredited average sound level bases of measurement). EGAG considers that PBN will lead to the creation of what has been described by the Civil Aviation Authority as ‘noise sewers’. As our area lies under multiple flight paths, especially given new technology to concentrate to a great extent and the possibility of 54% more flights with a third runway, this represents a massive threat to our quality of life and community.

As the Airspace Principles consultation has legal status under the DfT’s new airspace change processes, EGAG considers it is very important that the public respond to this consultation.

In formulating responses to the consultation it is suggested your comments could include;

  • No to extreme concentration
  • Increase heights of departures to reduce noise on the ground for departure and arrivals
  • There should be a ‘fair and equitable distribution’ of flights over our heads.
  • Existing flight paths should not be intensified (the Government may see this as an easy option). The aviation industry should be placed under an obligation to devise an action plan to comply with World Health Organisation noise standards.
  • Focussing flight paths over major open spaces is also unacceptable. Places like Richmond, Bushy, Windsor Great and Home Parks, as well as Kew Gardens are key recreational resources for local residents, as well as being assets of national importance. As well as destroying their amenity, the communities overflown before the parks are reached will be decimated by aviation noise.
  • A reduction in the night period for those under departures to 11.00 pm to 5.30 am, as proposed with Heathrow expansion is totally unacceptable.
  • There should be much more stringent controls over late evening and early morning  flights – both in terms of numbers and the loudness of the planes that are permissible.

You may have other points you would like to raise in your responses, please follow links below to other considered questions/responses that might be helpful.

EGAG Consultation advice response

Consultation – possible questions

No3R Briefing

West London Friends of the Earth

EGAG proposes to issue further guidance on its website as the consultation progresses.

You can email us or sign up to our mailing list via our website to ensure that you receive further updates. https://www.englefieldgreenactiongroup.com/contact/


Last Chance: Have your say – The Revised NPS for Heathrow’s 3rd Runway closes today at 11:45pm

19th December 2017

You can do it online, email or write.



The revised documentation consists of over 2,500 pages with radical changes from the original NPS, but below are some ideas that may help in your response.




No3R video

Hillingdon Cabinet meeting transcript


Overflown communities demand government action to reduce aircraft noise

May 22 2017

With the General Election less than one month away, nearly 40 community groups (including Englefield Green Action Group who are AEF members) representing hundreds of thousands of people, including many AEF members, today delivered a statement to Number 10 warning the next novernment that it must prioritise introducing tougher regulation to deal with the adverse impacts of aircraft noise.

Charles Lloyd of the Aviation Communities Forum, who co-ordinated the statement, said:

“Anyone who lives near an airport expects some noise.  But the changes caused by new concentrated routes – motorways in the sky – and the growth in flight numbers are having unacceptable affects on people’s lives, up and down the country.”

“For far too long the aviation industry has been unaccountable and able to do virtually what it wants in the skies.  The industry has little interest in its impact on people on the ground and there’s no proper regulation to hold it to account. The Government’s hands-off attitude needs to change: communities near airports and under flight paths are no longer willing to be ignored.”

“Frustration is reaching a boiling point: people can’t sue the industry because its exempt from noise laws, there’s no noise regulator to turn to, the industry plays pass-the-parcel if you try to get things changed and they don’t even have to pay compensation if they destroy your health or the value of your house.”

Despite the election, the government consultation on the design and use of airspace policy, which makes no pretence of its ambition to ‘upgrade’ UK airspace in order to ‘unlock the national and social economic benefits which a thriving aviation sector offers’, remains open until the 25th May.

Today’s community statement calls on the next government to:

  1. Set ambitious noise reduction targets. These should be in line with those recommended by WHO. Any growth in flight numbers should be conditional on the achievement of these targets.
  2. Create a regulatory body that will require and enforce achievement of these policy goals.
  3. Provide full compensation in the cases where aviation noise cannot be brought within acceptable thresholds, in line with the polluter pays principle.

A full copy of the statement can be read here.



Have your say: DfT Consultations

Remember the trial flights of 2014? These could become permanent over Englefield Green, unless you take action NOW!

Two crucial Government consultation processes close on 25th May 2017, the outcome of which will have far reaching consequences for the South East of England and critically Englefield Green.

The two Government consultation processes closing on the 25th May 2017 are:

  1. NPS – National Policy Statement on new runway capacity and infrastructure at airports in the South East of England.
  2. UK Airspace Policy – The modernisation of airspace to allow greater concentration of aircraft in our skies, using GPS technology (enabling aircraft to fly effectively down the white line of a road each and every time as opposed to the current dispersion of aircraft achieved across a defined 3km lateral swathe).

Using the same GPS technology used during the trials of 2014 and an increase of 54% of flights that the 3rd runway brings and given the low population density of Englefield Green, as identified by the government’s Civil Aviation Authority (CAA) Dr Darren Rhodes in his noise contour designs (see Fig. 1 & 2) around Heathrow, used by the DfT in their recent Heathrow Northwest Runway Consultation exhibitions at 20 locations around Heathrow, Englefield Green will experience unprecedented levels of aircraft noise that will make the trial flights of 2014 seem like a quiet day in a monastery.

Fig. 1 – 2013 16hr day average noise contour (Englefield Green boundary highlighted in Red)
Fig. 2 – 2030 16hr day average noise contour (Englefield Green boundary highlighted in Red)

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