Category Archives: Consultation responses

When governments offer us the chance to put the case for cleaner, safer, quieter living conditions, we always do. Here you can browse some of our responses to government and other consultations, beginning with our submissions to the Terminal 5 public enquiry in 1995.

Airports Commission Air Pollution Consultation

The Airports Commission has released a short consultation on air pollution, with  29th May deadline.  The consultation documents can be found on the Commission’s website:  https://www.gov.uk/government/consultations/airports-commission-air-quality-assessment

This is a technical consultation assessing  future air pollution levels around Heathrow and Gatwick if new runways are built.

It is unlikely that this consultation was prompted by the recent Supreme Court ruling that required the Government to draw up plans by the end of the year on how it was going to meet the EU legal limits on air pollution (across the UK).  The Airports Commission, under Sir Howard Davies, always intended to do this work.

The legal limits came into force in 2010 under the terms of the EU Air Pollution Directive but the EU has not taken action against breaches of them because no member state has been able to meet the targets.  So the Commission is now asking member states to outline plans on how they intend to meet the targets but without having set a new date.

During the last consultation the Airports Commission carried out, it said it was going to do more work on air pollution, particularly on how pollution levels might disperse.  This is critical because the predictions were that by 2030 (when any new runway would be up and running) there might still be pockets around the airport that would be over the EU legal limits.  Dispersal could potentially spread the pollution more thinly so that no area remained above the limits.

The Airports Commission commissioned the consultancy firm, Jacobs, to do the work on dispersal.  Jacobs has found that by 2030 there will be a problem in small areas close to the Bath Road (very close to the airport) if no mitigation measures have been put in place.  The problem would be a little worse from the Heathrow Hub scheme that with the Heathrow Airport’s 3rd runway scheme.  But it expects the problem to be resolved within a few years.  Jacobs doesn’t appear to foresee a problem at Gatwick.

Jacobs then lists the mitigation schemes by Heathrow – things like encouraging airlines to shut down an engine during taxiing, the use of the extended runway to allow a proportion of the take-off emissions to be well away from the airport boundary and the introduction of congestion charging in the area.  But it doesn’t really analyse them.  Rather it tends to assumes that, with some mitigation, the levels will be below the EU legal limits in 2030.

There is one other point that it not addressed.  A new, if built, will not be running to capacity by 2030.  Jacobs doesn’t look at what air pollution levels will be when it is running to capacity.  It implies that with mitigation measures in place and, as aircraft become cleaner as the years go by, there should not be a problem.  But no detailed work has been done on this.

HACAN accuses Heathrow of abusing Airport Commission’s consultation process

Campaign group HACAN has accused Heathrow Airport of abusing the Airport Commission’s current consultation, which closes on February 3rd, by “flooding the Commission with thousands of pro-forma responses.” 

In a letter to Sir Howard Davies (see letter and full HACAN response below), the chair of the Commission, HACAN, has said that Heathrow has “strained every sinew of its advertising budget to try to persuade as many people as possible to email or write to the Commission that they want a third runway at Heathrow”.

In its consultation the Commission asked for comments on whether it had correctly assessed the proposals put forward for a new runway at Heathrow and a second runway at Gatwick.

HACAN chair John Stewart, said “This was a technical consultation.  What the Commission was not looking for was a flood of responses for or against a third runway.  Yet Heathrow even went as far as placing post boxes in its terminals for passengers to pop in their letters of support.   It is simply a side-show to the serious work the Commission is undertaking”.

Letter to Sir Howard: HACAN consultation letter to Sir Howard Davies

HACAN response to the Consultation: Response to the Airports Commission from HACAN January 2015 _2_