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HEATHROW EXPANSION CONSULTATION ONE -
INTERIM FEEDBACK REPORT
VOLUME 3 OF 3
JANUARY 2019
HEATHROW EXPANSION CONSULTATION ONE -
INTERIM FEEDBACK REPORT
VOLUME 3 OF 3
JANUARY 2019
Heathrow Expansion Airspace and Future Operations Consultation
2 © Heathrow Airport Limited 2019 Heathrow Expansion Consultation One - Interim Consultation Feedback Report - Volume 3
CONTENTS
SURFACE ACCESS 5
Introduction 5
Prescribed Consultees 6 Local Authorities 6 Statutory Consultees 16 Other Prescribed Bodies 17
Local Communities 19 Members of the public 19 Businesses 21 Community Groups 25
Wider/other consultees 31
Issues Raised and Heathrow’s Responses 38
AIR QUALITY AND EMISSIONS 137
Introduction 137
Prescribed Consultees 137 Local Authorities 137 Statutory Consultees 142 Other Prescribed Bodies 143
Local Communities 143 Members of the public 143 Businesses 145 Community Groups 146
Wider/other consultees 149
Issues Raised and Heathrow’s Responses 152
CARBON AND CLIMATE CHANGE 195
Introduction 195
Prescribed Consultees 195 Local Authorities 195 Statutory Consultees 197 Other Prescribed Consultees 197
Local Communities 198 Members of the public 198 Businesses 199 Community Groups 199
Wider/other consultees 200
Issues Raised and Heathrow’s Responses 202
NATURAL ENVIRONMENT 220
Introduction 220
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3 © Heathrow Airport Limited 2019 Heathrow Expansion Consultation One - Interim Consultation Feedback Report - Volume 3
Prescribed Consultees 221 Local Authorities 221 Statutory Consultees 224 Other prescribed bodies 227
Local Communities 228 Members of the public 228 Businesses 230 Community groups 232
Wider/other Consultees 234
Issues Raised and Heathrow’s Responses 239
HISTORIC ENVIRONMENT 279
Introduction 279
Prescribed Consultees 279 Local Authorities 279 Statutory Consultees 281 Other prescribed bodies 282
Local Communities 282 Members of the public 282 Businesses 285 Community groups 285
Wider/other Consultees 286
Issues Raised and Heathrow’s Responses 290
AIRSPACE 321
Introduction 321
Prescribed Consultees 321 Local Authorities 321 Statutory Consultees 322 Other prescribed bodies 323
Local Communities 323 Members of the public 323 Businesses 323 Community groups 324
Wider/other Consultees 326
Issues Raised and Heathrow’s Responses 328
CONSULTATION 354
Introduction 354
Prescribed Consultees 355 Local Authorities 355 Statutory Consultees 357 Other prescribed bodies 358
Local Communities 358 Members of the public 358 Businesses 361 Community groups 362
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Wider/Other Consultees 363
Issues Raised and Heathrow’s Responses 366
COSTS 392
Introduction 392
Prescribed Consultees 392 Local Authorities 392 Statutory Consultees 394 Other prescribed bodies 394
Local Communities 395 Members of the public 395 Businesses 395 Community groups 398
Wider/other Consultees 399
Issues Raised and Heathrow’s Responses 401
PLANNING 417
Introduction 417
Prescribed Consultees 417 Local Authorities 417 Statutory Consultees 420 Other prescribed bodies 420
Local Communities 421 Members of the public 421 Businesses 421 Community groups 423
Wider/other Consultees 423
Issues Raised and Heathrow’s Response 425
Overview of Ongoing Engagement and Next Steps 443
Introduction 443
Overview of ongoing engagement 443 Prescribed Consultees 443 Local Communities 444 Members of the public 445 Wider Consultees 447
Next steps 448
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SURFACE ACCESS
Introduction
20.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in
relation to the priorities and initiatives proposed for the development of the Surface
Access Strategy and the options for road user charging. A total of 1,139
consultees made comments about the priorities and initiatives proposed to be
used to develop Heathrow’s Surface Access Strategy and 1,606 consultees made
comments about road user charging.
20.1.2 Heathrow provided the following material that is directly related to the Surface
Access Strategy:
1. Airport Expansion Consultation Document; and
2. Our Approach to Developing a Surface Access Strategy.
20.1.3 Heathrow asked the following questions regarding the Surface Access Strategy at
Airport Expansion Consultation One:
1. Please tell us what you think about the priorities and initiatives we propose to
use to develop our surface access strategy.
2. 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.
20.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Heathrow
Airport Expansion Project (the Project), we have provided a summary of the way in
which we are seeking to consider the issues as part of preparing the detailed
proposals which will be presented as part of the Airport Expansion Consultation
planned for June 2019.
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Prescribed Consultees
Local Authorities
General Comments
20.2.1 General comments from local authorities either focussed on the commitments and
priorities of the Surface Access Strategy and modal share targets or sought further
information.
20.2.2 The London Borough of Brent recommended that the priorities of the Surface
Access Strategy should be focussed on those areas where public transport is not
currently used to travel to/from the airport.
20.2.3 Elmbridge Borough Council requested greater clarity on the surface transport
infrastructure proposals for their Borough.
20.2.4 Essex County Council also sought additional information on the wider surface
access network and in particular bus, coach and rail proposals.
20.2.5 The London Borough of Hammersmith & Fulham commented that Heathrow needs
to include local communities in the development of the Surface Access Strategy.
They considered this should include impacts on those communities further away
from the airport.
20.2.6 Hampshire Services who responded on behalf of central and eastern Berkshire
authorities1 stated that the Surface Access Strategy should also take account of
the construction phase.
20.2.7 Hertfordshire County Council considered that a more comprehensive and realistic
picture of collective growth in the sub-region needs to be agreed, to enable an
assessment of the required mitigation measures and the agencies responsible for
delivery.
20.2.8 Runnymede Borough Council suggested that the National Infrastructure
Commission and Department for Transport (DfT) should develop a framework for
delivering the Surface Access Strategy, which considers the complex interfaces
between infrastructure schemes, runway construction, surface access works,
phasing of growth and funding.
20.2.9 South East England Councils highlighted that the productivity of the south east is
supported to ensure that economic growth prospects are not undermined by poor
services. They said that local authorities and Local Enterprise Partnerships (LEPs)
1 Bracknell Forest Council, Reading Borough Council, The Royal Borough of Windsor & Maidenhead and Wokingham Borough Council
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have limited funds for transport investment and should not be expected to cover
the costs of improvements or mitigation measures required as a result of the
Project. All mitigation works, including upgrading local road and rail networks,
should be forward-funded by Heathrow, or by Heathrow securing government
funding.
20.2.10 Surrey County Council welcomed the ‘no more traffic’ commitment but said trips by
private car to/from car parks beyond the perimeter of the airport should be
included in the definition of ‘airport related traffic’.
20.2.11 They also expressed concern that there is no integrated strategy for those
travelling to and from the airport or any coherent view on how Heathrow sits within
the wider, national and regional transport network. The London Borough of Harrow
expressed a similar view commenting that the Surface Access Strategy should
consider cumulative impacts on the wider area.
20.2.12 The Royal Borough of Windsor and Maidenhead said the proposals should include
a clear strategic objective for the management of surface traffic associated with
the airport.
Modal share
20.2.13 Buckinghamshire and Essex County Councils, the London Borough of Ealing,
Runnymede and Spelthorne Borough Councils sought clarification on the ‘no more
traffic’ commitment and the areas, roads and traffic types it would include.
20.2.14 The London Boroughs of Ealing and Hounslow both expressed concern with the
proposed monitoring regime for mode shift involving the Heathrow Area Transport
Forum, suggesting that a viable, independent alternative solution is needed.
20.2.15 The London Borough of Hammersmith & Fulham, the London Borough of Harrow
and the Royal Borough of Kingston upon Thames questioned how the share of
passengers accessing the airport via sustainable transport would be achieved.
20.2.16 They also said there was a lack of evidence on whether the proposals would
successfully achieve their aims; they questioned the adequacy of the targets and
whether they were representative of the number of passengers expected to travel
to and from the airport. They also noted that there is no commitment to annual
reporting on performance against the modal shift targets.
20.2.17 Kent and Surrey County Councils expressed general support for the commitment
to mode share targets.
20.2.18 Slough Borough Council and Surrey Heath Borough Council recognised that the
targets could take pressure off the public highway, alleviate congestion on
surrounding road networks and bring about improvements to air quality.
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20.2.19 The Royal Borough of Kingston upon Thames and Spelthorne Borough Council
also said that ongoing monitoring of progress towards modal shift targets will be
necessary. The Royal Borough of Kingston upon Thames suggested that there
should be enforcement action for non-compliance and considered that the modal
shift estimates were optimistic.
20.2.20 Runnymede Borough Council questioned why the mode share targets are so low.
20.2.21 Slough Borough Council commented that there needs to be clarity on how and
where the modal shift targets will be monitored, assessed and reported.
20.2.22 Spelthorne Borough Council stated that the Surface Access Strategy should
contain specific targets to maximise journeys to the airport by public transport,
cycling or walking.
20.2.23 The London Borough of Sutton stated that the Surface Access Strategy appears
too “road and car-focused” and that increasing rail and bus mode share is not
given enough priority.
20.2.24 Wokingham Borough Council requested clarification on the definition of public
transport, the monitoring arrangements and the consequences of failure to meet
targets.
Putting Heathrow at the heart of the rail network
General Comments
20.2.25 Elmbridge Borough Council stated that the growth of the airport should be
conditional upon substantial investment and the provision of major rail investment.
20.2.26 London Borough of Harrow stated that Heathrow should help deliver the West
London Orbital Rail Link and provide assurance of service frequency and reliability
improvements for the Piccadilly Line to Uxbridge.
20.2.27 Kent County Council welcomed the commitment to the Western and Southern Rail
Links but said Heathrow should lead these projects. They also suggested that
Heathrow should incentivise use of the Elizabeth Line with special ticketing as part
of the Surface Access Strategy.
20.2.28 The South East England Councils stated that rail transport should be given equal
priority with road, to resolve gaps in public transport. They also considered that the
Project should not be used to delay investment in surface access improvements to
the airport that are already developed and needed.
20.2.29 Spelthorne Borough Council stated that existing public transport improvements
deal with existing demand created by a two-runway airport, not to cater for the
Project. They said no commitment has been made by Heathrow to public transport
that will meet the needs of an expanded airport, particularly to the south. A similar
view was shared by the London Boroughs of Brent, Ealing and Hounslow.
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Western Rail Link
20.2.30 The London Borough of Brent expressed concern that there are no alternatives
proposed for the Western Rail Link if it does not go ahead. They also suggested
that any extended hours on the Elizabeth Line need to be implemented in
conjunction with extended hours on public transport within London, to ensure that
people can complete their journeys.
20.2.31 Buckinghamshire County Council expressed a similar view commenting that early
planning and investment in the Western Rail Link and other rail projects will be
required well before the runway is completed, to avoid an increase in road traffic.
20.2.32 Reading Borough Council expressed concern about the lack of commitment to
ensuring delivery of the Western Rail Link in a timely manner. They considered
the construction of the Western Rail Link should be completed in advance of
construction for the Project, to mitigate disruption and enable significant modal
shift to take place.
20.2.33 Slough Borough Council expressed support for the Western Rail Link and
indicated that Heathrow should agree the contribution to provide certainty over its
delivery.
20.2.34 South Bucks District Council commented that the Western Rail Link and Elizabeth
Line will improve access and provide quicker journeys for residents close to
stations, such as Iver and Taplow.
20.2.35 Wokingham Borough Council considered that the Western Rail Link is the priority
infrastructure project and welcomed Heathrow’s commitment to contribute to the
scheme.
Southern Rail Link
20.2.36 Bracknell Forest Council expressed support for the Southern Rail Link.
20.2.37 Ealing Council commented that a Southern Rail Link is essential to help relieve the
Crossrail and Piccadilly lines, and raised concern about the number of competing
options being promoted. They suggested a need for an objective analysis of all the
options.
20.2.38 The London Borough of Hounslow expressed concern that no new rail connectivity
is proposed and considered it implausible that no more traffic on the road can be
delivered without improved rail access from the south. They also expressed
concern that the targets around the shift to public transport are not considered to
be reliant on the implementation of the Southern Rail Link.
20.2.39 The Royal Borough of Kingston upon Thames also expressed support for the
Southern Rail Link and recommended that an extended scheme is investigated
which involves tunnelling through to Wimbledon, rather than just to Kingston. They
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identified that contributions towards the costs of major rail schemes will need to be
secured and without sufficient investment in the public transport network, negative
impacts will result on the road network over a wide area.
20.2.40 London Borough of Lambeth considered that a direct rail link between London
Waterloo and Heathrow with a stop at Vauxhall has the opportunity to reduce the
number of car journeys to the airport.
20.2.41 Runnymede Borough Council expressed concerns about ‘barrier downtime’ at
level crossings associated with the Southern Rail Link in the Borough and the
likely knock on effects on congestion and air quality.
20.2.42 Spelthorne Borough Council commented that the Southern Rail Link is needed to
deliver the ‘no more traffic on the road’ pledge and without it there will be more
traffic congestion. They considered Heathrow should support and commit to help
pay for the Southern Rail Link but said there is an opportunity for a ‘Super Public
Transport Levy Fund’ to support funding of major surface access schemes and
fund sustainable transport projects.
20.2.43 Surrey County Council stated that the Southern Rail Link is needed now to
address poor public transport links to the south of the airport, encourage modal
shift and reduce air pollution from congestion and emissions. They considered
that a scheme that enables connectivity between Surrey and Heathrow should be
a key element of the Surface Access Strategy and should be delivered before a
new runway is operational.
20.2.44 Waverley Borough Council expressed concern that there is no commitment from
Heathrow to fund the Southern Rail Link and that the proposals do not include a
direct link with Woking. They stated that a more direct southern access rail link
from Woking to the Airport would provide the greatest accessibility improvement
for residents and employees within this area of Surrey and Hampshire and would
provide a realistic alternative to the use of the private car.
Providing a public transport led scheme
20.2.45 Bracknell Forest Borough Council said their area is poorly served by sustainable
transport access to the airport. They considered that improvements to sustainable
transport modes need to be implemented before the Project is complete.
20.2.46 London Borough of Brent supported the focus on public transport but questioned
the commitment to its delivery. They welcomed the intention to align employment
and public transport but considered there is a lack of incentives to reduce car use.
20.2.47 Buckinghamshire County Council supported Heathrow’s aspirations to develop the
public transport network and identified potential for services to feed into
Buckinghamshire using key transport hubs. They stated that they are keen to
work with Heathrow to ensure that hub locations are appropriately located to
enable airport related employees to travel by public transport. The Council also
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noted that the Elizabeth Line and the Western Rail Link would support new and
enhanced bus services to these rail stations from Buckinghamshire.
20.2.48 London Borough of Islington considered that flights should be timed to depart and
arrive at times when public transport is available and any increase in airport
capacity should be subject to the provision of additional public transport capacity.
20.2.49 Royal Borough of Kingston upon Thames said that access by road, rail and other
public transport to the airport needs to be high quality, efficient and reliable for
both passengers and workers and it must maximise the number of journeys to the
airport by sustainable forms of transport.
20.2.50 Reading Borough Council expressed support for the development of public
transport initiatives for both passengers and staff. They stated that for the targets
to be achieved, Heathrow will need to demonstrate support for a step change in
public transport provision to the airport.
Providing a resilient and reliable road network
20.2.51 Buckinghamshire County Council identified the following key areas on the highway
network requiring mitigation: Beaconsfield; Burnham; Iver (including the Five
Points Roundabout and to address the poor road traffic accident record); Iver
Heath (Willow Lane); and north/south connectivity via High Wycombe and to
Aylesbury.
20.2.52 Kent County Council stated it was unacceptable for the Project to have a
detrimental effect on the road network as it would not only impact airport users, but
also other users of the road network, including local communities and freight
companies/hauliers.
20.2.53 The London Borough of Lambeth commented that the motorway network around
Heathrow already suffers from congestion and high pollution levels. They said that
the Project should address this by providing measures to combat congestion and
pollution, and encourage sustainable means of travel.
20.2.54 Reigate and Banstead Borough Council raised concerns about the impact on
transport routes such as the M25 and the North Downs Line if appropriate
mitigation is not put in place. They also said Highways England had concerns
about the impact of future development on the M25 South West Quadrant and
southern stretches of the M25.
20.2.55 The South East England Councils considered that there is a need for a fully
integrated strategic transport network to ensure that non-airport ‘through’ traffic
has access to viable alternative routes as the Project would impact on the M25
and surrounding roads.
Strengthening the coach hub at Heathrow
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20.2.56 The London Borough of Brent, Kent County Council and Surrey County Council
expressed support for strengthening the coach hub. The London Borough of Brent
also stated that a commitment should be made to improve links to areas with low
public transport use.
Investing in local transport solutions
20.2.57 London Borough of Brent said buses play a vital role for trips in the local area.
They welcomed the provision of new express and shuttle bus services
commenting that these will need to be frequent enough to attract people from their
cars. They also welcomed collaboration with Heathrow to develop strategic bus
routes and ‘demand responsive services’.
20.2.58 Buckinghamshire County Council requested bus and coach services towards
southern Buckinghamshire are reviewed for additional stops and route additions
within the final 10 kilometres to Heathrow. They also suggested Heathrow
identifies the need to provide on-demand services within southern
Buckinghamshire.
20.2.59 Ealing Council suggested that Heathrow investigate bus rapid transit to local areas
(Southall, Greenford, Northolt) aimed at employees living locally, as well as
demand responsive bus services.
20.2.60 The London Borough of Harrow stated that Heathrow should provide assurances
in relation to service reliability for the 140 bus service (capacity and frequency) or
introduce a new bus service/s to cope with the forecast increased demand.
20.2.61 The Royal Borough of Kingston upon Thames suggested an increase in the
frequency of the X26 express bus service on its route between the airport and
West Croydon.
20.2.62 Reading Borough Council stated the proposed expansion of bus routes ignores
those running outside the Greater London area to the Thames Valley. They
suggested the relocation/rebuilding of roads such as the A4 should include the
provision of dedicated bus lanes in each direction on the approach to the airport
campus. They also suggested that bus lanes should be in place for the
construction period and could provide support for bus services to serve shift
workers.
20.2.63 Slough Borough Council said Heathrow must help to fund/support mass rapid low
emission transport schemes to improve the links and journey time to the airport.
They also stated that these services must be located where demand is and that
the number of shuttles operating from hotels should be limited with mass rapid
transit facilities used to access the airport.
20.2.64 South Bucks District Council expressed a similar view, commenting that
consideration should be given to priority lanes for coaches and buses to speed up
journey times and ensure reliability. They suggested that if the Project generated
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HGV traffic, in addition to that generated by other major infrastructure schemes in
the same area, Heathrow should make a significant contribution to the cost of the
Iver Relief Road. They also stated that the cumulative impact of these schemes
be addressed.
20.2.65 Spelthorne Borough Council also stated that Heathrow must commit to paying
capital and revenue costs for the introduction of regular and quick bus routes to
and from the areas to the west and south.
20.2.66 Surrey County Council queried whether ‘on-demand services’ which are a cross
between private taxi and public bus should be defined as public transport. They
also requested engagement with Heathrow on how bus services might be
enhanced and improving the local cycle network.
20.2.67 Wycombe District Council commented that consideration should be given to other
schemes to enable use of more sustainable transport modes such as the High
Wycombe rail connection to Old Oak Common, coach links to Handy Cross hub
and re-opening of the High Wycombe to Bourne End heavy rail line.
Making public transport easier for users
20.2.68 London Borough of Brent suggested that better advertising and information about
the free travel zone is required and a review of the pricing structure for public
transport to the airport is needed.
20.2.69 London Borough of Hounslow considered that more attention should be given to
inter-urban coach services rather than local buses. They expressed concern about
the frequency and timing of local services and a lack of detail on how Heathrow
will engage with the industry to improve frequencies to at least five an hour. They
suggested that Heathrow should be required to pay for enhanced service levels.
20.2.70 Kent County Council stated that making all public transport options easier for
users is essential to transfer mode share away from the private car. They
suggested that integrating ticketing for onward travel could create a seamless
journey for passengers.
20.2.71 Reading Borough Council considered that enabling passengers and employees to
obtain reasonably priced, flexible tickets incorporating free or discounted surface
access public transport tickets as part of an airline ticket package, would make
public transport more attractive.
20.2.72 Spelthorne Borough Council agreed that affordable and convenient transport
choices for employees and passengers are critical to achieving sustainable
surface access. They highlighted that Heathrow must consider the future
workforce and encourage a greater spread of employees with an equitable choice
of transport modes.
Enabling more efficient and responsible use of the road network
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20.2.73 The London Borough of Brent said that further analysis should be undertaken
about how road user charging would reduce emissions and vehicle numbers, and
that any scheme needs to be simple with viable alternatives.
20.2.74 They also stated that all Heathrow related vehicles should be low or zero emission
and expressed support for measures to reduce the number of taxis and private
hire vehicles that travel to/from the airport empty, and that these should not be
defined as public transport.
20.2.75 Buckinghamshire County Council stated that Heathrow needs to make the case
that road user charging will not be used to increase income for the airport through
displacing traffic and parking. They suggested that if it is seen to be used to fund
public transport links to transport hubs with dedicated parking sites, then a
charging approach would have greater support. They also indicated that the
proposed environmental zones (uLEZ) need to be designed to ensure that any
impacts or benefits are effective and offset all potential emission source increases,
including from aircraft.
20.2.76 Buckinghamshire County Council also said that HGVs are a key issue for the Iver
community and welcomed Heathrow working with local communities and the
freight industry ahead of the Project.
20.2.77 Ealing Council and Hounslow welcomed the proposal for road user charging and
indicated their preference was for a graduated approach covering:
1. emission-based parking charges in Heathrow’s controlled car parks;
2. emission-based charges in third party and tenanted car parks;
3. workplace parking levy; and
4. emission-based drop off charges.
20.2.78 Ealing Council and the London Borough of Hounslow stated that if these were not
sufficient, a wider zone should be considered. However, both Councils expressed
concern that a wider charging zone may lead to displacement of traffic from the
airport highway network to the surrounding roads and streets, using them as a
through route or short cut. This would lead to increased pollution close to sensitive
receptors.
20.2.79 The Councils stated that more information is required to demonstrate the
effectiveness of the proposed measures to make taxis operations more efficient.
This should include innovative solutions such as the use of online trip-matching
systems, and rewards and penalties for efficient and inefficient operators such as;
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introducing a charter for all private hire vehicles seeking to access the site which
encourages backfilling2, and incentivising operators to sign up to the charter
and/or a reward scheme.
20.2.80 The Councils also expressed concern over the feasibility and deliverability of
satellite consolidation sites3, the ability to incentivise and/or compel companies to
participate, and a lack of detail on mitigation if such plans are not successful.
20.2.81 Kent County Council supported the exploration of road user charging and
suggested it will be necessary to raise the emissions standards incrementally as
technology improves. They also highlighted that a drop off/pick up charge will need
to be carefully managed and a uLEZ for freight vehicles could see a reduction in
emissions.
20.2.82 Slough Borough Council stated that in order to meet the sustainable travel targets
by 2030 and 2040 that Heathrow and Slough will need to work together to provide
suitable alternatives that are not only affordable to the user but punctual and
reliable. If suitable alternatives are not provided they would not support road-user
charging. They also stated that they will need to work with Heathrow to create a
wider low emission zone (CAZ) that helps address the Air Quality Management
Area’s (AQMA’s) surrounding the expanded airport. They were concerned that an
approach involving a simple extension of the Transport for London (TfL) low
emission zone (LEZ) in to the Borough would not be acceptable as it could
potentially lead to more polluting vehicles to travel in the surrounding
Slough Borough.
20.2.83 Spelthorne Borough Council, whilst generally supportive of road user charging,
raised similar concerns and requested more detail on the options.
20.2.84 Surrey County Council commented that road user charging must be designed to
avoid unacceptable displacement impacts and be fully funded by Heathrow,
including associated mitigation measures, to ensure local communities are not
unfairly penalised.
20.2.85 The London Borough of Sutton noted that road user charging regimes may have
an impact on switching to more sustainable modes of transport.
20.2.86 Wokingham Borough Council considered that road user charging and drop off
charges for leisure travellers will form part of the decision on transport mode. They
2 Ensuring that taxi’s dropping off customers at the airport are used to fill demand for customers with onward journeys from the airport.
3 Freight transport consolidation or holding sites located outside of the airport perimeter to reduce the number of final mile journeys by
freight vehicles.
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considered that it would be inevitable that there would be some form of road user
charging introduced at Heathrow as a means to encourage the use of public
transport and help improve air quality.
Building on our successful commuter programme
20.2.87 Ealing Council and the London Borough of Hounslow stated that Heathrow should
provide safe, high quality cycle infrastructure for employees living near the airport.
Slough Borough Council and South Bucks District Council also supported the
provision of cycle routes.
20.2.88 Ealing Council and the London Borough of Hounslow also said that employees
can often benefit from a monthly season bus ticket and suggested that this could
be addressed through an expansion of the free travel zone for buses. Slough
Borough Council also suggested an extension of the free travel zone.
20.2.89 London Borough of Harrow expressed concern over the target to reduce staff car
journeys to Heathrow by 25% by 2030. They considered that meeting such targets
will be key to no adverse impacts on traffic congestion and air quality from
additional vehicle journeys.
20.2.90 Wokingham Borough Council agreed that Heathrow should continue their
commuter programme to reduce car use.
Statutory Consultees
General Comments
20.2.91 Highways England supported the aims of the Surface Access Strategy so long as
it considers their Surface Access Priorities. They highlighted the need for robust
multi-modal traffic modelling, including future proofing requirements, before any
final decisions are made on terminal locations, car parking or road and junction
locations and capacities. They also suggested the Surface Access Strategy be
flexible to accommodate changing circumstances without losing sight of strategic
principles.
20.2.92 In addition, comments were received from statutory consultees on the efficient and
responsible use of the road network and the commuter programme.
Modal share
20.2.93 Highways England also supported the targets for public transport use and no
increase in airport related traffic but requested greater clarity on what airport
related traffic is, as the current proposed definition appears to be too narrow.
They also recommended that robust and enforceable processes are needed
to correct or mitigate any divergence from the expected reduction in airport
related traffic.
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20.2.94 They also identified that the commitment to not increase airport related traffic will
redistribute traffic on some sections of the strategic road network for which
Heathrow will have to mitigate.
20.2.95 Natural England welcomed the ambition to expand airport capacity without any
increase in airport related traffic but stated that Heathrow must demonstrate that
this can and will be achieved with robust monitoring and that nitrogen-sensitive
designated sites will be avoided. They highlighted that the Habitats Regulations
require a high degree of certainty that any measures put in place to avoid or
mitigate impacts are deliverable.
20.2.96 They also suggested that a consistent measurement is used for colleague car trip
and passenger transport targets to ensure clarity relating to changes and targets
for surface access transport.
Enabling more efficient and responsible use of the road network
20.2.97 Highways England commented that the details of any proposed road charging
schemes should take into account the need to control any adverse impacts at the
charging boundary.
Building on our successful commuter programme
20.2.98 Highways England requested certainty on how Heathrow will achieve the
proposed targets for reducing staff car trips.
Other Prescribed Bodies
General Comments
20.2.99 Windlesham Parish Council expressed support for a wider surface traffic study and
road improvements but raised concerns about how Surrey Heath public transport
infrastructure will contribute to delivering the public transport passenger targets.
Windlesham Parish Council also suggested that a national approach to traffic was
required and commented that they would welcome the opportunity to discuss
transport to/from the airport across the M3 corridor.
20.2.100 The Heathrow Strategic Planning Group (HSPG) stated that recent commitments
by government for the Western and Southern Rail Links were a positive indication
that a suitable Surface Access Strategy can be developed.
Modal share
20.2.101 Iver Parish Council identified that there is no indication as to how the commitment
to not increase airport related traffic would be managed, monitored or enforced.
20.2.102 The HSPG said the consultation documentation does not provide any confidence
that the Project can be achieved with no increase in airport related traffic or that
progress to improve air quality in the surrounding area can be assured. They
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considered that approval should only be granted for the Project if the target for no
more airport related traffic can be met, or if increases in capacity are linked to the
achievement of the targets and made a condition of approval.
Putting Heathrow at the heart of the rail network
20.2.103 The HSPG considered that the Western and Southern Rail Links are needed now,
prior to the Project.
20.2.104 Network Rail considered that surface rail must provide an increase in journeys of
200-300%, and schemes such as the Western and Southern Rail Links are critical
to achieving this. They highlighted that Heathrow needs to work with its Western
Rail Link project team to provide assurance on compatibility of design.
20.2.105 They identified that further work is needed with funders and stakeholders to
develop the business case for future funding of the Southern Rail Link and
requested that Heathrow support a collaborative approach to funding and
financing.
20.2.106 They also stated that Heathrow should support both the Elizabeth Line and other
services between London Paddington and the airport to optimise the available
capacity and make system wide decisions.
Providing a public transport led scheme
20.2.107 Chobham Parish Council supported the provision of a public transport led scheme
for an expanded airport.
Providing a resilient and reliable road network
20.2.108 Albury Parish Council raised concerns about an increase of freight and
passengers on the M25 and A3. They said that rail and public transport will not
absorb this excess traffic, as it would be dependent on existing overloaded road
and rail networks. They also expressed concerns about bottlenecks during the
rebuilding of the M25/A3 Wisley interchange and upgrading the Dennis
interchange (A25).
Enabling more efficient and responsible use of the road network
20.2.109 Bray Parish Council expressed concerns with road user charging. They also stated
that it is not within Heathrow’s remit to consolidate the freight loads of cargo
companies and applying road user charging to freight vehicles will increase prices
with no decrease in traffic and pollution.
20.2.110 The HSPG stated that road user charging may not be effective and that there is no
clear detail on how it will be monitored and by who. They recommended that
emission charging should be for direct users of the airport rather than all vehicles
and that joint monitoring and review of air quality across the area is vital to the
success of achieving a reduction in emissions. They also suggested that there
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should be a combined logistics and freight strategy and an improvement on the
impact from freight.
20.2.111 Windlesham Parish Council expressed concern about the impact of the proposals
on local taxi companies and requested discussions with Heathrow regarding the
proposals for a preferential supplier system for taxi firms.
Building on our successful commuter programme
20.2.112 Windlesham Parish Council requested an opportunity to evaluate how transport for
airport workers can be incorporated into a wider public transport strategy across
the M3 corridor, incorporating passenger transport and airport access.
Local Communities
Members of the public
General Comments
20.3.1 Most responses from members of the public were general and provided negative
feedback about the Surface Access Strategy. These were often linked to negative
views about the extent of development or the Project.
20.3.2 These included general opposition to the Surface Access Strategy, that it was
insufficient, inadequate or would not be achievable due to inconsistencies between
the ambition of becoming traffic neutral and the proposals to expand. Comments
that the Surface Access Strategy would not resolve existing traffic congestion and
that there would be impacts on local people and local communities from both
traffic and unregulated parking in villages, specifically by taxis. Other members of
the public stated that a strategy was not required at all or raised concerns about
negative impacts on air pollution due to more traffic, longer journey times and
further congestion.
20.3.3 General positive comments were also received. Some said the Surface Access
Strategy would reduce the number of cars travelling to/from the airport; that local
cycle paths and accessibility would be improved and that it would address long
term requirements. Members of the public also considered that the Surface
Access Strategy would encourage more staff/workers to use public transport to get
to/from work at the airport.
20.3.4 Other respondents suggested that public transport should be subsidised, made
less expensive or free of charge, that public transport and rail access should be
improved and that road transport to/from the airport should be discouraged.
20.3.5 Queries were also received asking how the proposals would be funded, the cost
effectiveness of the Surface Access Strategy and the timescales for decision
making and its implementation.
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20.3.6 In addition, comments were received from members of the public on putting
Heathrow at the heart of the rail network, providing a public transport led scheme,
providing a resilient and reliable road network, strengthening the coach hub and
enabling more efficient use of the road network.
Putting Heathrow at the heart of the rail network
20.3.7 Members of the public commented that the proposals would improve rail access
to/from the airport including from the south and west and that there would be
benefits from the Elizabeth Line.
20.3.8 However, some also considered that the proposed Surface Access Strategy would
not improve the rail network, that there were no commitments to funding the
necessary improvements and that the proposals would not work or make any
difference. A small number considered that Heathrow was already well served by
the rail network and that improvements were unnecessary.
Providing a public transport led scheme
20.3.9 Responses received from members of the public relating to public transport often
said the Surface Access Strategy would result in improvements to public transport
in general and that it would result in improved bus services, improved public
transport links, improved accessibility to and around the airport and that it would
ease traffic congestion.
20.3.10 Other comments suggested that public transport was not a practical option for
passengers with luggage that the transport infrastructure would not be able to
cope, that improvements in public transport would not make any difference, that
there would be negative consequences for traffic congestion and that public
transport is unreliable and not cost effective.
Providing a resilient and reliable road network
20.3.11 Of the members of the public that commented on the road network, the main
comments were that the area was already heavily congested and that
improvements would make the road network more efficient for users. Some
considered that improvements would also make access to the airport by road from
the south better.
20.3.12 However, most that commented on the road network expressed concern about the
negative impacts during construction and operation, the impacts of congestion and
that the roads will be unable to cope with the increased number of cars. Specific
comments were also received which expressed concern about the impacts on
traffic and congestion on local roads, the M25, the M4 and the M40.
Strengthening the coach hub at Heathrow
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20.3.13 A small number of members of the public expressed support for the improvement
of the coach hub.
Enabling more efficient and responsible use of the road network
20.3.14 Members of the public expressed support for the proposals for road user charging
as they considered it would encourage public transport use and reduce the
number of cars on the road. Others suggested that road user charging would
result in better access and convenience for passengers, would ease congestion
and result in a reduction in emissions, noise pollution and an improvement in air
quality. Some also suggested that it would encourage the use of low emission
cars.
20.3.15 Negative comments about the proposals for road user charging were also
received. They said that:
1. the focus should be on improving public transport or electric cars;
2. the proposal was motivated by increasing revenue for the airport rather than
reducing impacts or delivering road improvements; and
3. it will not reduce the number of cars on the road or that it will just move
congestion to other places and drive businesses away from the airport,
affecting competitiveness.
20.3.16 Others commented that motorists are already taxed too much and that the
proposals for road user charging were unfair for those working at the airport, and
would also result in increases in taxi fares.
20.3.17 Members of the public also suggested that the revenue from road user charging
should be spent on improved public transport and public transport infrastructure or
that public transport should be affordable, subsidised or free. Suggestions that
residents who live near the airport should be exempt from any road charges were
also received.
Businesses
General Comments
20.3.18 The Copas Partnership commented that surface access should be continually
improved without delay.
20.3.19 Business South said that they were content for the airport to find the right option
for configurations.
20.3.20 The Hampshire Chamber of Commerce said that ongoing investment in road and
rail transport infrastructure is essential for an expanded Heathrow and there
should be a commitment to enhanced connectivity and congestion reduction,
aligned with the new runway development.
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20.3.21 Hatton Farm Estates Limited commented that the proposals for surface access
look sensible and are important for fast and affordable access to London.
20.3.22 Hatton Garden Trustees Limited and Pickering Properties considered that the
Surface Access Strategy proposals will help deliver a reduction in emissions and
limit fuel use, if applied correctly.
20.3.23 London (Heathrow) Airline Consultative Committee (LACC) and the Board of
Airline Representatives in the UK (BAR) supported the provision of varied,
affordable and reliable surface access options but expressed concern about the
affordability of the proposals. They stated that airlines and passengers should not
be responsible for subsidising national programmes or funding betterment of other
schemes and requested further engagement with the Airline Community in the
development of the Surface Access Strategy.
20.3.24 The Surrey Chambers of Commerce stated that the Surface Access Strategy is a
key part of the plans and the proposals seem well thought through.
20.3.25 Virgin Atlantic Airways Limited (Virgin) expressed concern that the Surface Access
Strategy is insufficiently developed and un-costed, with aspirational and
challenging objectives. They requested a detailed Surface Access Strategy,
including detailed modelling, evidence to support Heathrow’s ambitions, and an
assessment of the cost and risk to the entire scheme if the targets are not met.
Modal share
20.3.26 Greengauge 21 stated that a simple expansion of facilities will not achieve the
required increase in public transport mode share, zero growth of airport-related
vehicle traffic, local air quality limits and a reduction in the risk of unrestricted
vehicle access. They considered the benefits identified by the Airports
Commission and the draft ANPS for the national economy are at risk if the Project
is not accompanied by a clear strategic plan accompanied by new rail connections
and services.
20.3.27 LACC and BAR stated that Heathrow has not demonstrated how mode share and
employee car journey targets, as well as targets to limit freight movements, relate
to known air quality and/or congestion policy. They considered that the modal shift
targets should be reset to show that the airport is taking its ‘fair share’ of
congestion and will not increase road traffic. Also, that any schemes aimed at
reaching the targets must provide value for money and be in the interests of
passengers. They also suggested that Heathrow should analyse the needs of
specific groups of workers and passengers before defining the requirements.
20.3.28 Segro considered the mode shift targets ambitious and recommended that
Heathrow investigate the possibility of an extensive network of park and ride sites
to free up road capacity.
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20.3.29 Virgin stated that there is insufficient modelling or supporting evidence to
demonstrate that the aim of no increase in road traffic is anything other than
ambition. They expressed concern that as new runway capacity will not be made
available if noise, traffic or emissions targets will be breached, the new runway
may never be fully utilised. They considered this would undermine the economic
case for the Project.
Putting Heathrow at the heart of the rail network
20.3.30 Airlines for America stated that current rail and road access to the airport is
outdated and must be enhanced to enable airlines to cater for passenger demand
when the third runway is operational.
20.3.31 Airport Industrial Property Unit Trust (AIPUT) stated that the Western Rail Link and
the Southern Rail Link must be considered if the Project is to be successful.
20.3.32 The Brett Group suggested that their land at Hithermoor should be considered for
a new rail station as part of the Southern Rail Link.
20.3.33 Greengauge 21 stated that although the draft ANPS says an interchange at Old
Oak Common will enable airport passengers to make a connecting journey to
access HS2, air passengers would be heavily dissuaded from using rail if an
interchange is required. They also suggested that the Western Rail Link could
provide national connectivity but will only connect the airport with the Great
Western Main Line if passengers are prepared to change during their journey.
20.3.34 They also highlighted that Heathrow should be relieved of any obligation to fund
enhanced rail access infrastructure and should instead contribute to new rail links
through expenditure that can be taken in to account by the CAA.
20.3.35 The Hampshire Chamber of Commerce considered the Western Rail Access and
Southern Rail Link to be of significant national interest, serving a range of
economic needs supporting the Project.
20.3.36 Jayflex Aggregates Limited suggested that a new passenger transfer hub adjacent
to Wraysbury station would enhance rail access, as rail passengers could be
transferred in automated pods along the embankment of the Wraysbury Reservoir
as far as M25 Jct. 14 and from there directly into the airport Terminals.
20.3.37 Segro stated that the key to Heathrow’s transport strategy is the delivery of new
strategic rail services, including the Western and Southern Rail Links
complemented with a network of high quality and reliable park and ride facilities for
passengers arriving by car. They considered that this will help ensure that local
roads around the airport are not overloaded with passenger traffic and will allow
essential goods, services and cargo to move efficiently and sustainably to and
from the airport. They also stated that the Western Rail Link is required now to
support the two-runway capacity.
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20.3.38 The Thames Valley Chamber of Commerce said there is a clear business case for
the Western Rail Link based on a two or three runway airport. They suggested that
Heathrow actively participates in and leads the delivery of the Western Rail Link
before construction commences on the third runway.
Providing a public transport led scheme
20.3.39 Virgin welcomed the ambition to make the Project sustainable by providing high
quality reliable public transport links but said there is uncertainty as to who will
provide and pay for the different schemes and a lack of modelling to demonstrate
modal shift will take place.
Investing in local transport solutions
20.3.40 AIPUT considered it necessary to increase the provision of public transport options
to serve the southern side of the airport by bus.
Making public transport easier for users
20.3.41 GlaxoSmithKline (GSK) highlighted that a significant proportion of trips to the
airport are by road, which results in road congestion impacts on local businesses.
They suggested a review of the fare structure of public transport should be
undertaken and that there should be better access at stations and better north /
south rail services.
20.3.42 Segro supported the provision of enhanced bus services but expressed concern
about the ability to deliver new bus priority measures on roads that under the
control of local authorities and TfL. They stated that, without the full support of
these organisations, it is unclear how the free travel zone could be expanded.
Enabling more efficient and responsible use of the road network
20.3.43 AIPUT raised concerns about road user charging and low emissions zone
charging around the airport as they considered it may distort how the market
operates and negate the attempts to minimise traffic generation. They suggested
that Heathrow should consult with commercial operators and land owners to
ensure that it does not reduce competitiveness or lead to more traffic in areas on
the edge of the zone.
20.3.44 Airlines for America stated that proposals to limit vehicles accessing the airport
should be rejected. They expressed particular concern about proposals to charge
airlines and their passengers for the cost of the infrastructure work associated with
the Project.
20.3.45 The Copas Partnership considered that the focus should be on low emission
vehicles and that road user charging is not the right principle.
20.3.46 Electron Bean Processes Limited considered road user charging inevitable and
logical.
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20.3.47 The Fuel Trading Company generally supported road user charging but noted that
it works on the assumption that all the vehicles in and around the airport are
electric. They suggested that Heathrow consider using renewable diesel for bus
and coaches if a uLEZ is to be introduced.
20.3.48 GSK suggested that charging for passenger drop-off and collection should be
further reviewed as part of a wider strategy to increase the cost of road travel to
Heathrow compared with rail. They indicated that they would need to review the
impact of this on their business and the implications for staff and visitor travel if
road user charging and an airport uLEZ were to be considered.
20.3.49 Hatton Farm Estates Limited would be in favour of road user charging if electric
vehicle were exempt. This would encourage their use and not restrict vehicle
access for passengers.
20.3.50 LACC and BAR considered that Heathrow’s stated aim to ‘grow the airport without
increasing traffic’ does not appear to be realistic with respect to freight. They also
identified that any additional road user charges will directly impact the airport,
passengers and employees. They stated that alternative mechanisms and
schemes for promoting modal shift and meeting the targets of the ANPS should be
exhausted before additional charges to airport users are introduced.
20.3.51 Heathrow Southern Railway Limited supported the principle of vehicle charging to
encourage modal shift from road to rail. They considered this can only be justified,
and is only likely to be acceptable to airlines and passengers, if carried out in
conjunction with major improvements to public transport connections.
20.3.52 The Surrey Chambers of Commerce said that road user charging may be the only
way to encourage public transport use but only if public transport is readily
accessible.
20.3.53 Town Centre Securities PLC did not agree with the proposals for road user
charging as they believe it is not socially inclusive.
20.3.54 Virgin considered it unreasonable to pay a road user charge to access the airport
for private car or taxi on top of high airport charges and Air Passenger Duty.
20.3.55 WeMoved Limited suggested that the focus should be on autonomous vehicles
rather than road user charging.
Community Groups
General Comments
20.3.56 Aircraft Noise Three Villages and Englefield Green Action Group stated that a
Surface Access Strategy is not required if there is no third runway. Aircraft Noise
Three Villages also said that Heathrow should ensure there is no increase in road
traffic even as a two-runway operation.
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20.3.57 The Colnbrook Community Partnership expressed support for the priorities of the
Surface Access Strategy and the key initiatives which seek to shift passengers
and workers from private car to public transport.
20.3.58 Dover House Estate Residents Association stated that the Surface Access
Strategy was poor.
20.3.59 Ealing Aircraft Noise Action Group considered the surface access proposals
unrealistic and highlighted uncertainty around the funding contributions and
delivery of the Piccadilly Line upgrades and the Western and Southern Rail Links.
They also considered that proposals to promote walking and cycling should only
relate to staff working on the airport periphery and not to passengers or to staff
needing to go into the central area.
20.3.60 Ealing Fields Residents Association said that even with upgrades, the Project will
result in overcrowding on the Piccadilly Line. They also considered that a premium
fare on the Elizabeth Line will push more passengers onto the Piccadilly Line.
20.3.61 Eastcote Conservation Panel and SCR Residents for a fair consideration of
Heathrow expansion expressed concern that changes to road layouts, more public
transport and train links will cause more disruption to communities.
20.3.62 Mortlake with East Sheen Society suggested that Heathrow should start
developing the Surface Access Strategy now and not in the future. They stated
that rail trips to Heathrow from SW London involve a detour which is time
consuming, resulting in most trips being made by car or taxi.
20.3.63 Residents Association HVG CA said the Surface Access Strategy is not accurate
in terms of the number of people affected or the effects on quality of life.
20.3.64 Richmond Heathrow Campaign considered the surface access options have not
been through a proper assessment to consider the environmental, operational,
economic and financial implications. They considered that there is a risk that
demand and the required capacity to meet it has been significantly
underestimated.
20.3.65 Slough and District Against Runway 3 considered the proposals for surface access
are unrealistic and unacceptable due to the scale of land and property that will
need to be compulsorily acquired, which will lead to blight in neighbouring
communities.
Modal share
20.3.66 Four Lanes Are More Than Enough (FLAME) stated that the commitments to
increase passenger numbers travelling by public transport and not increase airport
related traffic are not credible. They also raised concerns about the pressure that
will be placed on the M25 if the pledges are not honoured.
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20.3.67 Local Conversation in Stanwell suggested that specific targets for maximising the
proportion of journeys made to the airport by public transport, cycling or walking
should be set and should apply to both the workforce and passengers.
20.3.68 Richmond Heathrow Campaign stated incentivising and supporting modal share
shift is insufficient and requires input from and cooperation with others. They
expressed concern that the government will end up paying Heathrow's surface
access costs and suggested that the surface access initiatives should be pursued
regardless of a third runway, so that rapid improvements to air quality are
delivered over and above those in the draft London Plan. They also highlighted the
release of runway capacity should be linked to surface access tests based on
predicted outcomes. The number of Heathrow related vehicles should be no more
than today and the tests must be based on targeted reductions in such traffic
compared to a ‘Do-minimum’ over future years.
20.3.69 Stanwell’s Green Lungs, Teddington Action Group and West London Friends of
the Earth suggested there must be no increase in road traffic and therefore no
need for new car parks or more road capacity.
Putting Heathrow at the heart of the rail network
20.3.70 The Camberley Society stated that there is a need for better transport links from
the west, south west and south including the proposed Southern Rail Link.
20.3.71 The Chertsey Society stated that they would oppose the Project unless a direct
link is provided to the South West Railway network. They stated that their
preferred option for this would be a light rail system from Chertsey in a tunnel.
They also expressed opposition to the Southern Rail Link which would require
heavy weight trains to cross over the M3, A30, River Thames and other local
roads.
20.3.72 The Colnbrook Community Partnership said that the Piccadilly Line is already
overcrowded and an expanded airport will put greater pressure on the public
transport system. They suggested that a link from the east would relieve much of
this overcrowding.
20.3.73 Egham Residents’ Association supported the principle of having direct rail access
to the airport from the south. They said their preferred option for this would be a
railway tunnel starting on the edge of Staines, emerging between Egham and
Virginia Water, and with a station within Runnymede Borough to provide a service
from Egham to the airport.
20.3.74 FLAME expressed support for the principle of a new direct rail link to the airport
from the south but raised concerns about the closure of level crossings because of
the effects on road traffic congestion. They also expressed concern about any
proposal to build a new railway line immediately alongside the M25 from Staines to
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Chertsey, due to adverse effects on local people and the disruption to the M25 and
other roads during construction.
20.3.75 The Fulham Society considered a new rail link from Waterloo to the airport via
Clapham Junction, Putney and Staines should be a priority.
20.3.76 Heathrow Association for the Control of Aircraft Noise (HACAN) expressed
support for increased frequency and operating hours on the Elizabeth line,
contribution to the costs for a new Western Rail Link and a new direct rail link to
Heathrow from the south. However, they expressed concern that there is no clarity
on the cost and who will pay for new heavy rail infrastructure. Without this the
achievement of no increase in airport related traffic or the modal shifts will not be
possible.
20.3.77 Heathrow U3 Sustainability Group expressed support for the Southern Rail Link.
They considered the Piccadilly Line improvements will reduce car use and the
proposals to use a freight line from Hendon and Cricklewood for passenger trains
would be an improvement.
20.3.78 Local Conversation in Stanwell considered the ‘no more traffic on the road’ pledge
cannot be delivered without improving rail access from the south.
20.3.79 Mortlake with East Sheen Society expressed concern about the potential for a
Southern Rail Link to cause traffic congestion at the level crossings in the
Mortlake/East Sheen area. They suggested that all level crossings should be
replaced by tunnels or bridges or an alternative route found to Waterloo.
20.3.80 The Pavilion Association expressed support for a rapid rail T5 – Staines park and
ride.
Providing a public transport led scheme
20.3.81 The Chiltern Society welcomed the proposals to increase surface access to the
airport by alternatives to car transport.
20.3.82 The Colnbrook Community Partnership queried whether a realigned A4 with two
lanes will have sufficient capacity for good public transport. They suggested that
an effective and efficient public transport system needs to be augmented for both
workers and travellers to and from the airport.
20.3.83 Friends of the River Crane stated that Heathrow should develop walking and
cycling routes that will provide safe and attractive routes into the airport as well as
alternative green transport links between each of the population nodes.
20.3.84 Local Conversation in Stanwell stated that affordable and convenient transport
choices for staff and passengers are critical to achieving sustainable surface
access.
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20.3.85 Richmond Heathrow Campaign said the planned increases in public transport
capacity are only sufficient to cater for growth in two runway demand.
20.3.86 Wentworth Residents Association expressed concern about the construction of car
parking and considered it contradicts the suggestion that most passengers/freight
will travel to/from the airport by public transport.
Providing a resilient and reliable road network
20.3.87 Eastcote Residents Association queried how route changes to the M25, A4, A312,
A30 and A3044 will ensure that there will be no increase in airport related traffic on
them.
20.3.88 The Hitcham and Taplow Society requested a ban on construction traffic on the A4
over Maidenhead Bridge as it is the only access from the west in the case of a
temporary closure of the M4.
20.3.89 Northumberland Walk Residents Association queried why road capacity needs to
be increased as Heathrow has stated that they will keep traffic volumes at current
levels.
20.3.90 Old Chiswick Protection Society expressed concern about the effect of increased
traffic on the M4 corridor in to and out of London, Hogarth roundabout and the
surrounding roads. They queried the plans for keeping traffic flowing with the
added pressure of extra transport to and from Heathrow.
Investing in local transport solutions
20.3.91 Ashford and Staines Community Centre highlighted recent cutbacks in bus
services and the need for better transport links to and from the airport from the
Ashford area.
20.3.92 The Camberley Society stated that there is a need for better transport links to
Heathrow from the west, south west and south from Farnborough and Camberley.
20.3.93 The Chiltern Society suggested that sustainable transport options are required to
improve access to the airport from towns in the Chilterns.
20.3.94 The Colnbrook Community Partnership stated that a cycle network is essential to
encourage workers to cycle to and from work and in the vicinity of the airport. They
suggested that this must be considered in the road alignments and junction
layouts of both the local road network and motorway.
20.3.95 Elmbridge Friends of the Earth suggested that there should be trains from stations
in Elmbridge and a local bus to provide local people with sustainable access to the
airport.
20.3.96 Local Conversation in Stanwell expressed concerns that there is no commitment
to provide improved public transport to meet the needs of an expanded airport,
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particularly to the south. They suggested that Heathrow considers where the future
workforce will be from and seek to encourage a greater spread of employees with
an equitable choice of transport modes.
20.3.97 Stanwell’s Green Lungs suggested bus connections to Terminal 5 via Stanwell
and Stanwell Moor should be restored and further consideration should be given to
a local tramway or light railway connection.
Enabling more efficient and responsible use of the road network
20.3.98 Aircraft Noise Three Villages, Stanwell’s Green Lungs, Teddington Action Group
and West London Friends of the Earth considered that consultation on road user
charging is the government's responsibility.
20.3.99 Camberley Society and the Cheyne Walk Trust did not favour road user charging.
20.3.100 The Colnbrook Community Partnership stated that road user charging is an
effective method to dis-incentivise vehicle use within certain areas but considered
that around the airport it will create disadvantages to local residents.
20.3.101 Dover House Estate Residents Association was supportive of road user charging.
Egham Residents Association also supported the principle of road user charging,
specifically on the basis of emissions.
20.3.102 Ealing Fields Residents Association considered that road user charging has a role
but that it would have no more effect than the already high parking charges.
Elmbridge Friends of the Earth shared a similar view commenting that that road
user charging will not necessarily reduce travel.
20.3.103 Englefield Green Action Group suggested residents within a 10-mile radius should
be exempt from road user charging. They also highlighted that the impact of an
increase in freight needs to be addressed, including HGV parking, road
congestion, infrastructure damage and the increase in air pollution from diesel
engine HGV vehicles.
20.3.104 HACAN stated that it is not clear whether a congestion charge scheme would be
required but said that Heathrow should have a scheme that is ready to be put in
place should it be required.
20.3.105 Harrow U3 Sustainability Group expressed support for road user charging if there
are adequate improvements in public transport. The Wentworth Residents
Association shared a similar view but indicated that the charging is not a fix for a
lack of public transport investment.
20.3.106 The Richmond Heathrow Campaign also stated that road-user charging and car
parking charges can be effective tools but must be accompanied by alternative
public transport. They considered that these measures should be pursued to
improve air quality regardless of a third runway.
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20.3.107 Local Conversation in Stanwell expressed support for the principle of a uLEZ but
stated that cars should not be displaced into surrounding areas to park on local
roads. They also commented that a fund must be provided to support major
surface access schemes and sustainable transport projects in the wider area to
the benefit of local communities.
20.3.108 Residents Association HVG CA said the proposal for road user charging has not
been researched properly or accurately and it will not work.
20.3.109 SCR Residents for a fair consideration of Heathrow expansion stated that airport
employees will have the road user charging factored into rates of pay or contracts
and it will instead have the greatest effect on local residents who are not
compensated through employment.
20.3.110 Slough and District Against Runway 3 considered that a road user charge will
make no difference to air and noise pollution.
Wider/other consultees
General Comments
20.4.1 Association of British Travel Agents (ABTA) stated that surface access is crucial in
the choice of a passenger’s departure airport and recommended an increased
focus on improved surface access benefitting passengers and staff, as well as the
local population.
20.4.2 The Chartered Institute of Highways and Transportation (CIHT) expressed support
for the priorities and initiatives in the Surface Access Strategy but queried whether
they were all achievable.
20.4.3 Lambeth/Herne Hill Green Party stated that the initiatives identified are vital to
drive the development of the Surface Access Strategy and achieve the identified
priorities.
20.4.4 The London Parks and Gardens Trust welcomed all transport that minimises
environmental impacts.
20.4.5 The Kingston Environment Forum considered the plans inadequate, relying too
much on travellers using clean transport options.
20.4.6 The Liberal Democrats expressed concern at the lack of commitment from
Heathrow to fund new public transport infrastructure. They considered the Surface
Access Strategy to be dependent on projects to manage current demand that are
funded and controlled by other bodies.
20.4.7 The London Wildlife Trust expressed support for initiatives to provide more
sustainable travel alternatives but requested consideration of how the airport will fit
into the existing cycle and footpath network.
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20.4.8 The Mayor of London stated that the Surface Access Strategy is almost wholly
dependent on pre-existing rail schemes such as the Elizabeth and Piccadilly Line
upgrades which were planned based on a two-runway Heathrow. He considered
that the Project would result in worsening congestion and delays on the roads and
increased crowding on the railways.
20.4.9 The National Trust expressed concern about the indirect impacts of increased
levels of traffic and parking, new transport infrastructure and new railway lines.
20.4.10 The Richmond Cycling Campaign indicated the Project should not lead to an
increase in climate-changing emissions, or any increase in motor vehicle volumes
(and resulting pollution and emissions).
20.4.11 The Royal Parks stated that transport links are important but expressed concern
about new transport infrastructure affecting the Longford River.
20.4.12 Transport for the South East expressed concern that there is not a coherent view
on how the airport sits within the wider transport network and indicated that a more
coherent and integrated strategy should be produced, with Heathrow taking the
lead.
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Modal shift
20.4.13 CIHT considered the modal shift target will be difficult to achieve and expressed
concern that there is minimal explanation as to how the increase in public
transport usage would be achieved and funded.
20.4.14 Dominic Raab MP stressed the importance of Heathrow meeting its modal shift
and airport related traffic commitments, to ensure that the existing road network in
Elmbridge is not put under further strain from traffic generated by a third runway.
He suggested the Environment Agency or another body be mandated to monitor
the full environmental impact of the airport, including any additional congestion.
20.4.15 England’s Economic Heartland considered the pledge to have ‘no net increase’ in
airport related traffic and corresponding investment in surface access capacity can
enable the required improvements in air quality.
20.4.16 Enterprise M3 LEP considered that the lack of a detailed integrated Surface
Access Strategy for passengers, freight and workforce was a serious failing and
that without major infrastructure investment Heathrow will be unable to meet
modal split and sustainable transport targets. They also expressed concern that
without additional sustainable surface access the airport will not be able to
contribute fully to the economy or meet the demands of future air travel growth.
20.4.17 The Mayor of London stated that there are a lack of tangible commitments by
Heathrow to ensure no increase in airport related traffic. He queried what happens
if some of the measures do not come forward and suggested that if Heathrow’s
analysis has identified an alternative package of schemes this should be published
together with details of how these schemes will be delivered.
20.4.18 Transport for the South East also considered that meeting modal split and
sustainable transport targets without major infrastructure investment needs to be
properly evidenced, especially given recent evidence from the ANPS consultation
that passenger demand will grow faster than first expected.
Putting Heathrow at the heart of the rail network
20.4.19 ABTA welcomed the proposals for a Southern Rail Link and the introduction of
direct access to Heathrow by the Elizabeth line in 2018.
20.4.20 Bracknell Forest Economic and Skills Development Partnership highlighted the
importance of a Southern Rail Link to the future success of the airport and
recommended that it should form an integral part of the Project. They expressed
concern that without such a link residents and businesses would continue to suffer
from long and difficult public transport journeys to and from the airport, made
worse by the Project.
20.4.21 Crossrail to Ebbsfleet identified that Kent and much of South East London still lack
a direct, high-capacity connection to the airport and the Crossrail to Ebbsfleet
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scheme is a vital part of reducing car journeys and in helping Heathrow to tackle
air quality impacts.
20.4.22 England’s Economic Heartland expressed support for Heathrow’s financial support
for the new Western Rail Link but considered that this should be provided as
matter of urgency in support of current airport operations. They also suggested
that strategic access could be provided to the airport by linking it to a single
interchange at Old Oak Common and requested that the High Wycombe to Old
Oak Common link is recognised as one of the key building blocks to enable
passengers and staff to sustainably access an expanded airport.
20.4.23 Enterprise M3 LEP expressed disappointment that the Western and Southern Rail
Links were not identified as essential schemes. They considered that the case for
these schemes has been more than clearly made for a two-runway airport.
Transport for the South East shared a similar view stating that the Western and
Southern Rail Links were identified by the Airports Commission as being justified
on the basis of a two-runway airport.
20.4.24 Heathrow Southern Railway Limited suggested TfL’s analysis concludes that both
the Western and Southern Rail Links are essential for the Project. They
considered the government’s call for ‘Market Led Proposals’ identifies the
Heathrow Southern Rail Link as a priority and Heathrow Southern Railway Limited
proposals would provide this.
20.4.25 Hounslow Green Party stated that the new rail schemes are not realistically costed
and Heathrow is neither willing nor able to fund them.
20.4.26 The Liberal Democrats stated that they would like to see firmer commitments from
Heathrow on plans to contribute to the cost of the Western Rail Link. They stated
that without a financial contribution to the costs of increasing the frequency of
trains on the Elizabeth Line or to the development of the Southern Rail Link, it is
difficult to see how the Surface Access Strategy would be fulfilled.
20.4.27 The London Cycling Campaign suggested Heathrow ensure that walking and
cycling are enabled and there should be no increase in road vehicles across the
area.
20.4.28 The Thames Valley Berkshire LEP identified that their priority for infrastructure
investment is the Western Rail Link scheme and that it is required for a two-
runway airport.
20.4.29 World Federalist Party said the priority should be improving the public transport
infrastructure.
Providing a resilient and reliable road network
20.4.30 CIHT expressed concern at the provision of ‘a resilient and reliable road network’
noting that many of the schemes are designed to deal with existing growth in
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demand and not the extra journeys generated by an expanded airport. They
suggested an integrated approach between Heathrow, the DfT and Highways
England will be required to ensure a good level of service for road users.
20.4.31 Transport for the South East highlighted that the DfT-sponsored M25 South
West Quadrant study has identified several options for further consideration
and recommended that these need to be integrated far more closely into the
Project proposals.
Strengthening the coach hub at Heathrow
20.4.32 England’s Economic Heartland supported the expansion of the coach and bus
hub, noting that there is an opportunity to introduce new services or increase
frequency either directly to the airport or to connect with direct train services via
East West Rail, the Elizabeth Line and mainline stations in and near the
Heartlands area.
Investing in local transport solutions
20.4.33 London First welcomed the reference to demand responsive transport.
20.4.34 The Colne Valley Regional Park considered that walking and cycling needs to
become part of an integrated approach to reducing traffic and managing air
quality. They also considered cycling and walking routes need to serve people
accessing the Colne Valley Regional Park, create important links and build on the
strategic green infrastructure network.
20.4.35 Ealing Cycling Campaign said the new runway would present one of the largest
barriers to north-south cycling in London and suggested that Heathrow includes a
tunnel for cyclists under the runway. They suggested that there should be a more
central north-south cycle route through the airport, which could potentially be
combined with the proposed new southern access to the central terminal area.
Also, that there could be cycle routes around the perimeter and to the west and
south of the airport. They also highlighted that cycle hub areas will require large
amounts of cycle parking.
20.4.36 The London Cycling Campaign highlighted that much of the area surrounding the
airport is inhospitable to cycling and/or walking and that better walking and cycling
routes, connections and neighbourhoods should be provided. They identified that
corridors aligned with Bath Road, Staines Road east-west, High Street Harlington,
the A408, Parkway and A3063 north-south, Hayes, Yiewsley, Southall and
Hounslow as areas that should be prioritised.
Enabling more efficient and responsible use of the road network
20.4.37 The British Helicopter Association expressed opposition to road user charging,
considering it to be a stealth tax.
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20.4.38 The Chartered Institute of Logistics and Transport supported the principle of road
pricing and suggested that a commitment to use the proceeds to provide transport
improvements could improve its acceptance.
20.4.39 The CIHT also supported the principle of road user charging and suggested that
the London Congestion Charge is a useful model. They recommended that the
DfT and the local transport authority develop a scheme to minimise the impact of
the airport on surrounding communities, and which provides additional funds to the
local highway network including sustainable travel options for those working at the
airport.
20.4.40 The Colne Valley Regional Park suggested road-user charging be implemented in
a way that reduces traffic, poor air quality and noise impact on the Park and its
local communities. They expressed concern about the risk of introducing
excessive charges that lead to car drivers using surrounding villages as
alternatives for parking. The London Wildlife Trust expressed a similar view stating
that any road-user charging should be implemented in a way that reduces traffic,
poor air quality and noise impact on the natural environment.
20.4.41 World Federalist Party and Lambeth/Herne Hill Green Party supported road user
charging.
20.4.42 London First welcomed the option of restricting vehicle access through emissions
or access-based charging, suggesting that further analysis of congestion, charging
and other interventions should be undertaken.
20.4.43 The London Cycling Campaign supported road-user charging and/or other
methods to reduce private motor vehicle volumes. They suggested that these
approaches must be considered across the entire area to avoid either displacing
private car journeys to a few stops down the underground line or nearby hotels
etc.
Building on our successful commuter programme
20.4.44 The CIHT expressed support for Heathrow’s work on sustainable travel plans for
its staff and contractors, to reduce reliance on private motor vehicles.
20.4.45 London First welcomed the awareness of changing staff travel behaviour and
encouraged Heathrow to think creatively about how this might be achieved.
20.4.46 The London and Richmond Cycling Campaigns stated that more could be done to
ensure that a far higher proportion of those working at or near the airport can cycle
to work. The London Cycling Campaign recommended that Heathrow sets a clear
target for cycle journeys for staff that exceed TfL targets for London and develops
a plan to deliver the infrastructure necessary to meet any cycling targets in the
Surface Access Strategy.
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20.4.47 The Richmond Cycling Campaign recommended that conditions for cycle access
to Heathrow will require an improvement to cycle superhighway standard and
secure cycle parking at all parts of the airport where employees are based.
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Issues Raised and Heathrow’s Responses
The table below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Surface Access. None of the feedback received in relation to Surface Access is directly related to the
proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019) but
instead relate to other aspects of the Project. The table therefore provides a summary of the way in which we are seeking to
consider the issues raised, and are provided for information only. No further feedback is being sought on the basis that a full
consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.
Table 20.1B
Issue Consultee4 Heathrow Response
PC MC WC
Public transport should be affordable, subsidised or free. ✓ The Airport Expansion Consultation One (January
2018) document, Our approach to developing a
surface access strategy explained the options
Heathrow was considering to make public transport
easier to use. This included measures to build on the
success of the Free Travel Zone, which provides free
travel by public transport around the Heathrow
Campus for passengers and colleagues.
Public transport should be subsidised, made less expensive or free
of charge.
✓
There should be a review of the fare structure of public transport
along with better access at stations and better north south rail
services.
✓
4 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Issue Consultee4 Heathrow Response
PC MC WC
Without the full support of Local Authorities and TFL, it is unclear
how the free travel zone could be expanded.
✓ At the Airport Expansion Consultation One (January
2018) Heathrow also expressed an intention to work
with local transport operators to make travel to and
from the airport on public transport as affordable as
possible. This could be through offers and promotions
on Heathrow’s services or negotiated discounts with
other operators.
With the significant upgrade in rail capacity and
frequency due to the introduction of the Elizabeth line
and Piccadilly line upgrade, there is an opportunity to
review the pricing structure of Heathrow Express fares
to ensure the service provides the optimal customer
experience and demand requirements. Making
efficient use of available rail capacity will be a key
driver in making public transport more accessible for
both passengers and colleagues.
The Airports National Policy Statement (ANPS) at
paragraph 5.7 identifies major rail improvements that
would support a new north west runway. In
considering the surface access infrastructure needed
to support the expansion plans, Heathrow must have
regard to paragraph 4.39 of the ANPS. This requires
Heathrow to demonstrate that its scheme is cost-
efficient and sustainable, and seeks to minimise costs
to airlines, passengers and freight owners over its
lifetime. Heathrow is supporting Network Rail’s
Development Consent Order (DCO) application for a
Western Rail Link to Heathrow and is supporting the
emerging plans for a Southern Rail Link. DfT is
exploring the potential for a Southern Rail Link to be
brought forward with private sector involvement.
There should be an extension of the free travel zone. ✓
Public transport is unreliable and not cost effective. ✓
Public transport and rail access should be improved. ✓
Public transport is not a practical option for passengers with
luggage.
✓
Concern expressed about the frequency and timing of local services
and a lack of detail on how Heathrow will engage with the industry
to improve frequencies to at least five an hour.
✓
Heathrow should be required to pay for enhanced service levels. ✓
Enabling passengers and employees to easily obtain economic,
flexible tickets and incorporating free or discounted surface access
public transport tickets as part of an airline ticket package would
make public transport more accessible and easier to use.
✓
Affordable and convenient transport choices for employees and
passengers are critical to achieving sustainable surface access.
✓
Making all public transport options easier for users is essential to
transfer mode share away from the private car.
✓
Integrating ticketing for onward travel could create a seamless ✓
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Issue Consultee4 Heathrow Response
PC MC WC
journey for passengers. Elizabeth Line services will begin operations to
Heathrow in 2019.
Heathrow is committed to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips in the
ANPS. Heathrow will also continue to strive to meet its
pledge to have landside airport-related traffic no
greater than today.
Heathrow has been working with colleagues at the
airport to reduce the number of people driving single
occupied, private cars to work. Heathrow has invested
in a dedicated commuter team as well as local
transport to make it easier and more affordable for
people to use.
Outside the airport boundary, Heathrow is committed
to working with Highways England, Network Rail, TfL,
local authorities and transport operators to understand
and plan for the transport needs of the local
communities affected by the expansion.
At the Airport Expansion Consultation One (January
2018) the Our approach to developing a surface
access strategy document explained the measures
being considered to increase public transport use and
reduce the need to travel more generally. This
included consideration of an access charge /
emissions charge to access Heathrow and improved
taxi / PHV management. In addition, the Our
Emerging Plans document set out proposals that
would rationalise the existing four terminals, focused
on Terminal 5 and Terminal 2. This would focus
Better advertising and information about the free travel zone is
required and a review of the pricing structure for public transport to
the airport is needed.
✓
The focus on public transport is a good thing but is there a real
commitment to its delivery. The intention to align employment and
public transport is welcomed, but there is a lack of incentives to
reduce car use.
✓
Road, rail and other public transport access to the airport needs to
be high quality, efficient and reliable for both passengers and
workers and it must maximise the number of journeys to the airport
by sustainable forms of transport.
✓
Flights should be timed to depart and arrive at times when public
transport is available and any increases in capacity should be
subject to the provision of additional public transport capacity.
✓
Heathrow must help to fund/support mass rapid low emission
transport schemes to improve the links and journey time to the
airport.
✓
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Issue Consultee4 Heathrow Response
PC MC WC
activity and trips along the existing public transport
spine (with the addition of new Elizabeth Line
services) and improved bus and coach facilities at the
Terminals. Fewer larger terminals will also reduce the
need to travel around the airport, between terminals.
The draft Surface Access Strategy, supported by
technical information in the Preliminary Transport
Information Report (PTIR), will explain Heathrow’s
preferred options for the transport infrastructure
needed to support the expansion plans in the context
of increasing the use of public transport by
passengers and colleagues. This includes plans for a
new car park strategy and freight/logistics strategy.
This will be part of the documents published at the
Airport Expansion Consultation in June 2019.
Consideration should be given to other schemes to enable use of
more sustainable transport modes such as the High Wycombe rail
connection to Old Oak Common, coach links to Handy Cross hub
and re-opening of the High Wycombe to Bourne End heavy rail line.
✓ Heathrow supports improved public transport links
from areas that currently do not have direct links to the
airport. Improved bus / coach and rail options are
being investigated as part of the overall surface
access strategy, and links from High Wycombe and
Buckinghamshire more generally will be considered as
part of this. Bus and coach are key modes of travel for
Heathrow passengers and colleagues. Heathrow is
investigating the possibility of improving and extending
local bus services to the airport to capture demand
from wider areas and make travel by bus and coach
more attractive. The emerging Surface Access bus
and coach strategies are exploring how Heathrow can
promote the use of the buses or coaches by making
them a more attractive mode of transport through the
Heathrow’s aspirations are supported and should develop the
public transport network. There is also potential for services to feed
into Buckinghamshire using key transport hubs.
✓
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Issue Consultee4 Heathrow Response
PC MC WC
introduction of new express services, improvements to
the frequency and alignment of existing routes, and
extending operating hours. A draft Surface Access
Strategy will be consulted on at the Airport Expansion
Consultation (2019).
The Elizabeth Line will begin operating to Heathrow in
2019, offering the potential for connections to be
made from destinations in Buckinghamshire. In
addition, Heathrow is supporting Network Rail’s
proposal for a Western Rail Link to the airport from the
Great Western Mainline, which is the subject of a
separate DCO application. This may also provide
opportunities for connecting bus and coach services to
Reading and Maidenhead from Buckinghamshire.
Not certain if ‘on-demand services’ which are a cross between
private taxi and public bus should be defined as public transport.
✓ Heathrow is exploring the potential of Demand
Responsive Transport (DRT) services to fill gaps in
the public transport network early in the morning or
late at night, particularly to enable colleagues to travel
to and from the airport. Heathrow intends to trial DRT
services in the near future and roll them out to further
areas if the prove to be successful. Heathrow
acknowledges that as DRT technology evolves, it may
be necessary to adapt current definitions of what
constitutes public transport.
A commitment should be made to improve links to areas with low
public transport use.
✓ On the basis of the analysis carried out to date
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provides an
effective means of meeting the surface access targets
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Issue Consultee4 Heathrow Response
PC MC WC
to increase the proportion of passengers travelling by
public transport and reduce the number of colleague
car trips. Further assessment and analysis is ongoing
by Heathrow to determine exactly which combinations
of measures are required by which date to deliver the
best surface access for the expanded airport.
Heathrow is working with Highways England, Network
Rail and TfL to co-ordinate the expansion plans with
their investment plans in the Heathrow area.
As part of an integrated surface access strategy, a
variety of measures are being considered to help meet
the surface access targets. Heathrow supports the
provision of improved public transport facilities to and
from the airport and is currently investigating a
number of options to improve access by rail,
underground and bus. For instance, Heathrow is
investigating the possibility of improving and extending
local bus services to the airport to capture demand
from wider areas. Heathrow is supporting Network
Rail’s DCO application for a Western Rail Link to
Heathrow and is supporting the emerging plans for a
Southern Rail Link to Heathrow. DfT is exploring the
potential for a Southern Rail Link to be brought
forward with private sector involvement. Elizabeth Line
services will begin operations to Heathrow in 2019,
which will provide a direct rail link to Heathrow from
the City and areas to the east for the first time.
The local area is poorly served by sustainable transport access to
the airport.
✓ The ANPS states at paragraph 3.36 that, “Heathrow
Airport already has good surface transport links to the
rest of the UK. It enjoys road links via the M25, M4,
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Issue Consultee4 Heathrow Response
PC MC WC
M40 and M3, and rail links via the London
Underground Piccadilly Line, Heathrow Connect, and
Heathrow Express. In the future, it will connect to
Crossrail, and link to HS2 at Old Oak Common. Plans
are being developed for improved rail access: the
proposed Western Rail Access could link the airport to
the Great Western Main Line, and Southern Rail
Access could join routes to the South Western
Railway network and London Waterloo Station. This
varied choice of road and rail connections makes
Heathrow Airport accessible to both passengers and
freight operators in much of the UK, and provides
significant resilience to any disruption.” Where there
are gaps in provision, the Surface Access Strategy -
informed by the technical assessment work in the
Transport Assessment - will set out practical
measures, including new and enhanced public
transport provision, that will seek to address them. A
draft Surface Access Strategy and a Preliminary
Transport Information Report (PTIR) will be consulted
on at the Airport Expansion Consultation in June
2019.
Improvements to sustainable transport modes need to be
implemented before the expansion is complete.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provide an effective
means of meeting the surface access targets and
pledges. Further assessment and analysis is ongoing
by Heathrow to determine exactly which combinations
of measures are required, by which date, to deliver the
best surface access for the expanded airport.
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Issue Consultee4 Heathrow Response
PC MC WC
Heathrow is working with Highways England, Network
Rail and TfL to co-ordinate the expansion plans with
their investment plans in the Heathrow area.
Keen to work with Heathrow to ensure that hub locations are
appropriately located to enable airport related employees to travel
by public transport.
✓ Many Heathrow colleagues live in boroughs close to
the airport such as Hillingdon, Hounslow, Ealing,
Slough and Spelthorne. These are also the areas with
the highest proportion of people travelling to work by
public transport. Where there are good alternatives,
people are using public transport or other sustainable
modes such as car sharing to get to work. Heathrow
will work with TfL and other transport operators to
create the conditions that will encourage colleagues to
use public transport rather than drive to the airport, by
making it more attractive as an option.
Heathrow has been working with colleagues at the
airport to reduce the number of people driving single
occupied, private cars to work. Heathrow has invested
in a dedicated commuter team, as well as local
transport, to make it easier and more affordable for
people to use. Heathrow will seek feedback on more
detailed plans as part of the draft Surface Access
Strategy which will be published as part of Airport
Expansion consultation in June 2019.
Rapid low emission transport schemes must be located where
demand is and the number of shuttles operating from hotels should
be limited with mass rapid transit facilities used to access the
airport.
✓ Heathrow will work with TfL and local authorities to
identify new and improved bus priority measures that
could be considered to improve the reliability and
experience of bus users to/from Heathrow. As
explained in the Our approach to developing a surface
access strategy document at the Airport Expansion
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Issue Consultee4 Heathrow Response
PC MC WC
Consultation One (January 2018), Heathrow is
considering the following bus priority measures for the
airport:
• Implementing an internal campus road network that enables easy access to terminals for buses
• Introducing bus-only corridors to Heathrow – exact locations to be determined; and
• Providing off-campus bus priority measures - re-allocate road space for buses (working with TfL/highway authorities) and coaches (working with Highways England) to improve journey times and reliability.
The Surface Access Strategy is also supported by an
Intelligent Mobility Strategy which considers the
potential for technological change in transport,
including the potential development of autonomous
vehicles, and explains how the benefits arising from
these changes can be captured. Heathrow will seek
feedback on more detailed plans as part of the draft
Surface Access Strategy which will be published as
part of Airport Expansion Consultation in June 2019.
Concerns expressed about the impact of the proposals on local taxi
companies. Discussions should take place with Heathrow regarding
the proposals for a preferential supplier system for taxi firms.
✓ The ANPS contains surface access targets around
public and colleague mode share which Heathrow will
need to meet. Heathrow’s strategy to meet these
requirements will necessarily include consideration of
taxis and private hire vehicles (PHV). Measures to reduce the number of taxis and private hire vehicles
that travel to/from the airport empty are supported. These vehicles
✓
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should not be defined as public transport. Heathrow is considering a range of measures to make
taxi operations more efficient, backfilling return
journeys and delivering higher vehicle occupancy.
These could include:
• priority taxi queueing for full arrivals - taxis arriving with a passenger are given a preferential lane for re-ranking which would reduce the amount of time spent waiting for their next fare;
• a taxi sharing scheme - many taxi passengers are heading to central London and other high density urban locations. Priority lanes within the forecourt for these customers that are willing to share a taxi could decrease vehicle traffic and reduce the waiting times and costs for passengers.
Local taxi companies will have the opportunity to
comment on Heathrow’s proposals to make taxi
operations more efficient as they emerge through the
pre-application consultation process.
The draft Surface Access Strategy will be published
as part of the Airport Expansion Consultation in June
2019 and will explain Heathrow’s preferred options for
managing taxis and PHVs at the airport. More efficient
management of taxis at the airport will reduce the
need for taxis to park and wait in streets around the
airport. Heathrow will also work with local authorities
to develop schemes to prevent taxis parking on local
residential roads, including support for the introduction
of Controlled Parking Zones (CPZs) and their
More information is required to demonstrate the effectiveness of the
proposed measures to make taxis more efficient. This should
include more innovative solutions including the use of online trip-
matching systems and reward and penalties for efficient and
inefficient operators such as introducing a charter for all private
hire vehicles seeking to access the site which encourages
backfilling or incentivising operators to sign up to the charter
and/or a reward scheme.
✓
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enforcement.
Concern expressed over the feasibility and deliverability of satellite
consolidation sites, the ability to incentivise and/or compel
companies to participate, and the lack of detail on mitigation if such
plans are not successful.
✓ At the Airport Expansion Consultation One (January
2018), Heathrow explained its proposals for a “Freight
Hub” in the Our Emerging Plans document. Chapter
10 included three options for a modal hub that sought
to offer opportunities to consolidate freight operations
in locations close to existing infrastructure, such as
main access routes to the airport and the existing rail
head at Colnbrook. In addition, four locations were
considered for a “Truck Park” in order to provide
appropriate facilities for long distance drivers and
improved management for HGVs, mitigating the
impact of freight traffic on the roads around Heathrow.
Through the masterplan, the modernisation of the
airport cargo facilities will help allow more cargo to be
processed on airport, reducing the need for goods to
be trucked to and from off airport warehouses.
Cargo and logistics facilities around the airport have
grown in an incremental and organic way which
means there are lots of facilities in different locations.
By working with the local authorities to more
proactively plan the land uses around the airport,
Heathrow can provide facilities in appropriate
locations, helping to reduce shuttling movements
through consolidation of loads and reducing impacts
on local communities.
Heathrow will be working with TfL and other
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authorities on re-timing journeys that are not time
critical to outside peak periods, monitoring of routing
for HGVs and other freight vehicles, as well as
ensuring there are appropriate measures in place for
those that do not comply.
In October 2017, Heathrow published a “Blueprint for
Sustainable Freight”. This included ten measures to
provide for more efficient management of freight
vehicles, in partnership with industry bodies and major
freight operators. The ten steps included:
• Using innovation through tools like a load
consolidation “Heathrow Cargo Cloud” app for
local forwarders and the trial of low emission
freight vehicles and geo-fencing technology to
reduce emissions on local roads;
• Investments in airfield charging points to
install an ultra-low emission zone for vehicles
on-airport;
• Modernising cargo infrastructure at the airport
to allow for more airside transhipments,
consolidation points away from airport local
roads and a new cargo village that reduces
unnecessary vehicle movements;
• Working with local authorities to address
congestion points with a Code of Conduct for
operators, and a joint strategic freight plan for
local roads.
Following ongoing technical assessment work and
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engagement, Heathrow will publish its preferred
options for a Freight Hub and measures to manage
freight trips around the airport in a draft Surface
Access Strategy and an Updated Scheme
Development Report at the Airport Expansion
Consultation in June 2019.
Heathrow’s stated aim to ‘grow the airport without increasing traffic’
does not appear to be realistic with respect to freight.
✓ Heathrow will continue to strive to meet its pledge to
have landside airport-related traffic no greater than
today, including freight traffic. Heathrow will help
operators clean up the vehicle fleets through a range
of different initiatives, including increasing efficiency,
optimising the fleet mix and modernisation of airport
cargo facilities. The approach and options being
considered in relation to freight were set out in the
Airport Expansion Consultation One (January 2018) in
the Our approach to developing a surface access
strategy. The preferred option for freight management
under expansion will be set out in the Airport
Expansion Consultation in June 2019. Heathrow
published a Blueprint for Sustainable Freight as part of
the Heathrow 2.0 Sustainability Strategy, which has
informed the emerging freight proposals for the
expansion plans.
Through the masterplan, the modernisation of the
airport cargo facilities will help allow more cargo to be
processed on airport, reducing the need for goods to
be trucked to and from off airport warehouses. Cargo
and logistics facilities around the airport have grown in
an incremental and organic way which means there
are lots of facilities in different locations. By working
There should be a combined logistics and freight strategy and an
improvement on the impact from freight.
✓
It is not within Heathrow’s remit to consolidate the freight loads of
cargo companies and applying road user charging to freight
vehicles will increase prices with no decrease in traffic and
pollution.
✓
Heathrow working with local communities and freight industry
ahead of expansion is welcomed.
