heathrow expansion consultation one - interim consultation ...€¦ · heathrow expansion...

HEATHROW EXPANSION CONSULTATION ONE -

INTERIM FEEDBACK REPORT

VOLUME 2 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 2

CONTENTS

14. DISPLACED LAND USES 4

14.1 Introduction 4

14.2 Prescribed Consultees 5 Local Authorities 5 Statutory Consultees 9 Other prescribed bodies 9

14.3 Local Communities 11 Members of the public 11 Businesses 14 Community groups 17

14.4 Wider/other Consultees 19

14.5 Issues Raised and Heathrow’s Responses 22

15. AIRPORT RELATED DEVELOPMENT 50

15.1 Introduction 50

15.2 Prescribed Consultees 51 Local Authorities 51 Statutory Consultees 55 Other Prescribed 57

15.3 Local Communities 58 Members of the public 58 Businesses 61 Community Groups 66



16. CONSTRUCTION 105


16.2 Prescribed Consultees 106 Local Authorities 106 Statutory Consultees 111




17. MASTERPLANNING 160








18. PROPERTY POLICIES 200


18.2 Prescribed Consultees 201 Local Authorities 201 Statutory consultees 202 Other Prescribed bodies 202

18.3 Local Communities 203 Members of the public 203 Businesses 205 Community Groups 208

18.4 Wider/other consultees 210


19. NOISE 235



19.3 Members of the Community 245 Members of the public 245 Businesses 249 Community Groups 253





14. DISPLACED LAND USES

14.1 Introduction

14.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in

respect of the land uses likely to be affected by the Heathrow Expansion Project

(the Project) and on the potential sites identified for the relocation of the

Immigration Removal Centres. A total of 777 consultees made comments relating

to the specific parcels of land affected by the Project and 659 consultees made

comments relating to the relocation of the Immigration Removal Centres.

14.1.2 Heathrow provided the following material that is directly related to land affected by

the Project and the potential sites identified for the relocation of the Immigration

Removal Centres:

1. Airport Expansion Consultation Document;

2. Our Emerging Plans; and

3. Scheme Development Report.

14.1.3 Within Section 12 of the Our Emerging Plans Document, Heathrow identified a

number of potential sites for land uses and the relocation of the Immigration

Removal Centres. References to Option Numbers below are taken from the Our

Emerging Plans Document.

14.1.4 Heathrow asked the following questions regarding land use and the potential sites

identified for the relocation of the Immigration Removal Centres:

1. Do you have any comments on the land uses that will be affected by

Heathrow’s expansion?

2. Please tell us what you think about the sites identified for the relocation of the

Immigration Removal Centres, and if you have a preference please tell us why.

14.1.5 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.

14.2 Prescribed Consultees

Local Authorities

General comments

14.2.1 Ealing Council said that displaced uses 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.

14.2.2 The London Borough of Brent supported the use of locations outside the

immediate vicinity of the airport for displaced uses that do not need to be close to

it. They said that sites should be chosen that are well served by bus and rail

connections and do not require car travel by staff. They also said that the

improvement of public transport access to the airport from surrounding areas and

growth areas in west London was vital to accommodate these displaced uses.

14.2.3 The London Borough of Hounslow sought further clarification on the number and

extent of land uses that need to be removed/re-located. They expressed support

for the principle of areas needing to be landscaped, planted, restored or enhanced

in order to reduce the potential effects of the Project.

14.2.4 Kent County Council commented that the Project will lead to the relocation of a

variety of land uses and that the operation of these in their new location should be

improved as part of the legacy of the Project.

14.2.5 South Bucks District Council commented on the loss of Green Belt, highlighting

the significant loss of strategic Green Belt that separates Slough from London.

They considered the loss of Green Belt should be offset through improvements to

the environmental quality and accessibility of remaining Green Belt land and

indicated that some within the District would benefit from improvements in terms of

environmental quality and increased accessibility.

14.2.6 Spelthorne Borough Council highlighted that much of the northern part of the

Borough is within the Green Belt and that all the sites assessed in Heathrow’s land

use strategy fall within this designation. They expressed disappointment that the

individual site schedules do not reference the Council’s Green Belt Assessment

and instead rely on Heathrow’s own assessments. They said that further detail

should be provided on the methodology used to assess these sites against the five

purposes of Green Belt.



