RBC response to Heathrow’s 2018 consultation

Runnymede Borough Councils response is based on part of the Corporate Management Committee of the 22 March 2018 publication, the draft full text can be found here

The Heathrow Consultation responses are extracted below.

An amendment to the draft proposal: The Committee asked to add an opening sentence to the Heathrow Consultation response that RBC as a council oppose an expanded Heathrow. 

RESPONSE TO HEATHROW AIRPORT’S CONSULTATIONS (CORPORATE SERVICES)

Synopsis of report:

Heathrow Airport are currently seeking feedback on two consultations related to
their proposal for a third runway. These consultations are a Airport Expansion
Consultation and an Airspace Principles Consultation. Both consultations have
a deadline of 28 March 2018.
Officers are submitting the consultation responses recommended by the
Council’s Heathrow Airport Expansion Member Working Group as shown in
Appendices ‘B’ and ‘C’, in order to represent the interests of Runnymede.
Recommendations:
The submission of the proposed Airport Expansion Consultation response at
Appendix ‘B’ and the proposed Airspace Principles Consultation response at
Appendix ‘C’ be approved as the Council’s responses.

1. Context of the report
1.1 The UK has the third largest aviation network in the world, and London’s airports
serve more routes than the airports of any other European city. However, London
and the South East are now facing longer term capacity problems. Heathrow Airport
is operating at capacity today, Gatwick Airport is operating at capacity at peak times,
and the whole London airports system is forecast to be full by 2040. On 25 October
2016 the Government therefore announced its preferred scheme for meeting the
need for additional airport capacity in the south-east of England is a new north-west
runway at Heathrow Airport.
1.2 The aviation industry is a major contributor to the UK economy. It supports
thousands of jobs and delivers billions of pounds in economic and social benefits.
Aviation can, however, also have negative impacts on communities surrounding
airports.
2. Report
2.1 Airport Expansion Consultation
2.1.1 The Airport Expansion Consultation document provided by Heathrow Airport seeks
general views related to its plans for expansion, plus proposals for: road network
changes; water course changes; land use changes; proposed development site
locations; property policies; objectives of the noise envelope; noise insulation; a
noise respite period; priorities and initiatives related to a surface access strategy;
emissions management; natural environment issues; and site specific proposals.
The proposed Council response for this consultation, as recommended by Officers
and the Heathrow Airport Expansion Member Working Group, can be found in
Appendix ‘B’.
2.1.2 It should be noted there are a number of questions that Officers and the Heathrow
Airport Expansion Member Working Group have not drafted a response to because it
is felt that either they do not directly impact Runnymede, or it would be completely
unrealistic to request Runnymede benefits, or because we do not have the
associated expertise. These questions are listed at the end of Appendix ‘B’.
2.2 Airspace Principles Consultation
2.2.1 For the Airspace Principles Consultation, Heathrow Airport are seeking feedback on the six key design principles titled: Flight paths; Urban and rural areas; Urban areas;
Noise and emissions; Technology and innovation; and Night flights. The proposed
Council response for this consultation, as recommended by Officers and the
Heathrow Airport Expansion Member Working Group, can be found in Appendix ‘C’.
2.3 Next steps
2.3.1 Following the consultation and Parliamentary scrutiny, if the Secretary of State
decides to proceed, a final Airports National Policy Statement will be laid before
Parliament. If this is successful, the final Airports National Policy Statement will be
designated. Following its designation it will be used by Government as the primary
policy source against which any Development Consent Orders for expansion at
Heathrow will be assessed.
3.0
Conclusion
3.1
After reviewing the consultation documents provided by Heathrow Airport, Officers
and the Heathrow Expansion Member Working Group recommend Corporate
Management Committee Members approve the submission of the consultation
responses in Appendices ‘B’ and ‘C’, in order to represent the interests of
Runnymede.