✓
The impact of an increase in freight needs to be addressed
including HGV parking, road congestion, infrastructure damage and
the increase in air pollution from diesel engine HGV vehicles.
✓
Heathrow’s stated aim to ‘grow the airport without increasing traffic’
does not appear to be realistic with respect to freight.
✓
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with the local authorities to more proactively plan the
land uses around the airport, Heathrow can provide
facilities in appropriate locations helping to reduce
shuttling movements through consolidation of loads
and reducing impacts on local communities.
Heathrow will work with TfL and other authorities on
re-timing journeys that are not time critical to outside
peak periods, monitor routings for HGVs and other
freight vehicles, and ensure that there are appropriate
measures in place for those that do not comply.
Concerns expressed about the construction of car parking and it
contradicts the suggestion that most passengers/freight will travel
to/from the airport by public transport.
✓ The total number of parking spaces available at
Heathrow is limited by an existing planning condition.
Heathrow’s current masterplan proposals would seek
to provide a similar number of car parking spaces as
permitted at the airport today, despite the increase in
passenger and staff numbers that would result due to
expansion. A sustainable level of passenger car
parking will continue to be provided as an alternative
to “kiss and fly” trips, which are an inefficient means of
accessing the airport. As part of the plans to reduce
colleague car trips, Heathrow will reduce the number
of parking spaces available for colleagues working at
the airport. However, Heathrow recognises the need
to be careful that this does not encourage more pick
up and drop off trips, whether by private car or taxi.
With expansion, a lot of the car parking along the
north side of Heathrow will be demolished. To ensure
Heathrow efficiently use all land available today and
There must be no increase in road traffic and therefore no need for
new car parks or more road capacity.
✓
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minimise the need to acquire land, it is likely that car
parking will re-provided by creating multi-storey car
parks.
Managing car parking is part of how Heathrow will
meet the surface access targets in the ANPS and how
Heathrow will manage air quality around the airport. In
addition to the re-provision of demolished car parking,
Heathrow’s thinking at Airport Expansion Consultation
One (January 2018) was to vacate some of the
existing surface level passenger and colleague car
parks and use a smaller number of multi-level car
parking sites, which are located near main access
routes and have dedicated access to the front door of
terminals. This will reduce traffic circulating around the
airport and improve way-finding. The consolidation of
passenger and colleague car parking also provides
the flexibility to change colleague and passenger car
parking allocations over time, in line with phasing and
meeting time-dependent NPS targets, as well dealing
with future vehicle types and technologies.
It is unacceptable for expansion to have a detrimental effect on the
road network as it would not only impact airport users but people
and freight using the network and local communities.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provides an
effective means of meeting the surface access targets
and pledges set out in the ANPS. Further assessment
and analysis is ongoing by Heathrow to determine
Concerns expressed about the negative impacts during
construction and operation, and due to the impacts of congestion,
the roads will be unable to cope with the increased number of cars.
✓
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Expansion would result in worsening congestion and delays on the
roads and increased crowding on the railways.
✓ exactly which combinations of measures are required,
by which date, to deliver the best surface access for
the expanded airport. Heathrow is working with
Highways England, Network Rail and TfL to co-
ordinate the expansion plans with their investment
plans in the Heathrow area.
At the Airport Expansion Consultation One (January
2018), the Our approach to developing a surface
access strategy document explained the measures
being considered to increase public transport use and
reduce the need to travel more generally. This
included consideration of an access charge /
emissions charge to access Heathrow and improved
taxi / PHV management. In addition, the Our
Emerging Plans document set out options that would
rationalise the existing 4 terminals, focused on
Terminal 5 and Terminal 2. This would focus activity
and trips along the existing public transport spine (with
the addition of new Elizabeth Line services) and
improved bus and coach facilities at the Terminals.
The draft Surface Access Strategy, supported by
technical information in the PTIR, will explain
Heathrow’s preferred options for the transport
infrastructure needed to support the expansion plans,
in the context of increasing the use of public transport
by passengers and colleagues. This includes plans for
a new parking strategy and freight/logistics strategy.
Heathrow will be working with DfT, Highways England,
Network Rail, the local transport authorities and other
transport operators in developing the Surface Access
The plans for keeping traffic flowing with the added pressure of
extra transport to and from Heathrow are not clear.
✓
The motorway network around Heathrow already suffers from
congestion and high pollution levels. Expansion should address
this by providing measures to combat congestion and pollution and
encourage sustainable means of travel.
✓
The DfT and the local transport authority develop a scheme to
minimise effects of the airport on surrounding communities and
which provides additional funds to the local highway network and
includes sustainable travel options for those working at the airport.
✓
A significant proportion of trips to the airport are by road which has
resulting road congestion impacts on local businesses.
✓
The area is already heavily congested, and improvements would
make the road network more efficient for users.
✓
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Strategy for the Project. The PTIR will be an Airport
Expansion Consultation (June 2019) document and
will summarise and illustrate the outputs from the
transport modelling. It will identify locations where the
project will potentially have material impacts on the
operation of the transport networks that require further
detailed assessment. It will also set out, at a high-
level, the strategy for mitigating any impacts on the
surrounding transport networks that are considered
severe. A Transport Assessment will be submitted
with the DCO application and report on the results of
the further detailed assessment work and, for
locations where the impacts of the project are
determined to be severe, will set out in more detail the
proposed mitigation strategy.
A Code of Construction Practice will also form part of
the DCO application for expansion. It will set out how
construction traffic will be managed to minimise
environmental effects. Heathrow will consult on the
provisions contained in the draft Code of Construction
Practice at the Airport Expansion Consultation in June
2019.
Through effective planning, Heathrow aims to
minimise the amount of construction related traffic on
the roads. It will encourage suppliers and their
workforce to use the existing public transport
infrastructure and aim to move as much material as
possible in and out of the construction site using the
existing rail route in the north west of the proposed
Expansion site. This approach for construction
materials is closely associated with Heathrow’s plans
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for using remote logistics hubs across the UK, which
should both reduce construction material traffic and
the numbers of construction workers engaged directly
on the site.
There should be a ban on construction traffic on the A4 over
Maidenhead Bridge as it is the only access from the west in the
case of a temporary closure of the M4.
✓ Heathrow will employ a number of measures to
mitigate the impact of construction related traffic on
the local and strategic road network. These will
include:
• Maximise use of rail freight to reduce road deliveries.
• Construct a network of construction and haul roads for the site-related traffic to minimise the need of using public roads and so mitigate the risk of traffic backing-up onto the strategic road network.
• Implement a delivery management system to distribute the arrival of materials to site throughout the day to avoid peak hours.
• Create lorry parking facilities to hold vehicles off the public highways as and when required.
• Open the new sections of road infrastructure before the existing is closed.
• Maximise opportunities for off-site manufacture to reduce the need for on-site workforce and to consolidate material deliveries.
• Maximise the use of public transport and buses to reduce car trips during construction.
The A4 at the grade I listed Maidenhead Bridge is
maintained by The Royal Borough of Windsor and
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Maidenhead Borough Council, as the local highways
authority. Therefore, it has the relevant powers to
place weight restrictions on bridges and structures on
its road network and more generally protect heritage
assets in its area. Heathrow will work with the local
highways authorities around the airport to mitigate the
impact of the construction and operation of the
expanded airport, including the management of HGV
traffic where technical assessments and traffic
modelling show this to be necessary.
Concerns expressed about the effect of increased traffic on the M4
corridor in to and out of London, Hogarth roundabout and the
surrounding roads.
✓ Having taken account of feedback, Heathrow revised
early proposals in order to avoid changes to the
M25/M4 interchange.
Heathrow does not believe that the M4 and A4 (Great
West Road), including the Hogarth Roundabout in
Chiswick, need to be widened or altered as a result of
the Project. There are three key elements to the
emerging surface access strategy: making public
transport the preferred choice for more passengers;
making more efficient use of road transport; and
continuing to reduce the number of colleagues driving
to work. By the time Heathrow is expanded, and for
the first time, the airport will be part of an integrated
transport network served by at least 3 railway lines
and 5 motorways to North, South, East and West. This
will ensure the continuation of the trend that has seen
passenger numbers at Heathrow double since 1991,
but airport-related road traffic remain largely static.
Heathrow plans to almost double passenger journeys
made by public transport from 18 million (in 2013), to
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35 million by 2030.
The DfT confirmed that “The Government is looking at
M4 capacity as part of normal roads investment
planning. London’s population is growing and
congestion on the M4 is not just an airport issue – if
improvements benefit airport users then the airport is
expected to pay a share of the cost in line with
existing policy on the funding of surface access
schemes.” Heathrow recognises the existing
challenges on the road network in the Heathrow area,
with high traffic levels and local air quality issues.
Heathrow will work with the DfT and Highways
England as part of the planning process in order to
determine the most appropriate solution.
It Is not clear how route changes to the M25, A4, A312, A30 and
A3044 will ensure that there will be no increase in airport related
traffic on them.
✓ The proposed new runway location will result in the
loss of the Western Perimeter Road and parts of the
Northern Perimeter Road, and result in severance of
the A4 (Bath Rd) and A3044 (Stanwell Moor Rd).
These changes will require close working with a
number of interested highway authorities: Slough
Borough Council (A4), TfL (A4, A30 and A312),
London Borough of Hillingdon (A3044), as well as
Highways England as an interested party operating
nearby and parallel roads. To maintain traffic
connectivity in the area and reduce potential effects
on road users, the existing A3044 and A4 will be
maintained until the new replacement roads are
complete. Heathrow will also aim to reduce the effect
of construction traffic using these existing roads by
creating an internal construction road system as soon
Concern expressed about the impacts on traffic and congestion on
local roads, the M25, the M4 and the M40.
✓
Concerns expressed that changes to road layouts and more public
transport and train links will cause more disruption to communities.
✓
The commitment to not increase airport related traffic will
redistribute traffic on some sections of the strategic road network
for which Heathrow will have to mitigate.
✓
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as practical. More information about how Heathrow
will manage traffic flows during the construction stage
will be provided at the Airport Expansion Consultation
in 2019. In particular, the Updated Scheme
Development Report and draft Code of Construction
Practice will explain how the impacts of the
construction stage will be mitigated.
Detailed designs and programmes of work for the M25
diversion and works to the M4 spur are still being
developed, so it is not possible to be specific about
the duration of any works at this stage. As much as
possible of the construction works will be undertaken
alongside or near to the existing carriageway as it
continues to operate, to minimise disruption to road
users.
A wider surface traffic study and road improvements would be
supported.
✓ Heathrow is committed to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips in the
ANPS. Heathrow will also continue to strive to meet its
pledge to have landside airport-related traffic no
greater than today.
The draft Surface Access Strategy, supported by
technical information in the PTIR, published at Airport
Expansion Consultation in June 2019 will explain
Heathrow’s preferred options for the transport
infrastructure needed to support the expansion plans,
in the context of increasing the use of public transport
by passengers and colleagues. This includes plans for
a new parking strategy and freight/logistics strategy.
The Surface Access Strategy would result in improvements to
public transport in general and in improved bus services, improved
public transport links, improved accessibility to and around the
airport and it would also ease traffic congestion.
✓
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The surface access strategy would not resolve existing traffic
congestion and there would be impacts on local people and local
communities from both traffic and unregulated parking in villages,
specifically by taxis.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provide an effective
means of meeting the surface access targets and
pledges. Further assessment and analysis is ongoing
by Heathrow to determine exactly which combinations
of measures are required, by which date, to deliver the
best surface access for the expanded airport.
Heathrow is working with Highways England, Network
Rail and TfL to co-ordinate the expansion plans with
their investment plans in the Heathrow area.
Heathrow will be part of an integrated transport
network with connections to the north, east, south and
west connecting all of the UK. This will ensure
Heathrow continues the trend that has seen
passenger numbers at the airport double since 1991,
but airport-related road traffic remain largely static.
Rail and public transport will not absorb this excess traffic, as it
would be dependent on existing overloaded road and rail networks
✓
Concerns expressed about bottlenecks during the rebuilding of the
M25 Wisley interchange and upgrading the Dennis interchange.
✓ Heathrow is working closely with Highways England to
develop the outline solution for the elements of their
network that are affected by the expansion of the
airport. This includes detailed consideration of the
construction methodology to be adopted, ensuring
minimum disruption to the users of the M25.
Heathrow’s aim is to have agreement with HE on the
main construction methodology before the Airport
Expansion Consultation (June 2019) takes place.
Heathrow is feeding into and working with Highways
Concerns expressed about an increase of freight and passengers
on the M25 and A3.
✓
Concerns expressed about the impact of future development on the
South West Quadrant and southern stretches of the M25.
✓
A national approach to traffic is required and opportunity for
councils to discuss transport to/from the airport across the M3
✓
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corridor would be welcomed. England on the M25 South West Quadrant Study.
There are currently a number of different proposals
that could connect the existing South Western railway
network to Heathrow via a new Southern Rail Link.
There is currently no railway connection between
Heathrow and the south so this link would fill a key
gap in the rail network. A feasibility study undertaken
by Network Rail showed that there is a strong
business case for the proposals and that there are
credible infrastructure solutions that should be
explored further. Heathrow’s analysis to date indicates
that the proposed surface access strategy is not
reliant on a Southern Rail Link to deliver the mode
share targets in the NPS. DfT is exploring the potential
for a Southern Rail Link to be brought forward with
private sector involvement and Heathrow is supportive
of this initiative.
Concerns expressed about the impact on transport routes such as
the M25 and the North Downs Line (Reading to Gatwick) if
appropriate mitigation is not put in place.
✓
There is no commitment to provide improved public transport to
meet the needs of an expanded airport, particularly to the south.
✓
There are a number of key areas on the highway network requiring
mitigation: Beaconsfield; Burnham; Iver including the Five Points
Roundabout and to address poor road traffic accident record, Iver
Heath (Willow Lane) and north-south connectivity via High
Wycombe and to Aylesbury.
✓ Heathrow’s proposals for the strategic and local road
networks will be focused on mitigating the impact of
the expansion project having regard to the ANPS
which states that the scheme should be, “cost-efficient
and sustainable, and seek to minimise costs to
airlines, passengers and freight owners over its
lifetime”. The scale and nature of the mitigation
proposed will be developed in that context and
informed by traffic modelling and analysis of the likely
significant impacts due to the construction and
operation of the expanded airport.
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Heathrow recognises the existing challenges on the
road network in the Heathrow area, with high traffic
levels and local air quality issues. There are three key
elements to the plans to enhance surface access to
the airport: making public transport the preferred
choice for more passengers; making more efficient
use of road transport; and continuing to reduce the
number of colleagues driving to work.
Transport links are important but expressed concern about new
transport infrastructure affecting the Longford River.
✓ The Project will extend the Airport's footprint into the
Colne Valley, in the path of existing alignments of
watercourses and areas of floodplain storage within
the valley. An extensive and detailed evaluation of
potential sites and environmental impacts is being
undertaken in order to identify the preferred location
and routes of the river diversions and flood storage
areas, taking into account the consultation responses.
For more information on our response on the effects
of the Project on rivers, please see Chapter 12.
The Environment Agency or another body be mandated to monitor
the full environmental impact of the airport, including any additional
congestion.
✓ Heathrow will be working with Natural England, the
Environment Agency and other stakeholders to deliver
appropriate solutions for the natural environment and
waterways.
Heathrow will seek to agree details about the
environmental monitoring regime with stakeholders,
including the Environment Agency. Monitoring
commitments will be secured in the draft DCO that will
be submitted with the application. The emerging
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proposals for monitoring will be set out in the Airport
Expansion Consultation (June 2019) documents,
including the Preliminary Environmental Information
Report (PEIR).
Campaign indicated expansion should not lead to an increase in
climate-changing emissions, or any increase in motor vehicle
volumes (and resulting pollution and emissions).
✓ The Our approach to air quality document published at
Airport Expansion Consultation One (January 2018)
explained the goals and targets identified in the
Heathrow 2.0 sustainability strategy. This stated
Heathrow’s goal to reduce emissions from airside
vehicles by working with partners and to meet a target
to reduce NOx emissions from airside vehicles by at
least 50% by 2020 and 70% by 2025 (from 2013
baseline).
The draft Surface Access Strategy will be an Airport
Expansion Consultation (June 2019) document which
will explain Heathrow’s preferred options for promoting
the use of cleaner vehicles accessing and servicing
the airport.
Concerns expressed about the indirect impacts of increased levels
of traffic and parking, new transport infrastructure and new railway
lines.
✓ An extensive and detailed evaluation of potential sites
has been undertaken in order to identify the preferred
location for transport infrastructure to serve the
expanded airport, taking into account the consultation
responses. Heathrow believes that the proposals
comprise the most sustainable balance between being
appropriately located, comprising an acceptable level
of land take, and minimising impacts upon the
environment and communities as far as possible.
Further information will be contained in the PEIR,
Trust welcomed all transport that minimises environmental impacts ✓
The proposals for surface access are unrealistic and unacceptable
due to the massive land grab which will lead to blight in
neighbouring communities.
✓
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The Surface Access Strategy is not accurate in terms of the number
of people affected or the effects on quality of life.
✓ which Heathrow will consult on as part of the Airport
Expansion Consultation in June 2019.
The surface access options have not been through a proper
assessment to consider the environmental, operational, economic
and financial implications.
✓
Concerns expressed about negative impacts on air pollution due to
more traffic, longer journey times and further congestion.
✓
The Habitats Regulations require a high degree of certainty that any
measures put in place to avoid or mitigate impacts are deliverable.
✓ The Secretary of State for Transport, as the
competent authority, will be required to undertake a
Habitats Regulations Assessment of the Project in the
context of European sites. In order to inform the
Secretary of State in making their decision, Heathrow
will provide the information required for an
assessment to take place. A HRA Screening Report
will be prepared by Heathrow and consulted on as
part of the information provided at the Airport
Expansion Consultation in June 2019.
Heathrow is committed to achieving an overall net
gain in biodiversity and this will include consideration
of opportunities to conserve and enhance the Ramsar
and Special Protection Area (SPA) designations of the
surrounding borough’s reservoirs.
The Surface Access Strategy is dependent on projects to manage
current demand that are funded and controlled by other bodies.
✓ The ANPS sets out targets for Heathrow to increase
the public transport mode share of passengers and
reduce the number of colleague car trips to the airport.
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Heathrow will work with TfL, Network Rail and other
transport providers/ operators to ensure these targets
are met and in order to understand the target
completion dates of any third party or external
schemes included in existing rail, road or other
transport investment plans. Paragraph 5.12 of the
ANPS states that, “Heathrow must demonstrate that
Highways England, Network Rail and any relevant
highway and transport authorities and transport
providers have been consulted, and are content with
the deliverability of any new transport schemes or
other changes required to existing links to allow
expansion within the timescales required for the
preferred scheme as a whole, the requirements of the
ANPS and other statutory requirements.”
Heathrow has a strong track record of investing in
surface access improvements. Heathrow is committed
to funding all of the required road diversions alongside
a fair and reasonable contribution to new rail
infrastructure. Some surface access infrastructure will
be secured in the DCO itself, while funding and
support for schemes that are being delivered by third
parties can be secured through planning obligations, if
necessary.
This is consistent with the Government’s Aviation
Policy Framework that states "The general position for
existing airports is that developers should pay the
costs of upgrading or enhancing road, rail or other
transport networks or services where there is a need
to cope with additional passengers travelling to and
from expanded or growing airports. Where the
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scheme has a wider range of beneficiaries, the
Government will consider, along with other relevant
stakeholders, the need for additional public funding on
a case-by-case basis."
The provision of varied, affordable and reliable surface access
options is supported but concerns expressed about the affordability
of the proposals.
✓ The expansion of Heathrow will be privately funded
and no public funds will be required.
The ANPS para. 5.20 states “Where a surface
transport scheme is not solely required to deliver
airport capacity and has a wider range of
beneficiaries, the Government, along with relevant
stakeholders, will consider the need for a public
funding contribution alongside an appropriate
contribution from the airport on a case by case basis”.
Heathrow has a track record of investing in surface
access improvements at the airport and will fund all of
the road diversions required by expansion alongside a
fair and reasonable contribution to new rail
infrastructure, in accordance with the CAA policy on
surface access.
Heathrow continues to engage regularly with airlines
and stakeholders to develop its draft Surface Access
Strategy and the preferred masterplan.
Airlines and passengers should not be responsible for subsidising
national programmes or funding betterment of other schemes and
further engagement should be had with the Airline Community in
the development of the Surface Access Strategy.
✓
Airlines and passengers should not be responsible for subsidising
national programmes or funding betterment of other schemes and
requested further engagement with the Airline Community in the
development of the Surface Access Strategy.
✓
All pre-negotiated mitigation works, including upgrading local road
and rail networks, should be forward-funded by Heathrow, or
through Heathrow securing national Government funding.
✓ The Project will be privately funded and no public
funds will be required to deliver the airport
infrastructure. Heathrow has a strong track record of
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Contributions towards the costs of major rail schemes will need to
be secured as without sufficient investment in the public transport
network negative impacts will result on the road network over a
wide area.
✓ investing in surface access improvements. Heathrow
is committed to funding all of the required road
diversions alongside a fair and reasonable
contribution to new rail infrastructure.
Some surface access infrastructure will be secured in
the DCO itself, while funding and support for schemes
that are being delivered by third parties can be
secured through planning obligations.
This is consistent with the Government’s Aviation
Policy Framework that states "The general position for
existing airports is that developers should pay the
costs of upgrading or enhancing road, rail or other
transport networks or services where there is a need
to cope with additional passengers travelling to and
from expanded or growing airports. Where the
scheme has a wider range of beneficiaries, the
Government will consider, along with other relevant
stakeholders, the need for additional public funding on
a case-by-case basis."
Heathrow should support and commit to help pay for Southern Rail
but there is an opportunity for a ‘Super Public Transport Levy Fund’
to support funding of major surface access schemes and
sustainable transport projects.
✓
There are no commitments to funding the necessary improvements
and the proposals would not work or make any difference.
✓
Concern at the lack of commitment from Heathrow to fund new
public transport infrastructure.
✓
A fund must be provided to support major surface access schemes
and sustainable transport projects in the wider area to the benefit of
local communities.
✓
LEPs have limited funds for transport investment and should not be
expected to cover the costs of improvements or mitigation
measures required as a result of expansion
✓
Concerns expressed that the Government will end up paying
Heathrow's surface access costs and the surface access initiatives
should be pursued regardless of a third runway so that rapid
improvements to air quality are delivered over and above those in
the draft London Plan
✓
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The ambition to make the Project sustainable by providing high
quality reliable public transport links is welcomed, however, there is
uncertainty as to who will provide and pay for the different schemes
and a lack of modelling to demonstrate modal shift will take place.
✓
Heathrow should be relieved of any obligation to fund enhanced rail
access infrastructure and should instead contribute to new rail links
through expenditure that can be taken in to account by the CAA.
✓ The Project will be privately funded and no public
funds will be required to deliver the airport
infrastructure.
Heathrow is committed to funding all of the required
road diversions alongside a fair and reasonable
contribution to new rail infrastructure in accordance
with the CAA policy on surface access.
The Project should not be used to delay investment in surface
access improvements to the airport that are already developed and
needed.
✓ The expansion plans are being developed around
existing commitments such as the Elizabeth Line and
Piccadilly Line upgrade. Heathrow’s plan is to focus
development on the existing public transport spine
that runs between the CTA and Terminal 5 / Terminal
4.
The productivity of the South East is falling behind other areas and
local authorities.
✓ A new runway will double Heathrow’s cargo capacity
and create up to 40 new long-haul trading routes to
fast growing economies. This will create new
opportunities for businesses in the South East and
beyond, both large and small, to trade with the rest of
the world.
The package of transport improvements, that will form
an important element of the expansion plans, will
create new and enhanced public transport links to
South East England. The expansion plans also
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provide an opportunity to improve traffic conditions on
the strategic road network around the airport such as
the M25 and A4. All of these improvements will
contribute to improving the productivity of London and
the South East.
There is a lack of tangible commitments by Heathrow to ensure no
increase in airport related traffic.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) and the emerging
Airport Expansion Consultation (June 2019) provide
an effective means of meeting the surface access
targets and pledges. Further assessment and analysis
is ongoing by Heathrow to determine exactly which
combinations of measures are required, by which
date, to deliver the best surface access for the
expanded airport. Heathrow is working with Highways
England, Network Rail and TfL to co-ordinate the
expansion plans with their investment plans in the
Heathrow area.
If Heathrow’s analysis has identified an alternative package of
schemes this should be published together with details of how
these schemes will be delivered.
✓
The modal shift targets should be reset to reflect that the airport is
taking its ‘fair share’ of congestion and will not increase road traffic
but any schemes aimed at reaching the targets must provide value
for money and be in the interests of passengers.
✓ Heathrow is committed to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips in the
ANPS. Heathrow will also continue to strive to meet
its pledge to have landside airport-related traffic no
greater than today.
At the Airport Expansion Consultation One (January
Heathrow meeting its modal shift and airport related traffic
commitments is very important in order to ensure that the existing
road network in Elmbridge is not put under further strain from traffic
✓
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generated by a third runway. 2018), the Our approach to developing a surface
access strategy document explained the measures
being considered to increase public transport use and
reduce the need to travel more generally. This
included consideration of an access charge /
emissions charge to access Heathrow and improved
taxi / PHV management. In addition, the Our
Emerging Plans document set out proposals that
would rationalise the existing four terminals, focused
on Terminal 5 and Terminal 2. This would focus
activity and trips along the existing public transport
spine (with the addition of new Elizabeth Line
services) and improved bus and coach facilities at the
Terminals. Fewer larger terminals will also reduce the
need to travel around the airport, between terminals.
The draft Surface Access Strategy to be published at
Airport Expansion Consultation in June 2019,
supported by technical information in the PTIR, will
explain Heathrow’s preferred options for the transport
infrastructure needed to support the expansion plans,
in the context of increasing the use of public transport
by passengers and colleagues. This will include plans
for a new parking strategy and freight/logistics
strategy.
Heathrow is working with Highways England, Network
Rail and TfL to co-ordinate the expansion plans with
their investment plans in the Heathrow area.
Meeting modal split and sustainable transport targets without major
infrastructure investment needs to be properly evidenced,
especially given recent evidence from the NPS consultation that
passenger demand will grow faster than first expected.
✓
Transportation considered the modal shift target will be difficult to
achieve and expressed concern that there is minimal explanation as
to how the increase in public transport usage would be achieved
and funded.
✓
The lack of a detailed integrated Surface Access Strategy for
passengers, freight and workforce was a serious failing and that
without major infrastructure investment Heathrow will be unable to
meet modal split and sustainable transport targets.
✓
Specific targets for maximising the proportion of journeys made to
the airport by public transport, cycling or walking should be set and
should apply to both the workforce and passengers.
✓
Incentivising and supporting modal share shift is insufficient and
requires input from and cooperation with others.
✓
The commitments to increase passenger numbers travelling by
public transport and not increase airport related traffic are not
credible.
✓
For the targets to be achieved, Heathrow will need to demonstrate
support for a step change in public transport provision to the
✓
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airport.
The focus should be on improving public transport or electric cars,
the proposal was motivated by increasing revenue for the airport
rather than reducing impacts or delivering road improvements, it
will not reduce the number of cars on the road or it will just move
congestion to other places and drive businesses away from the
airport affecting competitiveness.
✓
There is insufficient modelling or supporting evidence to
demonstrate that the aim of no increase in road traffic is anything
other than ambition.
✓
Concerns expressed that without additional sustainable surface
access the airport will not be able to contribute fully to the economy
or meet the demands of future air travel growth.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provides an
effective means of meeting the surface access targets
and pledges. Further assessment and analysis is
ongoing by Heathrow to determine exactly which
combinations of measures are required, by which
date, to deliver the best surface access for the
expanded airport. Heathrow is working with Highways
England, Network Rail and TfL to co-ordinate the
expansion plans with their investment plans in the
Heathrow area.
The pledge has ‘no net increase’ in airport related traffic and
corresponding investment in surface access capacity can enable
the required improvements in air quality.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
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Heathrow have not demonstrated how targets for mode share,
employee car journeys and freight movements relate to known Air
Quality and/or congestion policy
✓ Consultation One (January 2018) provides an
effective means of meeting the surface access targets
and pledges. Further assessment and analysis is
ongoing by Heathrow to determine exactly which
combinations of measures are required, by which
date, to deliver the best surface access for the
expanded airport. Heathrow is working with Highways
England, Network Rail and TfL to co-ordinate the
expansion plans with their investment plans in the
Heathrow area.
Given that non-airport-related road traffic is a
dominant source of emissions around Heathrow,
national and regional measures to improve air quality
will have an important role in addressing the wider
pollution issue across the UK that affects
concentrations in the area.
Since publication of the Airports Commission’s final
report, the Government has undertaken further work
on air quality to understand the implications of
updates to the tools published by Government to
calculate road vehicle emission rates. The
Government’s air quality re-analysis and the Appraisal
of Sustainability, published alongside the ANPS, are
clear in stating that the Project is capable of being
delivered in accordance with legal obligations for air
quality.
The ANPS recognises a range of potential mitigation
measures that Heathrow could put in place to help
meet legal air quality obligations and improve air
quality around the airport. Heathrow is already
Heathrow have not demonstrated how mode share and employee
car journey targets as well as targets to limit freight movements,
relate to known Air Quality and/or congestion policy.
✓
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delivering a number of these measures today. The
expansion of Heathrow provides the opportunity to
expand these initiatives and develop new ones, as
well as a chance to bring major change to the
surrounding road and public transport network. More
information about this will be set out at the Airport
Expansion Consultation in June 2019.
Heathrow should analyse the needs of specific groups of workers
and passengers before defining the requirements.
✓ Heathrow has been working with colleagues at the
airport to reduce the number of people driving single
occupied, private cars to work. Heathrow has invested
in a dedicated commuter team as well as local
transport to make it easier and more affordable for
people to use, including funding the Heathrow Free
Travel Zone.
The PTIR will be published as part of the Airport
Expansion Consultation in June 2019 and will
summarise and illustrate the outputs from the
transport modelling and identify locations where the
project will potentially have material impacts on the
operation of the transport networks that require further
detailed assessment. It will also set out, at a high-
level, the strategy for mitigating any impacts on the
surrounding transport networks that are considered
severe.
Further technical assessment work and consideration
of the feedback from the statutory consultation,
including comments about the PTIR and the draft
Surface Access Strategy, will inform the preparation of
a Transport Assessment. This will be submitted with
the DCO application and will report on the results of
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the further detailed assessment work and, for
locations where the impacts of the project are
determined to be severe, will set out in more detail the
proposed mitigation strategy.
Concerns expressed that there is not a coherent view on how the
airport sits within the wider transport network and a more coherent
and integrated strategy should be produced, with Heathrow taking
the lead.
✓ Heathrow will submit a Surface Access Strategy with
the DCO application for the Project, which will accord
with the ANPS. In so doing, the Strategy will set out
“improvements to Heathrow Airport’s transport links to
be able to support the increased numbers of people
and freight traffic which will need to access the
expanded airport.” (Paragraph 5.8).
The Airport Expansion Consultation One (January
2018) materials presented the options that were being
considered by Heathrow to improve public transport at
the airport. These were set out in the Our Emerging
Plans and Our approach to developing a surface
access strategy documents. For the forthcoming
Airport Expansion Consultation (June 2019) Heathrow
is setting out its preferred options for public transport
provision at the expanded airport based on feedback
from the Airport Expansion Consultation One (January
2018) and ongoing design and assessment work.
The draft Surface Access Strategy will be an Airport
Expansion Consultation (June 2019) document which
will explain Heathrow’s preferred options for the
provision of new and enhanced public transport to
serve the expanded airport.
The Surface Access Strategy is almost wholly dependent on pre-
existing rail schemes such as the Elizabeth and Piccadilly Line
upgrades which were planned based on a two-runway Heathrow.
✓
The priorities and initiatives in the Surface Access Strategy are
supported but it is not clear whether they were all achievable.
✓
The initiatives identified are vital to drive the development of the
Surface Access Strategy and achieve the identified priorities.
✓
The plans are inadequate, relying too much on travellers using
clean transport options.
✓
Surface access is crucial in the choice of a passenger’s departure
airport. There should be an increased focus on improved surface
access benefitting passengers and staff, as well as the local
population.
✓
Affordable and convenient transport choices for staff and
passengers are critical to achieving sustainable surface access.
✓
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An effective and efficient public transport system needs to be
augmented for both workers and travellers to and from the airport.
✓
The planned increases in public transport capacity are only
sufficient to cater for growth in two runway demand.
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) and the Airport
Expansion Consultation (June 2019) provide an
effective means of meeting the surface access targets
and pledges. Further assessment and analysis is
ongoing by Heathrow to determine exactly which
combinations of measures are required, by which
date, to deliver the best surface access for the
expanded airport. Heathrow is working with Highways
England, Network Rail and TfL to co-ordinate the
expansion plans with their investment plans in the
Heathrow area.
The release of runway capacity should be linked to surface access
tests based on predicted outcomes, the number of Heathrow related
vehicles should be no more than today, and the tests must be based
on targeted reduction in such traffic compared to a ‘Do-minimum’
over future years.
✓ Heathrow must demonstrate that the targets set in
ANPS to increase the passenger mode share and
reduce the number of colleague car trips can be met
at each of the milestone dates referred to (2030 and
2040).
Reflecting the requirements set out in the ANPS and
Heathrow’s commitments towards delivering a
sustainable expansion, the surface access strategy
will contain specific and measurable targets that can
be monitored over time. Heathrow is currently in the
process of fully defining its targets and monitoring
process. In order to provide independence, there will
be a mechanism whereby the Heathrow Area
Robust and enforceable processes are needed to correct or mitigate
any divergence from the expected reduction in airport related traffic.
✓
Ongoing investment in road and rail transport infrastructure is
essential for an expanded Heathrow and there should be a
commitment to enhanced connectivity and congestion reduction
aligned with the new runway development.
✓
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A detailed Surface Access Strategy is requested, including detailed
modelling, evidence to support Heathrow’s ambitions and an
assessment of the cost and risk to the entire scheme if the targets
are not met.
✓ Transport Forum can oversee implementation of the
strategy and monitor progress. Heathrow will also
monitor the proposed timeframes for delivery of the
targets to ensure that the right measures are in place
sufficiently early as passenger numbers grow. More
details will be set out in the Airport Expansion
Consultation in June 2019.
The delivery of Heathrow’s strategy will require it to
work with other agencies such as Transport for
London, Highways England, Network Rail and Local
Authorities. Heathrow has a strong history in working
with partners to deliver surface access improvements
that benefit both Heathrow and the surrounding area.
This offers a unique opportunity to plan the UK’s
infrastructure needs in an integrated way and will help
ensure the surface access plans for Heathrow are
embedded in key strategic long-term planning
processes and investment opportunities. For example:
• Highways England is currently delivering a programme of activity that was set out in its first Road Investment Strategy. There are a number of projects in the Heathrow area including M25 J10 improvements, M25 J10-16 and the M4 Smart Motorway between J3 and J12. Plans are currently being developed for the RIS2 (2021-2026) which will include outputs from the M25 Southwest quadrant study and other strategic studies.
• Network Rail is also preparing its plan for the next investment period (2019-24) known as Control Period 6 (CP6).
A simple expansion of facilities will not achieve the required
increase in public transport mode share, zero growth of airport-
related vehicle traffic, local air quality limits and a reduction in the
risk of unrestricted vehicle access.
✓
The Surface Access Strategy should contain specific targets to
maximise journeys to the airport by public transport, cycling or
walking.
✓
Approval should only be granted for expansion if the target for no
more airport related traffic can be met, or if increases in capacity
are linked to the achievement of the targets and made a condition of
approval.
✓
The growth of the airport should be conditional upon substantial
investment and the provision of major rail investment.
✓
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• The Mayor and Transport for London have set out their priorities for transport in London over the period to 2041.
There is an opportunity to develop a co-ordinated plan
for Heathrow surface access that brings together the
emerging plans for Heathrow with the programmes
developed by Highways England, Network Rail,
Transport for London, Local Authorities and others.
The range of schemes and initiatives presented at the
Airport Expansion Consultation One (January 2018)
include some which are in the process of being
delivered already, and others where delivery will be
secured through the DCO for expansion. A more
detailed programme for delivery of surface access
improvements will be developed taking account of
comments from the public consultation exercises in
the Airport Expansion Consultation in June 2019.
There is a risk demand and required capacity has been significantly
underestimated
✓ On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) and the Airport
Expansion Consultation (June 2019) provide an
effective means of meeting the surface access targets
and pledges. Further assessment and analysis is
ongoing by Heathrow to determine exactly which
combinations of measures are required, by which
date, to deliver the best surface access for the
expanded airport. Heathrow is working with Highways
England, Network Rail and TfL to co-ordinate the
expansion plans with their investment plans in the
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Heathrow area.
Heathrow should start developing the Surface Access Strategy now
and not in the future.
✓ At the Airport Expansion Consultation One (January
2018), Heathrow began the process of preparing a
Surface Access Strategy and presented initial
proposals and strategies in order to get early feedback
from consultees. These were set out in the Our
approach to developing a surface access strategy
consultation document. A draft Surface Access
Strategy will be presented at the Airport Expansion
Consultation in June 2019.
A Surface Access Strategy is not required if there is no third
runway.
✓ The ANPS recognises that there is an urgent need for
new airport capacity in the South East (paras. 2.10-
18), that the Heathrow Northwest Runway scheme is
best placed to deliver this capacity and that overall it
would deliver the greatest net benefits to the UK
(para. 3.74).
Heathrow should ensure there is no increase in road traffic even as
a two-runway operation.
✓ Committed schemes that will come forward regardless
of the expansion plans include the Elizabeth Line,
which will begin operating to the airport in 2019, and
the Piccadilly Line upgrade that is planned for 2023.
The Western Rail Link to Heathrow is being promoted
by Network Rail to provide a direct rail connection
from the Great Western Mainline to the west of the
airport.
Together these committed projects will contribute
towards continuing the trend that has seen passenger
numbers at the airport double since 1991, but airport-
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related road traffic remain largely static.
The priorities of the Surface Access Strategy and the key initiatives
which seek to shift passengers and workers from private car to
public transport are supported.
✓ Heathrow is committed to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips in the
ANPS. Heathrow has also pledged that there will be
no more landside airport-related traffic as a result of
expansion.
At the Airport Expansion Consultation One (January
2018), the Our approach to developing a surface
access strategy document explained the measures
being considered to increase public transport use and
reduce travel demand more generally through smarter
airport design; for example, by consolidating some
activities around the airport such as parking and
freight operations.
The Airport Expansion Consultation in June 2019 will
seek views on the draft Surface Access Strategy. This
will be supported by technical information in the PTIR.
Together these will explain Heathrow’s preferred
options for the transport infrastructure needed to
support the expansion plans in the context of
increasing the use of public transport by passengers
and colleagues.
The Surface Access Strategy is a key part of the plans and the
proposals seem well thought through.
✓
The strategy would reduce the number of cars travelling to/from the
airport, improving local cycle paths and accessibility whilst also
addressing long term requirements.
✓
The provision of a public transport led scheme for an expanded
airport is supported.
✓
The proposals for surface access look sensible and are important
for fast and affordable access to London. The Surface Access
Strategy proposals will help deliver a reduction in emissions and
limit fuel use if applied correctly.
✓
The development of public transport initiatives for both passengers
and staff is supported.
✓
The aims of the Surface Access Strategy are supported, as long as
it considers their Surface Access Priorities.
✓
The proposals to increase surface access to the airport by
alternatives to car transport are welcomed.
✓
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The priority should be improving the public transport infrastructure. ✓
Concern expressed that there is no integrated strategy for those
travelling to and from the airport or any coherent view on how
Heathrow sits within the wider, national and regional transport
network.
✓ The Airport Expansion Consultation One (January
2018) materials presented the options that were being
considered by Heathrow to improve public transport at
the airport. These were set out in the Our Emerging
Plans and Our approach to developing a surface
access strategy documents. For the Airport Expansion
Consultation in June 2019, Heathrow is setting out its
preferred options for public transport provision at the
expanded airport in a draft Surface Access Strategy.
This will take account of feedback from the Airport
Expansion Consultation One (January 2018), this
consultation, and ongoing design and assessment
work.
This iterative approach to consultation on NSIPs is
advocated in government guidance on the pre-
application process (DCLG March 2015). Paragraph
70 of the guidance states that, “…applicants might
wish to consider undertaking non-statutory early
consultation at a stage where options are still being
considered. This will be helpful in informing proposals
and assisting the applicant in establishing a preferred
option on which to undertake statutory consultation.”
The draft Surface Access Strategy will be published
as part of the Airport Expansion Consultation (June
2019) and will explain Heathrow’s preferred options
for the provision of new and enhanced public transport
The Surface Access Strategy was poor. ✓
Concerns expressed that the Surface Access Strategy is
insufficiently developed and un-costed, with aspirational and
challenging objectives.
✓
The Surface Access Strategy is insufficient, inadequate and would
not be achievable due to inconsistencies between the ambition of
becoming traffic neutral and the proposals to expand.
✓
The consultation documentation does not provide any confidence
that expansion can be achieved with no increase in airport related
traffic or progress to improve air quality in the surrounding area can
be assured.
✓
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to serve the expanded airport
On the basis of the analysis carried out to date,
Heathrow is confident that the broad range of surface
access measures suggested at the Airport Expansion
Consultation One (January 2018) provides an
effective means of meeting the surface access targets
and pledges referred to in the ANPS. Further
assessment and analysis is ongoing by Heathrow to
determine exactly which combinations of measures
are required, by which date, to deliver the best surface
access for the expanded airport. Heathrow is working
with Highways England, Network Rail and TfL to co-
ordinate the expansion plans with their investment
plans in the Heathrow area.
Proposals to limit vehicles accessing the airport should be rejected. ✓ The ANPS sets out targets for Heathrow to increase
the proportion of passengers travelling to the airport
by public transport and reduce the number of car trips
made by colleagues. Heathrow must prepare a DCO
application, including a Surface Access Strategy, that
demonstrates that these targets can be met in order
for the expansion plans to be consented. More
generally, Heathrow is committed to developing the
airport in a sustainable way as explained in the
Heathrow 2.0 document, Our plan for sustainable
growth published in 2017.
The modal shift targets should be reset to show that the airport is
taking its ‘fair share’ of congestion and will not increase road traffic
but any schemes aimed at reaching the targets must provide value
for money, being in the interests of passengers.
✓ Heathrow will submit a Surface Access Strategy with
the DCO application for the Project, which will accord
with the ANPS. In so doing, the Strategy will set out
“improvements to Heathrow Airport’s transport links to
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be able to support the increased numbers of people
and freight traffic which will need to access the
expanded airport.” (Paragraph 5.8).
The ANPS at paragraph 5.7 identifies major rail
improvements that would support a new north west
runway. In considering the surface access
infrastructure needed to support the expansion plans,
Heathrow must have regard to paragraph 4.39 of the
ANPS. This requires Heathrow to demonstrate that its
scheme is cost-efficient and sustainable, and seeks to
minimise costs to airlines, passengers and freight
owners over its lifetime. Heathrow remains committed
to keeping airport charges close to 2016 levels.
The mode shift targets ambitious and recommended that Heathrow
investigate the possibility of an extensive network of park and ride
systems to free up road capacity.
✓ With expansion, a lot of the car parking along the
north side of Heathrow will be demolished. This is
likely to be replaced elsewhere at the airport. To
ensure Heathrow efficiently use all land available
today and minimise the need to acquire land, it is
likely that car parking will re-provided by creating
multi-storey car parks.
Managing car parking is part of how Heathrow will
meet the surface access targets in the ANPS and how
Heathrow will manage air quality around the airport. In
addition to the re-provision of demolished car parking,
Heathrow’s thinking at the Airport Expansion
Consultation One (January 2018) was to vacate some
of the existing surface level passenger and colleague
car parks and use a smaller number of multi-level car
parking sites which are located near main access
routes and have dedicated access to the front door of
The key to Heathrow’s transport strategy is the delivery of new
strategic rail services, including the Western and Southern Rail
Links complemented with a network of high quality and reliable park
and ride facilities for passengers arriving by car. This will help
ensure that local roads around the airport are not overloaded with
passenger traffic and will allow essential goods, services and cargo
to move efficiently and sustainably to and from the airport.
✓
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terminals. This will reduce traffic circulating around the
airport and improve way-finding. The consolidation of
passenger and colleague car parking also provides
the flexibility to change colleague and passenger car
parking allocations over time, in line with phasing and
meeting time-dependent ANPS targets, as well
dealing with future vehicle types and technologies.
Surface access should be continually improved without delay. ✓ Heathrow is committed to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips in the
ANPS. Heathrow will also continue to strive to meet its
pledge to have landside airport-related traffic no
greater than today
At the Airport Expansion Consultation One (January
2018), the Our approach to developing a surface
access strategy document explained the measures
being considered to increase public transport use and
reduce the need to travel more generally. This
included consideration of an access charge /
emissions charge to access Heathrow and improved
taxi / PHV management. In addition, the Our
Emerging Plans document set out proposals that
would rationalise the existing four terminals, focused
on Terminal 5 and Terminal 2. This would focus
activity and trips along the existing public transport
spine (with the addition of new Elizabeth Line
services) and improved bus and coach facilities at the
Terminals.
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A draft Surface Access Strategy, supported by
technical information in a PTIR, will explain
Heathrow’s preferred options for the transport
infrastructure needed to support the expansion plans,
in the context of increasing the use of public transport
by passengers and colleagues. This includes plans for
a new parking strategy and freight/logistics strategy.
This will be consulted on at the Airport Expansion
Consultation in June 2019.
A strategy is not required at all. ✓ The ANPS sets out targets for Heathrow to increase
the proportion of passengers travelling to the airport
by public transport and reduce the number of car trips
made by colleagues. The ANPS requires Heathrow to
submit a Surface Access Strategy with the DCO
application that demonstrates that these targets can
be met in order for the expansion plans to be
consented. More generally, Heathrow is committed to
developing the airport in a sustainable way as
explained in the Heathrow 2.0 document, Our plan for
sustainable growth published in 2017.
There is no indication as to how the commitment to not increase
airport related traffic would be managed, monitored or enforced.
✓ Heathrow must demonstrate that the targets set in
ANPS to increase the passenger mode share and
reduce the number of colleague car trips can be met
at each of the milestone dates referred to (2030 and
2040).
Reflecting the requirements set out in the ANPS and
Heathrow’s commitments towards delivering a
sustainable expansion, the Surface Access Strategy
submitted with the DCO application will contain
The Surface Access Strategy should be flexible to accommodate
changing circumstances without losing sight of strategic principles.
✓
A consistent measurement should be used for colleague car trip
and passenger transport targets to ensure clarity relating to
changes and targets for surface access transport.
✓
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The ambition to expand airport capacity without any increase in
airport related traffic is welcomed but Heathrow must demonstrate
that this can and will be achieved with robust monitoring and
nitrogen-sensitive designated sites will be avoided.
✓ specific and measurable targets that can be monitored
over time.
Heathrow is currently in the process of fully defining its
targets and monitoring process. In order to provide
independence, there will be a mechanism whereby the
Heathrow Area Transport Forum can oversee
implementation of the strategy and monitor progress.
Heathrow will also monitor the proposed timeframes
for delivery of the targets to ensure that the right
measures are in place sufficiently early as passenger
numbers grow.
The draft Surface Access Strategy and other
consultation documents that will be consulted on at
the Airport Expansion Consultation in June 2019, such
as the PEIR, will contain more detail about how the
ANPS targets and Heathrow’s commitments will be
monitored, enforced and managed over time, so they
remain effective.
The ‘no more traffic’ commitment is welcomed. ✓ Heathrow will continue to strive to meet its pledge to
have landside airport-related traffic no greater than
today. Heathrow is currently defining what vehicles
are considered to be ‘airport-related traffic’ and details
of this will be presented in the draft Surface Access
Strategy at the Airport Expansion Consultation in June
2019.
The targets for public transport use and no increase in airport
related traffic are supported but there is a need for greater clarity on
what airport related traffic is, as the current proposed definition
appears to be too narrow.
✓
Trips by private car to/from car parks beyond the perimeter of the
airport should be included in the definition of ‘airport related traffic’.
✓
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There is a need for robust multi modal traffic modelling, including
future proofing requirements, before any final decisions are made
on terminal locations, car parking or road and junction locations
and capacities.
✓ The draft Surface Access Strategy and the PTIR will
be published as part of the Airport Expansion
Consultation (June 2019) and together they will
explain what measures will need to be taken to deal
with the anticipated transport impacts of the
development. They will summarise and illustrate the
outputs from the transport modelling and identify
locations where the project will potentially have
material impacts on the operation of the transport
networks that require further detailed assessment.
They will also set out, at a high-level, the strategy for
mitigating any impacts on the surrounding transport
networks that are considered severe.
Further technical assessment work, including traffic
modelling, and consideration of the feedback from this
and future consultations will inform the preparation of
the masterplan and Transport Assessment.
Concern expressed over the target to reduce staff car journeys to
Heathrow by 25% by 2030. Meeting such targets will be key to no
adverse impacts on traffic congestion and air quality from
additional vehicle journeys.
✓ Many Heathrow colleagues live in boroughs close to
the airport such as Hillingdon, Hounslow, Ealing,
Slough and Spelthorne. These are also the areas with
the highest proportion of people travelling to work by
public transport. Where there are good alternatives,
people are using public transport or other sustainable
modes such as car sharing to get to work. Heathrow
wants fewer colleagues to drive to work by making
more sustainable modes more attractive and will be
putting in place measure to ensure the ANPS target to
reduce colleague car trips is met. In particular,
reducing the number of staff car parking spaces in a
managed way that ensures the operational needs of
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the airport continue to be met.
Heathrow has been working with colleagues at the
airport to reduce the number of people driving single
occupied, private cars to work. Heathrow has invested
in a dedicated commuter team as well as local
transport to make it easier and more affordable for
people to use.
Heathrow’s plans to reduce colleague car trips will be
set out in the draft Surface Access Strategy, produced
for the Airport Expansion Consultation in June 2019.
The National Infrastructure Commission and the Department for
Transport should develop a framework for delivering the Surface
Access Strategy which considers the complex interfaces between
infrastructure schemes, runway construction, surface access
works, phasing of growth and funding.
✓ The ANPS, informed by the Final Report of the
Airports Commission, sets out the national policy for
the expansion of Heathrow, including policy on the
development of a Surface Access Strategy and the
involvement of other infrastructure providers such as
Network Rail, Highways England, TfL and local
highways authorities.
Priorities of the Surface Access Strategy should be focussed on
those areas where public transport is not currently used to travel
to/from the airport.
✓ New and enhanced public transport infrastructure and
services are at the heart of the expansion plans. The
introduction of Elizabeth Line services in 2019 will
improve access to the airport from the City, East
London and the Thames Gateway. Heathrow is
supporting Network Rail’s proposed DCO for a
Western Rail Link that will provide direct access by rail
to the Airport for communities to the west on the Great
Western Mainline. Heathrow is also supporting the
plans for a Southern Rail Link from the South Western
Mainline rail network between Hampshire and
Waterloo. DfT is exploring the potential for a Southern
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Rail Link to be brought forward with private sector
involvement. Heathrow is working with TfL and local
authorities to identify new and improved bus priority
measures that could be considered to improve the
reliability and experience of bus users to/from
Heathrow.
The proposals for a Southern Rail Link and the introduction of
direct access to Heathrow by the Elizabeth line in 2018 are
welcomed.
✓ Support for the Southern Rail Link and the introduction
of direct services to Heathrow on the Elizabeth Line is
noted.
Kent and much of South East London still lack a direct, high-
capacity connection to the airport and the Crossrail to Ebbsfleet
scheme is a vital part of reducing car journeys and in helping
Heathrow to tackle air quality impacts.
✓ The Elizabeth Line will begin operating high capacity
frequent trains to Heathrow in 2019, providing direct
services to Stratford and connecting services using
the HS1 line, including commuter services to Kent.
The Department for Transport and Network Rail are
responsible for making investment decisions on the
national rail network. The ANPS at paragraph 5.7
identifies major rail improvements that would support
a new north west runway. In considering the surface
access infrastructure needed to support the expansion
plans, Heathrow must have regard to paragraph 4.39
of the ANPS. This requires Heathrow to demonstrate
that its scheme is cost-efficient and sustainable, and
seeks to minimise costs to airlines, passengers and
freight owners over its lifetime.
Strategic access could be provided to the airport by linking it to a
single interchange at Old Oak Common and the High Wycombe to
✓ Although Heathrow will not be directly served by HS2,
there will be an opportunity for passengers to
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Old Oak Common link is recognised as one of the key building
blocks to enable passengers and staff to sustainably access an
expanded airport.
interchange at the new station at Old Oak Common
via the Elizabeth Line, which will give significantly
reduced rail journey times between Heathrow,
Midlands and the major towns and cities of the North
of England and Scotland. Heathrow is working with
HS2 Ltd, Old Oak and Park Royal Development
Corporation, TfL and Network Rail to ensure the
design of the station at Old Oak Common meets the
needs of airport passengers.
The new rail schemes are not realistically costed and Heathrow is
neither willing nor able to fund them.
✓ The ANPS at paragraph 5.7 identifies major rail
improvements that would support a new north west
runway. In considering the surface access
infrastructure needed to support the expansion plans,
Heathrow must have regard to paragraph 4.39 of the
ANPS. This requires Heathrow to demonstrate that its
scheme is cost-efficient and sustainable, and seeks to
minimise costs to airlines, passengers and freight
owners over its lifetime. Heathrow is supporting
Network Rail’s DCO application for a Western Rail
Link to Heathrow and is also supporting emerging
plans for a Southern Rail Link, currently being
explored by the DfT to be brought forward with private
sector involvement. Elizabeth Line services will begin
operations to Heathrow in 2019. Heathrow remains
committed to keeping airport charges close to 2016
levels.
Support given for a rapid rail T5 – Staines park and ride. ✓ Park and Ride facilities have been considered in
developing the Surface Access Strategy, alongside
other ways of providing an appropriate amount of car
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parking linked to the airport.
However, Park and Ride is not currently the preferred
option within the emerging parking strategy. Heathrow
considers that the current preferred approach of using
parkways, with options to use people movers to link
directly to airport terminals, provides a better
passenger experience at a lower overall cost and
would not undermine efforts to encourage passengers
and colleagues to use existing and planned public
transport services.
The Piccadilly Line improvements will reduce car use and the
proposals to use a freight line from Hendon and Cricklewood for
passenger trains would be an improvement.
✓ The Airport Expansion Consultation One (January
2018) document, Our approach to developing a
surface access strategy explained that TfL plans to
upgrade the Piccadilly line, with work commencing in
2023. The existing trains will be replaced with new
trains with more capacity and a modern fit-out. The
signaling system will be upgraded to allow a higher
frequency of trains and faster journey times. The
upgraded Piccadilly line will provide 50% more
capacity with up to 18 trains per hour in each direction
serving Heathrow.
A link from the east would relieve much of this overcrowding. ✓ The Elizabeth Line will begin operations to Heathrow
in 2019 and will provide a fast and frequent service
between Heathrow and destinations to the east such
as Shenfield, Canary Wharf and Liverpool Street
Station.
Support expressed for increased frequency and operating hours on
the Elizabeth line, contribution to the costs for a new Western Rail
✓ The ANPS at paragraph 5.7 identifies major rail
improvements that would support a new north west
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Link and a new direct rail link to Heathrow from the south but
concerns expressed that there is no clarity on the cost and who will
pay for new heavy rail infrastructure. Without this the achievement
of no increase in airport related traffic or the modal shifts will not be
possible.
runway. In considering the surface access
infrastructure needed to support the expansion plans,
Heathrow must have regard to paragraph 4.39 of the
ANPS. This requires Heathrow to demonstrate that its
scheme is cost-efficient and sustainable, and seeks to
minimise costs to airlines, passengers and freight
owners over its lifetime. Heathrow is supporting
Network Rail’s DCO application for a Western Rail
Link to Heathrow and is also supporting the emerging
plans for a Southern Rail Link. DfT is exploring the
potential for a Southern Rail Link to be brought
forward with private sector involvement. Elizabeth Line
services will begin operations to Heathrow in 2019.
Heathrow is clear that Government is responsible for
funding rail and road networks, regardless of
expansion.
It is important that any contribution provided by the
taxpayer is proportionate to the benefits that non-
airport users receive as a result of the new
infrastructure. Heathrow will pay for the proportion of
costs driven by expansion. For example, new rail
connections for the Great Western Mainline benefit
many travellers, and will reduce travel times,
congestion and pollution. This is a good business
case for public investment, regardless of expansion
for the airport. Nevertheless, an expanded Heathrow
is, as the Airports Commission’s analysis concluded,
“commercially viable and financeable” and with £187
billion in additional growth for the British economy, it
represents good value for money.
The Surface Access Strategy was unrealistic and highlighted
uncertainty around the funding contributions and delivery of the
Piccadilly Line upgrades and the Western and Southern Rail Links.
✓
Without a financial contribution to the costs of increasing the
frequency of trains on the Elizabeth Line or to the development of
the Southern Rail Link, it is difficult to see how the Surface Access
Strategy would be fulfilled.
✓
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Even with upgrades, airport expansion will result in overcrowding
on the Piccadilly Line.
✓ The Airport Expansion Consultation One (January
2018) document, Our approach to developing a
surface access strategy explained that TfL plans to
upgrade the Piccadilly line, with work commencing in
2023. The existing trains will be replaced with new
trains with more capacity and a modern fit-out. The
signalling system will be upgraded to allow a higher
frequency of trains and faster journey times. The
upgraded Piccadilly line will provide 50% more
capacity with up to 18 trains per hour in each direction
serving Heathrow. The current and forecast patronage
of the Piccadilly Line will be assessed as part of the
emerging Surface Access Strategy, a draft of which
will be consulted on at the Airport Expansion
Consultation in June 2019.
Heathrow will work with TfL, Network Rail and other
transport operators to ensure that the fare structures
for travelling to Heathrow on the various services are
consistent with the need to meet the surface access
targets in the ANPS.
That a premium fare on the Elizabeth Line will push more
passengers onto the Piccadilly Line.
✓
The Piccadilly Line is already overcrowded and an expanded airport
will put greater pressure on the public transport system
✓
Although the draft NPS says an interchange at Old Oak Common
will enable airport passengers to make a connecting journey to
access HS2, air passengers would be heavily dissuaded from using
rail if an interchange is required.
✓ HS2 is the subject of a separate consultation and
consenting process as a hybrid bill. The Airports
Commission assessed the case for a direct HS2 spur
to Heathrow and concluded that, “the scheme was
likely to attract only a small number of passengers,
carry a high capital cost and represent an inefficient
use of HS2 capacity.” (Airports Commission Final
Report page 159). A direct connection to HS2 at
Heathrow was therefore not recommended to form
part of the surface access package that would support
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airport expansion. The HS2 Heathrow spur was
consequently not included in the ANPS. Although
Heathrow is not directly served by HS2, there will be
an opportunity for passengers to interchange at the
new station at Old Oak Common via the Elizabeth
Line, which will give significantly reduced rail journey
times between Heathrow, Birmingham and the major
cities of the North of England and Scotland. Heathrow
is working with HS2 Ltd, Old Oak and Park Royal
Development Corporation, TfL and Network Rail to
ensure the design of the station at Old Oak Common
meets the needs of airport passengers.
Current rail and road access to the airport is outdated and must be
enhanced to enable airlines to cater for passenger demand when
the third runway is operational.
✓ The ANPS states at paragraph 3.36 that “Heathrow
Airport already has good surface transport links to the
rest of the UK. It enjoys road links via the M25, M4,
M40 and M3, and rail links via the London
Underground Piccadilly Line, Heathrow Connect, and
Heathrow Express. In the future, it will connect to
Crossrail, and link to HS2 at Old Oak Common. Plans
are being developed for improved rail access: the
proposed Western Rail Access could link the airport to
the Great Western Main Line, and Southern Rail
Access could join routes to the South Western
Railway network and London Waterloo Station. This
varied choice of road and rail connections makes
Heathrow Airport accessible to both passengers and
freight operators in much of the UK and provides
significant resilience to any disruption.”
The benefits identified by the Airports Commission and the draft
ANPS for the national economy are at risk if expansion is not
✓ Heathrow will submit a Surface Access Strategy with
the DCO application for the Project, which will accord
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accompanied by a clear strategic plan accompanied by new rail
connections and services.
with the Airports National Policy Statement. The
Strategy will set out “improvements to Heathrow
Airport’s transport links to be able to support the
increased numbers of people and freight traffic which
will need to access the expanded airport.” (Paragraph
5.8). At the Airport Expansion Consultation One
(January 2018), Heathrow consulted on the early
options and strategies that will form the basis of the
Surface Access Strategy in the, Our approach to
developing a surface access strategy document. A
draft Surface Access Strategy will set out Heathrow’s
preferred options for surface access and will be
consulted on during the Airport Expansion
Consultation in June 2019.
Heathrow is already well served by the rail network and
improvements were unnecessary.
✓ Heathrow is committed to ensuring that the needs of
an expanded airport can be met. A Surface Access
Strategy will be submitted with the DCO application,
which will demonstrate how the targets to increase the
proportion of passengers travelling by public transport
and reduce colleague car trips will be met. The
Strategy will include measures for new and enhanced
rail services to Heathrow.
The proposed Surface Access Strategy would not improve the rail
network.
✓ The ANPS at paragraph 5.7 identifies major rail
improvements that would support a new north west
runway. In considering the surface access
infrastructure needed to support the expansion plans,
Heathrow must have regard to paragraph 4.39 of the
ANPS. This requires Heathrow to demonstrate that its
scheme is cost-efficient and sustainable, and seeks to
minimise costs to airlines, passengers and freight
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owners over its lifetime. Heathrow is supporting
Network Rail’s DCO application for a Western Rail
Link to Heathrow and is also supporting the emerging
plans for a Southern Rail Link. The DfT is exploring
the potential for a Southern Rail Link to be brought
forward with private sector involvement. Elizabeth Line
services will begin operations to Heathrow in 2019.
These schemes individually and collectively have the
potential to significantly improve rail services to the
airport in terms of the quality and frequency of
services, and accessibility for areas not currently
served by direct rail links to Heathrow.
The Western and Southern Rail Links were not identified as
essential schemes.
✓ The ANPS at paragraph 5.7 identifies major rail
improvements that would support a new north west
runway. In considering the surface access
infrastructure needed to support the expansion plans,
Heathrow must have regard to paragraph 4.39 of the
ANPS. This requires Heathrow to demonstrate that its
scheme is cost-efficient and sustainable, and seeks to
minimise costs to airlines, passengers and freight
owners over its lifetime. Heathrow is supporting
Network Rail’s DCO application for a Western Rail
Link to Heathrow and is also supporting emerging
plans for a Southern Rail Link, which is being explored
by the DfT with private sector involvement.
The case for these schemes has been more than clearly made for a
two-runway airport
✓
Western and Southern Rail Links were identified by the Airports
Commission as being justified on the basis of a two-runway airport.
✓
Both the Western and Southern Rail Links are essential for airport
expansion.
✓
The Western Rail Access and Southern Rail Link is of significant
national interest, serving a range of economic needs supporting
expansion.
✓
Surface rail must provide an increase in journeys of 200-300%, and
schemes such as the Western and Southern Rail Links are critical to
✓
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achieving this.
The Western and Southern Rail Links are needed now, prior to
expansion.
✓
The Western Rail Link and the Southern Rail Link must be
considered if Heathrow's expansion is to be successful.
✓
Recent commitments by the Government for the Western and
Southern Rail Links were a positive indication that a suitable
Surface Access Strategy can be developed.
✓
The Western Rail Link and the Southern Rail Link must be
considered if Heathrow's expansion is to be successful.
✓
The commitment to the Western and Southern Rail Links is
welcomed, however, it should be Heathrow should lead these
projects.
✓
Heathrow’s financial support for the new Western Rail Link is
welcomed but this should be provided as matter of urgency in
support of current airport operations.
✓ Network Rail is promoting a new rail connection
between Heathrow Terminal 5 and the Great Western
Main Line close to Langley station. A new 7km section
of railway would be constructed in a tunnel and would
allow direct rail services from Heathrow to places such
as Reading (in 26 minutes) and Slough (in 7 minutes).
This new Western Rail Link would provide direct rail
links to key passenger and colleague catchments in
the Thames Valley, taking traffic off the M4.
The proposed rail link is currently being developed by
Network Rail and a statutory public consultation was
The priority for infrastructure investment is the Western Rail Link
scheme and that it is required for a two-runway airport.
✓
There should be firmer commitments from Heathrow on plans to
contribute to the cost of the Western Rail Link.
✓
The Western Rail Link is required now to support the two-runway ✓
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capacity. held in 2018, in advance of a DCO application being
submitted. This would be separate from Heathrow’s
DCO application for the expansion of the airport. If
granted consent, the new rail link could become
operational by 2025. The funding and development of
the rail link is currently linked to the DCO application
stage for that project– with additional funding required
for construction as part of Network Rail’s Control
Period 6 (2019-2024) to deliver the project. Heathrow
is working with Network Rail in support of the Project.
There is a clear business case for the Western Rail Link based on a
two or three runway airport.
✓
Heathrow needs to work with its Western Rail Link project team to
provide assurance on compatibility of design.
✓
Heathrow should support both the Elizabeth Line and other services
between London Paddington and the airport to optimise the
available capacity and make system wide decisions.
✓
Heathrow should incentivise use of the Elizabeth Line with a special
ticketing as part of the Surface Access Strategy.
✓
Any extended hours on the Elizabeth Line need to be implemented
in conjunction with extended hours on public transport within
London, to ensure that people can complete their journeys.
✓
Heathrow actively participates in and leads the delivery of the
Western Rail Link before construction commences on the third
runway.
✓
The Western Rail Link could provide national connectivity but will
only connect the airport with the Great Western Main Line if
passengers are prepared to change during their journey.
✓
Support expressed for the Western Rail Link and recommendations
that Heathrow should agree the contribution to provide certainty
over its delivery.
✓
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Early planning and investment in the Western Rail Link and other
rail projects will be required well before the runway is completed to
avoid an increase in road traffic.
✓
The Western Rail Link and Elizabeth Line will improve access and
provide quicker journeys for residents close to stations such as Iver
and Taplow.
✓
The Western Rail Link is the number one infrastructure project and
welcomed Heathrow’s commitment to contribute to the scheme.
✓
Concern expressed that there are no alternatives proposed for the
Western Rail Link if it does not go ahead.
✓
Heathrow should help deliver the West London Orbital Rail Link and
provide assurance of service frequency and reliability
improvements for the Piccadilly Line to Uxbridge.
✓ The Mayor’s Transport Strategy includes an early
proposal for a West London Orbital rail line connecting
Hounslow with Cricklewood and Hendon. TfL is
responsible for taking forward these proposals.
Heathrow is committed to working with TfL to support
proposals that will contribute to the assessed transport
needs and demands arising from the expanded
airport.
Rail transport should be given equal priority with road to resolve
gaps in public transport.
✓ The Airport Expansion Consultation One (January
2018) document Our approach to developing a
surface access strategy set out Heathrow’s surface
access priorities in Chapter 4 of the document. It
explained that the proposed priorities were:
• Making public transport the preferred choice for more passengers;
• Offering sustainable and affordable
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alternatives for colleagues, and
• Facilitating more efficient and responsible use of the road network.
Key initiatives set out in Chapter 5 are to put
Heathrow at the heart of the rail network, create a
public transport focused airport, and make public
transport easier to use. These initiatives will see rail
play a vital role in ensuring that Heathrow meets the
surface access targets set out in the ANPS.
Rail trips to Heathrow from SW London involve a detour which is
time consuming result in most trips are being made by car or taxi.
✓ There are currently a number of different proposals
that could connect the existing South Western railway
network to Heathrow via a new Southern Rail Link.
These proposals form part of a wider network
improvement being considered by Network Rail. There
is currently no railway connection between Heathrow
and the south so this link would fill a key gap in the rail
network. A feasibility study undertaken by Network
Rail showed that there is a strong business case for
the proposals and that there are credible infrastructure
solutions that should be explored further. Heathrow’s
analysis to date indicates that the proposed Surface
Access Strategy is not reliant on a Southern Rail Link
to deliver the mode share targets in the ANPS.
However, Heathrow is supportive of proposals for a
Southern Rail Link, which are now being explored in
greater detail by the DfT with private sector
involvement.
Heathrow will set out its draft Surface Access Strategy
at the Airport Expansion Consultation in June 2019,
which includes a range of schemes and considers that
The preferred option for this would be a light rail system from
Chertsey in a tunnel.
✓
Concerns expressed about any proposal to build a new railway line
immediately alongside the M25 from Staines to Chertsey, due to
adverse effects on local people and the disruption to the M25 and
other roads during construction.
✓
Concerns expressed that without such a link residents and
businesses would continue to suffer from long and difficult public
transport journeys to and from the airport, made worse by
expansion.
✓
Concern expressed that the targets around the shift to public
transport are not considered to be reliant on the Southern Rail.
✓
They said no commitment has been made by Heathrow to public
transport that will meet the needs of an expanded airport,
✓
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particularly to the south. they should be delivered whether or not the airport
expands. Heathrow has also ensured that the
emerging Surface Access Strategy has resilience so
that it is not reliant on the delivery of any one scheme.
It is important that any contribution provided by
Heathrow is proportionate to the benefits that airport
users receive as a result of the new infrastructure. For
example, new rail connections for the Great Western
Main line benefit many travellers, and will reduce
travel times, congestion and pollution. This is a good
business case for public investment, regardless of the
expansion of the airport.
Nevertheless, an expanded Heathrow is, as the
Airports Commission’s analysis concluded,
“commercially viable and financeable” and with £187
billion in additional growth for the British economy,
represents value for money in the UK.
The Southern Rail Link is essential to the future success of the
airport and it should form an integral part of the airport’s expansion.
✓
The preferred option would be a railway tunnel starting on the edge
of Staines, emerging between Egham and Virginia Water and with a
station within Runnymede Borough to provide a service from
Egham to the airport.
✓
The principle of having direct rail access to the airport from the
south is supported.
✓
The ‘no more traffic on the road’ pledge cannot be delivered without
improving rail access from the south.
✓
The Government’s Call for ‘Market Led Proposals’ identifies the
Heathrow Southern Rail Link as a priority and their proposals would
provide this.
✓
Opposition expressed to the Southern Rail Link which would
require heavy weight trains to cross over the M3, A30, River Thames
and other local roads.
✓
All level crossings should be replaced by tunnels or bridges or an
alternative route found to Waterloo.
✓
The principle of a new direct rail link to the airport from the south is
supported but concerns expressed about any closing of crossings
because of the effects on road traffic congestion.
✓
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A new rail link from Waterloo to the airport via Clapham Junction,
Putney and Staines should be a priority.
✓
Support expressed for the rail link to southern lines ✓
There is a need for better transport links from the west, south west
and south including the proposed southern rail link
✓
Expansion would not be supported unless a direct link is provided
to the south west railway network.
✓
Further work is needed with funders and stakeholders to develop
the business case for future funding of the Southern Rail Link and
Heathrow should support a collaborative approach to funding and
financing.
✓
A direct rail link between London Waterloo and Heathrow with a
stop at Vauxhall has the opportunity to reduce the number of car
journeys to the airport.
✓
A more direct southern access link from Woking to the Airport
would provide the greatest accessibility improvement for residents
and employees within this area of Surrey and Hampshire and would
provide a realistic alternative to the use of the private car.
✓
There is no commitment from Heathrow to fund the new southern
rail access or proposals do not include a direct link with Woking.
✓
A scheme that enables connectivity between Surrey and Heathrow
should be a key element of the Surface Access Strategy and should
✓
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be delivered before a new runway is operational.
Concern Expressed about the lack of commitment to ensuring
delivery of the Western Rail Link in a timely manner. The
construction of the Western Rail Link should be completed in
advance of construction for airport expansion, to mitigate
disruption and enable significant modal shift to take place.
✓
Concerns expressed about ‘barrier downtime’ at level crossings
associated with the Southern Rail Link in the Borough and the likely
knock on effects on congestion and air quality.
✓
The Southern Rail Link is needed now to address poor public
transport links to the south of the airport, encourage modal shift
and reduce air pollution from congestion and emissions.
✓
Southern Rail Link is essential to help relieve the Crossrail and the
Piccadilly line. There are also issues about the number of
competing options being promoted. There is a need for an objective
analysis of all the options.
✓
Concern expressed that no new rail connectivity has been proposed
and it is implausible that no more traffic on the road can be
delivered without improved rail access from the south.
✓
The Southern Rail Link is needed to deliver the ‘no more traffic on
the road’ pledge, without it there will be more traffic congestion.
✓
Support expressed for the Southern Rail Link. ✓
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Support expressed for the Southern Rail Link. An extended scheme
recommended to be investigated involving tunnelling through to
Wimbledon, rather than just to Kingston.
✓
Concerns expressed at the provision of ‘a resilient and reliable road
network’ noting that many of the schemes are designed to deal with
existing growth in demand and not the extra journeys generated by
an expanded airport.
✓ Heathrow is in regular dialogue with Highways
England to ensure the final M25 design is the best
possible solution for the Strategic Road Network,
Highways England and Heathrow. The M25 is an
important artery into the airport, so for resilience
purposes, Heathrow will be required to ensure it
remains open and operational during construction and
operation. Also, all final road designs will be in
accordance with design standards and regulatory
requirements. Ongoing collaboration with Highways
England is important to ensure this is achieved.
A robust traffic model is being developed, which will
determine the locations of the most severe traffic flow
levels and thus the type of road required to ensure
access is easily achievable for all.
There should be an integrated approach between Heathrow, DfT and
Highways England which will be required to ensure a good level of
service for road users.
✓ The delivery of Heathrow’s strategy will require it to
work with other agencies such as Transport for
London, Highways England, Network Rail and Local
Authorities. Heathrow has a strong history in working
with partners to deliver surface access improvements
that benefit both Heathrow and the surrounding area.
There is an opportunity to develop a coordinated plan
for Heathrow surface access that brings together the
The DfT-sponsored M25 South West Quadrant study has brought
forward several options for further consideration, these need to be
integrated far more closely into the expansion proposals.
✓
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emerging plans for Heathrow with the programmes
developed by Highways England. For example,
Highways England is currently delivering a
programme of activity that was set out in its first Road
Investment Strategy. There are a number of projects
in the Heathrow area including M25 J10
improvements, M25 J10-16 and the M4 Smart
Motorway between J3 and J12. Plans are currently
being developed for the RIS2 (2021-2026) which will
include outputs from the M25 Southwest Quadrant
Study and other strategic studies.
The range of schemes and initiatives presented at the
Airport Expansion Consultation One (January 2018)
include some which are in the process of being
delivered already, and others where delivery will be
secured through the DCO for expansion. A more
detailed programme for delivery of surface access
improvements will be developed taking account of
comments from the public consultation exercises and
further engagement with Highways England.
It is not clear whether a realigned A4 with two lanes will have
sufficient capacity for good public transport.
✓ A robust traffic model is being created, so that any
new road designs for the A4 will bring positive
outcomes for the surrounding communities. The
Airport Expansion Consultation One (January 2018)
was an opportunity for Heathrow to exhibit all options
that will provide suitable links, once the Western
Perimeter Road is removed and the existing
alignments of the A4 and A3044 are diverted.
Heathrow will continue to engage with local
stakeholders, including TfL and other transport
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providers to ensure a suitable solution is arrived at for
the masterplan.
The draft Surface Access Strategy, supported by
technical information in the PTIR will summarise and
illustrate the outputs from the transport modelling and
will be consulted on during the Airport Expansion
Consultation in June 2019. These will explain
Heathrow’s preferred options for the transport
infrastructure needed to support the expansion plans
in the context of increasing the use of public transport
by passengers and colleagues as required by the
ANPS.
There is a need for a fully integrated strategic transport network to
ensure that non-airport ‘through’ traffic has access to viable
alternative routes as the expansion proposals would impact on the
M25 and surrounding roads.
✓ Heathrow is building a sophisticated suite of transport
models which will be utilised to predict the flow of
traffic on the M25 mainline and around the various
junction links. Heathrow is working closely with
Highways England to ensure that the outline solution
for the M25 presented at the Airport Expansion
Consultation (June 2019) will have their agreement,
which will include meeting their views on capacity
requirements. Heathrow has already agreed to
provide collector distributor roads which will improve
traffic flow on the mainline. Key to mitigating the
potential increases of traffic on the M25 is the delivery
of the Surface Access Strategy, which includes
measures to get significant numbers of passengers
and colleagues out of their cars and onto public
transport. A draft Surface Access Strategy will set out
Heathrow’s preferred options for the provision of
infrastructure to meet the needs of the expanded
Concerns expressed about the pressure that will be placed on the
M25 if the pledges are not honoured.
✓
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airport and will be consulted on at the Airport
Expansion Consultation in June 2019.
Road transport to/from the airport should be discouraged. ✓ The Airport Expansion Consultation in June 2019 will
include a draft Surface Access Strategy and
supporting technical information in a PTIR. These will
explain Heathrow’s preferred options for the transport
infrastructure needed to support the Project in the
context of increasing the use of public transport,
walking and cycling by passengers and colleagues,
and our preferred plans for a new parking strategy and
freight/logistics strategy.
The draft Surface Access Strategy will make clear our
commitment to meeting the targets for increasing
passenger mode share by public transport and
reducing the number of colleague car trips, as
required by the ANPS.
The expansion of the coach and bus hub, is supported. There is an
opportunity to introduce new services or increase frequency either
directly to the airport or to connect with direct train services via
East West Rail, the Elizabeth Line and mainline stations in and near
the Heartlands area.
✓ Heathrow plays an important role as a local transport
hub. As a focus for local bus services it is a key
interchange and provides access to the London
Underground and local rail services. As rail and coach
access improves at Heathrow, this role will only
increase. There is an opportunity to ensure that local
communities benefit from this improved access by
making sure there are local services that connect
communities to on airport stations. Heathrow will also
Bus connections to Terminal 5 via Stanwell and Stanwell Moor
should be restored and further consideration should be given to a
local tramway or light railway connection.
✓
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Provision of enhanced bus services is supported, however, there
are concerns about the ability to deliver new bus priority measures
on roads that under the control of local authorities and TfL.
✓ seek to deliver solutions that work towards achieving
local transport priorities that align with our own
strategy, encouraging more sustainable travel in the
local area by all users.
Heathrow will work with TfL and local authorities to
identify new and improved bus priority measures that
could be considered to improve the reliability and
experience of bus users to/from Heathrow. In the
Airport Expansion Consultation One (January 2018)
document, Our approach to developing a surface
access strategy Heathrow explained that it was
considering the following bus priority measures:
• Implementing an internal campus road network that enables easy access to terminals for buses
• Introducing bus-only corridors to Heathrow – exact locations to be determined; and
• Providing off-campus bus priority measures (re-allocate road space for buses (working with TfL/highway authorities) and coaches (working with Highways England) to improve journey times and reliability.
Approximately one third of colleagues (around 10 m
trips per year) and around one million passengers per
year use local buses to travel to and from Heathrow.
The development of bus priority measures into the
airport, on corridors where there are larger
concentrations of colleagues and passengers, could
help achieve a bigger shift towards bus use.
It necessary to increase the provision of public transport options to
serve the southern side of the airport by bus.
✓
The improvement of the coach hub supported. ✓
More attention should be given to inter-urban coach services rather
than local buses.
✓
There should be engagement with Heathrow on how bus services
might be enhanced and improving the local cycle network.
✓
Heathrow must commit to paying capital and revenue costs for the
introduction of regular and quick bus routes to and from the areas
to the west and south.
✓
Bus lanes should be in place for the construction period and could
provide support for bus services to serve shift workers.
✓
Consideration should be given to priority lanes for coaches and
buses to speed up journey times and ensure reliability.
✓
Buses play a vital role for trips in the local area. ✓
The provision of new express and shuttle bus services is welcomed,
these will need to be frequent enough to attract people from their
cars.
✓
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Collaboration would be welcomed with Heathrow to develop
strategic bus routes and ‘demand responsive services’.
✓ The current central bus station will be upgraded into a
new public transport interchange over the life of the
expansion programme. This will have more capacity
for buses and be better integrated with Terminal 2 and
with easier access to London Underground, Rail
stations and walking and cycling routes. In addition to
improving the coach station, Heathrow will work with
the coach industry to encourage new and innovative
routes and operators to improve services for
passengers and increase the travel options on offer.
Areas for growth include the South Coast, with urban
areas like Worthing and Eastbourne, the M40 corridor
including High Wycombe as well as North West
London. Other growing cities in the North would also
benefit from direct coach services.
Heathrow’s preferred options for new and enhanced
bus and coach facilities at the airport will be explained
in the draft Surface Access Strategy, which will be
consulted on as part of the Airport Expansion
Consultation in June 2019.
Heathrow should investigate bus rapid transit to local areas
(Southall, Greenford and Northolt) aimed at employees living
locally, as well as demand responsive bus services.
✓
Heathrow should provide assurance of service reliability
improvements for the 140 bus service (capacity and frequency) or
introduce a new bus service/s to cope with the forecast increased
demand.
✓
The proposed expansion of bus routes ignores those running
outside the Greater London area to the Thames Valley.
✓
Roads such as the A4 should be rebuilt/relocated to include the
provision of dedicated bus lanes in each direction on the approach
to the airport campus.
✓
There should be a bus and coach services towards southern
Buckinghamshire and a review for additional stops and route
additions within the final 10 kilometres to Heathrow.
✓
There is support for strengthening the coach hub. ✓
The Elizabeth Line and the Western Rail Link would support new
and enhanced bus services to these rail stations from
Buckinghamshire.
✓
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Walking and cycling corridors aligned with Bath Road, Staines Road
east-west, High Street Harlington, the A408, Parkway and A3063
north-south, Hayes, Yiewsley, Southall and Hounslow should be
prioritised.
✓ The Our approach to developing a surface access
strategy consultation document at the Airport
Expansion Consultation One (January 2018) stated
that the provision of better and more sustainable
commuting options (public transport, cycling and
walking) was one of the key priorities for the emerging
surface access strategy. It set out a number of
measures and options about how cycling provision
could be improved including expanding the Heathrow
Cycle Hub scheme, new cycle hub facilities, and
ensuring that fast and frequent connections are
available from the cycle hubs to relevant employment
locations around the airport. It would be possible to
build similar hubs at key entrances to the south and
east of the airport, making cycling more convenient for
many more of our colleagues.
Heathrow is developing and refining plans for cycle
and walking provision taking into account feedback
from the Airport Expansion Consultation One (January
2018) and technical assessment. A draft Surface
Access Strategy, including an Active Travel Strategy,
will be consulted on at the Airport Expansion
Consultation in June 2019, and will explain
Heathrow’s preferred options for improving cycle and
walking provision.