14.2.7 They also highlighted that a case for very special circumstances will be needed to

demonstrate that the significant harm to the Green Belt will be clearly outweighed

by the benefits of the Project. They suggested that this should consider not only

the harm to individual sites within the Green Belt but also the effect on the wider,

‘strategic arc’ of important green spaces.

14.2.8 The Council also considered that if parts of the Green Belt are to be lost to airport

related development, all new buildings should be of the highest quality design with

landscaping integral to the development.

14.2.9 The London Borough of Sutton commented that the closure of hotels and other

facilities would have a significant short to medium term impact on employment

both locally and within the wider employment catchment area. They requested

further detail on how this would be managed.

Immigration Removal Centres

14.2.10 The London Borough of Hounslow objected to the site at Bedfont (Site E1 in

Heathrow’s Our Emerging Plans Document) being shortlisted for the immigration

removal centres (IRC) relocation. They said the site provides an opportunity to

create a high-density mixed-use employment led development located around a

new Southern Access railway. They queried whether consideration had been

given to co-locating the Feltham Young Offenders facility, the IRC and Immigration

Tribunal Centre.

14.2.11 Spelthorne Borough Council made the following comments on the potential

sites identified in Heathrow’s Our Emerging Plans Document for the relocation

of the IRC:

1. Site F1 – the relocation of the IRC is an unacceptable use of this site as it

would be incompatible with the proposed high-quality offices and hotels (and

one of the three proposed locations for a new or expanded terminal).

2. Site A4 – is a significantly larger site than Site F1 and the IRC could be

accommodated further away from existing residents. This site is also separated

from West Drayton by the M4, which would act as a barrier. The London

Borough of Hillingdon currently houses the two immigration centres associated

with the airport and has the infrastructure in place to deal with these sites.

3. Site E3 – is in close proximity to Spelthorne’s borough boundary, Ashford and

Staines-upon-Thames. If this site was selected, further information would be

required on the process for those who leave the centre and whether there

would be housing and homelessness obligations for nearby authorities.



Lakeside Waste Management Facilities

14.2.12 Bracknell Forest Council queried the proposals for the relocation of Lakeside

Waste Management Facilities (Lakeside). They said that firm proposals need to

be made prior to the start of any works and that there must be engagement with

the appropriate authorities.

14.2.13 Kent County Council said Lakeside should be improved on the relocated site by

improving energy efficiency or increasing capacity.

14.2.14 Hampshire Services, who responded on behalf of the Central and Eastern

Berkshire Authorities, highlighted that the loss of Lakeside would be detrimental

for a number of waste planning authorities. They considered that further studies

are needed to identify suitable relocation sites and that a commitment should be

made to ensuring that the replacement facility becomes operational before the

existing facility is closed.

14.2.15 The London Borough of Hounslow said their borough was not a suitable location

for the relocation of the Lakeside facility.

14.2.16 Slough Borough Council shared concern that no provision had been made for the

replacement of the Lakeside and considered that the simplest solution would be to

relocate on a like for like basis north of the third runway next to the M4.

14.2.17 Surrey County Council said that Lakeside should be replaced so that there is

continuity to the provision of waste treatment capacity in the area.

Waterside Offices (British Airways Headquarters)

14.2.18 The London Borough of Hounslow commented that it would welcome discussions

with British Airways to re-locate their offices within the Borough. They highlighted

the Heathrow Gateway site or alternative sites along the Great West Road in

Brentford as possible options.

14.2.19 Slough Borough Council said that the new British Airways Headquarters could be

built in Slough town centre.

BT Data Centre and Maintenance Depot

14.2.20 No comments were received from local authorities on the BT Data Centre and

Maintenance Depot.

Total Fuel Depot Site

14.2.21 Kent County Council highlighted the importance of the relocated fuel depot being

connected to the railway network.



14.2.22 Slough Borough Council commented that Heathrow should give priority to the

provision of a multipurpose rail depot south of the M4. As a result, they

considered that the site north east of the M4/M25 interchange should be used for

the Total Fuel Depot.

Overhead Power Lines and Substation

14.2.23 The London Borough of Hounslow requested further information and clarification

on the relocation of the overhead lines and substation.