APPENDIX ‘B’
Heathrow’s Airport Expansion Consultation (Heathrow questions in red)

RBC Draft response

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

Whilst it is recognised there will be significant national benefits for the economy in  creating a third runway at Heathrow Airport, Runnymede Borough Council remains extremely concerned about the impact on its local community. The harmful impacts will reach a far wider area than any Development Consent Order (DCO) ‘redline’, and if the benefits of the airport beyond the ‘redline’ are to be highly regarded, then so must the harmful impacts.
These impacts particularly include the implications for air quality associated with surface access and the direct noise implications for residents as well as those using the public open spaces in the Borough.

Please tell us what you think about the re-positioning of the M25.

We are concerned about the level of disruption that will likely occur in repositioning the
M25. We feel every effort should be made to minimise disruption through there being
appropriate targets with the delivery agents. Failure to meet the targets should result in
heavy sanctions given the importance of this motorway to the network.

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

We understand that all three runway options will result in the M25 needing to be
repositioned. However, if the different options result in significantly different levels of
disruption to the M25 then we feel this should be an important consideration in the cost
benefit analyses of the different options.

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

The consultation proposes that the Colne, the Wraysbury, The Duke of Northumberland and Longford Rivers are to be culverted. Only the Colne Brook is to be diverted as an open river.
The Water Framework Directive requires that water bodies should attain a good ecological status or potential (in the case of heavily modified water bodies). Nothing should be done to reduce the status or potential of a water body. Nor should anything be done that would prevent the status or potential being improved. The proposal to culvert these rivers is thus contrary to the provisions of the Water Framework Directive.

The Environment Agency in their river byelaws require that an 8 metre strip from the top of the river bank should be maintained and free from development. This can be viewed as the habitat connectivity referred to in the consultation document. This corridor should try to minimise the ecological impacts on the water body.

The consultation document does mention briefly habitat connectivity and the photo on page 32 shows “how we have successfully re-routed rivers as part of previous
developments”. The photo shows two heavily engineered channels with a strip of grass
going down the middle. Although there does appear to be vegetation in the channel at the top of the photo, it is difficult to see whether in this case the habitat connectivity is all that is to be desired. It would be hoped that any future diversion channels would be more natural and provide better habitat connectivity.
It appears that some of the proposals are based more on expediency and cost as opposed
to making sure that the development has the minimum impact on the local environment and ecology.

The building in the floodplain will require the provision of floodplain compensation. The
consultation document identifies that the river system in the Colne valley is complex and that it is prone to flooding. It does not address the implication on the local fluvial flood risk beyond that created by the construction of the new runway. Again, it appears that some of the proposals are based on expediency and cost.

Please tell us what you think about the locations and sites that we have identified as
being potentially suitable for airport related development. Do you have any views on
how the demand for additional airport related development such as hotels and offices
might best be delivered? 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 (see
pages 40 and 41)?

Runnymede Borough Council believes that all essential development to meet the functional operation of the airport should be considered as part of the master planning of the airport, with the necessary airport related development that must have immediate proximity being sequentially preferable for sites within the airport boundary, and expanded as necessary.
Other uses of land that benefit from being in the locality of the airport but do not have a
functional link, such as international scale corporate offices, should specifically be excluded from the scarce land within the airport boundary and opportunities to locate and support them in the wider sub-region, utilising the sustainable transport links necessary for the passenger transport improvements, should be taken to ensure the wider local area shares equally in the economic opportunities associated with your proposal.

Please tell us what you think about the locations and sites that we have identified as
being potentially suitable for airport supporting facilities. Please tell us what you think
about our approach to providing car parking and the potential site options we have
identified (see page 39).

We feel that any parking provision should closely align with the surface access strategy and air quality targets.
We would also like to make Heathrow Airport aware that there is already a problem with airport users parking in our local residential roads and streets in order to avoid the higher charges associated with parking at and around the airport. An expanded airport is likely to exacerbate this problem and we feel additional support should be provided by the airport to help manage this problem.