There should be trains from stations in Elmbridge and a local bus to
provide local people with sustainable access to the airport.
✓ As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy a priority of the surface
access strategy for Heathrow is improving public
transport so that it becomes the preferred mode of Due to recent cutbacks in bus services, there is a need for better
transport links to and from the airport from the Ashford area.
✓
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There is a need for better transport links to Heathrow from the west,
south west and south from Farnborough and Camberley.
✓ travel for more passengers.
Heathrow supports improved public transport links
from areas that currently do not have direct links to the
airport. Improved bus / coach and rail options are
being investigated as part of the overall surface
access strategy. Elmbridge, Ashford, Farnborough
and Camberley may also benefit from proposals being
considered for a Southern Rail Link that could connect
the existing South Western Railway network to
Heathrow. These proposals form part of a wider
network improvement being considered by the DfT
with private sector involvement.
The preferred options for surface access at the
expanded airport will be set out in the draft surface
access strategy published at the Airport Expansion
Consultation in June 2019, based on feedback from
the Airport Expansion Consultation One (January
2018) and ongoing design and assessment work.
Sustainable transport options are required to improve access to the
airport from towns in the Chilterns.
✓ As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy a priority of the surface
access strategy for Heathrow is improving public
transport so that it becomes the preferred mode of
travel for more passengers.
Heathrow supports improved public transport links
from areas that currently do not have direct links to the
airport. Heathrow acknowledges that the Chilterns
region currently has no direct rail access. Improved
bus / coach and rail options are being investigated as
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part of the overall surface access strategy.
The preferred options for surface access at the
expanded airport will be set out in the draft surface
access strategy published at the Airport Expansion
Consultation in June 2019, based on feedback from
the Airport Expansion Consultation One (January
2018) and ongoing design and assessment work.
Concern expressed about the potential for a Southern Rail Link to
cause traffic congestion at the level crossings in the Mortlake/East
Sheen area.
✓ The operation of level crossings does not fall under
the remit or responsibility of Heathrow; it is the
responsibility of Network Rail as the rail transport
operator. Furthermore, the Southern Rail Link is a
scheme being explored outside of the Project by the
DfT with private sector involvement and as such, the
impact of the Southern Rail Link on traffic congestion
at level crossings is not a specific consideration for the
Project.
However, Heathrow is working and consulting with
transport operators in developing the surface access
strategy for expansion and is supportive of the
principle of a Southern Rail Link.
A new passenger transfer hub adjacent to Wraysbury station would
enhance rail access, as rail passengers could be transferred in
automated pods along the embankment of the Wraysbury Reservoir
as far as M25 Jct. 14 and from there directly into the airport
Terminals.
✓ The proposal suggested does not currently form part
of the options being considered by Heathrow as part
of its Surface Access Strategy.
As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy, new technologies (referred
to in the document as “Intelligent Mobility”) have been
taken into account in developing the surface access
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strategy. Heathrow also recognises in this document
the role that new technologies, including automated
vehicles and on-demand services, could have on the
nature of transport and access to the airport.
The land at Hithermoor should be considered for a new rail station
as part of the Southern Rail Link.
✓ There are currently a number of different proposals
that could connect the existing South Western railway
network to Heathrow via a new Southern Rail Link.
These proposals form part of a wider network
improvement being explored by the DfT. There is
currently no railway connection between Heathrow
and the south so this link would fill a key gap in the rail
network. A feasibility study undertaken by Network
Rail showed that there is a strong business case for
the proposals and that there are credible infrastructure
solutions that should be explored further. Heathrow’s
analysis to date indicates that the proposed surface
access strategy is not reliant on a Southern Rail Link
to deliver the mode share targets in the ANPS and
commitment to no increase in Heathrow-related traffic.
Heathrow will work with the DfT to explore options for
a Southern Rail Link. Heathrow has set out its
preferred surface access strategy, which includes a
range of schemes and considers that they should be
delivered whether or not the airport expands.
However, Heathrow has ensured that the emerging
surface access strategy has resilience so that it is not
reliant on the delivery of any one scheme.
Concerns expressed about how Surrey Heath public transport
infrastructure will contribute to delivering the public transport
✓ The ANPS sets down targets for Heathrow to increase
the public transport mode share of passengers and
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passenger targets. reduce the number of colleague car trips to the airport.
Heathrow will work with local authorities, TfL, Network
Rail and other transport providers / operators to
ensure these targets are met and in order to
understand the target completion dates of any third
party or external schemes included in existing rail,
road or other transport investment plans.
Paragraph 5.12 of the ANPS states that, “Heathrow
must demonstrate that Highways England, Network
Rail and any relevant highway and transport
authorities and transport providers have been
consulted, and are content with the deliverability of
any new transport schemes or other changes required
to existing links to allow expansion within the
timescales required for the preferred scheme as a
whole, the requirements of the ANPS and other
statutory requirements.”
Some surface access infrastructure will be secured in
the DCO itself, while funding and support for schemes
that are being delivered by third parties can be
secured through planning obligations if necessary.
This is consistent with the Government’s Aviation
Policy Framework that states “The general position for
existing airports is that developers should pay the
costs of upgrading or enhancing road, rail or other
transport networks or services where there is a need
to cope with additional passengers travelling to and
from expanded or growing airports. Where the
scheme has a wider range of beneficiaries, the
Government will consider, along with other relevant
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stakeholders, the need for additional public funding on
a case-by-case basis.”
HGVs are a key issue for the Iver community. ✓ In relation to freight, Heathrow plans to limit freight
vehicles to similar levels to today and help operators
clean up the vehicle fleets through a range of different
initiatives, including increasing efficiency, optimising
the fleet mix and modernisation of airport cargo
facilities. The approach and options being considered
in relation to freight were set out in the Airport
Expansion Consultation One (January 2018) in the
Our approach to developing a surface access strategy
consultation document. The preferred option for freight
management will be set out in the Airport Expansion
Consultation in June 2019.
Through the masterplan, the modernisation of the
airport cargo facilities will help allow more cargo to be
processed on airport, reducing the need for goods to
be trucked to and from off airport warehouses. Cargo
and logistics facilities around the airport have grown in
an incremental and organic way which means there
are lots of facilities in different locations. By working
with the local authorities to more proactively plan the
land uses around the airport Heathrow can provide
facilities in appropriate locations helping to reduce
shuttling movements through consolidation of loads
and reducing impacts on local communities, including
Iver.
Heathrow will be working with TfL and other
authorities on re-timing journeys that are not time
critical to outside peak periods, monitoring of routing
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for HGVs and other freight vehicles, as well as
ensuring there are appropriate measures in place for
those that do not comply.
Heathrow is continuing to assess any likely significant
effects associated with construction traffic on local
communities. For further information see Chapter 16.
There should be an increase in the frequency of the X26 express
bus service on its route between the airport and West Croydon.
✓ Heathrow recognises the importance of the airport as
a transport hub and the role of local bus services in
connecting communities to the airport, which will only
be more important as rail, coach and Underground
services to Heathrow are improved under expansion.
As such, Heathrow will work with local authorities, TfL
and transport operators to identify measures for new
and improved services, including bus priority
measures to improve the reliability and experience of
bus users travelling to and from Heathrow.
The emerging Surface Access bus and coach
strategies seek to promote use of the bus or coach by
making them a more attractive mode of transport
through the introduction of new express services,
improvements to the frequency and alignment of
existing routes, and extending operating hours.
Heathrow’s preferred options will be set out in the
draft Surface Access Strategy that will be consulted
on at the Airport Expansion Consultation in June
2019.
If the airport expansion proposals generate HGV traffic in addition
to that generated by other major infrastructure schemes in the same
area, Heathrow should make a significant contribution to the cost of
✓ Heathrow will continue to strive to meet its pledge to
have landside airport-related traffic no greater than
today, including freight traffic. The PTIR will be
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the Iver Relief Road in order to address the cumulative impact of
these schemes.
published as part of the Airport Expansion
Consultation (June 2019) and explains what measures
will need to be taken to deal with the anticipated
transport impacts of the development. It summarises
and illustrates the outputs from the traffic modelling. It
will also set out, at a high-level, the strategy for
mitigating any impacts on the surrounding transport
networks that are considered severe.
Further technical assessment work and consideration
of the feedback from the statutory consultation,
including comments about the PTIR and the draft
Surface Access Strategy, will inform the preparation of
a Transport Assessment. This will be submitted with
the DCO application and will report on the results of
the further detailed assessment work and, for
locations where the impacts of the project are
determined to be severe, will set out in more detail the
proposed mitigation strategy.
Heathrow should identify the need to provide on-demand services
within southern Buckinghamshire
✓ As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy, new technologies (referred
to in the document as ‘Intelligent Mobility’) have been
taken into account in developing the surface access
strategy. Heathrow also recognises in this document
the role that new technologies, including automated
vehicles and on-demand services, could have on the
nature of transport and access to the airport.
For the Airport Expansion Consultation in June 2019,
Heathrow is setting out its preferred options for
surface access at the expanded airport based on
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feedback from the Airport Expansion Consultation
One (January 2018) and ongoing design and
assessment work.
Cycling and walking routes should serve people accessing the
Colne Valley Regional Park, creating important links and building on
the strategic green infrastructure network.
✓ The Our approach to developing a surface access
strategy consultation document at the Airport
Expansion Consultation One (January 2018) stated
that the provision of better and more sustainable
commuting options (public transport, cycling and
walking) was one of the key priorities for the emerging
surface access strategy. It set out a number of
measures and options about how cycling provision
could be improved including expanding the Heathrow
Cycle Hub scheme, new cycle hub facilities, and
ensuring that fast and frequent connections are
available from the cycle hubs to relevant employment
locations around the airport. It would be possible to
build similar hubs at key entrances to the south and
east of the airport, making cycling more convenient for
many more of our colleagues.
Heathrow is developing and refining plans for cycle
and walking provision taking into account feedback
from the Airport Expansion Consultation One (January
2018) and technical assessment. A draft Surface
Access Strategy will be consulted on at the Airport
Expansion Consultation in June 2019, and will explain
Heathrow’s preferred options for improving cycle and
walking provision.
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The reference to demand responsive transport is welcomed. ✓ As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy, new technologies (referred
to in the document as ‘Intelligent Mobility’) have been
taken into account in developing the surface access
strategy.
For the Airport Expansion Consultation in June 2019,
Heathrow is setting out its preferred options for
surface access at the expanded airport based on
feedback from the Airport Expansion Consultation
One (January 2018) and ongoing design and
assessment work.
Concerns expressed that as new runway capacity will not be made
available if noise, traffic or emissions targets will be breached, the
new runway may never be fully utilised. This would undermine the
economic case for expansion.
✓ The ANPS paragraph 5.31 states that the Government
is satisfied that, with a suitable package of policy and
mitigation measures, including the Government’s
modified air quality plan, the Heathrow Northwest
Runway scheme would be capable of being delivered
without impacting the UK’s compliance with air quality
limit values. This also aligns with the conclusion of the
Airport’s Commission and Heathrow’s own work.
The ANPS also includes requirements on noise and
traffic which Heathrow must demonstrate it can meet
as part of its DCO. As part of our Airport Expansion
Consultation in June 2019, we will be publishing more
information on how we will monitor environmental
performance for an expanded airport.
All Heathrow related vehicles should be low or zero emissions. ✓ One option for road user charging being considered,
and which was set out at the Airport Expansion
Consultation One (January 2018) in the Our approach
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to developing a surface access strategy consultation
document, is a charge based on vehicle emissions or
the creation of a low emissions zone. Furthermore, it
explained that Heathrow is investigating options to
ensure that new vehicle technology can be supported
at the airport through appropriate electric vehicle
charging or fuel infrastructure at the airport. This is
already happening with the introduction of a hydrogen
filling station at the airport and Heathrow’s investment
of almost £4million on electric vehicle charging
infrastructure since 2014.
For the Airport Expansion Consultation in June 2019,
Heathrow is setting out its preferred options for
surface access at the expanded airport based on
feedback from the Airport Expansion Consultation
One (January 2018) and ongoing design and
assessment work.
Heathrow should include local communities in the development of
the Surface Access Strategy.
✓ Heathrow has engaged with neighbouring
communities to understand their surface access
requirements to and from the airport, which the draft
Surface Access Strategy will look to support. The
ANPS (paragraph 5.9) also requires that the surface
access strategy is developed in conjunction with the
Airport Transport Forum of key stakeholders including
representatives of local communities. Heathrow
consulted on the emerging surface access strategy at
the Airport Expansion Consultation One (January
2018) where the options were presented in the Our
approach to developing a surface access strategy
consultation document. A draft Surface Access
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Strategy will explain and seek feedback on
Heathrow’s preferred options, which will be consulted
on in the Airport Expansion Consultation in June 2019,
in advance of the submission of the application for a
DCO.
Heathrow should include communities that are further away in the
development of the Surface Access Strategy.
✓ Heathrow consulted on the emerging surface access
strategy at the Airport Expansion Consultation One
(January 2018) where the options were presented in
the Our approach to developing a surface access
strategy consultation document. A draft Surface
Access Strategy will explain and seek feedback on
Heathrow’s preferred options, which will be consulted
on in the Airport Expansion Consultation in June 2019,
in advance of the submission of the application for a
DCO. The ANPS (paragraph 5.9) also requires that
the surface access strategy is developed in
conjunction with the Airport Transport Forum of key
stakeholders including representatives of local
communities affected by the expansion plans. Anyone
who is interested in the expansion plans, regardless of
where they live, can put forward their views about the
surface access strategy and the expansion plans.
Publicity about the Airport Expansion Consultation in
June 2019 will be published in local and national
newspapers and journals in accordance with the
Statement of Community Consultation and the
requirements of the Planning Act 2008.
There should be existing public transport improvements to deal
with existing demand under a two-runway airport, not to cater for
✓ The ANPS states at paragraph 3.36 that “Heathrow
Airport already has good surface transport links to the
rest of the UK. It enjoys road links via the M25, M4,
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expansion. M40 and M3, and rail links via the London
Underground Piccadilly Line, Heathrow Connect, and
Heathrow Express. In the future, it will connect to
Crossrail, and link to HS2 at Old Oak Common. Plans
are being developed for improved rail access: the
proposed Western Rail Access could link the airport to
the Great Western Main Line, and Southern Rail
Access could join routes to the South Western
Railway network and London Waterloo Station. This
varied choice of road and rail connections makes
Heathrow Airport accessible to both passengers and
freight operators in much of the UK, and provides
significant resilience to any disruption.”
Committed schemes that will come forward regardless
of the expansion plans include the Elizabeth Line, that
will begin operating to the airport in 2019, and the
Piccadilly Line upgrade that is planned for 2023. The
Western Rail Link is being promoted by Network Rail
to provide a direct rail connection to Heathrow from
the Great Western Mainline to the west of the airport.
Together these committed projects will contribute
towards continuing the trend that has seen passenger
numbers at the airport double since 1991, but airport-
related road traffic remain largely static.
Road user charging supported. ✓ Support for the principle of road user charging is
noted. Heathrow considers the ability to impose road
user charges where necessary is an important Support for the principle of road pricing and a commitment to use ✓
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the proceeds to provide transport improvements could improve its
acceptance.
component of an integrated surface access strategy
that responds to the targets on air quality, public
transport use and congestion set out in the ANPS. It is
an approach supported by ANPS (paragraph 5.39)
and the recommendations of the Airports Commission.
Options for road user charging were set out at the
Airport Expansion Consultation One (January 2018) in
the Our approach to developing a surface access
strategy consultation document. These included:
• Emissions based surcharge
• Drop off charge
• Terminal low emission zone
• Airport low emissions zone
• Airport access charge
A preferred option is being developed taking into
account consultation feedback and ongoing technical
assessment on the anticipated transport impacts of
expansion. The preferred option will be set out in the
Airport Expansion Consultation in June 2019.
The principle of road user charging is supported, London’s is a
useful model.
✓
Campaign supported road-user charging and/or other methods to
reduce private motor vehicle volumes.
✓
Support expressed for road user charging. ✓
Support expressed for the principle of road user charging,
specifically on the basis of emissions.
✓
Welcome the option of restricting vehicle access through emissions
or access-based charging, suggesting that further analysis of
congestion, charging and other interventions.
✓
The proposals for road user charging supported as it would
encourage public transport use and reduce the number of cars on
the road.
✓
Road user charging would result in better access and convenience
for passengers, would ease congestion and result in a reduction in
emissions and noise pollution and an improvement in air quality.
✓
The Surface Access Strategy would encourage the use of low
emission cars.
✓
Road user charging is both inevitable and logical. ✓
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Road user charging and drop off charges for leisure travellers
should form part of the decision on transport mode.
✓
Charging for passenger drop-off and collection should be further
reviewed as part of a wider strategy to increase the cost of road
travel to Heathrow compared with rail.
✓
It is not clear whether a congestion charge scheme would be
required but Heathrow should have a scheme that is ready to be put
in place should it be required.
✓
Road user charging is supported if electric vehicle were exempt.
This would encourage their use and not restrict vehicle access for
passengers.
✓
The exploration of road user charging and is supported, it will be
necessary to raise the emissions standards incrementally as
technology improves.
✓
Support expressed for road user charging if there are adequate
improvements in public transport.
✓ Heathrow considers that the ability to impose road
user charges where necessary is an important
component of an effective surface access strategy
that responds to the targets on air quality, public
transport use and congestion set out in the ANPS.
Alongside a charging strategy, Heathrow is developing
a wide range of improvements to public transport
provision and accessibility within its surface access
strategy, including rail, coach and local bus, as well as
cycling and walking and colleague travel initiatives.
This aims to create an integrated strategy to meet the
The principle of vehicle charging to encourage modal shift from
road to rail is supported. This can only be justified and is only likely
to be acceptable to airlines and passengers if carried out in
conjunction with major improvements to public transport
connections.
✓
Road user charging may be the only way to encourage use of public ✓
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transport but only if public transport is readily accessible. targets within the ANPS and make public transport the
preferred choice of more passengers and colleagues.
Consideration is being given to the most appropriate
allocation of any potential funding stream generated
by road user charging. Options for road user charging
and the surface access strategy in general were set
out at the Airport Expansion Consultation One
(January 2018) in the Our approach to developing a
surface access strategy consultation document. A
preferred option is being developed taking into
account consultation feedback and ongoing technical
assessment on the anticipated transport impacts of
expansion. The preferred option will be set out in the
Airport Expansion Consultation in June 2019.
The Road-User Charging is not a fix for a lack of public transport
investment.
✓
Road-user charging and car parking charges can be effective tools
but must be accompanied by alternative public transport. They
considered that these measures should be pursued to improve air
quality regardless of a third runway.
✓
If suitable alternatives are not provided, road-user charging cannot
be supported.
✓
The revenue from road user charging should be spent on improved
public transport and public transport infrastructure.
✓
Heathrow needs to make the case that road user charging will not
be used to increase income for the airport through displacing traffic
and parking.
✓
If it is seen to be used to fund public transport links to transport
hubs with dedicated parking sites, then a charging approach would
have greater support.
✓
A road user charge will make no difference to air and noise
pollution.
✓ Objection to the principle of road user charging is
noted.
The ANPS, paragraph 5.39, states that an emissions-
based access charge is a potential mitigation measure Opposition shown to road user charging, considering it to be a ✓
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stealth tax. that may be put forward by the applicant in order to
meet the passenger mode share and colleague car
trip targets in the ANPS. This is consistent with the
Airports Commission recommendation that the
introduction of a congestion or access charge for road
vehicles should be considered.
Heathrow considers the ability to impose road user
charges where necessary is an important component
of an integrated surface access strategy that responds
to the ANPS surface access targets. A price incentive
that favours public transport is important to obtain the
required behavioural change from airport users and
enable maximum effectiveness and use of
investments in public transport. It is intended to be
implemented as a component of an integrated surface
access strategy alongside a wide range of
improvements to public transport provision and
accessibility.
Heathrow remains committed to keeping airport
charges close to 2016 levels.
Did not favour road user charging. ✓
Road user charging has a role, however, it would have no more
effect than the already high parking charges.
✓
Road user charging will not necessarily reduce travel. ✓
It is unreasonable to pay a road user charge to access the airport
for private car or taxi on top of high airport charges and Air
Passenger Duty.
✓
Concern expressed about proposals to charge airlines and their
passengers for the cost of the access work associated with
expansion.
✓
Concerns expressed about road user charging. ✓
Motorists are already taxed too much and the proposals for road
user charging are unfair for those that work at the airport and would
also result in increases in taxi fares.
✓
Any additional road user charges will directly impact the airport,
passengers and employees.
✓
Alternative mechanisms and schemes for promoting modal shift
and meeting the targets of the ANPS should be exhausted before
✓
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any form of additional charges to airport users is introduced.
Any alternative mechanisms and oncoming schemes for promoting
modal shift to meet the targets of the ANPS should be exhausted
before any form of additional charges to airport users are
introduced.
✓
Further analysis of congestion, charging and other interventions
should be undertaken.
✓ The Airport Expansion Consultation One (January
2018) materials presented the options that were being
considered by Heathrow to improve public transport at
the airport. These were set out in the Our Emerging
Plans and Our approach to developing a surface
access strategy. For the Airport Expansion
Consultation in June 2019, Heathrow is setting out its
preferred options for public transport provision at the
expanded airport based on feedback from the Airport
Expansion Consultation One (January 2018) and
ongoing design and assessment work.
Furthermore, a Transport Assessment will be
submitted with the DCO application and will report on
the results of the further detailed assessment work
and, for locations where the impacts of the project are
determined to be severe, will set out in more detail the
proposed mitigation strategy. An Environmental
Statement will assess the scheme in terms of its likely
impacts on the environment and identify mitigation
measures to minimise impacts.
Further analysis should be undertaken as to how road user
charging would reduce emissions and vehicle numbers.
✓
Road user charging may not be effective and there is no clear detail
on how it will be monitored and by who.
✓
The impact of this strategy on business and the implications for
staff and visitor travel if road user charging and an airport uLEZ
were to be considered needs to be understood.
✓
Concerns expressed about road user charging and low emissions
zone charging around the airport as it is considered that it may
distort how the market operates and negate the attempts to
minimise traffic generation.
✓
Road user charging is generally noted but it should be noted that it
only works on the assumption that all the vehicles in and around
the airport are electric.
✓
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The proposed uLEZ zones need to be designed to ensure that any
impacts or benefits are effective and offset all potential emission
source increases including from aircraft.
✓
The proposal for road user charging has not been researched
properly or accurately and it will not work.
✓
The focus should be on low emission vehicles and that road user
charging is not the right principle.
✓ One option for road user charging being considered,
and which was set out at the Airport Expansion
Consultation One (January 2018) in the Our approach
to developing a surface access strategy consultation
document, is a charge based on vehicle emissions or
the creation of a low emissions zone. Furthermore, it
explained that Heathrow is investigating options to
ensure that new vehicle technology can be supported
at the airport through appropriate electric vehicle
charging or fuel infrastructure at the airport. This is
already happening with the introduction of a hydrogen
filling station at the airport and Heathrow’s investment
of almost £4million on electric vehicle charging
infrastructure since 2014.
For the Airport Expansion Consultation in June 2019,
Heathrow is setting out its preferred options for
surface access at the expanded airport based on
feedback from the Airport Expansion Consultation
One (January 2018) and ongoing design and
assessment work.
The focus should be on autonomous vehicles rather than road user
charging.
✓ As set out in the Airport Expansion Consultation One
(January 2018) document Our approach to developing
a surface access strategy, new technologies (referred
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to in the document as ‘Intelligent Mobility’) have been
taken into account in developing the surface access
strategy.
For the Airport Expansion Consultation in June 2019,
Heathrow will set out its preferred options for surface
access at the expanded airport based on feedback
from the Airport Expansion Consultation One (January
2018) and ongoing design and assessment work.
Heathrow should consider using renewable diesel for bus and
coaches if a uLEZ is to be introduced.
✓ The Airport Expansion Consultation One (January
2018) document Our approach to developing a
surface access strategy explained that Heathrow is
investigating options to ensure that new vehicle
technology can be supported at the airport through
appropriate electric vehicle charging or fuel
infrastructure at the airport. This is already happening
with the introduction of a hydrogen filling station at the
airport and Heathrow’s investment of almost £4million
on electric vehicle charging infrastructure since 2014.
The draft Surface Access Strategy will be published
as part of the Airport Expansion Consultation (June
2019) and will explain Heathrow’s preferred options
for promoting the use of cleaner vehicles servicing the
airport, including providing electric charging
infrastructure at the airport.
Consultation on road user charging is the Government's
responsibility.
✓ The proposals for user charging would involve
Heathrow being granted powers in the DCO to impose
charges for vehicles using the airport roads. It is
therefore Heathrow's responsibility to carry out
consultation on those proposals. Heathrow is
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therefore consulting on road user charging relating to
the Project. Options for road user charging at the
airport related to expansion were consulted on at the
Airport Expansion Consultation One (January 2018) in
the document Our approach to developing a surface
access strategy. Further consultation is being
undertaken prior to submission of the DCO application
in accordance with best practice and statutory
requirements, as more detailed proposals are
developed and preferred options identified.
The proposals for road user charging are not socially inclusive. ✓ Heathrow considers the ability to impose road user
charges where necessary is an important component
of a surface access strategy that responds to the
targets on air quality, public transport use and
congestion set out in the ANPS. It is an approach
supported by ANPS (paragraph 5.39) and the
recommendations of the Airports Commission. A price
incentive that favours public transport is important to
obtain the required behavioural change from airport
users and enable maximum effectiveness and use of
investments in public transport. Any charging strategy
will be implemented in a manner that is sensitive to
the needs of airline colleagues and passengers and
would include appropriate exemptions.
Emission charging should be for direct users of the airport rather
than all vehicles. Joint monitoring and review of air quality across
the area is vital to the success of achieving a reduction in
emissions.
✓ The principle of vehicle charging is considered a
necessary component of an integrated strategy that
responds to the ANPS targets. A price incentive
towards alternative modes of transport is important to
obtain the required behavioural change from airport
users and enable maximum effectiveness and use of
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investments in public transport.
As set out in the Airport Expansion Consultation One
document Our approach to developing a surface
access strategy, any charging strategy will be
implemented in a manner that is sensitive to the
needs of airline staff and passengers and would
include appropriate exemptions. Heathrow has stated
that the surface access strategy for expansion will
contain specific and measurable targets that can be
monitored over time.
Concerns expressed about road user charging and low emissions
zone charging around the airport as it is considered that it may
distort how the market operates and negate the attempts to
minimise traffic generation.
✓ A low emissions zone was just one option within the
wider consideration of road user charging that was set
out at the Airport Expansion Consultation One
(January 2018) in the Our approach to developing a
surface access strategy consultation document. A
preferred option is being developed taking into
account consultation feedback and ongoing technical
assessment on the anticipated transport impacts of
expansion. The preferred option will be set out in a
draft Surface Access Strategy at the Airport
Expansion Consultation in June 2019. This will take
account of feedback received during ongoing
consultation and engagement activities, including with
the public, local authorities, landowners, TfL and
numerous other stakeholders.
Heathrow should consult with commercial operators and land
owners to ensure that it does not reduce competitiveness or lead to
more traffic in the areas on the edge of the zone.
✓
Heathrow should work with councils to create a wider low emission
zone (CAZ) that helps address the AQMA’s surrounding the
expanded airport rather than an extension of the TfL LEZ causing
more polluting vehicles to travel in the surrounding Slough
Borough.
✓
A drop off/pick up charge will need to be carefully managed and a
uLEZ for freight vehicles could see a reduction in emissions.
✓ A low emissions zone and a drop off/pick up charge
are two options within wider consideration of road user
charging set out at the Airport Expansion Consultation
One (January 2018) in the Our approach to
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developing a surface access strategy consultation
document. A preferred option is being developed
taking into account consultation feedback and ongoing
technical assessment on the anticipated transport
impacts of expansion. The preferred option will be set
out in the Airport Expansion Consultation in June
2019. Options specifically in relation to freight are also
being considered and developed alongside a charging
strategy.
Any road user charging scheme needs to be simple with viable
alternatives.
✓ Heathrow considers that the ability to impose road
user charges where necessary is an important
component of a surface access strategy that responds
to the targets on air quality, public transport use and
congestion set out in the ANPS. Alongside a charging
strategy, Heathrow is developing a wide range of
improvements to public transport provision and
accessibility within its surface access strategy,
including rail, coach and local bus, as well as cycling
and walking and colleague travel initiatives. This aims
to create an integrated strategy to meet the targets
within the ANPS and make public transport the
preferred choice of more passengers and colleagues.
Concern expressed about the risk of introducing excessive charges
that lead to car drivers using surrounding villages as alternatives
for parking.
✓ Heathrow considers that the ability to impose road
user charging, where necessary, is an important
component of a surface access strategy that responds
to the targets on air quality, public transport use and
congestion set out in the ANPS. A price incentive
towards alternative modes of transport is important to Road user charging is an effective method to dis-incentivise vehicle
use within certain areas but around the airport it will create
✓
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disadvantages to local residents. obtain the required behavioural change from airport
users and enable maximum effectiveness and use of
investments in public transport. Any charging strategy
will be implemented in a manner that is sensitive to
the needs of airline colleagues and passengers and
would include appropriate exemptions.
As set out at the Airport Expansion Consultation One
(January 2018) in the Our approach to developing a
surface access strategy consultation document,
Heathrow will work with local authorities to develop
schemes to prevent airport-related parking on local
residential roads, such as the introduction of
Controlled Parking Zones (CPZs) and their
enforcement.
The options for road user charging were consulted on
at the Airport Expansion Consultation One (January
2018). Further information and the preferred approach
to a charging strategy will be set out and consulted
upon in the draft Surface Access Strategy during the
Airport Expansion Consultation in June 2019.
Furthermore, a Transport Assessment will be
submitted with the DCO application and will report on
the results of the further detailed assessment work
and, for locations where the impacts of the project are
determined to be severe, will set out in more detail the
proposed mitigation strategy.
The principle of a uLEZ is supported but cars should not be
displaced into surrounding areas to park on local roads.
✓
Residents who live near the airport should be exempt from any road
charges were also received.
✓
The details of any proposed road charging schemes should take
into account the need to control any adverse impacts at the
charging boundary.
✓
Road user charging must be designed to avoid unacceptable
displacement impacts and be fully funded by Heathrow, including
associated mitigation measures, to ensure local communities are
not unfairly penalised.
✓
These approaches must be considered across the entire area to
avoid either displacing private car journeys to a few stops down the
underground line or nearby hotels etc.
✓
Airport employees will have the road user charging factored into
rates of pay or contracts and it will instead have the greatest effect
on local residents who are not compensated through employment.
✓
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Any road-user charging should be implemented in a way that
reduces traffic, poor air quality and noise impact on the natural
environment.
✓ Heathrow considers the ability to impose road user
charges where necessary is an important component
of a surface access strategy that responds to the
targets on air quality, public transport use and
congestion set out in the ANPS. It is an approach
supported by ANPS (paragraph 5.39). The options for
road user charging were consulted on at the Airport
Expansion Consultation One (January 2018) and
included consideration of charging related to vehicle
emissions, drop-off, general access or the creation of
low emissions zones. The aim of a charging strategy
would be to prevent increases in traffic, encourage
public transport use and help address air quality
concerns.
Further information and the preferred approach to a
charging strategy will be set out and consulted upon in
the draft Surface Access Strategy during the Airport
Expansion Consultation in June 2019.
Road-user charging be implemented in a way that reduces traffic,
poor air quality and noise impact on the Park and its local
communities.
✓
Heathrow’s work on sustainable travel plans for its staff and
contractors to reduce reliance on private motor vehicles is
supported.
✓ The Airport Expansion Consultation in June 2019 will
include a draft Surface Access Strategy and
supporting technical information in the PTIR. This will
explain Heathrow’s preferred options for the transport
infrastructure needed to support the Project in the
context of increasing the use of public transport,
walking and cycling by passengers and colleagues,
and Heathrow’s preferred plans for a new parking
Heathrow should continue their commuter programme to reduce car
use.
✓
Heathrow should consider where the future workforce will be from
and seek to encourage a greater spread of employees with an
✓
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equitable choice of transport modes. strategy and freight/logistics strategy.
The draft Surface Access Strategy will make clear
Heathrow’s commitment to meeting the targets for
increasing passenger mode share by public transport
and reducing the number of colleague car trips as
required by the ANPS.
Many Heathrow colleagues live in boroughs close to
the airport such as Hillingdon, Hounslow, Ealing,
Slough and Spelthorne. These are also the areas with
the highest proportion of people travelling to work by
public transport. Where there are good alternatives
people are using public transport or other sustainable
modes such as car sharing to get to work. Heathrow
wants fewer colleagues to drive to work by making
more sustainable modes more attractive.
Heathrow has been working with colleagues at the
airport to reduce the number of people driving single
occupied, private cars to work. Heathrow has invested
in a dedicated commuter team as well as local
transport to make it easier and more affordable for
people to use.
As part of its surface access strategy for expansion,
Heathrow is committed to working with Highways
England, Network Rail, TfL, local authorities and
transport operators to understand and plan for the
transport needs of the local communities affected by
the expansion and further improve colleague access
to sustainable travel as well as changing travel
behaviour.
The strategy allows more staff/workers to use public transport to
get to/from work at the airport.
✓
The awareness of changing staff travel behaviour is welcomed and
Heathrow should think creatively about how this might be achieved.
✓
An opportunity to evaluate how transport for airport workers can be
incorporated into a wider public transport strategy across the M3
corridor, incorporating passenger transport and airport access
would be welcomed.
✓
Employees can often benefit from a monthly season bus ticket and
this could be addressed through an expansion of the free travel
zone for buses.
✓
Heathrow must consider the future workforce and encourage a
greater spread of employees with an equitable choice of transport
modes.
✓
There is a need for certainty on how Heathrow will achieve the
proposed targets for reducing staff car trips.
✓
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A draft Surface Access Strategy will be consulted on
at the Airport Expansion Consultation in June 2019
and will explain Heathrow’s preferred options for
encouraging sustainable travel by colleagues.
The provision of cycle routes is supported. ✓ The Our approach to developing a surface access
strategy consultation document at the Airport
Expansion Consultation One (January 2018) stated
that the provision of better and more sustainable
commuting options (public transport, cycling and
walking) was one of the key priorities for the emerging
surface access strategy. It set out a number of
measures and options about how cycling provision
could be improved including:
• expanding the Heathrow Cycle Hub scheme which already has over 2,300 members and offers discounted cycles and equipment, free labour on maintenance and training to all airport employees.
• new cycle hub facilities could provide a single point of entry to and from Heathrow and a holistic service to users, including shower and changing facilities.
• ensure that fast and frequent connections are available from the cycle hubs to relevant employment locations around the airport. It would be possible to build similar hubs at key entrances to the south and east of the airport, making cycling more convenient for many
More could be done to ensure that a far higher proportion of those
working at or near the airport can cycle to work.
✓
Cycle hub areas will require large amounts of cycle parking. ✓
Heathrow should provide safe, high quality cycle infrastructure for
employees living near the airport.
✓
Walking and cycling needs to become part of an integrated
approach to reducing traffic and managing air quality.
✓
A clear target for cycle journeys for staff that exceeds TfL targets
for London and develops a plan to deliver the infrastructure
necessary to meet that target.
✓
Heathrow should ensure that walking and cycling are enabled and
there should be no increase in road vehicles across the area.
✓
The new runway would present one of the largest barriers to north-
south cycling in London. Heathrow should include a tunnel for
cyclists under the runway.
✓
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Suggested that there should be a more central north-south cycle
route through the airport which could potentially be combined with
the proposed new southern access to the central terminal area.
✓ more of our colleagues.
Heathrow is developing and refining plans for cycle
and walking provision taking into account feedback
from the Airport Expansion Consultation One (January
2018) and ongoing technical assessment work. A draft
Surface Access Strategy will be consulted on at the
Airport Expansion Consultation in June 2019 and will
explain Heathrow’s preferred options for improving
cycle and walking provision.
Much of the area surrounding the airport is inhospitable to cycling
and/or walking. Better walking and cycling routes, connections and
neighbourhoods should be provided.
✓
There could be cycle routes around the perimeter and to the west
and south of the airport.
✓
The proposals to promote walking and cycling should only relate to
staff working on the airport periphery and not to passengers or to
staff needing to go into the central area.
✓
Initiatives to provide more sustainable travel alternatives are
supported but consideration should be given to how the airport will
fit into the existing cycle and footpath network.
✓
A cycle network is essential to encourage workers to cycle to and
from work and in the vicinity of the airport. They suggested that this
must be considered in the road alignments and junction layouts of
both the local road network and motorway.
✓
Heathrow should develop walking and cycling routes that will
provide safe and attractive routes into the airport as well as
alternative green transport links between each of the population
nodes.
✓
Conditions for cycle access to Heathrow will require an
improvement to cycle superhighway standard and secure cycle
✓
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parking at all parts of the airport where employees are based.
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AIR QUALITY AND EMISSIONS
Introduction
21.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in
relation to the measures proposed to manage emissions from the design,
construction and operation of the Heathrow Expansion Project (the Project). A
total of 1,226 consultees made comments relating to this topic.
21.1.2 Heathrow provided the following material that is directly related to the measures
proposed to manage emissions:
1. Airport Expansion Consultation Document; and
2. Our Approach to Air Quality.
21.1.3 Heathrow asked the following questions in relation to the measures proposed to
manage emissions at Airport Expansion Consultation One:
1. Please tell us what you think about the measures proposed to manage
emissions. Are there any other measures that we should consider?
21.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
Prescribed Consultees
Local Authorities
General Comments
21.2.1 Bracknell Forest Council expressed concerns that expansion will increase
disturbance and pollution for its residents, particularly those in the northern
parishes of the borough. They requested further information on the proposals to
eliminate these effects, maintain air quality and minimise emissions.
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21.2.2 The London Boroughs of Hillingdon, Richmond upon Thames and Wandsworth
and the Royal Borough of Windsor and Maidenhead stated their opposition to the
Project due to unlawful air pollution. They suggested that the government’s air
quality plan does not include expansion at Heathrow and considered that there is
no evidence to suggest an expanded Heathrow can be achieved and operated
without causing additional unlawful air pollution. They suggested the best
approach is to not expand Heathrow and address the current adverse impacts.
21.2.3 The London Borough of Islington expressed opposition to expansion and raised
concerns that any increase in air travel will have a detrimental impact on air quality
and increase greenhouse gas emissions.
21.2.4 Kent County Council welcomed Heathrow‘s commitment to develop new
technologies that could improve the environment in which they operate. They
suggested that Heathrow contribute funding for such technological improvements
and facilitate the development of new technologies to do this.
21.2.5 The London Borough of Lambeth expressed concern about the potential impact on
air quality in the immediate and Greater London area. They stated that an
expanded Heathrow will undermine London’s ability to meet legal air quality limits
and said that the Heathrow area has breached air pollution limits every year for the
past decade due to its location between the M25 and M4 motorways, planes and
traffic.
21.2.6 Wycombe District Council expressed concern about the impacts of pollution on
their residents due to the Project. They commented that Heathrow must make a
commitment to deliver projects that enable passengers, workers, commuters and
freight to move to more sustainable and accessible modes of travel and contribute
towards the achievement of mode share targets.
Surface access related emissions and management
21.2.7 The London Borough of Brent considered that more could be done to
control/influence how the airport is accessed and reduce the need for passenger
and staff car use. Elmbridge Borough Council also referred to surface access
issues in respect of air quality and noted that better traffic management and
vehicle improvements will also improve air quality around the airport, whilst
highlighting that tackling air quality is not the sole responsibility of Heathrow.
21.2.8 The London Borough of Hounslow contested Heathrow’s statement that airport
related traffic accounts for only 16% of the total volume of traffic on the
surrounding road network. They expressed concern about the deliverability of
Heathrow’s pledge to deliver expansion with no more vehicles on the road without
any new significant public transport infrastructure being proposed. They also
commented that dust emissions will need to be assessed as part of a cumulative
impact assessment.
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21.2.9 The Royal Borough of Kingston on Thames said that air quality modelling
contributions towards the costs of major schemes and investment in the public
transport network will be required. They identified that even with these approaches
the latest government air quality assessments show that the Project will make the
London Zone non-compliant in 2026/28. They considered that the only way to
address this would be the implementation of a Clean Air Zone and/or Zero
Emissions Zone. A similar view was shared by Ealing Council who stated that
there needs to be an Ultra-Low Emission Zone (ULEZ) and that consideration
should be given to alternative fuel infrastructure especially for freight transport, so
that ultra-low emission vehicle technologies can be introduced.
21.2.10 The Royal Borough of Kingston on Thames also stated that the implementation of
Air Quality Action Plans, surface access improvements and encouraging
sustainable forms of transport would be of benefit and suggested that Heathrow
work with stakeholders to increase understanding of key matters such as how it
affects the health and quality of life of local communities.
21.2.11 Reading Borough Council emphasised that the delivery of the rail and bus links for
surface access will be the most effective way of reducing emissions and improving
air quality. They also requested further detail on how the emissions from the extra
planes will be addressed.
21.2.12 Slough Borough Council expressed concern that displaced airport and non-airport
traffic will give rise to air pollution hot spots, suggested that the scope of air quality
assessments will need to be agreed with Heathrow Strategic Planning Group
(HSPG) and requested that Brands Hill Air Quality Management Area be included
with the airports air quality model and study area.
21.2.13 Spelthorne Borough Council requested mitigation measures to improve air quality
in pollution hotspots beyond the immediate area of the scheme. They raised
concerns that expansion will result in significant redistribution of traffic around the
airport and additional traffic flows across the north of Spelthorne where
improvements and mitigation will also be required.
21.2.14 They suggested that the definition of Heathrow related traffic must include traffic
on all roads, as vehicle movements on the airport controlled landside roads could
have significant highways, air quality and noise impacts. The Perimeter Roads
also carry a high proportion of traffic circulating around the airport between
terminals, car parks and other ancillary airport facilities and must be included in
both the baseline and future assessment of vehicle movements.
21.2.15 Surrey Heath Borough Council welcomed Heathrow's aim to incentivise more
efficient operation of aircraft on the ground and upgrade the airline fleet but
requested that their highway network is given full consideration in Heathrow's
future approach to air quality. This includes an AQMA in place on the M3 between
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J3 and 4 and the A331 in the west of Surrey Heath, where exceedances of the
annual mean NO2 limit value have been identified.
21.2.16 The Royal Borough of Windsor and Maidenhead expressed concern that
expansion would increase traffic in the Air Quality Management Areas (AQMAs)
within the borough and that no strategic objective for the management of surface
transport had been produced. They considered that Heathrow has not
demonstrated how it can effectively deliver its proposed scheme, including its
2030 public transport modal share target, without adversely affecting air quality.
21.2.17 They also requested that:
1. the A4 is declared as a clean air zone (CAZ) and aligned with the airports low
emission zone (LEZ);
2. airport related freight routes that use the strategic road network (motorway),
are CAZ compliant;
3. electric vehicle infrastructure is implemented within and outside the airport to
encourage the adoption of low emission vehicles; and
4. Heathrow work with the Council to enable all taxis to be ultra-low emission
vehicles (ULEV) by 2025.
Air quality assessment and monitoring
21.2.18 Buckinghamshire County Council stated that local air quality and the potential
effects of pollution upon public health remain a significant concern to communities
around Heathrow. They welcomed Heathrow’s commitment to complete a detailed
air quality assessment and commented that increases in passengers, freight and
staff are likely to push air quality over legal limits in communities in the southern
part of the county.
21.2.19 They stated that the area of monitoring must include locations in and around the
Ivers which will be subject to cumulative increases in traffic and locations and has
high numbers of vulnerable users i.e. schools and where the public access leisure
and recreation facilities.
21.2.20 They also stated that it is not clear what the current health impacts are, and no
information is provided on the health impacts and mitigation measures, a view also
expressed by Elmbridge Borough Council. They requested the health impact and
air quality assessment methodologies and reports are provided at the earliest
opportunity.
21.2.21 The London Borough of Hammersmith and Fulham expressed concern that
increases in emissions of pollutants during the construction or operational phases
of the scheme could result in the worsening of local air quality. They also
highlighted that air quality assessments show that an expanded Heathrow would
contribute to exceedances of the Nitrogen Dioxide air quality limits.
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21.2.22 The London Borough of Hounslow expressed disappointment at Heathrow’s
reluctance to fund on-site air quality monitoring and requesting continuous
monitoring to establish an accurate baseline at specific sites. They also shared
concern that Heathrow appears content to use the Pollution Climate Mapping
(PCM) model, which is known to under-predict real air pollution level by a
wide margin.
21.2.23 Runnymede Borough Council commented that to grant development consent, the
Secretary of State will need to be satisfied that the scheme would be compliant
with legal requirements on air quality impacts in the wider area. They requested
confirmation of how the wider area is defined before they could confirm
acceptance of Heathrow’s approach. They also highlighted that Heathrow’s
assessment must include the cumulative impact on existing exceedances and
likelihood of new/additional exceedances of the air quality objective limits.
21.2.24 They expressed concern about the impacts on air quality and the health of
communities during the construction and operation of the expanded airport
including the M25 and suggested that compliance with the National Air Quality
Objectives and rigorous monitoring of performance against agreed measures at
regular intervals are essential. To achieve this, they considered that air pollutants
should be monitored and assessed on the surrounding local and strategic road
network and not just within the red line boundary.
21.2.25 Slough Borough Council expressed support for the ‘Triple Lock Guarantee’.
21.2.26 South Bucks District Council expressed concern about the impact on the proposed
AQMA in the Iver and Burnham Beeches Special Area of Conservation. They
suggested that extending the ULEZ to the area around the airport, including
preferably the M25 Motorway, will assist in improving air quality for residents.
21.2.27 Spelthorne Borough Council welcomed the use of independent Air Quality experts
and requested clarity on how the group will function, the level of transparency and
how outputs from the assessment will be shared with stakeholders.
21.2.28 They also made the following comments as summarised below.
1. The air quality assessment must model all main roads across the wider area
and local roads in the immediate vicinity of the scheme and must take account
of air quality monitoring data from the local authority networks across the
Heathrow area.
2. The highways and air quality assessments must consider the cumulative
impacts of expansion with existing consented major schemes, likely schemes
from the Local Plans and all displaced uses.
3. The effect of airborne aircraft emissions on local pollutant concentrations
should be demonstrated by mapping airport-related contributions to annual
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mean concentrations of pollutants, with a plan showing just the airborne aircraft
emissions contribution.
4. Targets or measures should be proposed to minimise air quality impacts
arising from the construction workforce.
21.2.29 Surrey County Council commented that Heathrow should commit to support
progressive reductions in air pollutants in areas that do not meet Air Quality
Objective thresholds. They further assert that the ‘Triple Lock Guarantee5’ must be
honoured.
Legislation and policy
21.2.30 The London Borough of Hammersmith and Fulham requested detailed information
on pollution sources at Heathrow and the mitigation measures detailed in the draft
Airports National Policy Statement (draft ANPS) as this information was not in the
consultation document.
21.2.31 They also commented that the ‘Triple Lock Guarantee’ on air quality made by
Heathrow is not consistent with the draft ANPS and cannot be regarded as long-
term commitments.
21.2.32 The London Borough of Harrow referred to the aspirations and targets set out by
the Mayor of London in the draft New London Plan and requested further detail on
how emissions would be mitigated and how Heathrow would contribute to the Air
Quality Positive policy.
Statutory Consultees
Surface access related emissions and management
21.2.33 Highways England commented that adverse change to noise and air quality from
any changes to the strategic road network must be fully considered and mitigated,
including in relation to compliance with the European air quality limit values and/or
in local authority designated Air Quality Management Areas (AQMAs).
Air quality assessment and monitoring
21.2.34 Natural England stated that the consultation documents did not include an
assessment of potential air quality impacts on European sites and advised that a
detailed assessment should be completed prior to submission of the Development
Consent Order (DCO) application.
5 Triple lock Guarantee as detailed on page 58 of the Airport Expansion Consultation Document
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Other Prescribed Bodies
General Comments
21.2.35 Bray Parish Council suggested the measures proposed to manage emissions
would only increase prices.
Surface access related emissions and management
21.2.36 Albury Parish Council suggested that the roads surrounding Heathrow cannot
cope with the existing volume of traffic contributing to poor air quality. They
considered that new rail links must be built before the new runway to ensure
impacts on the existing road system are minimised.
21.2.37 Horton Parish Council expressed concern that additional construction traffic
movements would add to the existing issues with air quality caused by traffic
congestion and commercial vehicles using the roads through the village. They
commented that existing air quality measures have not worked, and that further
erosion of land and green space will worsen air pollution in the area.
Air quality assessment and monitoring
21.2.38 Iver Parish Council stated that it was not possible to form a view on many of the
proposals without more information on the impact on air quality. They stated that
no baseline measurements had been undertaken in the area following existing air
quality breaches and noted that an AQMA has been declared within the Parish.
21.2.39 The Heathrow Strategic Planning Group noted that air quality demands a joint
approach by Heathrow and Local Authorities, including monitoring and
compliance. They welcomed Heathrow’s ambition to be a ‘flagship’ of sustainability
and suggested that the ‘Triple Lock Guarantee’ should be honoured by Heathrow
and intertwined into the DCO requirements. They also said that joint monitoring
and review processes are vital to the success of achieving a reduction in
emissions and Heathrow should provide funding for this.
Legislation and policy
21.2.40 Windlesham Parish Council recognised Heathrow’s commitment to improving air
pollution by adopting an incentive policy which will encourage airlines to upgrade
their fleet. They expressed disappointment that Heathrow considers surface traffic
to be the major cause of pollution and are concerned that measures to manage
emissions do not extend beyond a 2km radius of the airport.
Local Communities
Members of the public
General Comments
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21.3.1 Members of the public who commented on air quality and emissions made a range
of comments that comprised general statements of support for the approach along
with criticisms about the effects of the existing and proposed airport expansion and
the approach to managing effects. The main criticism received was that the
proposed measures were inadequate, insufficient or ineffective with concerns
about the lack of practical measures being applied to reduce the airport related
traffic movements for staff and service vehicles as well as airport users. Others
commented that the measures were unrealistic, lacked credibility and were
unsuitable with some respondents suggesting that emissions management will not
keep pace with longer term expansion.
21.3.2 Respondents highlighted that managing air quality is of the utmost importance and
that greener vehicles, such as electric cars, will have a positive effect in the future,
whilst others recommended a review of the achievements made by other cities
which prevent aircraft flying over communities. Other respondents indicated that
there wasn’t enough information or detail about proposed measures for them to
provide comment or feedback at this stage.
21.3.3 Positive comments were received from the public about the approach to managing
air quality and emissions and Heathrow’s ‘Triple Lock Guarantee’. These were
often general statements of support for the approach and were not qualified with
further information or detail. Comments were also received which expressed
support for the approach to managing air quality impacts and emissions subject to
certain conditions being met.
21.3.4 Consultation feedback highlighted the effects of extra vehicle traffic on the local
road network and congestion on air quality. The additional vehicular movements
associated with construction activities was also a concern. Respondents
suggested that measures to manage emissions would have negative
consequences on traffic congestion, business and the economy.
21.3.5 Concerns were also raised about the lack of detail and information on air quality
matters, the impact on people’s quality of life, health and well-being, the impacts of
air pollution, the effect on the environment and that the proposals fail to consider
pollution produced by aircraft and the danger of breaching EU limits.
21.3.6 Suggestions for plans to deal with air quality emissions were received, these
comprised:
1. reducing the number of flights in order to manage air pollution from aircraft
taking off and that aircraft should fly higher;
2. The proposals are based on old technology and should include measures that
ensure all airport related vehicles including cargo and maintenance are electric
and the banning of more polluting planes;
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3. Real-time public display of air quality data against targets with the
encouragement of less polluting commercial vehicles with a rebate system;
4. restricting or banning high polluting vehicles with cleaner less polluting vehicles
paying less for parking and road charges and having better access to the
Terminals;
5. using/incentivising cleaner aircraft and the incentivisation of low carbon flights;
and
6. enforcing a ban on aircraft of a certain age.
Businesses
General Comments
21.3.7 Annie’s Nest Nursery cited noise, pollution and the overall human cost of extra air
pollution in the area as the reasons they opposed the scheme.
21.3.8 Hatton Garden Trustees Limited and Pickering Properties Limited acknowledged
the requirement for Heathrow to provide a resilient and reliable road network in
order for it to deliver a reduction in emissions and limit fuel use.
21.3.9 Hatton Farm Estates Limited suggested that Heathrow should encourage the use
of electric vehicles by providing incentives.
Surface access related emissions and management
21.3.10 The Arora Group expressed concern about the air quality impacts of construction
as well as other scheme elements such as a realigned M25 and suggested that
legal challenges will emerge following the adoption of the Airports National Policy
Statement, which are likely to address air quality.
Air quality and carbon assessment and monitoring
21.3.11 The Airport Industrial Property Unit Trust (AIPUT) commented that Heathrow
should publish the results of their air quality assessments as well as the embodied
carbon and emissions impact.
21.3.12 The Arora Group said that it was unclear how the assessments for evaluation and
discontinuation of options had taken in to consideration issues such as air quality,
public transport considerations and the influence of other scheme elements. They
commented that discounting the Family C Runway options (as detailed in the
Scheme Development Report) based on air quality impacts does not appear to sit
properly within the unworkable evaluation prescribed to it.
21.3.13 The Emerson Group on behalf of Orbit Developments (Southern) Limited stated
that the approach set out in the consultation documentation is inadequate and
lacks information on mitigation measures. They also suggested that if Heathrow is
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in breach of air quality requirements it weakens the case for the use of compulsory
purchase powers.
21.3.14 The Fuel Trading Company suggested that the measures proposed to combat the
issue of emissions were very vague. They suggested that mandating all
contractors to use renewable diesel would improve both the air quality and
greenhouse gas emissions/carbon intensity when building the runway.
21.3.15 Segro asked for confirmation as to whether the ‘Triple Lock Guarantee’ includes
freight and cargo traffic or is limited to light duty vehicles. They considered that
any air quality measures taken around the airport that may apply to freight or other
air related businesses in the future must be consistent with the ULEZ in London
and the government’s Clean Air Strategy to avoid fragmentation of vehicle
standards. They also expressed a desire to participate in the Sustainable Freight
Group.
21.3.16 The Thames Valley Chambers of Commerce asked that mitigation be introduced
as early as possible, before the runway is completed.
21.3.17 The London (Heathrow) Airline Consultative Committee and the Board of Airline
Representatives UK commented that the airline community has an important role
and any air quality and emissions measures must be developed in full consultation
and agreement with them. Non-airport related emissions should be distinguished
clearly from airport-related emissions and the focus for Heathrow and the airline
community should be on collective working to address the latter.
21.3.18 They indicated that the Airline Community will support cost-effective and
operationally viable initiatives to help reduce emissions including supporting a
broad choice of sustainable transport modes for passengers, cargo and
employees. They agreed with the conclusion that NOx emissions are a
consequence of urban development and non-airport traffic but suggested that
punitive emission charges should not be introduced unless affordable and
sustainable alternative means to access the airport are implemented.
Community Groups
General Comments
21.3.19 The Camberley Society highlighted the need to look at the existing Heathrow
Airport first, in respect of air quality issues, and queried whether Heathrow is
looking at best practice examples from around the world.
21.3.20 Colnbrook Community Association considered the plans to reduce emissions are
inadequate and fail on all grounds according to the recent report produced by the
New Economics Foundation which uses DfT modelling.
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21.3.21 Slough and District Against Runway 3 commented that Heathrow cannot meet
World Health Organisation air and noise pollution limits today and has no credible
or acceptable plan to do so.
21.3.22 West Windsor Residents Association stated they have no confidence in
Heathrow’s claims that air pollution can be adequately addressed. They suggested
it has been promised many times previously and air pollution remains at an
unacceptable and in places dangerous level.
Surface access related emissions and management
21.3.23 The Camberley Society suggested that better transport links are required to
reduce traffic emissions.
21.3.24 The Colnbrook Community Partnership suggested consideration be given to how
unauthorised car park and caravan sites for construction workers will be managed
as these could lead to adverse air quality impacts on residential areas.
21.3.25 The Fulham Society commented that air quality problems extend to areas further
from Heathrow airport. Limiting car parking spaces and the provision of a new rail
link from Waterloo are therefore important measures.
21.3.26 The Heathrow Association for the Control of Aircraft Noise expressed concern
that the amount of traffic on the roads will have a knock-on effect on the ability
to control air quality levels. They considered improvements to air quality will
largely depend on government action to tackle vehicle emissions and investment
in rail schemes.
21.3.27 Local Conversation in Stanwell commented that Heathrow’s commitment to not
increase the amount of airport-related vehicle traffic on the road and increase the
numbers of people using public transport would not be enough to improve air
quality in Stanwell and Stanwell Moor.
21.3.28 Northumberland Walk Residents Association commented that current traffic
volumes, especially HGVs, already have a significant and negative impact on their
community from noise, air pollution and poor road safety.
21.3.29 St Albans Quieter Skies commented that in the long term, increased flights from
Heathrow will lead to a lot more traffic on the M25 (and M4) increasing congestion
and air pollution near Heathrow and up to and near St Albans.
21.3.30 Wentworth Residents’ Association said that building more car parks, hotels and
other sites around the airport contradicted Heathrow’s intention of dealing properly
with air quality issues.
Air quality assessment and monitoring
21.3.31 Aircraft Noise Three Villages stated that Heathrow already breaches legal air
pollution limits and does not have a tenable plan to meet legal air pollution limits
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even without a third runway. They considered that Heathrow are misleading
consultees by suggesting that ground based sources are the main contributor to
harmful emissions when planes emit large amounts of NOx and have vastly higher
emissions than suggested.
21.3.32 The Colnbrook Community Partnership expressed support for the ‘Triple Lock
Guarantee’, the establishment of an independent regulator and the use of
construction logistic hubs to reduce emissions.
21.3.33 They raised concerns about air quality impacts on Elbow Meadow properties due
to the proximity of the potential Area 2 taxiways and queried whether air quality
had been considered when selecting the options for the A3044, the M25, or Option
6C for the A4 (as detailed on pages 23, 27 and 28 of the Airport Expansion
Consultation Document).
21.3.34 Ealing Fields Residents Association commented that the Project will mean more
emissions on top of the existing situation.
21.3.35 Egham Residents’ Association suggested the ‘Triple Lock Guarantee’ is a work of
fiction and that any binding commitments can be undone by blaming the increases
on the M25 or the M4. They also raised concerns about Britain exiting the EU for
air quality regulations. A similar view was shared by Harrow U3A Sustainability
group who commented that “Brexit” may affect regulations.
21.3.36 The Residents association HVG CA highlighted the need for an accurate
measurement of air quality and emissions and compliance with EU standards.
21.3.37 The Richmond Heathrow Campaign stated that air pollution is damaging to health
and quality of life for over 100,000 people. They suggested that the release of
runway capacity should be linked to air quality tests based on predicted outcomes
and not be based on value limit compliance but also a reduction in pollution.
21.3.38 Stanwell’s Green Lungs and Teddington Action Group commented that
Heathrow’s commitment to deliver expansion while meeting all relevant legal air
quality obligations is profoundly misleading and no evidence has been given for
the assertion.
Legislation and policy
21.3.39 Eastcote Conservation Panel commented that one of the most contentious areas
in the plans for the Project was air quality. They stated that no evidence had been
provided to show that there will be measures in place to ensure that illegal levels
of pollution are reduced and that air quality regulations will be met and maintained.
21.3.40 Eastcote Residents’ Association said they find it hard to see how air quality will be
able to be kept within legal requirements with a new third runway. They stated that
if levels cannot be managed to fulfil this requirement the area will be left with an
unused runway and redundant supporting infrastructure.
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21.3.41 SCR Residents for a fair consideration of Heathrow Expansion commented that
they assume Heathrow will comply with current legislation regarding air quality and
emissions thresholds.
Wider/other consultees
General Comments
21.4.1 The Chiltern Society asked whether Heathrow would be interested in exploring
environmental offsetting in the Chilterns, possibly in the form of improved habitat
management. They considered that this could provide some habitat enhancement
in a nationally important landscape to compensate for any habitat or species loss
that may arise through the works to expand the airport.
21.4.2 West London Friends of The Earth considered Heathrow’s claim that expansion
can be delivered while meeting all relevant legal air quality obligations to be
misleading. The Local Authorities’ Aircraft Noise Council expressed a similar view
commenting that the Project will directly and indirectly cause unlawful levels of air
pollution which damages health.
21.4.3 The Herts and Middlesex Wildlife Trust commented that the proposals send the
wrong message both nationally and internationally as we should be striving to
reduce our carbon emissions.
21.4.4 Kingston Environment Forum suggested that the plans are inadequate and rely too
much on people using clean transport options with massive behaviour and
technological changes that are unlikely to happen soon enough.
21.4.5 The Mayor of London stated that effects on climate change must be minimised
and that Heathrow must contribute to the ambition for London to be a zero-carbon
city by 2050.
Surface access related emissions and management
21.4.6 The Colne Valley Regional Park stated that Heathrow already contributes
significantly to air pollution in the area and post-expansion effects will be more
keenly felt, especially by those using the Colne Valley Regional Park. They
requested an evidence-based approach to looking at how noise and air quality,
including aerial pollutants, will be managed and suggested that opportunities to
extend the ULEZ to keep the effects of freight traffic under control should be
implemented.
21.4.7 Crossrail to Ebbsfleet commented that they are a vital part of reducing the
current volumes of traffic between Kent and Heathrow and the subsequent effects
on air pollution.
21.4.8 London Cycling Campaign stated that the Project must not lead to an increase in
climate-changing emissions or any increase in motor vehicle volumes (and
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resulting pollution and emissions). They considered that enabling people to use
modes other than the private motor vehicle is vital.
21.4.9 Dominic Raab MP expressed concern that the increase in road traffic caused by a
growth in the number of passengers travelling to and from the airport risks a
negative impact on local air pollution. He also suggested that the Environment
Agency or another body should be mandated to monitor the full environmental
impact of the airport, not just from extra flights but from additional congestion.
21.4.10 Elmbridge Friends of the Earth expressed opposition to the Project and raised
concerns about a lack of clarity on how there will be no increase in road usage and
why there is no consideration of inflight emissions from aircraft.
21.4.11 The Liberal Democrats expressed concerns around air quality and commented
that they would like to see firmer commitments from Heathrow on its plans to
contribute to the cost of the Western Rail Link and the Heathrow Southern Railway
to achieve modal change.
21.4.12 The London Wildlife Trust stated that Heathrow must address the risk of
increasingly poor air quality but considered that discouraging individuals from
travelling by car is an inadequate response to address this. They stated that
Heathrow already contributes significantly to air pollution in the area and that
impact will be even greater post-expansion. They proposed that an evidence-
based approach to the management of air quality during construction be
undertaken and that opportunities to extend the Mayor of London’s ULEZ should
be investigated.
21.4.13 The Royal Parks expressed support for measures that improve air quality in and
around the airport but raised concern about the likely increase in pollution from
increased air and vehicle traffic on the main trunk roads. They also expressed
concern about the implications this could have on sensitive and protected
grassland habitats, specifically Richmond Park, Bushy Park Site of Special
Scientific Interest, Kensington Gardens, Primrose Hill, Regents Park and
Greenwich Park.
Air quality assessment and monitoring
21.4.14 The Chartered Institute of Logistics and Transport raised concerns over who would
be held to account if air quality limits are breached. They proposed that a limit on
passenger numbers be applied until any breaches related to the airport cease.
21.4.15 The Church of England Diocese of London, Oxford and Southwark expressed a
similar view raising concerns with the commitments not to release capacity unless
compliance on air quality is assured. They indicated that Heathrow has been
working to address the air quality impacts for more than 15 years but the problem
remains. They highlighted that there is a much stronger focus on reducing
Nitrogen Dioxide, than on particulates.
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21.4.16 Dominic Raab MP stated that there should be legally binding limits on air quality
and compliance should be independently monitored. He commented that a
concern of his constituents is that the Project should not lead to any deterioration
of air quality as a result of the additional flights or additional vehicles that may use
the roads. He also said the Civil Aviation Authority had provided assurances that
an increase in flights would have no direct impact on air quality in Elmbridge.
21.4.17 England’s Economic Heartland expressed support for the ‘Triple Lock Guarantee’
which they consider will ensure that new capacity at an expanded Heathrow will
only be released in compliance with air quality requirements.
21.4.18 Friends of the River Crane commented that air quality is similar to noise in respect
of its widespread impact on public open spaces and the relatively limited means
available to mitigate it. They suggested that green infrastructure has capacity to
absorb poor air quality and that the impact of air quality upon the value and
diversity of the open spaces within the Heathrow envelope should be addressed
as part of the overall project alongside the impact of air quality on people using
open spaces.
21.4.19 Lambeth/Herne Hill Green Party referred Heathrow to the London Assembly's
consultation on changes to the ULEZ. They identified that there are environmental
organisations with expertise to reduce or mitigate the potential local air quality
effects that may arise due to the Project.
21.4.20 London First commented that Heathrow should think holistically about how it can
unilaterally and bilaterally reduce emissions from all sources, tackling the greatest
sources of emissions first.
21.4.21 London Parks and Garden’s Trust welcomed the 'Triple Lock Guarantee’ but urged
greater consideration to be given to horticulture as a means of carbon
sequestration and other air pollutant capture.
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Issues Raised and Heathrow’s Responses
Tables 21.1A and 21.1B present a summary of the main issues raised by prescribed consultees, local communities and
wider/other consultees in relation to Air Quality and Emissions.
Table 21.1A presents a summary of Heathrow’s responses to those issues which are directly related to the proposals on which
we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019), and how in preparing
those proposals we have had regard to the relevant Airport Expansion Consultation One feedback.
Table 21.1B provides a summary of the way in which we are seeking to consider the issues raised in relation to any other
aspects of the Project not included in the Airspace and Future Operations Consultation. These interim responses are provided
for information only, and so no further feedback is being sought on the basis that a full consultation feedback report will be
published as part of the Airport Expansion Consultation in June 2019.
Table 21.1A
Issue Consultee6 Heathrow Response
PC MC WC
A review should take place of the
achievements made by other cities which
prevent aircraft flying over communities.
✓ Heathrow are working with a range of specialists in airspace and airport
design who are aware of projects and practices undertaken elsewhere.
The Airspace and Future Operations Consultation (January 2019) presents geographical areas within which flight paths could be positioned. The consultation seeks feedback on what local factors should be taken into
6 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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account when developing new flightpaths within these geographical defined areas known as design envelopes.
Table 21.1B
Issue Consultee7 Heathrow Response
PC MC WC
The best approach is to not expand Heathrow
and address the current adverse impacts of
the airport on air quality.
✓ The Government has designated the Airports National Policy Statement (ANPS), which sets out the need for additional airport capacity in the south-east of England and confirms that the Government believes that this need is best met by a north-west runway at Heathrow Airport. The ANPS sets out specific requirements that Heathrow as the applicant for a new north-west runway will need to meet to gain development consent. “The Secretary of State will use the Airports NPS as the primary basis for making decisions on any development consent application for a new Northwest Runway at Heathrow Airport, which is the Government’s preferred scheme” (paragraph 1.15). The ANPS is informed by an Appraisal of Sustainability, which describes the analysis of reasonable alternatives to the preferred scheme. The Appraisal of Sustainability informs the development of the ANPS by assessing the potential economic, social and environmental impacts of options to increase airport capacity. The ANPS states at paragraph 1.29 that “the overall conclusions of the Appraisal of Sustainability show that (provided any scheme remains within the parameters and boundaries in this policy), whilst
The number of flights should be reduced in
order to manage air pollution.
✓
7 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Issue Consultee7 Heathrow Response
PC MC WC
there will be inevitable harm caused by a new Northwest Runway at Heathrow Airport in relation to some topics, the need for such a scheme, the obligation to mitigate such harm as far as possible, and the benefits that such a scheme will deliver, outweigh such harm. However, this is subject to the assessment of the effects of the preferred scheme, identification of suitable mitigation, and measures to secure and deliver the relevant mitigation.”
One of the most contentious areas in the
plans for expansion is air quality.
✓ Heathrow recognise that the potential air quality effects of the Heathrow
Expansion Project (the Project) are a concern to communities around
Heathrow and other interested stakeholders. We are committed to any
potential significant adverse air quality effects of the Project and will publish
the initial assessment findings within the Preliminary Environmental
Information Report (PEIR), as part of the Airport Expansion Consultation in
June 2019.
Heathrow should be looking at best practice
examples from around the world.
✓
Heathrow are working with a range of specialists in airspace and airport
design who are aware of projects and practices undertaken elsewhere.
To reduce emissions aircraft should fly
higher.
✓ The modernisation of UK airspace, which is being developed in parallel to
plans for the Project, provides opportunities for changing the ways in which
aircraft currently fly. Additionally, as newer technologies become available,
operating practices are also likely to change. As such, our environmental
assessments will consider the impacts of measures such as steeper descent
approaches and departures, which would result in aircraft flying higher for
longer as well as changes in aircraft flight paths.
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Issue Consultee7 Heathrow Response
PC MC WC
There is no attempt to bring NOx emissions at
altitude within scope.
✓ Heathrow submitted an Environmental Impact Assessment (EIA) Scoping
Report to the Planning Inspectorate (PINS) on 21st May 2018. We
subsequently received a Scoping Opinion from PINS, on behalf of the
Secretary of State, on 2nd July 2018. The Scoping Opinion sets out PINS
opinion on the scope, level of detail and information to be provided in the
Environmental Statement (ES). The Infrastructure Planning (EIA) Regulations
2017 (the EIA Regulations) require Heathrow to submit an ES which is in
based on the most recent scoping opinion adopted.
Air quality effects are assessed at a local level, based on potential changes in
pollutant concentrations at locations where people might be exposed, for
example at residential properties. It is for this reason that the air quality
assessment will not assess pollutant emissions from aircraft above the
landing and take-off cycle (3000ft). Due to the dispersion of these emissions
at height, they have a negligible effect on pollutant concentrations at ground
level. This approach is based on the International Civil Aviation Organization
(ICAO) air quality guidance.
Concerns why there is no consideration of
inflight emissions from aircraft.
✓ Heathrow submitted an EIA Scoping Report to the Planning Inspectorate
(PINS) on 21st May 2018. We subsequently received a Scoping Opinion from
PINS, on behalf of the Secretary of State, on 2nd July 2018. The Scoping
Opinion sets out PINS opinion on the scope, level of detail and information to
be provided in the ES. The EIA Regulations require Heathrow to submit an
ES which is in based on the most recent scoping opinion adopted.
Air quality effects are assessed at a local level, based on potential changes in
pollutant concentrations at locations where people might be exposed, for
example at residential properties. It is for this reason that the air quality
assessment will not assess pollutant emissions from aircraft above the
landing and take-off cycle (3000ft). Due to the dispersion of these emissions
at height, they have a negligible effect on pollutant concentrations at ground
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Issue Consultee7 Heathrow Response
PC MC WC
Concerns about the impacts of air pollution,
the effect on the environment and that the
proposals fail to consider pollution produced
by aircraft and the danger of breaching EU
limits.
✓ level. This approach is based on the ICAO air quality guidance.
Concern expressed that increased traffic and
aircraft movements will worsen air quality.
This is damaging to the health, quality of life
and wellbeing for people across the local area
and Greater London.
✓ ✓ Heathrow recognise that the potential impacts of the Project on local air
quality and how these could potentially affect public health is a concern to
local communities. Heathrow will undertake both a detailed air quality
assessment and an assessment of impacts on human health as a result of
the Project. These will be presented as part of the ES. A standalone Health
Impact Assessment report will also be appended to the ES submitted with the
Development Consent Order (DCO) application. This will include mitigation
proposals where potential significant effects are identified. Chapter 12 of the
EIA Scoping Report sets out the approach to the assessment of impacts on
human health.
Expansion will directly and indirectly cause
unlawful levels of air pollution which
damages health.
✓
Heathrow must work with stakeholders to
increase understanding of key matters such
as how it affects the health and quality of life
of local communities.
✓
Heathrow already contributes significantly to
air pollution in the area and the expansion will
exacerbate this. This will particularly affect
those using the Colne Valley Regional Park.
✓ Recreational routes, spaces and facilities within the Colne Valley Regional
Park are being considered as part of the recreation and amenity impact
assessment which will form part of the community chapter of the ES, to be
submitted with the DCO application. It will identify recreation and amenity
effects resulting from the construction and operation of the Project.
Information on the mitigation strategies to address any likely significant
effects will also be identified.
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Issue Consultee7 Heathrow Response
PC MC WC
Concern about the implications impacts on
air quality and increased emissions could
have on sensitive and protected grassland
habitats, specifically Richmond Park, Bushy
Park SSSI, Kensington Gardens, Primrose
Hill, Regents Park and Greenwich Park.
✓ The impacts of potential changes in air quality on biodiversity designations
(including European site designations and Sites of Special Scientific Interest
(SSSIs)) will be assessed in detail as part of the EIA. Early findings and initial
information on any proposed mitigation measures will be reported in the PEIR
to be published as part of the Airport Expansion Consultation in June 2019.
The consultation documents did not include
an assessment of potential air quality impacts
on European sites, a detailed assessment
should be completed prior to submission of
the DCO application.
✓
Concerns about air quality impacts on Elbow
Meadow properties due to the proximity of the
Area 2 taxiways.
✓ The likely air quality effects on receptors in Elbow Meadow and other
communities will be assessed during the EIA, with initial findings reported in
the PEIR to be published as part of the Airport Expansion Consultation in
June 2019.
The positioning of aircraft taxiways and other elements of infrastructure will
seek to reduce air quality impacts by facilitating efficient aircraft movements
on the ground and maximising separation between emission sources and
receptors as far as reasonably practicable. A detailed evaluation considering
a range of criterion (as detailed in the Scheme Development Report) is being
undertaken to identify the preferred location and options for new taxiways,
taking into account the consultation responses. The findings of this
evaluation will be presented in the Updated Scheme Development Report
that will be published to accompany the Airport Expansion Consultation in
June 2019.
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Issue Consultee7 Heathrow Response
PC MC WC
The release of runway capacity should be
linked to air quality tests. This should be
based on a reduction in pollution and not on
value limit compliance.
✓ The ANPS sets out the tests that Heathrow must meet in order to be granted
a DCO for the Project. This includes a requirement to demonstrate that the
Project would be compliant with legal obligations that provide for the
protection of human health and the environment.
Heathrow has also made a commitment that in addition to continuing to play
its part in improving air quality and ensuring further measures are ready to be
introduced if required to reduce traffic. Extra capacity at an expanded
Heathrow will only be released when it is clear that the airport’s contribution
will not delay compliance with EU air quality obligations.
Concerns about the lack of detail and
information.
✓ The information provided in Airport Expansion Consultation One reflected the
fact that the Project was at an early design stage. Further information
regarding air quality and emissions, including early findings from our EIA
work assessing potential effects upon local communities and developing
proposed mitigation measures, will be provided within the PEIR. This will be
published as part of the Airport Expansion Consultation in June 2019.
It was not possible to form a view on many of
the proposals without more information on
the impact on air quality.
✓
Lack of information of in the consultation
documents regarding pollutions sources,
health impacts and mitigation measures
including those detailed in the draft ANPS.
✓
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Issue Consultee7 Heathrow Response
PC MC WC
Discounting the Family C Runway options
based on air quality impacts does not appear
to sit properly within the unworkable
evaluation prescribed to it.
✓ The Scheme Development Report published at Airport Expansion
Consultation One presented the findings of the evaluation process to date.
The Family C options were considered likely to result in adverse ground
noise, air quality and amenity impacts at a larger number of properties than
the alternatives, given proximity of the runway end to Harlington. The Family
C options would also result in additional property loss and community
displacement in Sipson when compared to Family A and as a result were
discounted.
Concern that the proposed measures lack
credibility and are unrealistic, inadequate or
insufficient.
✓
The information provided in Airport Expansion Consultation One reflected the
fact that the Project was at an early design stage. We remain confident in the
ability of our proposals to deliver sustainable growth and demonstrate that
construction and operation of the Project will not affect the UK’s ability to
comply with legal obligations. Further information regarding the potential
effects of emissions associated with the Project, including early findings from
the EIA, will be contained within the PEIR which will be published as part of
the Airport Expansion Consultation in June 2019.
Heathrow has not demonstrated how it can
effectively deliver its proposed scheme,
including its 2030 public transport modal
share target, without adversely affecting air
quality.
✓ The air quality assessments previously undertaken by the Airports
Commission, Heathrow and Government have consistently demonstrated that
the Project can be delivered in compliance with legal air quality obligations
and without causing exceedances of the National Air Quality Objectives.
The ANPS puts in place a planning framework for a new runway in the South
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Issue Consultee7 Heathrow Response
PC MC WC
No evidence had been provided to show that
there will be measures in place to ensure that
illegal levels of pollution are reduced and that
air quality regulations will be met and
maintained.
✓ of England. In doing so, it defines requirements for Heathrow’s environmental
assessment. In the context of air quality, this includes demonstrating that
construction and operation of the Northwest Runway will not affect the UK’s
ability to comply with legal obligations that provide for the protection of human
health and the environment.
The ES submitted alongside the DCO will report the likely significant effects
of the Project. This will include consideration of EU Limit Values and Local Air
Quality Objectives for NO2 and particulates. Heathrow will therefore provide
further evidence that the Project can be delivered in compliance with legal air
quality obligations. In advance of the ES being submitted, the initial findings
from our assessments will be provided within the PEIR, which forms part of
the Airport Expansion Consultation in June 2019.
Concerns about confidence levels in
Heathrow’s claims that air pollution can be
adequately addressed.
✓
Concern that if expansion goes ahead there
will be a huge increase in emissions from
aircraft and vehicle movements.
✓ ✓
The expansion of Heathrow should not lead to
any deterioration of air quality as a result of
the extra flights or the extra vehicles that may
use the roads.
✓
The Secretary of State will need to be
satisfied that the scheme would be compliant
with legal requirements on air quality impacts
in the wider area.
✓
Opposition to an expanded Heathrow as
increases in passengers, freight and staff is
likely to make air quality over legal limits in
the local area, Greater London and the south-
east.
✓
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Issue Consultee7 Heathrow Response
PC MC WC
Concern that air quality assessments show
that an expanded Heathrow would contribute
to breaching Nitrogen Dioxide air quality
limits.
✓
Heathrow’s commitment to deliver expansion
while meeting all relevant legal air quality
obligations is profoundly misleading and no
evidence has been given for the assertion.
✓ ✓ ✓
Heathrow will have to comply with current
legislation regarding air quality and
emissions thresholds.
✓
The latest government air quality
assessments show that expansion will make
the London Zone non-compliant in 2026/28.
✓
Heathrow already contributes significantly to
air pollution in the area and that impact will
be even greater post-expansion.
✓ We have been working to address emissions from Heathrow for more than 15
years and we, alongside our partners, have a strong track-record of reducing
emissions from airport operations. For example, our 2013 Emissions
Inventory showed that the implementation of the Air Quality Action Plan led to
a 430 tonne (16%) reduction in total emissions of NOX from ground-based
sources since the last full inventory for the period 2008/9. This action has
contributed to concentrations of NO2 at Heathrow falling by over 20% in the
past 20 years.
We have carried out continuous air quality monitoring at locations on and
around Heathrow since 1993, in addition to the monitoring conducted by the
local authorities. This network of monitoring illustrates that within 2km of
Heathrow has been working to address the air
quality impacts for more than 15 years but the
problem remains.
✓ ✓
It has been promised many times previously
and air pollution remains at an unacceptable
and in places dangerous level.
✓
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Heathrow already breaches legal air pollution
limits and does not have a tenable plan to
meet legal air pollution limits even without a
third runway.
✓ Heathrow, only two air quality monitoring sites have historically recorded
annual mean NO2 concentrations exceeding the Air Quality Objectives (AQO)
– these are located next to the M4 motorway. Real time air quality monitoring
data and details of monitoring sites are available from Heathrow Airwatch
(http://www.heathrowairwatch.org.uk/latest).
We will continue to work in partnership with local authorities and Government
to play our part in improving local air quality.
Concern that more flights will mean more
emissions, air quality levels are already poor
and breach EU limits.
✓
Heathrow should focus on low emissions. ✓ We agree that Heathrow should focus on low emissions and are developing
measures that will encourage the uptake of low emission technologies, be
that in relation to aircraft operations and ground support equipment on the
airfield, or trips made to and from the airport by passengers and colleagues.
Further details of these measures will be provided in the PEIR, which forms
part of the Airport Expansion Consultation in June 2019.
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Heathrow are misleading consultees by
suggesting that ground based sources are
the main contributor to harmful emissions
when planes emit large amounts of NOx and
have vastly higher emissions than suggested.
✓ Our dispersion modelling studies enable us to specifically assess the impact
of aircraft emissions and other sources on pollutant concentrations at relevant
locations (i.e. those where people might be exposed). Our work, and other
work from around the world, shows that although aircraft are a significant
source of total NOX emissions at Heathrow, because emissions from aircraft
in flight are elevated, the effect at ground-level is limited. Road traffic-related
NOx emissions are the most important source in terms of local air quality. It is
customary for studies on air quality around airports to include the whole
aircraft landing and take-off (LTO) cycle, including operations on the ground
and in the air up to 3,000 feet (~1,000 metres (m)) above ground level.
However, it is generally understood that emissions from aircraft become
negligible, in terms of their effect on ground-level air quality, once aircraft are
more than approximately 100-200m above the ground on departure, and
when greater than approximately 50-100m on arrival. Aircraft are much
higher than this when they are on the flight path, therefore, the effect of
emissions from these aircraft in the sky on ground level pollutant
concentrations at receptors beyond the airport boundary is negligible.
Concerns that if levels cannot be managed to
stay within legal requirements the area will be
left with an unused runway and redundant
supporting infrastructure.
✓ We stand by our ‘triple lock’ commitment and specifically the guarantee that
new capacity at an expanded airport will only be released when it is clear that
the airport’s direct contribution to air quality will not delay or cause non-
compliance with the UK’s legal air quality obligations. It has repeatedly been
demonstrated through previous assessment undertaken by the Airports
Commission, Heathrow and Government that the Project can be delivered
without delaying compliance. We will provide further evidence through the
EIA process, the initial findings of which will be reported in the PEIR which
forms part of the Airport Expansion Consultation in June 2019.
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Concern that building more car parks, hotels
and other sites around the airport
contradicted Heathrow’s intention of dealing
properly with air quality issues.
✓ An expanded Heathrow will need to be supported by appropriate Airport
Related Development (ARD), which includes hotel development where
demand is generated by the growth in passenger numbers and the
displacement of existing hotels to facilitate construction of the Project.