Other Land Uses

14.2.24 Bracknell Forest Borough Council said the additional demand for housing (and

health and school provision) as a result of the Project need to be assessed. They

highlighted that due to the environmental constraints in Bracknell Forest combined

with the challenge of meeting current targets for development, the Council should

not be required to accommodate additional housing, outside current requirements.

14.2.25 The London Borough of Brent highlighted their opportunity area and two housing

zones that are currently being built which would provide 15,000 homes, 11,000

new jobs and 30,000 square metres of commercial/office space. They also

highlighted that the Alperton Housing Zone is situated next to the Piccadilly Line

and therefore has good access to the airport.

14.2.26 Harrow Council commented that the loss of the housing needs to be addressed

with new residential development. This view was shared by Surrey Heath

Borough Council who said that if the loss of housing is addressed as a wider

strategic issue it should not impact housing requirements beyond the Heathrow

and Slough Travel to Work Area1.

14.2.27 The Royal Borough of Windsor and Maidenhead expressed similar concerns about

the lack of detail on the quantity and spatial distribution of additional housing that

will be required. They said that without this detail it is not possible to liaise with

adjoining local authorities to determine whether the area around the airport can

accommodate the potential additional housing demand.

1 A statistical tool used to indicate where the population would generally commute to for the purposes of employment.



Statutory Consultees

General Comments

14.2.28 The Environment Agency said that flood risk will affect which land uses will be

appropriate and that Table 3 of the National Planning Policy Guidance for Flood

Risk and Coastal Change should be used.

14.2.29 Historic England commented that there should be greater consistency in how

heritage assets are identified and considered for future land uses. They also

highlighted the importance of understanding the significance of these assets, how

they may be affected and ensuring integration with the Local Plans of the adjacent

local authorities to ensure a plan-led approach to the various elements of new

development.

14.2.30 Natural England said that consideration should be given to soils that are going to

be disturbed/harmed and whether ‘best and most versatile’ agricultural land is

used. They said that details of how adverse impacts on best and most versatile

agricultural land and soil resources have been be minimised should be provided

and that a mechanism to address compensation for loss should be developed.

14.2.31 Highways England commented that demand for additional airport related

development such as hotels and offices needs to be taken forward in consultation

with local planning authorities as they develop their Local Plans. The impact of

these developments should be considered in the multi modal traffic model to

ensure appropriate mitigation on the strategic road network (SRN) and local road

network is developed.


14.2.32 Highways England did not express a preference for any of the sites identified for

the relocation of the IRC but said that security measures would need to be

incorporated into any designs for locations immediately adjacent to the SRN.

Other prescribed bodies

General comments

14.2.33 The Heathrow Strategic Planning Group (HSPG) said that the Joint Evidence Base

and Infrastructure Study (JEBIS) and the Joint Strategic Planning Framework

(JSPF) will identify options to meet demand for land uses on a plan-led basis.

They indicated that hotels and guest house accommodation, freight forwarding,

cargo and logistics, industrial uses, recreational land, offices local retail services

and housing would be affected by development and market pressures. They also

highlighted the importance of addressing impacts on the Green Belt.



14.2.34 Bray Parish Council said the repositioning of recently constructed infrastructure

should be avoided as it is uneconomic.

Immigration Removal Centre

14.2.35 Bray Parish Council requested further consultation on the relocation of the IRC

when further work on this has been completed.

Total Fuel depot

14.2.36 Network Rail said the severance of the Colnbrook Branch line will affect a number

of commercial facilities including the Northern Fuel Receipt site. They said that the

relocation of this facility will require careful planning with Network Rail.

Other Land Uses

14.2.37 Thames Water Utilities Limited commented that the Compulsory Purchase and

Wider Property Offer Zone (WPOZ) map includes the Iver South Sludge Treatment

Centre. They highlighted that this is an integral asset for the treatment of sewage

sludge associated with Mogden Sewage Treatment Works and that further

information is needed to understand the effects on this facility.