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. Is there anything further we should be considering to reduce noise?
Please tell us what you think about our suggested approach to the provision of
respite. Please tell us what you think of our proposals for noise insulation and
phasing of delivery. 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.

The impact of noise from any expansion at Heathrow airport remains of significant concern to Runnymede Borough Council and its affected communities.
The consultation document states it is your committed goal to expand Heathrow while
affecting fewer people with noise. It also states that key to the development of noise
measures will be the feedback you receive from communities and local authorities affected by aircraft noise. Given these points and the strong links between noise areas and flight paths, we would like to make a strong plea for a wider dispersal of flight paths in order to distribute noise more fairly. Whilst this will mean affecting more people, it will at least give a greater respite to those that would otherwise be in a concentrated flight path.
Runnymede Borough Council would also very much welcome being given the opportunity to have a representative on your Noise Envelope Design Group.
Para 6.46 of the draft NPS consultation document states that, ‘Heathrow Airport has also
committed approximately £700 million to insulate residential properties closest to the airport, where 160,000 households could be eligible. It has also pledged up to £40 million to insulate schools and community buildings affected by noise from aircraft’. The consultation document provides a boundary of where it is intended compensation for noise insulation measures will be offered. We feel this boundary is premature when the flight paths and the principles of the flight paths are yet to be determined. We also feel it is important that we are given an opportunity to comment on particularly sensitive locations e.g. Commonwealth War Graves Commission memorial in Englefield Green, that may be affected once firmer proposals for the specific flight paths are available.
With regards to the night-flight ban, we feel the Airport Commission’s proposal of a ban
between 11:30pm-6am will be generally less disruptive to the local communities than your proposed times of 11:00pm-5:30am and so favour the Airport Commission’s proposal.

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

It is the Council’s view that significant surface level public transport improvements are
needed just to serve the existing airport – including the Western Rail Access and Southern Rail Access – as endorsed by the Airports Commission. The Council believes that the work undertaken by the Airports Commission underestimated the job market growth in London and as a result, existing rail infrastructure such as the Piccadilly Line and Crossrail will be far fuller with rising background traffic than has been assumed. Without ‘new’ capacity, the achievability of modal shift from highway, the absolute space on public transport to accommodate that shift and consequently the likelihood of achieving air quality targets are questioned. Critically, as any surface transport system approaches overloading then unreliability increases; the resilience of the airport to operate successfully through such interruptions on any one link will also be increased with these further links.
Given the location of Runnymede Borough, it is the southern rail access proposal which is of greatest relevance to Runnymede. This Council supports the principle of a southern rail link into Heathrow Airport, however the Surrey County Council Southern Access to Heathrow Final Report, December 2016
(https://www.surreycc.gov.uk/__data/assets/pdf_file/0008/109718/Surrey-SRAtH-Final-
Report-Dec-2016-part-1.pdf) recommended further development of the preferred Southern Rail Access options including ‘a detailed feasibility study of the potential to close/replace the Egham area level crossings’. Closing and/or replacing these crossings was identified as the key action that could unlock the Southern Rail Access option 1c, Western Alignment plus Staines Chord, which was identified as having the best potential to achieve the required outputs to meet Surrey County Council’s development objectives. The outcomes of the Egham Level Crossings Feasibility Study are awaited at the time of writing. The absence of the findings of this study being reported and details of any mitigation measures being known, the Council remains particularly concerned with the matter of barrier downtime at level crossings in the Borough as a result of southern rail access to Heathrow. This is due to the likely knock on effects relating to congestion on the surrounding road and rail network which would only serve to exacerbate existing problems experienced in Runnymede caused by current level crossing down time. Whatever final Southern Rail Access option is taken forward the delivery of this essential infrastructure must consider the local implications along its route to ensure impacts on local communities, including the cumulative congestion and air
quality impacts at level crossings. These issues must be dealt with but we would also urge Heathrow Airport to encourage Central Government to bring the scheme forward as soon as possible. It should also be noted that the borough is home to large international companies such as Samsung, Centrica (British Gas), Gartner and Compass. It is seen as essential that Runnymede has a scheduled stop in any Southern Rail Access plans in order to protect and improve the extremely strong GVA per head generated in the Borough of £45,500/head (source: ONS GVA/head – income approach, 2015). This is the second highest GVA per head figure of the 67 local councils which comprise the South East region.