Proposals for ARD and airport supporting facilities such as car parks are not
considered to conflict with Heathrow’s goal of improving local air quality. The
Project provides an opportunity to consolidate existing facilities, which over
time have grown organically around Heathrow, and facilitate more holistic and
efficient land use. This includes, for example, locating hotel facilities near
public transport links, or consolidating car parking capacity close to the
motorway network to reduce traffic movements otherwise circulating on the
local road network. Potential air quality impacts have been considered
throughout the design development process and will continue to inform our
choices as we finalise a preferred masterplan. This will be published in June
2019 during our Airport Expansion Consultation.
Hopes for a much stronger focus on reducing
NO2, than on particulates.
✓ Heathrow’s focus is on managing all relevant emissions associated with the
airport and the Project, where they have potential to result in adverse
environmental effects, including NO2, particulates and carbon. Emissions of
these pollutants and associated effects will be assessed as part of the EIA,
the initial findings of which will be reported within the PEIR as part of the
Airport Expansion Consultation in June 2019.
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The expansion of Heathrow Airport must not
lead to an increase in climate-changing
emissions or any increase in motor vehicle
volumes (and resulting pollution and
emissions).
✓ The ANPS sets out the planning framework for a new runway in the South of
England. In doing so, it defines requirements for Heathrow’s environmental
assessment. In the context of carbon, this includes demonstrating that the
increase in carbon emissions resulting from the project would not have a
material impact on the ability of Government to meet its carbon reduction
targets, including carbon budgets.
The ANPS does not require Heathrow to demonstrate that there will be no
increase in motor vehicle volumes due to the Project. It does however require
that the DCO application include details of how Heathrow will increase the
proportion of journeys made to the airport by public transport, cycling and
walking to achieve a public transport mode share of at least 50% by 2030 and
at least 55% by 2040 for passengers. The application will also detail how a
25% and 50% reduction in all colleague car trips will be achieved by 2030
and 2040 respectively.
Heathrow will also continue to strive to meet its pledge to have landside
airport-related traffic no greater than today.
Heathrow should commit to support
progressive reductions in air pollutants in
areas that do not meet Air Quality Objective
thresholds.
✓ We have carried out continuous air quality monitoring at locations on and
around Heathrow since 1993, in addition to the monitoring conducted by the
local authorities. This network of monitoring illustrates that within 2km of
Heathrow, only two air quality monitoring sites have historically recorded
annual mean NO2 concentrations exceeding the AQO – these are located
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Heathrow’s proposals should not increase
emissions from the current levels, suggesting
that tapered reduction targets should be set.
✓ next to the M4 motorway. Real time air quality monitoring data and details of
monitoring sites are available from Heathrow Airwatch
(http://www.heathrowairwatch.org.uk/latest).
As older vehicles with higher emissions are replaced by newer ones that
meet progressively tighter EU emission standards, air quality is predicted to
improve, such that those locations within London and the south east which
currently exceed the EU Limit Value/AQO are projected to be compliant by
the mid to late 2020s8. To accelerate this process, Heathrow is exploring the
potential for strategically managed access charges, low emission zones, and
parking charges at Heathrow to further encourage the use of low emissions
vehicles, reduce unnecessary highway travel, and generate revenue to invest
in public transport.
Despite the application of appropriate mitigation measures, the Project could
potentially result in increases in pollutant concentrations in distinct locations,
due to, for example, redistribution of traffic or amendments to the road
network. Heathrow is committed to managing the potential air quality impacts
of the Project and playing our part in meeting the Government’s national
AQOs and achieving compliance with European air quality limits. The initial
findings of the EIA, including air quality projections and proposed mitigation
measures, will be reported within the PEIR which forms part of the Airport
Expansion Consultation in June 2019.
8 Air quality plan for nitrogen dioxide (NO2) in UK (2017), Department for Environment, Food and Rural Affairs and Department for Transport
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Details required on how Heathrow would
contribute to the Air Quality Positive policy.
✓ Policy SI1 of the Draft New London Plan states that “the development of
large-scale redevelopment areas, such as Opportunity Areas and those
subject to an EIA should propose methods of achieving an Air Quality
Positive approach through the new development”. In line with this draft policy
and its existing commitments, Heathrow will implement measures to actively
reduce air pollution, which may include provision of low or zero-emission
heating and energy, improvements to public transport, walking and cycling
infrastructure, and designing out features that prevent effective dispersion of
pollutants.
Concerns with the commitments not to
release capacity unless compliance on air
quality is assured.
✓ As required by the ANPS, Heathrow must demonstrate (via the ES), that with
mitigation, the scheme would be compliant with legal obligations that provide
for the protection of human health and the environment.
Heathrow should think holistically about how
it can unilaterally and bilaterally reduce
emissions from all sources, tackling the
greatest sources of emissions first.
✓ Heathrow agree that a holistic approach is appropriate when developing
measures to manage the potential emissions associated with the airport, and
that these measures will require both direct action by Heathrow and
partnership with the relevant stakeholders. Further details on the measures
proposed to manage the effects of the Project will be contained within the
PEIR, which forms part of the Airport Expansion Consultation in June 2019.
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Requested the health impacts and air quality
assessment methodologies and reports are
provided at the earliest opportunity.
✓ Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018,
which described the proposed assessment methodologies for all aspects to
be considered during the EIA, including health and air quality. We
subsequently received a Scoping Opinion from PINS, on behalf of the
Secretary of State, on 2nd July 2018. The Scoping Opinion sets out PINS
opinion on the scope, level of detail and information to be provided in the ES.
Further information on the assessment methodologies will also be published
within the PEIR which forms part of the Airport Expansion Consultation in
June 2019.
The ‘Triple Lock’ guarantee is a work of
fiction, any binding commitments can be
undone by blaming the increases on the M25
or the M4.
✓ We remain confident in the ability of our proposals to expand Heathrow to
deliver sustainable growth and with respect to air quality, we stand by our
‘triple lock’ guarantee. The three elements of the triple lock are:
1. meeting our existing commitment to improving air quality by not increasing the amount of landside airport-related vehicle traffic (including freight and cargo traffic) on the road by supporting improved surface access and by encouraging and incentivising the use of new technology and cleaner vehicles;
2. ensuring further measures are ready to be introduced if required to reduce traffic: Heathrow has identified a number of options available to improve air quality that can be implemented if needed as part of our expansion plans to reduce road journeys (e.g. the introduction of a road user charge or emission-based access charge); and;
3. binding our commitment by guaranteeing that new capacity at an expanded airport will only be released when it is clear that the airport’s direct contribution to air quality will not delay or cause non-
The ‘triple lock guarantee’ must be honoured
by Heathrow and intertwined into the DCO
requirements.
✓ ✓
Confirmation as to whether the ‘Triple Lock’
guarantee includes freight and cargo traffic or
is limited to light duty vehicles is needed.
✓
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The triple lock guarantee on air quality made
by Heathrow is not consistent with the draft
ANPS and cannot be regarded as a long-term
commitment.
✓ compliance with the UK’s legal air quality obligations.
This commitment is consistent with the ANPS, which requires Heathrow to
demonstrate that construction and operation of the Project will not affect the
UK’s ability to comply with legal obligations that provide for the protection of
human health and the environment.
Concerns over who would be held to account
if air quality limits are breached.
✓ The EIA Regulations require decision-makers of DCO applications (i.e. in the
case of transport DCOs, the Secretary of State for Transport) to consider
whether it is appropriate to impose monitoring measures of any likely
significant adverse effects identified through the EIA process. This includes
consideration of potential remedial action.
This provides additional assurance that consideration of the effects of
expansion and appropriate mitigation will continue into the construction and
operational phases of the project, informed by an appropriate monitoring
regime.
We also continue to think that there is the potential for an independent
regulator to provide scrutiny and further confidence in our air quality plans.
We are ready to work with government should they move to create such a
role.
Concern about how plans will be impacted by
Britain exiting the EU for air quality
regulations.
✓ The Government has confirmed that it intends to uphold its obligations under
international environmental treaties. Regarding air quality regulations, the
Government has stated that the Ambient Air Quality Directive (including its
limit values and target values) was transposed into law in England through
the Air Quality Standards Regulation 2010, and that it has no plans to change
the limit values and target values in the regulations.
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Legal challenges will emerge following the
adoption of the NPS which are likely to
address air quality.
✓ Noted.
If Heathrow is in breach of air quality
requirements it weakens the case for the use
of compulsory purchase powers.
✓ The assessments previously undertaken by the Airports Commission,
Heathrow and Government have consistently demonstrated that the Project
can be delivered in compliance with legal air quality obligations and without
causing exceedances of the National Air Quality Objectives. Assessment of
compliance with EU limit values will be a key component of the assessment.
We remain confident in the ability of our proposals to expand Heathrow to
deliver sustainable growth and with respect to air quality, we stand by our
‘triple lock’ guarantee to deliver the Project in accordance with the UK’s legal
air quality obligations.
Concerns that the government’s Air Quality
Plan does not account for the expansion of
Heathrow.
✓ The Government referenced Heathrow’s plan for sustainable growth within
the Greater London Urban Area (UK001) zone plan published in support of
the Air Quality Plan for Nitrogen Dioxide (the AQ Plan). Based on the
Pollution Climate Mapping projections supporting the AQ Plan, the
Government also updated previous air quality assessments completed by the
Airports Commission. This work concluded that based on a conservative
assessment, with the implementation of actions as set out in the AQ Plan, the
Project would not impact on modelled compliance with limit values in any
potential opening year.
The focus for Heathrow and the Airline
Community should be on collectively working
towards addressing airport-related emissions.
✓ ✓ We have been working to address emissions from the airport for more than
15 years and we, alongside our partners, have a strong track-record of
reducing emissions from airport operations. We will continue to work in
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The airline community has an important role
and any air quality and emissions measures
must be developed in full consultation and
agreement with them.
✓ partnership with the aviation community to manage emissions associated
with the airport operation and the aviation industry. Further details of the
measures proposed to manage the emissions resulting from the Project will
be provided within the Preliminary Environmental Information Report,
published in June 2019 as part of our Airport Expansion Consultation.
The Airline Community will support cost-
effective and operationally viable initiatives to
help reduce emissions including supporting a
broad choice of sustainable transport modes
for passengers, cargo and employees.
✓
Concern about Air quality impacts of
construction as well as other scheme
elements such as a realigned M25.
✓
Heathrow will employ best practice management and delivery systems to
manage the effects of construction. Detailed measures will be developed to
avoid, reduce and mitigate the likely impacts of construction on communities
and the environment as the DCO application becomes more developed. As
part of the EIA process, a draft Code of Construction Practice will be
prepared, which will outline how construction activities will be managed. This
document will set out the requirements for mitigation and the monitoring of
potential environmental impacts throughout the construction period. Heathrow
will be consulting on the draft Code of Construction Practice as part of the
PEIR which will be published as part of the Airport Expansion Consultation in
June 2019.
Concern about the impacts on air quality and
the health of communities during the
construction of the expanded airport.
✓
Consideration should be given to how
unauthorised car park and caravan sites for
construction workers will be managed as
these could lead to adverse air quality
impacts on residential areas.
✓
Concern about the additional vehicular
movements associated with construction
activities.
✓
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Electric engines to aircraft which could be a
compulsory source of power when landing
should be introduced.
✓ Although Heathrow supports developments and innovations in this area, this
comment refers more directly to aircraft manufacturers and airlines.
Heathrow engages with airlines and other stakeholders to operate in an
environmentally efficient way and will continue to support solutions to improve
ways of working and operating whilst maintaining safety and efficiency.
Existing air quality measures have not
worked and that further erosion of land and
green space will worsen air pollution in the
area.
✓
As part of Airport Expansion Consultation One (January 2018) Heathrow
presented Our Design Approach to the Natural Environment, which included
an approach to multifunctional green infrastructure to achieve as much
environmental and community benefit as possible. The PEIR that Heathrow
will consult on as part of the Airport Expansion Consultation in June 2019,
includes further details in regard to mitigation proposals. This includes
landscaping and air quality measures.
Timely adoption of sustainable aircraft and
higher landing fees for aircrafts with higher
emissions are critical.
✓
Through variable landing charges, Heathrow charges the highest prices to
the noisiest and highest emitting aircrafts in order to encourage use of the
greenest aircrafts at the airport. Heathrow will continue this approach and is
exploring how this policy may evolve in the future to manage the emissions
directly associated with aviation.
Through its Committee on Aviation Environmental Protection (CAEP), the
International Civil Aviation Organization (ICAO) sets new emission standards
for aircraft engines – including for NOx. Engine models which were certified
on or after 1 January 2014 must meet CAEP8, the latest standard for NOx.
The proportion of flights made by newer, cleaner CAEP8 aircraft at Heathrow
increased from 20.8% in 2016 to 27.2% at the end of Q2 2018. The trend is
expected to continue as airlines proceed in replacing their older, higher
emission aircraft and Heathrow’s NOx emission landing charges and
Use and/or incentivise cleaner aircraft,
incentivise low carbon flights and banning
older, more polluting planes.
✓
Aircraft emissions should be reduced and
there should be penalties for older or more
polluting aircraft.
✓
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Suggestions that the fee airlines pay to
operate at the airport should not remain close
to current levels but should reflect the cost in
harm to the environment.
✓ engagement encourages the use of best-in-class aircraft.
Concern that Heathrow will not be able to
influence existing behaviours and as a result
expansion will simply lead to more of the
current impacts.
✓ Heathrow has a good record when it comes to managing emissions. For
example, through the implementation of an Air Quality Action Plan, we cut
total NOx emissions from ground-based sources by 16% between 2008 -
2013. This has contributed to observed concentrations of NO2 at the airport
falling by over 20% in the last 20 years. Over this same period, Heathrow’s
passenger numbers have risen by almost 80% but airport related road traffic
has remained broadly static. This demonstrates that significant growth in
passenger numbers is possible whilst managing vehicle trips to and from the
airport.
The plans are inadequate and rely too much
on people using clean transport options with
massive behaviour and technological
changes that are unlikely to happen soon
enough.
✓
Plans to reduce emissions are inadequate
and fail on all grounds according to the
recent report produced by the New
Economics Foundation which uses DfT
modelling.
✓
Mitigation should be introduced as early as
possible, before the runway is completed.
✓ As part of the design development and EIA processes, Heathrow is
developing a suite of mitigation measures designed to manage the potential
effects of the Project during both construction and operation. A number of
measures may be implemented in advance of the runway being completed.
As part of the Airport Expansion Consultation in June 2019, Heathrow will
publish the initial findings of the EIA (including a description of proposed
mitigation measures) within the PEIR.
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Suggested the measures proposed to manage
emissions would only increase prices.
✓ The Project is being carefully prepared to balance design priorities, including
reducing potential emissions, and also achieve a scheme of optimal viability.
There is an overarching emphasis upon affordability to ensure that the airport
is expanded with passenger charges staying as close as possible to 2016
levels.
Concern that the measures would negatively
impact on businesses and the economy.
✓
Details should be provided on how increased
emissions will be effectively mitigated.
✓
The information provided in Airport Expansion Consultation One (January
2018) reflected the fact that the Project was at an early design stage. We will
provide further detail on mitigation measures aimed at managing emissions
and effects on air quality within the PEIR, published part of our Airport
Expansion Consultation in June 2019. The purpose of the Airport Expansion
Consultation One was to provide an early opportunity to provide feedback on
options and components to inform the preferred masterplan that will be
presented as part of the Airport Expansion Consultation in June 2019.
The measures proposed to combat the issue
of emissions were very vague
✓
The approach set out in the consultation
documentation is inadequate and lacks
information on mitigation measures.
✓
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Concern that the emissions management
measures proposed will only offset or
mitigate in the short term.
✓ Heathrow have considered potential emissions into the longer term. For
example, Heathrow are developing measures to ensure that the carbon
associated with the construction and operation of the airport itself is managed
appropriately, working towards its goal of operating zero carbon airport
infrastructure by 2050. The Air Quality and Carbon and other greenhouse
gases chapters of the PEIR, to be published as part of the Airport Expansion
Consultation in June 2019 will provide further details on the approach to
mitigating emissions.
Concerned that measures to manage
emissions do not extend beyond a 2km radius
of the airport.
✓ The assessment will consider air quality beyond the immediate area around
Heathrow. The spatial extent of the detailed study area will be based on
where potential changes in pollutant concentrations could result in significant
environmental effects, through for example changes in traffic flows on the
public highway. This will be determined in accordance with the EIA Scoping
Opinion published by the Planning Inspectorate on the 2nd July 2018,
through use of appropriate screening criteria.
The measures proposed within our Surface Access Strategy will be effective
beyond the immediate area surrounding Heathrow. They are expressly
designed to manage the number of potential vehicle trips to and from the
airport, which originate within a wide catchment area.
Mitigation measures to improve air quality in
pollution hotspots beyond the immediate area
of the scheme should be implemented.
✓✓
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Invites should be offered to participate in the
Sustainable Freight Group.
✓ In October 2017 Heathrow published its Blueprint for Sustainable Freight.
Part of the commitments set out in this initiative was to establish a
partnership with leading cargo and freight companies, the Freight Transport
Association and the British International Freight Association (BIFA). The
Group meets twice a year to exchange experience and best practice, support
the development of initiatives to reduce emissions from freight activity at the
airport and feed into local and national freight policy development. It also
supports the roll out of freight accreditation schemes with emissions reduction
targets, trials low and zero emission vehicle technologies and identifies
measures to consolidate freight movements to and from the airport.
Heathrow’s assessment must include the
cumulative impact on existing exceedances
and likelihood of new/additional exceedances
of the air quality objective limits.
✓ The potential cumulative effects of the Project and other committed
developments will be considered as part of the EIA process, the initial
findings of which will be published within the PEIR as part of the Airport
Expansion Consultation in June 2019.
The highways and air quality assessments
must consider the cumulative impacts of
expansion with existing consented major
schemes, likely schemes from the Local
Plans and all displaced uses (whether in the
DCO application or not).
✓
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The effect of airborne aircraft emissions on
local pollutant concentrations should be
demonstrated by mapping airport-related
contributions to annual mean concentrations
of pollutants, with a plan showing just the
airborne aircraft emissions contribution.
✓ The air quality dispersion model used to assess the potential significant
environmental effects of the Project will include aircraft within the Landing
and Take-off Cycle (LTO), up to approximately 3000ft. Therefore, the
predicted effects of the Project on local annual mean pollutant concentrations
will include consideration of the influence of airborne aircraft. This is
consistent with the Scoping Report submitted to the Planning Inspectorate
and subsequent Scoping Opinion provided by PINS on 2nd July 2018.
Heathrow's reluctance to fund on-site air
quality monitoring is disappointing. Accurate
and continuous monitoring is necessary to
establish a baseline at specific sites and
ensure compliance with EU standards.
✓ Heathrow has carried out continuous monitoring at locations on and around
the airport since 1993, in addition to the monitoring conducted by the local
authorities. This data can be accessed via the Heathrow Airwatch website,
funded by a joint working partnership consisting of Heathrow Airport Limited,
London Boroughs of Hillingdon and Hounslow, Slough and Spelthorne
Borough Councils and British Airways.
Targets or measures be proposed to minimise
air quality impacts arising from the
construction workforce.
✓ A draft Code of Construction Practice will be produced, setting out a series of
control measures and standards to be implemented throughout the
construction of the Project. This document will ensure effective planning,
management and control of construction activities, to mitigate potential
impacts upon people and the environment. It will include reference to
Construction Workforce Travel Plan (CWTP) to support and encourage use of
sustainable, active modes of travel and reduce impacts of workforce travel
upon transport networks and air quality. A draft of the Code of Construction
Practice will be published as part of the PEIR in June 2019.
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The area of air quality monitoring must
include locations in and around the Ivers,
which will be subject to cumulative increases
of traffic in locations that have high numbers
of vulnerable users (e.g. schools and
recreational facilities).
✓ It is acknowledged that an Air Quality Management Area (AQMA) has
recently been declared for the Parish of The Ivers and this will be considered
within the EIA. Air quality monitoring is currently undertaken by the local
authority, whose responsibility it is monitor pollutant concentrations under the
Local Air Quality Management (LAQM) regime. This monitoring will be used
to inform the baseline assessments undertaken as part of the EIA.
Additionally, the EIA Regulations require decision-makers (i.e. in the case of
transport DCOs, the Secretary of State for Transport) to consider whether it is
appropriate to impose monitoring measures of any significant adverse effects
of the Project, as identified through the EIA process. This includes
consideration of potential remedial action. This provides additional assurance
that consideration of the effects of expansion and appropriate mitigation will
continue into the construction and operational phases of the Project.
Welcome the use of independent Air Quality
experts and requested clarity on how the
group will function, the level of transparency
and how outputs from the assessment will be
shared with stakeholders.
✓ Heathrow is working with a range of air quality experts, including advisory
groups which are providing additional scrutiny of the approach to air quality
assessment and development of appropriate mitigation measures. Outputs
will be reflected in the EIA process and the PEIR published as part of the
Airport Expansion Consultation in June 2019.
It is unclear how the assessments for
evaluation and discontinuation of options had
taken in to consideration issues such as air
quality, public transport considerations and
the influence of other scheme elements.
✓ The scheme development process that Heathrow has applied is explained
within the Scheme Development Report. The document explains how
Heathrow has applied a range of criteria to evaluate the respective
performance of different design options. This includes criteria which triggers
consideration of the relative risk of adverse air quality impacts as a result of
the Project, for example this may differ based on proximity of receptors to
emission sources or based on the likely traffic and transport effects of a
particular design option.
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Joint monitoring and review processes are
vital to the success of achieving a reduction
in emissions and Heathrow should provide
funding for this.
✓ Heathrow is committed to working alongside key stakeholders (such as the
Heathrow Strategic Planning Group, HSPG) and local authority partners to
achieve air quality and emissions objectives. The Heathrow Air Quality
Working Group (a partnership between ourselves, our neighbouring local
authorities – London Borough of Hillingdon, London Borough of Hounslow,
Slough Borough Council and Spelthorne Borough Council, the GLA, TfL and
the Environment Agency) works collaboratively to monitor, share and publish
data from 22 air quality monitoring stations within approximately 20
kilometres (km) of Heathrow. The data collected by us, our surrounding local
authorities and Defra is publicly available and can be found on the Heathrow
Airwatch website.
The air quality assessment must take account
of air quality monitoring data from the local
authority networks across the Heathrow area
not just Heathrow’s continuous monitoring
stations.
✓
Air quality demands a joint approach by
Heathrow and Local Authorities, including
monitoring and compliance.
✓
The scope of air quality assessments will
need to be agreed with HSPG.
✓ Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018. PINS
consulted on the Scoping Report, taking into account responses received
from consultation bodies (including HSPG) before providing a Scoping
Opinion, on behalf of the Secretary of State, on 2nd July 2018. The Scoping
Opinion sets out PINS opinion on the scope, level of detail and information to
be provided in the Project ES. The EIA Regulations require Heathrow to
submit an ES which is in based on the most recent scoping opinion adopted.
No baseline measurements had been
undertaken in the area following existing air
quality breaches.
✓ The PEIR, which will be published in June 2019 as part of the Airport
Expansion Consultation, will set out baseline (current) air quality within the
study area, as will the final ES to be submitted with the DCO application for
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Heathrow should publish the results of their
air quality assessments as well as the
embodied carbon and emissions impact.
✓ the Project. The assessment will draw on the extensive network of automatic
and non-automatic monitoring sites around Heathrow. Much of this data can
be accessed via the Heathrow Airwatch website, funded by a joint working
partnership consisting of Heathrow Airport Limited, London Boroughs of
Hillingdon and Hounslow, Slough and Spelthorne Borough Councils and
British Airways.
Real-time public display of air quality data
against targets with the encouragement of
less polluting commercial vehicles with a
rebate system.
✓
Air pollutants should be monitored and
assessed on the surrounding local and
strategic road network.
✓ The spatial extent of the detailed study area for the air quality assessment will
be based on where potential changes in traffic flows could result in changes
in pollutant concentrations, be that on the Strategic Road Network (SRN) or
local roads. This will be determined in accordance with the EIA Scoping
Opinion published by the Planning Inspectorate in July 2018, through use of
appropriate screening criteria. The air quality assessment in the
environmental statement must model all main
roads across the wider area and local roads
in the immediate vicinity of the scheme.
✓
Discouraging individuals from travelling by
car is an inadequate response to air quality
concerns.
✓ Discouraging individuals from travelling by car is just one of Heathrow’s
priorities. Our Surface Access Strategy will set out a suite of measures
expressly designed to manage the effects associated with traffic, including
making public transport more accessible and putting Heathrow at the heart of
an improved rail network. Beyond managing the number of vehicles travelling
to and from the airport, we are also developing measures to encourage use
of low emission vehicles (both on the public road network and on the airfield),
uptake of the latest in aircraft technology and adoption of increasingly
sustainable operating practices.
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Agreement with the conclusion that NOx
emissions are a consequence of urban
development and non-airport traffic but
suggested that punitive emission charges
should not be introduced unless affordable
and sustainable alternative means to access
the airport are implemented.
✓ ✓ As older vehicles with higher emissions are replaced by newer ones that
meet progressively tighter EU emission standards, air quality is predicted to
improve. To accelerate this process, Heathrow is exploring the potential for
strategically managed access charges, low emission zones, and parking
charges at Heathrow to further encourage the use of low emissions vehicles,
reduce unnecessary highway travel, and generate revenue to invest in public
transport.
A draft Charging Strategy will be published as part of the Surface Access
Strategy at the Airport Expansion Consultation in June 2019. High polluting vehicles should be restricted
whilst cleaner, less polluting vehicles should
be incentivised e.g. by paying less for parking
and road charges and being given better
access to the Terminals.
✓
Concern that measures to manage emissions
would have negative consequences on traffic
congestion.
✓ The main source of pollution outside of the airport boundary is traffic. As
such, the effective management of potential air quality effects associated with
the expansion of Heathrow is inherently linked to the effective management
of potential traffic and transport impacts, including congestion. Given that the
low speeds and stop start driving behaviour associated with congestion result
in greater emissions than driving at a more constant speed, measures to
manage congestion and measures to manage emissions are typically
considered complementary.
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Proposals are based on old technology and
should include measures that ensure all
airport related vehicles are electric
✓
In accordance with the ANPS, our mitigation proposals for reducing impacts
on air quality will include encouraging use of zero- or low-emission hybrid or
electric vehicles (ultra-low emission vehicles), and providing adequate
charging infrastructure across the airport.
We are already putting in place measures to increase the number of low
emission vehicles operating at Heathrow. This includes replacing all
Heathrow operated cars and small vans with electric vehicles by 2020 and
implementing standards for airside vehicles in line with the London Ultra Low
Emission Zone.
EV infrastructure should be implemented
within and outside the airport to encourage
the adoption of low emission vehicles.
Concern that managing air quality is of the
utmost importance and that greener vehicles,
such as electric cars, will have a positive
effect in the future.
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Consideration should be given for alternative
fuel infrastructure especially for freight
transport.
✓ In designing the appropriate infrastructure at an expanded airport, Heathrow
are considering future trends in vehicle technology and fuel use. This
includes, for example, understanding the potential demand for electric vehicle
charging infrastructure in the future and ensuring adequate capacity is
provided for both passengers and those operating at the airport.
Heathrow should work with the Council to
enable all taxis to be ULEV by 2025.
✓ We remain open to working with partners to maximise opportunities for
appropriate mitigation and welcome further discussions through existing
engagement channels, such as the HSPG.
New rail links must be built before the new
runway to ensure impacts on the existing
road system are minimised.
✓ There are several large committed rail infrastructure projects that are likely to
have an effect on how passengers get to Heathrow in the future. These
include the Elizabeth Line, Piccadilly Line upgrade and HS2 at Old Oak
Common.
The draft Surface Access Strategy, that will be published as part of the
Airport Expansion Consultation in June 2019 will explain how Heathrow are
working with Network Rail to support their application for a western rail link
and the DfTs proposals for a southern rail link. In designing the expanded
Heathrow care is being taken to plan for the interface between these
proposed rail links and the terminals.
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Concern about the deliverability of
Heathrow’s pledge to deliver expansion with
no more vehicles on the road without any new
significant public transport infrastructure
being proposed.
✓ ✓ The ANPS states at paragraph 3.36 that “Heathrow Airport already has good
surface transport links to the rest of the UK. It enjoys road links via the M25,
M4, M40 and M3, and rail links via the London Underground Piccadilly Line,
Heathrow Connect, and Heathrow Express. In the future, it will connect to
Crossrail, and link to HS2 at Old Oak Common. Plans are being developed
for improved rail access: the proposed Western Rail Access could link the
airport to the Great Western Main Line, and Southern Rail Access could join
routes to the South-Western Railway network and London Waterloo Station.
This varied choice of road and rail connections makes Heathrow Airport
accessible to both passengers and freight operators in much of the UK, and
provides significant resilience to any disruption.”
Heathrow will publish a draft Surface Access Strategy at the Airport
Expansion Consultation in June 2019, which will set out measures we
propose to put in place to continue to strive to meet our pledge of ensuring
the expanded airport landside airport-related traffic is no greater than today.
It will also set out measures to achieve the NPS requirements of a public
transport mode share of at least 50% by 2030, and at least 55% by 2040, for
passengers for the expanded airport.
The delivery of the rail and bus links for
surface access will be the most effective way
of reducing emissions and improving air
quality.
✓
Heathrow agree that increasing the use of public transport is key to improving
air quality. Part of our approach to meeting our existing commitment to
improving air quality is by continuing to strive to meet our commitment of not
increasing the amount of landside airport-related vehicle traffic on the road
compared to today; by supporting improved surface access that would
increase the number of people (both passengers and employees) using
public transport; and by encouraging and incentivising the use of new
technology and cleaner vehicles.
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Heathrow’s commitment to not increase the
amount of airport-related vehicle traffic on the
road and increase the numbers of people
using public transport would not be enough
to improve air quality in Stanwell and
Stanwell Moor.
✓ Heathrow will publish a draft Surface Access Strategy at the Airport
Expansion Consultation in June 2019, which will set out measures to deliver
our commitment of ensuring the expanded airport landside airport-related
traffic is no greater than today. It will also set out measures to achieve a
public transport mode share of at least 50% by 2030, and at least 55% by
2040, for passengers for the expanded airport. The strategy will play a key
role in managing the potential air quality effects of the Project, assessed as
part of the EIA. The initial findings of the EIA will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June 2019. This
will include predicted effects in Stanwell and Stanwell Moor and further
details of proposed mitigation measures.
More could be done to control/influence how
the airport is accessed. Heathrow must make
a commitment to deliver projects that enable
passengers, workers, commuters and freight
to move to more sustainable and accessible
modes of travel and contribute towards the
achievement of mode share targets.
✓ ✓ Heathrow are developing a surface access strategy to meet targets set out in
the ANPS on public transport mode share (at least 50% of surface access
passengers arriving or departing from Heathrow by public transport in 2030
and at least 55% of surface access passengers arriving or departing from
Heathrow by public transport in 2040), colleague car use reduction (25%
reduction of all colleague car trips by 2030 compared with 2013 levels and
50% reduction of all colleague car trips by 2040 compared with 2013 levels).
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The implementation of surface access
improvements to encourage sustainable
forms of transport is needed.
✓
We will also continue to strive to meet our commitment of not increasing
landside in airport-related traffic compared to today.
The Surface Access Strategy will include initiatives that improve the physical
infrastructure and the level of service provided to passengers, colleagues and
residents and initiatives that make public transport easier to use and change
travel behaviour more widely. A draft Surface Access Strategy will be
published as part of the Airport Expansion Consultation in June 2019.
Concern that the Heathrow Express is too
expensive and holds back Heathrow’s
aspirations for modal change.
✓ At Airport Expansion Consultation One (January 2018) Heathrow expressed
an intention to work with local transport operators to make travel to and from
the airport on public transport as affordable as possible. This could be
through offers and promotions on Heathrow’s services or negotiated
discounts with other operators. Heathrow has already led a number of
innovative pricing offers on Heathrow Express such as advanced fares for as
little as £5.50, children travelling for free and the recent £15 summer price
promotions.
With the significant upgrade in rail capacity and frequency due to the
introduction of the Elizabeth line and Piccadilly line upgrade, there is an
opportunity to review the pricing structure of Heathrow Express fares to
ensure the service provides the optimal customer experience and demand
requirements. Making efficient use of available rail capacity will be a key
driver in making public transport more accessible for both passengers and
colleagues.
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Air quality problems extend to areas further
from the airport. Limiting car parking spaces
and the provision of a new rail link from
Waterloo are therefore important measures.
✓ It is recognised that a large number of monitoring sites across London
currently record pollutant concentrations in excess of the relevant EU Limit
Values and Air Quality Objectives. It is important to note that non-airport
related road traffic is the dominant contributor to ground-level pollutant
concentrations outside of the airfield and that international, national and
regional actions will play an important role in reducing pollutant
concentrations across the UK in the forthcoming years.
We will continue our work in partnership with the companies operating at
Heathrow, local authorities and Government, and we remain fully committed
to playing our part in meeting the Government’s national Air Quality
Objectives (AQOs) and achieving compliance with European air quality limits.
Our Surface Access Strategy will set out how we intent to do so, and include
initiatives that improve the physical infrastructure and the level of service
provided to passengers, colleagues and residents and initiatives that make
public transport easier to use and change travel behaviour more widely. A
draft Surface Access Strategy will be published as part of the Airport
Expansion Consultation in June 2019.
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Enabling people to use modes other than the
private motor vehicle is vital such as
improved cycle access.
✓ Our approach to developing a surface access strategy which was published
at Airport Expansion Consultation One (January 2018) stated that the
provision of better and more sustainable travel options (public transport,
cycling and walking) was one of its the key priorities. It set out a number of
measures and options about how cycling provision could be improved
including:
• Expanding the Heathrow Cycle Hub scheme which already has over
2,300 members and offers discounted cycles and equipment, free
labour on maintenance and training to all airport employees.
• New cycle hub facilities could provide a single point of entry to and
from Heathrow and a holistic service to users, including shower and
changing facilities.
• Ensuring that fast and frequent connections are available from the
cycle hubs to relevant employment locations around the airport. It
would be possible to build similar hubs at key entrances to the south
and east of the airport, making cycling more convenient for many
more of our colleagues.
• Heathrow is also currently re-purposing an existing tunnel to provide
direct bicycle access to the Central Terminal Area from the north
boundary of the airport.
This approach has been progressed in the Surface Access Strategy and a
draft will be published at the Airport Expansion Consultation in June 2019.
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Improvements to air quality will largely
depend on government action such as
investment in rail schemes.
✓ Heathrow acknowledged within the Airport Expansion Consultation One
materials that international, national and regional actions will play an
important role in reducing pollutant concentrations across the UK in the
forthcoming years. We are however committed to playing our part and
managing the influence of Heathrow on local air quality. As required by the
ANPS, we must demonstrate through the DCO and supporting ES that the
Project would be compliant with legal air quality obligations that provide for
the protection of human health and the environment.
In the long term, increased flights from
Heathrow will lead to more traffic on the M25
(and M4) increasing congestion and air
pollution near Heathrow and up to and near St
Albans.
✓ Heathrow recognises the existing challenges on the road network in the
Heathrow area with high traffic levels and local air quality issues.
Heathrow are developing a Surface Access Strategy that will set out
measures to meet the requirements of the ANPS. These requirements
include: increase the proportion of journeys made to the airport by public
transport, cycling and walking to achieve a public transport mode share of at
least 50% by 2030, and at least 55% by 2040 for passengers; from a 2013
baseline level, achieve a 25% reduction of all colleague car trips by 2030,
and a reduction of 50% by 2040.
We will also continue to strive to meet our public pledge to ensure that
landside airport related traffic is no greater than today.
In doing so, we are developing measures which are expressly designed to
manage on site traffic movements from passengers, such as improving on-
Concern that displaced airport and non-
airport traffic will give rise to air pollution hot
spots.
✓
Concerns that expansion will result in
significant redistribution of traffic around the
airport and additional traffic flows.
✓
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Concern that expansion would increase traffic
in the Air Quality Management Areas
(AQMA’s) within the borough and that no
strategic objective for the management of
surface transport had been produced.
✓ site transport facilities to encourage the use of public transport. Meeting these
requirements is important to our approach to reducing air quality impacts. The
draft Surface Access Strategy will be published in at the Airport Expansion
Consultation in June 2019.
The increase in road traffic caused by a
growth in the number of passengers
travelling to and from the airport risks a
negative impact on local air pollution.
✓
The roads surrounding Heathrow cannot cope
with the existing volume of traffic
contributing to poor air quality.
✓
Concern that the amount of traffic on the
roads will have a knock-on effect on the
ability to control air quality levels.
✓
There is a requirement for Heathrow to
provide a resilient and reliable road network
in order for it to deliver a reduction in
emissions and limit fuel use.
✓
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Adverse change to noise and air quality from
any changes to the strategic road network
must be fully considered and mitigated,
including ensuring compliance with the
European air quality limit values and/or in
local authority designated Air Quality
Management Areas.
✓
Concern about the lack of measures to
reduce airport related traffic movements for
staff, service vehicles and airport users.
✓
Additional construction traffic movements
would add to the existing issues with air
quality caused by traffic congestion and
commercial vehicles using the roads through
the village.
✓ Air quality will be monitored as part of the wider pre-construction/construction
monitoring programme, which will include appropriate locations based on
potential impacts. The full programme for monitoring has not yet been
planned, but monitors will be installed in advance of the construction
programme.
Concern whether air quality had been
considered when selecting the options for the
A3044, the M25, or Option 6C for the A4.
✓ The Scheme Development Report published at Airport Expansion
Consultation One explains the evaluation process for the selection of
proposed options for the Project. Evaluation criteria includes seven discipline
areas which includes sustainability. Air quality is a criterion within the
sustainability discipline against which all masterplan options are considered.
The preferred masterplan will be presented at the Airport Expansion
Consultation in June 2019 along with the Updated Scheme Development
Report that will set out the findings of the evaluation process.
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Current traffic volumes, especially HGVs,
already have a significant and negative
impact on their community from noise, air
pollution and poor road safety.
✓ As part of the Project Heathrow will aim to limit freight vehicles to similar
levels to today and help operators clean up the vehicle fleets through a range
of different initiatives, including: increasing efficiency; optimising the fleet mix
and using new technology to increase load factors to help more goods to be
delivered in the same number of vehicles. Cargo and logistics facilities
around the airport have grown in an incremental and organic way which
means there are lots of facilities in different locations. By working with the
local authorities to more proactively plan the land uses around the airport
Heathrow can provide facilities in appropriate locations helping to reduce
shuttling movements through consolidation of loads and reducing impacts on
local communities. Working with Transport for London and other authorities
on re-timing journeys that are not time critical to outside peak periods,
monitoring of routing for HGVs and other freight vehicles, as well as ensuring
there are appropriate measures in place for those that do not comply.
The Perimeter Roads also carry a high
proportion of traffic circulating around the
airport between terminals, car parks and
other ancillary airport facilities and must be
included in both the baseline and future
assessment of vehicle movements.
✓ The Airport is surrounded and accessed by an inner ring road, formed by the
northern, eastern, southern and western perimeter roads and an outer ring of
the A4, A312, A30 and A3044.
The Project would result in the loss of the Western Perimeter Road and parts
of the Northern Perimeter Road. It would also result in severance of the A4
(Bath Rd) and A3044 (Stanwell Moor Rd). These roads will form part of the
baseline and transport and traffic impact assessment. This will include
considering how the impact of physical changes to the road network and or
changes in traffic flow associated with the Project will affect delay on these
roads. Early findings of the traffic and transport assessment will be published
in the PEIR at the Airport Expansion Consultation in June 2019.
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The definition of Heathrow related traffic must
include traffic on all roads.
✓ Heathrow will continue to strive to meet its pledge to have landside airport-
related traffic no greater than today. Heathrow is currently defining what
vehicles are considered to be ‘airport-related traffic’ and details of this will be
presented in the draft Surface Access Strategy at the Airport Expansion
Consultation in June 2019.
Brands Hill Air Quality Management Area
should be included with the airports air
quality model and study area.
✓ The spatial extent of the detailed study area will include the Brands Hill
AQMA.
Concern about the impact on the proposed
Air Quality Management Area in the Iver and
Burnham Beeches Special Area of
Conservation.
✓ The assessment will consider air quality beyond the immediate area around
Heathrow. The spatial extent of the detailed study area will be based on
where potential changes traffic flow as a result of the Project could result in
changes in pollutant concentrations, to the extent that these could result in
significant environmental effects. This will be determined in accordance with
the EIA Scoping Opinion published by the Planning Inspectorate on the 2nd
July 2018, through use of appropriate screening criteria.
The initial findings of the assessment will be reported in the PEIR to be
published as part of the Airport Expansion Consultation in June 2019. The highway network should be given full
consideration in Heathrow's future approach
to air quality. This includes an Air Quality
Management Area in place on the M3 between
Junction 3 and Junction 4 and the A331 in the
west of Surrey Heath, where exceedances of
the annual mean NO2 limit value have been
identified.
✓
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Extend the ULEZ to the area around the
airport, including preferably the M25
Motorway. This will assist in improving air
quality for residents.
✓ ✓ Heathrow is exploring the potential for strategically-managed access charges,
low emission zones, and parking charges at the airport to encourage the use
of low emissions vehicles and reduce unnecessary trips. In doing so,
Heathrow is engaging with the Mayor and Transport for London to co-
ordinate proposals for an emission based charge with plans for the emerging
London Ultra Low Emissions Zone. These proposals will be outlined at the
Airport Expansion Consultation in June 2019. The only way to address air quality issues
would be the implementation of a Clean Air
Zone and/or Zero Emissions Zone.
✓
The A4 should be declared as a CAZ and
aligned with the airports LEZ.
✓
Air quality measures taken around the airport
that may apply to freight or other air related
businesses in the future must be consistent
with the ULEZ in London and the
Government’s Clean Air Strategy to avoid
fragmentation of vehicle standards.
✓
Airport related freight routes that use the
strategic road network (motorway) should be
CAZ compliant.
✓
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CARBON AND CLIMATE CHANGE
Introduction
22.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in
relation to the measures proposed to limit carbon emissions from the design,
construction and operation of the Heathrow Expansion Project (the Project). A
total of 878 consultees made comments relating to this topic.
22.1.2 Heathrow provided the following material that is directly related to the measures
proposed to limit carbon emissions:
1. Airport Expansion Consultation Document; and
2. Our Approach to Carbon and Climate Change.
22.1.3 Heathrow asked the following question in relation to the approach to limiting
carbon emissions at Airport Expansion Consultation One:
1. Do you have any comments on our approach to limiting carbon emissions from
the design, construction and operation of an expanded Heathrow?
22.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
Prescribed Consultees
Local Authorities
22.2.1 The London Borough of Brent supported Heathrow’s efforts to date to reduce the
carbon footprint of terminal buildings and incentivising airlines to use greener
aircraft. However, they considered that more could be done to reduce the carbon
emissions generated by travel to and from the airport.
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22.2.2 Elmbridge Borough Council said Heathrow’s dependence on technological
progress, including the evolution of aircraft fleet, gave optimistic carbon
projections.
22.2.3 The London Borough of Hammersmith and Fulham stated that a carbon neutral
third runway was aspirational and requested formal commitments from Heathrow.
They recommended that Heathrow quantify the carbon emission impacts before
and after mitigation to show its value, otherwise there is no way to assess if
measures are achieving the low/zero carbon or carbon neutral targets.
22.2.4 They requested more information on whether Heathrow’s carbon neutral
commitments apply across all the demand scenarios that were used for modelling
by the Airports Commission and the Department for Transport (DfT).
22.2.5 Hampshire Services, on behalf of the Central and Eastern Berkshire Authorities,
supported the proposals for low carbon construction and materials, particularly the
minimisation of materials wherever possible.
22.2.6 The London Borough of Hounslow commented that carbon emissions associated
with aircraft will increase with the additional proposed flights and will be significant
unless timely measures are implemented. They considered the adoption of fuel-
efficient aircraft and sustainable biofuel critical to achieve the carbon reduction
targets set by Heathrow and UK/EU Legislation.
22.2.7 They asked for more detail on the approaches that will be used to limit carbon
emissions and concrete commitments which demonstrate how Heathrow will
incentivise and monitor progress with targets and penalties. They suggested that
timely adoption of sustainable aircraft and higher landing fees for aircrafts with
higher emissions are critical for the sustainable expansion of Heathrow.
22.2.8 They also highlighted that:
1. details should be provided on how increased emissions will be effectively
mitigated;
2. carbon offsetting should be the last resort once all the mitigation has been
implemented;
3. failure to reduce carbon emissions immediately will result in ever-increasing
costs and public safety risk associated with the impacts of climate change;
4. effective baseline, monitoring and periodic targets are set to ensure carbon
reduction is apparent; and
5. loss of green space should be minimised as it is critically important for carbon
storage, temperature regulation and flood mitigation.
22.2.9 The London Borough of Islington considered that the expansion of any airport
cannot be justified unless the volume of greenhouse gas emissions that would
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result from expansion, including emissions from additional flights, is consistent
with the government’s overall climate change targets.
22.2.10 Kent County Council stated that carbon impacts should be assessed at all stages
of the project lifecycle and consideration should be given to the waste hierarchy
during operations, specifically energy generation. They highlighted that all
practicable measures should be taken to ensure carbon emissions are minimised
at all stages of construction and operation and that measures to increase public
transport use are vital to maintaining and reducing the airport’s carbon emissions.
22.2.11 The Council also supported the use of carbon offsetting but said that this should
be meaningful. They cited the example of providing finance to support energy
efficient housing stock in the local area.
22.2.12 Reading Borough Council supported the proposals to reduce carbon emissions
and reduce the airport’s effect on climate change. They highlighted the need to
make surface access by sustainable transport as attractive and easy as possible
to reduce car use and the influence on climate change.
22.2.13 Spelthorne Borough Council stated that the approach to carbon and climate
change was highly encouraging but said that the aspiration and related objectives
appeared high-level and lacking in specific details. They recognised Heathrow’s
investment into electric vehicle infrastructure and that it would also assist with
wider air quality benefits through faster and greater uptake of electric vehicles by
the residents and businesses in the local communities to help offset increased
surface access emissions.
22.2.14 Surrey County Council supported the overarching aspiration to make growth from
the new runway carbon neutral and the objective to operate a zero-carbon airport
but requested more details on how these would be achieved, measured and
monitored. Further information was also requested on where materials for
construction would be sourced and waste would be disposed. They considered
this should be documented in a materials and disposals brief for the scheme.
22.2.15 Wokingham Borough Council supported the strategy for reducing carbon
emissions outlined in the consultation document.
Statutory Consultees
22.2.16 No comments were received from statutory consultees about lowering carbon
emissions.
Other Prescribed Consultees
22.2.17 Albury Parish Council expressed concern that no details were provided on how
airlines will be incentivised to deliver low carbon flights or how it will be policed.
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22.2.18 Bray Parish Council commented that on still days the smell of aviation fuel is
apparent and increased traffic will only make pollution worse. They perceive that
the country is not achieving the reduced carbon emissions required and fail to see
how carbon reduction policies can be achieved.
Local Communities
Members of the public
22.3.1 Positive and negative comments on the approach to managing carbon emissions
were received. The most comment positive comment was that the measures
appeared suitable and fair. Positive comments were also received that stated that
the approach was comprehensive, that limiting emissions was necessary and that
investment into renewable energy sources, the use of low emission and/or electric
vehicles and that the proposals would address long term needs or requirements.
22.3.2 Responses were also received which expressed support for the approach subject
to certain conditions being met, these comprised that:
1. there must be an extension of the proposed ULEZ further beyond the boundary
of the airport;
2. alternative energy should be introduced on site; and
3. aircraft emissions should be reduced and there should be penalties for older or
more polluting aircraft.
22.3.3 Negative comments relating to carbon emissions often expressed general
concerns about the effects of emissions from aircraft or commented that the
approach to managing carbon emissions was inadequate or insufficient. Other
negative comments and criticisms comprised:
1. the approach is unrealistic or unachievable;
2. the approach lacks credibility given the current air pollution;
3. carbon emissions would not be reduced;
4. Heathrow will not be able to influence existing behaviours and that expansion
will simply lead to more of the current impacts, overall levels of pollution will not
be reduced.
5. concern that the emissions management measures proposed can only hope to
offset or mitigate in the short term.
6. the methods proposed to reduce carbon emissions should be implemented
ASAP and not be delayed.
7. concern that more flights will mean more emissions, air quality levels are
already poor and breach EU limits; and
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8. concern with the impact of emissions on local communities from traffic and
planes.
22.3.4 Members of the public also raised points about the need for low carbon design,
that it was important and that it would also improve the resilience of the airport.
However, others believed that low carbon design would not make a difference or
that it would be insufficient.
22.3.5 Suggestions were also received that Heathrow should invest in new technology,
use of solar panels or wind turbines within the design or that the priority should be
for an energy efficient design, be carbon neutral or that the buildings should be
zero carbon utilising recycled materials or reuse for construction where possible.
22.3.6 With regard to low carbon operations suggestions were received that cleaner/low
emission aircraft and cleaner/low emission ground vehicles should be used and,
that older aircraft should be banned from using Heathrow Airport.
22.3.7 Suggestions were also received that the process should be expedited, that
emissions were unavoidable, and that the theory of climate change and its impacts
were a myth.
Businesses
22.3.8 The Airport Industrial Property Unit Trust (AIPUT) requested that Heathrow publish
the results of its air quality assessments as well as the embodied carbon and
emissions impact.
22.3.9 The Copas Partnership suggested that Heathrow should focus on low emissions.
22.3.10 The Emerson Group on behalf of Orbit Developments (Southern) Limited stated
that it is not clear how Heathrow can remain within the Committee on Climate
Change's recommended assumptions in respect of carbon emissions, especially
when combined with emissions from other UK airports. They considered that
inadequate information was provided on this.
22.3.11 The Fuel Trading Company recommended that renewable diesel should be used
in both the operation and the construction of any part of the airport to limit carbon
emissions.
22.3.12 Suez UK indicated that as a recycling, resource management renewable energy
company, they had numerous comments to make on this matter but requested a
discussion with the Project team, separate to the consultation.
Community Groups
22.3.13 Aircraft Noise Three Villages considered that Heathrow is relying entirely on
reductions in carbon emissions from other sources such as regional airports. They
also expressed concern that there is no acknowledgement of the facts laid out by
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the Committee on Climate Change. The Richmond Heathrow Campaign
expressed a similar view and suggested that restrictions on other sectors of the
UK economy and growth at other UK airports was likely to be required to address
carbon emissions.
22.3.14 The Colnbrook Community Partnership expressed support for the approach set
out within the consultation documents to limit carbon emissions.
22.3.15 The Chertsey Society stated that if the Project goes ahead there will be a huge
increase in carbon dioxide emissions from planes and vehicle movements. They
suggested that airlines should set aside money to plant trees to absorb the carbon
dioxide as an offsetting scheme.
22.3.16 Ealing Fields Residents Association considered Heathrow’s proposals satisfactory
but expressed concern that air travel is a disproportionate contributor to climate
change.
22.3.17 Englefield Green Action Group commented that Heathrow’s proposals should not
increase emissions from the current levels, suggesting that tapered reduction
targets should be set. They also expressed opposition to the use of carbon
offsetting.
22.3.18 Harrow U3A Sustainability Group expressed concerns over the use of the term
'carbon emissions' and suggested that carbon dioxide, particulate carbon or
methane should be considered.
22.3.19 Local Conversation in Stanwell recognised Heathrow’s investment into electric
vehicle infrastructure and considered it will help staff, taxis and private hire
vehicles in making the transition to electric vehicles. They also considered that
greater uptake of electric vehicles by the residents and businesses in the local
communities will help to offset increased surface access emissions.
22.3.20 Richmond Environmental Information Centre asked for the introduction of electric
engines to aircraft which could be a compulsory source of power when landing.
Wider/other consultees
22.4.1 The Royal Society for the Protection of Birds expressed opposition to any airport
expansion until the Committee on Climate Change’s recommendation that
government produce a plan to limit UK aviation emissions is set in motion. They
considered that airport expansion within current policy structures will damage the
UK’s ability to keep emissions within carbon budgets and that expanding Heathrow
will lead to increased aviation emissions.
22.4.2 The Colne Valley Regional Park supported measures that encourage low carbon
design, construction and operation of the airport and requested further details on
Heathrow’s approach.
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22.4.3 The Campaign to Protect Rural England stated that the vast majority of carbon
(dioxide) emissions will be from the extra aircraft and there are no proposals that
would appreciably offset this increase. They also commented that there was no
mention of the impact of the Project on the UK’s obligations in the Climate Act and
no recognition of the significant greenhouse-causing emissions at altitude from the
extra aircraft.
22.4.4 The Church of England – Diocese of London, Oxford and Southwark expressed
concern that the approach to tackling climate change is incoherent, incomplete,
inadequate and deeply unconvincing. They said there is no attempt to bring
Nitrogen Oxide emissions at altitude within scope or to improve on the
International Civil Aviation Organisation’s (ICAO) offsetting scheme.
22.4.5 Hounslow Green Party commented that the Project defies logic on air pollution and
climate change grounds. National targets on carbon reduction should be tougher
and Heathrow should not be allowed to expand unless the other emitters reduce
activity beyond what is viable.
22.4.6 Lambeth/Herne Hill Green Party requested carbon emission reduction goals are
taken seriously and that measures to reduce carbon emissions before considering
off-setting are implemented. They also suggested that the fee airlines pay to
operate at the airport should not remain close to current levels but should reflect
the cost in harm to the environment.
22.4.7 The London Parks and Garden Trust highlighted concerns that there are
insufficient details to comment on the approach to limiting carbon emissions at
present and urged as much use of green infrastructure as possible.
22.4.8 The London Wildlife Trust expressed support for measures that encourage low
carbon design, construction and operation and requested further details on
Heathrow’s approach.
22.4.9 The Royal Parks expressed support for the move to reduce carbon emissions.
They suggested that mitigation should be included that allows biodiversity to
develop and tolerate changes in climate.
22.4.10 The World Federalist Party commented that the approach to carbon and climate
change was short-sighted or disingenuous.
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Issues Raised and Heathrow’s Responses
The table below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Carbon and Climate Change. None of the feedback received in relation to Carbon and Climate
Change are directly related to the proposals on which we are seeking feedback as part of the Airspace and Future Operations
Consultation (January 2019) but instead relate to other aspects of the Project. The table therefore provides a summary of the
way in which we are seeking to consider the issues raised, and are provided for information only. No further feedback is being
sought on the basis that a full consultation feedback report will be published as part of the Airport Expansion Consultation in
June 2019.
Table 22.1B
Issue Consultee9 Heathrow Response
PC MC WC
Concerns that emissions management
will not keep pace with longer term
expansion.
✓ The Environmental Impact Assessment (EIA) will assess the likely significant effects
of the Heathrow Expansion Project (the Project) based on a range of variables.
These include reasonable worst-case projections of the growth in aircraft
movements facilitated by the Project, but also other factors which will affect
emissions in the future. These factors include developments in aircraft and vehicle
9 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Heathrow’s dependence on technological
progress, including the evolution of
aircraft fleet, gave optimistic carbon
projections.
✓ technology and subsequent evolution of the fleets, modernisation of airspace and
the uptake of sustainable aviation fuels. In accordance with the EIA Scoping Opinion
provided by the Planning Inspectorate (PINS), conservative assumptions relating to
these variables will be applied during the assessment. However, Heathrow is
developing a number of measures which aim to accelerate the uptake of increasingly
sustainable technologies, practices and fuels, across both the airfield and for those
passengers and colleagues travelling to and from the airport via the transport
network.
Further information relating to emissions projections and proposed mitigation
measures will be published within the Preliminary Environmental Information Report
(PEIR), as part of the Airport Expansion Consultation in June 2019.
Carbon emissions associated with
aircraft will increase with the additional
proposed flights and will be significant
unless timely measures are implemented.
✓ It is recognised that in the short term, the growth in air traffic movements associated
with the Project will result in an increase in absolute carbon emissions. However, in
accordance with the Airports National Policy Statement (ANPS), Heathrow must
demonstrate that expansion will not result in an increase in carbon emissions that
would have a material impact on the ability of Government to meet its carbon
reduction targets, including carbon budgets. Through the adoption of appropriate
measures which seek to accelerate the uptake of new aircraft technology and
encourage the use of sustainable operating practices and aviation fuels, we are
confident in meeting this test.
Concern that carbon emissions would
not be reduced
✓
Concern that air travel is a
disproportionate contributor to climate
change.
✓ Heathrow recognise that aviation has a central role to play in helping to meet the
global challenge of limiting climate change. As required by the ANPS, we will need
to demonstrate that the Project will not result in an increase in emissions so
significant that it would have a material impact on the ability of Government to meet
its carbon reduction targets, including carbon budgets. Looking beyond this
requirement, our long-term aspiration is for growth from our new runway to be
carbon neutral.
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Failure to reduce carbon emissions
immediately will result in ever-increasing
costs and public safety risk associated
with the impacts of climate change.
✓ Climate change is widely accepted as one of the greatest global risks facing our
planet and the challenge facing all of us is to find a way to cut our emissions whilst
continuing to develop socially and economically. The aviation industry has to play its
part and Heathrow’s aim is to take a lead globally in decoupling growth in aviation
from growth in carbon emissions.
The EIA will consider the likely significant impacts of carbon emissions associated
with the construction and operation of the Project and identify appropriate mitigation
measures to manage these emissions. We are also assessing the effects of
potential future changes in climate on the Project itself and on surrounding
receptors. This includes, for example, how the potential effects of the Project on
biodiversity receptors could be exacerbated by projected changes in temperature.
The initial findings of our Carbon and other greenhouse gases and Climate Change
assessments will be published within the PEIR, as part of the Airport Expansion
Consultation in June 2019.
Concerns over the use of the term
'carbon emissions' and suggested that
carbon dioxide, particulate carbon or
methane should be considered.
✓ The scope and methodology of our Carbon and other greenhouse gases
assessment is described within the EIA Scoping Report submitted to PINS on 21st
May 2018, and the subsequent Scoping Opinion provided by PINS (on behalf of the
Secretary of State) on 2nd July 2018.
Emissions resulting from the Project will be reported in terms of carbon dioxide
equivalent (CO2e) for all main greenhouse gases (carbon dioxide, methane etc.),
with the exception of aircraft emissions. Heathrow has adopted the advice of the
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Committee on Climate Change10 to consider only CO2 emissions from air transport.
This advice has also been adopted by the DfT11 and has informed its policy on
aviation and climate change.
Heathrow should be looking at best
practice examples from around the world.
✓ Heathrow are working with a range of specialists in airspace and airport design who
are aware of projects and practices undertaken elsewhere.
10 Committee on Climate Change, Scope of carbon budgets – Statutory advice on inclusion of international aviation and shipping, April 2012, and
Committee on Climate Change, Meeting the UK aviation target – options for reducing emissions to 2050, December 2009
11 Department for Transport, UK Aviation Forecasts, 2017
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No recognition of the significant
greenhouse-causing emissions at altitude
from the extra aircraft (NOx and H2O).
✓
✓
Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018. We
subsequently received a Scoping Opinion from PINS, on behalf of the Secretary of
State, on 2nd July 2018. The Scoping Opinion sets out PINS opinion on the scope,
level of detail and information to be provided in the ES. The EIA Regulations require
Heathrow to submit an ES which is in based on the most recent scoping opinion
adopted.
As set out in the Scoping Report and subsequent Scoping Opinion, the EIA will
assess CO2 emissions from aircraft, both in the landing and take-off cycle and above
3000ft (cruise). The approach which will be applied by Heathrow is consistent with
the advice of the Committee on Climate Change, which has also been adopted by
the DfT and has informed its policy on aviation and climate change.
The approach which will be adopted during the air quality assessment differs to that
for carbon due to the different nature of the effects and receptors. Specifically, the
impact of carbon emissions is generally assessed at a global level, given the
influence of aircraft CO2 emissions in the atmosphere on climate change. Air quality
effects however are assessed at a local level, based on potential changes in
pollutant concentrations (NO2 and particulate (PM)) at locations where people might
be exposed, for example at residential properties. It is for this reason that the air
quality assessment will not assess pollutant emissions from aircraft above the
landing and take-off cycle (3000ft). Due to the dispersion of these emissions at
height, they have a negligible effect on pollutant concentrations at ground level. This
approach is based on the International Civil Aviation Organization (ICAO) air quality
guidance.
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Concerns about the lack of detail and
information.
✓
The information provided in Airport Expansion Consultation One reflected the fact
that the Project was at an early design stage. Further information regarding the
potential effects of carbon emissions associated with the Project, including early
findings from the EIA, will be contained within the PEIR which will be published as
part of the Airport Expansion Consultation in June 2019.
We remain confident in the ability of our proposals to deliver sustainable growth and
demonstrate that the Project will not result in an increase in emissions that would
have a material impact on the ability of Government to meet its carbon reduction
targets.
Concern that the approach to tackling
climate change is incoherent, incomplete,
inadequate and deeply unconvincing.
✓ The information provided in Airport Expansion Consultation One reflected the fact
that the Project was at an early design stage. Further information regarding the
potential effects of carbon emissions associated with the Project, including early
findings from the EIA, will be contained within the PEIR which will be published as
part of the Airport Expansion Consultation in June 2019.
We remain confident in the ability of our proposals to deliver sustainable growth and
demonstrate that the Project will not result in an increase in emissions that would
have a material impact on the ability of Government to meet its carbon reduction
targets.
Concern that the proposed measures
lack credibility and are unrealistic,
inadequate or insufficient.
✓
Concern that low carbon design would
not make a difference and be insufficient.
✓ Heathrow is in the process of developing a baseline for the carbon emissions
associated with construction (known as embodied carbon) and put in place
measures to reduce these carbon emissions (See Our Approach to Carbon and
Climate Change). Heathrow is in the process of establishing a set of principles for
design and construction to address the carbon impact of expansion.
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The vast majority of carbon (dioxide)
emissions will be from the extra aircraft
and there are no proposals that would
appreciably offset this increase.
✓ Heathrow acknowledges that the primary source of carbon emissions associated
with the airport is aircraft, with operations and energy use and travel to and from the
airport other contributing sources. As required by the ANPS, we will demonstrate via
the ES that the Project will not result in an increase in emissions so significant that it
would have a material impact on the ability of Government to meet its carbon
reduction targets, including carbon budgets.
Looking beyond this requirement, our aspiration is to make growth from our new
runway carbon neutral. This would mean that growth in emissions from additional
flights after expansion would be offset through carbon credits – resulting in no net
growth in emissions. Following a historic agreement in 2016 at the International Civil
Aviation Organisation (ICAO), the UN body for international aviation, the industry is
working with governments to implement CORSIA, the world’s first sector wide
market-based measure for offsetting the growth in international aviation emissions
after 2020. In December 2018, Heathrow published its plan for carbon neutral
growth, and in 2019 will work with the aviation industry, advocacy groups and
climate change experts to seek further inputs.
We want to play a lead role in developing the next generation of high quality, cost
effective carbon offsetting in the UK. For example, we recently funded a project to
restore 70 hectares of peatland in the north-west of the UK, in partnership with the
Lancashire Wildlife Trust. This pilot scheme will stop this peatland emitting carbon,
and over time sequester it, and deliver other benefits, like more biodiversity value
and a lower risk of flooding downstream. It will help us offset a portion of emissions
from Heathrow’s own infrastructure to achieve our goal of carbon neutral
infrastructure by 2020.
A carbon neutral third runway was
aspirational, formal commitments from
Heathrow would be appreciated.
✓ It remains Heathrow’s aspiration to make growth from the new runway carbon
neutral. In December 2018, Heathrow published its plan for carbon neutral growth,
and in 2019 will work with the aviation industry, advocacy groups and climate
change experts to seek further inputs.
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Heathrow is relying entirely on
reductions in carbon emissions from
other sources such as regional airports.
✓ Heathrow dispute the statement that we are relying entirely on reductions in carbon
emissions from other sources, such as regional airports. As required by the ANPS,
we will demonstrate through the DCO application and supporting ES that the
increase in carbon emissions resulting from the Project would not have a material
impact on the ability of Government to meet its carbon reduction targets, including
carbon budgets. The initial findings of the EIA process will be reported in the PEIR
as part of the Airport Expansion Consultation in June 2019.
The expansion of Heathrow Airport must
not lead to an increase in climate-
changing emissions or any increase in
motor vehicle volumes (and resulting
pollution and emissions).
✓ The ANPS sets out the planning framework for a new runway in the South of
England. In doing so, it defines requirements for Heathrow’s environmental
assessment. In the context of carbon, this includes demonstrating that the increase
in carbon emissions resulting from the project would not have a material impact on
the ability of Government to meet its carbon reduction targets, including carbon
budgets.
The ANPS does not require Heathrow to demonstrate that there will be no increase
in motor vehicle volumes due to the Project. It does however require that the
application for development consent to include details of how Heathrow will increase
the proportion of journeys made to the airport by public transport, cycling and
walking to achieve a public transport mode share of at least 50% by 2030 and at
least 55% by 2040 for passengers. The application will also detail how a 25% and
50% reduction in all colleague car trips will be achieved by 2030 and 2040
respectively.
Heathrow should think holistically about
how it can unilaterally and bilaterally
reduce emissions from all sources,
tackling the greatest sources of
emissions first.
✓ Heathrow agree that a holistic approach is appropriate when developing measures
to manage the potential emissions associated with the airport, and that these
measures will require both direct action by Heathrow and partnership with the
relevant stakeholders. Further details on the measures proposed to manage the
effects of the Project will be contained within the PEIR, which forms part of the
Airport Expansion Consultation in June 2019.
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Project should use technologies that
could improve environment, e.g. use an
energy efficient/carbon neutral design,
solar panels or wind turbines and
utilising recycled materials in
construction.
✓ ✓ Heathrow objective is to develop an expanded airport that minimises carbon in its
operation and construction. This means carbon is a key criterion that informs our
thinking and the design of the Project ensuring, for example, that land is
safeguarded for renewable energy technology and flexibility is built into our designs
to enable new technologies to be adopted in the future.
Our goal is to be a zero-carbon airport by 2050 – generating no carbon from the
energy used to run Heathrow. In the near term, we’re maximising renewable energy
generation onsite and already purchase 100% renewable electricity. Alternative energy should be introduced
on site.
✓
Concern regarding expansion of any
airport in relation to the government's
climate change targets (e.g. Climate Act).
✓ ✓ Paragraphs 5.82 and 5.83 of the ANPS set out the policy requirement of ensuring
that the Project would not have a material impact on the ability of Government to
meet its carbon reduction targets, including carbon budgets. Evidence of
appropriate mitigation measures in both design and construction will be presented
as part of the DCO application, along with emission projections for construction
activity, transport to and from the airport, operations (e.g. fuel and energy use) and
aircraft movements. The Secretary of State will consider the effectiveness of
Heathrow’s proposed mitigation measures to ensure that the project's carbon
footprint is not unnecessarily high. The Secretary of State’s view of the adequacy of
the mitigation measures will be a crucial factor in the decision-making process.
The initial findings of the EIA, including carbon and greenhouse gas projections and
proposed mitigation measures, will be reported within the PEIR which forms part of
the Airport Expansion Consultation in June 2019.
Concern that airport expansion within
current policy structures will damage the
UK’s ability to keep emissions within
carbon budgets.
✓ The Climate Change Act 2008 set out a 2050 carbon reduction target (80%
reduction versus 1990) for the UK and requires the Committee on Climate Change
(CCC) to put forward for government approval 5 year carbon budgets consistent with
this target. The Act also requires the CCC to monitor and report progress to
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Concern that the country is not achieving
the reduced carbon emissions required
and fail to see how these policies can be
achieved.
✓ Government including providing advice on any remedial actions required. Latest
advice from the CCC indicates that the UK has reduced its greenhouse gas
emissions by 43% compared to 1990 levels and is on the way to a target of at least
80% reduction by 2050 albeit that there is a need for Government to consider further
policies to ensure progress is improved in order to meet the fourth and fifth carbon
budgets. Notwithstanding wider carbon reduction targets that apply at a national
level the ANPS has considered the CCC’s advice on international aviation emissions
and concluded that its policy support for the north west runway option is consistent
with the UK’s climate change obligations.
The proposals send the wrong message
both nationally and internationally.
✓
It is not clear how Heathrow can remain
within the Committee on Climate
Change's recommended assumptions in
respect of carbon emissions, especially
when combined with emissions from
other UK airports. Inadequate information
was provided on this.
✓ The ANPS has considered the advice of the CCC and is supported by in-depth
technical assessment to demonstrate that domestic and international UK aviation
emissions can be consistent with the CCC’s advice with the additional capacity
provided through the north west runway option. This assessment has considered not
only carbon emissions from the north west runway option but also forecast carbon
emissions for all UK airports.
Government has committed to publishing its Aviation Strategy in 2019 setting out its
position on international aviation emissions and UK climate change policy. Opposition to any airport expansion until
the Committee on Climate Change’s
recommendation that government
produce a plan to limit UK aviation
emissions is set in motion.
✓
Concern that there is no
acknowledgement of the facts laid out by
the Committee on Climate Change.
✓
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Mitigation should be included that allows
biodiversity to develop and tolerate
changes in climate.
✓ Heathrow has committed to achieving an overall net gain in biodiversity and this will
include the creation of new and enhanced habitats and management arrangements
(EIA Scoping Report May 2018).
The EIA process will also include consideration of the effects of potential future
changes in climate on the Project itself and on surrounding receptors. This includes,
for example, how the potential effects of airport expansion on biodiversity receptors
could be exacerbated by projected changes in temperature, which will inform
appropriate mitigation measures.
Early findings of the biodiversity and climate change assessments will be reported in
the PEIR to be published as part of the Airport Expansion Consultation in June 2019.
More information should be supplied on
whether Heathrow’s carbon neutral
commitments apply across all of the
Airport Commission/DfT demand
scenarios.
✓ As required by the ANPS, Heathrow will need to demonstrate that the Project will not
result in an increase in emissions so significant that it would have a material impact
on the ability of Government to meet its carbon reduction targets, including carbon
budgets.
Looking beyond this requirement, our long-term aspiration is for growth from the
Project to be carbon neutral. This would mean that growth in emissions from
additional flights after expansion would be offset through carbon credits – resulting in
no net growth in emissions. This aspiration is applicable to actual aircraft
movements rather than Airport Commission of DfT demand scenarios. In December
2018, Heathrow published its plan for carbon neutral growth, and in 2019 will work
with the aviation industry, advocacy groups and climate change experts to seek
further inputs.
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All practicable measures should be taken
to ensure carbon emissions are
minimised at all stages of construction.
✓ Heathrow will employ best practice management and delivery systems to manage
the effects of construction. Detailed measures will be developed to avoid or reduce
the likely impacts of construction on communities and the environment as the Project
develops. As part of the EIA process, a Code of Construction Practice will be
prepared, which will outline how construction activities will be managed. This
document will set out the requirements for mitigation and the monitoring of potential
environmental impacts throughout the construction period. Heathrow will be
consulting on the draft Code of Construction Practice as part of the PEIR which will
be published as part of the Airport Expansion Consultation in June 2019.
Further information requested on where
materials for construction would be
sourced and waste would be disposed.
✓ Heathrow are in the process of developing a baseline for the carbon emissions
associated with construction (known as embodied carbon) and will put in place
measures to reduce these carbon emissions. (This was set out in Our Approach to
Carbon and Climate Change at Airport Expansion Consultation One). We are also in
the process of establishing a set of principles for design and construction to address
the carbon impact of expansion. These currently include using carbon as a key
criterion for determining material choice and minimising the need for virgin materials
and sourcing materials and products locally to where they are used. The Logistics
hubs and use of off-site construction should help to reduce the carbon footprint of
the Project.
Loss of green space should be minimised
as it is critically important for carbon
storage, temperature regulation and flood
mitigation.
✓
As part of Airport Expansion Consultation One (January 2018) Heathrow presented
Our Design Approach to the Natural Environment, which included an approach to
multifunctional green infrastructure to achieve as much environmental and
community benefit as possible. The PEIR that Heathrow will consult on as part of the
Airport Expansion Consultation in June 2019, includes further details in regard to
mitigation proposals.
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There are insufficient details to comment
on at present and urged as much use of
green infrastructure as possible.
✓
No details were provided on how airlines
will be incentivised to deliver low carbon
flights or how it will be policed.
✓
Through variable landing charges, Heathrow charges the highest prices to the
noisiest and highest emitting aircrafts in order to encourage use of the greenest
aircrafts at the airport. Heathrow will continue this approach and is exploring how
this policy may evolve in the future to manage carbon emissions directly associated
with aviation. Further information on the measures proposed to manage carbon
emissions will be included in the PEIR, published as part of the Airport Expansion
Consultation in June 2019. Use and/or incentivise cleaner aircraft,
incentivise low carbon flights and
banning older, more polluting planes.
✓
Suggestions that the fee airlines pay to
operate at the airport should not remain
close to current levels but should reflect
the cost in harm to the environment.
✓
Heathrow should quantify the carbon
emission impacts before and after
mitigation to show its value.
✓ As required by the ANPS, within the ES published alongside the DCO application,
Heathrow will quantify the greenhouse gas impacts of the Project before and after
mitigation, to show the impacts of the proposed mitigation.
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More detail on the approaches that will be
used to limit carbon emissions and
concrete commitments which
demonstrate how Heathrow will
incentivise and monitor progress with
targets and penalties are requested.
✓
The information provided in Airport Expansion Consultation One (January 2018)
reflected the fact that the Project was at an early design stage. We will provide
further detail on mitigation measures aimed at managing carbon dioxide emissions
within the PEIR, published part of our Airport Expansion Consultation in June 2019.
The purpose of the Airport Expansion Consultation One was to provide an early
opportunity to provide feedback on options and components to inform the preferred
masterplan that will be presented as part of the Airport Expansion Consultation in
June 2019.
Concern that the emissions management
measures proposed will only offset or
mitigate in the short term.
✓
Heathrow have considered carbon emissions into the longer term. For example,
Heathrow are developing measures to ensure that the carbon associated with the
construction and operation of the airport itself is managed appropriately, working
towards its goal of operating zero carbon airport infrastructure by 2050. The Air
Quality and Carbon chapters of the PEIR, to be published as part of the Airport
Expansion Consultation in June 2019 will provide further details on the approach to
managing emissions.
Curiosity whether Heathrow would be
interested in exploring environmental
offsetting in the Chilterns, possibly in the
form of improved habitat management
✓ As required by the ANPS, Heathrow will need to demonstrate that the Project will not
result in an increase in emissions so significant that it would have a material impact
on the ability of Government to meet its carbon reduction targets, including carbon
budgets. In this context, we are developing measures to manage gross CO2
emissions, such as encouraging use of the latest (lower emitting) aircraft, uptake of
sustainable fuels and adoption of increasingly sustainable operating practices.
Looking beyond the ANPS requirement, our aspiration is to make growth from the
Project carbon neutral. This would mean that growth in emissions from additional
flights after expansion would be offset through carbon credits – resulting in no net
growth in emissions. Following a historic agreement in 2016 at ICAO, the UN body
Airlines should set aside money to plant
trees to absorb the Co2 as an offsetting
scheme.
✓
Carbon offsetting should be meaningful. ✓
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Carbon offsetting should be the last
resort once all the mitigation has been
implemented.
✓ for international aviation, the industry is working with governments to implement
CORSIA, the world’s first sector wide market-based measure for offsetting the
growth in international aviation emissions after 2020. In December 2018, Heathrow
published its plan for carbon neutral growth, and in 2019 will work with the aviation
industry, advocacy groups and climate change experts to seek further inputs.
We want to play a lead role in developing the next generation of high quality, cost
effective carbon offsetting in the UK. For example, we recently funded a project to
restore 70 hectares of peatland in the north-west of the UK, in partnership with the
Lancashire Wildlife Trust. This pilot scheme will stop this peatland emitting carbon,
and over time sequester it, and deliver other benefits, like more biodiversity value
and a lower risk of flooding downstream. It will help us offset a portion of emissions
from Heathrow’s own infrastructure to achieve our goal of carbon neutral
infrastructure by 2020.
Opposition to the use of carbon
offsetting.
✓
Carbon emission reduction goals should
be taken seriously and that measures to
reduce carbon emissions before
considering off-setting are implemented.
✓
Renewable diesel should be used in both
the operation and the construction of any
part of the airport to limit carbon
emissions.
✓ Heathrow are already putting in place measures to increase the number of low
emission vehicles operating at the airport. This includes replacing all Heathrow cars
and small vans with electric vehicles by 2020 and implementing standards for airside
vehicles in line with the London Ultra Low Emission Zone. We will also adopt
appropriate emission standards during construction of the Project through the Code
of Construction Practice, a draft of which will be published as part of the PEIR in
June 2019.
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Consideration should be given to the
waste hierarchy during operations,
specifically energy generation.
✓ Heathrow are committed to delivering a resource efficient, zero waste airport, as set
out in goal 10.3 of the Heathrow 2.0 sustainability strategy. This will include following
the waste hierarchy (reduce, re-use, recycle) in our approach to waste management
in the design, construction and operation of the Project. Heathrow is also actively
considering options to maximise the generation of renewable energy on-site (with
technologies that are compatible with airport operation) in preparing its masterplan.
Additional details of the carbon and air quality impacts of the project during both
construction operation will be provided in the Carbon and other greenhouse gasses
chapter in the PEIR, to be published as part of the Airport Expansion Consultation in
June 2019.
Effective baseline, monitoring and
periodic targets are important ensure
carbon reduction.
✓ Heathrow is in the process of developing a baseline for the carbon emissions
associated with construction activity, operations (e.g. fuel and energy use), travel to
and from the airport and aircraft movements. This is a critical aspect of the EIA
process and existing and future baseline data will be reported in the PEIR, to be
published in June 2019 as part of the Airport Expansion Consultation. The PEIR will
also include emission projections in the 3-runway scenario, based upon Heathrow’s
proposed mitigation measures.
Heathrow should publish the results of
their air quality assessments as well as
the embodied carbon and emissions
impact.
✓ The PEIR, which will be published in June 2019 as part of the Airport Expansion
Consultation, will report the initial findings of our air quality and carbon and other
greenhouse gases assessments. The PEIR will be followed by the ES, published in
support of the DCO application.
Proposals are based on old technology
and should include measures that ensure
all airport related vehicles are electric.
✓
In accordance with the ANPS, our mitigation proposals for managing potential
emissions associated with the Project will include encouraging use of zero- or low-
emission hybrid or electric vehicles (ultra-low emission vehicles) and providing
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EV infrastructure should be implemented
within and outside the airport to
encourage the adoption of low emission
vehicles.
✓
adequate charging infrastructure across the airport.
We are already putting in place measures to increase the number of low emission
vehicles operating at Heathrow. This includes replacing all Heathrow operated cars
and small vans with electric vehicles by 2020 and implementing standards for airside
vehicles in line with the London Ultra Low Emission Zone.
Limiting emissions and investment into
renewable energy sources is necessary.
✓ ✓ Heathrow’s objective is to develop an expanded airport that minimises carbon in its
operation and construction. This means carbon is a key criterion that informs our
thinking and the design of the Project ensuring, for example, that land is
safeguarded for renewable energy technology and flexibility is built into our designs
to enable new technologies to be adopted in the future.
In the near term, we’re maximising renewable energy generation onsite and already
purchase 100% renewable electricity.
Consideration should be given for
alternative fuel infrastructure especially
for freight transport.
✓
In designing the appropriate infrastructure at an expanded airport, Heathrow are
considering future trends in vehicle technology and fuel use. This includes, for
example, understanding the potential demand for electric vehicle charging
infrastructure in the future and ensuring adequate capacity is provided for both
passengers and those operating at the airport.
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Measures to increase public transport
use are vital to maintaining and reducing
the airport’s carbon emissions.
✓
Heathrow are developing a surface access strategy to meet targets set out in the
ANPS on public transport mode share (at least 50% of surface access passengers
arriving or departing from Heathrow by public transport in 2030 and at least 55% of
surface access passengers arriving or departing from Heathrow by public transport
in 2040), colleague car use reduction (25% reduction of all colleague car trips by
2030 compared with 2013 levels and 50% reduction of all colleague car trips by
2040 compared with 2013 levels) and the commitment that landside airport related-
traffic is no greater than today.
The Surface Access Strategy will include initiatives that improve the physical
infrastructure and the level of service provided to passengers, colleagues and
residents and initiatives that make public transport easier to use and change travel
behaviour more widely. A draft Surface Access Strategy will be published as part of
the Airport Expansion Consultation in June 2019.
There is a need to make surface access
by sustainable transport as attractive and
easy as possible to reduce car use and
the influence on climate change.
✓ Heathrow are developing a surface access strategy to meet targets set out in the
ANPS on public transport mode share (at least 50% of surface access passengers
arriving or departing from Heathrow by public transport in 2030
and at least 55% of surface access passengers arriving or departing from Heathrow
by public transport in 2040), colleague car use reduction (25% reduction of all
colleague car trips by 2030 compared with 2013 levels and 50% reduction of all
colleague car trips by 2040 compared with 2013 levels) and the commitment that
landside airport related-traffic is no greater than today.
The Surface Access Strategy will include initiatives that improve the physical
infrastructure and the level of service provided to passengers, colleagues and
residents and initiatives that make public transport easier to use and change travel
behaviour more widely. A draft Surface Access Strategy will be published as part of
the Airport Expansion Consultation in June 2019.
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NATURAL ENVIRONMENT
Introduction
23.1.1 In response to Airport Expansion Consultation One Heathrow sought feedback in
relation to its proposed approach to managing the effects of the Heathrow
Expansion Project (the Project) on the natural environment. A total of 1,125
consultees made comments relating to this topic.
23.1.2 Heathrow provided the following material that is directly related to managing the
effects of the Project on the natural environment:
1. Airport Expansion Consultation Document;
2. Our Emerging Plans; and
3. Our Design Approach to the Natural Environment.
23.1.3 Heathrow asked the following questions regarding the natural environment at
Airport Expansion Consultation One:
1. Please tell us what you think about our approach to natural
environment issues.
2. Are there any opportunities that the expansion of Heathrow could provide to
enhance the natural environment?
23.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
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23.1.5
Prescribed Consultees
Local Authorities
General comments
23.2.1 Local authorities provided general comments on the proposed approach to the
natural environment and potential enhancement opportunities. The majority of
those that responded considered that the natural environment should be protected
and enhanced. The importance of continued engagement and collaboration with
stakeholders including Natural England and the Environment Agency was also
highlighted.
23.2.2 Ealing Council considered that the approach was generally acceptable. They
supported the need for biodiversity offsetting and suggested that further
enhancements could be achieved through the improvement of local parks and
footpaths, to provide high quality walking and cycling routes for local communities.
23.2.3 Hampshire Services who responded on behalf of Central and Eastern Berkshire
Authorities indicated that high quality mitigation around Heathrow Airport for the
benefit of local communities and wildlife was required and should be implemented.
