Heathrow Consultation: Closing at 11:45pm 19th December 2017

There's still time for you to respond to the Government's consultation on Heathrow - it closes at 11.45pm tonight.


Sarah Olney, Parliamentary Spokesperson for Richmond Park and North Kingston submitted: 

"Liberal Democrats welcome the opportunity to contribute further to the decision-making process around Heathrow expansion, and note that the scale of this consultation shows that the government’s case for a third runway is not supported by the evidence.

London’s airports are forecast to be full by the mid-2030s, with Heathrow already operating at full capacity and Gatwick at capacity during peak times. This could be an opportunity to invest and develop other parts of the country and promote regional economies. This perspective is missing. Moreover, there are potentially serious environmental and health impacts, notably from the deterioration in air quality from an additional 700 flights a day and from the supporting ground traffic.

We recognise, as does the government’s own appraisal, that a second runway at Gatwick would cause less environmental damage than either potential scheme at Heathrow. The update to the air quality analysis describes Gatwick expansion as ‘low risk’ with ‘low vulnerability’. Noise affects far fewer people. In addition, 17 listed buildings will be destroyed, 2 scheduled monuments, 2 conservation areas, and 167 non-designated assets in the land-take if Heathrow is expanded. The significance of these sites should not be underestimated as they contribute to the history and culture of the area.

We take this opportunity to reiterate the position that was expressed in our previous submission, that if any expansion of a UK airport is to take place, our preference would be for this to take place outside of the south-east. To rebalance the economy, we must look to the regions. Two-thirds of flights in and out of the UK land or take-off from the south-east of England, despite only one-third of the population living there. If the government is committed to improving the inter-connectivity of the country with HS2, HS3 and East to West rail, then they should have more ambition and faith in areas such as Birmingham and Manchester, where airports are running below capacity. With HS2, the journey from London to Birmingham can be completed in forty minutes and Manchester to Birmingham in half an hour; yet Birmingham airport is currently operating at only 30% capacity.

Whilst we recognise the decision of Heathrow to use new metrics to measure noise, as one of the first airports in the world to do so, and the use of noise contours, the way Heathrow measures noise gives too much weight to individual aircraft rather than the cumulative impact of noise. In the CAA report "Heathrow Airport 2016: Summer Noise Contours and Noise Action Plan Contours" they make much of the fact that plane noise has seemingly fallen, but not enough of the number of planes going overhead. It fails to acknowledge that it is the sheer volume of the planes, and the incessant consistency of the noise, that is most damaging.

It is also not clear that Heathrow has fully factored in the increased concentration that some communities under the flight path have experienced, both on landings and departures. There was a 70%/30% split in terms of the west/east split, but 10% of planes failed to adhere to runway alternation measures.

One thing that is clear is that a third runway could not be built at Heathrow without causing unacceptable air and noise pollution. The government’s own sustainability appraisal expects the plans for expansion to have a negative effect on air quality, noise, and biodiversity.

The plans also undermine efforts to reduce greenhouse gas emissions by at least 80% on 1990 levels by 2050, as legislated by the Climate Change Act. Indeed, if national quota limits are set for the aviation sector, Heathrow’s expansion will be at the expense of provincial airports.

If Heathrow are serious about their environmental responsibilities then there are measures that they could already have in place to show this, such as, donating all proceeds from car parking at their terminals to environmental causes or investing in environmentally sustainable modes of transport within the airport site, such as those used for passenger mobility or transporting food and cargo.

Heathrow has an impossible task to mitigate against any significant deterioration in air quality and recognises that this cannot be done soon, and that they need over a decade to get the pollution risks down to a ‘medium’ level after 2030 in the option for the Northwest runway and the extended Northern runway.

It is simply not good enough that the implementation and the effectiveness of the updated surface access strategy is dependent almost entirely on the government’s proposals to reduce emissions from diesel vehicles on the roads. As the government have not suggested any sort of scrappage scheme for diesel vehicles, it is unlikely that we are going to see a major shift in the types of vehicles that people use daily until the infrastructure to run cleaner vehicles, and the prices of electric vehicles, make this realistic and viable for consumers.

For the government to meet its commitment that there be no increase in road traffic as a result of the third runway, significant infrastructure upgrade in West and South-West London will be required, but no details are available as to either how the costs of these will be met, or what impact the new road and rail links will have on local communities.

It is unrealistic that a vote on this could take place in Parliament in the early half of 2018, and it would be irresponsible of the government to push ahead with these proposals without much greater clarity around environmental, health and noise impacts and infrastructure costs."

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