There is also concern that the draft Airports NPS does not recognise the severity of
congestion problems on the surrounding road networks at the current time, let alone with an expanded Heathrow airport. With the proposed doubling of freight capacity and the subsequent impact this will have on traffic on both the local and strategic network particularly across the sub region. We therefore feel that freight traffic should be included in any targets set that are linked to your ‘no more traffic’ pledge, but it seems they are not proposed to.
This is particularly important to us given the impact of heavy goods vehicles on air quality (please also see our response to the question below for further information on this matter).
It is also felt that there needs to be greater encouragement of electric vehicles through a
strategy.
The draft Airports NPS makes reference to explicit targets for passenger and staff modal
split. The Council requires clarity on whether the ‘no more traffic’ pledge is set against a
scenario based on today, or a 2030 scenario of a completely full two runway airport as used by the Airports Commission. The Council notes that City Airport has 60% modal share for non-car traffic movements and question why the targets for Heathrow have been set so low?
The Council is concerned that at this stage there is also no comprehensive assessment of
the infrastructure requirements of an expanded Heathrow Airport, including an outline of the costs, the responsibilities and the overall accountability. The Council suggests that there should be a fully integrated approach to improving strategic infrastructure. As part of an overall surface access strategy, the associated implications for local road networks, including impacts on level crossing down time must be fully assessed and mitigated. It is suggested that the National Infrastructure Commission/Department for Transport should develop a framework for delivering a surface access strategy including consideration of the complex interfaces between all the schemes, runway construction, the most appropriate timing for surface access works, phasing and growth as well as responsibilities and funding.
The timetable for all infrastructure schemes must be made clear to key stakeholders as well as the specific details of the schemes proposed.
Runnymede retains serious doubts over whether Heathrow Airport will be able to meet its pledge that expansion will not lead to more airport-related traffic on the roads than today.
The Council would therefore be interested to comment on any monitoring criteria proposed in this regard.

Please tell us what you think about the measures proposed to manage emissions. Are
there any other measures that we should consider? Do you have any comments on
our approach to limiting carbon emissions from the design, construction and
operation of an expanded Heathrow?