23.2.4 The London Borough of Islington commented that the social, economic and
environmental impacts of the proposed Heathrow airport growth and growth in air
travel should be examined. They stated that all proposals to expand London
airports and increase air travel should be subjected to a Strategic Environmental
Assessment.
23.2.5 The London Borough of Lambeth expressed concern that there were no costed
mitigation plans to address the environmental impacts of the Project.
23.2.6 Runnymede Borough Council considered that the environmental impacts must be
considered beyond the immediate area of development.
23.2.7 Slough Borough Council also supported the general approach to the natural
environment. They indicated that the overall strategy must retain the integrity and
connectivity of the Colne Valley Park as far as is possible and provide off-site
compensation and mitigation for any permanently used land. They also outlined
that Colnbrook and Poyle villages should be protected within a ‘Green Envelope’12.
12 A network of green spaces protected from development
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23.2.8 The South East England Councils requested a stronger package of environmental
protection measures and requested that Heathrow work with councils in the South
East region.
23.2.9 Spelthorne Borough Council welcomed the consideration of integrated and
connected green infrastructure but expressed concern that this approach should
not result in a reduction in the amount of green infrastructure created or the
focussing of benefits into a very small area.
23.2.10 The London Borough of Sutton commented that it is not clear how the Project
could be anything other than detrimental to the natural environment.
Ecology
23.2.11 Mitigating the effects on ecology and biodiversity was cited by local authorities.
Where this was the case they indicated that the proposed approach to mitigating
the effects was generally acceptable and provided detailed comments or outlined
concerns about specific aspects of the proposals.
23.2.12 Buckinghamshire County Council supported the focus on the Biodiversity Strategy
2020 and the use of net gain, natural capital13 and green infrastructure concepts.
They also welcomed the design of connectivity within the proposals which they
recognised are often not included within major infrastructure projects.
23.2.13 They commented that the use of green infrastructure as the primary basis for
measuring success regarding the environment has potential disadvantages due to
the conflicting objectives. They indicated that the design of multifunctional space
needs careful consideration to avoid these conflicts.
23.2.14 They went on to highlight that the environmental mitigation and enhancements
proposed need to be evidence based, address legislative requirements and
provide general enhancements for wildlife. They also indicated that ecological
surveys and assessments must incorporate all impacted areas including an
adequate buffer.
23.2.15 The London Borough of Ealing supported the need for biodiversity offsetting where
loss or harm to habitats from the Project is unavoidable.
23.2.16 The London Borough of Hammersmith and Fulham commented that the negative
effect of the scheme on biodiversity was not acknowledged in the consultation
information. They expressed concern that the mitigation hierarchy was not being
used and indicated that a much more comprehensive approach is required.
13 the world's stocks of natural assets which include geology, soil, air, water and all living things.
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23.2.17 The London Borough of Hounslow commented that biodiversity offsetting
approaches should not only consider the quantity and quality of the habitats but
also the significance of biodiversity linkages. They highlighted that the potential
indirect impacts and species specific recolonisation potential should also be
considered.
23.2.18 They highlighted that the development is likely to impact habitat used by
designated bat species and suggested that there are various sites east of the
airport that should be considered for bat habitat offsetting.
23.2.19 The Council sought clarity on how the loss of river habitat will be calculated and
offset, how the proposals will be enforced, what baseline will be used and how
progress will be monitored.
23.2.20 Runnymede Borough Council raised similar points about the scope of the
ecological assessments and indicated that wider impacts on nearby designated
sites must be considered e.g. the Thames Basin Heaths Special Protection Area.
23.2.21 Spelthorne Borough Council commented that there was little information specific to
local sites and wildlife which meant an assessment of impacts could not be
undertaken. They indicated that these, together with details of the protected
species for each of the sites, must be made available in future consultations.
23.2.22 They also made the following comments.
1. The diversion of Colne Valley Way through Staines Moor could lead to other
issues such as litter or disturbance to wildlife.
2. Staines Moor contains the oldest known colony of yellow meadow ants in the
whole country and would be affected by any work on the northern end of the
site. As a result, any development in this location would be strongly resisted.
3. Reduction of Bonehead woodland (an area of woodland to the east of Staines
Moor SSSI) would probably lead to the loss of the deer and would reduce the
habitat available to many species of bird.
4. Any work on the Staines Moor floodplain would disturb wildlife and could also
alter the amount of water on the floodplain. This could lead to a change in the
historical composition of habitats and a knock-on reduction in biodiversity.
5. The whole of Staines Moor should be designated as a proposed protected
species site and should not be included within the potential development area.
23.2.23 Surrey County Council expressed concerns about whether compensatory habitats
can be achieved if Compulsory Purchase Order (CPO) powers cannot be used.
They commented that there needs to be further detail on how any habitat
compensation land will be managed and highlighted that wildlife corridors should
be at least 100m wide.
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23.2.24 The Royal Borough of Windsor and Maidenhead highlighted the importance of the
Colne Valley to the Borough and surrounding areas. They questioned how
mitigation would be maintained in the longer term if not part of the Development
Consent Order (DCO) application.
Landscape
23.2.25 The London Borough of Hounslow commented that greening measures would be
likely to bring economic, health and tourism benefits. They also suggested that
mitigation measures to maintain or improve facilities could be part of the ‘quality of
life’ fund proposed by the council to mitigate the effects of the Project on local
communities and could include:
1. tree planting;
2. improvement of nearby green areas;
3. public transport to green areas;
4. free or low cost indoor play places;
5. high intensity play places (e.g. climbing wall) at low cost; and
6. enhanced school green spaces that are accessible after school and on
weekends.
23.2.26 Spelthorne Borough Council commented that Heathrow’s ‘Our Design Approach to
the Natural Environment’ only included a very brief section on landscape and
visual amenity and requested considerably more detail.
Watercourses/Flood risk
23.2.27 Runnymede Borough Council commented that any proposals need to be
considered in a holistic manner, with links to other strategic interventions in the
surrounding area also being considered, for example the River Thames Scheme.
23.2.28 South Bucks District Council commented that new ponds and lakes could benefit
and compensate the local area if done well and queried whether these would be
included in the DCO.
23.2.29 The Royal Borough of Windsor and Maidenhead considered that there was
insufficient information presented to allow an assessment of impacts on
watercourses. They expressed concern that local authorities have not been
consulted on potential sites for flood storage and that the proposals may impact
existing flood alleviation schemes.
Statutory Consultees
General comments
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23.2.30 Natural England and the Environment Agency both welcomed the principles
outlined in Heathrow’s ‘Our Design Approach to the Natural Environment’
document, presented at Airport Expansion Consultation One. They both
emphasised the need for detailed assessments to be undertaken and provided
comments on the proposed approach.
Ecology
23.2.31 Natural England welcomed measures to ensure net gain for biodiversity and
encouraged Heathrow to make a firm commitment. They highlighted that the
biodiversity metric designed by Defra has been used for a number of major
developments and recommended that industry good practice published by CIEEM,
IEMA and CIRIA should be used when designing the approach.
23.2.32 They highlighted a comprehensive suite of biodiversity surveys will be required to
establish current populations of protected species within and around the
development area and the likely impact of the proposals upon them. These will
also inform biodiversity offsetting or net gain calculations.
23.2.33 Natural England indicated that a large number of lakes to the north west of
Heathrow Airport are likely to function as supporting habitat for the South West
London Water Bodies Special Protection Area (SPA). Some of these sites are
likely to be impacted by construction which will need consideration as part of the
Habitats Regulation Assessment (HRA).
23.2.34 The importance of the network of locally protected sites for biodiversity and local
communities was also highlighted and they requested that Heathrow examine
opportunities for enhancing the connectivity of these sites for the benefit of people
and wildlife.
23.2.35 Natural England also highlighted that management and maintenance of green
infrastructure should be integrated into the Project design. This could include
green features, such as green walls, green roofs and green bridges, which would
improve the resilience of the development whilst also protecting the building fabric
from sunlight and temperature fluctuations, reducing costs, reducing noise,
providing visual features of interest, capturing air pollutants and dust and providing
wildlife habitat.
23.2.36 The Environment Agency commented that biodiversity offsetting and environment
net-gain principals should be followed. They considered that rivers should be
defined as having high distinctiveness and condition assessments should use a
wide suite of techniques to measure the biological quality.
23.2.37 They also highlighted that connectivity should be maintained and enhanced for
terrestrial mammals and that unhindered fish migration will help to prevent
ecological impacts outside of the footprint of the Project.
Landscape
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23.2.38 Natural England welcomed the provision of high quality, connected, integrated and
multifunctional green infrastructure and supported the aim of connecting local
people to the natural environment. They highlighted that good quality design will
be required to ensure effective north/south movement within the Colne Valley
Regional Park.
23.2.39 They welcomed the inclusion of landscape design as part of the integrated green
infrastructure aim and indicated that it could deliver additional benefits for
landscape and visual amenity. However, they commented that no details of the
approach to Landscape Visual Impact Assessment were provided and as a result
could not comment.
23.2.40 They also highlighted that the Project may disrupt recreational walking routes and
suggested that Heathrow take account of local authority open space strategies or
rights of way improvement plans to identify possible enhancements.
Watercourses/Flood risk
23.2.41 Natural England commented that water discharged from Heathrow Airport must be
effectively treated and pollutants removed. They highlighted the success of
Mayfield Farm reedbeds (which were installed to treat run-off from Heathrow’s
Southern Catchment) and encouraged the use of similar systems. However, they
suggested that consideration should be given to the integration of drainage and
pollution controls with the green infrastructure masterplan.
23.2.42 They expressed concern that the increase in non-permeable material across the
development site will alter the effects on ground water, aquifer recharge and
connections with river channels. They recommended that existing flows within the
nearby water courses are maintained alongside the use of Sustainable Drainage
System (SuDS).
23.2.43 The Environment Agency expressed concerns that need for long-term monitoring
had not been mentioned.
23.2.44 They indicated that naturalised flow regimes within the modified river channels and
improved connectivity through all channels will be required. They considered that
the issue of connectivity could not be delivered solely through the Colne Brook
diversion option.
23.2.45 They recommended that dimensions of local River channels should be used to
define the physical characteristics of the modified ones. They supported the use of
infiltration SuDS but indicated that a large part of the area of the Project contains
licensed and historic landfills or land which may be affected by contamination. As
a result, infiltration SuDS may not always be an appropriate option.
23.2.46 The Environment Agency also highlighted that the water table is at a very shallow
depth and susceptible to contamination. They specified that if any infiltration SuDS
are proposed for areas where there is a potential for an accidental spill of
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contaminants, such as car parks, then appropriate pollution prevention measures
must be in place.
Other prescribed bodies
General comments
23.2.47 Windlesham Parish Council welcomed the proposed approach to the natural
environment but sought clarification whether Heathrow will maintain the
environment surrounding Project area. The Parish Council also drew attention to
the opportunity to create cycle routes which will encourage visitors and increase
cycling.
23.2.48 Bray Parish Council commented that the aims and intentions towards the natural
environment are commendable but unachievable as existing habitats will be
disturbed and destroyed. They also indicated that the effects of light pollution need
to be considered and requested further consultation.
23.2.49 The Heathrow Strategic Planning Group (HSPG) commented that a health impact
assessment should be central to all environmental considerations and highlighted
that those responsible for local resources should be consulted to design lasting
managed solutions.
Ecology
23.2.50 The HSPG commented that sites designated for nature conservation must be
protected and enhanced. Local wildlife sites and undesignated habitats must be
conserved and enhanced with ongoing monitoring, maintenance and
management. They considered that where loss or harm is unavoidable,
biodiversity off-setting should be provided locally.
23.2.51 They also highlighted that the Green and Blue infrastructure strategy should drive
the design process and be intertwined into all proposals.
23.2.52 Iver Parish Council commented that the Colne Valley Regional Park will be
fundamentally changed by the Project. As a result, they considered that any Green
and Blue Infrastructure Plan should extend to The Ivers.
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Landscape
23.2.53 Albury Parish Council were critical of the focus on the immediate vicinity of
Heathrow and suggested that the natural environment of the Surrey Hills AONB
should be equally respected.
23.2.54 Iver Parish Council commented that landscape mitigation should enhance the local
environment for wildlife and ecology as well as for residents, employees and
visitors. It should also improve site connectivity by land and water wherever
possible. They requested further information on the proposals and expressed
support in principle for the protection and enhancement of green belt land.
Watercourses/Flood risk
23.2.55 The HSPG indicated that Colne Brook should be retained as an open channel with
the other watercourses remaining as open channels as much as possible. They
commented that the Rivers, water bodies and storage are interconnected systems
and need to be considered together. They also requested further information on
surface water run-off and any exceptional release of polluted waters.
23.2.56 Thames Water commented that the best available technology with respect to
water efficiency should be used within all new supporting facilities and terminal
buildings. They also encouraged rain and greywater harvesting and recycling to
meet non-potable water needs. They highlighted that SuDS need to be considered
in the design of drainage for all large areas of hard standing (including car parks).
23.2.57 Iver Parish Council highlighted that strategic corridors are provided in Iver by the
Rivers Colne, Colne Brook, Alderbourne and Horton Brook and their drains and
tributaries. These waterways extend through the Colne Valley and must be
protected and enhanced to counter the effect of culverting and diverting flows
downstream.
23.2.58 They also expressed concern that each proposal is considered as a separate
scheme without an overall view on the impact to surface water, drainage and
flooding.
Local Communities
Members of the public
General
23.3.1 The majority of members of the public that made comments in relation to the
natural environment expressed negative views.
23.3.2 The concerns raised were wide ranging and covered the effects on wildlife habitats
and species, the Green Belt and green open spaces, watercourses, recreational
areas, the landscape and the environment in general.
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23.3.3 Respondents stated that the enhancement of the natural environment would be
impossible given the impacts of the existing airport and the expansion proposals.
Reservations were also expressed about whether the mitigation measures would
ever be delivered.
23.3.4 Respondents expressed support for the preservation and enhancement of the
natural environment. They stated that protecting and mitigating effects on the
natural environment was necessary and fair, that there could be benefits for
habitats and wildlife, that effects on environmentally sensitive and valued sites
should be minimised as far as possible and that sites for development should
avoid important landscapes and designated green belt.
23.3.5 Those that expressed support for the proposals also indicated that more could be
done to protect the natural environment. These were often accompanied by
requests for further detailed information.
Ecology
23.3.6 Comments received either considered that the Heathrow’s approach to the natural
environment would be beneficial for wildlife and people or raised concerns about
wildlife sites or species that would be impacted. The latter included concerns
about the effects on the Colne Valley Regional Park, Crown Meadow, the Thames
Basin SPA, the River Crane, ancient woodland and number of species of wildlife.
23.3.7 Suggestions were also received about the following factors that should be
considered further:
1. more trees should be planted;
2. greater consideration should be given to the impact on wildlife and habitats;
3. new/additional green spaces should be created;
4. any negative impacts should be mitigated as much as possible;
5. experts and environmental groups should be consulted;
6. green spaces should be maintained and managed for the long term;
7. locations proposed for supporting facilities should be turned in to green spaces
and parks after being used for construction;
8. flood storage areas and habitats that may attract birds should be away from the
airport;
9. wildlife parks and a wildlife centre should be created; and
10. contributions should be made to improving a country park along the
River Colne.
Landscape
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23.3.8 Comments on the landscape either highlighted the benefits of the proposals to the
natural environment and local communities or raised concerns that the proposals
failed to consider local people, would result in a loss of green space/recreational
facilities or were generally insufficient.
23.3.9 The following suggestions were also received about factors that should be
considered further:
1. more trees should be planted;
2. consideration should be given to using trees/landscaping and the soil/waste
material as embankments to act as noise barriers;
3. new/additional green spaces should be created;
4. any negative impacts should be mitigated as much as possible;
5. more consideration should be given to the landscape such as creating
parks/parkland landscapes around the airport;
6. new recreational spaces for people should be created;
7. more could be done to improve public walking and cycling access to the natural
environment;
8. dedicated/segregated cycle paths and footpaths should be created;
9. natural/sustainable design measures should be incorporated;
10. attractive landscaping and design would reduce the landscape and visual
impacts of the Project;
11. consideration needs to be given to impacts on the countryside and
enhancement of amenity as part of the approach to the natural environment;
12. green corridors / buffer zones between the airport and neighbouring residential
areas including Stanwell and Stanwell Moor should be retained and enhanced;
13. consideration should be given to creating a botanic garden landscape; and
14. impacts on green/open spaces and the countryside should be minimised.
Watercourses/Flood Risk
23.3.10 Those members of the public that commented on watercourses/flood risk either
expressed concerns about an increased risk of flooding or suggested that
disruption to waterways should be minimised, flood prevention targets should be
promoted or that SuDS should be used.
Businesses
General
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23.3.11 The London Airline Consultative Committee and the Board of Airline
Representatives noted that whilst they were supportive of using the Project as an
opportunity to enhance the natural environment, it should not add delay to the
construction phase, increase risks, costs and complexity to airport users. They
also commented that such proposals should be funded though other mechanisms
that do not pass on costs to airport users.
23.3.12 The Copas Partnership noted the importance of ‘green lungs’ but highlighted that
airports are not a natural environment.
23.3.13 The Arora Group commented that there was insufficient supporting information to
allow further comment and understand the approach taken to date. They identified
that Heathrow had failed to take account of the environmental characteristics of its
alternative development proposals.
23.3.14 The Surrey Chamber of Commerce highlighted that it considered Heathrow had
adopted a responsible approach to the natural environment. They suggested that
an educational centre would provide further enhancement for the natural
environment.
23.3.15 The Hampshire Chamber of Commerce noted that Heathrow is located between
areas of importance for tourism, leisure and heritage. They considered that the
appropriate development of Heathrow Airport could enhance these sectors.
23.3.16 The Thames Valley Chamber of Commerce commented that the Project provides
an opportunity for Heathrow to deliver a step change in the quality of natural and
historic environment in and around the airport. They considered that creating a
positive long-lasting legacy should be a core component of the development.
Ecology
23.3.17 Jayflex Construction Limited commented that in order to maximise environmental
enhancements and biodiversity offsetting proposed on land at Horton Brook
Quarry, the land must be protected from development. It commented that areas of
parkland and open space previously created in the vicinity of the airport suffer from
underuse and neglect, often because of concerns over lack of safe parking,
security and isolation.
23.3.18 They suggested that one possible solution would be to protect the new parkland
area by developing a small area of light industrial units in Horton Brook Quarry
along the Horton Road. This would maintain a continual presence in the area and
create a buffer zone to defend against fly tipping and illegal occupation.
23.3.19 The Thames Valley Chamber of Commerce highlighted that the protection,
enhancement and re-introduction of indigenous species and habitats would be a
long-lasting legacy.
Landscape
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23.3.20 GlaxoSmithKline commented that the proposed cycle route around the airport
could be attractive for its employees provided it is built to a high standard. To
achieve this, they considered that the cycle route needs to be integrated into a
landscape zone and not just placed immediately next to the perimeter road or
airport fence.
Watercourses/Flood risk
23.3.21 The Airport Industrial Property Unit Trust assumed that all proposals concerning
rivers/watercourses will not detrimentally affect any of the assets within their
property portfolio.
Community groups
23.3.22 Many of the community groups who provided feedback to Airport Expansion
Consultation One expressed opposition to the Project but did not necessarily
include specific feedback on the natural environment.
23.3.23 Those that did often raised concerns about the effect of the Project on the natural
environment and the lack of detail or made specific suggestions about aspects of
the environment or factors that should be considered further.
General
23.3.24 Slough and District Against Runway 3, Residents Association HVG, Englefield
Green Action Group, Aircraft Noise Three Villages, St Albans Quieter Skies,
Eastcote Residents Association, Stanwell’s Green Lungs and Colnbrook
Community Association all indicated that the Project will harm the environment
and that this harm will not be offset by the measures proposed.
23.3.25 Wentworth Residents’ Association supported efforts to offset impacts on the
environment but considered that effects cannot be adequately offset.
23.3.26 The Camberley Society highlighted the importance of protecting biodiversity and
wildlife and challenged Heathrow to be one of the 'greenest' airport developments.
23.3.27 Harrow U3A Sustainability Group welcomed measures to maintain continuity of
green space along northern boundary and along the Colne. They considered these
measures essential to prevent discharges into the Colne along the western edge
of airport.
23.3.28 The Richmond Environmental Information Centre considered the plans to be
inadequate and lacking detail.
Ecology
23.3.29 Local Conversation in Stanwell commented that wildlife corridors are visible and
lead into surrounding areas of biodiversity. They considered that the diversion of
Colne Valley Way through Staines Moor could be positive but could lead to other
issues such as litter or disturbance to wildlife.
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23.3.30 They also made the following comments.
1. Staines Moor contains the oldest known colony of yellow meadow ants in the
whole country and would be affected by any work on the northern end of the
site. As a result, any development in this location would be strongly resisted.
2. Bonehead woodland provides a home for many bird species and a small
population of deer. Reduction of this small area of woodland would probably
lead to the loss of the deer and would reduce the habitat available to many
species of bird.
3. Any work on the Staines Moor floodplain would disturb wildlife and could also
alter the amount of water on the floodplain. This could lead to a change in the
historical composition of habitats and a knock-on reduction in biodiversity.
4. The whole of Staines Moor should be designated as a proposed protected
species site and should not be included within the potential development area.
23.3.31 Colnbrook Community Partnership commented that the wildlife corridor through
Crown Meadow is very narrow and would need to be further reduced if river
diversion Option C1F and/or A3044 replacement were to go through Crown
Meadow. They also highlighted that burying the National Grid overhead cables
through Crown Meadow would severely affect the biodiversity value of the site
unless the site were restored and a net gain in biodiversity achieved. The
Partnership also expressed opposition to the diversion of the Colne Valley Way to
the west, commenting that it should follow the alignment of the potential primary
cycle route which appears to be along the Colne Brook.
Landscape
23.3.32 Local Conversation in Stanwell commented that there was only a very brief section
on landscape and visual amenity in the consultation documents and that more
detail is required.
23.3.33 They highlighted that the proposed cycle route appears to connect well to the
surrounding area but that further investment is needed around Stanwell/Stanwell
Moor to connect the current off airport routes with the routes within the airport
boundary. They also commented that the cycle route along the Southern
Perimeter Road should be extended to link up with routes to Terminal 4 and
Bedfont.
Watercourses/Flood risk
23.3.34 Colnbrook Community Partnership highlighted that along the river courses in
Slough (the Horton Brook and the Colne Brook) there are numerous fallen trees in
the water which impede flow, particularly during flood events. They suggested that
the removal of the fallen trees would enhance the natural environment and help to
reduce flood risk and this should be undertaken as part of overall measures to
improve the habitat along the watercourses.
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23.3.35 Eastcote Residents Association commented that the loss of wildlife habitat and
putting rivers underground is unacceptable. They considered that the effects of the
Project on the Colne Valley Regional Park should not be allowed to happen.
Wider/other Consultees
23.4.1 The majority of those that responded indicated support for aspects of the approach
and made specific suggestions about factors or sites that should be considered
further. The importance of engagement with relevant stakeholders in the further
development of the proposals was also highlighted.
General
23.4.2 The Kingston Environment Forum and the World Federalist Party considered the
plans to be inadequate and lacking detail.
23.4.3 The Buckinghamshire and Milton Keynes Natural Environment Partnership
indicated that all aspects of the environment and the benefits it provides to people,
wildlife and the economy should be taken into account in options development and
any future stages of the Project.
23.4.4 They requested that Heathrow commit to a long-term measurable net gain in
biodiversity and make use of a recognised biodiversity accounting metric. They
also highlighted the importance of:
1. early and strategic planning of green and blue infrastructure;
2. minimising the impact on protected areas and land take within wildlife and
recreation areas;
3. employing best practice to integrate biodiversity and green infrastructure into
the design of the development;
4. working closely with environmental stakeholders; and
5. ensuring any works and compensation integrates with existing priorities,
habitats, environmental functions and benefits.
23.4.5 Friends of the River Crane highlighted the need for an overall masterplan for open
spaces covering the whole of the area covered by the consultation exercise. They
cited impacts on the local area, opportunities for improvements and benefits to
local communities and challenges to the preservation of the green belt and
Metropolitan Open Land as reasons for this need. They also commented that the
scope of this masterplan should be developed with key stakeholders.
23.4.6 The Colne Valley Regional Park commented that the Heathrow’s Design Approach
to the Natural Environment document, published at Airport Expansion Consultation
One, is too vague to provide detailed comment.
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23.4.7 The National Trust highlighted the requirements of relevant national, regional and
local planning policy and the need to address the potential impact on the Colne
Valley Regional Park. They expressed concerns that the Project will be likely to
result in significant environmental effects and indicated that they wished to be
consulted on the DCO application and Environmental Impact Assessment
documentation in due course.
23.4.8 The London Parks and Gardens Trust welcomed the inclusion of more
opportunities for the public to visit the proposed landscaped areas. They
suggested that participation in events such as Open Garden Squares Weekend
would go some way to allowing the public a greater understanding of the natural
landscape around the airport.
23.4.9 The London Wildlife Trust and Surrey Wildlife Trust both welcomed Heathrow’s
design approach and commitments to create a positive legacy of better, well
connected green infrastructure and maintain current populations of animals and
plants.
23.4.10 The Royal Parks expressed concern about the effects on grasslands in Richmond
Park, Bushy Park Kensington Gardens, Primrose Hill, Regents Park and
Greenwich Park. They considered that it should be part of the project to improve
the natural habitat surrounding the airport and that green areas should link
together to provide wildlife corridors.
23.4.11 Lambeth/Herne Hill Green Party commented that the approach to the natural
environment needs to be led by Biodiversity Officers and environmental advisers.
23.4.12 The Church of England Diocese of London, Oxford and Southwark welcomed
individual mitigation measures but challenged the idea that the Project provides a
unique opportunity to deliver high quality mitigation. They considered that it would
be better to avoid the harm altogether.
Ecology
23.4.13 London Wildlife Trust noted that many of the proposals were too vague to allow
anything other than generic comments. They commented an overall gain in
biodiversity should be a legally-binding commitment and that they were happy to
work with Heathrow to identify potential sites and strategies to ensure they can be
managed and maintained.
23.4.14 They welcomed the consideration of the All London Green Grid but indicated that
this should also take account of the habitat restoration and creation targets in the
Mayor’s London Environment Strategy, Biodiversity Action Plan targets, the
Wildlife Trusts’ Living Landscapes, and the Crane and Colne catchment plans.
They also highlighted the Colne Valley as an area of significant focus as it is one
of the most affected landscapes by the Project. They suggested that further
information on implications of the proposed flood storage areas/lakes/rivers on bird
strikes should be made available.
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23.4.15 The Hertfordshire and Middlesex Wildlife Trust stated that the proposal must
achieve a measurable net gain to biodiversity. They considered that the ecological
impact of the plans must be fully understood and informed by ecological survey.
23.4.16 They considered that development should not be permitted until all ecological
measures necessary to achieve net gain have been fully secured. They
recommended the establishment of an ecological steering group to review surveys
and guide ecological mitigation, compensation and enhancement.
23.4.17 The Surrey Wildlife Trust also considered that there should be a net gain for
biodiversity and suggested that a commitment to this should be made. They
sought clarity on the purpose of the Potential Protected Species Area and queried
whether this relates to the existing location of protected species or is a designated
refuge for translocated species.
23.4.18 They welcomed the intention to use a natural capital and Ecosystem Services
approach to measure the overarching impacts of the Project on the natural
environment and recommended that Heathrow consider the use of the Surrey
Nature Partnership Natural Capital Investment Plan.
23.4.19 Friends of the River Crane commented that the risk of bird strike results in controls
being put on the habitats around an airport runway. They indicated that these
approaches already impact upon the diversity and management of wildlife habitat
within the river corridors around the airport (including within the Crane corridor)
and assumed that it would be necessary to increase these areas. They highlighted
that such restrictions have a negative impact upon the existing or potential wildlife
management opportunities over a wider surrounding area and this should be
evaluated during the ongoing assessment process.
23.4.20 The Colne Valley Regional Park commented that Heathrow must ensure a net
gain for biodiversity. They indicated that they would be happy to work with
Heathrow to identify potential sites and strategies to ensure they can be managed
and maintained. They also indicated that compensation for the permanent loss of
Colne Valley Regional Park land in the south should be provided by expanding the
Park boundaries.
23.4.21 They also highlighted the need for a Green and Blue Infrastructure Plan and a
number of opportunities for mitigation within the Park. They indicated that the key
elements of the Green and Blue Infrastructure Plan must be included in the DCO
application to ensure they can be delivered, managed and maintained.
23.4.22 The Surrey Bat Group also indicated that a net gain to biodiversity should be
ensured. They indicated that they would like to see surveys (and impact
assessment results) as soon as they become available.
23.4.23 The Buckinghamshire and Milton Keynes Natural Environment Partnership
highlighted the value of green infrastructure and indicated that it must be
considered and planned for. They commented that Heathrow needs to go beyond
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its current commitments and commit to a net biodiversity gain. They also urged
the use of a recognised biodiversity accounting metric, based on the one produced
by Defra.
23.4.24 They indicated that biodiversity offsets should be located locally to maximise the
creation of ecological networks and should consider priority habitats and species,
priority areas for biodiversity and wildlife investment, local wildlife sites and
opportunities to extend, enhance, create and connect habitats and green
infrastructure for wildlife and people.
Landscape
23.4.25 The London Parks and Gardens Trust considered that insufficient account has
been taken of the loss of amenity value for many of the surrounding parkland and
nature rich areas as a result of the increased air traffic. They considered that an
endowment fund, grant scheme or additional flight levy should be set up for
London's public Parks to support their maintenance and enhancement.
23.4.26 The Colne Valley Regional Park commented that open green spaces need to
include walking routes and cycling paths which link with the wider Colne Valley
Park, other green spaces and walking/cycling corridors surrounding the airport.
They indicated that provision of recreational areas should also consider areas
further away which less affected by the airport
23.4.27 They also commented that Heathrow should extend the Colne Valley Trail further
south and explore enhancement of existing sections of the Colne Valley Trail.
Watercourses/Flood risk
23.4.28 Friends of the River Crane commented that there must be no negative impacts
upon water quality in the River Crane and that the risks of pollution minimised
through appropriate planning, design and operational controls.
23.4.29 The Colne Valley Regional Park commented that the proposed flood storage areas
will need to form part of the Green and Blue Infrastructure Plan. They highlighted
that opportunities for constructed wetlands that deliver open green spaces should
be explored and that a fully integrated SuDS, drainage and storm management
strategy is required.
23.4.30 The London Wildlife Trust indicated that the proposed flood storage areas need to
form part of the green infrastructure plan. The suggested that opportunities for
newly created wetlands should be explored that meet water quality standards and
flood requirements whilst also delivering open green spaces.
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23.4.31 The Wildlife Trust also suggested that a fully integrated SuDS, drainage and storm
management strategy within the airport is required and that is should consider
opportunities for integrated green roofs, living walls, and swales14.
23.4.32 Surrey Wildlife Trust challenged the claim that the proposals would protect rivers
and their associated vegetation corridors when over one kilometre of the diverted
rivers would flow beneath the new runway, essentially below ground.
14 Swales are shallow, broad and vegetated channels designed to store and/or convey runoff and remove pollutants
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Issues Raised and Heathrow’s Responses
The table below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Natural Environment. None of the feedback received in relation to Natural Environment are directly
related to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation
(January 2019) but instead relate to other aspects of the Project. The table therefore provides a summary of the way in which
we are seeking to consider the issues raised, and are provided for information only. No further feedback is being sought on the
basis that a full consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.
Table 23.1B
Issue Consultee15 Heathrow Response
PC MC WC
The natural environment should be protected and
enhanced.
✓ The Heathrow Expansion Project (the Project) is being developed in
accordance with the designated Airports National Policy Statement
(ANPS) which identifies the need for the Project to meet additional
airport capacity in the South East of England during the short, medium
and long term. Habitat creation and enhancement proposals will be
designed to ensure that the biodiversity interest of designated sites in
this area will be maintained and where possible, enhanced.
As part of the development of the Project, proposals for landscaping,
It would be better to avoid the harm from the
Heathrow Expansion Project altogether.
✓
Note the importance of ‘green lungs’ but highlighted
that airports are not a natural environment.
✓
15 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Issue Consultee15 Heathrow Response
PC MC WC
The Project provides an opportunity for Heathrow to
deliver a step change in the quality of the natural
environment in and around the airport.
✓ mitigation and compensation works (‘green infrastructure’) are being
developed that will form a network of connected green spaces and
water environments in the vicinity of the Airport. This network will help
provide biodiversity habitats, with Heathrow working to achieve a net
gain in biodiversity.
Heathrow are undertaking an Environmental Impact Assessment (EIA).
This assessment has informed the design of the Project, through an
ongoing evaluation process. Early findings of this process will be
reported in the Preliminary Environmental Information Report (PEIR)
and the Updated Scheme Development Report to be published at the
Airport Expansion Consultation in June 2019.
The delivery of the expanded airport will impact on the existing natural
environment. As part of the process the Project will carry out an
assessment of habitats and species. However, it also presents an
unprecedented opportunity to deliver high quality mitigation for green
infrastructure in the local area. The preferred masterplan which will be
published as part of the Airport Expansion Consultation in June 2019
will include areas which could be landscaped, planted, restored or
enhanced in order to mitigate and off-set the effects of the Project as
far as possible.
Concerns about wildlife sites or species that would
be impacted.
✓
Happy to work with Heathrow to identify potential
sites and strategies to ensure they can be managed
and maintained.
✓ Heathrow are considering a range of options for ecological mitigation,
compensation and enhancement and are engaging stakeholders in the
process. A detailed collaborative and multidisciplinary approach to the
evaluation and selection of options is being undertaken. This includes
engagement with a range of stakeholders including the Heathrow
Strategic Planning Group (HSPG) and Natural England as part of the
EIA as well as consideration of the feedback received in relation to
Airport Expansion Consultation One. Heathrow will present its
preferred option and the early findings of its assessments in the PEIR
that will be published as part of the Airport Expansion Consultation in
Requested that Heathrow work with councils in the
South East.
✓
Recommend the establishment of an ecological
steering group to review surveys and guide
✓
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Issue Consultee15 Heathrow Response
PC MC WC
ecological mitigation, compensation and
enhancement.
June 2019.
Would like to see surveys (and impact assessment
results) as soon as they become available.
✓ Heathrow are considering a range of options and are engaging
stakeholders in the process. A detailed collaborative and
multidisciplinary approach to the evaluation and selection of options is
being undertaken. Heathrow have shared the early findings of the
biodiversity surveys with stakeholders and will present the early
findings of this assessment, information on surveys that have been
undertaken and their findings in the PEIR which will be published as
part of the Airport Expansion Consultation in June 2019.
Participation in events such as Open Garden
Squares Weekend would go some way to allowing
the public a greater understanding of the natural
landscape around the airport.
✓ The government has established the need for the Project within the
ANPS. The ANPS expresses the need for the applicant to ensure the
functionality and connectivity of the green infrastructure is maintained
and to mitigate any adverse impacts where possible.
Heathrow today is actively involved in number of external events and is
open to exploring new events.
Heathrow has a number of existing relationships with local educational
facilities and opportunities to promote further learning about the natural
environment will be with them. The Project also presents an opportunity
to deliver high quality mitigation for communities through green
infrastructure in the local area, taking the consultation responses
received into account and facilities, such as educational or visitor
centres to aid understanding of the natural and historic environment.
Heathrow are considering a range of options and are engaging
stakeholders in the process. A detailed collaborative and
multidisciplinary approach to the evaluation and selection of options is
being undertaken.
Heathrow will present its preferred masterplan and the early findings of
An educational centre would provide further
enhancement for the natural environment.
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Issue Consultee15 Heathrow Response
PC MC WC
this assessment in the Updated Scheme Development Report.
Information on surveys that have been undertaken and their findings
will also be published in PEIR. Both of these documents will form part
of the Airport Expansion Consultation in June 2019.
Concerns that need for long-term monitoring had not
been mentioned.
✓ A draft Biodiversity Off-setting Plan will form part of the Airport
Expansion Consultation in June 2019. The ANPS states that in terms
of off-setting and biodiversity mitigation that areas that will provide the
most ecological and ecosystem service benefits should be focussed
on.
It will include long term management prescriptions, a monitoring
protocol and a method to determine suitable remediation should any be
required.
Welcome the intention to use a Natural Capital and
Ecosystem Services approach to measure the
overarching impacts of the Project on the natural
environment and recommended that Heathrow
consider the use of the Surrey Nature Partnership
Natural Capital Investment Plan.
✓ Heathrow will use the natural capital concept in its approach to
expressing the value of nature to society and the effects of the Project
on the local natural environment. The use of monetary values is not
intended to put a price tag on nature, but to demonstrate one of many
services that the local natural environment provides to communities.
The approach will also include quantitative assessments of natural
capital and ecosystem services to allow for other ways of assisting
decision making on the Project.
During 2018 Heathrow has been developing the Natural Capital
approach and methodology with Natural England based upon the
Natural England draft ecometric. In order to agree our natural capital
approach with Natural England we looked at various industry examples
to help inform that strategy but the approach we are adopting is not that
of the Surrey Nature Partnership Natural Capital Investment Plan.
Supported the focus on the biodiversity strategy
2020 and the use of net gain, Natural Capital and
green infrastructure concepts.
✓
Whilst supportive of using expansion as an ✓ ✓ The delivery of the Project will impact some areas of the existing
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Issue Consultee15 Heathrow Response
PC MC WC
opportunity to enhance the natural environment, it
should not add delay to the construction phase,
increase risks, costs and complexity to airport users.
natural environment and However, Heathrow are considering
opportunities to deliver high quality mitigation for green infrastructure,
biodiversity (wildlife and plants), the landscape and the water
environment (rivers, ponds and streams) for the benefit of both local
communities and wildlife in the local area as part of the Project is a key
aspect of the ANPS. However, any enhancements that are required (in
order to deliver specific mitigation and legal compliance) within or
adjacent to the areas within which construction or operational activity
will be necessary will be designed in-conjunction with the delivery
teams to ensure delays and increased cost can be managed
effectively.
Heathrow also aim to ensure that the expanded airport will operate with
passenger charges staying as close to 2016 levels as possible.
As part of the development of its proposals Heathrow is considering
areas which could be landscaped, planted, restored or enhanced in
order to mitigate and offset the effects of the Project. Further details on
the proposals for landscaping and the enhancement of the natural
environment will be reported in the PEIR which will be published as
part of the Airport Expansion Consultation in June 2019.
It is not clear how expansion could be anything other
than detrimental to the natural environment.
✓ The delivery of the Project will impact the existing natural environment.
However, Heathrow are considering opportunities to deliver high quality
mitigation for green infrastructure, biodiversity (wildlife and plants), the
landscape and the water environment (rivers, ponds and streams), for
the benefit of both local communities and wildlife in the local area. In
accordance with paragraph 5.127 of the ANPS, the Secretary of State
will need to assess whether very special circumstances justify potential
changes to the Green Belt. Heathrow will need to demonstrate that
such circumstances exist for the Project.
The enhancement of the natural environment would
be impossible given the impacts of the existing
airport and the expansion proposals.
✓
Support for the preservation and enhancement of the
natural environment.
✓
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More could be done to protect the natural
environment.
✓ Heathrow are undertaking an EIA, which includes an assessment of
impacts on the natural environment and Green Belt. This assessment
is informing the design of the Project, through an ongoing evaluation
process. Early findings of this process will be reported in the PEIR and
the Updated Scheme Development Report to be published at the
Airport Expansion Consultation in June 2019.
Concerns about the effects on wildlife habitats and
species, the Green Belt and green open spaces,
watercourses, recreational areas, the landscape and
the environment in general.
✓
The Approach to Natural Environment is too vague to
provide detailed comment.
✓ The information provided in Airport Expansion Consultation One
reflected the fact that the Project was at an early design stage. Further
information regarding statutorily and non-statutorily designated sites,
including early findings from our EIA work regarding potential effects
upon them, will be provided will be contained within the PEIR which
forms part of the Airport Expansion Consultation in June 2019.
Paragraph 5.89 of the ANPS expects that the ES submitted with the
Development Consent Order (DCO) sets out clearly the likely
significant impacts on local, national and nationally designated sites
and factors that are of principal importance for the conservation of
biodiversity.
Heathrow’s plans for the natural environment were
inadequate or lacking detail.
✓
Opposition to the expansion of Heathrow and as a
result a number did not make comments on the
natural environment.
✓
Concerns about the effect of expansion on the
natural environment and the lack of detail
✓
Many of the proposals were too vague to allow
anything other than generic comments.
✓
Insufficient supporting information to allow further
comment and understand the approach taken to
date.
✓
Requests for further detailed information. ✓ Consultation documents provided at Airport Expansion Consultation
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Welcomed the consideration of the All London Green
Grid but indicated that this should also take account
of the habitat restoration and creation targets in the
Mayor’s London Environment Strategy, Biodiversity
Action Plan targets, the Wildlife Trusts’ Living
Landscapes, and the Crane and Colne catchment
plans.
✓ One provided information early in the design and assessment process,
focused on design components and options. Heathrow recognised the
need for strategic ecological corridors and biodiversity rich habitats,
including ones to enable connectivity between the Colne and Crane
Valleys. Opportunities for the provision of such corridors and habitats
are being explored and designed to reflect local context and to support
and enhance the flora and fauna characteristic of the area in
developing the Project.
Heathrow are undertaking an EIA, which includes an assessment of
effects on biodiversity. This assessment has informed the design of the
Project, through an ongoing evaluation process. Early findings of this
process will be reported in the PEIR to be published at the Airport
Expansion Consultation in June 2019.
Employing best practice to integrate biodiversity and
green infrastructure into the design of the
development.
✓
Good quality design will be required to ensure
effective north/south movement within the Colne
Valley Regional Park.
✓
All proposals to expand London airports and
increase air travel should be subjected to a Strategic
Environmental Assessment.
✓ As required by the Planning Act 2008, the Government has produced
an Appraisal of Sustainability in relation to the ANPS. The Appraisal of
Sustainability describes the analysis of the reasonable alternatives to
the Project and has informed the development of the ANPS by
assessing the potential environmental, economic and social impacts of
options to increase airport capacity. The Appraisal of Sustainability also
incorporates a Strategic Environmental Assessment, which assesses
12 environmental topics. It describes the analysis of reasonable
alternatives to the preferred scheme. The Appraisal of Sustainability
informs the development of the ANPS by assessing the potential
economic, social and environmental impacts of options to increase
airport capacity.
The ANPS states at paragraph 1.29 that “the overall conclusions of the
Appraisal of Sustainability show that (provided any scheme remains
within the parameters and boundaries in this policy), whilst there will be
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inevitable harm caused by a new Northwest Runway at Heathrow
Airport in relation to some topics, the need for such a scheme, the
obligation to mitigate such hard as far as possible, and the benefits that
such as scheme will deliver, outweigh such harm. However, this is
subject to the assessment of the effects of the preferred scheme,
identification of suitable mitigation, and measures to secure and deliver
the relevant mitigation.” The independent Airports Commission
explored potential alternatives to additional runway capacity, which
included: redistribution methods, for example changing the rate of air
passenger duty; investment in high speed rail and improved surface
access options; and new technologies. The Airports Commission found
that none of these options delivered a sufficient increase in capacity,
and that many required investment far in excess of the cost of runway
expansion. The Airports Commission did note that the need to make
best use of existing infrastructure would remain. (Airports Commission
Final Report, paragraph 16.1 and 16.40). The ‘Environmental
Assessment of Plans and Programmes Regulations 2004’ which
implement the requirements of the European Directive 2001/42/EC (the
‘Strategic Environmental Assessment Directive’) set out the
requirements for an assessment of the effects of certain plans and
programmes on the environment.
The Project will be subject to a DCO application and supported by an
ES in accordance with Infrastructure Planning EIA Regulations 2017.
The Project does not constitute a ‘plan’ or ‘programme’ as is defined by
the Environmental Assessment of Plans and Programmes Regulations
2004.
A comprehensive suite of biodiversity surveys will
be required to establish current populations of
✓ As part of the EIA Heathrow is undertaking a range of ecological
surveys and assessments. The survey work and assessments being
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protected species within and around the
development area and the likely impact of the
proposals upon them.
undertaken are compliant with the CIEEM Guidelines for Ecological
Impact Assessment.
A series of method statements describing the field survey programme
will be included in the PEIR to be published as part of the Airport
Expansion Consultation in June 2019. The methodologies are based
on relevant guidance and have been formally agreed with Natural
England. Further information regarding statutorily and non-statutorily
designated sites, including potential effects upon them, will be provided
within future consultation information and the ES.
The negative effect of the scheme on biodiversity
was not acknowledged in the consultation
information.
✓
The biodiversity metric designed by Defra has been
used for a number of major developments and
recommended that industry good practice published
by CIEEM, IEMA and CIRIA should be used when
designing the approach.
✓
Ecological surveys and assessments must
incorporate all impacted areas including an adequate
buffer.
✓
The ecological impact of the plans must be fully
understood and informed by ecological survey.
✓
Urge the use of a recognised biodiversity accounting
metric, based on the one produced by Defra.
✓ Heathrow are undertaking an EIA, which includes an assessment of
effects on biodiversity. Paragraph 5.96 of the ANPS confirms that the
DCO must make provision for the long term management of
biodiversity measures. The ANPS also expects that full advantage of
and maximised opportunities to conserve biodiversity and geological
conservation interests have been taken. The approach being taken
forward for biodiversity accounting by the Project has been agreed with
Natural England and other stakeholders. It seeks to deliver high value
biodiversity habitats by ensuring that losses are accounted for through
the provision of offsets that have a biodiversity value that is the same,
Request that Heathrow commit to a long-term
measurable net gain in biodiversity and make use of
a recognised biodiversity accounting metric.
✓
An overall gain in biodiversity should be a legally-
binding commitment
✓
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Heathrow must ensure a net gain for biodiversity. ✓ or greater than the area lost. Flexibility in the approach to the delivery
of net gain will be maintained to consider projects identified by local
stakeholders on their merits. This approach is consistent with Defra’s
guidance which encourages replacement of high value habitats with
similar habitat types and avoids issues associated with the acquisition
of sites (including use of compulsory purchase powers).
The approach to biodiversity accounting and proposals for
compensation land will be provided as part of the DCO application.
The PEIR to be published as part of the Airport Expansion Consultation
in June 2019, will provide more information on these matters.
Development should not be permitted until all
ecological measures necessary to achieve net gain
have been fully secured.
✓
The importance of protecting biodiversity and
wildlife and challenged Heathrow to be one of the
'greenest' airport developments.
✓
A net gain to biodiversity should be ensured. ✓
The aims and intentions towards the natural
environment are commendable but unachievable as
existing habitats will be disturbed and destroyed.
✓
There should be a net gain for biodiversity and
suggested that a commitment to this should be
made.
✓
Heathrow needs to go beyond its current
commitments and commit to a net biodiversity gain.
✓
Concerns about whether compensatory habitats can
be achieved if CPO powers cannot be used.
✓
Ensuring any works and compensation integrates
with existing priorities, habitats, environmental
functions and benefits
✓
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There needs to be further detail on how any habitat
compensation land will be managed and highlighted
that wildlife corridors should be at least 100m wide.
✓
New ponds and lakes could benefit and compensate
the local area if done well and queried whether these
would be included in the DCO.
✓
Burying the National Grid overhead cables through
Crown Meadow would severely affect the biodiversity
value of the site unless the site were restored and a
net gain in biodiversity achieved.
✓ Crown Meadow and Horton Brook Quarry provide an opportunity for
enhancing the biodiversity. These sites, amongst others, are being
considered during the design process for green infrastructure.
As part of the development of the Project, Heathrow will continue to
work with stakeholders such as National Grid and land owners to
ensure that property affected by associated developments will be
considered appropriately and mitigation measures, such as green
infrastructure to offset the effects of the proposals, can be employed if
necessary. Crown Meadow is a valuable local public open space and
the project is not looking to locate development on it. Crown Meadow
does provide an opportunity for enhancing biodiversity and this is being
actively considered during the design process for green infrastructure.
In order to maximise environmental enhancements
and biodiversity offsetting proposed on land at
Horton Brook Quarry the land must be protected
from development.
✓
The wildlife corridor through Crown Meadow is very
narrow and would need to be further reduced if river
diversion Option C1F and/or A3044 replacement were
to go through Crown Meadow.
✓
The approach to the natural environment needs to be
led by Biodiversity Officers and environmental
advisers.
✓ Heathrow’s approach to the natural environment is being designed by
environmental specialists. Ongoing engagement with stakeholders,
such as Natural England and the Environment Agency, on matters
related to the natural environment is required to ensure that the
approaches and measures being proposed, as part of the EIA process,
are suitable and effective across a wide range of subject matters.
The proposed approach to the natural environment will be set out in the
PEIR which will be published as part of the Airport Expansion
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Consultation in June 2019.
Support for the need for biodiversity offsetting and
suggested that further enhancements could be
achieved through the improvement of local parks
and footpaths, to provide high quality walking and
cycling routes for local communities.
✓ The delivery of the Project will impact the existing natural environment.
However, Heathrow are considering opportunities to deliver biodiversity
offsetting areas (for wildlife, habitats and linkages between habitats)
and high-quality mitigation (including re-colonisation) for biodiversity
(wildlife and plants), the landscape and the water environment (rivers,
ponds and streams), for the benefit of both local communities and
wildlife in the local area.
Biodiversity offsetting calculations will be undertaken to demonstrate
the delivery of net gain by the Project. The mechanism to achieve this
has been agreed with Natural England and the Environment Agency.
Heathrow are considering a range of options and are engaging
stakeholders within the Colne Valley Regional Park and
Buckinghamshire in the process. The EIA that Heathrow are
undertaking, in accordance with best practice guidance, policy and
legislation, includes an assessment of direct and indirect impacts on
the environment and communities. The initial findings relating to
specific impacts and mitigation for the resources identified will be
reported in the PEIR to be published as part of the Airport Expansion
Consultation in June 2019.
Biodiversity offsets should be located locally to
maximise the creation of ecological networks and
should consider priority habitats and species,
priority areas for biodiversity and wildlife investment,
local wildlife sites and opportunities to extend,
enhance, create and connect habitats and green
infrastructure for wildlife and people.
✓
Supported efforts to offset impacts on the
environment but considered that effects cannot be
adequately offset.
✓
Welcome the provision of high quality, connected,
integrated and multifunctional green infrastructure
and supported the aim of connecting local people to
the natural environment.
✓
Supported the need for biodiversity offsetting where
loss or harm to habitats from expansion is
unavoidable.
✓
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Expansion will harm the environment and that this
harm will not be offset by the measures proposed.
✓
Biodiversity offsetting approaches should not only
consider the quantity and quality of the habitats but
also the significance of biodiversity linkages.
✓
Biodiversity offsetting and environment net-gain
principles should be followed.
✓
Where loss or harm is unavoidable, biodiversity off-
setting should be provided locally.
✓
The potential indirect impacts and species specific
re-colonisation potential should also be considered.
✓
The development is likely to impact habitat used by
designated bat species and suggested that there are
various sites to east of the airport that should be
considered for bat habitat offsetting.
✓
Clarity is required on how the loss of river habitat
will be calculated and offset, how the proposals will
be enforced, what baseline will be used and how
progress will be monitored.
✓
The need for detailed assessments to be undertaken
and provided a number of comments on the
proposed approach.
✓
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The project should include measures to improve the
natural habitat surrounding the airport and create
wildlife habitat linked together to form wildlife
corridors.
✓
Welcomed measures to ensure net gain for
biodiversity and encouraged Heathrow to make a
firm commitment.
✓
It should be part of the project to improve the natural
habitat surrounding the airport and that green areas
should link together to provide wildlife corridors.
✓
High quality mitigation around the airport for the
benefit of local communities and wildlife was
required and should be implemented.
✓ The government has established the need for the Project within the
ANPS. The Project presents an opportunity to deliver high quality
mitigation through green infrastructure in the local area, taking the
consultation responses into account. In accordance with the ANPS,
the Secretary of State will need to be satisfied that the proposed
landscaping measures are appropriate and deliverable when
determining the DCO application.
A detailed collaborative and multidisciplinary approach to the
evaluation and selection of options is being undertaken. This has
included engagement with a range of stakeholders as part of the EIA
as well as taking into account the consultation responses received in
relation to Airport Expansion Consultation One. Heathrow will present
its preferred option and the early findings of this assessment in the
Updated Scheme Development Report. Information on surveys
undertaken and their findings will be published in the PEIR. Both
documents will be published as part of the Airport Expansion
Challenged the idea that expansion provides a
unique opportunity to deliver high quality mitigation.
✓
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Consultation in June 2019.
Concern that there were no costed mitigation plans
to address the environmental impacts of expansion.
✓ In accordance with the ANPS the mitigation hierarchy is being used
within the design process to ensure that negative impacts on
biodiversity are limited as far as possible. Potential effects on SSSIs
will be assessed in detail within the EIA.
Consultation documents provided at Airport Expansion Consultation
One provided information early in the design and assessment process,
focused on design components and options in relation to a number of
aspects of the development still under consideration, this included the
approach to mitigation and environmental protection measures.
Heathrow are undertaking an EIA of the Project, and early findings will
be reported in the PEIR to be published as part of the Airport
Expansion Consultation in June 2019. That process will enable
Heathrow to provide the initial information on the detail, quantity and
cost of mitigation and protection measures.
The proposed approach to mitigating the effects was
generally acceptable.
✓
Concern that the mitigation hierarchy is not being
used and indicated that a much more comprehensive
approach is required.
✓
Requested a stronger package of environmental
protection measures.
✓
Concerns that expansion will be likely to result in
significant environmental effects.
✓
Questioned how mitigation would be maintained in
the longer term if not part of the DCO application.
✓ The maintenance of habitats created for the Project will be over the
long term, as specified within the Defra guidance on biodiversity
offsetting. The definition of "long term" is a topic of discussion with
Natural England and will continue to be as the green infrastructure
design progresses. This discussion will continue as individual land
owners and organisations where habitat creation and management will
be proposed will have their own views on the definition of long term.
The Masterplan Scheme Development Manual include a wide range of
considerations in the evaluation criteria used for appraising different
options and masterplan components, including sustainability and
impacts on communities. The ANPS requires at paragraph 4.31 “a
good design should meet the principal objectives of the scheme by
Reservations about whether the mitigation measures
would ever be delivered.
✓
Local wildlife sites and undesignated habitats must
be conserved and enhanced with ongoing
monitoring, maintenance and management.
✓
Clarification whether Heathrow will maintain the
environment surrounding the expansion area.
✓
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eliminating or substantially mitigating the adverse impacts of the
development, for example by improving operational conditions. It
should also mitigate any existing adverse impacts wherever possible,
for example in relation to safety or the environment”.
The DCO application will comply with this. In addition, an ES will form
part of the DCO application to explain how Heathrow will identify and
mitigate any likely significant environmental effects during construction
and operation of the airport. Early findings of this process will be
reported in the PEIR to be published at the Airport Expansion
Consultation in June 2019.
Mitigation measures to maintain or improve facilities
could be part of the ‘quality of life’ fund to include
• tree planting;
• improvement of nearby green areas;
• public transport to green areas;
• free or low cost indoor play places;
• high intensity play places (e.g. climbing wall) at low cost; and
• enhanced school green spaces that are accessible after school and on weekends.
✓ Any natural environment proposals for mitigation will be funded by a
contribution payable under a legally binding planning agreement.
The Our Design Approach to the Natural Environment document
presented at Airport Expansion Consultation One set out Heathrow’s
plans in relation to the natural environment. Currently, no areas have
been designated for any specific use. However, Heathrow are
identifying areas that could form part of a high quality, multi-functional
green infrastructure network with good connections to the places where
people live and work. Heathrow are aiming to provide a richly varied
landscape that will benefit both people and wildlife, providing diverse
uses, accessible to all.
Further information will be contained within the PEIR, identifying the
plans for the future provision of green space around the airport which
will form part of the Airport Expansion Consultation in June 2019.
Landscape mitigation should enhance the local
environment for wildlife and ecology as well as for
residents, employees and visitors.
✓
The mitigation and enhancements proposed need to
be evidence based, address legislative requirements
and provide general enhancements for wildlife.
✓
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Factors that should be considered further relating to
landscape:
• more trees should be planted;
• consideration should be given to using
trees/landscaping and the soil/waste material as
embankments to act as noise barriers;
• new/additional green spaces should be created;
• any negative impacts should be mitigated as
much as possible;
• more consideration should be given to the
landscape such as creating parks/parkland
landscapes around the airport;
• new recreational spaces for people should be
created;
• more could be done to improve public walking
and cycling access to the natural environment;
• dedicated/segregated cycle paths and footpaths
should be created;
• natural/sustainable design measures should be
incorporated;
• attractive landscaping and design would reduce
the landscape and visual impacts of expansion;
• consideration needs to be given to impacts on
the countryside and enhancement of amenity as
part of the approach to the natural environment;
• green corridors / buffer zones between the
airport and neighbouring residential areas
including Stanwell and Stanwell Moor should be
retained and enhanced;
• consideration should be given to creating a
✓
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botanic garden landscape; and
• impacts on green/open spaces and the
countryside should be minimised.
The risk of bird strike results in controls being put on
the habitats around an airport runway. These
approaches already impact upon the diversity and
management of wildlife habitat within the river
corridors around the airport (including within the
Crane corridor) and assumed that it would be
necessary to increase these areas. Such restrictions
have a negative impact upon the existing or potential
wildlife management opportunities over a wider
surrounding area and this should be evaluated
during the ongoing assessment process.
✓ Proposals for mitigation and enhancement will be designed to minimise
the risk of bird-strike. Areas away from an operational airport provide
opportunities to promote biodiversity in locations where the risk of bird-
strike is reduced.
Management of wildlife strike risk will focus on creating habitats that
will not attract the species (e.g. Canada goose) considered to be a risk.
Where there are areas that need greater levels of management (e.g.
use of netting) the design will focus on ensuring that the exclusion of
risk species does not prevent usage by other species (e.g. bats).
Further information will be contained within the PEIR, identifying the
plans for the future provision habitats and wildlife management areas
around the airport which Heathrow are consulting on as part of the
Airport Expansion Consultation in June 2019. That further information on implications of the
proposed flood storage areas/lakes/rivers on bird
strikes should be made available.
✓
Request for further information on the proposals for
each of the sites and expressed support in principle
for the protection and enhancement of green belt
land.
✓ The Project will require areas of Green Belt land. Where possible
Heathrow will seek to minimise the amount of Green Belt which is
required.
As set out at paragraph 5.127 of the ANPS, the Secretary of State, as
the decision maker on the DCO application, will need to assess
whether there are very special circumstances to justify development on
areas of Green Belt land.
Impacts on the local area, opportunities for
improvements and benefits to local communities and
challenges to the preservation of the Green Belt and
Metropolitan Open Land are all reasons for an overall
masterplan.
✓
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Protecting and mitigating effects on the natural
environment was necessary and fair, that there could
be benefits for habitats and wildlife, that effects on
particular sites and locations should be minimised
as far as possible and that sites for development
should avoid important landscapes and Green Belt.
✓
Wider impacts on nearby designated sites must be
considered e.g. the Thames Basin Heaths Special
Protection Area.
✓ As part of the development of the Project Heathrow is seeking to
minimise the requirement for additional land take, including that within
wildlife and recreation areas wherever practicable.
The ANPS requires an ES to be submitted as part of the application
which describes any likely impact on protected areas, species, and
habitats that are considered of principal importance for the
conservation of biodiversity. Habitat creation and enhancement
proposals will be designed to ensure that the biodiversity interest of
designated sites in this area will be maintained and where appropriate
enhanced.
Proposals for landscaping, mitigation and compensation works (‘green
infrastructure’) are being developed that will form a network of
connected green spaces and water environments in the vicinity of the
airport. This network will help provide biodiversity habitats, with
Heathrow aiming to achieve a net gain in biodiversity.
Sustainability considerations are sub-divided into environmental topic
areas, with the consideration of potential biodiversity impacts being
guided by the following criteria: 1) Impacts on protected sites for nature
conservation (e.g. Special Protection Area (SPA), Sites of Special
Scientific Interest (SSSI), Site of Importance for Nature Conservation
(SINC)) 2) Impacts on designated Ancient Woodland 3) Impacts on
Sites designated for nature conservation must be
protected and enhanced.
✓
Minimising the impact on protected areas and land
take within wildlife and recreation areas.
✓
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priority habitats and species.
A Habitats Regulations Appraisal Screening Report will be published at
the Airport Expansion Consultation in June 2019. It will consider the
potential for significant effects on the Thames Basin Heaths SPA.
Clarity on the purpose of the Potential Protected
Species Area and queried whether this relates to the
existing location of protected species or is a
designated refuge for translocated species.
✓ For some legally protected species, there will be a need to translocate
populations from land located within the area that will be affected by
the Project. For example, habitat creation works can apply to land
where there is a need for major earthmoving work to create flood
storage areas. The sites to which translocated animals would be
relocated could be located in habitat creation areas where major
earthmoving work is not required. Where necessary, habitat creation
and management works will be undertaken in advance of translocation
in order to ensure that the chosen locations are sufficiently mature to
be effective as receptor sites.
Heathrow are undertaking an EIA, which includes an assessment of
impacts on protected species. This assessment is being used to inform
the design of the Project, through an ongoing evaluation process. Early
findings of this process will be reported in the PEIR to be published at
the Airport Expansion Consultation in June 2019.
Details of the protected species for each of the sites
must be made available in future consultations.
✓
The network of locally protected sites for biodiversity
and local communities was also highlighted and they
requested that Heathrow examine opportunities for
enhancing the connectivity of these sites for the
benefit of people and wildlife.
✓
Protect the new parkland area by developing a small
area of light industrial units in Horton Brook Quarry
along the Horton Road.
✓ It is unclear how the development of light industrial units within Jayflex
Quarry would result in the protection of new parkland. However, any
parkland design will be developed on the basis that function and form
are not compromised by neighbouring land uses.
The delivery of the Project will impact the existing natural environment.
However, it also presents an unprecedented opportunity to deliver high
quality mitigation for green infrastructure in the local area.
Through the development of carefully considered and integrated
Concern about the effects on grasslands in
Richmond Park, Bushy Park, Kensington Gardens,
Primrose Hill, Regents Park and Greenwich Park.
✓
Insufficient account has been taken of the loss of ✓
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amenity value for many of the surrounding parkland
and nature rich areas as a result of the increased air
traffic.
natural and built environment proposals, the expanded Airport seeks to
provide positive contributions to the local landscape and views, where
opportunities arise. The draft masterplan will propose areas which
could be landscaped, planted, restored or enhanced in order to mitigate
and off-set the effects of the Project, including those upon habitats, as
far as possible. Heathrow are undertaking an EIA, which includes an
assessment of impacts on public open space. This assessment is
informing the design of the Project, through an ongoing evaluation
process.
The Open Space Assessment carried out to support the DCO will
identify the scale and location of the public open space affected by the
Project. The ANPS requires the preferred scheme to be carried out to
high environmental standards and, where possible, includes measures
to enhance other aspects of the environment. As part of the landscape
mitigation strategy the re-provision of public open space affected by the
Project including parks will be required. The locations of new public
open space will be detailed during the Airport Expansion Consultation
in June 2019 following consultations with the LPAs. Early findings of
this process will be reported in the PEIR to be published at the Airport
Expansion Consultation in June 2019.
The need for an overall Masterplan for open spaces
covering the whole of the area covered by the
consultation exercise.
✓
The scope of this Masterplan should be developed
with key stakeholders
✓
Critical of the focus on the immediate vicinity of
Heathrow and suggested that the natural
environment of the Surrey Hills AONB should be
equally respected.
✓ The Project would not physically affect the Surrey Hills AONB and any
tranquility effects would relate to airspace change rather than ground-
based infrastructure or development proposals.
The DCO application for the Project cannot pre-determine flight paths
(which are subject to a separate consenting process), however an aim
of airspace change is to minimise impacts on the Area of Outstanding
Natural Beauty (AONB). More information on AONBs will be provided
within the Landscape and Visual Impact Assessment (LVIA) Chapter of
PEIR during the Airport Expansion Consultation in June 2019.
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A health impact assessment should be central to all
environmental considerations and highlighted that
those responsible for local resources should be
consulted to design lasting managed solutions.
✓ To meet the statutory and policy requirements, Heathrow are preparing
a health impact assessment (HIA) which will identify, assess and
manage any health impacts caused by the DCO Project. The HIA will
also take account of Chapter 12 of the EIA Scoping Report which sets
out the approach to the assessment on human health (including
children’s health). Section 12.4 of the EIA Scoping Report explains how
the study area used for the purposes of the assessment is to be
determined.
Drawing on the analysis in the HIA, the Environmental Statement will
report on the likely significant health effects and the measures taken by
the DCO Project to enhance positive health effects and reduce
negative health effects. The HIA will be reported as an appendix to the
health chapter of the Environmental Statement.
Heathrow will continue to work with a number of stakeholders such as
Natural England, the Environment Agency, and London Wildlife Trust to
look into good practice as well as the latest techniques and technology
in which to implement within our proposals for the natural environment.
Details of these engagements will be provided within the Consultation
Report submitted as part of the DCO application.
✓
There was insufficient information presented to allow
an assessment of impacts on watercourses.
✓ As part of Airport Expansion Consultation One numerous options for
the diversion of rivers were presented in the Airport Expansion
Consultation Document and Our Emerging Plans.
As part of the further refinement of the proposals and the EIA detailed Concerns about an increased risk of flooding ✓
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Disruption to waterways should be minimised, flood
prevention targets should be promoted or that SuDS
should be used.
✓ consideration is being given to the risk to flooding and the potential to
increase the risk of flooding. This will be presented in the flood risk
assessment that will accompany Heathrow’s DCO application.
Heathrow are undertaking an EIA, which includes an assessment of
impacts on watercourses. This assessment has informed the design of
the Project, through an ongoing evaluation process. A detailed
evaluation considering a range of criterion is also being undertaken to
identify the preferred location and routes for river diversions, taking into
account consultation responses.
Early findings of this process will be reported in the PEIR and the
Updated Scheme Development Report to be published at the Airport
Expansion Consultation in June 2019.
Along the river courses in Slough (the Horton Brook
and the Colne Brook) there are numerous fallen trees
in the water which impede flow, particularly during
flood events.
✓
The removal of the fallen trees would enhance the
natural environment and help to reduce flood risk
and this should be undertaken as part of overall
measures to improve the habitat along the
watercourses.
✓
Rivers should be defined as having high
distinctiveness and condition assessments should
use a wide suite of techniques to measure the
biological quality.
✓
Water discharged from the airport must be effectively
treated and pollutants removed.
✓ Heathrow recognise that the use of infiltration-based Sustainable
Drainage Systems (SuDS) will be constrained by the risk of pollution to
shallow groundwater. Pollution prevention measures will be applied so
that water discharged from the airport will be effectively treated and
pollutants removed. The draft Code of Construction Practice (CoCP) for
the Project will influence the approach to water discharges that may
occur during construction. The draft CoCP will be developed in
conjunction with stakeholders, such as the Environment Agency and
will form part of the DCO application.
Recommended that existing flows within the nearby
water courses are maintained and the use of
Sustainable Drainage Systems.
✓
A large number of lakes to the north west of the ✓ Heathrow is preparing a Habitats Regulations Assessment (HRA)
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airport are likely to function as supporting habitat for
the South West London Water Bodies SPA. Some of
these sites are likely to be impacted by construction
which will need consideration as part of the HRA.
Screening Report. The purpose of the Screening Report is to identify
the likely impacts of the Project, either alone or in combination with
other projects, upon European sites and to determine (in consultation
with statutory consultees) whether these impacts are likely to be
significant or uncertain – in either case Appropriate Assessment will be
required. The HRA Screening Report will be published as part of the
Airport Expansion Consultation in June 2019. The HRA will include
consideration of likely significant effects on supporting habitats.
Concern that the increase in non-permeable material
across the development site will alter the effects on
ground water, aquifer recharge and connections with
river channels.
✓ Heathrow are committed to protecting the quality of the water
environment. Heathrow are considering a range of options and are
engaging stakeholders in the process. Heathrow will present its
preferred option at the Airport Expansion Consultation in June 2019.
The objectives of the Water Framework Directive (WFD), which are
reiterated in the ANPS, are being taken into account.
The proposed masterplan will be designed to protect and enhance the
biodiversity associated with the water environment as far as possible.
More information will be provided the PEIR to be published as part of
the Airport Expansion Consultation in June 2019.
There must be no negative impacts upon water
quality in the river and that the risks of pollution
minimised through appropriate planning, design and
operational controls.
✓
Naturalised flow regimes within the modified river
channels and improved connectivity through all
channels will be required.
✓ The Project will extend the airport's footprint into the Colne Valley, in
the path of existing alignments of watercourses and areas of floodplain
storage.
It is proposed that the Duke of Northumberland’s River and the
Longford River are combined in one channel underneath the runway,
before being returned to their current channels and flow conditions
downstream of the expanded airfield.
An extensive and detailed evaluation of potential sites has been
undertaken in order to identify the preferred location and routes of the
Colne Brook should be retained as an open channel
other watercourses remaining as open channels as
much as possible.
✓
The issue of connectivity could not be delivered
solely through the Colne Brook diversion option.
✓
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Strategic corridors are provided in Iver by the Rivers
Colne, Colne Brook, Alderbourne and Horton Brook
and their drains and tributaries. These waterways
extend through the Colne Valley and must be
protected and enhanced to counter the effect of
culverting and diverting flows downstream.
✓ river diversions and flood storage areas, taking into account the
consultation responses. Heathrow believe that the proposals provide
the most sustainable balance between being appropriately located,
requiring an acceptable level of land take, and minimising impacts upon
the environment and communities as far as possible. More information
will be provided within the PEIR to be published as part of the Airport
Expansion Consultation in June 2019.
Opposition to the diversion of the Colne Valley Way
to the west, commenting that it should follow the
alignment of the potential primary cycle route which
appears to be along the Colne Brook.
✓
Rivers, water bodies and storage are interconnected
systems and need to be considered together.
✓
Opportunities for newly created wetlands should be
explored that meet water quality standards and flood
requirements whilst also delivering open green
spaces.
✓ Heathrow are committed to aiming to achieve an overall net gain in
biodiversity and this will include the creation of new and enhanced
habitats (including wetlands and marshlands.
Heathrow are committed to protecting the quality of the water
environment and working with the Environment Agency and other third
parties to deliver appropriate solutions.
The masterplan is being designed to accord with the environmental
objectives of the WFD, which are reiterated in the ANPS. In this regard,
one of the emerging scheme’s overall aims is to prevent the
deterioration in status of water bodies, and not to jeopardise the future
achievement of good status for any affected water bodies. The
proposed masterplan is also being designed to protect and enhance
the biodiversity associated with the water environment as far as
possible.
More information will be provided within the PEIR to be published as
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part of the Airport Expansion Consultation in June 2019.
Welcome measures to maintain continuity of green
space along northern boundary and along the Colne.
They considered these measures essential to
prevent discharges into the Colne along the western
edge of airport.
✓ A green infrastructure strategy is being developed as part of the
Project. It will be focused on improving the area for biodiversity and
people including creating a network of green spaces around the airport.
Discussions are underway with local landowners on a range of land
uses of which green infrastructure is given a high priority.
Open green spaces need to include walking routes
and cycling paths which link with the wider Colne
Valley Park, other green spaces and walking/cycling
corridors surrounding the airport.
✓ Heathrow have been developing a full active travel strategy which
includes cycling. The proposed cycle network will be included in the
documents published as part of the Airport Expansion Consultation in
June 2019.
The delivery of the Project will impact the existing natural environment.
However, Heathrow are considering opportunities to deliver high quality
mitigation for green infrastructure, and for biodiversity (wildlife and
plants), the landscape and the water environment (rivers, ponds and
streams) – for the benefit of both local communities and wildlife in the
local area.
Effects on ecological sites and habitats will be considered as part of the
EIA and mitigation will be proposed where significant effects are
identified. More information will be provided within the PEIR to be
published as part of the Airport Expansion Consultation in June 2019.
Heathrow should extend the Colne Valley Trail
further south (section 3) and explore enhancement of
existing sections of the Colne Valley Trail.
✓
Colne Valley Regional Park will be fundamentally
changed by Heathrow expansion. As a result, they
considered that any Green and Blue Infrastructure
Plan should extend to The Ivers.
✓
The effects of expansion on the Colne Valley
Regional Park should not be allowed to happen.
✓
The need to address the potential impact on the
Colne Valley Regional Park.
✓
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Compensation for the permanent loss of Colne
Valley Regional Park land in the south should be
provided by expanding the Park boundaries.
✓
Concerns about the effects on the Colne Valley
Regional Park, Crown Meadow, the Thames Basin
SPA, the River Crane, ancient woodland and number
of species of wildlife.
✓
The overall strategy must retain the integrity and
connectivity of the Colne Valley Park as far as is
possible and provide off-site compensation and
mitigation for any permanently used land.
✓
Colnbrook and Poyle villages should be protected
within a ‘Green Envelope’.
✓ Slough Borough Council, through the ongoing HSPG engagement have
stressed the importance of the ‘green envelope principle around Poyle
and Colnbrook and the Project is looking to maintain and enhance that
principle where practicable. Heathrow will continue to work with HSPG
to seek to identify an effective solution.
Heathrow is located between a number of areas of
importance for tourism, leisure and heritage. They
considered that the appropriate development of the
airport could enhance these sectors.
✓ Heathrow recognises that in accordance with the ANPS the Secretary
of State should refuse consent unless it can be demonstrated that
substantial harm or loss of significance of heritage assets is necessary
in order to deliver substantial public benefits that outweigh the loss
(ANPS 5.204). Heathrow must therefore take steps to minimise the
extent of harm to heritage assets alongside demonstrating the public
benefits (including any heritage benefits) from the proposals. One of
the key principles of Heathrow’s approach to the historic environment is
opportunity. As part of this, an exploration of initial options to unlock the
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potential for sustainable uses of heritage assets and for creating
circumstances to help others to manage heritage assets that might
otherwise be at risk; as well as creating new amenity that increase
people’s ability to enjoy the wider historic environment
The proposed cycle route appears to connect well to
the surrounding area but that further investment is
needed around Stanwell/Stanwell Moor to connect
the current off airport routes with the routes within
the airport boundary.
✓ Almost 20,000 airport personnel currently live within 5km of the airport
boundary – a comfortable cycling distance for many people. The
Project represent an opportunity to improve connections to the airport
from existing cycle routes and improve the quality of the environment
and infrastructure for cyclists in the future with improved or new routes.
The cycle route along the Southern Perimeter Road
should be extended to link up with routes to Terminal
4 and Bedfont.
✓
The proposed cycle route around the airport could
be attractive for its employees provided it is built to a
high standard. The cycle route needs to be
integrated into a landscape zone and not just placed
immediately next to the perimeter road or airport
fence.
✓
The development may disrupt recreational walking
routes and suggested that Heathrow work alongside
Local Authority open space strategies or rights of
way improvement plans to identify possible
enhancements.
✓ Heathrow are considering a range of options and are engaging
stakeholders in the process. Heathrow are working with stakeholders to
ensure that it is understood what the precise amount of green space
that will be lost or created as part of this application will be. Heathrow’s
aim is that the new landscapes to be created by the Project are at least
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Provision of recreational areas should also consider
areas further away which less affected by the airport
✓ as good in terms of quantity, quality and connectivity as those they
replace. Heathrow’s vision is to create new landscapes that will deliver
a range of environmental, social and economic benefits to local
communities and beyond.
The expansion of Heathrow will affect the existing natural environment
but it also represents a unique opportunity to deliver high quality
mitigation around the airport for biodiversity (wildlife and plants), the
landscape and the water environment (rivers, ponds and streams) for
the benefit of both local communities and wildlife. Heathrow will
continue to work with stakeholders, including local authorities, to
identify opportunities and improvements as part of the development
proposals. More information will be provided within the PEIR to be
published as part of the Airport Expansion Consultation in June 2019.
Concerns that the proposals failed to consider local
people, would result in a loss of green
space/recreational facilities or were generally
insufficient.
✓
Welcome the consideration of integrated and
connected green infrastructure but expressed
concern that this approach should not result in a
reduction in the amount of green infrastructure
created or the focussing of benefits into a very small
area.
✓ One of the four principles of Heathrow’s Green Infrastructure approach
is to improve connectivity around the airport by creating new cycle
paths and footpaths to improve public access to the natural
environment for health and wellbeing. Heathrow is considering the
implementation of dedicated/segregated cycle paths and footpaths
(e.g. providing connections to the London Loop path by improving
existing cycle paths and footpaths). In addition, baseline study work will
assess the existing network to identify areas for improvement (e.g.
resurfacing and maintaining the cycle/footpaths) and linking with off-
airport routes (e.g. around Stanwell/Stanwell Moor, Colne Valley Way).
These routes will aim to provide safe cycle pathways for colleagues.
More information will be provided within the PEIR to be published as
part of the Airport Expansion Consultation in June 2019.
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The water table is at a very shallow depth and
susceptible to contamination.
✓ Heathrow are undertaking EIA, which includes an assessment of
impacts on the water table. The risks associated with having shallow
river terrace gravels will be assessed as part of the EIA.
This assessment has informed the design of the Project, through an
ongoing evaluation process. Early findings of this process will be
reported in the PEIR to be published at the Airport Expansion
Consultation in June 2019.
Concern that local authorities have not been
consulted on potential sites for flood storage and
that the proposals may impact existing flood
alleviation schemes.
✓ Heathrow are considering a range of options and are engaging
stakeholders in the process, including Lead Local Flood Authorities
through the HSPG and the Environment Agency, to ensure that
locations identified are appropriate and that the proposals do not affect
existing flood alleviation schemes.
The proposed flood storage areas will need to form
part of the Green and Blue Infrastructure Plan.
✓ The Project presents an opportunity to deliver high quality mitigation for
green and blue infrastructure in the local area. Heathrow are
considering a range of options on this. The Project will propose areas
which could be landscaped, planted, restored or enhanced in order to
mitigate and off-set the effects of the Project. Heathrow are
undertaking an EIA of the Project, including an extensive and detailed
evaluation of potential sites, to identify the preferred location and routes
of the river diversions and flood storage areas, taking into account the
consultation responses received from the Airport Expansion
Consultation One.
A landscape vision that includes a green and blue infrastructure
strategy that focuses on providing multifunctional space that is
beneficial to both wildlife and people is also being developed. This
strategy includes habitat connectivity, biodiversity mitigation,
biodiversity offsetting, re-provision of public open space, active
transport, historic setting and improvement of existing green belt.
Green infrastructure must be considered and
planned for.
✓
Need for a Green and Blue Infrastructure Plan and a
number of opportunities for mitigation within the
Park.
✓
Welcome Heathrow’s design approach and
commitments to create a positive legacy of better,
well connected green infrastructure and maintain
current populations of animals and plants.
✓
The key elements of the Green and Blue ✓
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Infrastructure Plan must be included in the DCO
application to ensure they can be delivered,
managed and maintained.
More information will be provided within the PEIR to be published as
part of the Airport Expansion Consultation in June 2019.
Early and strategic planning of green and blue
infrastructure.
✓
Creating a positive long-lasting legacy should be a
core component of the development.
✓
Areas of parkland and open space previously created
in the vicinity of the airport suffer from underuse and
neglect, often because of concerns over lack of safe
parking, security and isolation.
✓
Protection, enhancement and re-introduction of
indigenous species and habitats would be a long-
lasting legacy.
✓
Improve site connectivity by land and water wherever
possible.
✓
Greening measures would likely bring economic,
health and tourism benefits.
✓
The proposed flood storage areas need to form part
of the green infrastructure plan.
✓
Management and maintenance of green
infrastructure should be integrated into project
✓
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design.
This could include green features, such as green
walls, green roofs and green bridges, which would
improve the resilience of the development whilst also
protecting the building fabric from sunlight and
temperature fluctuations, reducing costs, reducing
noise, providing visual features of interest, capturing
air pollutants and dust and providing wildlife habitat.
✓
Challenged the claim that the proposals would
protect rivers and their associated vegetation
corridors when over one kilometre of the diverted
Rivers would flow beneath the new runway,
essentially below ground.
✓
Green and Blue infrastructure strategy should drive
the design process and be intertwined into all
proposals.
✓
Welcomed the inclusion of landscape design as part
of the integrated green infrastructure aim and
indicated that it could deliver additional benefits for
landscape and visual amenity.
✓
The use of green infrastructure as the primary basis
for measuring success regarding the environment
has a number of potential disadvantages due to the
conflicting objectives.
✓
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Any proposals need to be considered in a holistic
manner, with links to other strategic interventions in
the surrounding area also being considered, for
example the River Thames Scheme.
✓ However, it also presents an opportunity to deliver high quality
mitigation for green infrastructure in the local area. Heathrow are
considering a range of options, including areas which could be
landscaped, planted, restored or enhanced in order to mitigate and off-
set the effects of the Project, including those upon habitats. Further
information will be contained within the PEIR to be published as part of
the Airport Expansion Consultation in June 2019.
Consideration should be given to the integration of
drainage and pollution controls with the green
infrastructure masterplan.
✓ Heathrow are committed to protecting the quality of the water
environment. Plans for expansion consider a range of options which
will be presented to our stakeholders, including the Environment
Agency, for their consideration. Stakeholders will help Heathrow to
deliver appropriate solutions in accordance with the environmental
objectives of the WFD. In this regard, Heathrow aims to prevent the
deterioration in status of water bodies and not adversely affect the
future achievement of good status by any affected water bodies. In
accordance with the WFD, Heathrow are considering options to protect
and enhance the biodiversity associated with the water environment.
More information will be provided within the PEIR to be published as
part of the Airport Expansion Consultation in June 2019.
Heathrow had failed to take account of the
environmental characteristics of its alternative
development proposals.
✓ The ANPS sets out specific requirements that Heathrow will need to
meet to gain development consent for the Project. Heathrow are
undertaking an EIA of the Project, which will take account of the
proposals. As part of the requirements for an EIA, a scoping report was
presented to the planning inspectorate setting out the extent of the
study area beyond the immediate environment. Early findings in line
with these requirements will be reported in the PEIR to be published as
part of the Airport Expansion Consultation in June 2019. As part of the
decision making process, the Secretary of State will have to be
Environmental impacts must be considered beyond
the immediate area of development.
✓
The social, economic and environmental impacts of ✓
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airport growth and growth in air travel should be
examined.
satisfied that the economic, social and environmental benefits of the
Project outweigh the environmental impacts and are within local and
global levels.
The design of multifunctional space needs careful
consideration to avoid conflicts.