14.2.38 Colnbrook with Poyle Parish Council said that sites along its eastern boundary

should be used to re-provide local businesses that would be displaced by the new

north-west runway and M25 diversion (as detailed in the Airport Expansion

Consultation Document). They also said that:

1. the site at the north end of Lakeside Road should not include all the green

open land north of the A4 Colnbrook Bypass;

2. the area north of Gallymead Road should be used in a way that does not

interfere with residential property and the nearby school;

3. there is some development potential along the eastern side of

Gallymead Road;

4. the area south of Poyle New Cottages could be used for the expansion of the

Poyle Industrial Estate;

5. development between the Third Runway and Pippins Park is needed for a

protective green envelope separating Colnbrook from the Airport;

6. the area south of Horton Road may have development potential for multiple

uses; and

7. proposals for land south of Popes Close would interrupt its restoration after

mineral extraction.



14.3 Local Communities

Members of the public

General Comments

14.3.1 Almost two thirds of members of the public that made comments in relation to land

use expressed opposition to the Project or had concerns about the impacts of the

Project on existing land uses.

14.3.2 Concerns were wide ranging and comprised impacts on the Green Belt and green

open spaces, agricultural land, wildlife and habitats, watercourses, recreational

areas and the environment in general. Concerns were also raised about the loss

of residential properties and residential communities (in Harmondsworth,

Longford, Sipson and Stanwell), the impact on the local economy and impacts

on existing land uses and businesses that would need to be relocated as a result

of the proposals.

14.3.3 Members of the public who made these criticisms also made comments or

suggestions. These comprised:

1. effects should be minimised;

2. as much airport land should be used as possible to avoid land take and

local impacts;

3. greenfield land must be avoided;

4. brownfield locations should be preferred; and

5. unused land should be prioritised to reduce the need for to compulsorily

purchase of residential or business properties.

14.3.4 It was also suggested that High Wycombe should be used as it has plenty of

space and the town would benefit from the employment opportunities.

14.3.5 Positive comments received recognising the importance of the Project and the

necessity to affect and relocate some land uses to accommodate it. Members of

the public said that more land should be acquired than currently needed to allow

for future needs and that the Project provides an opportunity to improve the area

through better design or by acting as a catalyst for regeneration in the area.


14.3.6 Members of the public expressed concerns or criticised the proposals for the

relocation of the IRC due to the proximity of the sites to local people or the impacts

of the IRC relocation on residential properties, quality of life, green space, traffic,

noise and pollution.



14.3.7 Of those members of the public that expressed a preference for any of the

potential sites some considered the northern sites (Sites A4 and B1 as detailed in

Heathrow’s Our Emerging Plans Document) to be preferable due to their existing

developed character and accessibility. Others felt that the southern site (Site E1 as

detailed in Heathrow’s Our Emerging Plans Document) would be best as it is not

next to residential areas, will have good connectivity to the new central area

access tunnel and will distribute service support around the airport in all directions

to minimise traffic.

14.3.8 Members of the public identified other factors they considered should be important

in locating the IRC, these comprised:

1. Minimising noise and air quality impacts;

2. Maximising distance to residential properties;

3. Avoiding loss of residential properties and communities;

4. Minimising effects on local communities;

5. Avoiding loss of green spaces;

6. Avoiding impacts and blight on Stanwell Moor;

7. Ensuring the welfare of immigrants/detainees;

8. Minimising environmental impact;

9. Minimising impacts on emissions/climate change;

10. Good access road links to the UK/rest of the airport;

11. Cost and security; and

12. Operational efficiency.

14.3.9 Suggestions were also received from members of the public on alternative

locations for the IRC. These comprised that it should be extended below ground,

located next to HMP Ashford, at Gatwick, at Stanstead, at Bedfont Lakes, on a

Scottish Island, in Hull, in Chelsea or as an Annex to T5. It was also suggested

that Heathrow should buy all properties in Colnbrook and Sipson and use this land

for IRC.


14.3.10 Members of the public expressed concern about the loss of Lakeside and

considered that further studies should be undertaken to identify suitable relocation

sites in the local area. Concern was also expressed about the impacts of the

relocation on local people and communities, on vehicle emissions and on waste

management.



14.3.11 Members of the public also criticised the loss of Lakeside so soon after it was

constructed considering this to be uneconomic and a waste of money.

Suggestions were also received that Lakeside should be relocated on a like for like

basis north of the third runway next to the M4 or near Colnbrook to provide

benefits for local employment.