The Council was pleased to see in paragraph 5.41 of the draft Airports NPS that, ‘The
Secretary of State will consider air quality impacts over the wider area likely to be affected, as well as in the vicinity of the scheme. In order to grant development consent, the Secretary of State will need to be satisfied that, with mitigation, the scheme would be compliant with legal requirements’. However it must be confirmed what area the ‘wider area’ consists of before it can be confirmed whether Runnymede Borough Council is satisfied with the approach set out.
The ‘wider area’ definition is considered to be particularly important given that across the sub region, there are a number of designated Air Quality Management Areas and air quality hot spots on the surrounding local and strategic road network. The land on either side of the M25 motorway for its entire length in Runnymede, including an extended area at Egham, was declared as an Air Quality Management Area (AQMA) in 2001 for both nitrogen dioxide and particulate matter (PM).
The impact of airport expansion on air quality in the Borough both during the construction phase at Heathrow Airport and any schemes to improve the M25 motorway, as well as during the operation of the expanded airport and M25, are of a significant concern to the Council and its residents in terms of the impacts on air quality and the subsequent impacts on the health of our communities. We believe rigorous monitoring of performance against agreed measures at regular intervals should be regarded as essential with action plans and sanctions when measures are being breached. It is also considered important that the applicant also complies with the National Air Quality Objectives which are enshrined in UK legislation.
The Council’s 2014 Air Quality Strategy states that the Borough records high levels of traffic travelling to and through the borough which contributes to adverse air quality. Heavy Goods Vehicles were also found to be the dominant source of NOx at relevant locations close to the M25 being responsible for more than 50% at all locations. In order to meet the air quality standards, the Air Quality Strategy notes that it will be necessary to further reduce overall concentrations of NO2 within the AQMA by up to 8%. A number of scenarios were modelled to test how this could be achieved. Although impracticable in the short term, this work has shown that the most effective intervention would be to reduce the number of HGVs on the M25 by 10%. For PM10 the contributions from heavy goods vehicles exceeded that of cars, and for all locations the contribution from cars exceeded that of buses. The background PM10 contribution at all locations was predicted as being almost constant (approximately 21 μg/m -3 ). An increase in freight movements to and from Heathrow Airport due to expansion of its freight handling capabilities will therefore make it even more challenging for the Council and Highways England/the Department for Transport / DEFRA to reduce harmful air quality emissions to acceptable levels in the Borough. The Council therefore believes that the applicant’s assessment must include the cumulative impact on existing exceedances and likelihood of new/additional exceedances of the air quality objective limits and propose suitable mitigation measures. Proposed mitigation measures not only need to satisfy the Secretary of State but also ensure that measures proposed would be sufficient to ensure
compliance with air quality standards and as a result the Council believes that air pollutants need to be monitored and assessed on the surrounding local and strategic road network and not just within the red line boundary.
The Council believes that the Heathrow Northwest Runway development once operational would be in breach of EU air quality targets unless very significant progress is achieved.
Within the proposed red line boundary and the airport perimeter, you claim that you are complying with EU air quality targets, but as stated earlier, the Council believes that the air quality issue extends beyond the perimeter to a wider area and impacts authorities neighbouring the airport who are currently in breach of air pollutant targets.
Heathrow Airport’s assessment of future air quality projections through modelling or
otherwise must be verified against measured data, as opposed to Defra background maps because there are considerable variations between these two data sets. In order to do this, we feel you must establish suitable monitoring locations near sensitive receptors (at your expense) in order to establish a current and a true baseline, and both local communities and local authorities should be consulted as a way forward. The baseline air quality modelling must also ensure that the latest real world Emissions Factor Toolkits are used and also allows for level of uncertainty within the modelling process which is quantified.
As advised earlier in our response, there is already a problem with airport users parking in our local residential roads and streets in order to avoid the higher charges associated with parking at and around the airport. An expanded airport is likely to exacerbate this problem and we feel additional support should be provided by the airport to help manage this problem.

Please tell us what you think about our approach to natural environment issues. Are
there any opportunities that the expansion of Heathrow could provide to enhance the
natural environment?

Runnymede Borough Council considers it essential that the environmental impacts are
reviewed over the full area of impact, which extends beyond the defined DCO area, and
certainly into Runnymede.
In terms of ecological conservation, wider air quality impacts on nearby/associated special protection areas (SPA) associated with expansion at Heathrow, including along key surface access routes must be considered e.g. the Thames Basin Heaths Special Protection Area (TBHSPA) which is located adjacent to the M3 motorway. Given that the NPS notes that the M3 is one of the key access and egress routes for Heathrow Airport, Runnymede Borough Council has an expectation that the knock on effects of expansion on the TBHSPA, including Habitat Regulation Assessment, will be carefully assessed through the DCO application.
With regards to flood risk, any scheme progressed at Heathrow Airport would need to be considered in a holistic manner, with links to other strategic interventions which are
progressing in the surrounding area also being considered, for example the River Thames Scheme.

Consultation questions which Officers and the Heathrow Expansion Member Working Group propose we do not provide a response to
It is proposed the Council does not provide a response to the below questions due to them either not directly impacting Runnymede, being completely unrealistic to request
Runnymede benefits, or because we do not have the associated expertise e.g. highways.