✓ The Project provides an opportunity to create linked spaces for both
people and wildlife (known as multi-functional spaces) which reflect the
characteristics of the local area. As distance from the airport increases,
so a greater range of habitat types may be possible as potential
conflicts reduce. Heathrow are considering a range of options.
Heathrow will present its preferred option/s at the Airport Expansion
Consultation in June 2019. This information will be presented in the
PEIR to be published as part of the Airport Expansion Consultation in
June 2019.
There was little information specific to local sites and
wildlife which meant an assessment of impacts could
not be undertaken.
✓ Heathrow are undertaking an EIA of the Project. The EIA is being
undertaken in accordance with best practice guidance, policy and
legislation. It includes an assessment of effects on the environment
and communities. Early findings will be reported in the PEIR, including
mitigation measures to avoid and reduce impacts on the environment
and communities, to be published as part of the Airport Expansion
Consultation in June 2019.
Connectivity should be maintained and enhanced for
terrestrial mammals and that unhindered fish
migration will help to prevent ecological impacts
outside of the footprint of the project.
✓ The Project represents an opportunity to deliver high quality mitigation
around the airport for biodiversity (wildlife and plants), the landscape
and the water environment (rivers, ponds and streams) for the benefit
of both local communities and wildlife. Mitigation on a catchment scale
should ensure that habitat connectivity can be maintained between the
upper Colne catchment and the River Thames, including connections
to the Crane catchment. factors that should be considered further related to
ecology:
✓
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• more trees should be planted;
• greater consideration should be given to the
impact on wildlife and habitats;
• new/additional green spaces should be created;
• any negative impacts should be mitigated as
much as possible;
• experts and environmental groups should be
consulted;
• green spaces should be maintained and
managed for the long term;
• locations proposed for supporting facilities
should be turned in to green spaces and parks
after being used for construction;
• flood storage areas and habitats that may attract
birds should be away from the airport;
• wildlife parks and a wildlife centre should be
created; and
• contributions should be made to improving a
country park along the River Colne.
Heathrow is considering a range of options. The new landscapes
created by the Project will aim to be at least as good in terms of
quantity, quality and connectivity as those they replace. Heathrow’s
landscape vision is to create new landscapes that will deliver a range of
environmental, social and economic benefits to local communities and
beyond. Heathrow is undertaking an Environmental Impact
Assessment of the Project, and early findings will be reported in the
PEIR which will be published as part of the Airport Expansion
Consultation in June 2019.
The diversion of Colne Valley Way through Staines
Moor could be positive but could lead to other issues
such as litter or disturbance to wildlife.
✓ Heathrow is not planning any development on the Staines Moor Site of
Special Scientific Interest (SSSI), to the east of the M25. Heathrow are
however undertaking an EIA, which includes an assessment of impacts
on this SSSI. This assessment informs the design of the Project,
through an ongoing evaluation process. Early findings of this process
will be reported in the PEIR and the Updated Scheme Development
Report to be published at the Airport Expansion Consultation in June
2019. Opportunities for mitigation and enhancement measures will
continue to be assessed in light of the Staines Moor status as a SSSI
Highlighted the importance of the Colne Valley to the
Borough and surrounding areas.
✓
Staines Moor contains the oldest known colony of
yellow meadow ants in the whole country and would
✓
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be affected by any work on the northern end of the
site. As a result, any development in this location
would be strongly resisted.
as the Project progresses.
Any work on the Staines Moor floodplain would
disturb wildlife and could also alter the amount of
water on the floodplain. This could lead to a change
in the historical composition of habitats at Staines
Moor and a knock-on reduction in biodiversity.
✓
The whole of Staines Moor should be designated as
a proposed protected species site and should not be
included within the potential development area.
✓
The diversion of Colne Valley Way through Staines
Moor could be positive but could lead to other issues
such as litter or disturbance to wildlife.
✓
Bonehead woodland provides a home for many bird
species and a small population of deer. Reduction of
this small area of woodland would probably lead to
the loss of the deer and would reduce the habitat
available to many species of bird.
✓ ✓ Bonehead Woodland lies within the Staines Moor SSSI. There are no
plans for any works within the area of this woodland.
Heathrow are undertaking an EIA. Survey data is being collected
across the area for both breeding and wintering birds, and mammals.
This assessment has informed the design of the Project, through an
ongoing evaluation process. Early findings of this process will be
reported in the PEIR to be published at the Airport Expansion
Consultation in June 2019.
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All aspects of the environment and the benefits it
provides to people, wildlife and the economy should
be taken into account in options development and
any future stages of Heathrow expansion.
✓ A wide range of considerations are being applied within the evaluation
criteria used for appraising different options and masterplan
components which will form part of the decision making process,
including cost, buildability, land use, environment, including biodiversity
and impact on existing operations. All metrics and sub-criteria will have
no formal weighting applied. However, in considering the overall
balance of considerations, material issues will be highlighted, including
any ‘show stoppers’ which are considered to prejudice the deliverability
of the scheme as well as elements causing excessive environmental
impacts. This approach will ensure that effects on biodiversity are
weighed in the balance at all stages of masterplan scheme
development and will feed into the DCO application. As the scheme is
developed, further information will become available and this
information will be presented within PEIR to be published as part of the
Airport Expansion Consultation in June 2019.
The loss of wildlife habitat and putting rivers
underground is unacceptable.
✓ Numerous options for the diversion of rivers were presented in Airport
Expansion Consultation One.
A detailed evaluation considering a range of criterion (as detailed in the
Scheme Development Report) is being undertaken to identify the
preferred location and routes for river diversions, taking into account
the consultation responses. The findings of this assessment will be
presented in the Updated Scheme Development Report that will be
published as part of the Airport Expansion Consultation in June 2019.
No details of the approach to Landscape Visual
Impact Assessment were provided.
✓ Airport Expansion Consultation One set out a range of options and
approaches under consideration by Heathrow in the formation of its
masterplan.
The landscape in the airport vicinity encompasses a diverse range of
land uses, including areas that are degraded or in decline.
There was only a very brief section on landscape and
visual amenity in the consultation documents and
✓ ✓
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that more detail is required. Through the development of carefully considered and integrated
natural and built environment proposals, the Project seeks to provide
positive contributions to the local landscape and views, where
opportunities arise.
A LVIA considering a range of criterion will be undertaken to consider
the landscape character and visual amenity context of the proposals, to
minimise adverse landscape and visual consequences of the Project
and, where possible, to provide enhancement.
Further information will be contained within the PEIR to be published as
part of the Airport Expansion Consultation in June 2019.
Dimensions of local River channels should be used
to define the physical characteristics of the modified
ones.
✓ The design of any modified river channels will seek to maintain
naturalised flow regimes to support a range of natural fluvial
geomorphological processes. The design will also take into account
the requirements of the water environment to allow it to function as
naturally as possible.
Supported the use of infiltration SuDS but indicated
that a large part of the area of the proposed airport
extension contains licensed and historic landfills or
land which may be affected by contamination. As a
result, infiltration SuDS may not always be an
appropriate option.
✓ Heathrow recognise that the use of infiltration-based SuDS will be
constrained by the risk of pollution to shallow groundwater.
Heathrow operate an existing SuDS system which will be expanded to
incorporate the new runway and associated airside infrastructure.
If any infiltration SuDS are proposed for areas where
there is a potential for an accidental spill of
contaminants, such as car parks, then appropriate
pollution prevention measures must be in place.
✓
Requested further information on surface water run- ✓ Heathrow recognise that the use of infiltration-based SuDS will be
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off and any exceptional release of polluted waters. constrained by the risk of pollution to shallow groundwater.
Heathrow operate an existing SuDS system which will be expanded to
incorporate the new runway and associated airside infrastructure.
Roads and other development outside the airport boundary will be
served by dedicated SuDS, in compliance with Policy 5.13 of the
London Plan. These systems will capture and attenuate surface water
before releasing it sustainably back into the environment in accordance
with the London Plan SuDS Hierarchy.
Heathrow will consider using green roofs as part of a wider offering but
the Project will have to adhere to strict Civil Aviation Authority (CAA)
guidelines on green roofs as proposing green roofs next to an airport
will attract gulls, a significant risk to aircraft.
Green infrastructure design and water efficiency is a key part of the
design in terms of the landscape and views/visual amenity and water
reuse as it provides the opportunity to integrate natural environment
components so that the Project fits into and enhances its surroundings,
wherever possible.
Concern that each proposal is considered as a
separate scheme without an overall view on the
impact to surface water, drainage and flooding.
✓
SuDS need to be considered in the design of
drainage for all large areas of hard standing
(including car parks).
✓
A fully integrated SuDS, drainage and storm
management strategy within the airport is required
and that it should consider opportunities for
integrated green roofs, living walls, and swales.
✓
Opportunities for constructed wetlands that deliver
open green spaces should be explored and that a
fully integrated SuDS, drainage and storm
management strategy is required.
✓
The best available technology with respect to water
efficiency should be used within all new supporting
facilities and terminal buildings.
✓
Rain and greywater harvesting and recycling should
be used to meet non-potable water needs.
✓
The effects of light pollution need to be considered
and requested further consultation.
✓ Heathrow are undertaking an EIA, which includes an assessment of
impacts of light pollution. Heathrow will seek to minimise the impacts
of light pollution on the surrounding area. This assessment has
informed the design of the Project, through an ongoing evaluation
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process. Early findings of this process will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019.
Proposals should be funded though other
mechanisms that do not pass on costs to airport
users.
✓ ✓ The programme for ecological measures, funding and delivery
mechanisms will be set out as part of the DCO application. The PEIR
to be published as part of the Airport Expansion Consultation in June
2019 will provide additional information.
An endowment fund, grant scheme or additional
flight levy should be set up for London's public
Parks to support their maintenance and
enhancement.
✓
Working closely with environmental stakeholders. ✓ Heathrow are considering a range of options and are engaging
stakeholders in the process. Early findings will be reported in the PEIR
to be published as part of the Airport Expansion Consultation in June
2019. Information received from stakeholders, including consultation
responses, will inform the approaches that are put forward for
consideration.
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HISTORIC ENVIRONMENT
Introduction
24.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in
relation to its proposed approach to managing the effects of the Heathrow
Expansion Project (the Project) on the historic environment. A total of 908
consultees made comments relating to this topic.
24.1.2 Heathrow provided the following material that is directly related to the approach to
managing the effects of the Project on the historic environment:
1. Airport Expansion Consultation Document;
2. Our Emerging Plans; and
3. Our Approach to Historic Environment.
24.1.3 Heathrow asked the following questions regarding the historic environment at
Airport Expansion Consultation One:
1. Please tell us what you think about our approach to historic
environment issues.
24.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
Prescribed Consultees
Local Authorities
General comments on approach to managing effects on the historic environment
24.2.1 Buckinghamshire County Council also considered the approach to be largely
appropriate. However, they expressed concern that Heathrow’s Our Approach to
the Historic Environment document was focused on the built-environment and that
potentially significant buried archaeological remains could be missed. They
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highlighted that field evaluation should take place at an early a stage to inform
preferred design options and that geophysical surveys should be ‘ground truthed’
through trail trenching as geophysical surveys can have variable results within the
area.
24.2.2 They requested that joint meetings are held with Historic England to share findings
and progress historic environment assessment in the areas of the county
potentially affected by the proposals.
24.2.3 Ealing Council considered the approach to be acceptable and noted that the
proposed method for the characterisation study appears to follow the relevant
guidance. However, they highlighted that the study area should not exclude areas
that are located beyond the immediate area of the Project, such as the Southall
area, and that the assessment should also consider the impact of airspace
design/future flight plans on these areas.
24.2.4 The London Borough of Hounslow expressed support for the three-pronged
approach of understanding, protection and opportunity and confirmed that the
approach to the historic environment identifies appropriate heritage assets in each
area. They welcomed that input has been sought from Historic England and that
Heathrow’s Our Approach to the Historic Environment document refers to their
guidance at various points.
24.2.5 They suggested that the study area could include Heston Village, Cranford and
Bedfont Green Conservation Areas. They expressed concern that there was no
detailed approach for archaeological baseline data and indicated that the
approach to assessing significance should consider potential impacts on cultural,
social and townscape changes.
24.2.6 Kent County Council considered that the scheme should make a positive
contribution to the historic environment both in its immediate area and further
afield where new flight paths may alter the way heritage assets can be enjoyed.
24.2.7 The London Borough of Sutton considered that the approach to the historic
environment was too narrowly focussed and ignored potential significant impacts
on nearby heritage assets as well as environmentally important sites such as
Royal Botanic Gardens at Kew, the Royal Parks and Windsor Castle.
Comments on specific heritage assets
24.2.8 Ealing Council highlighted that it is seeking a £150million package of measures to
maximise the economic benefits of the Project and mitigate the environmental
impacts of a third runway. They considered that the following sites should be
covered by this fund:
1. Part of Southall’s oldest building, the Grade II* Manor House to provide a café
and additional space for training; and
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2. The historic St John’s Church and Gardens and the Kings Centre - to provide a
community and cultural hub.
24.2.9 Slough Borough Council welcomed the identification of Colnbrook as a potential
historic enhancement area. It stated that it would like to see enhancements to the
Colnbrook Conservation Area and the urban realm and that appropriate parts of
the Colnbrook and Poyle green envelope should be managed and enhanced in a
way which would reflect the historic importance of the area.
Statutory Consultees
General comments on approach to managing effects on the historic environment
24.2.10 Historic England highlighted that based upon available information, a new north
west runway is likely to mean the loss of 21 designated heritage assets and effects
on the setting of 220 designated heritage assets.
24.2.11 They welcomed the research-led approach to the consideration of historic
environment issues and highlighted that this approach should result in a strategy
that understands the context and significance of all heritage assets affected and a
design and mitigation response that is appropriately informed by the baseline.
They also highlighted that there should be a presumption that scheduled
monuments and associated remains of equivalent significance should be protected
and preserved in-situ.
24.2.12 They highlighted the importance of the natural and historic environment working
together on green infrastructure and indicated that the proposed Cultural
Interpretation Framework should raise public awareness of the results of previous
archaeological interventions, and the history of the area generally.
24.2.13 They highlighted that any diversions of rivers around the airport will have an
impact on hydrology which could lead to locally waterlogged deposits experiencing
periods of drying which would be detrimental to preservation of archaeological
remains. They suggested that appropriate testing and modelling of the water
environment before, during and after diversions could be required and that Lidar
data (as well as geophysical survey) may be of use in locating potential former
paleochannels.
24.2.14 They asked for innovative and successful mitigation measures to address noise
impacts on the historic environment. They also requested further detail on the
potential for heritage assets currently in viable uses to become at risk as a result
of the Project citing the Great Barn, St Mary’s Church and the Five Bells public
house in Harmondsworth as examples of this.
Comments on specific heritage assets
24.2.15 Historic England suggested that Lanz farmhouse and the King William IV public
house (both on Harmondsworth Lane and listed Grade II) will be subject to
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significant effects should the westernmost runway option be taken forward and
should be considered as part of the assessment.
24.2.16 They also highlighted that in addition to two scheduled monuments the Mayfield
Farm site is also covered by the East Bedfont Archaeological Priority Area and is
adjacent to the Bedfont Green Conservation Area. They highlighted that the site
will contain considerable archaeological potential and any proposed development
will require appropriate investigation to ensure that it will not cause harm to their
significance.
Other prescribed bodies
General comments on approach to managing effects on the historic environment
24.2.17 The Heathrow Strategic Planning Group suggested heritage assets affected by the
Project should be enhanced. They requested further development of the heritage
mitigation scheme to achieve wider objectives around traffic management,
environmental, social economic compensatory and mitigation actions and
highlighted that this will be particularly relevant to the ‘green envelope’ concept at
the Colnbrook Village Conservation Area.
24.2.18 Windlesham Parish Council expressed concern that the Project would result in the
likely loss of Longford Conservation Area and part of the Harmondsworth
Conservation Area. They deferred on this to Historic England as the experts in this
field but indicated that wherever possible historically significant buildings and
areas should be retained.
24.2.19 Horton Parish Council stated that the village of Horton contains several listed and
historic buildings. It asked that the village be designated a conservation area to
protect heritage buildings and residents from disruption from passing vehicle
traffic.
24.2.20 Bray Parish Council questioned how the Project can be acceptable when it results
in the loss of a number of listed buildings and other heritage assets.
Comments on specific heritage assets
24.2.21 No comments on specific sites/assets were received from other prescribed
consultees.
Local Communities
Members of the public
General comments on approach to managing effects on the historic environment
24.3.1 More than half of the members of the public that made comments about the
historic environment expressed concerns about the impacts of the Project on the
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local area or perceived that the measures proposed to mitigate effects on the
historic environment were unsuitable, would not make a difference or lacked
credibility.
24.3.2 The concerns raised were wide ranging and comprised the loss of irreplaceable
heritage assets including listed buildings, the impact of noise and air pollution on
the historic environment and the impact on local towns and villages. The impact of
flight paths and increased flights on heritage assets and local tourism related to
the historic environment was also highlighted.
24.3.3 Concerns were also raised about the cost of the effects on the historic
environment. Members of the public who raised this issue considered that the cost
of preserving and/or relocating the heritage assets should be borne by Heathrow
and not taxpayers and that these costs may be significant.
24.3.4 Members of the public also expressed general support for the proposed approach
to the historic environment as they considered it irreplaceable. Comments were
also received that the preservation of heritage assets is important but should not
jeopardise operational safety or hinder expansion.
24.3.5 As well as raising general concerns or expressing support for the proposed
approach, the following suggestions were provided about factors that should be
considered further:
1. all heritage assets must be protected and not removed;
2. flightpaths should be designed to avoid overflying heritage assets;
3. Kew and the Royal Parks should be made a no-flight zone;
4. there should be an ongoing levy to support heritage assets across London;
5. a more proactive approach should be adopted to enable the adequate
recording of affected sites;
6. as many listed buildings as possible should be kept, even if it means
relocation;
7. priority should be placed upon listed buildings that have a social function and
contribute to community health;
8. there should be communication with/involvement of residents;
9. any archaeology found should remain publicly accessible;
10. items recovered from investigations should be preserved in a local museum
e.g. the Museum of Middlesex’, ‘Colne Valley Visitor and Learning Centre or a
Heathrow Heritage Museum;
11. there should be contributions, sponsorship and support for local museums and
galleries;
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12. Heathrow should consult with experts to ensure the best approach to the
preservation of the historic environment;
13. if archaeology is found to be present within the site it would be best to leave it
undisturbed and not be compelled to ‘save/rescue’;
14. land take should be minimised to preserve as much archaeology as possible;
15. the historic environment and natural environment issues should be considered
together; and
16. Heathrow should establish a new conservation area into which affected
heritage assets could be moved.
Comments on heritage assets
24.3.6 Members of the public expressed general concerns about the effects of the Project
on the following specific properties or locations:
1. Colnbrook, Harmondsworth, Longford and Sipson conservation areas;
2. heritage assets along the River Thames;
3. Osterley House;
4. Cliveden House and Gardens;
5. Hampton Court Palace;
6. the historic centre of Windsor;
7. heritage assets in Richmond Park;
8. the Air Force Memorial at Runnymede;
9. heritage buildings in Bedford Park;
10. Chiswick House;
11. St Mary's Church;
12. Windsor Castle;
13. heritage assets at Kew Gardens;
14. Harmondsworth Great Barn
15. Holloway College and Holloway Sanatorium;
16. Taplow Court (Saxon burial site);
17. Bushy Park; and
18. Windsor Great Park
24.3.7 In addition to these general concerns respondents expressed support for the
consideration given to the potential impacts on Harmondsworth Great Barn and St
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Mary's Church and indicated that detailed proposals need to be provided for the
preservation or relocation of these heritage assets.
24.3.8 Suggestions were also received that Sipson Church, Sun House, Five Bells Inn,
Grange House, Crown Inn, Gorge and Barnes Wallis Memorial should be
considered for relocation and that the best historic buildings in the Longford
Conservation Area should be relocated to the north.
Businesses
General comments on approach managing effect on the historic environment
24.3.9 Of the businesses that commented on Heathrow’s approach to the historic
environment, Hampshire Chamber of Commerce highlighted that the consideration
of heritage sites is vital. They considered that the appropriate development of the
airport would enhance the use of these assets and boost the adjacent tourism,
leisure and heritage sectors.
24.3.10 The Copas Partnership recognised the importance of the historic environment but
considered that its importance was overplayed, and that effects could not be
avoided.
Comments on specific heritage assets
24.3.11 No comments on specific heritage assets were received from businesses.
Community groups
General comments on approach to managing effects on the historic environment
24.3.12 Many of the community groups who provided feedback to Airport Expansion
Consultation One expressed opposition to the Project but did not necessarily
include specific feedback on the historic environment.
24.3.13 Aircraft Noise Three Villages, Colnbrook Community Association, Teddington
Action Group, Slough and District Against Runway 3, Dover House Residents
Association, Residents Association HVG CA and the all made comments opposing
the approach and the impacts on historic assets.
24.3.14 Colnbrook Community Partnership did not consider that the impact on Colnbrook
Conservation Area and the listed buildings within it had been taken into account.
They queried why the designation of Colnbrook as a Potential Historic
Enhancement Area was not referred to in the Approach to the Historic
Environment document or other consultation information. They also suggested that
enhancements should be made to the Colnbrook Conservation Area and that
Heathrow should contribute financially to local projects which would preserve the
historic past.
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24.3.15 Local Conversation in Stanwell commented that the historic buildings to the north
of Stanwell or Stanwell Moor could be deconstructed and rebuilt in a new location
near the airport and used as a teaching/learning opportunity.
24.3.16 Stanwell’s Green Lungs commented that it did not support an approach that would
result in heritage sites and features being destroyed or adversely impacted.
24.3.17 Ealing Fields Residents Association commented that historic environment issues
should be continually addressed irrespective of the proposed Heathrow expansion.
24.3.18 The Wentworth Residents Association highlighted that the impact on the
environment will be negative. They supported efforts to offset effects but
considered that this could not be adequately achieved.
Comments on specific heritage assets
24.3.19 The Sant Nirankari Mission requested exemption from inclusion within the
Heathrow Expansion proposals due to the spiritual and architectural heritage of
their land and buildings which cannot be transferred to another site.
24.3.20 Harrow U3A Sustainability Group suggested that Harmondsworth Great Barn is on
a timber frame and should be relocated, possibly to the Chalfont Open Air
Museum. They also commented that St Mary's Church will lose its congregation
and will come to resemble the village of Lowfield Heath.
24.3.21 The Old Chiswick Protection Society expressed concern about the effects of
increased traffic through Chiswick Hogarth roundabout on the Old Chiswick
Conservation Area.
24.3.22 The Richmond Heathrow Campaign considered that full weight should be given to
protecting and improving the World Heritage Site at Kew which is significantly
impacted by noise.
24.3.23 The Pavilion Association Stanwell and Stanwell Moor suggested that the area
around the Great Barn should be expanded to a Heathrow Heritage Site.
Wider/other Consultees
General comments on approach to managing effects on the historic environment
24.4.1 The World Federalist Party considered that Heathrow’s plans for the historic
environment were inadequate and lacking in detail. West London Friends of the
Earth were also critical and indicated that they did not support an approach which
would destroy or adversely impact heritage sites.
24.4.2 The London Wildlife Trust supported the consideration of the historic environment
and highlighted that areas of countryside character that support remnant features
of an agricultural landscape should be considered for protection and/or
enhancement in any proposals.
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24.4.3 London Parks and Gardens considered that the loss of heritage assets such as
the Longford Conservation Area would be irreplaceable. They suggested the
establishment of a levy or other mechanism to fund and sustain heritage assets (in
particular parks and historic gardens across London which are not supported
through statutory funding) would bring huge benefits across London and provide a
unique way of offsetting any damage done.
24.4.4 The Royal Parks highlighted that the Project should contribute to the conservation
of the historic environment wherever possible.
24.4.5 The Richmond Cycling Campaign considered that the measures set out in
Heathrow’s Our Approach to the Historic Environment document should be definite
commitments rather than aspirations.
24.4.6 The National Trust expressed concern that the Project will have a direct impact on
its properties but welcomed Heathrow’s intent to minimise negative effects and
ensure everyone is treated fairly. They indicated that they have previously
opposed expansion primarily on the grounds of the noise impacts and that these
concerns need to be addressed before this position could change.
24.4.7 The Society of Antiquaries considered that the study area for the historic
environment assessment should be expanded (particularly to the west and the
north) to include all potentially affected areas, so that the total impact of the project
on heritage assets and undesignated archaeological deposits is understood. They
suggested that the airport perimeter in the vicinity of Harmondsworth should be
designed to deflect aircraft noise and mitigate visual impact on its setting.
24.4.8 They expressed concern about the potential loss and relocation of the Great Barn
and considered that if the barn cannot be retained as a monument because of
noise levels the northern half of Harmondsworth Conservation Area, also has
no future.
24.4.9 They highlighted that a comprehensive archaeological mitigation programme will
be required to address impacts on archaeological remains within the Colne Valley
floodplain and cited the example of Kingsmead Quarry which produced in-situ
archaeological remains from the Late Glacial and Mesolithic periods (10,000-4000
BC), the Neolithic, Bronze and Iron Ages and the Romano-British, Saxon and
medieval periods. They also highlighted that the Colne alluvial deposits have
greater potential for the exceptional preservation of archaeological waterlogged
organic remains and expressed concern that to the scale and importance of such
deposits had not been considered.
24.4.10 They commented that due to the limitations of non-intrusive survey techniques,
trial trenching and other intrusive survey techniques should be given greater
importance and that a clear rationale for any intrusive surveys should be
developed, rather than relying on a percentage-based approach to sampling.
They suggested that the results of all work and mitigation for the Project should be
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integrated with the Geographical Information System, that a deposit model should
be created and that detailed topographic survey data for areas required for the
new expanded Heathrow should be undertaken.
24.4.11 The Milestone Society expressed concern about the destruction of the Old Bath
Road in Longford. They considered that as the road does not form part of the
runway it would be possible to retain it and site any required ancillary buildings or
features elsewhere or build them in such a way to allow retention of the route.
24.4.12 They requested that if the route is removed heritage assets should first be
carefully recovered, preserved, re-installed and exhibited elsewhere at Heathrow’s
expense. They suggested that an appropriate museum for such a display might
include the Chiltern Museum which holds and displays a number of historic
highways assets removed from the line of the M25.
24.4.13 They also expressed concern that the Project would result in the loss of other
historic milestones along Bath Road between Harlington and Longford and the
cannon marking the northern end of General Roy's Base. They highlighted that
these assets should be protected as part of scheme design and during
construction.
24.4.14 The Colne Valley Regional Park considered that where heritage assets are directly
affected, they should be moved to another location locally. Any archaeological
findings should also be displayed locally at venues such as visitor centres,
museums, community buildings and public houses.
24.4.15 They highlighted the importance of retaining and enhancing the setting of historic
villages such as Colnbrook and Harmondsworth and suggested that community
development projects should be implemented to maintain and build community
and ‘village life’.
24.4.16 They also suggested that Heathrow should provide simple interpretation boards to
keep the public fully informed during construction. These could include artists
impressions of the pre-historic landscape of the Colne Valley, photos/artwork of
the C20th landscape, a viewing hole to the construction site or and artists
impression of restored green infrastructure or airport development at the site.
24.4.17 The Church of England Diocese of London, Oxford and Southwark considered that
the approach to the historic environment was ‘broadly sound’ but indicated that it
would be preferable for these impacts not to be necessary in the first place.
24.4.18 They considered that the Church of St Mary and the Great Barn at Harmondsworth
must be retained and that any options that do not meet this criterion should be
discontinued. They also considered that the assessment of significance should
include spiritual significance and that other churches, graveyards and cemeteries
in the study area should not be overlooked.
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24.4.19 Lambeth/Herne Hill Green Party suggested that Heathrow should consult with
Historic England about the approach to the historic environment.
Comments on specific sites
24.4.20 The National Trust made a number of detailed comments about properties they
considered likely to be affected by the Project that are summarised as follows.
1. Osterley currently enjoys respite from arriving aircraft when the runways are
alternated. Any attempts to end alternation at Heathrow would have a
significant impact on the way that visitors experience their visit and noise
disturbance.
2. Runnymede and Ankerwyck currently experience overflying of aircraft on
departures from the southern runway when on westerly operations. The end of
alternation would offer no respite to those enjoying this open space and would
impact on the quality of visitors’ lives. The new runway also has the potential
to dominate views from Coopers Hill at Runnymede.
3. Ham House and Gardens experiences both arrivals and departures from both
runways and the burden of being located under these flightpaths should not be
underestimated.
4. Petersham Meadows are an iconic view and have been immortalised by the
landscape painter JMW Turner. Aircraft noise is detrimental to the enjoyment of
this space.
24.4.21 They also commented that sites potentially affected by the Project and changes to
flight paths include Cliveden, Claremont Garden, Morden Hall Park, Basildon Park,
Carlyle’s House, 575 Wandsworth Drive, 2 Willow Road and Fenton House.
24.4.22 Friends of the River Crane expressed concern about the potential loss of heritage
features along river channels. They indicated that surveys for structures, heritage
or archaeological features should be undertaken by Heathrow’s consultants. They
highlighted the example of a historic brick bridge across the Upper Duke’s River
near to Harmondsworth that could be at risk due to the scheme.
24.4.23 The Royal Parks highlighted that the Kings Bridge over the river in Longford
should be retained and repositioned in a publicly accessible area.
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Issues Raised and Heathrow’s Responses
Tables 24.1A and 24.1B present a summary of the main issues raised by prescribed consultees, local communities and
wider/other consultees in relation to Historic Environment.
Table 24.1A presents a summary of Heathrow’s responses to those issues which are directly related to the proposals on which
we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019), and how in preparing
those proposals we have had regard to the relevant Airport Expansion Consultation One feedback.
Table 24.1B provides a summary of the way in which we are seeking to consider the issues raised in relation to any other
aspects of the Project not included in the Airspace and Future Operations Consultation. These interim responses are provided
for information only, and so no further feedback is being sought on the basis that a full consultation feedback report will be
published as part of the Airport Expansion Consultation in June 2019.
Table 24.1A
Issue Consultee16 Heathrow Response
PC MC WC
Concerns about the impact of flight paths and
increased flights on heritage assets and local
tourism related to the historic environment.
✓ The Airspace Design Principles do not include a generic design
principle for Expansion on avoiding historical assets. This is because
the scope of this airspace change means that it has potential effects
over a large geographic area, within which there will be a wide range of
noise sensitive buildings/areas to consider.
(Full details of our fixed airspace design principles for Expansion can be
Flightpaths should be designed to avoid overflying
heritage assets.
✓
16 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Issue Consultee16 Heathrow Response
PC MC WC
Kew and the royal parks should be made a no-flight
zone.
✓ found at: https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-2018/London-
Heathrow-airspace-departure-and-arrival-procedures/)
However, we are still at a relatively early stage of our airspace design
process which started from a ‘blank sheet’. We have now identified the
‘design envelopes’, which show the geographical areas which are
potentially overflown. This consultation asks for feedback on local
factors relating to these areas to which we will have regard in designing
the flight paths. Local factors can include historical assets. See further
Heathrow’s Airspace design envelopes for expansion and Making
Better Use of Our Existing Runways.
Further information of the likely effects of the Project on the historic
environment will be presented in the Preliminary Environmental
Information Report (PEIR) as part of the Airport Expansion Consultation
in June 2019.
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Issue Consultee16 Heathrow Response
PC MC WC
Osterley currently enjoys respite from arriving
aircraft when the runways are alternated. Any
attempts to end alternation at Heathrow would have
a significant impact on the way that visitors
experience their visit and noise disturbance.
✓ Alternation
Heathrow recognises that a new third runway provides an opportunity to
consider how the runways will operate in the future, and that this will
require a change to how runway alternation operates today.
The Airspace and Future Operations Consultation in January 2019
provides information on our emerging proposals for the provision of
respite through alternation.
For more information, please see the Airspace and Future Operations:
Consultation Document and the Runway Operations – Respite Through
Alternation Documents.
Overflight generally
The Airspace Design Principles do not include a generic design
principle for Expansion on avoiding historical assets. This is because
the scope of this airspace change means that it has potential effects
over a large geographic area, within which there will be a wide range of
noise sensitive buildings/areas to consider.
(Full details of our fixed airspace design principles for Expansion can be
found at: https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-2018/London-
Heathrow-airspace-departure-and-arrival-procedures/)
However, we are still at a relatively early stage of our airspace design
process which started from a ‘blank sheet’. We have now identified the
‘design envelopes’, which show the geographical areas which are
potentially overflown. This consultation asks for feedback on local
factors relating to these areas to which we will have regard in designing
the flight paths. Local factors can include sensitive placed and
historical assets. See further Heathrow’s Airspace design envelopes
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Issue Consultee16 Heathrow Response
PC MC WC
for expansion and Making Better Use of Our Existing Runways.
We will treat this comment as response on local factors.
Further information of the likely effects of the Project (including on the
historic environment) will be presented in the Preliminary Environmental
Information Report (PEIR) as part of the Airport Expansion Consultation
in June 2019.
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Issue Consultee16 Heathrow Response
PC MC WC
Ham House and Gardens currently experiences both
arrivals and departures from both runways and the
burden of being located under these flightpaths
should not be underestimated.
✓ The Airspace Design Principles do not include a generic design
principle for Expansion on avoiding historical assets. This is because
the scope of this airspace change means that it has potential effects
over a large geographic area, within which there will be a wide range of
noise sensitive buildings/areas to consider.
(Full details of our fixed airspace design principles for Expansion can
be found at: https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-2018/London-
Heathrow-airspace-departure-and-arrival-procedures/)
However, we are still at a relatively early stage of our airspace design
process which started from a ‘blank sheet’. We have now identified the
‘design envelopes’, which show the geographical areas which are
potentially overflown. This consultation asks for feedback on local
factors relating to these areas to which we will have regard in designing
the flight paths. Local factors can include sensitive placed and
historical assets. See further Heathrow’s Airspace design envelopes
for expansion and Making Better Use of Our Existing Runways.
We will treat this comment as response on local factors.
Further information of the likely effects of the Project (including on the
historic environment) will be presented in the Preliminary Environmental
Information Report (PEIR) as part of the Airport Expansion Consultation
in June 2019.
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Issue Consultee16 Heathrow Response
PC MC WC
Petersham Meadows are an iconic view and have
been immortalised by the landscape painter JMW
Turner. Aircraft noise is detrimental to the enjoyment
of this space.
✓ The Airspace Design Principles do not include a generic design
principle for Expansion on avoiding historical assets. This is because
the scope of this airspace change means that it has potential effects
over a large geographic area, within which there will be a wide range of
noise sensitive buildings/areas to consider.
(Full details of our fixed airspace design principles for Expansion can
be found at: https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-2018/London-
Heathrow-airspace-departure-and-arrival-procedures/)
However, we are still at a relatively early stage of our airspace design
process which started from a ‘blank sheet’. We have now identified the
‘design envelopes’, which show the geographical areas which are
potentially overflown. This consultation asks for feedback on local
factors relating to these areas to which we will have regard in designing
the flight paths. Local factors can include sensitive placed and
historical assets. See further Heathrow’s Airspace design envelopes
for expansion and Making Better Use of Our Existing Runways.
We will treat this comment as response on local factors.
Further information of the likely effects of the Project (including on the
historic environment) will be presented in the Preliminary Environmental
Information Report (PEIR) as part of the Airport Expansion Consultation
in June 2019.
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Issue Consultee16 Heathrow Response
PC MC WC
Runnymede and Ankerwyck currently experience
overflying of aircraft on departures from the
southern runway when on westerly operations. The
end of alternation would offer no respite to those
enjoying this open space and would impact on the
quality of visitors’ lives.
✓ Alternation
Heathrow recognises that a new third runway provides an opportunity to
consider how the runways will operate in the future, and that this will
require a change to how runway alternation operates today. We are
committed to delivering respite through alternation as part of the
Project.
The Airspace and Future Operations Consultation in January 2019
provides information on our emerging proposals for the provision of
respite through alternation.
For more information, please see the Airspace and Future Operations:
Consultation Document and the Runway Operations – Respite Through
Alternation Documents.
Further information of the likely effects of the Project will be presented
in the Preliminary Environmental Information Report (PEIR) as part of
the Airport Expansion Consultation in June 2019.
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Table 24.1B
Issue Consultee Heathrow Response
PC MC WC
The approach to the historic environment is
acceptable, noting that the proposed method for the
characterisation study appears to follow the relevant
guidance.
✓ Comments duly noted.
Support for the three-pronged approach of
understanding, protection and opportunity and
confirmed that the approach to the historic
environment identifies appropriate heritage assets in
each area.
✓
General support for the proposed approach to the
historic environment.
✓
Welcomed the research-led approach to the
consideration of historic environment issues and
highlighted that this approach should result in a
strategy that understands the context and
significance of all heritage assets affected and a
design and mitigation response that is appropriately
informed by the baseline.
✓
The natural and historic environment are important
elements to green infrastructure.
✓
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In addition to two scheduled monuments the Mayfield
Farm site is also covered by the East Bedfont
Archaeological Priority Area and is adjacent to the
Bedfont Green Conservation Area.
✓
The approach to the historic environment was
‘broadly sound’ but it would be preferable for these
impacts not to be necessary in the first place.
✓
The consideration of heritage sites is vital.
✓
Why was the designation of Colnbrook as a Potential
Historic Enhancement Area not referred to in the
approach to historic environment or consultation
information?
✓ The information leaflet for Poyle, Colnbrook and Brands Hill provided at
the Airport Expansion Consultation One identified Colnbrook as a
potential historic enhancement area.
Further details on proposed potential enhancements and mitigation to
the historic environment will be provided in the Preliminary
Environmental Information Report (PEIR) that will be published at the
Airport Expansion Consultation in June 2019. The document Our
Approach to the Historic Environment published at the Airport
Expansion Consultation One provided a high-level overview of
Heathrow’s early considerations regarding its approach to the historic
environment to seek feedback early in the design process of the
Project.
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PC MC WC
The study area should not exclude areas which lie
beyond the immediate area of the proposed
expansion, such as the Southall area, and the
assessment should also consider the impact of
airspace design/future flight plans on these areas.
✓ Heathrow are undertaking an Environmental Impact Assessment (EIA)
of the Project, and early findings will be reported in the Preliminary
Environmental Information Report (PEIR) to be published as part of the
Airport Expansion Consultation in June 2019. This will include an
assessment of likely effects of the Project on heritage assets.
Heathrow proposes that the study area for the purposes of the EIA will
comprise a core study area and a wider study area. The core study area
is to be based on an area extending a one-kilometre beyond the
proposed development area for the Project.
A wider study area will be defined to identify heritage assets which lie
beyond the core study area but which may be impacted by operational
effects relating to noise and the setting of heritage assets, known as the
zone of theoretical visibility. The wider study area will be identified in
accordance with Scoping Opinion published by the Planning
Inspectorate in July 2018. Section 4.7 of the Scoping Opinion states the
following regarding the study area for the historic environment
assessment “the potential for significant effects from airport operations
on settings of heritage assets beyond the ‘core’ study area and within
the within the zone of theoretical visibility should be considered in the
ES”.
The study area could include Heston Village,
Cranford and Bedfont Green Conservation Areas.
✓
The study area for the historic environment
assessment should be expanded (particularly to the
west and the north) to include all potentially affected
areas, so that the total impact of the Project on
heritage assets and undesignated archaeological
deposits is understood.
✓
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Concern that the Approach to the Historic
Environment document was built-environment
orientated and that potentially significant buried
archaeological remains could be missed.
✓ Heathrow recognise the importance of archaeological remains as
heritage assets and in accordance within planning policy aim to avoid
damage to the most significant archaeological sites. (Airports National
Policy Statement (ANPS) 5.212)) The ANPS also notes that “where a
site on which development is proposed includes or has the potential to
include heritage assets with archaeological interest, the applicant
should include an appropriate desk-based assessment and, where
necessary, a field evaluation. The applicant should ensure that the
extent of the impact of the proposed development on the significance of
any heritage asset affected can be adequately understood from the
application and supporting documents.” Heathrow will accord with this
approach as set out in the ANPS.
Heathrow are undertaking research to predict the nature and extent of
surviving archaeological remains across the site. Where the potential
presence of significant archaeological sites remains, there are several
mitigation strategies that can be agreed before construction to facilitate
development while minimising potential disturbance. This approach will
be set out in the PEIR to be published as part of the Airport Expansion
Consultation in June 2019.
Further archaeological field evaluation or other investigation will be
undertaken in accordance with the overarching written scheme of
investigation (to be produced in agreement with Historic England, the
Heathrow Strategic Planning Group (HSPG) and the Greater London
Archaeology Advisory Service (GLAAS).
Individual archaeological field investigations are to be agreed as
detailed site specific written schemes of investigation, prepared in
collaboration with construction contractors and subject to stakeholder
consultation and approval.
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Field evaluation should take place at an early stage
to inform preferred design options and geophysical
surveys should be ‘ground trothed’.
✓ In accordance with Historic England advice and guidance, the historic
environment baseline surveys Heathrow are undertaking include
archaeological field evaluation (see paragraph 11.9.8 of the EIA
Scoping Report)). The baseline data and the assessment of likely
impacts on heritage assets will inform the design of the Project.
The Mayfield Farm site will contain considerable
archaeological potential and any proposed
development will require appropriate investigation to
ensure that it will not cause harm to their
significance.
✓
A comprehensive archaeological mitigation
programme will be required to address impacts on
archaeological remains within the Colne Valley
floodplain
✓
The Colne alluvial deposits have greater potential for
the exceptional preservation of archaeological
waterlogged organic remains, concern that to the
scale and importance of such deposits had not been
considered.
✓
Due to the limitations of non-intrusive survey
techniques, trial trenching and other intrusive survey
techniques should be given greater importance and
that a clear rationale for any intrusive surveys should
be developed, rather than relying on a percentage-
based approach to sampling.
✓
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Request that joint meetings are held with Historic
England to share findings and progress the historic
environment assessment in the areas of the county
potentially affected by the proposals.
✓ Heathrow have a programme of ongoing engagement with Historic
England including joint meetings with the HSPG. These discussions
have been ongoing since late 2017. These ongoing meetings with
Historic England are informing the approach being taken for the EIA
relating to the historic environment
Heathrow also has an ongoing programme of engagement with
communities and residents covering a variety of issues including the
historic environment.
There should be communication with/involvement of
residents.
✓
Heathrow should consult with experts to ensure the
best approach to the preservation of the historic
environment.
✓
Heathrow should consult with English Heritage about
the approach to the historic environment.
✓
Concern that there was no detailed approach for
archaeological baseline data.
✓ Since the Airport Expansion Consultation One Heathrow have published
details of our approach to the collection of historic environment baseline
data sources in chapter 11 of the EIA Scoping Report. The Secretary of
State provided their scoping opinion in June 2018 and we will be
developing the baseline data in accordance with our report and their
comments. The details will form part of the PEIR to the published as
part of the Airport Expansion Consultation in June 2019.
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The approach to assessing significance should
consider potential impacts on cultural, social and
townscape changes.
✓ In urban areas landscape may be termed townscape, which includes
buildings and urban open space. The methodology for assessing the
likely impacts of the proposed development, including the impacts of
noise, on landscape and townscape amenity is set out in the EIA
Scoping Report. Specifically, it is covered in the Chapter 13 dealing
with landscape and visual amenity. The assessment of these impacts
will be presented in the PEIR in the Airport Expansion Consultation in
June 2019.
The masterplan will be carefully designed to avoid or minimise adverse
landscape and visual consequences of development and, where
possible, provide enhancement. Impacts on landscape and townscape
amenity will also be considered as part of the airspace design proposals
and the airspace change process as, well as the DCO application. The
impacts of aircraft noise on open spaces and tranquility will be one of
several factors that will be considered as part of the development of the
airspace design and the siting of flightpaths.
Concerns about the impacts of expansion on the
local area.
✓
Concerns regarding the impact on local people,
towns and villages and the effects on tourism.
✓
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The following sites should be covered by a fund:
• The Grade II* Manor House - to provide a café and additional space for training; and
• The historic St John’s Church and Gardens and the Kings Centre - to provide a community and cultural hub.
✓ Heathrow is undertaking an assessment of likely impacts on heritage
assets as part of the EIA for the Project, including identification of
potential mitigation measures. For assessment of effects on the historic
environment, a two-part study area is being determined in accordance
with the proposals set out in Heathrow’s Scoping Report and as
commented on by the Secretary of State in the Scoping Opinion
received in June 2018. Preliminary findings will be presented in the
PEIR as part of the Airport Expansion Consultation in June 2019. This
will include early information on our proposed mitigation measures for
the historic environment.
As set out in Heathrow’s EIA Scoping Report (2018), additional
mitigation measures will be identified on a case by case basis
depending on the significance of the heritage asset and the likely
environmental effect and may include: provision of enhanced access
and interpretation to heritage assets to mitigate potential loss of historic
interest; and localised enhancement measures within areas of historical
and architectural interest to mitigate against visible change in setting
causing loss of historical and architectural interest.
Heathrow are also proposing a Community Compensation Fund, details
of which will be consulted on as part of the Airport Expansion
Consultation in June 2019.
A new north-west runway is likely to mean the loss of
21 designated heritage assets and effects on the
setting of 220 designated heritage assets.
✓ Heathrow has currently identified 17 listed buildings within the boundary
of the land being considered for the Project. The Longford and
Harmondsworth Conservation Areas are also within the boundary. In
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[GROUP D] Concern that the project would result in
the likely loss of Longford Conservation Area and
part of the Harmondsworth Conservation Area. The
loss of these assets would be irreplaceable.
✓ ✓ certain circumstances, it may be possible to consider relocation and
reconstruction, but in other cases, the proposals will result in permanent
loss of the heritage asset.
The ANPS (paragraph 5.200) confirms that the Secretary of State will
give great weight to the conservation of heritage assets. The ANPS
further states (5.203) that harmful impacts to the significance of a
heritage asset will need to be weighed against the public benefit of the
Project, recognising that and that the greater the harm to the
significance of the heritage asset, the greater the justification that will
needed for any loss.
In developing the preferred masterplan for the Project, where demolition
or loss of a heritage asset is unavoidable, Heathrow will need to put
forward justification for such loss. In addition, Heathrow will accord with
the ANPS (paragraphs 5.209 to 5.212) regarding carrying out relevant
recording and the depositing of those records with the relevant Historic
Environmental Record and repository.
Heathrow is continuing to develop the preferred masterplan which
includes understanding the potential effects on heritage assets.
Early findings of the EIA for the Project will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019. This will include an assessment of likely effects of the Project on
heritage assets. The PEIR will also consider mitigation measures, and
this could include scope for relocation or for retention of specific
architectural elements which can then be placed within a relevant
museum repository.
There should be a presumption that scheduled
monuments and associated remains of equivalent
significance should be protected and preserved in-
situ.
✓
Historic environment is irreplaceable and should
therefore be a priority and the preservation of
heritage assets is important but should not
jeopardise operational safety or hinder expansion.
✓
As many listed buildings as possible should be kept,
even if it means relocation.
✓
Recognised the importance of the historic
environment but considered that its importance was
overplayed, and that effect could not be avoided.
✓
Historic environment would be impacted or
destroyed by expansion.
✓
It is noted that the impact on Colnbrook
Conservation Area and the listed properties within it
will be taken into account.
✓
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Do not support an approach that would result in
heritage sites and features being destroyed or
adversely impacted.
✓
The impact on the environment will be hugely
negative.
✓
Supported efforts to offset effects but considered
that this could not be adequately achieved.
✓
Concern about the effects of increased traffic
through Chiswick Hogarth roundabout on the Old
Chiswick Conservation Area.
✓
Heathrow’s plans for the historic environment were
inadequate or lacking detail.
✓
Do not support an approach which would destroyed
or adversely impact heritage sites.
✓
Concerns about the loss of irreplaceable historic
assets and listed buildings.
✓
How can the development be acceptable when it
results in the loss of listed buildings and other
heritage assets?
✓
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Concern about the potential loss of heritage features
along river channels.
✓
Concern that expansion would result in the loss of
other historic milestones along Bath Road between
Harlington and Longford and the cannon marking the
northern end of General Roy's Base. These assets
should be protected as part of scheme design and
during construction.
✓
Concern about the potential loss and relocation of
the Great Barn.
✓
The historic buildings to the north of Stanwell or
Stanwell Moor could be deconstructed and rebuilt in
a new location near the airport and used as a
teaching/learning opportunity.
✓ Heathrow are undertaking an EIA, which includes an assessment of
impacts on the historic environment and will conclude with mitigation
measures to avoid and reduce adverse impacts. Early findings and
mitigation proposals will be set out in the PEIR to be published for
consultation in the Airport Expansion Consultation in 2019.
Our approach to mitigation for heritage assets includes a consideration
of the translocation of heritage assets to retain elements of architectural
and historic interest. It also includes the provision of enhanced access
and interpretation to heritage assets to mitigate potential loss of historic
interest.
The proposed Cultural Interpretation Framework
should raise public awareness of the results of
previous archaeological interventions, and the
history of the area generally.
✓ Heathrow will consider its approach to heritage interpretation as part of
wider measures to be proposed in reference to the preferred masterplan
and this will be presented at Airport Expansion Consultation in June
2019.
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Any diversions of rivers around the airport will have
an impact on hydrology which could lead to locally
waterlogged deposits experiencing periods of drying
which would be detrimental to preservation of
archaeological remains.
✓ Heathrow are undertaking research to predict the nature and extent of
surviving archaeological remains across the site. Early findings of the
EIA for the Project will be reported in the PEIR to be published as part
of the Airport Expansion Consultation in June 2019. This will include an
assessment of likely effects of the Project on heritage assets.
Appropriate testing and modelling of the water
environment before, during and after diversions
could be required and that Lidar data (as well as
geophysical survey) may be of use in locating
potential former paleo channels.
✓
Further detail on the potential for heritage assets
currently in viable uses to become at risk as a result
of airport expansion citing the Great Barn, St Mary’s
Church and the Five Bells public house in
Harmondsworth as examples of this.
✓ Potential impacts of the Project on the Great Barn, St Mary’s Church,
Lanz Farmhouse, the King William IV Public House and Five Bells
public house in Harmondsworth are being assessed as part of the EIA
for the Project. Early findings will be reported in the PEIR to be
published as part of the Airport Expansion Consultation in June 2019.
This will include both an assessment of likely effects of the Project on
heritage assets and potential impacts in regard to community resources
and businesses (reported in the Community and Socio-Economic
chapters of the PEIR).
Lanz farmhouse and the King William IV public house
(both on Harmondsworth Lane and listed Grade II)
will be subject to significant effects should the
westernmost runway option be taken forward and
should be considered as part of the assessment.
✓
Historic assets affected by expansion should be
enhanced.
✓ Heathrow recognises that loss of conservation areas and listed
buildings is only permitted in exceptional or wholly exceptional
circumstances. The ANPS guides Heathrow to make decisions that
avoid and minimise harm, and this applies to all aspects of the project,
including temporary as well and permanent development effects that All heritage assets must be protected and not
removed.
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Wherever possible historically significant buildings
and areas should be retained.
✓ might harm the fabric of heritage assets or the setting of heritage
assets.
One of the key principles of Heathrow’s approach to the historic
environment is opportunity. As part of this, an exploration of initial
options to unlock the potential for sustainable uses of heritage assets
and for creating circumstances to help others to manage heritage
assets that might otherwise be at risk; as well as creating new amenity
that increase people’s ability to enjoy the wider historic environment.
Heathrow’s understanding of the heritage assets and their significance
will inform design proposals for the Project and in doing so address the
ANPS policy.
Specifically, Heathrow will seek to reduce loss of or substantial harm to
the Longford conservation area and part of Harmondsworth
conservation area and associated heritage assets, including both
designated and non-designated heritage buildings. This is underpinned
by the evaluation process for the ongoing design of the Project, which
includes a consideration of heritage as part of the assessment criteria
that influence the progression of the design. The outcomes of this
evaluation, including how criteria have informed the decision-making
process in considering design options will be reported in the Updated
Scheme Development Report in June 2019.
Heathrow is restricted to minimal land take essential to expand national
airport capacity in accordance with the ANPS.
Early findings of the EIA for the Project will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019. This will include an assessment of likely effects of the Project on
heritage assets.
Would like to see enhancements to the conservation
area and the urban realm and that appropriate parts
of the Colnbrook and Poyle. Green envelope should
be managed and enhanced in a way which would
reflect the historic importance of the area.
✓
Enhancements should be made to the conservation
area and that Heathrow should contribute financially
to local projects which would preserve the historic
past.
✓
The appropriate development of the airport would
enhance the use of these assets and boost the
adjacent tourism, leisure and heritage sectors.
✓
Areas of countryside character that support remnant
features of an agricultural landscape should be
considered for protection and/or enhancement in any
proposals.
✓
The scheme should make a positive contribution to
the historic environment both in its immediate area
and further afield where new flight paths may alter
the way historical assets can be enjoyed.
✓
The project should make a contribution to retain the
historic environment wherever possible.
✓
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Heathrow should establish a new conservation area
into which affected heritage assets could be moved.
✓ The designation of new conservation areas (or amendments to existing
conservation areas) is a matter for the relevant local authority in
accordance with the provisions of the Planning (Listed Buildings and
Conservation Areas) Act 1990.
Heathrow will assess the effects of the Project on heritage assets and
early findings of the EIA for the Project will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019.
The village of Horton should be designated a
conservation area to protect heritage buildings and
residents from disruption from passing vehicle
traffic.
✓
Requested further development of the heritage
mitigation scheme to achieve wider objectives
around traffic management, environmental, social
economic compensatory and mitigation actions and
highlighted that this will be particularly relevant to
the ‘green envelope’ concept at the Colnbrook Village
Conservation Area.
✓ The heritage mitigation scheme will be further developed to achieve
wider objectives around traffic management, environmental, social
economic compensatory and mitigation actions. This information will be
provided in the PEIR to be published in June 2019.
Concern that the measures proposed to mitigate
effects on the historic environment were unsuitable,
would not make a difference or lacked credibility.
✓ At Airport Expansion Consultation One high level information was
provided on Our approach to the Historic Environment, which reflected
the early stage of the design process, environmental assessment and
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The measures set out in the approach to historic
environment should be definite commitments rather
than just aspirations.
✓ mitigation proposals relating to the Project.
Heathrow is continuing to develop the preferred masterplan which
includes understanding the potential effects on heritage assets.
Early findings of the EIA for the Project will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019. This will include an assessment of likely effects of the Project on
heritage assets. The PEIR will also consider mitigation measures and
will reflect continued engagement with Historic England (and other
stakeholders).
Concerns about the impact of noise and air pollution
on the historic environment.
✓ Heathrow will assess the effects of the Project on the Historic
Environment and this will include the effects of noise on the setting of
heritage assets. Early findings of the EIA for the Project will be reported
in the PEIR to be published as part of the Airport Expansion
Consultation in June 2019.
Concerns about the cost of the effects on the historic
environment.
✓ As part of the EIA for the Project Heathrow will be carrying out an
assessment of the likely effects on the historic environment, and this will
include consideration of relevant measures to address any identified
effects.
Early findings of the EIA for the Project will be reported in the PEIR to
be published as part of the Airport Expansion Consultation in June
2019, and this will include consideration of mitigation.
The cost of preserving and/or relocating the heritage
assets should be borne by Heathrow and not
taxpayers.
✓
There should be an ongoing levy to support historic
assets across London.
✓
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There should be contributions, sponsorship and
support for local museums and galleries.
✓
Establishment of a levy or other mechanism to fund
and sustain heritage assets (in particular parks and
historic gardens across London which are not
supported through statutory funding) would bring
huge benefits across London and provide a unique
way of offsetting any damage done.
✓
A more proactive approach should be adopted to
enable the adequate recording of affected sites.
✓
Any archaeology found should remain publicly
accessible.
✓
Items recovered from investigations should be
preserved in a local museum e.g. the Museum of
Middlesex’, ‘Colne Valley Visitor and Learning Centre
or a Heathrow Heritage Museum.
✓
If the Old Bath Road in Longford is removed heritage
assets should first be carefully recovered, preserved,
re-installed and exhibited elsewhere at Heathrow’s
expense. An appropriate museum for such a display
might include the Chiltern Museum which holds and
displays several historic highways assets removed
from the line of the M25.
✓
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Priority should be placed upon listed buildings that
have a social function and contribute to community
health.
✓ The Historic Environment assessment methodology recognises the
requirement for designated heritage assets to be assessed on a case
by case basis, in accordance with legislation. This approach is adopted
for Listed Buildings, Registered Historic Parks and Gardens, and
Scheduled Monuments.
Heathrow will present findings of its initial assessment of impacts on the
historic environment in the PEIR as part of the Airport Expansion
Consultation in June 2019.
If archaeology is found to be present within the site it
would be best to leave it undisturbed and not be
compelled to ‘save/rescue’.
✓ Heathrow are undertaking research to predict the nature and extent of
surviving archaeological remains across the site. Early findings of the
EIA for the Project will be reported in the PEIR to be published as part
of the Airport Expansion Consultation in June 2019, and this will include
the approach to confirming baseline data. Land take should be minimised to preserve as much
archaeology as possible.
✓
The historic environment and natural environment
issues should be considered together.
✓ Heathrow is continuing to engage with Historic England and other
stakeholders, and this includes regular meetings with the HSPG under
forums relating to both green infrastructure and the historic
environment.
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Concerns about the effects of expansion on specific
properties or locations, these included:
• Colnbrook, Harmondsworth, Longford and Sipson conservation areas;
• heritage assets along the River Thames;
• Osterley House;
• Cliveden House and Gardens;
• Hampton Court Palace;
• the historic centre of Windsor;
• heritage assets in Richmond Park;
• the Air Force Memorial at Runnymede;
• buildings in Bedford Park;
• Chiswick House;
• St Mary's Church;
• Windsor Castle;
• heritage assets at Kew Gardens;
• Harmondsworth Great Barn;
• Holloway Collage and Holloway Sanatorium;
• Taplow Court (Saxon burial site);
• Bushy Park; and
• Windsor Great Park.
✓ The ANPS gives great weight to heritage conservation (paragraph
5.200). Harmful impacts will be weighed against the public benefit of
Heathrow’s proposals, recognising that the greater the harm to the
significance of the heritage asset, the greater the justification that will
needed for any loss (paragraph 5.203).
Heathrow acknowledges and appreciates the feedback received
regarding specific heritage assets. We will assess the likely effects of
the Project on all heritage assets which fall within the study areas
confirmed for the purposes of the EIA, and early findings will be
presented in the PEIR as part of Airport Expansion Consultation in June
2019. This will include relevant mitigation measures being considered.
Chapter 11, Section 11.9 of Heathrow’s EIA Scoping Report (2018) sets
out our approach to preparing the baseline and identification of heritage
assets for the assessment of impacts on the historic environment.
Heathrow recognises that it may be possible to relocate and reconstruct
heritage assets where they would otherwise be lost or significantly
affected by development, but such actions can only ever be considered
on a case-by-case basis.
Full weight should be given to protecting and
improving the World Heritage Site at Kew which is
significantly impacted by noise.
✓
Why the designation of Colnbrook as a Potential
Historic Enhancement Area was not referred to in the
approach to historic environment or consultation
information.
✓
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The Sant Nirankari Mission should be exempt from
inclusion within the expansion plans due to their
spiritual and architectural heritage which cannot be
transferred to another site.
✓
Concern that the expansion of Heathrow will have a
direct impact on National Trust properties
✓
The airport perimeter in the vicinity of
Harmondsworth should be designed to deflect
aircraft noise and mitigate visual impact on its
setting.
✓
Concern about the destruction of the Old Bath Road
in Longford. As the route does not form part of the
runway it would be possible to retain it and site any
required ancillary buildings or features elsewhere or
build them in such a way to allow retention of the
route.
✓
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The Kings Bridge over the river in Longford should
be retained and repositioned in a publicly accessible
area.
✓
Sipson Church, Sun House, Five Bells Inn, Grange
House, Crown Inn, Gorge and Barnes Wallis
Memorial should be considered for relocation and
that the best historic buildings in the Longford
Conservation Area should be relocated to the north.
✓
Sites potentially affected by expansion and changes
to flight paths include Cliveden, Claremont Garden,
Morden Hall Park, Basildon Park, Carlyle’s House,
575 Wandsworth Drive, 2 Willow Road and Fenton
House.
✓
A historic brick bridge across the Upper Duke’s River
near to Harmondsworth could be at risk due to the
Project.
✓
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Harmondsworth Great Barn is on a timber frame and
should be relocated, possibly to the Chalfont Open
Air Museum.
✓ Heathrow’s proposals to the Airports Commission, developed following
consultation with local communities, suggested options for the
preservation of both the Grade I listed Harmondsworth Great Barn and
the Grade II* listed St Mary’s Church in the present locations. Retaining
these significant heritage assets in in situ remains our preferred
approach, although one of our key concerns is to avoid exposing them
to increased risk. Heathrow will continue to consult with residents and
other stakeholders about options for the future setting and use of these
buildings and the ways in which we can mitigate the effects of the
development.
The effects of the Project on both the Great Barn and St Mary’s Church
will be assessed and early findings presented in the PEIR as part of the
Airport Expansion Consultation in June 2019.
The area around the Great Barn should be expanded
to a Heathrow Heritage Site.
✓
If the Great Barn cannot be retained as a monument
because of noise levels the northern half of
Harmondsworth Conservation Area, also has no
future.
✓
Church of St Mary and the Great Barn at
Harmondsworth must be retained and that any
options that do not meet these criteria should be
discontinued.
✓
St Mary's Church will lose its congregation and will
come to resemble Lowfield Heath.
✓
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Concerns about the effects on the green belt,
heritage assets, biodiversity, increased levels of
traffic and parking, new transport infrastructure such
as road repositioning and widening, new railway
lines and additional airport support facilities.
✓ The ANPS gives great weight to heritage conservation (para 5.200).
Harmful impacts will be weighed against the public benefit of
Heathrow’s proposals, recognising that the greater the harm to the
significance of the heritage asset, the greater the justification that will
needed for any loss (para 5.203).
Heathrow are undertaking an EIA of the Project, and early findings will
be reported in the PEIR to be published as part of the Airport Expansion
Consultation in June 2019. This will include an assessment of likely
effects of the Project on heritage assets. It will also include chapters
reporting findings of our assessed impact on biodiversity, traffic and
transport and landscape.
Suggestion that the results of all work and mitigation
for the third runway project should be integrated with
the Geographical Information System (GIS).
✓ All fieldwork arising from trial work and mitigation for the third runway
project will be integrated with the GIS system.
A deposit model should be created and that detailed
topographic survey data for areas required for the
new expanded Heathrow should be undertaken.
✓ Heathrow is collating all available aerial photography, and LIDAR data
which will inform the topographic survey assessment, including mapping
areas already destroyed.
Any archaeological findings should also be displayed
locally at venues such as visitor centres, museums,
community buildings and public houses.
✓ In the ES, Heathrow will set out the proposed methodology for
developing and implementing an archaeological research framework
from the early stages of the Project through to completion. Early
proposals on this framework will be set out in the PEIR, to be published
in June 2019.
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The importance of retaining and enhancing the
setting of historic villages such as Colnbrook and
Harmondsworth and suggested that community
development projects should be implemented to
maintain and build community and ‘village life’.
✓ As part of considering mitigation measures associated with the effects
of the Project on historic environment, Heathrow will be exploring a
strategy for enhancing the setting of historic villages. The strategy is
also considering how heritage assets can be used for community
development projects in the local villages to maintain the assets and
help build community life
Heathrow continues to run Community Engagement workshops which
include discussions on heritage assets and their role within local
communities, and this will inform the development of the preferred
masterplan to be presented at the Airport Expansion Consultation in
June 2019.
Heathrow should provide simple interpretation
boards to keep the public fully informed during
construction. These could include artist’s
impressions of the pre-historic landscape of the
Colne Valley, photos/artwork of the C20th landscape,
a viewing hole to the construction site or and artists
impression of restored green infrastructure or airport
development at the site.
✓ Heathrow’s will be developing its wider interpretation strategy, which will
include heritage interpretation, and early details of this will form part of
the materials presented with the preferred masterplan at Airport
Expansion Consultation in June 2019.
The assessment of significance should include
spiritual significance and that other churches,
graveyards and cemeteries in the study area should
not be overlooked.
✓ Heathrow are undertaking an assessment of impacts on heritage assets
as part of the EIA. Churches cemeteries, and graveyards are included
in this assessment. Early findings will be published for consultation in
June 2019 in the PEIR.
The new runway also has the potential to dominate
views from Coopers Hill at Runnymede.
✓ Heathrow will be including Coopers Hill in our landscape and visual
impact assessment, and preliminary findings will be presented in the
PEIR as part of the Airport Expansion Consultation in June 2019.
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Surveys for structures, heritage or archaeological
features should be undertaken by Heathrow’s
consultants.
✓ Heathrow have appointed a range of environmental specialists to
undertake environmental surveys and assessment work.
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AIRSPACE
Introduction
25.1.1 In response to Airport Expansion Consultation One, most consultees that made
comments about airspace did so directly in response to the Airspace Consultation
which had a separate feedback form. These are separately reported in the
Airspace Principles Analysis of Findings Report. Consultees did however make
general comments in relation to flight paths and airspace in their responses to the
Airport Expansion Consultation One. A total of 134 consultees made comments
relating to this topic.
25.1.2 Heathrow provided the following material that is directly related to airspace:
1. Airport Expansion Consultation Document;
2. Our Emerging Plans;
3. Airspace Principles Consultation Document;
4. Airspace Change Information Paper; and
5. Heathrow Operations Handbook.
25.1.3 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Heathrow
Airport Expansion Project (the Project), we have provided a summary of the way in
which we are seeking to consider the issues as part of preparing the detailed
proposals which will be presented as part of the Airport Expansion Consultation
planned for June 2019.
Prescribed Consultees
Local Authorities
25.2.1 The most common response from local authorities was that flight paths had not
been shown and so it was not possible to understand who would be affected and
to what extent. The London Borough of Brent, Ealing Council, Elmbridge Borough
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Council, Spelthorne Borough Council, Surrey County Council, and the Royal
Borough of Windsor and Maidenhead all made this comment.
25.2.2 Buckinghamshire County Council commented that new flight paths could have a
significant adverse impact on the quality of life and health of its residents, service
users and workers. They considered that minimising the need to affect new
populations and businesses should be the first principle in the redesign
of airspace.
25.2.3 They also expressed concern about impacts on the communities of Dorney and
Taplow who would be directly under the east – west flight path, and the Colne
Valley Regional Park which they considered would be significantly adversely
impacted if the majority of new flight paths are routed away from urban areas.
25.2.4 The Royal Borough of Kingston upon Thames expressed concern that flight paths
will be focussed on areas that do not already have significant air quality issues and
will therefore be over areas with existing low background noise levels. They asked
for further information on the assessment principles and the capping of airport size
and flight numbers. They also queried the implications for aircraft stacking if the
airport operates at full capacity.
25.2.5 Kent County Council emphasised the importance of working with local
communities and those affected by overflight to reduce the impacts of noise from
the Project. They also considered that new flight paths may alter the way heritage
assets can be enjoyed.
25.2.6 Runnymede Borough Council stated that there should be a wider dispersal of flight
paths in order to distribute noise more fairly. They considered that although this
would affect more people it would provide greater respite to those that would
otherwise be under a concentrated flight path.
25.2.7 Spelthorne Borough Council suggested that planes should gain as much altitude
as possible as quickly as possible and that the current stacking arrangements
should be removed. They also commented that residents should benefit from
quieter aircraft/airport technology and systems.
25.2.8 Surrey County Council expressed concern that if the new runway cannot
accommodate the largest planes it would increase usage of the other runways with
the likelihood of more overflight of its communities.
Statutory Consultees
25.2.9 Highways England queried whether the environmental statement for the airspace
change process will be the same as for the DCO application. They commented
that if the two are different they will need to be consulted on whether the
determination of flight paths could alter decisions about highway networks.
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Other prescribed bodies
25.2.10 Albury Parish Council expressed concern about planes taking off to the west and
then turning east on route to Europe and eastern destinations. They considered
that the increased number of aircraft using these routes would further impact on
the Surrey Hills AONB and its tranquillity.
25.2.11 Bray Parish Council also said that little or no information about flight paths had
been provided.
25.2.12 The Civil Aviation Authority (CAA) stated that there must be no unacceptable
safety, economic or airspace consequences arising from the proposals that would
prevent them from providing the relevant regulatory approvals. They stated that
this will require Heathrow to engage with the CAA on its proposals with sufficiently
detailed and mature information so that they can provide meaningful advice and
commentary and ultimately be satisfied that the ‘no impediments’ threshold has
been met.
25.2.13 The Heathrow Strategic Planning Group highlighted that a key issue was how
predictable, reliable runway and flight path alternation could be provided to allow
respite to local communities throughout the day, night and shoulder periods.
Local Communities
Members of the public
25.3.1 Members of the public commented that flight paths should be over less populated
areas and should consider noise. Linked to this were suggestions that urban
areas should be avoided, that flights should not be routed over London and that
where flights do go over urban areas the flight paths should be wider to share
noise more equally.
25.3.2 Suggestions were also received that flight paths should be moved to locations
where dilution or dispersion would be easier, circling/stacking should be reduced
and flight paths should be tied to specific noise and air quality limits.
Businesses
25.3.3 Greengauge 21 requested an analysis of the costs and environmental benefits of
extending the Southern Runway to the west to provide quieter landings for planes
from the east and decrease the number of residents within the 65-decibel contour.
25.3.4 Heathrow Hub commented that the scheme is dependent on an unprecedented
scale of airspace change and if this cannot be delivered the scheme would not be
able to operate at the capacity and/or with the respite that has been assumed.
They also expressed concern that there is no consideration how airspace change
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would affect other London and south east airports or the flight paths necessary to
deliver runway alternation and respite.
25.3.5 The London Airline Consultative Committee and the Board of Airline
Representatives UK stated that the UK’s airspace is in urgent need of
modernisation and this is necessary to support the Project. Clear policy direction
from the government is urgently required to ensure that the international
commitments of the UK via ICAO’s Balanced Approach to noise, carbon and air
quality needs can be met.
25.3.6 They also expressed concern that until an airspace design is agreed it will not be
possible to define, consult on and agree the noise envelope.
25.3.7 PPL/IR Europe commented that the needs of other airspace users need be
considered. They specifically highlighted the following three groups who use
airspace near to Heathrow:
1. Light aircraft flying instrument flight rules through the London Terminal Control
Area;
2. Light aircraft flying visual flight rules to airports in the Heathrow vicinity; and
3. Light aircraft flying visual flight rules outside the control zone.
25.3.8 They stated that flight paths that are as direct as possible and allow aircraft to
climb and descend as quickly as possible have the potential to minimise controlled
airspace. They also stated that any expansion of the Heathrow control zone to
accommodate new flight paths must consider the impact on potential chokepoints
in the visual flight rule corridors outside the control zone.
25.3.9 Virgin Atlantic Airways Limited considered that if airspace is not upgraded
passenger delays will increase as traffic levels increase. They cited analysis
conducted by NATS on behalf of the Department for Transport (DfT) which
predicts that by 2030 air traffic delays will increase to 5.6 million minutes and
commented that if delays reach this level, more than 1 in 3 flights from all UK
airports will depart over half an hour late. They stated that such delays would have
significant environmental consequences and would reduce the resilience of the air
transport network.
Community groups
25.3.10 Many of the community groups who provided feedback to Airport Expansion
Consultation One expressed opposition to the Project but did not necessarily
include specific feedback on flight paths and airspace
25.3.11 Aircraft Noise Three Villages, Ealing Fields Residents Association, Eastcote
Conservation Panel and the Local Authorities Aircraft Noise Council commented
that the lack of detail on the position of flight paths made it difficult to understand
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how communities would be impacted and respond to the consultation. The Local
Authorities Aircraft Noise Council also commented that people need to know if
they are likely to be overflown and how often.
25.3.12 St Albans Quieter Skies stated that Heathrow affects all communities on or near its
departure flight paths including those between 6,000 and 11,000 feet, as up to this
altitude aircraft are climbing steadily and often sustaining high levels of noisy climb
thrust. They also noted that Heathrow flights at this altitude overlap with those
from Luton and force departures from Luton to fly at lower levels causing a
persistent noise nuisance.
25.3.13 They expressed concern about the impact of the proposed increase in aircraft
numbers on Hertfordshire, the current very high levels of vectoring off Heathrow
departure routes (BUZAD and BPK) directly over St Albans and the likely
significantly increase in noise over certain parts of London and the Home Counties
caused by the Project.
25.3.14 They also stated that the burden of aircraft noise should be shared out equally and
fairly among the UK population and suggested that as London’s airspace is
already one of the busiest in the world the expansion of air traffic should instead
be in less busy areas of UK airspace.
25.3.15 Teddington Action Group commented that the masterplan should not be
developed until environmental conditions including the restriction of air pollution
and noise as well as flight paths, are finalised.
25.3.16 Cheyne Walk Trust stated that flights over central and SE/SW London are a major
hazard in this age of non-state terrorism.
25.3.17 Local Conversation in Stanwell welcomed the added respite that would be
provided through runway alternation. However, they commented that the use of
the existing runways to create an additional 25,000 flights per annum would likely
result in a reduction of respite which would have an adverse impact on residents’
quality of life. They also commented that since the scrapping of The Cranford
Agreement there has been no change to the operating procedures at the airport
during easterly operations.
25.3.18 Wentworth Residents Association stated their preference for airport expansion at
Gatwick and highlighted the concerns and mistrust of Heathrow by local
communities following flight path changes in 2015.
25.3.19 The Fulham Society stated that the concentration of flights in a densely populated
area is unfair and unnecessary. They considered that regardless of the Project,
new measures that reduce the number of flights arriving over West London are
required as this is the only way to reduce noise.
25.3.20 West Windsor Residents Association stated that their residents will be situated
between the flight paths of two runways. They expressed concern that aircraft
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operating on the new runway would be flying at significantly lower altitude than
those on the current northern runway and as there would be significantly more
aircraft movements this will make relief periods almost non-existent.
25.3.21 Spring Grove Residents Association expressed concern about noise from
overflying aircraft and highlighted that a third runway would create a new approach
path over Osterley and ruin the peace of Osterley Park.
Wider/other Consultees
25.4.1 Aviation Safety Investigations commented that no indication had been provided
about how the go-around flight paths will be integrated with the proposed
departure routes.
25.4.2 London Biggin Hill Airport recognised that there are options for changing the
routes of arriving and departing flights and opportunities to reduce noise by raising
their height. They recommended that Heathrow should seek to reduce the noise
on existing routes rather than creating new noise impacted areas.
25.4.3 Dominic Rabb MP stated that the Project provides an opportunity to shift away
from the current policy of concentrated flight paths towards a policy of dispersal
over a wider geographical area. He considered that this would provide relief to
local residents most severely impacted by noise and asked Heathrow to take this
opportunity to improve local residents’ quality of life.
25.4.4 The Mayor of London considered it unacceptable that the indicative flight paths
that would form the basis of the DCO may bear no relation to the actual future
flight paths used. He suggested that to meaningfully address public concerns the
process should be accelerated and actual flight path options used.
25.4.5 The London Parks and Gardens Trust urged a re-think on flying over parkland and
in particular, designated historic spaces. They also considered that as well as
compensating householders Heathrow should compensate local authorities for
loss of amenity value of parkland by setting up a fund for public parks.
25.4.6 The Campaign to Protect Rural England stated that more sophisticated flight
programming may result in future improvements but would depend on better
coordination and reliability of take-off and landings so that “stacking” is less
necessary.
25.4.7 The National Trust requested further details on the geographic areas for potential
flight path options, the likely environmental effects such as noise, air quality and
health and Heathrow’s plans for mitigation.
25.4.8 The Hounslow Green Party expressed opposition to the Project stating that it
includes destruction of communities and introduction of blight to new areas. They
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also expressed concern that no clear indication of new flight paths had been
provided.
25.4.9 The Lambeth/Herne Hill Green Party stated that the use of multiple rotated flight
paths and sharing routes over a wider area would give communities a break from
noise each day. They also considered that new technology to modernise airspace
may provide respite for local communities.
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Issues Raised and Heathrow’s Responses
Table 25.1A below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Airspace. The table presents a summary of Heathrow’s responses to the issues on the basis that they
relate to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation
(January 2019), and how in preparing those proposals we have had regard to the relevant Airport Expansion Consultation One
feedback.
Table 25.1A
Issue Consultee17
PC MC WC Heathrow Response
Flight paths had not been shown and so it was not possible to
understand who would be affected and to what extent.
✓ We recognise that some people want to see detailed
flight path options before engaging in our design
process. We also recognise that some people want
to be involved from the outset, so that they have a
chance to influence the development of the options
whilst we still have a blank sheet. We have therefore
developed a 3-phase consultation strategy designed
to involve people at key stages as soon as design
The lack of detail on the position of flight paths made it difficult to
understand how communities would be impacted and respond to the
consultation.
✓
Little or no information about flight paths had been provided. ✓
17 Prescribed Consultees (PC), Members of the local community (MC) and Wider Consultee Groups (WC)
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No indication had been provided about how the go-around flight paths
will be integrated with the proposed departure routes.
✓ detail becomes available.
Airspace Principles Consultation One (January –
March 2018) was on airspace design principles, for
those wanting to influence from the outset. The
process for the development of the airspace design
principles, which have now been fixed, is set out in
Heathrow's Airspace Design Principles for
Expansion.
The Airspace and Future Operations Consultation,
which is currently taking place, is seeking feedback
on local factors that should be taken into account in
defining the flight paths within the design envelopes.
For more information, please see Heathrow’s
Airspace design envelopes for expansion, Making
better use of our existing runways, and
Understanding our design envelopes.
In our Airport Expansion Consultation we will present
preliminary environmental information which will
include an assessment of the effects of overflight
based on indicative flightpaths, in accordance with
the Airports NPS.
Then, our final consultation will seek feedback on
detailed route options and impacts arising from the
specific flight paths. This consultation is scheduled to
take place in 2022.
This 3-phase approach to consultation gives
stakeholders a number of opportunities to influence
the airspace change process, to include with
Further details requested on the geographic areas for potential flight
path options, the likely environmental effects such as noise, air quality
and health and Heathrow’s plans for mitigation.
✓
No clear indication of new flight paths had been provided. ✓
People need to know if they are likely to be overflown and how often. ✓
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reference to flight path design whilst allowing us to
present information as it becomes sufficiently certain.
New flight paths could have a significant adverse impact on the quality
of life and health of its residents, service users and workers.
✓ We are currently exploring plans to use the existing
runways more to create up to 25,000 ATMs per year.
This would be in advance of the completion of the
third runway and could only happen if consent for
expansion is granted. This would be an initial first
phase out of the additional ATMs per year that
expansion will permit.
This proposal will be the subject of a full assessment
as part of the development consent order application
(and airspace change process), to include in respect
of health and quality of life. At this stage the effects
are yet to be determined as we are still in the
formative phase of the design process.
It should be noted that the Airports National Policy
Statement (Airports NPS)18 requires that Heathrow’s
proposals must meet the following aims for the
effective management and control of noise, within the
context of Government policy on sustainable
development:
The use of the existing runways to create an additional 25,000 flights
per annum would likely result in a reduction of respite which would
have an adverse impact on residents’ quality of life.
✓
This would provide relief to residents most severely impacted by noise
and asked Heathrow to take this opportunity to improve local residents’
quality of life.
✓
18 https://www.gov.uk/government/publications/airports-national-policy-statement
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• Avoid significant adverse impacts on health and
quality of life from noise;
• Mitigate and minimise adverse impacts on health
and quality of life from noise; and
• Where possible, contribute to improvements to
health and quality of life.
In terms of our approach thus far, a Noise Expert
Review Group has been established to
independently peer review Heathrow’s approach to
aircraft noise assessment to ensure it is robust, and
Heathrow has set out its proposed methodology for
scoping and assessing aircraft noise for Expansion in
the Scoping Report submitted to the Planning
Inspectorate.19 On the basis of the information
provided in that report, the Planning Inspectorate
adopted its Scoping Opinion on 29 June 2018. This
sets out the Planning Inspectorate's opinion as to the
scope and level of detail of the information to be
provided in Heathrow's environmental statement, as
part of the development consent order application.20
19 https://infrastructure.planninginspectorate.gov.uk/projects/london/expansion-of-heathrow-airport-third-runway/?ipcsection=overview
20 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000451-HTHR%20-%20Scoping%20Opinion.pdf
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Minimising the need to affect new populations and businesses should
be the first principle in the redesign of airspace.
✓ These issues all relate to Heathrow's airspace design
principles and their prioritisation.
Heathrow's airspace design principles for Expansion
were submitted to the CAA on 31 August 2018 and
were approved on 28 September 2018. This forms
part of the CAA's CAP1616 process for establishing
design principles for airspace. The airspace design
principles are now fixed and will be used to evaluate
our airspace design options.
As part of the process for securing this approval from
the CAA, Heathrow received a number of responses,
in addition to those listed here, from the Airspace
Principles Consultation One. All of the issues raised
in those responses were considered by Heathrow
and were addressed in our submission to the CAA in
August last year.
Each of the comments listed here pertain to issues
which Heathrow has already considered and
addressed in the submission to the CAA on airspace
design principles. For a summary of this work see
Heathrow’s airspace design principles for Expansion.
For more information, please see:
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Heathrow-airspace-departure-and-
Heathrow should seek to reduce the noise on existing routes rather
than creating new noise impacted areas.
✓
The needs of other airspace users need be considered, specifically,
light aircraft flying instrument flight rules through the London Terminal
Control Area, light aircraft flying visual flight rules to airports in the
Heathrow vicinity and Light aircraft flying visual flight rules outside the
control zone.
Any expansion of the Heathrow control zone to accommodate new
flight paths must consider the impact on potential chokepoints in the
visual flight rule corridors outside the control zone.
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Flight paths that are as direct as possible and allow aircraft to climb
and descend as quickly as possible have the potential to minimise
controlled airspace.
arrival-procedures/.
If airspace is not upgraded passenger delays will increase as traffic
levels increase.
Analysis conducted by NATS on behalf of the DfT which predicts that
by 2030 air traffic delays will increase to 5.6 million minutes and
commented that if delays reach this level, more than 1 in 3 flights from
all UK airports will depart over half an hour late.
New technology to modernise airspace may provide respite for local
communities.
✓
It includes destruction of communities and introduction of blight to new
areas.
✓
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Welcomed the added respite that would be provided through runway
alternation.
✓
There are options for changing the routes of arriving and departing
flights and opportunities to reduce noise by raising their height.
✓
Planes should gain as much altitude as possible as quickly as possible
The use of multiple rotated flight paths and sharing routes over a wider
area would give communities a break from noise each day.
✓
There should be a wider dispersal of flight paths in order to distribute
noise more fairly. Although this would affect more people it would
provide greater respite to those that would otherwise be under a
concentrated flight path.