Waterside Offices (British Airways Headquarters)

14.3.12 A small number of comments were received about the British Airways Waterside

Offices. Many of these queried why the offices needed to be relocated and

suggested that they should stay within the airport boundary. Others highlighted the

risk of old landfill at the site or suggested that the offices should be relocated east

of the airport where there is better rail/underground infrastructure.

BT Data Centre and Maintenance Depot

14.3.13 Members of the public that commented on the BT data centre and Maintenance

depot either expressed support for the proposals to locate it offsite/away from the

airport or suggested that it could be placed in one of the new developments on the

site of the expanded Heathrow.


14.3.14 Members of the public that commented on the Total Fuel Depot highlighted the

importance of the fuel depot including a new rail terminal and a new junction from

M25, being located close to the railway and being located away from residential

development. Comments were also received which suggested that the existing

fuel depot should be enlarged, that consideration should be given to piping fuel to

locations where it is needed and that providing extra fuel in the locality at the Total

Fuel Depot could lead to a major security issue.


14.3.15 Comments were received from members of the public that the power lines should

be placed underground by Heathrow at their cost. Others commented that the

overhead lines should not be located over or near residential properties due to the

effects of electro-magnetic fields on health and that the proposals were

unnecessary if the proposals for the diversion of the M25 were modified.

14.3.16 Suggestions were also received that the power lines are safer to remain overhead

as any flooding from local rivers may affect an underground cable.



Businesses

General Comments

14.3.17 The Arora Group said that Heathrow’s proposals would require a significant

amount of their land over which rights would have to be acquired. They

considered that Heathrow had not engaged with them over this acquisition and

that options have been narrowed without proper engagement and due

consideration of alternatives.

14.3.18 They highlighted that their own development proposals would achieve a 23%

reduction in land take compared to Heathrow’s scheme and queried how

Heathrow can say its options are preferred when there is an alternative scheme

that uses less land.

14.3.19 They went on to say that Heathrow has not taken any steps to minimise the impact

of its proposals on their land and that it has an obligation to protect their business

and provide alternatives.

14.3.20 The Lanz Group commented that any commercial use including warehousing and

car parking affected by the Project should be relocated on new land adjacent to

the proposed airport. They commented that any loss of the car parking or offices at

the Golf Driving should be properly notified, new sites identified, and business

operations transferred to safeguard employment.

14.3.21 Global Grange Limited commented that due regard should be given to both

adopted and emerging planning policy at a local level and existing planning

permissions to ensure that the Project does not inhibit the delivery of important

development and growth. They also highlighted that if Site E1 is developed any

proposed uses should not be in conflict with the existing consent for the provision

of a 426-guestroom hotel.

14.3.22 Manor Farm/Wiggins Building Supplies Limited expressed concern that a study

had not been carried out to identify preferred locations in or around the airport for

airport related floorspace. As such they considered that extent to which these uses

could be accommodated within the expanded airport boundary was unknown.

14.3.23 Sapcote Developments indicated that it would be happy to explore if its

landholdings can assist and be designated as potentially suitable for airport

related development.

14.3.24 Heathrow Hydrant noted the proposals for the widening of the Southern Perimeter

Road and use of land for car parking, temporary construction sites and/or airport

related developments such as hotels, offices, industrial premises or warehousing.

They highlighted that if this option is taken forward Heathrow must ensure

unencumbered access to and from it depot and all other relevant facilities.



14.3.25 Segro said that the Project will result in several existing buildings and facilities

being displaced, including their site at the Colnbrook Logistics Centre in Slough.

They requested early engagement on this.

14.3.26 The London (Heathrow) Airline Consultative Committee and the Board of Airline

Representatives UK highlighted that the costs of any works or land purchases

must be borne by the scheme promoter until the asset could be used by its

customers. They also highlighted that a scheme promoter’s shareholders should

not be allowed to make early and additional returns because they are regulated.

14.3.27 The Brett Group supported the proposal for use of its land at Hithermoor for a

construction and logistics site. They also requested that further consideration is

given to use the land for future car parking, commercial facilities and a new rail

station as part of the southern rail link.

14.3.28 BMO Real Estate commented that decisions on land use requirements should be

made quickly to prevent losses that may be incurred as a result of uncertainty.

They indicated that if their property is retained in whole or in part, a clear route for

servicing the site must be provided so that the businesses there may continue to

operate. If the property is to be lost then further information should be provided on

how Heathrow proposes to relocate the tenants, particularly those with airport-

related operations.