What factors do you think should be important in locating new terminal and apron
space (see page 18)?
What factors do you think should be important in deciding the location of new
taxiways (see page 20)?
Please tell us which family of options you prefer for the alterations to Junctions 14
and 14a and reasons why (see page 25).
Please tell us which option you prefer for the diversion of the A4 and the reasons why
(see page 26 and 27).
Please tell us which option you prefer for the diversion of the A3044 and the reasons
why (see page 28).
Please tell us which option you prefer for the Stanwell Moor junction and the reasons
why (see page 29).
Please tell us what you think about the options to improve access to the Central
Terminal Area (see page 30).
Do you have any comments on the land uses that will be affected by Heathrow’s
expansion. 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
(see page 38).
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 (see page 43).
Please tell us what you think about our property policies (see page 48).
Please tell us what you think about our approach to historic environment issues (see
page 65).

APPENDIX ‘C’
Heathrow’s Airspace Principles Consultation response (Heathrow Airport are simply seeking feedback on the key design principles presented in their Airspace Principles Consultation document.)

RBC Draft response

Principle 1: Flight paths

The impact of noise from any expansion at Heathrow airport remains of significant concern to Runnymede Borough Council and its affected communities.
The airport expansion consultation document states it is your committed goal to expand
Heathrow while affecting fewer people with noise. It also states that key to the development of noise measures will be the feedback you receive from communities and local authorities affected by aircraft noise. Given the strong links between noise areas and flight paths, we would like to make a strong plea for a wider dispersal of flight paths in order to distribute noise more fairly, and therefore support Option C. Whilst this will mean affecting more people, it will at least give a greater respite to those that would otherwise be in a concentrated flight path. We would also like to request that when the proposals for the flight paths are beginning to be firmed up, that we are given further opportunity to advise you of particularly sensitive locations such as the Commonwealth War Graves Commission’s memorial in Englefield Green.
Runnymede Borough Council would also very much welcome being given the opportunity to have a representative on your Noise Envelope Design Group.

Principle 2: Urban and rural areas

As stated above, the Council believes that routing aircraft over rural areas, wherever
possible, is more favourable than over urban areas. Although it is recognised that some
rural areas are important spaces for tranquillity/leisure, particularly the Commonwealth War Graves Commission memorial which is elevated in Englefield Green, the impact on individuals would generally be less significant. The Council therefore favours Option B.

Principle 3: Urban areas

Within urban areas, the Council believes that positioning routes over parks and open
spaces, particularly in the evenings, is more favourable than residential areas because like above the exposure experienced by individuals will generally be less frequent. The Council therefore favours Option A.

Principle 4: Noise and emissions

Although designing flight paths to go around denser residential areas/communities may
result in increased emissions, it is felt the extra respite provided to residential areas would outweigh the small difference to emissions and air quality.
To conclude the comments written in Principles 1-4:
The Council supports flight paths being dispersed over a number of routes (to include all
options below), but prioritising them in the following order:
1) Flying over rural areas to circumnavigate dense residential areas
2) Flying over parks and open spaces within denser residential areas (particularly in the
evening)
3) Dispersing flight paths over a greater number of residential areas rather than a
concentrated few.

Principle 5: Technology and innovation

The Council supports Heathrow working with airlines to encourage investment in the latest navigation technology in order to assist greater flexibility in the designing of flight paths.

Principle 6: Night flights

The Council believes flight routes over parks and open spaces within denser residential
areas should be prioritised during the evenings. During the daytime there should be a
dispersal of flight routes as per the concluding comments in green above.
With regards to the night-flight ban, we feel the Airport Commission’s proposal of a ban
between 11:30pm-6am will be generally less disruptive to the local communities than your proposed times of 11:00pm-5:30am and so favour the Airport Commission’s proposal.