✓
The scheme is dependent on an unprecedented scale of airspace
change and if this cannot be delivered the scheme would not be able to
operate at the capacity and/or with the respite that has been assumed.
✓ Major changes to flight paths and the tools used by
air traffic controllers are taking place across the UK
as the Government implements its Airspace
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Concern raised that there is no consideration how airspace change
would affect other London and South- East airports or the flight paths
necessary to deliver runway alternation and respite.
✓ Modernisation Strategy. This is being led by the CAA
and is overseen by the Department for Transport.
The Airspace Modernisation Strategy will require all
the UK's main airports to modernise their airspace.
For more information on airspace modernisation,
please see What is airspace modernisation?
We plan to carry out the process to modernise our
airspace at the same time as we expand the airport.
We are coordinating our airspace change design
process with both NATS and all relevant
neighbouring airports. This will help to ensure that
both Expansion and airspace modernisation can be
delivered at Heathrow. In addition, this will ensure
that our proposals and the operations of our
neighbouring airports can function in tandem.
This Airspace and Future Operations Consultation
provides an opportunity to give feedback on a
number of areas, to include the delivery of respite to
local communities using our runway and airspace
alternation pattern.
The UK’s airspace is in urgent need of modernisation and this is
necessary to support expansion.
✓
Heathrow flights at this altitude overlap with those from Luton and
force departures from Luton to fly at lower levels causing a persistent
noise nuisance.
✓
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The burden of aircraft noise should be shared out equally and fairly
among the UK population and suggested that as London’s airspace is
already one of the busiest in the world the expansion of air traffic
should instead be in less busy areas of UK airspace.
✓ The Government has designated the Airports NPS,
which sets out the need for additional airport capacity
in the south-east of England and confirms that the
Government believes that this need is best met by a
north-west runway at Heathrow.
Preference raised for airport expansion at Gatwick.
✓
As explained in the above response, the Airports
NPS confirms that the Government believes that the
need for additional airport capacity in the south-east
of England is best met by a north-west runway at
Heathrow.
Residents will be situated between the flight paths of two runways. ✓ This consultation provides an opportunity to inform
us of any local factors (e.g. any particularly noise
sensitive locations) which should be taken into
account when we reach the stage of designing the
flight paths within the design envelopes.
For more information, please see Heathrow’s
Airspace and Future Operations Consultation
Document and, in particular, Heathrow’s airspace
design principles for Expansion which sets out the
principles as to how we will determine flight paths.
Impacts would likely continue as a result of increased air traffic but
requested that noise levels be reduced.
✓ Future noise levels will be managed according to our
‘noise envelope’.
A noise envelope is a framework for the control of the
effects of noise. It provides certainty to communities
about how noise will be managed to comply with
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Government policy, balancing growth and noise
reduction, for the long term.
This would include a set of aims and principles,
performance targets, evaluation criteria (and
method), the mitigation measures to be applied as
considered necessary and a review period. This will
be developed in consultation and engagement with
stakeholders and local communities.
For more information, see Developing our approach
to noise management.
Heathrow affects all communities on or near its departure flight paths
including those between 6,000 and 11,000 feet, as up to this altitude
aircraft are climbing steadily and often sustaining high levels of noisy
climb thrust.
✓ We are responsible for the design of routes up to
7,000ft for arrivals into and departures out of
Heathrow.
Higher level airspace (i.e. above 7,000ft) is being re-
designed by NATS, with input from Heathrow,
neighbouring airports and other stakeholders. The
Government's Air Navigation Policy (2017) states
that changes at or above 7,000 feet will usually not
have a noticeable impact and for that reason
consultation is unlikely to be necessary.
For the latest details of our proposed changes below
7,000ft see Heathrow’s Airspace and Future
Operations Consultation Document and Making
Better Use of Our Existing Runways.
For NATS changes above 7,000ft, please see:
https://www.caa.co.uk/Commercial-
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industry/Airspace/Airspace-change/Decisions-from-
2018/London-Airspace-Management-Programme-
Phase-2---ATS-Network/
Importance of working with local communities highlighted as well as
with those affected by overflight to reduce the impacts of noise from
expansion.
✓ Our consultations are open to all communities,
whether they are currently overflown or not.
Furthermore, our engagement on airspace design
principles has involved speaking to focus groups
including those from areas not currently overflown.
For full details of our airspace design principles
submission to the CAA for Expansion, including
details of all consultation and engagement activities
undertaken as part of that submission, please see:
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Heathrow-airspace-departure-and-
arrival-procedures/
Concern raised about the impact of the proposed increase in aircraft
numbers on Hertfordshire, the current very high levels of vectoring off
Heathrow departure routes (BUZAD and BPK) directly over St Albans
and the likely significantly increase in noise over certain parts of
London and the Home Counties caused by expansion.
✓ These responses raise concern over a potential
increase in overflight of specific areas.
As explained above, we have developed a 3-phase
consultation strategy. This Airspace and Future
Operations Consultation asks stakeholders for local
information now in order that we are able to take
them into account when defining the flight paths
within the design envelopes. Local information could
include suggestions for noise sensitive areas or
Concern raised about impacts on the communities of Dorney and
Taplow who would be directly under the east – west flight path, and the
✓
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Colne Valley Regional Park which was considered to potentially be
significantly adversely impacted if the majority of new flight paths are
routed away from urban areas.
buildings that stakeholders believe should get special
consideration (which may include those mentioned).
Following this consultation we will consider all
suggestions on a case-by-case basis.
This response also raises a concern that the flight
paths will be routed away from populations. This
relates to the work that we have already undertaken
in respect of the airspace design principles for
Expansion. Similar comments were received during
the Airspace Principles Consultation One in January
2018 and, as explained previously in this table, those
comments were addressed in our submission on the
principles to the CAA.
Our work on airspace design principles for Expansion
has been approved by the CAA – full details of the
airspace design principles, as approved on 28
September 2018, can be found at:
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Heathrow-airspace-departure-and-
arrival-procedures/
For a summary of Heathrow's airspace design
principles for Expansion, please see Heathrow's
Airspace Design Principles for Expansion.
Concern about noise from overflying aircraft and highlighted that a
third runway would create a new approach path over Osterley and ruin
the peace of Osterley Park.
✓
Regardless of expansion, new measures that reduce the number of
flights arriving over West London are required as this is the only way to
reduce noise.
✓
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The increased number of aircraft using these routes would further
impact on the Surrey Hills AONB and its tranquility.
✓ Our airspace design principles were approved by the
CAA on 28 September 2018. Of the approved
principles, one of the more strategic principles (rather
than a 'core' requirement of airspace design) that
Heathrow is intending on delivering on is 6(f) i.e.
limiting, where possible reducing, local noise effects
from flights by prioritising routing flight paths over
parks and open spaces (rather than over residential
areas), but avoiding overflight of Areas of
Outstanding Natural Beauty (AONB).
Heathrow does intend on delivering this, but it should
be noted that inevitably some trade-offs will have to
be made when making decisions.
Although not providing a simple formula to develop
airspace design, the principles are a valuable first
step in the CAA's airspace design process. We will
refer to them whenever we make design decisions.
This will ensure transparency so that all our
stakeholders can see how the principles have been
taken into account in our emerging designs.
Please see: Heathrow's Airspace Design Principles
for Expansion for more information.
Since the scrapping of The Cranford Agreement there has been no
change to the operating procedures at the airport during easterly
✓ Although the Government confirmed the Cranford
Agreement should be removed in 2010 following
public consultation, we need to make changes to the
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operations. taxiways in order to implement full alternation on
easterly operations.
To do so, in 2013 we submitted a planning
application to the London Borough of Hillingdon. This
was rejected so we appealed, and this was
eventually overturned by the Government in 2017.
However, we then assessed whether the taxiway
works approved in our original application would fit
with the airfield design for an expanded Heathrow
and this demonstrated the need to reposition the
taxiway works. Moving the location of the taxiway
works will change the noise impacts from departing
aircraft. Taken together, this will require a new
planning application to account for these changes.
We are therefore pursuing this work through our
DCO application.
Concern raised about planes taking off to the west and then turning
east on route to Europe and eastern destinations.
✓ For safety reasons, aircraft generally take off and
land into the wind. In the UK, the prevailing winds are
mostly south-westerly (from the south west). As a
result, the majority of aircraft (approximately 70% a
year) make their final approach to Heathrow towards
the west.
As part of our ongoing work in re-designing the
arrival and departure routes for Expansion, we have
been assessing various concepts which are intended
to be the starting point for the detailed design phase
of the airspace. As an example, one of those
concepts on departures is to provide opportunities to
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'wrap-around' the departure runway as the aircraft
climbs. This would help minimise fuel burn/CO2 and
also provide opportunities to maximise operational
efficiency.
Further information is provided in Heathrow’s
Airspace and Future Operations Consultation
Document and a technical description potential wrap
around routes are in Our approach to redesigning our
airspace network for an expanded Heathrow.
A key issue is how predictable, reliable runway and flight path
alternation could be provided to allow respite to local communities
throughout the day, night and shoulder periods.
✓ We are seeking feedback in this consultation on
respite through runway and airspace alternation,
amongst a number of other areas.
Please see Heathrow’s Airspace and Future
Operations Consultation Document and Runway
Operations – Respite through Alternation.
Concern raised that if the new runway cannot accommodate the largest
planes it would increase usage of the other runways with the likelihood
of more overflight of its communities.
✓ The Airports NPS requires that the proposed new
runway is a minimum length of 3,500m. A new
runway of at least 3,500m in length would enable the
largest commercial aircraft to take-off and land. For
more information see Chapter 7 of this Consultation
One Interim Feedback Report.
New flight paths may alter the way historical assets can be enjoyed.
✓ Further information on the effects of expansion on
the historical environment will be set out as part of
the Airport Expansion Consultation in June.
Our airspace design principles for Expansion do not
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include a generic principle on avoiding historical
assets. This is because the scope of this airspace
change means that it has potential effects over a
large geographic area, within which there will be a
wide range of noise sensitive buildings/areas to
consider.
(Full details of our fixed airspace design principles
for Expansion can be found at:
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Heathrow-airspace-departure-and-
arrival-procedures/)
However, we are still at a relatively early stage of our
airspace design process which started from a ‘blank
sheet’. We have now identified the ‘design
envelopes’, which show the geographical areas
which are potentially overflown. This consultation
asks for feedback on local factors relating to these
areas to which we will have regard in designing the
flight paths. Local factors can include historical
assets. See further Heathrow’s Airspace design
envelopes for expansion and Making Better Use of
Our Existing Runways.
A re-think on flying over parkland and, in particular, designated historic
spaces is urged.
✓
✓ This issue relates to the work that Heathrow has
already undertaken in respect of airspace design
principles for Expansion. Similar comments were
received during the Airspace Principles Consultation
One in January 2018 and, as explained previously in
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this table, those comments were addressed in our
submission to the CAA.
Principle 6(h) of the approved and now fixed airspace
design principles states that Heathrow should limit,
and where possible reduce, local noise effects from
flights by prioritising routing flight paths over parks
and open spaces rather than residential areas (but
avoiding overflight of AONB). It should be noted that
rather than being a 'core' requirement of airspace
design, this is one of the more strategic principles
that Heathrow intends to deliver on. Inevitably some
trade-offs will always have to be made.
Our work on airspace design principles for Expansion
has been approved by the CAA – full details of the
airspace design principles, as approved on 28
September 2018, can be found at:
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Heathrow-airspace-departure-and-
arrival-procedures/
For a summary of Heathrow's airspace design
principles for Expansion, please see Heathrow's
Airspace Design Principles for Expansion.
Concern expressed that flight paths will be focussed on areas that do
not already have significant air quality issues and will therefore be over
areas with existing low background noise levels.
✓ The Government’s Air Navigation Guidance 2017 states “Due to the effects of mixing and dispersion, emissions from aircraft above 1,000 feet are unlikely to have a significant impact on local air quality. “
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Air quality is therefore unlikely to influence the design
of the airspace beyond the immediate vicinity of the
airport.
Further information requested on the assessment principles and the
capping of airport size and flight numbers.
✓ We propose to put legally binding obligations in place to ensure the growth of the airport is only allowed to take place within the boundaries of the environmental criteria set out in the Airports NPS. For more information, please see Heathrow's Airspace and Future Operations Consultation Document. We will set out detailed proposals for how future growth will be managed as part of our Airport Expansion Consultation planned for June 2019. We will be seeking feedback on these proposals and we want local communities to have their say on our plans.
Questioning the implications for aircraft stacking if the airport operates
at full capacity.
✓ The plan to modernise the UK’s airspace involves
using technology to remove the need for stacking in
normal circumstances, even when the airport
reaches full capacity.
Heathrow stacks operate from 7,000ft upwards and
are therefore part of the NATS airspace change to
modernise airspace above 7,000ft. For information
on NATS changes above 7,000ft, please see
https://www.caa.co.uk/Commercial-
industry/Airspace/Airspace-change/Decisions-from-
2018/London-Airspace-Management-Programme-
Circling/stacking should be reduced and flight paths should be tied to
specific noise and air quality limits.
✓
More sophisticated flight programming may result in future
improvements but would depend on better coordination and reliability
of take-off and landings so that “stacking” is less necessary.
✓
Planes should gain as much altitude as possible as quickly as possible
and the current stacking arrangements should be removed.
✓
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Circling/stacking should be reduced and flight paths should be tied to
specific noise and air quality limits.
✓ Phase-2---ATS-Network/.
For more details on how Heathrow expansion is part
of the wider UK airspace modernisation please see
What is airspace modernisation? More sophisticated flight programming may result in future
improvements but would depend on better coordination and reliability
of take-off and landings so that “stacking” is less necessary.
✓
Queried whether the environmental statement for the airspace change
process will be the same as for the DCO application.
✓ These responses question the relationship between
the environmental information to be provided as part
of the development consent order application and the
airspace change process.
The development consent order application will be
made at an earlier stage than a decision is made by
the CAA on our airspace change proposal. For that
reason, the environmental information for the
development consent order will be based on
‘indicative’ flight paths rather than the final flight
paths. This is recognised in the Airports NPS which
states at paragraph 5.52 that "the applicant's
assessment of noise should be undertaken in
accordance with the developing indicative airspace
design”.
The development consent order will then set a noise
envelope that the airspace change proposal impacts
must fall within. Therefore the two submissions will
be linked, and the impacts of the latter limited by the
former.
More details on both processes can be found in How
do we seek approval to expand Heathrow?. More
Concern raised that until an airspace design is agreed it will not be
possible to define, consult on and agree the noise envelope.
✓
If the two are different they will need to be consulted on whether the
determination of flight paths could alter decisions about highway
networks.
✓
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detail on the role of the noise envelope can be found
in Developing our approach to noise management.
There must be no unacceptable safety, economic or airspace
consequences arising from the proposals that would prevent the
relevant regulatory approvals.
✓ We will be following the CAA's airspace design
guidance (CAP1616)21 for developing the airspace
change proposal.
This guidance covers all of the various elements
referred to in this response. Our proposals will be
subject to a full assessment under the airspace
change process.
There should be an analysis of the costs and environmental benefits of
extending the Southern Runway to the west to provide quieter landings
for planes from the east and decrease the number of residents within
the 65-decibel contour.
✓ As explained above, the Airports NPS confirms that
the Government believes that the need for additional
airport capacity in the south-east of England is best
met by a north-west runway at Heathrow.
Clear policy direction from the Government is urgently required to
ensure that the international commitments of the UK via ICAO’s
Balanced Approach to noise, carbon and air quality needs can be met.
✓ Any mitigation measures we put in place will need to
be developed through the application of the ICAO
Balanced Approach. This sets out a framework for
the development of a package of noise mitigation
measures with the goal of addressing an individual
airport’s environmental noise objective in the most
21 https://publicapps.caa.co.uk/docs/33/CAP1616E2interactive.pdf
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cost-effective way. EU Regulation 598/2014 requires
the application of ICAO's Balanced Approach in
relation to noise in the UK and the Airports NPS
requires compliance with that Regulation.
The Balanced Approach comprises four principle
elements:
• Reduction at source (e.g. quieter aircraft)
• Land use planning and management
• Noise abatement operational procedures
• Operating restrictions.
We also consider community engagement to be a
significant element of our approach. As part of our
approach we will also put forward plans for a noise
envelope to provide management, accountability,
and control of noise. Further information on the noise
envelope approach will be provided for consultation
at the Airport Expansion Consultation in June 2019.
The Balanced Approach does not apply to carbon or
air quality.
The masterplan should not be developed until environmental
conditions including the restriction of air pollution and noise as well as
flight paths, are finalised.
✓ The airspace change required for Expansion cannot
take place until the new runway is approved, so it will
happen after the development consent order is
made. However, the development consent order
application will include an assessment of impacts
based on prototype routes and will describe a noise It is unacceptable that the indicative flight paths that would form the
basis of the DCO may bear no relation to the actual future flight paths
✓
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used. envelope to ensure that the impacts of the final
routes are within acceptable limits.
The Airports NPS explains that at the time of the
development consent order process the airspace
design will not be finalised and so indicative airspace
designs should be developed (paragraph 5.52).
By the time we submit the development consent
order application we will have decided in broad terms
how many routes there will be and in which general
direction. Even though this will not tell us exactly
where the routes will be, we will be able to analyse
the scale of any potential benefits and adverse
effects. This will be fed into the development
consent order decision making process.
The development consent order, if approved, will
include the definition of a ‘noise envelope’. This will
set limits on impacts which the future design and
operation of the airspace must stay within and will
therefore give the Secretary of State, when deciding
whether to grant the development consent order, a
guarantee that the ongoing design process will
deliver an airspace design that meets specified
requirements.
More details on the noise envelope can be found in
Developing our approach to noise management.
In order to meaningfully address public concerns, the process should
be accelerated and actual flight path options used.
✓
Flights over central and SE/SW London are a major hazard in this age ✓ Our Environmental Statement will include an
assessment of major accidents and disasters as part
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of non-state terrorism. of the development consent order application. This
will be subject to scrutiny during Examination.
Highlighted the concerns and mistrust of Heathrow by local
communities following flight path changes in 2015.
✓ We have been working with communities in relation
to their concerns regarding airspace, for instance
through the ongoing Heathrow Community Noise
Forum.
In addition, we have established the Heathrow
Community Engagement Board and this will help
enable large scale community engagement
throughout the planning process for Expansion and
longer-term into the operational phase of the
expanded airport.
This will play an important role in building trust
between the airport and its communities and ensure
Heathrow delivers on its commitments today and in
the future.
In terms of consultation, this Airspace and Future
Operations consultation is part of a 3-phase
consultation process regarding airspace for
Expansion (as described earlier in this table). This is
to ensure that our design process is transparent and
so that all stakeholders get the chance to contribute
at key stages of the process.
Existing flight paths affect several areas of their land. ✓ This Airspace and Future Operations Consultation is
not about existing flight paths.
However, all flight paths are subject to review as part
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of the airspace redesign and we are asking for
information on the local factors that should be taken
into account in defining the flightpaths within design
envelopes for future operations.
Residents should benefit from quieter aircraft/airport technology and
systems.
✓ In accordance with the requirements of the Airports
NPS, we are developing a “noise envelope”, which is
a dynamic arrangement of legally binding controls
and limits for the ongoing and future management of
noise. Its aim is to provide certainty to communities
on the airport’s impacts, whilst allowing operators
(e.g. airlines) flexibility on how they can grow their
use at the airport. The noise envelope would be
legally binding and secured through the DCO
process. For more information on the noise envelope
and how we are developing it, please see the
document Developing Our Approach to Noise
Management which is part of the January 2019
Airspace and Future Operations Consultation.
Details of measures to incentivise the use of quieter
aircraft are set out in Heathrow’s Airspace and
Future Operations Consultation Document.
Concern that aircraft operating on the new runway would be flying at
significantly lower altitude than those on the current northern runway
and as there would be significantly more aircraft movements this will
make relief periods almost non-existent. Welcomed the added respite
that would be provided through runway alternation.
✓ This response suggests that aircraft using the new
runway would fly at a lower altitude than those on the
current northern runway. In fact, we will be applying
a minimum climb gradient of 5% and a ‘slightly
steeper’ approach angle of 3.14 degrees. This
means that the lowest aircraft seen in the future will
be higher than seen today for an equivalent phase of
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flight. These technical details are explained in Our
approach to redesigning our airspace network for an
expanded Heathrow.
The response also suggests references relief and
respite periods. We are seeking feedback on this
area, and describe the proposals in detail in Runway
Operations – Respite through Alternation.
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CONSULTATION
Introduction
26.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback on
the Consultation, the printed material, maps, plans, website and feedback form.
A total of 2,268 consultees made comments relating to this topic.
26.1.2 Heathrow provided the following consultation material:
1. Airport Expansion Consultation Document;
2. Development Consent Order Process Information Paper;
3. Environmental Impact Assessment Information Paper;
4. Property Policies Information Paper;
5. Our Emerging Plans;
6. Scheme Development Report;
7. Our Approach to Developing a Surface Access Strategy;
8. Our Design Approach to the Natural Environment;
9. Our Approach to Noise;
10. Our Approach to Air Quality;
11. Our Approach to Carbon and Climate Change;
12. Our Approach to Historic Environment;
13. Community Information Booklet – North;
14. Community Information Booklet – East;
15. Community Information Booklet – South West;
16. Community Information Booklet – West;
17. Interim Property Hardship Scheme – Panel Guidance and Policy Terms;
18. Fees and Costs Policy;
19. Commercial Property Policy;
20. Agricultural Land and Property Policy; and
21. Residential Property Policy.
26.1.3 Heathrow asked the following questions regarding the Consultation:
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1. Please tell us your views on this consultation (for example, the information we
have provided, any printed material you have received, any maps or plans, the
website and feedback form etc.).
26.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Heathrow
Airport Expansion Project (the Project), we have provided a summary of the way in
which we are seeking to consider the issues as part of preparing the detailed
proposals which will be presented as part of the Airport Expansion Consultation
planned for June 2019.
Prescribed Consultees
Local Authorities
26.2.1 Detailed comments were received from local authorities in relation to
the Consultation.
26.2.2 The London Borough of Brent expressed disappointment that no consultation
events were hosted in the Borough and suggested that this should be addressed
in future consultations.
26.2.3 Ealing Council said the consultation materials lacked information on the potential
regeneration benefits of the Project and the ways benefits would be maximised.
They also commented that the consultation materials could have included more
information about housing, including affordable housing and the provision of land
for housing, and surface access, such as cycle facilities and bus access.
26.2.4 Elmbridge Borough Council commented on the complexity of the Consultation,
noting that having two consultations in parallel was confusing and that materials
should be simplified to engage more people. They stated that the distinction
between the Consultation and the Airspace Principles Consultation (January 2018)
was not clearly explained, leading to further confusion. They also highlighted that
the consultation materials lacked information on the cost of the Project and that
Heathrow should explain how they consider residents' views against those of
other stakeholders.
26.2.5 The London Borough of Hammersmith and Fulham commented that the
presentation of the economic benefits of the Project was misleading, did not
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include a breakdown of how it was generated and did not align with the figure in
the Airports National Policy Statement (ANPS).
26.2.6 They also felt the consultation material included misleading content and felt that
Heathrow did not quantify the airport’s current operations against the potential
impacts of a proposed new third runway, meaning that residents could not make
an informed assessment of the impacts and costs of the Project.
26.2.7 The London Borough of Hammersmith and Fulham also considered that important
information was omitted from the Consultation, such as the potential reduction of
respite currently provided to communities under existing flightpaths, that there
appeared to be a conflict between the two consultations and that information on
noise issues was limited. This meant that there was no clear way for residents to
identify where they lived in relation to noise impacts around the airport.
26.2.8 They also commented that it was not clear that the Consultation formed part of the
DCO and that the timetable for finalising flight paths needed be aligned with the
DCO timeline so that airspace decisions could be fed into the DCO process.
26.2.9 The London Borough of Harrow stated that the consultation materials did not
contain any baseline data which the Council could use to assess the impacts of
proposed changes, for example on noise, traffic and air quality. They considered
that because information was vague or missing, the impacts on the borough could
not be fully understood and firm comments on the proposals put forward by
Heathrow could not be made.
26.2.10 Hertfordshire County Council suggested that consideration should be given to
engaging with Hertfordshire communities more proactively and hosting a
consultation event(s) within the south west of the County.
26.2.11 The London Borough of Hounslow commented positively on the consultation
process, stating that Heathrow’s staff at the consultation events were helpful and
well informed and that materials available at the events were high-quality and well-
presented. They did however express concern over missed deliveries of
Community Information Leaflets in their Borough and the separation between the
timelines for the Development Consent Order (DCO) and airspace
change processes.
26.2.12 Slough Borough Council stated that the Consultation did not clearly present the
various options as coherent strategies. They stated that the public were being
asked to comment on options such as land usage and road layouts without fully
understanding the impacts once they are put together.
26.2.13 South Buckinghamshire District Council commented that they were dissatisfied
that not all the consultation documents had been shared with Councillors prior to
the start of the Consultation.
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26.2.14 The South East England Councils commented that Heathrow should set out how it
will work with the public sector to ensure effective planning and delivery for
community infrastructure needs such as schools, healthcare facilities, utilities and
local services that will be required by new expanded Heathrow Airport and supply
chain employees and their families.
26.2.15 Spelthorne Borough Council shared a similar view, commenting that the
consultation documents were short on detail with no baseline data. They said that
Heathrow should provide comprehensive baseline data on issues including noise,
traffic and air quality. They also highlighted that many of the consultation
documents had imprecise wording and unrealistic options which made it difficult
for residents to understand and respond. They expressed concern that the
Consultation did not include information on important issues such as flight paths,
runway modes, baggage, park and ride, public transport interchanges, landscape
mitigation, temporary construction and displaced uses which they considered were
crucial to assessing the wider impacts on the borough. They also expressed
concern that limited consideration appeared to have been given to accommodating
the construction workforce.
26.2.16 Surrey County Council considered that the consultation materials did not provide a
coherent overview of the cumulative effects on their community. They commented
that the Project masterplan22 needed to extend beyond the red line boundary and
that the Consultation lacked a detailed surface access strategy.
26.2.17 They also commented on the presentation of noise impacts, stating that separating
information about noise between the Airport Expansion and Airspace Principles
consultation documents meant not all residents were aware of potential impacts or
the need to respond to both consultations.
Statutory Consultees
26.2.18 Few statutory consultees made comments on the consultation process, instead
providing detailed comments on aspects of the Project or Heathrow’s approach to
managing its effects.
26.2.19 Natural England commented that the content of the Consultation was high-level
due to the scheme being in the early stages of development. They highlighted that
a lack of detailed information meant they were unable to respond to the
Consultation with certainty.
22 A long-term plan that provides a conceptual layout to guide future growth and development
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26.2.20 Highways England commented that its response to the Consultation was
predicated on the information available at this early stage in the scheme
development process. They indicated that further information and extensive
engagement with Heathrow will be required to ensure the design delivers a safe
and serviceable strategic road network, to agree appropriate mitigation and the
use of robust modelling to ensure future proofing of the design.
Other prescribed bodies
26.2.21 Ivers Parish Council stated that the Consultation lacked a joined-up plan or map
showing the cumulative effect of the proposals on the area. They also stated that
the scale of the maps was too small to be able to clearly identify sites.
26.2.22 Bray Parish Council echoed the view that information was missing from the
Consultation and said that it prevented them and their residents from making a
fully informed response.
26.2.23 Colnbrook with Poyle Parish Council indicated that the Consultation was high-
quality and effective and presented opportunities to engage in face-to-face
discussions with Heathrow representatives throughout.
26.2.24 Network Rail did not make detailed comments about the Consultation but
suggested a bilateral workshop be convened to discuss their comments in relation
to impacts on the rail network and rail accessibility.
Local Communities
Members of the public
26.3.1 Roughly a quarter of respondents expressed positive views about the
Consultation but the majority of those that responded expressed opposition
or criticised the Consultation.
26.3.2 The main positive comments focussed on the level of detail and the accessibility of
documents and materials. Members of the public who were generally supportive of
the Project felt that the documents set out the case for expansion clearly and
informatively. Other positive comments said that the events were well-presented,
that event staff were helpful, that the Consultation was far-reaching and well-
publicised and that the website was accessible and contained useful information.
26.3.3 Positive feedback was also received about the inclusion of the sound
demonstration at the Heathrow Academy and the ability to express concerns to
team members face-to-face at events.
26.3.4 Members of the public that made negative comments expressed concern and
uncertainty about the purpose of the Consultation. They said that the Consultation
was biased, a ‘box-ticking exercise’ or PR exercise, that Heathrow would not listen
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to and act on consultation feedback and that the Consultation presented a new
runway as inevitable and no longer open to debate. It was also stated that the
Consultation carried no weight because it was non-statutory and undertaken
ahead of the designation of the ANPS.
26.3.5 Members of the public criticised the consultation events for the following reasons:
1. concerns regarding accessibility of information and events and inclusiveness;
2. the Hendon consultation event was organised on a Jewish holy day, preventing
attendance by the Jewish community;
3. the Freepost return envelopes provided at some events were too small;
4. staff at the Stanwell Moor event did not provide feedback forms;
5. staff were insensitive to concerns and not appropriately informed on specific
issues; and
6. requests for documentation at the Hayes event were not fulfilled.
26.3.6 Respondents also commented that the Consultation did not attract a young
audience, that an online consultation exhibition would have achieved a wider
reach and that better use should be made of social media platforms and the
website.
26.3.7 Suggestions were also received that events should have been held in Chelsea
and Sipson.
26.3.8 In addition to these criticisms, consultees made the following comments about the
consultation materials and written information:
1. data was vague, inaccurate or missing;
2. maps needed to be of a higher resolution;
3. noise maps were missing; and
4. documents were too detailed, long and difficult to understand.
26.3.9 Members of the public also highlighted a range of information considered to be
missing or not covered in sufficient detail in the consultation materials. Information
was stated to have been omitted in relation to:
1. construction;
2. night time ban on aircraft movements;
3. changes to flight paths;
4. the number of aircraft;
5. transport and accessibility;
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6. impacts of the M25 realignment works and local road diversion options;
7. road user charging;
8. noise;
9. pollution;
10. health effects and related mitigation;
11. demand for housing in the local area;
12. the environment;
13. loss of greenspace and agricultural land;
14. cost;
15. compensation and mitigation proposals;
16. project timescales;
17. alternatives to the Project;
18. historic assets and the historic environment impact;
19. safety and security issues;
20. impacts on local people, communities and businesses;
21. airline landing charges;
22. encouraging modal shift by using Crossrail;
23. relocation of the immigration centres; and
24. airport supporting facilities.
26.3.10 Members of the public expressed dissatisfaction with the Consultation Feedback
Form (Form) on the basis that it was long and tedious, cumbersome and difficult to
navigate. Others stated that the Form included questions which were leading and
too complex.
26.3.11 In relation to the online version of the Form, the following suggestions were made:
1. including ‘logout’ and ‘save’ options;
2. include a progress bar;
3. make related information accessible on each question page;
4. list all questions on one contents page up-front;
5. include relevant maps and figures
6. detail the number of answers required at the outset;
7. including multiple choice questions; and
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8. offer the opportunity to complete the form while remaining anonymous.
26.3.12 In relation to the paper version of the Form, it was suggested that more blank
space should be provided for responses.
Businesses
26.3.13 The Copas Partnership and The Lanz Group commented on the accessibility of
consultation materials, indicating that they were well written and visually
appealing. The Lanz Group also commented that consultation materials could
have been improved by more clearly demonstrating how each element of the
Consultation linked together.
26.3.14 Businesses made general positive comments on the Consultation. Hatton Estates
commented that the Consultation seemed comprehensive, Suez UK stated the
Consultation was well-conducted and wide reaching and Surrey Chambers of
Commerce commented that it was excellent.
26.3.15 The Arora Group expressed concern at the scope of the Consultation, indicating
that to enable a full and proper consultation on component parts and the delivery
of the optimum overall scheme, a number of options should be consulted upon for
each component.
26.3.16 They criticised the lack of reference in the consultation materials to their own
proposals to expand Heathrow Airport, stating that respondents had not been
given the full range of options to consider. They also criticised the lack of
information on construction costs, which they considered meant stakeholders
could not weigh up the costs and benefits.
26.3.17 Enterprise M3 Local Enterprise Partnership considered that the consultation
material lacked an overall coherent strategy and that there was too much focus on
individual specific elements rather than strategic options.
26.3.18 Heathrow Hub Limited shared a similar view indicating that the consultation
materials did not provide sufficient comparative analysis of issues such as costs,
benefits, risks and environmental impacts or explain the relationship between
options to help determine which were compatible. They also stated that the
consultation materials did not consider the timescales, costs and risks involved in
relocating residential, commercial and public property.
26.3.19 Petchey Industrial Properties Limited commented that the Consultation was
not broad enough as it only focused on one proposal for a third runway and
WeMoved Limited commented that no information had been provided about
local consultations.
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Community groups
26.3.20 Certain community groups who provided feedback to the Consultation expressed
opposition to the Project but did not necessarily include specific feedback on
the Consultation.
26.3.21 Harrow U3A Sustainability Group said the consultation events were informative
and that the Consultation explained the proposals clearly and thoroughly.
26.3.22 Aircraft Noise Three Villages commented that it should have been made clear that
the Consultation was non-statutory and was being undertaken at a time when
feedback on the ANPS consultation was still being analysed. They considered that
the Consultation was a PR exercise and carried no weight.
26.3.23 Both Colnbrook Community Association and Slough and District Against Runway 3
commented that the Consultation was designed to elicit predetermined responses
which favoured the Project. Slough and District Against Runway 3 added that they
believed consultation events had only been held in areas already overflown, rather
than those which may be overflown in the future.
26.3.24 Dover House Estate Residents’ Association commented that the online version of
the Form should include a progress bar to show how much had been completed
and that there should have been a ‘click-through’ to the documents relevant to
each question.
26.3.25 The Camberley Society made similar comments criticising the online version of the
Form saying it took too long to complete. They suggested that it should include a
save button which allows users to return to it later. The Chertsey Society echoed
these views and commented that the online Form would have benefited from
alerting consultees that it could be partly completed and returned to at a later
stage, before submitting.
26.3.26 The Teddington Action Group considered the main consultation document to be
misleading as it implied only one consultation was taking place. They also
considered that the Consultation was a PR exercise and contained insufficient
information for people to make decisions.
26.3.27 St Albans Quieter Skies said it was disappointed with the lack of information about
the impact on areas to the North of London.
26.3.28 The Englefield Green Action Group were positive about the approach taken but did
not consider that the Consultation presented a balanced view of the environmental
and community impacts.
26.3.29 The Colnbrook Community Partnership expressed concerns about a lack of area-
specific information and thought more information should have been provided
around the impacts on Colnbrook and Poyle. They suggested that this specific
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information could have included a composite map showing all possible local
impacts, such as road realignments and river diversions.
26.3.30 The Eastcote Residents’ Association expressed concern that the Consultation did
not make commitments to actions which would address community concerns, the
loss of land and properties, pollution or transport issues.
26.3.31 The Eastcote Conservation Panel commented that the consultation materials
contained unsubstantiated statements.
26.3.32 The Richmond Heathrow Campaign commented that the use of two columns in
documents made them difficult to read at appropriate magnification on a computer
screen.
26.3.33 HFT highlighted that further details on how Heathrow Airport will become a
champion for assisted travel should be provided in the next stage of consultation.
26.3.34 Local Conversation in Stanwell commented that the Consultation information was
too high-level which meant that it was not possible to comment in detail on issues
critical to Stanwell and Stanwell Moor residents.
26.3.35 The Local Authorities’ Aircraft Noise Council commented that the presentation of
the economic benefits of the Project was misleading, did not include a breakdown
of how it was generated and did not align with the figure in the ANPS.
26.3.36 They stated that the consultation material included misleading content, such as
presenting Heathrow as the only way to support economic growth and that it did
not quantify the airport’s current operations against the potential impacts of a third
runway. This meant that residents could not make an informed assessment of the
impacts and costs of the Project.
26.3.37 They also considered that important information was omitted from the
Consultation, such as the potential reduction of respite currently provided to
communities under existing flightpaths and commented that information on noise
issues was limited which meant here was no clear way for residents to identify
where they lived in relation to noise impacts around the airport.
Wider/Other Consultees
26.4.1 The Herts and Middlesex Wildlife Trust commented that information on the net
ecological impacts of the Project was lacking. They considered that this made
it impossible to conclude whether the development could provide a net gain
in biodiversity.
26.4.2 The London Wildlife Trust made similar comments, indicating that greater levels of
information were needed and that there should have been the option to provide
feedback on drainage/pollution control and light pollution. They also commented
that an effective means to engage stakeholders in the evaluation of the
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biodiversity evidence, and the design of the green infrastructure plan should be put
in place.
26.4.3 The Colne Valley Regional Park welcomed the Consultation taking place when it
was a non-statutory DCO requirement. They did, however, comment that there
should have been more information on drainage and pollution control and that the
consultation materials should have provided information about the impacts on
groundwater levels through increased water consumption as a result of the
proposed third runway.
26.4.4 Church of England Diocese of London, Oxford and Southwark commented that the
maps and diagrams showing an expanded airport were clear and information
papers were helpful.
26.4.5 The London Parks and Gardens Trust said it was frustrating to have to cross-refer
to documents that did not always follow the same sequence. They considered it
would have been beneficial to present consultation booklets based on single
subjects e.g. conservation, noise, pollution, airport logistics. They also considered
the maps were inadequate due to changing scales and that the conservation areas
and historic buildings which would be lost should have been made clear.
26.4.6 Aviation Safety Investigations commented that the masterplan was inadequate
and requested the opportunity to discuss the necessary changes with the design
team.
26.4.7 The Major of London recognised the significant amount of consultation that had
taken place in relation to Heathrow. He considered that the Consultation was a
missed opportunity to address concerns about the proposals for an expanded
Heathrow and to set out clear commitments to address these concerns.
26.4.8 Justine Greening MP (Putney) commented that the Consultation gave the
impression that expanding Heathrow Airport was a “given” even before the
Parliamentary vote had been held. She also expressed concerns on behalf of her
constituents about the lack of detail in relation to the various elements of the
proposals and how Heathrow will manage an airport which is 50% than the
existing Airport or which will have a proposed 50% increase in freight.
26.4.9 Justine Greening MP also considered there was insufficient information to enable
MPs to arrive at an educated position regarding the plans. She referred to a lack
of information concerning flight paths, the management of an enlarged airport, the
M25 and the lack of substantial detail on the relocation of the Lakeside Waste
Management facility. The Campaign to Protect Rural England – Surrey and
Guildford indicated that the Consultation was premature as it included too much
unresolved information to allow respondents to make an informed response. They
expressed concern that that the whole exercise was a PR event.
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26.4.10 The Guild of Air Traffic Control Officers made similar comments, indicating that the
Consultation was unnecessary as information necessary to inform consultees to
comment on some of the options is not available until the second consultation.
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Issues Raised and Heathrow’s Responses
Table 26.1A below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Consultation. The table presents a summary of Heathrow’s responses to the issues on the basis that
they relate to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation
(January 2019), and how in preparing those proposals we have had regard to the relevant Airport Expansion Consultation One
feedback.
Table 26.1A
Issue Consultee23 Heathrow Response
PC MC WC
The consultation was overly complex and materials
should have been simplified to engage more people.
✓ The Airport Expansion Consultation One documents were designed
to ensure that highly technical concepts and information was
presented in a way that was accessible to a range of audiences. This
avoided persuasive language and jargon as far as possible and the
Airport Expansion Consultation One Document and accompanying
information papers provided more simplified information on the
proposals.
Heathrow welcomes feedback on its consultation approach and has
had regard to this feedback in planning our subsequent consultations.
23 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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For example, the Airspace and Future Operations Consultation in
January 2019 and the planned Airport Expansion Consultation in
June 2019 provide a wider range of interactive online content and will
ensure that wording is accessible, un-biased and in plain English and
that information is presented using a tiered approach to ensure that
all audiences are able to access the information they require.
The distinction between the expansion and airspace
consultations was not clearly explained and running
two consultations in parallel was confusing.
✓ In 2018, Heathrow undertook two separate but parallel consultations for
airport expansion and airspace change. It was considered important
that we highlighted the two separate processes for airspace change
and the physical expansion of the airport given that they will be
assessed through different consenting procedures. To help consultees,
different colours and branding were used to indicate the separation
between the consultations and separate feedback forms and feedback
channels were provided. The Airport Expansion Consultation
Document provided information on the different consultation and
consenting procedures for airspace change and the airport expansion
and signposted consultees to the Airspace Principles Consultation
Document for further information.
Heathrow have considered the feedback received and have made
changes to subsequent consultations. For example, the Airspace and
Future Operations Consultation in January 2019 presents proposals in
relation to future operations (how we will use the runways following
expansion), airspace change for expansion and airspace change
following the introduction of Independent Parallel Approaches (IPA) as
'one consultation' under a single consultation brand. This includes the
use of one feedback form (rather than two). An interactive postcode
tool is also available on the project website and at exhibitions to help
consultees understand which aspects of the proposals would affect
them.
Separating information about noise between the
expansion and airspace consultation documents
meant not all residents were aware of potential
impacts or the need to respond to both
consultations.
✓
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Heathrow’s initial assessment of the environmental noise impacts
arising from the Heathrow Expansion Project (the Project) will be
contained within the Preliminary Environmental Information Report (the
PEIR). The PEIR will form part of the suite of documentation issued by
Heathrow during the Airport Expansion Consultation planned for June
2019.
Important information was omitted from the
consultation, such as the potential reduction of
respite currently provided to communities under
existing flightpaths, there appeared to be a conflict
between the two consultations and information on
noise issues was limited. This meant that there was
no clear way for residents to identify where they
lived in relation to noise impacts around the airport.
✓ Alternation
The Airspace and Future Operations Consultation commencing in
January 2019 provides information on our emerging proposals for the
provision of respite through alternation. For more information, please
see the Airspace and Future Operations Consultation Document and
the Runway Operations - Respite Through Alternation document for
more information.
It is recognised that for some communities which benefit from the current pattern of runway alternation that the level of respite that they currently receive each day will be reduced. This is acknowledged in the ANPS at paragraph 5.61. Why this is the case is explained in the consultation document Runway
Operations - Respite Through Alternation, which forms part of the
Airspace and Future Operations Consultation (January 2019).
Information on noise
The Airport Expansion Consultation One (2018) was very early in the
process for the development of a new airspace design for an expanded
Heathrow and as such there was limited geographically specific
information we could provide about likely noise impacts. In the January
2019 Airspace and Future Operations Consultation we are consulting
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on the broad geographical areas where future flight paths could be
positioned. These are known as design envelopes. The design
envelopes are accompanied by information about the height of aircraft
passing over a certain area within each envelope. On our consultation
website, it is possible for consultees to input their postcode to find
information relating directly to their area. We are seeking feedback from
the public on local factors which we should take into account when
designing future flight paths.
Heathrow’s initial assessment of the environmental noise impacts
arising from the Project will be contained within the PEIR. The PEIR
will form part of the suite of documentation issued by Heathrow during
the Airport Expansion Consultation planned for June 2019.
The consultation materials lacked information on the
cost of expansion.
✓ The Airport Expansion Consultation One information explained that the
proposed options for the Project had been evaluated against a range of
environmental, community, cost, operational, delivery and planning
criteria. The Scheme Development Report presented the findings of
this evaluation in Figure 22.
Given that a preferred masterplan had not been prepared at the time of
Airport Expansion Consultation One, it was not possible, therefore, to
provide a detailed breakdown of costs relating to the Project (although
the Airport Expansion Consultation Document and Scheme
Development Report did provide indications of more and less costly
options). The preferred masterplan for the Project, which will be
presented at the Airport Expansion Consultation in June 2019 along
with the Updated Scheme Development Report which will provide
further information relating to costs. This will include the findings of the
evaluation process that includes the ‘business case’ as one of the
seven criteria applied to the evaluation of masterplan options. This
Disappointed at the lack of information on
construction costs, which they considered meant
stakeholders could not weigh up the costs and
benefits.
✓
The consultation materials did not provide sufficient
comparative analysis of issues such as costs,
benefits, risks and environmental impacts or explain
the relationship between options to help determine
which were compatible.
✓
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includes scheme costs and operating costs.
The consultation documents lacked detail. ✓ ✓ The Airport Expansion Consultation One presented the process
followed and the progress made by Heathrow as of January 2018 in
developing options for the key components of an expanded airport and
its supporting facilities. This included information on proposed physical
changes to the airport, as well as in respect of Heathrow’s approach to
surface access and the natural environment. The primary aim of the
Consultation was to seek preliminary feedback to inform the ongoing
development of the masterplan.
The Airspace and Future Operations Consultation Document provides
more detail on proposed changes to airspace and Heathrow's emerging
thinking in relation to directional preference, respite through alternation
and a ban on scheduled night flights.
Similarly, in June 2019, as part of the Airport Expansion Consultation,
Heathrow will publish the preferred masterplan for the Project, which
will provide more detail about all of Heathrow's proposals.
Heathrow will also publish a draft Surface Access Strategy as part of
the Airport Expansion Consultation, which presents the preferred option
for park and ride and public transport proposals including for non-
motorised users.
The Airport Expansion Consultation will also include detail in the PEIR
on the construction process and mitigation proposals, including
potential impacts on housing.
The consultation provided insufficient information
for people to make decisions.
✓
The content of the consultation was high-level due to
the scheme being in the early stages of
development.
✓
The consultation information was too high-level
which meant that it was not possible to comment in
detail on issues critical to Stanwell and Stanwell
Moor residents.
✓
The consultation material included misleading
content and Heathrow did not quantify the airport’s
current operations against the potential impacts of a
new third runway, meaning that residents could not
make an informed assessment of the impacts and
costs of expansion.
✓
As information was vague or missing, the impacts
on an area could not be fully understood and firm
comments on the proposals could not be made.
✓
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Concern raised that the consultation did not include
information on important issues such as flight paths,
runway modes, baggage, park and ride, public
transport interchanges, landscape mitigation,
temporary construction sites and displaced uses
that are crucial to assessing the wider impacts on
the borough.
✓
The following should have been covered in the
Consultation; construction, the night time ban,
changes to flight paths, the number of aircrafts,
transport and accessibility, impacts of the M25 and
local road diversion options, road user charging,
noise, pollution, health effects and related
mitigation, demand for housing in the local area,
environment impacts, loss of greenspace, the
environment, cost, compensation and mitigation
proposals, project timescales, alternatives to
expansion, safety and security issues, impacts on
local people, communities and businesses, airline
landing charges, encouraging model shift by using
Crossrail and airport supporting facilities.
✓
Important information was omitted from the
consultation, such as the potential reduction of
respite currently provided to communities under
existing flightpaths. Information on noise issues was
limited which meant there was no clear way for
residents to identify where they lived in relation to
noise impacts around the airport.
✓
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The consultation materials could have included more
about housing and surface access, such as cycle
facilities and bus access.
✓
The consultation materials lacked information on the
potential regeneration benefits of expansion and the
ways benefits would be maximised.
✓ As part of Airport Expansion Consultation One, information on benefits
of the Project was provided in the Airport Expansion Consultation
Document. For example, this included Heathrow’s commitment to
“create 5,000 additional apprenticeships at Heathrow, bringing the total
to 10,000 by 2030.” Details of the proposed approach to the delivery of
high quality mitigation around the airport for biodiversity, the landscape
and the water environment for the benefit of both local communities
and wildlife were also set out in Our Design Approach to Natural
Environment.
The Development Consent Order (DCO) application will be determined
in accordance with policies contained in the ANPS weighing the
benefits against the impacts of the scheme. It is therefore important
that we present both the likely adverse and beneficial effects of the
Project. As part of the Airport Expansion Consultation planned for June
2019, the PEIR will present the preliminary assessment of the preferred
proposals which will consider both positive and adverse effects within
the context of relevant policy and guidance, and as informed by the
Scoping Opinion received in June 2018.
Heathrow should explain how the views of residents
are considered against those of other stakeholders.
✓ Heathrow consider all consultation feedback equally and take it into
account in the design and evaluation process for the Project.
This Interim Consultation Feedback Report (Interim CFR) outlines the
progress which Heathrow has made in responding to the wider
feedback received from Airport Expansion Consultation One. Where
the issues raised are directly relevant to the materials prepared for the
Airspace and Future Operations Consultation (January 2019),
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Heathrow has set out how it has had regard to the feedback from the
Airport Expansion Consultation One.
At the Airport Expansion Consultation in June 2019, Heathrow will
publish a Consultation Feedback Report on the response to the first
rounds of consultation, which will build on this Interim CFR, and will
include Heathrow’s responses to the combined feedback relating to
Airport Expansion from the two previous phases of consultation (i.e.
January 2018 and January 2019) and how that feedback has informed
the preferred proposals presented for consultation in June 2019.
The consultation material did not contain any
baseline data so that an assessment of the impacts
of proposed changes can be made, for example on
noise, traffic and air quality. Comprehensive
baseline date should be provided.
✓ Heathrow is collating baseline data for a range of topics as part of the
Environmental Impact Assessment (EIA) that is being undertaken in
respect of the Project. Preliminary findings of this assessment,
including the baseline data used, will be presented in the PEIR at the
Airport Expansion Consultation in June 2019. Airport Expansion
Consultation One was undertaken at an early stage in the design
process and provided an opportunity to seek early engagement on the
Project. It therefore only provided high level information on
environmental considerations.
Many of the consultation documents had imprecise
wording and unrealistic options which made it
difficult for residents to understand and respond.
✓ As explained in Chapter 3 of this Report, Heathrow provided a range of
information and held a number of public consultation events to explain
our proposals as part of the Airport Expansion Consultation One. Our
aim was to provide accessible, effective, meaningful and engaging
consultation materials.
We have reflected on the responses received in respect of the
effectiveness of Airport Expansion Consultation One in order to
improve subsequent public consultation processes. For example, the
Airspace and Future Operations Consultation in January 2019 and the
planned Airport Expansion Consultation in June 2019 provide a wider
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range of interactive online content and will ensure that wording is
accessible, un-biased and in plain English and that information is
presented using a tiered approach to ensure that all audiences are able
to access the information they require.
Concern raised that limited consideration appeared
to have been given to accommodating the
construction workforce.
✓ The Airport Expansion Consultation One provided information early in
the design process on options for the components of the masterplan. At
the Airport Expansion Consultation in June 2019 we will present the
preferred masterplan and provide information on environmental impacts
of the Project in a PEIR. This will include information on the
construction process and workforce.
For the proportion of the construction workforce that would require
accommodation during construction we are exploring approaches
including the reuse of existing assets or the construction of new
temporary facilities in dedicated areas of the site. The approach to
construction workers’ accommodation considers the effects of the
construction workforce on local housing markets, services and
infrastructure. This information will be presented in the PEIR as part of
the Airport Expansion Consultation proposed for June 2019.
Consultation materials did not provide a coherent
overview of the cumulative effects on the
community.
✓ Airport Expansion Consultation One was undertaken at an early stage
in the project development process to obtain feedback on the options
identified for the various components of the Heathrow masterplan. As
such it was not possible to provide details of the cumulative effects of
the proposals on the local community or a ‘joined up’ masterplan. An
assessment of cumulative impacts will be presented as part of the
PEIR in the Airport Expansion Consultation in June 2019.
Heathrow has reflected on the responses received in respect of the
effectiveness of Airport Expansion Consultation One in order to
The consultation lacked a joined-up plan or map
showing the cumulative effect of the proposals on
the area. The scale of the maps was too small to be
able to clearly identify sites.
✓
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improve subsequent public consultation processes.
At the Airspace and Future Operations Consultation in January 2019
and at the Airport Expansion Consultation planned for June 2019 an
interactive postcode map tool will also be used on the Project website
and at exhibitions to help consultees understand which aspects of the
proposals would affect them.
Concerns raised over missed deliveries of
Community Information Leaflets.
✓ At the start of Airport Expansion Consultation One, all properties and
businesses within the Potentially Affected Zone (defined as the area
within which aircraft fly at 4,000ft or less) were sent a consultation
information leaflet (CIL). Over 2.2 million copies of the CIL were sent
via Royal Mail. In areas where Heathrow received notification that
copies of the CIL had not been received targeted leafletting was
undertaken during the consultation. Heathrow apologise if the delivery
of the leaflets was not successful in some cases.
The presentation of the economic benefits of the
Heathrow Expansion was misleading, did not include
a breakdown of how it was generated and did not
align with the figure in the draft ANPS.
✓ ✓ Heathrow is continuing to assess the potential economic benefits of the
Project, which will become more detailed as the masterplan is
developed. The benefits reported at Airport Expansion Consultation
One reflected our consideration of benefits of the Project at that time.
Further information will be provided at the Airport Expansion
Consultation in June 2019.
It was not clear that the consultation formed part of
the DCO process and that the timetable for finalising
flight paths needs to be aligned with the DCO
timeline so that airspace decisions could be fed into
the DCO process.
✓ Airport Expansion Consultation One was not the statutory consultation
required by the Planning Act 2008 for a DCO application, but was an
additional consultation ahead of that. The Airport Expansion
Consultation Document for Airport Expansion Consultation One set out
clearly the role of the consultation in the DCO process (page 9) and
further information was set out in a further consultation document called
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Development Consent Order Process Information Paper That Paper
also explained that the air space change process would determine the
final flight paths and that the assessment for DCO purposes would be
made on the basis of indicative flight paths.
Heathrow has had regard to the feedback received in respect of Airport
Expansion Consultation One in the design and evaluation process for
the Project.
The process going forward, including the interaction between the DCO
and airspace change process is further explained in this consultation in
our document: How do we seek approval to expand Heathrow?
Indicative timelines for the 2 processes are set out in the Airspace and
Future Operations Consultation Document.
All Consultations will inform the ongoing development of the preferred
masterplan (for the purposes of the DCO application and the preferred
scheme for airspace change).
The consultation did not clearly present the various
options as coherent strategies.
✓ The Airport Expansion Consultation One presented the process
followed and the progress made to that point (January 2018) in
developing options for the key components of an expanded airport and
its supporting facilities. The work was at an early stage of development
and the aim of the consultation was to seek feedback to inform the
development of the masterplan.
The preferred masterplan will be presented at the Airport Expansion
Consultation in June 2019, along with the PEIR. The PEIR will provide
consultees with a comprehensible report on the information compiled
by Heathrow as at that point in time about the predicted environmental
impacts of the preferred masterplan and the measures proposed to
mitigate such impacts.
The public were being asked to comment on options
such as land usage and road layouts without fully
understanding the impacts once they are put
together.
✓
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Not all the consultation documents had been shared
with Councillors prior to the start of the consultation.
✓ Prior to the launch of Airport Expansion Consultation One consultation
documents were not shared with the local planning authorities.
Heathrow did however carry out a number of pre-consultation briefings
for Local Authorities in the run up to the consultation and following
launch to brief them on the content of the consultation and the factors
on which feedback was being sought.
Heathrow should set out how it will work with the
public sector to ensure effective planning and
delivery for community infrastructure needs such as
schools, healthcare facilities, utilities and local
services that will be required by the new airport and
supply chain employees and their families.
✓ Heathrow are undertaking an assessment of impacts on communities
as part of the EIA process. This includes an assessment of potential
temporary and permanent effects on the viability, sustainability and
accessibility of all physical community facilities and community-facing
businesses and public services. We are also working closely with
HSPG and relevant service providers to assess the wider growth and
infrastructure development which is likely to be generated by the
Project. Early findings including mitigation proposals will be presented
in the PEIR at the Airport Expansion Consultation in June 2019.
No consultation events were hosted in the Borough
of Brent, this should be addressed in future
consultations.
✓ When considering the geographical area within which public
consultation exhibitions should take place, Heathrow has had regard to
key principles, including the areas likely to be affected by the Project,
the need to provide a broad and even distribution across these areas
and to provide exhibitions in accessible locations.
In relation to noise effects and locations further away from the airport,
at this stage, we do not know where the flight paths will be positioned
and as a result it is not possible to undertake a Lowest Observable
Adverse Effect Level (LOAEL) analysis. As a result, we have identified
the land within which aircraft arriving and departing the airport will be
travelling at 4,000ft or less as this represents the maximum extents of
the LOAEL. Southern parts of Hertfordshire are within the outer extent
of this Zone.
Consideration should be given to engaging with
Hertfordshire communities more proactively and
hosting a consultation event(s) within the south west
of the County.
✓
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Heathrow will formally consult the London Borough of Brent and
Hertfordshire County Council on our Statement of Community
Consultation for the Airport Expansion Consultation in June 2019,
which includes a list of proposed exhibition venues. We will take all
feedback into account ahead of confirming our final locations for
exhibitions for the June 2019 consultation.
Heathrow will publicise all stages of consultation within the London
Borough of Brent and Hertfordshire, including locations of exhibitions.
Heathrow does not currently intend for consultation exhibitions relating
to the Airspace and Future Operations Consultation in January 2019 to
take place within the London Borough of Brent or Hertfordshire.
However, we are proposing to hold an event within the London
Borough of Harrow (at Harrow Leisure centre) which adjoins the
London Borough of Brent and the Hertsmere and Three Rivers District
of Hertfordshire.
Locations for exhibitions are based on areas most accessible to people
located within the Zone. We have reviewed the venues of exhibitions
for Airport Expansion Consultation One and replaced those that were
poorly attended with venues in areas of higher footfall.
Further information and extensive engagement with
Heathrow will be required to ensure the design of the
Heathrow Expansion Project delivers a safe and
serviceable strategic road network, to agree
appropriate mitigation and the use of robust
modelling to ensure future proofing of the design.
✓ Heathrow are engaging with stakeholders as part of the preparation of
the draft Surface Access Strategy. The Surface Access Strategy and
technical information underpinning the modelling process used by
Heathrow will be presented at the Airport Expansion Consultation in
June 2019 in relation to the preferred masterplan.
A bilateral workshop should be convened to discuss
impacts on the rail network and rail accessibility.
✓ Heathrow are continuing to engage with Network Rail and rail service
providers regarding the likely impacts and requirements of the Project
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on the rail network and rail accessibility.
Concern about the purpose of the consultation. ✓ The Airport Expansion Consultation Document (Section 1) explained
the purpose of the Airport Expansion Consultation One.
The purpose of the Airspace and Future Operations Consultation is
explained in the Airspace and Future Operations Consultation
Document.
Heathrow remain committed to engaging with the local community,
statutory consultees, the wider public and all those with an interest in
the Project throughout the design process in order to continue to seek
views to shape its expansion plans.
Concerns raised that the consultation was biased, a
‘box-ticking exercise’ or PR exercise and that
Heathrow will not listen to and act on consultation
feedback.
✓ ✓ The purpose of the Airport Expansion Consultation One was to seek
views early in the design process for the Project. Heathrow have
considered all feedback received and have published this Interim CFR
which sets out details of the consultation undertaken and feedback
received in relation to the Project.
This Interim CFR also sets out Heathrow’s response to the feedback
received during the Airport Expansion Consultation One and will inform
the Consultation Feedback Report that will be produced to accompany
Heathrow’s statutory consultation and the Consultation Report that is
required to accompany the DCO application.
Heathrow remains committed to engaging with the local community,
statutory consultees, the wider public and all those with an interest in
the Project throughout the design process in order to continue to seek
views to shape its expansion plans.
The consultation presented a new runway that is no ✓ At the time of the Airport Expansion Consultation One, the draft ANPS
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longer open to debate. had not been designated. To retain flexibility, Heathrow therefore
presented three options for proposed new runway of varying lengths.
Options A2 and A3 proposed a runway length of 3,200m and Option A4
proposed a runway length of 3,500m.
Since the Airport Expansion Consultation One concluded, the ANPS
has been designated. The ANPS clarifies the Government’s position on
the length of the new runway at Heathrow, stipulating that it needs to
be at least 3,500m in length.
As such, and in order to meet the requirements in the ANPS, Heathrow
have discounted the two runway options consulted on (Options A2 and
A3) which were less than 3,500m in length.
The consultation carried no weight because it was
non-statutory and undertaken ahead of the
designation of the ANPS.
✓ Although non-statutory in nature, the Airport Expansion Consultation
One was undertaken in accordance with the relevant guidance on
consultation associated with the proposed DCO application.
The overarching aim of the Airport Expansion Consultation One was to
gather views from all those with an interest in Heathrow’s expansion
about its emerging plans, options for components of the scheme and
approaches to key issues such as noise, air quality, surface access and
climate change. Heathrow considered that it was important to seek
views early in the design process for the Project at a stage when
options were still being considered.
Heathrow has considered and continues to have regard to, all feedback
received during the Airport Expansion Consultation One.
It should have been made clear that the consultation
was non-statutory and was being undertaken at a
time when feedback on the ANPS consultation was
still being analysed. The consultation was a PR
exercise and carries no weight.
✓
The Hendon consultation event was organised on a
Jewish holy day, preventing attendance by the
Jewish community.
✓ Heathrow regrets that the timing of the Hendon consultation caused a
conflict with a Jewish holy day. We will seek to ensure that future
consultation events are accessible outside of days of religious or
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cultural significance.
The Freepost return envelopes provided at some
events were too small.
✓ Throughout Airport Expansion Consultation One, large envelopes were
provided at the majority of events. Respondents were also able to write
the Freepost address on any envelope and post this free of charge.
Going forward, Heathrow will ensure that large envelopes are provided
at every consultation event and respondents will still have the option to
write the Freepost address on any envelope and post this free of
charge.
Requests for documentation at the Hayes event were
not fulfilled.
✓ Heathrow apologises for any unmet requests for documentation.
Heathrow aims to ensure that all requests for copies of consultation
materials received at consultation events and via our project phoneline
or email address are fulfilled with materials either sent via email or in
hard copy, dependent on the nature of the request.
The consultation did not attract a young audience.
An online consultation exhibition would have
achieved a wider reach and better use should be
made of social media platforms and the website.
✓ As part of the development of our approach to subsequent stages of
consultation we have explored different channels and mechanisms to
engage with and capture feedback from different demographics. This
includes using a wider range of traditional materials and interactive
digital technology, a more interactive website, using targeted social
media and holding consultation exhibitions in more publicly accessible
venues, such as shopping centres and terminals.
The staff at the Stanwell Moor event did not provide
feedback forms.
✓ Heathrow apologises if feedback forms were not made accessible to all
that attended the Stanwell Moor event. Heathrow provided feedback
forms for use at all consultation events.
Heathrow has had regard to this feedback in the planning of future
public consultation events and will ensure that feedback forms are
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made available at all events.
Staff were insensitive to concerns and not
appropriately informed on specific issues.
✓ In staffing the consultation events Heathrow sought to ensure that
members of the project team with a range of specialisms and
knowledge were available. Those staffing the consultation events were
also given training and briefed prior to each event.
Heathrow continues to aim to have relevant staff at consultation events
and where specific queries cannot be answered, Heathrow staff will
agree to respond to consultees with the relevant information by phone,
email or post should the consultee provide contact details. Alternatively,
consultees can contact Heathrow to request information by email, a
freephone number or by post. In any event, Heathrow will continue to
seek to improve consultation events going forward.
The feedback form is long and tedious, cumbersome
and difficult to navigate.
✓ At Airport Expansion Consultation One, Heathrow was seeking views
on a wide range of Project options and approaches and recognise that
the feedback form was long.
Heathrow has sought to improve the hard copy and online versions of
the feedback form for the purposes of the Airspace and Future
Operations Consultation (January 2019).
For the Airspace and Future Operations Consultation in January 2019
and the Airport Expansion Consultation in June 2019, we will ensure
that feedback forms are more structured and are simplified with fewer
questions.
The Project website will also be designed to allow respondents to
quickly and easily provide feedback as they view information (in-line
questioning), rather than having to make their way through the entirety
of an online feedback form, though the option of completing the online
The form included questions which were leading and
too complex.
✓
The feedback form could be improved by including
‘logout’ and ‘save’ options, a progress bar, making
related information accessible on each question
page, listing all questions on one contents page up-
front, including relevant maps and figures, detailing
the number of answers required at the outset,
including multiple choice questions and offering the
opportunity to complete the form while remaining
anonymous.
✓
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The feedback form should have provided additional
blank space for feedback.
✓ feedback form question by question will still be there if they wish. The
online feedback form will allow respondents to ‘logout’ and ‘save’.
As at Airport Expansion Consultation One, feedback forms used
throughout future consultations will offer the option for respondents to
remain anonymous.
The feedback form will continue to provide sufficient blank space for
responding to consultation questions. Blank paper will also be provided
at events and can be stapled into the form, should respondents need
additional space for their consultation responses.
Concern raised at the scope of the consultation, to
enable a full and proper consultation on component
parts and the delivery of the optimum overall
scheme, several options should be consulted upon
for each component.
✓ The Airport Expansion Consultation One included a range of options for
each Project component. Options were summarised in the Airport
Expansion Consultation Document and explained in further detail in
Our Emerging Plans and the Scheme Development Report including
the findings of the evaluation process. The preferred masterplan for
the Project will be presented at the Airport Expansion Consultation in
June 2019. This will include an Updated Scheme Development Report
which explains the evaluation process for the options considered.
There was a lack of an overall coherent strategy and
too much focus on individual specific elements
rather than strategic options.
✓ The overarching aim of the Airport Expansion Consultation One was to
gather views from all those with an interest in Heathrow’s expansion
about its emerging plans, options for the components of the scheme
and approaches to key issues such as noise, air quality, surface access
and climate change. Heathrow considered that it was important to seek
views early in the design process for the Project at a stage when
options were still being considered.
The Airspace and Future Operations Consultation (January 2019) will
provide more detail on proposed changes to flight paths and
Heathrow's emerging thinking on directional preference, runway
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alternation and a ban on scheduled night flights
The preferred masterplan will then be shared at the Airport Expansion
Consultation planned for June 2019.
The consultation materials did not consider the
timescales, costs and risks involved in relocating
residential, commercial and public property.
✓ The Scheme Development Report (issued as part of Airport Expansion
Consultation One) provided details on the progress made at that time in
developing options for the components of an expanded airport and its
supporting facilities. The Report explained how options for the Project
components had been evaluated against a range of criteria. Figure 22
of this Report summarised the findings of the evaluation including in
regarding to issues relating to the delivery and cost of the Project.
Further detail will be provided at the Airport Expansion Consultation in
June 2019.
The consultation was not broad enough as it only
focused on one proposal for a third runway.
✓ The Airport Expansion Consultation One presented three shortlisted
options for the proposed north-west runway (Options A2, A3 and A4).
The ANPS requires a new runway to be located to the north west of
Heathrow’s two existing runways between Sipson in the east,
Colnbrook and Brands Hill in the west and Harmondsworth in the north.
The shortlisted options presented in the Airport Expansion Consultation
One reflected this requirement.
The Airport Expansion Consultation One sought views on these options
and factors that should influence the precise location and length of the
new runway.
No information had been provided about local
consultations.
✓ Heathrow undertook an extensive process of advertising the
consultation and notifying residents and stakeholders. This involved
adverts in local newspapers, posters and billboards, radio, social
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media, media websites, local televised news and letters and leaflets to
properties located within the potentially affected zone. This is explained
in further detail in chapter 3 of this Report.
The consultation was designed to elicit
predetermined responses which favoured
expansion.
✓ The Airport Expansion Consultation One sought views on options for
the expansion of Heathrow, within the context of development
contemplated by the ANPS.
The consultation events had only been held in areas
already overflown, rather than those which may be
overflown in the future.
✓ As part of Airport Expansion Consultation One Heathrow carefully
considered the area in which public consultation exhibitions should take
place in regard to key principles including the areas likely to be affected
by the Project, the need to provide a broad and even distribution across
these areas and to provide exhibitions in accessible locations. During
the course of the consultation 40 exhibitions events were held across
the Potentially Affected Consultation Zone (the land within which
aircraft arriving and departing the airport will be travelling at 4,000ft or
less) and this included areas both currently overflown and those with
the potential to be overflown in the future.
As part of the identification of locations for exhibitions for the Airspace
and Future Operations Consultation in January 2019 Heathrow has
written to all local authorities within the 4,000ft consultation zone to get
their feedback and suggestions on potential exhibition locations. The
locations selected for the exhibitions take in to account the feedback
received and are based on areas most accessible to people located
within the Zone. We have also reviewed the venues used for
exhibitions for Airport Expansion Consultation One and replaced those
that were poorly attended with venues in areas of higher footfall.
The main consultation document was misleading as
it implied only one consultation was taking place.
✓ The Airport Expansion Consultation Document included a section on
the consultation process which explained how the consultation fitted in
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with the overall consultation plan for the Project and that a subsequent
stage of consultation would take place.
The Airport Expansion Consultation Document also provided
information on the different consultation and consenting procedures for
airspace change and the airport expansion and signposted consultees
to the Airspace Principles Consultation Document for further
information.
Not enough had been said about the impact on areas
to the North of London.
✓ The PEIR, which will be consulted on as part of the Airport Expansion
Consultation in June 2019, will report on likely environmental impacts
and where they are likely to occur.
The consultation did not present a balanced view of
the environmental and community impacts.
✓ The PEIR, which will be consulted on as part of the Airport Expansion
Consultation in June 2019, will include a range of environmental topics
(including community impacts) and will present Heathrow’s preliminary
assessment of both adverse and beneficial impacts and effects in
respect of each of these topics.
Concerns raised about a lack of area-specific
information, more information should have been
provided around the impacts on Colnbrook and
Poyle.
✓ Community Information Booklets were published as part of the Airport
Expansion Consultation One. The Community Information Booklet -
West provided information about the Project options that would impact
on the areas in and around Poyle, Colnbrook and Brands Hill.
This specific information could have included a
composite map showing all possible local impacts,
such as road realignments and river diversions.
✓ Heathrow welcomes suggestions regarding improvements to
consultation material and has taken these suggestions into account in
the planning of our subsequent stages of consultation.
At the Airspace and Future Operations Consultation in January 2019
and at the Airport Expansion Consultation planned for June 2019 an
interactive postcode map tool will also be used on the project website
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and at exhibitions to help consultees understand which aspects of the
proposals would affect them.
The PEIR, which will be presented at the Airport Expansion
Consultation in June 2019, will provide information on environmental
effects including a range of maps to identify specific areas impacted by
the Project.
The consultation did not make commitments to
actions which would address community concerns,
the loss of land and properties, pollution or transport
issues.
✓ The Airport Expansion Consultation One included draft policies for:
Residential Property, Agricultural Land and Property, Commercial
Property, (Interim) Property Hardship Scheme, and Professional Fees
(together the Property Policies).
The Airport Expansion Consultation in June 2019 will provide further
information on the Property Policies and the Community Fund, as
required by the ANPS. It will also present our draft Surface Access
Strategy which will set out the role of surface transport in regard to
reducing carbon and impacts on air quality in accordance with the
ANPS (see paragraph 5.9). A PEIR will also be published which will
present the early findings of our EIA, including impacts on air quality
and proposed mitigation measures.
The consultation materials contained statements
which were not supported.
✓ These comments have been noted. Heathrow aims to provide
balanced and accurate information but also seeks to make its
consultation materials user-friendly and clear. At the Airport Expansion
Consultation One, we included both user friendly documents such as
the consultation booklet as well as technical studies such as the
Scheme Development Report. All this information was publicly
available.
The expansion of Heathrow will support economic growth nationally
and this is verified by numerous independent studies including those
The consultation material included misleading
content, such as presenting Heathrow as the only
way to support economic growth.
✓
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published by the Airports Commission and the Department for
Transport. Heathrow recognise that there are other drivers for
economic growth.
The use of two columns in documents made them
difficult to read at appropriate magnification on a
computer screen.
✓ Heathrow welcomes feedback on the accessibility of our consultation
materials. We will seek to take account of suggestions regarding the
layout and design of our documents as part of the preparation of
materials for the Airport Expansion Consultation June 2019.
Frustrating to have to cross-refer to documents that
did not always follow the same sequence.
✓
Further details on how Heathrow Airport will become
a champion for assisted travel should be provided in
the next stage of consultation.
✓ Heathrow is committed to making every journey better and we welcome
the forthcoming Aviation Strategy’s focus on enhancing the passenger
experience. We have already made significant progress in this area
and are always looking for further improvements. We look forward to
working closely with disability groups, industry and government to make
air travel as accessible as possible and give all passengers more
control over their own journeys.
The consultation material did not quantify the
airport’s current operations against the potential
impacts of a new third runway.
✓ The PEIR that will be published as part of the Airport Expansion
Consultation in June 2019 will set out baseline data that reflects the
airport’s current operations and an assessment of impacts of the
preferred Project as against the baseline.
Heathrow need to establish an effective approach to
engaging stakeholders in issues concerning
biodiversity and the design of a green infrastructure
plan.
✓ Heathrow are undertaking a programme of ongoing engagement with
different stakeholder groups concerning different elements of the
Project. Chapter 29 of this Report provides an overview of our ongoing
engagement activities.
Engagement with Natural England and the Environment Agency is
ongoing in respect of the Project’s likely interaction with the natural
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environment. This includes a programme of meetings to discuss our
approach to, and findings of, ecology surveys, to discuss potential
significant effects concerning biodiversity and to discuss mitigation
options and our proposals for biodiversity offsetting. We also engage
with the HSPG, Wildlife Trusts, the Royal Parks and other specialist
interest groups (e.g. Bat Groups, Amphibian and Reptile Groups) to
provide information on our survey programme and results of our
assessments. As the design of our green infrastructure proposals
progresses, this will become a focus of our engagement with the noted
stakeholders.
It would have been beneficial to present consultation
booklets based on single subjects e.g. conservation,
noise, pollution, airport logistics. The maps were
inadequate due to changing scales and that the
conservation areas and historic buildings which
would be lost were not made clear.
✓ As part of the Airport Expansion Consultation One Heathrow produced
a single consultation booklet which provided an overview of the
proposals and the factors on which feedback was being sought. This
was supported by a number of topic specific information papers, such
as Our Design Approach to the Natural Environment, Our Approach to
Air Quality and Our Approach to Noise. Heathrow will continue to
provide topic specific information in the Airport Expansion Consultation
in June 2019, this will include environmental topics.
At the Airspace and Future Operations Consultation in January 2019
and at the June 2019 consultation an interactive postcode tool will also
be used on the project website and at exhibitions to help consultees
understand which aspects of the proposals would affect them.
The PEIR, which will be presented at the Airport Expansion
Consultation in June 2019, will provide information on environmental
effects including on the historic environment. This will include a range
of maps to identify specific buildings and conservation areas.
The consultation was a missed opportunity to
address concerns about the proposals for an
✓ The Airport Expansion Consultation One took place early in the design
and assessment process and before the ANPS had been designated
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expanded Heathrow and to set out clear
commitments to address these concerns.
by the Government.
Heathrow will provide further detail on its proposed approach to
mitigating impacts likely to arise from the Project in the PEIR which will
be published as part of the Airport Expansion Consultation in June
2019.
The consultation gave the impression that
expanding Heathrow was a “given” even before the
Parliamentary vote had been held.
✓ The Airport Expansion Consultation One took place before the ANPS
had been designated by the Government.
The overarching aim of the Airport Expansion Consultation One was to
gather views from all those with an interest in Heathrow’s expansion
about its emerging plans, options for the components of the scheme
and approaches to key issues such as noise, air quality, surface access
and climate change. The Consultation documents made clear that the
Consultation was undertaken in accordance with the framework for
airport expansion at Heathrow contemplated by the draft ANPS.
The ANPS has now been adopted and so provides the key policy basis
for the development of proposals for expansion at Heathrow.
Concerns about the lack of detail in relation to
various elements of the proposals and how
Heathrow will deal with managing an airport which is
doubled in size.
✓ Heathrow will provide further detail on the Project, including the
preferred masterplan and the PEIR, which will include likely impacts
and mitigation, as part of the Airport Expansion Consultation in June
2019.
The consultation was premature as it included too
much unresolved information to allow respondents
to make an informed response.
✓ Although undertaken before the ANPS had been designated by the
Government, Heathrow does not consider that the Airport Expansion
Consultation One was premature.
The overarching aim of the Airport Expansion Consultation One was to
gather views from all those with an interest in Heathrow’s expansion The consultation was unnecessary as some of the
decisions the consultation asked consultees to make
✓
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depended on information not available until the
second consultation.
about its emerging plans, options for the components of the scheme
and approaches to key issues such as noise, air quality, surface access
and climate change. The Consultation documents made clear that the
Consultation was undertaken in accordance with the framework for
airport expansion at Heathrow contemplated by the draft ANPS.
The Airport Expansion Consultation in June 2019 will provide detail on
the preferred masterplan for the Project.
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COSTS
Introduction
27.1.1 In response to Airport Expansion Consultation One, consultees provided feedback
related to the costs of the Heathrow Expansion Project (the Project), its economic
benefits, cost of mitigation or how cost should be taken in to account in the
development of the Project. A total of 325 consultees made comments relating to
this topic.
27.1.2 Heathrow provided the following material that is directly related to the costs of the
Project:
1. Airport Expansion Consultation Document;
2. Our Emerging Plans; and
3. Scheme Development Report.
27.1.3 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
Prescribed Consultees
Local Authorities
27.2.1 Bracknell Forest Borough Council acknowledged the economic benefits of the
existing Heathrow Airport and requested access for its residents to the proposed
£1bn community compensation fund.
27.2.2 Ealing Council welcomed the jobs and economic benefits of the Project but said
that it will cause more noise, pollution and traffic that will damage the quality of life
of local people. They indicated they were seeking a £150million package of
measures to maximise the economic benefits of the Project, to mitigate the
environmental impacts of a third runway and to compensate those affected.
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27.2.3 Elmbridge Borough Council stated the proximity of Heathrow to Elmbridge has a
beneficial effect on the local economy through job creation, business location and
expansion but queried why the cost of the Project and the contributions that
Heathrow will make to related infrastructure projects was not set out in the Airport
Expansion Consultation One documents. They also expressed concern that
shortfalls in funding or a financial crisis during the construction of the Project could
lead to a cost to the tax-payer.
27.2.4 Essex County Council recognised the role that Heathrow plays in the airport
network and considered that the third runway will enable Heathrow to retain its hub
status, which is vital for future UK economic growth and productivity.
27.2.5 The London Borough of Hammersmith and Fulham said that no context or
breakdown of the stated £187 billion economic benefits of the Project was
provided. They queried why this differs to the figure calculated by the government
as part of its Airports National Policy Statement (ANPS).
27.2.6 They also stated that the consultation materials provided at Airport Expansion
Consultation One contained little information on the costs associated with the
proposed third runway and expressed concern that changes to the Project put
forward in Airport Expansion Consultation One are part of a cost cutting exercise.
27.2.7 Hertfordshire County Council stated that a more comprehensive and realistic
picture of collective growth in the sub-region needs to be agreed to allow an
assessment of the collective impact of growth on the road network, what mitigation
measures will be required and agencies responsible for delivery.
27.2.8 Runnymede Borough Council said there will be significant national benefits for the
economy through the creation of a third runway but expressed concern about the
impact on its local community and harmful impacts across a wider area than any
defined red line boundary to be identified by the Development Consent Order
(DCO) application. They also expressed concern that there was no assessment of
the infrastructure requirements or costs for the Project.
27.2.9 Spelthorne Borough Council recognised the importance of Heathrow’s ‘hub’ status
to the UK economy and its potential benefits to the local area but said that any
community facilities which need relocating must be enhanced and improved at
Heathrow’s cost.
27.2.10 The South East England Councils stated that the new jobs and economic
opportunities must not be gained at the expense of increased congestion, greater
noise, air pollution or reduced quality of life for South East residents. They also
highlighted the urgency of quantifying the increase in services and infrastructure
that will be required and funding to ensure they can be delivered in advance of the
demand for them.
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27.2.11 Surrey County Council recognised the importance of Heathrow Airport in
supporting employment for its residents, generating investment in the County’s
economy and in attracting major businesses but commented that the
environmental and surface access issues associated with the Project must be
addressed.
27.2.12 The London Borough of Sutton commented that the potential cost of relocating the
Lakeside energy from waste facility would appear to be a significant obstacle to
the Project.
27.2.13 Wokingham Borough Council acknowledged the proximity of Heathrow Airport is
an essential factor in driving economic growth and maintaining economic activity in
the Thames Valley.
27.2.14 Buckinghamshire County Council expressed concern about the economic impact
to the film industry and the management of Black Park, Langley Park and Thorney
Park used by Pinewood Studios.
Statutory Consultees
27.2.15 Highways England stated that Heathrow’s decision making needs to demonstrate
that whole life costs have been taken into account in the design of the Project, not
just capital construction costs. They highlighted that the Project must be designed
to minimise maintenance interventions and that Heathrow will need to pay
Highways England’s operational and maintenance costs for a period of 60 years
post completion, in line with government policy.
27.2.16 They also highlighted that Heathrow should not rely on the public road system to
provide resilience and should fund proportionate infrastructure improvements to
minimise the impact of the Project on the surrounding road network during
incidents.
Other prescribed bodies
27.2.17 The Civil Aviation Authority responded detailing its statutory functions and its role
in regulating the costs of expanding and operating Heathrow Airport and the extent
to which Heathrow can pass the costs of surface access schemes to airlines,
passengers and cargo companies.
27.2.18 The Heathrow Strategy Planning Group (HSPG) stated that Heathrow should
provide funding for monitoring and review of air quality across the HSPG area.
27.2.19 Windlesham Parish Council expressed concern that complexity, cost and land
issues had not been fully considered and stated that no false statements should
be made.
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27.2.20 Bray Parish Council commented that the Project requires a considerable amount
of repositioning of recently constructed infrastructure and that this should be
avoided as it is uneconomic.
Local Communities
Members of the public
27.3.1 Members of the public commented that Heathrow should cover all the costs
associated with the Project and that the taxpayer should not have to contribute to
accommodation works, compensation, airport related development, the relocation
of Lakeside or noise insulation. Consultees also commented that there is a need
to consider the price of air travel and ensure the Project does not increase ticket
prices.
27.3.2 Members of the public raised concerns that the proposals for airport supporting
facilities may be too expensive and have not fully taken into account the cost of
relocating existing infrastructure, that the costs of the Project will be borne by
airlines and therefore passengers and at the costs of the infrastructure required to
deal with risk of flooding and diversion of rivers.
27.3.3 Concerns were also raised about the cost of infrastructure and public transport
connections with consultees querying how these will be paid for if Heathrow is only
contributing a small part of the funding. Many considered that the cost of these
improvements should not be at the taxpayers’ expense and should not be passed
on to rail companies.
27.3.4 General comments in relation to cost also comprised that details had not been
provided, that the costs of the Project should be weighed against alternative
schemes, that the costs would be recovered through an intensification of flights,
that the project is unaffordable and not financially credible and that the costs have
been underestimated.
27.3.5 Respondents also expressed a contrary view suggesting that the price of air travel
should be increased to reflect the burden on local communities, costs should be
met by government as much as possible or that Heathrow should minimise
compensation to save cost.
Businesses
27.3.6 The Airport Industrial Property Unit Trust (AIPUT) stated that it is vital to the local
and national economies that Heathrow Airport's hub status is secured and capacity
provided to ensure investment takes place in the many companies that depend
upon its international connectivity.
27.3.7 Airlines for America commented that to ensure that the Project provides maximum
value for the UK economy and the traveling public, the Project must be managed
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with a strong focus on cost control and fair/equitable cost allocation. They
considered that proposals to reduce the high costs of the Project without
undermining its potential benefits should be investigated.
27.3.8 They stated that Heathrow’s charges are currently the highest of any other
commercial airport in the world and airlines and their passengers should not be
subject to the additional cost of pre-funding the Project and improving access to
Heathrow, as a result. To avoid this, they suggested that charges should be
capped rather than averaged over time as proposed.
27.3.9 Delta Airlines expressed a similar view stating that passenger charges are already
the highest in the world and any increase would erode the U.K.’s competitive
position relative to other global aviation hubs. They stated that cost control is vital
to ensure that their customers do not pay even more than they already do and
suggested that a passenger charges guarantee should be introduced.
27.3.10 The Arora Group said that the lack of cost information provided at Airport
Expansion Consultation One made it impossible to evaluate options. They
considered this a major flaw in Heathrow’s consultation and requested that cost
estimates and transparent information on each of the components is published so
that key stakeholders can be meaningfully engaged.
27.3.11 They requested that Heathrow:
1. confirm its absolute commitment not to increase in airport charges;
2. publish the detailed evidence for how its scheme, costs and options satisfy this
test; and
3. explain how a landing charge in excess of £20 will be compatible with the
strengthening of domestic air connections, these being highly cost sensitive.
27.3.12 They asked for confirmation on whether Heathrow is expecting to take any cost
risk in developing its proposals or whether it will expect all costs to be absorbed by
users. They also outlined that the Arora Group can deliver the Project more cost
effectively and that they have the support of airlines to do so.
27.3.13 Heathrow Hub expressed a similar view commenting that the consultation lacked
comparative analysis of cost, benefits, risk and environmental impacts of each
option and that there was no attempt to show the relationship between options in
order to determine which are compatible and which are not.
27.3.14 EasyJet highlighted that the cost impact to passengers is a key factor.
27.3.15 Enterprise M3 Local Enterprise Partnership (LEP) expressed support for the
proposals stating that expansion will bring better connections to emerging
markets, more tourists and support exporters and UK businesses to grow.
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27.3.16 The Thames Valley LEP also expressed support for expansion and commented
that on, near and off-airport infrastructure needs to be well planned and co-
ordinated in order to reap the maximum benefits for the local economy and to
minimise the negative impact on local communities.
27.3.17 The Staffordshire Chamber of Commerce highlighted the importance of aviation in
connecting the Staffordshire economy to the rest of the world. For Staffordshire
businesses, air transport provides access to international customers and suppliers,
as well as an international labour force. They said that following Brexit,
Staffordshire businesses must be able to connect with high-growth and emerging
economies beyond Europe and considered that unless immediate steps are taken
to increase airport capacity and expand the UK’s international connectivity,
businesses will face increased costs and the economy will experience a loss of
trade, tourism and foreign direct investment.
27.3.18 Greengauge 21 requested that Heathrow undertake an analysis of the costs and
benefits of building the proposed Northwest Runway in two construction phases.
This should explore the concept that, while the full-length runway is desirable for
the long-term future of the airport, it might not be cost-effective now. They also
considered that the study should examine a variety of operating assumptions, a
variety of respite combinations and explore any operational benefit which would
result from runway-use being restricted to only more efficient, shorter-haul aircraft.
27.3.19 The Hampshire Chamber of Commerce commented that Heathrow has the
potential to add approximately 25,000 new flights a year before a new runway
opens and indicated that this should not be delayed so that the economic benefit
can be gained prior to the operation of the Project.
27.3.20 They also stated that increasing domestic air connections to Heathrow is important
and that the continued development of a globally competitive hub airport is
essential to the delivery of the industrial strategy, UK global competitiveness and
the development of international freight.
27.3.21 Petchey Industrial Properties Limited stated that the plans have too great an
impact on the surrounding area and are too costly.
27.3.22 Star Alliance expressed concern that as Heathrow seeks to reduce capital
expenditure, it will sacrifice the completion of Terminal 2 phase one (the baggage
system and a vehicular T2A/B transport link) and the further expansion of Terminal
2. They considered that the failure to deliver this so far is having a negative
impact on both the passenger experience and operational costs and requested
that the delivery of these infrastructure developments is fully costed and included
within all masterplan options for the Project.
27.3.23 The London (Heathrow) Airline Consultative Committee and the Board of Airline
Representatives UK expressed concern that too much of the risk and cost is being
transferred to airlines and passengers. They stated that the airline community is
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agreeable to fair and reasonable surface access contributions based on ‘user
pays’ principles, provided these costs are directly related and prioritise integrated
transport schemes. They said that any move away or offer beyond this would not
be acceptable to the airline community.
27.3.24 They expressed concern that the crossing of the M25 may affect the viability of the
Project and suggested that the risks and costs associated with it should be
addressed and independently verified and costed, before progressing too far.
27.3.25 They also commented that any costs committed prior to the DCO being granted
must be borne by Heathrow and its shareholders. They should not be allowed to
make early and additional returns because they are regulated.
27.3.26 Sunvil Holidays stated that the Project needs to be in operation as soon as
possible to avoid the UK lagging behind the rest of Europe and that it must ensure
that passenger charges are not affected.
27.3.27 Virgin Atlantic Airways Limited commented that the Project must deliver the right
scope and benefits at the right price if it is to deliver on the business case for the
Project. They said that it should ensure passengers are not asked to pay more
and that a Passenger Cost Guarantee should be introduced which sets out:
1. the total budget for delivering expansion;
2. a commitment that passenger charges after the construction of the Project will
be no more than today’s in real terms; and
3. a guarantee to cover the costs of any overspend.
27.3.28 They expressed support for the ‘user pays’ principle indicating that the airport and
its users should not pay for the full cost of road infrastructure improvements where
the benefits are shared between airport and non-airport users. They also
requested clarity over how the ongoing maintenance costs of the M25 tunnel and
runway would be allocated.
27.3.29 They expressed concern about the immaturity of the Project and commented that
a lack of detail on capital expenditure and operational expenditure is preventing
them from being able to scrutinise the Project. They also expressed concern that
the new runway capacity would never be fully utilised if noise, traffic or emissions
targets are breached. They considered that this would undermine the economic
case for expansion and increase the cost of development both per passenger and
over its lifetime.
Community groups
27.3.30 Many of the community groups who provided feedback to Airport Expansion
Consultation One expressed opposition to the Project but did not necessarily
include specific feedback on cost.
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27.3.31 Aircraft Nosie Three Villages expressed concern about conflicting and overstated
economic benefits, a high risk of the taxpayer having to fund the development and
other UK regions being starved of investment. A similar view was shared by
Teddington Action Group who suggested that to subsidise the Project from the
public purse would be completely unconscionable.
27.3.32 Residents Association HVG CA asked Heathrow to be honest about cost and SCR
Residents for a Fair Consideration of Heathrow Expansion suggested that the
cost, social and environmental impact of the Project was unacceptable. Wentworth
Residents Association commented that the expansion plans involve too much
cost.
27.3.33 Englefield Green Action Group stated that all infrastructure costs for the M25, M4,
M3, A4 and A30 roads should be funded by Heathrow and there should not be any
public subsidy. Ealing Aircraft Noise Group shared a similar view commenting that
there is no justification for local or national taxpayers having to pay for the
proposed diversion and tunnelling of the M25, or for any proportion of the cost of
such a Project.
27.3.34 Eastcote Residents Association commented that the Project will cost tax payers
billions of pounds and considered that the proposed Gatwick Second Runway
could be delivered with greater economic benefits, at lower cost and with no
taxpayer funding. The Eastcote Conservation Panel expressed a similar view.
27.3.35 The Heathrow Association for the Control of Aircraft Noise (HACAN) expressed
support for the establishment of an independent Community Engagement Board
which will influence how money is spent on compensation and community support.
27.3.36 The Richmond Heathrow Campaign commented that the options presented at
Airport Expansion Consultation One are only descriptive and not sufficiently
developed for objective response. They said that topics are not linked into an
overall decision-making framework so it is impossible to discern and balance the
priorities and assess the economic and environmental uncertainties and risks.
27.3.37 John Ruskin Street Residents expressed concern that the costs of the Project had
not been effectively calculated and as a result the tax payer and council tax payer
will be forced to pay the difference.
27.3.38 West Windsor Residents Association suggested that rather than lowering air fares,
the Project would result in an increase in fares particularly if the cost of expansion
is taken into account.
Wider/other Consultees
27.4.1 The Association of British Travel Agents stated that the Project offers opportunities
for both the UK economy and the consumer but must be cost-efficient, deliver
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increased competition and improve international connectivity to both existing and
emerging new markets.
27.4.2 They stated that their priority was to ensure that consumers do not carry the risk of
meeting the costs of the Project. They also expressed concern that the high costs
of additional airport capacity might lead to higher passenger charges and
increased fares.
27.4.3 The Chartered Institute of Logistics and Transport stated that road replacement
and diversion schemes should be publicly funded if they include additional
capacity to meet general traffic growth.
27.4.4 Justine Greening MP (Putney) commented that a lack of detail means it is not
clear how much the Project will cost. She expressed concern that the costs will
increase so much that Heathrow will not be able to recover costs and the tax payer
will be expected to contribute to the cost of the Project.
27.4.5 The Hounslow Green Party said the economic analysis shows an increasingly
uncertain economic case where the benefit to the national economy looks minimal
and risk to investors is likely to require state guarantees.
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Issues Raised and Heathrow’s Responses
Tables 27.1A and 27.1B present a summary of the main issues raised by prescribed consultees, local communities and
wider/other consultees in relation to Costs.
Table 27.1A presents a summary of Heathrow’s responses to those issues which are directly related to the proposals on which
we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019), and how in preparing
those proposals we have had regard to the relevant Airport Expansion Consultation One feedback.
Table 27.1B provides a summary of the way in which we are seeking to consider the issues raised in relation to any other
aspects of the Project not included in the Airspace and Future Operations Consultation. These interim responses are provided
for information only, and so no further feedback is being sought on the basis that a full consultation feedback report will be
published as part of the Airport Expansion Consultation in June 2019.
Table 27.1A
Issue Consultee24 Heathrow Response
PC MC WC
The economic impact to the film industry and the
management of Black Park, Langley Park and Thorney
Park used by Pinewood Studios is a concern.
✓
Heathrow is promoting plans to modernise its airspace at the
same time as it is preparing its application for development
consent for expansion. Changes to our airspace will be consented
in accordance with the Airspace Change Process (ACP).
24 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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Issue Consultee24 Heathrow Response
PC MC WC
As part of the Airspace and Future Operations Consultation in
January 2019, Heathrow will be seeking feedback on the broad
geographic areas within which future flight paths could be
positioned. Heathrow will ask what local factors should be taken
into account when developing new flight paths within these
geographically defined areas known as ‘design envelopes’.
We will treat this response as feedback in relation to these local
factors.
The potential to add approximately 25,000 new flights a
year before a new runway opens should not be delayed so
that the economic benefit can be gained prior to
expansion.
✓ As a first phase of our expansion plans, we are proposing
to make increased use of our existing two runways, once
approval for the physical expansion of Heathrow has been
granted.
More information is available in the document Airspace and Future
Operations: Consultation Document, available as part of the
January 2019 Airspace and Future Operations Consultation.
Our intention is to bring forward proposals for early growth as part of the Airport Expansion Consultation in June 2019.
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Table 27.1B
Issue Consultee Heathrow Response
PC MC WC
The business case for expansion does not justify the
significant impact on the biodiversity and natural
environment in and around the airport.
✓ The Airports National Policy Statement (ANPS) recognises that
there is an urgent need for new airport capacity in the South East
(paras. 2.10-18), that the Heathrow Northwest Runway scheme is
best placed to deliver this capacity and that overall it would
deliver the greatest net benefits to the UK (para. 3.74). The
Government has also made it clear in supporting expansion at
Heathrow that any application for development consent must
demonstrate and secure a number of supporting measures in
order to mitigate the impacts of expansion on the environment
and affected communities (ANPS, para. 5.4).
The Development Consent Order (DCO) application will comply
with the ANPS and will include an Environmental Statement (ES)
to identify any likely significant environmental effects during
construction and operation of the Heathrow Expansion Project
(the Project) and any proposed mitigation relating to the same.
Preliminary findings will be available in the Preliminary
Environmental Information Report (PEIR) as part of the Airport
Expansion Consultation in June 2019. As part of this consultation
Heathrow will also be published a draft Surface Access Strategy.
The environmental and surface access issues associated
with expansion must be addressed.
✓
The plans have too great an impact on the surrounding
area and are too costly.
✓
New jobs and economic opportunities must not be gained
at the expense of increased congestion, greater noise, air-
pollution or reduced quality of life for South East
residents.
✓
The economic case for expansion had been overstated
and that airport expansion should be at Gatwick.
✓ The Airport Commission shortlisted three options to maintain the
UK’s status as a global hub for aviation: a new northwest runway
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Issue Consultee Heathrow Response
PC MC WC
Gatwick could be delivered with greater economic
benefits, at lower cost and with no taxpayer funding.
✓ ✓ at Heathrow Airport; a westerly extension of the northern runway
at Heathrow Airport and one new runway at Gatwick Airport. The
Airport Commission’s Final Report (July 2015) concluded (page
9): “Each of the three schemes shortlisted was considered a
credible option for expansion, capable of delivering valuable
enhancements to the UK’s aviation capacity and connectivity.
Each would also have environmental impacts, which would need
to be carefully managed. The Commission has nonetheless
unanimously concluded that the proposal for a new Northwest
Runway at Heathrow Airport, in combination with a significant
package of measures to address its environmental and
community impacts, presents the strongest case”. The ANPS
also contains an analysis on why the Government prefers the
Heathrow Northwest Runway Scheme to the Gatwick Second
Runway scheme in terms of delivering additional airport capacity
by 2030 (paras. 3.16 – 3.55).
Based on the Department for Transport’s (DfT’s) assessment of
direct benefits, and Frontiers assessment of catalytic benefits, the
economic benefits of expanding at Heathrow at £187bn are
significantly greater than that for expanding at Gatwick at £116bn.
The Project is a privately funded infrastructure project which will
be delivered in a cost effective and sustainable way.
Costs of Heathrow expansion should be weighed against
alternative schemes.
✓
Access for Bracknell Forest Borough Council residents to
the proposed £1bn community compensation fund.
✓ Heathrow will develop a community compensation fund (CCF).
The size of the CCF will be proportionate to environment impacts.
Further information will be available as part of the Airport
Expansion Consultation in June 2019. Heathrow should provide an £150million package of
measures to mitigate the environmental impacts of a third
runway and to compensate those affected in Ealing.
✓
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Issue Consultee Heathrow Response
PC MC WC
Heathrow should minimise compensation to save cost. ✓
Expansion will cause more noise, pollution and traffic that
will damage the quality of life of local people.
✓ Heathrow recognises that the Project will have some impact
during construction and operation and is committed to manage
and mitigate effects on the environment and local communities.
As part of the application for development consent, Heathrow will
need to assess likely significant impacts, including community
impacts, which will then form part of the Environmental Statement
(ES). This will be submitted with the DCO application.
In June 2019, as part of the Airport Expansion Consultation,
Heathrow will be publishing more details of the assessment,
including proposals for how Heathrow will manage, monitor and
report on impacts in the future. Further information on
environmental impacts will be available in Chapters 19 and 21 to
24 of the PEIR.
The project’s impact on its local community and harmful
impacts across a wider area than any DCO ‘redline’ are
concerning.
✓
There is an urgent need to quantify the increase in
services and infrastructure that will be required and
funding to ensure they can be delivered in advance of
demand for them.
✓
Heathrow is engaging with the relevant utility and service
providers and will ensure that adequate provisions are put in
place in the DCO to protect their interests.
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Issue Consultee Heathrow Response
PC MC WC
Any community facilities which need relocating must be
enhanced and improved at Heathrow’s cost.
✓ As part of the Environmental Impact Assessment (EIA), a
community impact assessment is being undertaken. This will
include an assessment of appropriate provision and mitigation
proposals for affected community facilities. Early findings of this
assessment will be presented in the PEIR published as part of
the Airport Expansion Consultation in June 2019.
Heathrow should provide funding for monitoring and
review of air quality across the Heathrow Strategic
Planning Group (HSPG) area.
✓
At the Airport Expansion Consultation in June 2019, Heathrow
plans to publish more detail on managing and mitigating effects of
growth, including proposals for monitoring and enforcement for
areas such as air quality.
The cost of expansion and the contributions that
Heathrow will make to related infrastructure projects was
not set out in the consultation documents.
✓ Airport Expansion Consultation One January 2018 sought to
provide information and obtain feedback on a range of
masterplan component options. As such it was not possible to
provide detailed cost information because the plans were still at
an early stage of development. The masterplan scheme
development process has been designed to ensure that
affordability considerations are fully taken into account, alongside
criteria within the other discipline areas (operations and service,
delivery, sustainability and community and planning and
property). Cost is an important consideration and the masterplan
is being carefully prepared to balance all the different design
requirements. Heathrow is evaluating the costs of all masterplan
options and will keep a record of this as progress is made to a
preferred masterplan. The outputs from the evaluation process
were presented in the Scheme Development Report at Airport
Expansion Consultation One and an Updated Scheme
The options provided are only descriptive and not
sufficiently developed for objective response.
✓
Consultation materials contained little information on the
costs associated with the 3rd Runway.
✓
The consultation lacked comparative analysis of cost,
benefits, risk and environmental impacts of each option
and that there was no attempt to show the relationship
between options in order to determine which are
compatible and which are not.
✓
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Issue Consultee Heathrow Response
PC MC WC
A lack of detail on capex and opex prevents scrutiny of
the development proposals.
✓ Development Report will be available as part of the Airport
Consultation in June 2019.
Topics are not linked into an overall decision-making
framework so it is impossible to discern and balance the
priorities and assess the economic and environmental
uncertainties and risks.
✓
Heathrow have not provided a detailed breakdown of cost. ✓ ✓
Cost information and information on each of the
components should be provided in order to evaluate
options.
✓
The lack of assessment of the infrastructure requirements
or costs for an expanded Heathrow is concerning.
✓
The project’s the benefit to the national economy looks
minimal and risk to investors is likely to require state
guarantees.
The Airports Commission estimated that the Project would deliver
up to 180,000 jobs across the UK, the majority predicted to be
outside London and the South East. Furthermore, the ANPS
recognises that the Project is best placed to deliver additional
runway capacity and overall would deliver the greatest net
benefits to the UK (Para 3.74).
The Project will be privately funded at no cost to the taxpayer.
Heathrow has already invested over £12 billion of private money
into the airport since going private in 2006 and will be able to
secure further attractive private financing for its expansion without
Shortfalls in funding or a financial crisis during the
expansion of Heathrow could lead to a cost to the tax-
payer.
✓
Repositioning recently constructed infrastructure should
be avoided as it is uneconomic.
✓
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Issue Consultee Heathrow Response
PC MC WC
Heathrow should cover all costs associated with
expansion.
✓ ✓ ✓ public loans or guarantees. Heathrow’s shareholders are
amongst the most experienced infrastructure investors in the
world, with over $1 trillion of funds under management.
The Project will be delivered affordably and sustainably, while
aiming to keep airport charges close to 2016 levels.
Heathrow is regulated by the Civil Aviation Authority (CAA). The
CAA will scrutinise Heathrow’s business plan.
The taxpayer should not have to contribute to
accommodation works, compensation, airport related
development, the relocation of Lakeside or noise
insulation.
✓
Costs should be met by government as much as possible. ✓
Any costs committed prior to the DCO being granted must
be borne by Heathrow and its shareholders.
✓ ✓
There should not be any public subsidy. ✓
Ensure that consumers do not carry the risk of meeting
the costs of expansion.
✓
Complexity, cost and land issues have not been fully
considered.
✓
No context or breakdown of the stated £187 billion
economic benefits of expansion was provided.
✓ The ANPS identified total benefits of up to £74 billion over 60
years for the Northwest Runway scheme at Heathrow (paragraph
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Issue Consultee Heathrow Response
PC MC WC
Heathrow’s stated £187 billion benefit of expansion differs
to the figure calculated by the Government as part of its
NPS.
✓ 3.26 refers) but this did not include wider trade benefits). The
draft ANPS (October 2017) identified the same benefit at
paragraph 3.26 but again that did not include wider trade
benefits.
£187bn is based on the DfT’s latest estimate of benefits, added to
catalytic impacts that Frontier have calculated.
The DfT estimated that Heathrow will generate £74.1-75.3bn over
the 60-year appraisal period (2026 - 2085). These benefits are
calculated as a sum of passenger benefits, Government revenue,
and wider economic impacts but significantly excludes trade and
foreign Direct Investment (FDI) benefits.
Frontier Economics has performed a catalytic impact analysis of
a 3rd runway at Heathrow, measuring the effect of additional
trade, FDIs and additional tourism spending on GDP – all of
which are not included in the DfT’s figure. They estimated that the
Project will lead to £113bn of catalytic impact.
The catalytic impact and those estimated by the DfT are based
on separate methodologies and capture different benefit types.
Heathrow consider them largely additive. Therefore, taken
together, the catalytic impact and the DfT’s impacts could lead to
a total benefits figure of up to £187bn for Heathrow.
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Issue Consultee Heathrow Response
PC MC WC
The potential cost of relocating the Lakeside energy from
waste facility would appear to be a significant obstacle to
the expansion proposals.
✓ Heathrow has been working with Grundon Waste Management &
Lakeside Energy from Waste (EfW) to identify potential suitable
sites for the relocation of its facilities. The objective has been to
replace these facilities and discussions are well advanced.
The Lakeside EfW’s operation cannot meet the definition of
Associated Development required for inclusion within the DCO
application, nor does the ANPS require its replacement. It will not,
therefore, be possible to include proposals for its relocation as
part of the DCO application. A replacement facility will require
consent from the relevant local planning authority.
Decision making needs to demonstrate that whole life
costs have been taken into account in the design of the
scheme, not just capital construction costs.
✓
The Project will be delivered affordably and sustainably, while
aiming to keep airport charges close to 2016 levels.
Heathrow is confident that the work it is doing and on-going
engagement with airlines, communities and other stakeholders
will enable it to meet that affordability challenge.
The ANPS states that the scheme should be “cost-efficient and
sustainable, and seeks to minimise costs to airlines, passengers
and freight owners over its lifetime” (paragraph 4.39).
Within that context, the scheme development process has been
designed to ensure that costs are fully taken into account,
alongside criteria within the other discipline areas such as
sustainability, community, operations and service and others.
Heathrow is regulated by the CAA and the CAA will be
responsible for scrutinising the business plan.
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Issue Consultee Heathrow Response
PC MC WC
The proposals for supporting facilities may be too
expensive and have not fully taken into account the cost
of relocating existing infrastructure.
✓ The masterplan scheme development process includes a wide
range of considerations in the evaluation criteria used for
appraising different options and masterplan components
(including supporting facilities) which will form part of the decision
making process, including cost, buildability, land use,
environment and impact on existing operations.
The Updated Scheme Development Report and preferred
masterplan, including preferred options for supporting facilities
will be published as part of the Airport Expansion Consultation in
June 2019.
Heathrow should undertake an analysis of the costs and
benefits of building the Northwest Runway in two
construction phases.
✓ It has always been intended that the north west runway scheme
would be phased. There are a number of reasons why it is likely
to be desirable to phase the introduction of new capacity,
including:
• it is a more cost-efficient way of delivering large scale
infrastructure;
• new assets can be brought into use as and when ready,
whilst other parts of the Project remain under
construction, thereby delivering early benefits;
• it enables passenger growth to be accommodated whilst
ensuring the programme is affordable and keeping the
passenger charge close to current levels;
• it also reduces operational impacts on airport users and
ensures the best customer experience; and
• it allows time for airlines to schedule and develop new
routes.
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Issue Consultee Heathrow Response
PC MC WC
New runway capacity will never be fully utilised if noise,
traffic or emissions targets are breached.
✓ Heathrow is proposing legally binding obligations to ensure that
growth of the airport’s operations can only take place if it respects
each of the environmental limits as set out in the ANPS related to
areas such as noise, traffic, or emissions.
As part of the Airport Expansion Consultation in June 2019,
Heathrow will publish proposals on how these should be
monitored or enforced.
A more comprehensive and realistic picture of collective
growth in the sub-region needs to be agreed to allow an
assessment of the collective impact of growth on the road
network, what mitigation measures will be required and
agencies responsible for delivery.
✓ Heathrow is working closely with the Heathrow Strategic Planning
Group (HSPG) to assess the wider growth which may be
generated by the Project, including effects on the road network
and any necessary mitigation measures required. This is
intended to inform future Local Plan reviews.
The cost of infrastructure and public transport is
concerning if Heathrow is only contributing a small part of
the funding.
✓ Where transport infrastructure benefits airport users, Heathrow is
committed to make a fair and reasonable contribution.
The ANPS (para. 5.20) states “Where a surface transport scheme
is not solely required to deliver airport capacity and has a wider
range of beneficiaries, the Government, along with relevant
stakeholders, will consider the need for a public funding
contribution alongside an appropriate contribution from the airport
on a case by case basis”. Heathrow has a track record of
investing in surface access improvements at the airport and will
fund all of the road diversions required by expansion alongside a
fair and reasonable contribution to new rail infrastructure, where
Infrastructure and public transport improvements should
not be at the taxpayers’ expense and should not be
passed on to rail companies.
✓
There is no justification for local or national taxpayers
having to pay for diversion and tunnelling of the M25, or
for any proportion of the cost of such a project.
✓
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Issue Consultee Heathrow Response
PC MC WC
The scheme must be designed to minimise maintenance
interventions and Heathrow will need to pay Highways
England operational and maintenance costs for a period
of 60 years post completion.
✓
this is required to secure planning permission for expansion or
enhance the efficient operation of the airport, in accordance with
the CAA policy on surface access.
Heathrow should not rely on the public road system to
provide resilience and should fund proportionate
infrastructure improvements to minimise the impact of
airport expansion on the surrounding road network during
incidents.
✓
The crossing of the M25 may affect the viability of the
project and suggested that the risks and costs associated
with it should be addressed and independently verified
and costed.
✓ ✓
All infrastructure costs for the M25, M4, M3, A4 and A30
should be funded by Heathrow.
✓
The project needs to provide clarity over how the ongoing
maintenance costs of the M25 tunnel and runway would
be allocated.
✓
Road re-provision schemes should be publicly funded if
they include additional capacity to meet general traffic
growth.
✓
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Issue Consultee Heathrow Response
PC MC WC
The costs of infrastructure required to deal with risk of
flooding and diversion of rivers is concerning.
✓ The costs associated with the Project will be privately funded.
Heathrow will comply with National Policy on flood risk
management, including the Water Framework Directive (WFD).
The scheme development process has been designed to ensure
that costs and affordability considerations are fully taken into
account, alongside all other relevant considerations including
sustainability and community and others. Preliminary findings will
be available in the PEIR as part of the Airport Expansion
Consultation in June 2019.
Costs will be borne by airlines and therefore passengers. ✓ The Project will be privately funded. Heathrow have already
invested over £12 billion of private money into the airport since
going private in 2006 and will be able to secure further attractive
private financing for our expansion without public loans or
guarantees. Heathrow’s shareholders are amongst the most
experienced infrastructure investors in the world, with over $1
trillion of funds under management.
The Project will be delivered affordably and sustainably. while
aiming to keep airport charges close to 2016 levels. Furthermore,
research from the CAA has shown that additional capacity will
increase competition and choice for passengers and has the
potential to drive down costs on airfares.
ANPS para. 3.26 states that “Expansion at Heathrow Airport
would increase the availability of services and increase
competition between airlines. This would lower fares that
passengers can expect to face relative to no expansion, leading
Ensure expansion does not increase ticket prices. ✓
Agreeable to fair and reasonable surface access
contributions based on ‘user pays’ principles, provided
these costs are directly related and prioritise integrated
transport schemes. Any move away or offer beyond this
would not be acceptable.
✓
Airlines and their passengers should not be subject to the
additional cost of pre-funding expansion and improving
access to Heathrow.
✓
Prefunding should be avoided by capping charges rather
than averaging over time.
✓
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Issue Consultee Heathrow Response
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Cost control is vital to ensure that customers do not pay
even more than they already do and a passenger charges
guarantee should be introduced.
✓ to significant benefits to business and leisure passengers and the
wider economy.”
To strengthen domestic connectivity between airports in the UK,
Heathrow has committed to introduce a package of measures to
increase connections to the UK’s hub airport. This has included
the introduction of a £15 discount on domestic departing
passenger charges to strengthen connectivity to other UK
regions.
Heathrow is regulated by the CAA and the CAA will scrutinise the
business plan.
Where airport users will benefit from transport infrastructure
proposals, Heathrow is committed to make a fair and reasonable
contribution in accordance with Government policy. Any
contribution to transport infrastructure will be made in line with,
and subject to approval through, the CAA’s surface access policy.
Heathrow is still developing a preferred masterplan in
consultation with airlines, communities and other stakeholders
and will publish the preferred masterplan as part of the Airport
Expansion Consultation in June 2019.
Heathrow should confirm its absolute commitment to no
increase in airport charges and publish the detailed
evidence for how its scheme, costs and options satisfy
this.
✓
Heathrow should explain how a landing charge in excess
of £20 will be compatible with the strengthening of
domestic air connections.
✓
Heathrow should clarify if it expecting to take any cost
risk in developing its proposals or whether it will expect
all costs to be absorbed by users.
✓
As Heathrow seeks to reduce capital expenditure, it will
sacrifice the completion of Terminal 2 phase one and the
further expansion of Terminal 2.
✓
Too much of the risk and cost is being transferred to
airlines and passengers.
✓ ✓
The project must ensure that passenger charges aren't
affected.
✓ ✓
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Issue Consultee Heathrow Response
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A Passenger Cost Guarantee should be introduced which
sets out; the total budget for delivering expansion, a
commitment that passenger charges after expansion will
be no more than today’s in real terms and a guarantee to
cover the costs of any overspend.
✓
Rather than lowering air fares, expansion would result in
an increase in fares.
✓
Costs of Heathrow expansion should we recovered
through an intensification of flights.
✓
The project is unaffordable and not financially credible. ✓
The costs have been underestimated. ✓
The project must be managed with a strong focus on cost
control and fair/equitable cost allocation to provide
maximum value for the UK economy and travelling public.
✓
Proposals to reduce the high costs of expansion without
undermining its potential benefits should be investigated.
✓
Changes to the scheme put forward in the consultation
are part of a cost cutting exercise.
✓
The price of air travel should be increased to reflect the
burden on local communities.
✓
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PLANNING
Introduction
28.1.1 In response to Airport Expansion Consultation One, consultees made comments
about planning policy applicable to the proposed expansion of Heathrow and/or
the important planning factors that should be taken in to account in the
development of the Heathrow Expansion Project (the Project). A total of 292
consultees made comments relating to this topic.
28.1.2 Heathrow provided the following material that is directly related to planning:
1. Airport Expansion Consultation Document;
2. Development Consent Order Process Information Paper;
3. Environmental Impact Assessment Information Paper;
4. Our Emerging Plans; and
5. Scheme Development Report.
28.1.3 Heathrow asked the following questions regarding planning at Airport Expansion
Consultation One:
1. Do you have any views on how the demand for additional airport related
development such as hotels and offices might best be delivered?
28.1.4 This chapter provides a summary of the relevant consultation feedback received
from prescribed consultees, local communities and wider/other consultees. The
issues raised by respondents have also been grouped in table form at the end of
this chapter, which includes Heathrow’s response to these issues. For the
purposes of the Airspace and Future Operations Consultation, we have prepared a
summary of our responses to those issues which are directly related to the
proposals being put forward in that consultation, and how in preparing those
proposals we have had regard to the relevant Airport Expansion Consultation One
feedback. For those issues raised in relation to any other aspects of the Project,
we have provided a summary of the way in which we are seeking to consider the
issues as part of preparing the detailed proposals which will be presented as part
of the Airport Expansion Consultation planned for June 2019.
Prescribed Consultees
Local Authorities
28.2.1 Bracknell Forest Borough Council commented that Extant Minerals and Waste
Local Plans should be recognised and that there must be engagement with the
appropriate authorities on this matter.
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28.2.2 The London Borough of Brent expressed disappointment that Heathrow had not
made a commitment to work with local authorities to propose policies in their local
plans that would prevent third party car parks. If they are to control the number of
vehicles accessing the airport and meet the targets in the draft Airports National
Policy Statement (ANPS), Heathrow will require the support of the local
authorities.
28.2.3 Buckinghamshire County Council commented that it had not received any
information to demonstrate how the modal share and transport targets in the draft
ANPS would be achieved. They highlighted that policy considerations should not
just include the London Plan but also the policies of Buckinghamshire County
Council, South Bucks District Council and the Chilterns District Council and other
local planning authorities.
28.2.4 They also requested funding for the Council’s work to assist Heathrow in taking
forward the Project and suggested a Planning Performance Agreement as an
appropriate mechanism.
28.2.5 Ealing Council expressed a similar view commenting that proposals for airport
supporting facilities are best addressed through emerging evidence base studies,
the proposed Joint Spatial Planning Framework for the wider Heathrow area and
where appropriate, specific site allocations in individual local development plans.
They stated that in the absence of a holistic strategy and supporting evidence it
was premature to comment.
28.2.6 The London Borough of Hammersmith and Fulham stated that consulting on a
shorter runway did not comply with the draft ANPS and was confusing. They also
expressed concern that mitigation measures set out in the draft ANPS were not
referenced in the Airport Expansion Consultation Document.
28.2.7 The London Borough of Hounslow commented that their emerging Local Plan
Review for the west of the borough proposes significant additional housing and
employment areas across Feltham and Bedfont but Heathrow’s proposals are for
low-density logistics or directly displaced functions such as the Immigration
Removal Centre. They requested that Heathrow review its plans to ensure
consistency with theirs and neighbouring Local Plans.
28.2.8 Runnymede Borough Council expressed concern that the draft ANPS does not
recognise the severity of congestion problems on the surrounding road networks
and considered that freight traffic should be included in any targets linked to
Heathrow’s ‘no more traffic’ pledge.
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28.2.9 Slough Borough Council stated that the following planning principles should apply
to any development at Heathrow:
1. Protect Colnbrook and Poyle villages in a “Green Envelope25”;
2. Enhance Colnbrook Conservation Area and built realm;
3. Prevent all through traffic but provided good public transport and cycle routes
to the airport;
4. Provide for the replacement of Grundon energy from waste plant and the rail
deport north of the new runway;
5. Ensure that there are good public transport links into Heathrow from Slough;
6. Enlarge the Poyle Trading Estate for airport related development but with
access only from the M25;
7. Provide mitigation for the Colne Valley Park and ensure that existing North
South connectivity is maintained through Crown Meadow;
8. Develop tangible measures to improve air quality in the Heathrow area; and
9. Ensure that all homes in the Borough that are eligible for noise insulation are
provided for under the Quieter Homes Scheme.
28.2.10 They considered that elements of the Project presented at Airport Expansion
Consultation One are in direct conflict with these principles and demonstrate a
disregard for the Council’s objectives for mitigating the impact of the expanded
airport.
28.2.11 Surrey County Council also sought clarification as to why Heathrow presented
options for runway length that did not comply with the draft ANPS. They stated
that airport related development should take account of any adopted and emerging
Local Plans (including site allocations) and should be delivered through the
Heathrow Strategic Planning Group (HSPG) on a joint strategic planning
framework.
28.2.12 The Royal Borough of Windsor and Maidenhead expressed concern about the
lack of detail around the quantity and distribution of additional housing required to
meet the needs of the proposed expanded airport. They commented that scope to
accommodate additional housing over and above the levels set out in the Local
Plan is severely restricted. They also stated that Heathrow should support local
authorities to develop an area-wide response to the spatial distribution of
25 A network of green spaces protected from development
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economic activity rather than leave it to local authorities to bear the risk and cost of
dealing with individual planning applications.
28.2.13 Wycombe District Council stated that over 75% of the district is green belt or an
Area of Outstanding Natural Beauty (or both) and this means that it is not able to
meet all of its housing and economic development land needs. They commented
that additional development arising from Heathrow alongside increased national
housing requirements will make the accommodation of future growth even more
difficult.
Statutory Consultees
28.2.14 Highways England sought clarification on what reference would be made to the
National Networks National Policy Statement in the Heathrow Development
Consent Order (DCO) application. They also commented that demand for
additional airport related development needs to be taken forward in consultation
with local planning authorities as they develop their local plans.
28.2.15 Historic England shared a similar view stating that airport related development
must be integrated with the local plans of the adjacent local authorities, to ensure
a properly plan-led approach to new development beyond the boundaries of an
expanded airport.
28.2.16 The Environment Agency highlighted the importance of adopting the sequential
approach to locating development in the areas of lowest flood risk in accordance
with the National Planning Policy Guidance for flood risk and coastal change.
28.2.17 Natural England commented that to satisfy the requirements of the National
Planning Policy Framework (NPPF), sufficiently detailed agricultural land
classification information must be submitted in support of Heathrow’s DCO
application.
Other prescribed bodies
28.2.18 The HSPG requested further explanation on why Heathrow had presented options
for a 3,200m runway when the draft ANPS states a length of 3,500m, the only
option that appears to offer full operational and respite benefits.
28.2.19 They commented that while national policy for nationally significant infrastructure
projects will be set out in National Policy Statements, other planning policies are
material including the NPPF policies and local development plans (adopted and
emerging). They also stated that normal planning principles should apply to airport
related development.
28.2.20 Watford Borough Council commented that it had previously provided information
on currently permitted/allocated developments to feed into the modelling of the
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traffic impacts of proposed growth and noted that this only makes up a relatively
small proportion of actual future development.
Local Communities
Members of the public
28.3.1 Members of the public that provided comments related to planning made
comments about perceived deficiencies in the draft ANPS or made general
comments about the need for the proposals to comply with planning policy.
Respondents commented that the planning process should be speeded up as the
expansion of Heathrow is long overdue and in the national interest.
28.3.2 Consultees also commented on the use of brownfield sites for development and
avoidance of impacts on the Green Belt. This comprised comments that car
parking should be on brownfield sites and not on green/open space in Stanwell
and Harlington, that hotel development needs to conform to local plan strategies
for housing and regeneration of underused brownfield sites and that the removal of
green spaces would be detrimental to Green Belt between West Drayton and
Slough.
28.3.3 Specific comments were also received that any development between Airport Way
and Stanwell Moor would not justify the very special circumstances required to
develop in the Green Belt and that the use of Green Belt and the loss of Little
Harlington Playing Fields for car parking must be avoided.
28.3.4 Other comments expressed concern that Heathrow would not be able to comply
with the NPS target to restrict airport related traffic, that proposals to introduce
road user charging need to be considered in accordance with national policies and
that evidence-based site analysis should be carried out to the determine the
suitability of sites for development.
Businesses
28.3.5 The Arora Group considered that as the ANPS had not been adopted, Airport
Expansion Consultation One was premature. They considered this particularly
important as key project decisions had been reached based on the Airports
Commission scheme and the draft ANPS.
28.3.6 They considered that discounting options based on unadopted policy was
premature and challenged why Heathrow was consulting on two runway options
that do not meet the criteria in the draft ANPS. They also highlighted that legal
challenges in respect of the ANPS will be brought forward which will address key
issues which Heathrow has used to discount options and on which the
consultation was based.
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28.3.7 Wiggins Building Supplies Limited commented that if the DCO application makes
no reference to land at Poyle Manor Farm for airport related car parking or for
uses including warehousing, industry and offices they intend to submit a planning
application for one or more of these uses.
28.3.8 Jayflex Construction Limited stated that it has promoted the Horton Brook Quarry
site for housing, commercial and amenity use in the Royal Borough of Windsor
and Maidenhead Borough Council’s recent ‘call for sites’ request. They
highlighted that the site is suitable for mixed use development servicing Heathrow
that will replace amenities lost through the Project.
28.3.9 Segro expressed concern about the delivery of airport-related development as the
majority of land identified (approximately 97%) is in the green belt. They requested
greater clarity on how development will be delivered on these sites given the
enhanced Green Belt safeguarding policies in the draft London Plan and NPPF.
28.3.10 They also commented that all of the sites for airport-related development should
be delivered through planning permissions separate from the DCO.
28.3.11 The Lanz Group highlighted that under the Section106 Agreement attached to
planning permission PP/10697/009 all site HGVs must exit their site east away
from the village of Colnbrook. They stated that any closure of the A4 east would
significantly affect this planning permission and current operations, making the
business unviable.
28.3.12 Crane Road Properties commented that it had submitted a representation to
Slough Borough Council in January 2017 as part of the “Call for Sites” exercise to
confirm that their site (Land at Green Acre Farm) could be released from the
Green Belt and made available for airport related development.
28.3.13 Harleyford Aggregates commented that the safeguarded status of Mayfield Farm
under the NPPF, the London Plan and London Borough of Hounslow’s Local Plan
does not appear to have been considered. They stated that this may not preclude
development proposals at the site providing mineral extraction is completed prior
to development.
28.3.14 Global Grange Limited expressed concern that consideration had not been given
to the proposals included within Hounslow’s ‘West of the Borough Plan’. They
highlighted that given the need for growth, development and regeneration within
this part of Hounslow, Heathrow should carefully consider the emerging planning
policy framework and work with Hounslow Council and landowners to deliver the
vision for development within this part of the Borough and ensure that there is no
conflict with the expansion proposals.
28.3.15 Greengauge 21 stated that the planning analysis should document the predicted
change in noise levels in Hounslow and Stanwell Moor compared to both current
levels and the Project.
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28.3.16 Goodman commented that land to the north of the A4 Colnbrook Bypass has been
the subject of two planning applications to Slough Borough Council for the creation
of a Strategic Rail Freight Interchange (planning application references:
P/10792/000 and P/14961/000). More recently, this land has been identified by
Slough Borough Council as a potential future location for new employment
development in the emerging Review of the Local Plan.
28.3.17 Ingrebourne Valley Limited stated that its site is identified in the Hillingdon Local
Development Plan as suitable for mineral extraction and a planning application for
this use was submitted in November 2017. They stated that they would resist any
proposals that would sterilise this site but would work with Heathrow and
potentially enter into agreements over the land once the mineral extraction
operations have been completed and the site has been fully restored.
Community groups
28.3.18 Many of the community groups who provided feedback to Airport Expansion
Consultation One expressed opposition to the Project but did not necessarily
include specific feedback relating to planning or the planning policy context.
28.3.19 The Local Authorities Aircraft Noise Council and Aircraft Noise Three Villages
stated that the consultation was premature as there was no government policy to
support the Project.
28.3.20 Teddington Action Group considered that it was not appropriate for Heathrow to
consult on alternative positions and lengths of runway that do not accord with the
draft ANPS.
28.3.21 Richmond Heathrow Campaign commented that conditions of expansion are
vague and provide little assurance to those potentially harmed. They considered
that the conditions of expansion should be placed on a legal footing with penalties
applied to Heathrow’s shareholders for any breach.
Wider/other Consultees
28.4.1 Transport for the South East commented that passenger demand will grow faster
than initially expected. As a result, they considered that without additional
sustainable surface access the airport will not become successful, meet
sustainability requirements nor meet the demands of future air travel growth.
28.4.2 The London Wildlife Trust highlighted that its continued engagement in the pre-
application planning process will incur costs and as a result they were keen to
explore how this could be addressed.
28.4.3 The National Trust highlighted the importance of requirements of relevant
National, Regional and Local planning policy including the draft London Plan, the
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London Environment Strategy and the All London Green Grid, and the need to
address the potential impact on the Colne Valley Regional Park.
28.4.4 Surrey Wildlife Trust highlighted the relevance of Surrey Biodiversity Opportunity
Area (Staines Moor and Shortwood Common) as the basis for achieving Surrey’s
local ecological network.
28.4.5 The Friends of the River Crane expressed concern that there is no single
overarching authority with responsibility to ensure that networks of green
infrastructure identified in development plans are protected from development and,
where possible, strengthened by or integrated within it.
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Issues Raised and Heathrow’s Response
The table below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other
consultees in relation to Planning. None of the feedback received in relation to Planning are directly related to the proposals
on which we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019) but instead
relate to other aspects of the Project. The table therefore provides a summary of the way in which we are seeking to consider
the issues raised, and are provided for information only. No further feedback is being sought on the basis that a full
consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.
Table 28.1B
Issue Consultee26 Heathrow Response
PC MC WC
Heathrow has not provided information to
demonstrate how the modal share and transport
targets in the draft Airports National Policy
Statement (ANPS) would be achieved.
✓ The Airport Expansion Consultation in June 2019 will include our draft
Surface Access Strategy and supporting technical information in the
Preliminary Transport Information Report. This will explain Heathrow’s
preferred approach to transport infrastructure needed to support the Project
in the context of increasing the use of public transport by passengers and
colleagues, and our preferred plans for a new parking strategy and
freight/logistics strategy. In addition, it will propose measures and incentives
which would help to manage demand by car users travelling to and from the
airport, as set out in the Airports National Policy Statement (ANPS) at
paragraph 5.17.
The draft Surface Access Strategy will set out how we intend to meet the
26 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees
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PC MC WC
ANPS requirements for increasing passenger mode share by public
transport and reducing the number of colleague car trips (paragraph 5.9).
At the time of Airport Expansion Consultation One in January 2018 the
ANPS was in draft. In June 2018, the ANPS was designated by the
Secretary of State for Transport with only minor changes. Regarding surface
access, paragraph 5.17 now includes additional text that states the surface
access strategy should also include an assessment of the feasibility of the
measures proposed. This information will be included in the draft Surface
Access Strategy which will be published in June 2019.
Policy considerations should not just include the
London Plan but should also include policy
documents of other local planning authorities
including Buckinghamshire, South Bucks and the
Chilterns District Council.
✓ As the Project is defined as a National Significant Infrastructure Project, it
can only be consented through an application for a Development Consent
Order (DCO) made to the Secretary of State. Under this process, the
proposals will be examined principally against the policy set out in the ANPS
and the National Networks National Policy Statement (NN NPS) for those
elements of the Project concerning proposals for the M25.
In addition to the ANPS and NN NPS, Heathrow is considering relevant
policy at national, regional and local levels (recognising that the ANPS and
the NN NPS represents the primary planning policy). The Project is being
designed and assessed in accordance with the National Planning Policy
Framework (NPPF) and National Planning Practice Guidance (NPPG)
where relevant. We are engaging with local authorities concerning local
development plan documents and will accord with policy objectives where
practicable for the Project to do so. This will be reported in a Planning
Statement to be submitted with the DCO application.
We have also had regard to specific evidence base and strategy documents
including the London Plan Environment Strategy and the All London Green
Grid, as referenced in our Environmental Impact Assessment (EIA) Scoping
Report (May 2018).
Heathrow should review its plans to ensure
consistency with Local Plans.
✓
The Project should have regard to the London
Plan Environment Strategy and the All London
Green Grid.
✓
Concern that elements of the Project are in direct
conflict with principles in Local Plans and this
demonstrates a disregard for the Councils’
objectives for mitigating the impact of the
Project.
✓
Extant Minerals and Waste Local Plans should be
recognised and there must be engagement with
✓
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Issue Consultee26 Heathrow Response
PC MC WC
the appropriate authorities on this matter. We are undertaking an EIA of the Project and early findings will be reported
in the Preliminary Environmental Information Report (PEIR) to be published
as part of the Airport Expansion Consultation in June 2019. The PEIR will
provide a legislative and policy overview and demonstrate where policy is
relevant to and has been considered in relation to the preliminary
assessment of likely environmental effects of the Project. It will guide the
preparation of the Environmental Statement (ES) to be submitted with the
DCO application.
In addition to the National Policy Statements, the
National Planning Policy Framework and
Guidance is also relevant to the proposals.
✓
✓
Heathrow need to assess and address the
potential impact on the Colne Valley Regional
Park and take this into account.
✓ Heathrow are undertaking ongoing engagement with the Colne Valley
Regional Park Interest Company who are part of the Heathrow Strategic
Planning Group (HSPG). Heathrow are undertaking an Environmental
Impact Assessment, which includes an assessment of potential impacts on
the Regional Park. This assessment has informed the design of the Project,
through an ongoing evaluation process. Early findings of this process will be
reported in the PEIR and the Updated Scheme Development Report to be
published at the Airport Expansion Consultation in June 2019.
Airport related development should take account
of any adopted and emerging Local Plans
including site allocations and accord with
standard planning principles.
✓ Where airport related development (ARD) is classified as associated
development, the intention is that it would be part of the DCO application,
and so assessed primarily against the ANPS. Where ARD is not included
with the DCO application, it will require separate consent by the relevant
local planning authority in response to applications submitted in accordance
with the Town and Country Planning Act. Such applications would need to
accord with the relevant local development plan. The ARD chapter of this
Report provides further detail on Heathrow’s response to related issues.
Heathrow are taking an evidence-based approach to determine the
suitability of sites for associated development, including both ARD and ASF,
that would form part of the DCO application. Decisions on the suitability of
sites are informed by a range of evidence in addition to local planning policy
Evidence-based site analysis should be carried
out to determine the suitability of sites for
development.
✓
Suggestion that proposals for airport supporting
facilities are best addressed through emerging
evidence base studies, the proposed Joint Spatial
✓
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Issue Consultee26 Heathrow Response
PC MC WC
Planning Framework for the wider Heathrow area
and where appropriate, specific site allocations in
individual local development plans.
and engagement with the HSPG and other stakeholders.
The sites required for airport-related development
should be delivered through planning
permissions separate from the DCO application.
✓
An emerging Local Plan review proposes
significant additional housing and employment
areas across Feltham and Bedfont. Heathrow’s
proposals are for low-density logistics or directly
displaced functions such as the immigration
removal centre. Heathrow should review its
plans to ensure consistency with Local Plans.
✓
Airport related development should be delivered
through the Heathrow Strategic Planning Group
(HSPG) on a joint strategic planning framework.
✓ Heathrow have undertaken detailed studies to determine the quantum of
ARD that the Project is likely to demand. Where proposed ARD can be
defined as associated development in accordance with the principles set out
in the Guidance on associated development applications for major
infrastructure projects (April 2013: CLG), it is intended to be included in the
DCO application. The remaining quantum of demand will need to be
planned for by the local planning authorities around Heathrow.
Heathrow are working closely with HSPG to identify all growth required to
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Issue Consultee26 Heathrow Response
PC MC WC
2041. The work will provide an evidence base for the local authorities in the
study area27, in the context of the wider region and sub-region, concerning
the potential impacts of the expansion of Heathrow Airport in addition to
planned ‘background’ growth in the sub-region. It looks principally at
potential impacts on the local economy, labour market and associated
demand for employment land and housing. It assesses associated
infrastructure requirements to support this level of development. The work
may inform the way HSPG plans for future growth.
Funding should be supplied to Councils for the
cost of the work required to assist Heathrow in
taking forward its proposals. A Planning
Performance Agreement would be an appropriate
mechanism for this.
✓ Heathrow have entered into a Service Level Agreement with the HSPG,
under which Heathrow funds agreed staffing costs for HSPG members in
relation to review of our emerging plans and assessments and for inputs to
joint evidence base/sub-regional planning work.
Continued engagement in the planning process
for the Project with wider consultees will incur
costs. This needs to be explored by Heathrow.
✓
Consulting on a shorter runway did not comply
with the draft ANPS and was confusing.
✓ ✓ During Airport Expansion Consultation One in January 2018, the ANPS was
still at draft stage (and subject to consideration of further consultation).
27 A Study Area was defined in partnership with the HSPG group, and following Planning Practice Guidance approach to defining commercial property
markets and housing market areas. This found that the HSPG area is very similar to the Heathrow and Slough Travel to Work area and also contains
the authorities accounting for a high proportion of current Heathrow employees. All of the authorities in the Core Study Area are members of the HSPG,
apart from LB Hillingdon.
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Heathrow included Option A2 within the Airport Expansion Consultation One
to retain openness and flexibility in the options that should be evaluated.
The ANPS has now been designated, and the Government has made it
clear in supporting the Heathrow Expansion that the ANPS “applies to
schemes at Heathrow Airport…. that include a runway of at least 3,500m in
length and that are capable of delivering additional capacity of at least
260,000 air transport movements per annum” (paragraph. 4.3). Heathrow
continues to consider the preferred option for the exact length of the third
runway and will present the preferred runway option in June 2019 as part of
the Airports Expansion Consultation. Heathrow will not be proposing any
runway options shorter than 3,500 m in length. Chapter 7 of this Report
provides further information on our response to runway related feedback.
Mitigation measures set out in the draft ANPS
were not referenced in the Heathrow consultation
document.
✓ Consultation documents provided at Airport Expansion Consultation One
provided information early in the design and assessment process, focused
on design components and options. The Airports Expansion Consultation in
June 2019 will outline proposals on mitigation measures, in a PEIR, which
will reference the requirements of the ANPS.
Heathrow should make a commitment to work
with local authorities to propose policies in their
local plans that would prevent third party car
parks. If Heathrow are to control the number of
vehicles accessing the airport and meet the
targets in the draft ANPS, Heathrow will require
the support of the local authorities.
✓ Heathrow have committed to working with local authorities on Controlled
Parking Zones. We continue to work with local authorities, including through
ongoing engagement with the HSPG.
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Concern about the lack of detail provided
regarding the quantity and distribution of
additional housing required to meet the needs of
the Project.
✓ Heathrow are working with the HSPG to undertake research in to the wider
growth implications of the project. This will include looking at the impact of
the Project on future employment growth and housing demand.
As part of the socio-economic impact assessment, to be reported in the
Environmental Statement, we are also assessing potential additional effects
on the housing market as a result of operational employment generation
linked to the Project. Early findings of this assessment will be reported in the
PEIR at the Airport Expansion Consultation in June 2019.
Concern from some local authorities that they
have limited scope to accommodate additional
housing to support the Project over and above
the levels set out in the Local Plan.
✓ Heathrow has proposed generous compensation payments for those losing
their homes, mitigation strategies where it is necessary to intervene to
ensure the re-provision of certain types of housing (such as affordable
housing) and we are working with the HSPG planning authorities to assist in
the planning of new housing in the wider area through Local Plan reviews,
which take account of the growth of the airport alongside other housing and
employment needs for which the authorities already need to plan.
Suggestion that Heathrow should support local
authorities to develop an area-wide response to
the spatial distribution of economic activity rather
than leave it to local authorities to bear the risk
✓ Heathrow recognise the need for strategic planning regarding economic
growth. Heathrow and HSPG have started to consider how this can be
planned for to help inform future Local Plan reviews. This includes the
consideration of an Economic Development Strategy. Early research shows
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and cost of dealing with individual planning
applications.
that the labour market impacts (jobs for residents) and business
opportunities will be the main direct benefit of the expansion for most
authorities. Maximising such benefits will require a combination of
accessibility improvements and ‘soft’ investments in jobs, training and
brokerage.
Concern that the draft ANPS does not recognise
the severity of congestion problems on the
surrounding road networks and that freight traffic
should be included in any targets linked to the
‘no more traffic’ pledge.
✓ Heathrow will publish a draft Surface Access Strategy for consultation at the
Airport Expansion Consultation in June 2019, which will help set out how we
will meet the requirements of the ANPS around modeshare. The strategy
will also support Heathrow’s commitment to strive for no more additional
landside airport-related traffic.
Concern that Heathrow would not be able to
comply with the ANPS target to restrict airport
related traffic.
✓
Protecting Colnbrook and Poyle villages in a
“Green Envelope” should be a planning principle
that applies to any development at Heathrow.
✓ Impacts at Colnbrook and Poyle villages will be assessed as part of the
Environmental Impact Assessment (EIA) of the preferred masterplan for the
Project. This will include a range of environmental topics including
biodiversity, nature conservation, land use and green infrastructure. Early
findings will be reported in the PEIR for consultation in June 2019. The
findings of this assessment will inform mitigation proposals. This will include
a green infrastructure strategy that is informed by engagement with a range
of environmental organisations regarding green infrastructure design.
The preferred masterplan for the Project will be presented at the Airport
Expansion Consultation in June 2019. The preferred masterplan will be
selected following an evaluation of masterplan options and which is
informed by the Airport Expansion Consultation One feedback. This
evaluation includes sustainability criteria, which includes a consideration of
impacts on landscape character and value and green infrastructure
provision, including opportunity to provide a network of multifunctional green
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spaces. The findings of the evaluation that have informed the decision-
making process will be presented in the Updated Scheme Development
Report at the June 2019 consultation.
Enhancing the Colnbrook Conservation Area and
built realm should be a planning principle that
applies to any development at Heathrow.
✓ Potential impacts on the Colnbrook Conservation Area are being assessed
as part of the EIA, as required by the ANPS and the NPPF. Early findings
will be reported in the Historic Environment chapter of the PEIR as part of
the Airport Expansion Consultation in June 2019. This will also include
proposed mitigation measures.
Preventing all through traffic but providing good
public transport and cycle routes to the airport
should be a planning principle that applies to any
development at Heathrow.
✓ Heathrow is committed to meeting the targets for increasing passenger
mode share by public transport as set out in the ANPS and reducing
colleague car trips. Heathrow will publish a draft Surface Access Strategy
(supported by technical information in a Preliminary Transport Information
Report) at the Airport Expansion Consultation in June 2019. This will set out
our preferred options for meeting these targets.
There are several new rail and coach routes proposed to improve
connectively to Heathrow, improving connectivity to the west and east.
There is likely to be a Western Rail Link scheme (promoted by Network
Rail), which would connect Heathrow to Reading, via Slough. The Western
Rail Link is not essential to deliver the modal share targets in the ANPS. We
are working closely with the Department for Transport and Network Rail on
the planning and design of the Western Rail Link Scheme to ensure
compatibility with the Project.
Ensuring that there are good public transport
links into Heathrow from Slough should be a
planning principle that applies to any
development at Heathrow.
✓
Providing for the replacement of the Lakeside
Waste Management Facilities and the rail depot
north of the new runway should be a planning
principle that applies to any development at
Heathrow.
✓ Heathrow has been working with Grundon Waste Management & Lakeside
Energy from Waste (EfW) to identify potential suitable sites for the
relocation of its facilities. The objective has been to replace these facilities
and discussions are well advanced.
The Lakeside EfW’s operation cannot meet the definition of Associated
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Development required for inclusion within the DCO application, nor does the
ANPS require its replacement. It will not, therefore, be possible to include
proposals for its relocation as part of the DCO application. A replacement
facility will require consent from the relevant local planning authority.
Land is likely to be required near the existing rail depot to provide a
relocated rail head, which is a critical component of our Construction
Strategy to minimise Heavy Goods Vehicle (HGV) traffic. The existing rail
depot site was identified at Airport Expansion Consultation One as an
opportunity site for development in the Scheme Development Report. It is
noted that the site is safeguarded as an aggregate rail depot site in local
planning policy. The preferred masterplan will be presented at the Airport
Expansion Consultation in June 2019 and this will confirm land
requirements at the existing rail depot site and impacts on existing facilities.
Enlarging the Poyle Trading Estate for airport
related development with access only from the
M25 should be a planning principle that applies to
any development at Heathrow.
✓ Heathrow are considering a range of options for ARD and are engaging
stakeholders in the process. Heathrow will present its preferred option at the
Airport Expansion Consultation in June 2019. The Airport Related
Development chapter of this Report provides further information on
Heathrow’s response to feedback received on ARD issues.
Providing mitigation for the Colne Valley Park
and ensure that existing North South connectivity
is maintained through Crown Meadow should be
a planning principle that applies to any
development at Heathrow.
✓ The preferred masterplan for the Project, will be presented at the Airport
Expansion Consultation in June 2019. The preferred masterplan will be
selected following an evaluation of masterplan options informed by
consultation and stakeholder feedback. This evaluation includes
sustainability criteria, which includes a consideration of impacts on
landscape character and value and green infrastructure provision including
opportunity to provide a network of multifunctional green space. The
findings of the evaluation that have informed the decision-making process
will be presented in the Updated Scheme Development Report at the Airport
Expansion Consultation in June 2019.
We will propose an approach to mitigating likely impacts at Colne Valley
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Park and Crown Meadow in the PEIR, which will be published for
consultation in June 2019. We are considering approaches to green
infrastructure design and engaging with a range of environmental
stakeholders and HSPG on green infrastructure to inform the preferred
masterplan.
Developing tangible measures to improve air
quality in the Heathrow area should be a planning
principle that applies to any development at
Heathrow.
✓ Heathrow will provide details of mitigation for likely impacts on air quality as
a result of the Project in the PEIR, which will be published for consultation in
June 2019. Heathrow will commit to air quality mitigation as part of the DCO
application. This will accord with paragraph 5.32 of the ANPS, which
requires that the ES demonstrates that the construction and operation of the
Northwest Runway will not affect the UK’s ability to comply with relevant
legal obligations. The Air Quality chapter of this Report provides further
information on Heathrow’s responses to air quality related issues.
Ensuring that all homes that are eligible for noise
insulation are provided for under the Quieter
Homes Scheme should be a planning principle
that applies to any development at Heathrow.
✓ The Quieter Homes Scheme is an existing scheme to provide insulation for
homes currently impacted by noise related to [the existing] Heathrow Airport
and is due to complete in 2020. Heathrow are preparing a compensation
scheme for those impacted by the Project, which includes a noise insulation
scheme. Further details of this scheme will be provided in June 2019. The
Noise chapter of this Report provides more information on the feedback
received concerning noise issues and Heathrow’s response.
Concern from local authorities that additional
development arising from the Project in addition
to increased national housing need will make the
accommodation of future growth even more
difficult.
✓ Heathrow understands the need for strategic planning in relation to future
growth around the Airport. We are working with the HSPG and have
recently commissioned a Joint Evidence Base and Infrastructure Study to
identify growth required to 2041 and HSPG have started to consider how
this can be planned for. In regard to housing, this research has found that
the impact of the expansion on population and housing demand is likely to
be small. However demographic and economic trends, as well as housing
targets, change and it will be important to keep a watching brief.
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Clarification sought on what reference would be
made to the National Networks NPS in the
Heathrow DCO application.
✓ The Project requires significant alterations to the M25 west of the airport.
Those works also meet the definition of an NSIP in their own right. For the
M25 works, the NN NPS is the principal policy document.
It is important that a sequential approach is taken
to locating development in areas of the lowest
flood risk in accordance with the National
Planning Policy Guidance for flood risk and
coastal change.
✓ Heathrow are undertaking a Flood Risk Assessment in accordance with the
ANPS, the NN NPS and relevant national planning policy guidance. Early
findings of the assessment will be included as part of the PEIR to be
published at the Airport Expansion Consultation in June 2019.
Detailed agricultural land classification
information must be submitted to support the
DCO application and to accord with the
requirements of the National Planning Policy
Framework.
✓ Heathrow are undertaking an assessment of impacts on agricultural land
quality, which will be reported as part of the ES. Early findings will be shared
in the PEIR to be published at the Airport Expansion Consultation in June
2019. The approach to this assessment is set out in Chapter 14 of the
Scoping Report, with comments received by the Planning Inspectorate as
set out in section 4.10 of the Scoping Opinion.
Consultees provided information on permitted
and allocated developments that should be
included in the traffic modelling process.
✓ Heathrow are undertaking traffic modelling to inform the draft Surface
Access Strategy and the transport assessment. A Preliminary Transport
Information Report will be published at the Airport Expansion Consultation in
June 2019 that explains the approach to including proposed development in
the traffic modelling process.
The time required for the consenting process
should be reduced as the expansion of Heathrow
is long overdue and in the national interest.
✓ The Heathrow Expansion Project is recognised as An NSIP, and as such is
following a prescribed consenting process in accordance with the Planning
Act 2008.
Car parking should be on brownfield sites and
not on greenfield sites or open space in Stanwell
and Harlington.
✓ Heathrow will present its preferred option for car parking as part of the
Project, at the Airport Expansion Consultation in June 2019. Heathrow has
been engaging with stakeholders in the ongoing design and evaluation
process in relation to car parking options, which seeks to reduce adverse
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environmental impacts in balance with other requirements.
Proposed hotel development needs to conform to
Local Plan objectives for housing and
regeneration of underused brownfield sites.
✓ Heathrow are considering options for hotel development, to be proposed as
part of the DCO application, against a range of criteria which includes local
planning policy. The preferred option for hotel development will be
presented at the Airport Expansion Consultation in June 2019. The Updated
Scheme Development Report will explain the reasons for the preferred
option.
Removal of green spaces would be detrimental to
the green belt between West Drayton and Slough.
✓ Through the design and evaluation process Heathrow is seeking to
minimise adverse impacts on the green belt as a result of the Project.
Where there is a need to use green belt land Heathrow are required to
demonstrate very special circumstances in accordance with green belt
policy and the ANPS. We will present an assessment of likely impacts of the
Project on open space and green belt land in the PEIR as part of the Airport
Expansion Consultation in June 2019. We will also present its preferred
approach to ARD in June 2019. The Updated Scheme Development Report,
to be published in June 2019, will set out the reasons for the preferred
approach to ARD, and the results of the evaluation process that has
informed the decision-making process.
Development between Airport Way and Stanwell
Moor would not justify the very special
circumstances required to develop in the green
belt.
✓
The use of green belt and the loss of Little
Harlington Playing Fields for proposed car
parking must be avoided.
✓
Concern about the delivery of airport-related
development as most of land identified is in the
Green Belt. Greater clarity on how development
will be delivered on these sites is needed given
the enhanced green belt safeguarding policies in
the draft London Plan and draft NPPF.
✓
Proposals to introduce road user charging need
to be considered in accordance with national
✓ In accordance with the aims of the Project and broader policy trends
towards lower emissions and mode sustainable modes of transport,
Heathrow is considering a charging strategy as part of its overall surface
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policies. access strategy to effectively bring down vehicle use and associated
emissions. We will consult on a charging strategy as part of our draft
Surface Access Strategy which will be published at the Airport Expansion
Consultation in June 2019.
As the ANPS had not been adopted the first
round of consultation was premature. This is this
particularly important as key project decisions
had been reached based on the Airports
Commission scheme and the draft ANPS.
✓ Heathrow does not consider that the consultation was premature. Airport
Expansion Consultation One provided an opportunity for early feedback on
options and approaches at an early stage in the design process for the
Project. The draft ANPS provided a framework for the early design process
and has since been adopted, and now provides more certainty and direction
for the Project going forward. Furthermore, the changes between the draft
ANPS and the adopted ANPS are minor.
Legal challenges in respect of the ANPS will be
brought forward which will address key issues
that Heathrow has used to discount a number of
options and on which the consultation was
based.
✓ The ongoing design and assessment of the Project is undertaken in
accordance with a programme of evaluation and engagement. This process
was explained in the Scheme Development Report published at Airport
Expansion Consultation One. Heathrow is aware of the legal challenges to
the ANPS. We are confident that the Government’s decision-making
process was robust.
If the DCO application makes no reference to land
at Poyle Manor Farm for airport related
developments a planning application will be
submitted for these uses.
✓ Heathrow will present the preferred approach for ARD as part of the
Heathrow Expansion Consultation in June 2019. Inclusion of land within the
DCO application does not preclude any planning application being
submitted to a local planning authority. Further detail on the feedback
received regarding ARD and Heathrow’s response to that feedback is set
out in the Airport Related Development chapter of this Report.
Horton Brook Quarry site is suitable for mixed
use development servicing Heathrow that will
replace amenities lost through the Project.
✓ Heathrow will present its preferred approach to ARD as part of the
Heathrow Expansion Consultation in June 2019. Further detail on the
feedback received regarding ARD and Heathrow’s response to that
feedback is set out in the Airport Related Development chapter of this
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Report.
A Section 106 Agreement attached to planning
permission PP/10697/009 states that all site HGVs
must exit the site east away from the village of
Colnbrook. Any closure of the A4 east would
significantly affect this planning permission and
current operations, making the business
unviable.
✓ The proposed new runway location would most likely result in the loss of the
Western Perimeter Road and parts of the Northern Perimeter Road. It will
likely also result in severance of the A4 (Bath Rd) and A3044 (Stanwell
Moor Rd). These changes will require close working with a number of
interested highway authorities: Slough Borough Council (A4), Transport for
London (A4, A30 and A312), London Borough of Hillingdon (A3044), as well
as Highways England as an interested party operating nearby and parallel
roads. To maintain traffic connectivity in the area and reduce potential
effects on road users, we recognise that the existing A3044 and A4 would
need to be maintained until the new replacement roads are complete. The
draft Surface Access Strategy to be published at the Airport Expansion
Consultation in June 2019 will explain Heathrow’s preferred options for re-
providing the A4. The Surface Access chapter of this Report provides
further detail on Heathrow’s response to surface access related issues.
A representation to Slough Borough Council has
been made for a site to be released from the
green belt and made available for airport related
development.
✓ Heathrow are undertaking ongoing engagement with Slough Borough
Council. Heathrow monitor local policy and changes to site allocations and
decisions regarding ARD will be informed by local planning policy. We will
present the preferred approach to ARD as part of the Airport Expansion
Consultation in June 2019.
The safeguarded status of Mayfield Farm under
the NPPF, the London Plan and London Borough
of Hounslow’s Local Plan does not appear to
have been considered. This may not preclude
development proposals at the site providing
mineral extraction is completed prior to
development.
✓ Heathrow are aware of the minerals allocation at the Mayfield Farm site.
Where we propose development on land that is safeguarded for minerals,
we will examine the feasibility of these being worked in advance.
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Concern that consideration had not been given to
the proposals in the Hounslow West of the
Borough Plan. Heathrow should carefully
consider the emerging planning policy framework
and work with Hounslow Council and landowners
to deliver the vision for development within this
part of the Borough and ensure that there is no
conflict with the Project.
✓ Heathrow is working closely with local authorities and is aware of the local
planning policy context at Hounslow and Slough.
We are considering local planning policy and site allocation as part of our
assessment of the suitability of sites for ARD and ASF that may be included
in the DCO application as associated development. Our preferred
masterplan will be presented at the Airport Expansion Consultation in June
2019 and this will include our preferred sites for associated development.
The Updated Scheme Development Report will present our reasons for
selecting these sites. Land to the north of the A4 Colnbrook Bypass
has been the subject of two planning applications
for the creation of a Strategic Rail Freight
Interchange. This land has also been identified by
Slough Borough Council as a potential future
location for new employment development in the
emerging Review of the Local Plan.
✓
A site identified in the Hillingdon Local
Development Plan is suitable for mineral
extraction and a planning application for this use
was submitted in November 2017. Any proposals
to sterilise this site would be resisted.
✓ Where we propose development on land that is safeguarded for minerals,
we will examine the feasibility of these being worked in advance.
The planning analysis should document the
predicted change in noise levels in Hounslow and
Stanwell Moor compared to both current levels
and the proposed Project.
✓ The noise impact assessment, which will be reported in the ES will report
baseline noise conditions and predicted changes in the noise environment
related to the Project. Early findings will be published in the PEIR, as part of
our Airport Expansion Consultation in June 2019. The Updated Scheme
Development Report, will also be published in June 2019, and will set out
how noise considerations have informed the preferred options for the
Project. The Noise chapter of this Report provides further information on
Heathrow’s response to noise issues.
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Concern that there is no single overarching
authority with responsibility to ensure that
networks of green infrastructure identified in
development plans are protected from
development and, where possible, strengthened
by or integrated within it.
✓ ✓ Heathrow seeks to minimise adverse impacts on green infrastructure as a
result of the Project. However, as a NSIP the Project will result in adverse
effects on green infrastructure. We will report on the impacts of the Project
on the natural environment and open space in the PEIR as part of our
Airport Expansion Consultation in June 2019. The Project represents an
opportunity to provide green infrastructure for the benefit of biodiversity, the
landscape, water environment and people. This will include biodiversity
offsetting areas and the re-provision of public open space to compensate for
the loss of these areas as a result of the Project. We continue to engage
with the HSPG and a range of environmental stakeholders on a strategy for
green infrastructure.
Effects of the Project are vague and provide little
assurance to those potentially harmed. The
effects of expansion should be placed on a legal
footing with penalties applied to Heathrow’s
shareholders for any breach.
✓ Heathrow will publish the PEIR as part of the Airport Expansion
Consultation in June 2019. This will present details on adverse and
beneficial effects of the Project and proposals for mitigation and monitoring.
More detailed information will be provided as part of the ES to be submitted
with the DCO application.
Passenger demand will grow faster than initially
expected. As a result, without additional
sustainable surface access, the airport will be
unsuccessful, will not meet sustainability
requirements nor meet the demands of future air
travel growth.
✓ At the Airport Expansion Consultation in June 2019 Heathrow will present its
draft Surface Access Strategy that will explain Heathrow’s plan for meeting
the surface access requirements of the ANPS. Technical information will be
presented in a Preliminary Transport Information Report that will set out
assumptions used regarding passenger growth, as part of the June 2019
consultation. The Surface Access Chapter of this Report provides further
detail on Heathrow’s response to surface access related feedback.
The Surrey Biodiversity Opportunity Area
(Staines Moor and Shortwood Common) are the
basis for achieving Surrey’s local ecological
network and therefore are relevant to the Project.
✓ Heathrow is assessing impacts on environmental resources as part of the
EIA and early findings will be reported in the PEIR in June 2019. This will
include consideration of the sites of special scientific interest (SSSI) at
Staines Moor and Shortwood Common.
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OVERVIEW OF ONGOING ENGAGEMENT AND NEXT STEPS
Introduction
29.1.1 Throughout 2018, Heathrow has maintained a regular programme of engagement
with its stakeholders. This engagement has been designed to keep community
groups, stakeholder forums, prescribed (statutory) consultees and local authorities
informed of progress on the Project as well as providing a forum for them to find
out more, test the emerging proposals and contribute to the ongoing technical
assessment work.
Overview of ongoing engagement
Prescribed Consultees
Local authorities and statutory consultees
29.2.1 As part of the development of the proposals and the environmental assessment
process, Heathrow has set up a number of topic-based stakeholder groups. These
groups are made up local planning authorities, statutory and other bodies and
meet on a regular basis to discuss and obtain feedback on our emerging
proposals, gather information about different elements of the Project and develop
potential mitigation proposals.
29.2.2 The list of topic-based stakeholder groups includes:
1. Air Quality
2. Biodiversity
3. Carbon
4. Climate
5. Community
6. Energy
7. Historic Environment
8. Natural Capital
9. Land Quality
10. Lighting
11. Landscape and Visual Impact Assessment
12. Major Accidents and Disasters
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13. Noise
14. Socio-economics
15. Waste
16. Water Environment
29.2.3 In addition to the above, Heathrow has also held meetings, provided information
and sought feedback from local authorities in relation to:
1. The proposed event venues to be used for the Airspace and Future Operations
Consultation in January 2019 (October 2018)
2. The content and approach to the Airspace and Future Operations Consultation
(November – December 2018)
3. The emerging draft of the Statement of Community Consultation for Airport
Expansion Consultation planned for June 2019 (November 2018)
Heathrow Strategic Planning Group (HSPG)
29.2.4 The HSPG is made up of local authorities for areas that will be or are potentially
going to be affected by the Project, Local Enterprise Partnerships (LEPs) and
other organisations in the vicinity of Heathrow. Heathrow engages with this Group
on a very regular basis and the focus of the Group’s work is principally
masterplaning, wider future land-use planning, transportation, regeneration,
economic development and environmental matters including mitigation.
29.2.5 The Group is an important conduit in providing ongoing feedback about the plans
from the communities and businesses affected by the emerging proposals, and
from elected members and officials in the member authorities and organisations.
29.2.6 We also engage bilaterally with individual local authorities on a range of issues
including masterplanning, mitigation options, and our approach to consultation.
Local Communities
Heathrow Community Engagement Board (HCEB)
29.2.7 The Heathrow Community Engagement Board (HCEB) was established in January
2018 and is a key focal point for engagement with local communities in the vicinity
of the airport. The independent board provides constructive challenge and scrutiny
to Heathrow with the aim of improving Heathrow’s consultation and engagement
and ensuring that communities are meaningfully engaged with and are able to
contribute effectively to consultations and evidence gathering in respect of the
Project. It also plays a key role in ensuring communities are consulted on matters
concerning the management or administration of the airport today which affects
their interests.
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29.2.8 Heathrow and the HCEB meet formally on a fortnightly basis at a Joint Working
Group. These sessions include presentations and the sharing of information on a
range of issues and topics including:
1. operational procedures;
2. scheme development;
3. surface access strategy;
4. managing community and environmental impacts;
5. expansion construction management and mitigation;
6. sustainable growth of the airport;
7. future airspace change;
8. noise management;
9. approaches to public consultation; and
10. community engagement.
29.2.9 The HCEB makes formal recommendations to Heathrow which Heathrow are
obliged to have regard to. The HCEB also provides advice to Heathrow for
example with regards to engagement materials or approaches to consultation.
Members of the public
Listening events
29.2.10 A programme of events was held between March and May 2018 to give local
communities the opportunity to share their views about what elements of their
community are important to them, what they value and what could be improved.
Table 29.1 details the time, date and locations of these events.
Table 29.1 Listening Events
Date Time Location
20 March 2018 6.30pm – 8.30pm Stanwell Moor – Stanwell Moor Village
Hall
28 March 2018 6.30pm – 8.30pm Colnbrook and Poyle – Hilton Heathrow
T5, Colnbrook
16 April 2018 6.30pm – 8.30pm Harmondsworth – St Marys Church Hall
17 April 2018 6.30pm – 8.30pm Iver and Richings Park – Iver Village Hall
18 April 2018 6.30pm – 8.30pm Cranford and Cranford Cross – Cranford
Baptist Church
19 April 2018 6.30pm – 8.30pm Stanwell – Stanwell Rose Community
Centre
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Date Time Location
23 April 2018 6.30pm – 8.30pm Heston – Heston Hyde Hotel
25 April 2018 6.30pm – 8.30pm Hatton – Hilton Garden Inn, Hatton Cross
26 April 2018 6.30pm – 8.30pm Sipson – Sipson Community Hall
30 April 2018 6.30pm – 8.30pm Bedfont and Feltham – St Giles Hotel,
Feltham
1 May 2018 6.30pm – 8.30pm Longford – Thistle Hotel, Longford
2 May 2018 6.30pm – 8.30pm Brands Hill – Heathrow Windsor Marriott,
Langley
3 May 2018 6.30pm – 8.30pm Harlington – Harlington Baptist Church
Hall
Information sessions
29.2.11 A programme of events was held throughout July 2018 for communities affected
by Heathrow’s expansion proposals (see Table 29.2). The events provided an
opportunity for communities to view information such as exhibition boards,
information flyers and short presentations and speak directly to members of the
Heathrow Expansion project team and the HCEB. Each of the events focussed on
the following topics:
1. An overview of the proposed timescales for submitting a DCO application and
starting construction
2. An update on the property compensation schemes available to residents in the
Compulsory Purchase Zone (CPZ) and Wider Property Offer Zone (WPOZ)
3. Bat surveys and their impacts on land and property owners
4. The role of Heathrow’s community engagement team
5. The role of the HCEB
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447 © Heathrow Airport Limited 2019 Heathrow Expansion Consultation One - Interim Consultation Feedback Report - Volume 3
Table 29.2 – Information sessions
Date Time Location
4 July 2018 5pm – 9pm Stanwell Moor Village Hall
5 July 2018 11am – 5pm St Mary’s Church, Harmondsworth
9 July 2018 3pm – 7pm Colnbrook Village Hall
10 July 2018 8am – 12pm Double Tree Hotel, Hounslow
10 July 2018 3pm – 7pm Thistle Hotel, West Drayton
11 July 2018 12pm – 4pm St Mary’s Church, Harmondsworth
12 July 2018 12pm – 4pm Sipson Community Centre
17 July 2018 4.30pm – 8.30pm Iver Village Hall
21 July 2018 9am – 12pm Heathrow Academy
Community Workshops
29.2.12 A programme of community workshops was held throughout November and
December 2018 for local communities potentially affected by Heathrow’s
expansion proposals (see Table 29.3). The workshops provided an opportunity for
communities to provide feedback on specific elements of the emerging masterplan
design, including ways to improve connections, proposed land uses and ways of
improving communities. They were designed to be interactive and attendees were
encouraged to sketch their ideas with architects, draw onto maps of the local area
and either submit feedback postcards or submit feedback through an online portal,
which was kept open for ten days after each event.
Table 29.3 Community workshops
Date Time Location
6 November 2018 5.30pm – 8.30pm Stanwell Moor Village Hall
19 November 2018 3pm – 7pm St Mary’s Church, Harmondsworth
21 November 2018 3pm – 7pm Colnbrook Village Hall
26 November 2018 3.30pm – 8pm Stanwell Rose, Stanwell
28 November 2018 3pm – 7pm St Peter and St Paul’s Church, Harlington
Wider Consultees
MPs
29.2.13 Throughout 2018, both before and after the parliamentary vote on the ANPS in
June, Heathrow maintained a regular programme of engagement with local MPs to
inform them of the expansion process, anticipated timelines and how and when
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Heathrow would be engaging with their constituents. This included regular
meetings and updates. Heathrow also held meetings and provided information to
local MPs in relation to:
1. The proposed event venues to be used for the Airspace and Future Operations
Consultation in January 2019 and the desire for pop up events in their
constituency (October 2018)
2. Land Referencing letters that their constituents would receive and the
emerging draft of the Statement of Community Consultation that had been
shared with local authorities (November 2018)
3. The content and approach to the Airspace and Future Operations Consultation
(November – December 2018)
Next steps
29.3.1 The information set out in this report will be considered alongside the findings of
our ongoing evaluations and the feedback received from our ongoing process of
engagement to develop our preferred masterplan and proposed DCO application.
This will form the basis for our statutory consultation under sections 42 to 48 of the
Planning Act 2008 proposed to take place in June 2019 (the Airport Expansion
Consultation).
29.3.2 The Airport Expansion Consultation will be accompanied by a Consultation
Feedback Report (CFR). The CFR will set out Heathrow’s response and the
regard had to the feedback received at the Airspace and Future Operations
Consultation relevant to the proposals being put forward in the consultation. It will
also explain Heathrow’s response to matters raised at Airport Expansion
Consultation One which have not been the subject of the Airspace and Future
Operations Consultation.
29.3.3 Prior to the Airport Expansion Consultation, Heathrow will consult Local Planning
Authorities in Spring 2019 on a draft Statement of Community Consultation
(SoCC) which explains how it will undertake Community Consultation as part of its
wider statutory consultation for the Project.
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