14.3.29 Speedbird Securities Limited highlighted that whilst its land could be suitable for

airport-related development, they should not be limited to such uses. They

considered that their land could assist in addressing the identified shortfall in

industrial land and suggested that this needs to be recognised in the future

planning of the area and the development of the masterplan.

14.3.30 Heathrow Hub said the consultation only lists a large number of sites as potential

locations for the relocation of residential, commercial and public property required

for the Project. They expressed concern that the timescales, cost and risk involved

in securing the sites as well as obtaining all necessary consents, including release

of Green Belt land and constructing replacement property and infrastructure had

not been considered.


14.3.31 Global Grange commented that given its location and relationship with the airport,

Site E1 (as detailed in Heathrow’s Our Emerging Plans Document) is not an

appropriate location for the IRC. They said the site is not well located in relation to

the motorway network or the main entrance to the airport and that it is better

placed to provide alternative facilities which would be well related to Hounslow

Council’s wider development aspirations.



14.3.32 They said that no reference has been made to these aspirations or to where the

proposed new housing and employment sites would be relocated. They

considered that these conflicts and considerations should be recognised and

addressed in detail within future consultations.

14.3.33 The Airport Industrial Property Unit Trust (AIPUT) commented that the two sites

identified as suitable for the relocation of the IRC to the south of the airport are not

appropriate. They said that if sites are to be released from the Green Belt to the

south of the airport then the priority for their use should be for airport supporting

facilities and airport related development.

14.3.34 Lapithus Hotels Management UK Limited said that any development to the west of

Holiday Inn M4/J4 must be sympathetic to the hotel and its customers. They

requested further consultation on detailed development proposals and indicated

that any intensification of traffic movements around the Holiday Inn M4/J4 resulting

from the Project should be accompanied by road improvements.

14.3.35 Suez UK considered that land at Holloway Lane is not an appropriate location for

the IRC but does provide a suitable site for a ‘prestigious gateway development’ to

the expanded airport.


14.3.36 Grundon Waste Management commented that a large number of sites had been

identified for airport supporting facilities which exceed the requirements for these

uses and as such some of this could be provided to accommodate displaced uses.

14.3.37 They said that Lakeside needs to be replaced and that the only solution for

Heathrow is to provide land for this. They requested a commitment from Heathrow

to provide land and fund replacement and suggested that future consultations

need to include the Lakeside facility.

14.3.38 Heathrow Hub expressed concern that little or no progress has been made in

agreeing a suitable site and relocating Lakeside.

Other Land Uses

14.3.39 DHL Group highlighted that it needs sufficient lead-in time to relocate its facilities.

They said that there is limited large warehouse space in close proximity to the

airport that would be suitable for the relocation and it was unclear if sites identified

for replacement facilities are already in the ownership of Heathrow or will need to

be bought. They also expressed concerns about traffic in the vicinity of their

Horton Road property during and after construction of the runway and requested

further detailed traffic study information.



14.3.40 Esso Petroleum Company Limited (Esso) highlighted the importance of the West

London Terminal site as part of the proposed Southampton to London pipeline

Project and as a key strategic asset in the UK for jet and ground fuels to London

and the wider South East. They objected to the redevelopment of the site as a

dedicated storage facility for aviation fuel and considered that the impact of its loss

on the supply of road and industrial fuels to millions of customers in the South East

had not be taken into account.

14.3.41 The Heathrow Airport Fuel Company supported the provision of additional fuel

storage in order to provide sufficient resilience to meet current and future fuel

demand. They considered the best location for this would be to expand the Perry

Oaks site, but also considered that it would be prudent to retain options to build

additional fuel storage on Grass Area 17A and/or at a northern apron site.

14.3.42 They also expressed concern at the potential relocation of the Perry Oaks fuel

storage facility and indicated that if this was required Heathrow should find a

suitable alternative location, fund the cost of re-provision of comparable facilities

and secure all necessary planning permissions, utilities, road access, fire, water,

COMAH requirements, security protection, service corridors, connections with the

T5 and CTA fuel hydrants.

14.3.43 Cappagh Companies said that its aggregate recycling site should be retained for

at least the period of construction to support the sustainable construction of the

expanded Heathrow. They also highlighted that the ongoing success of

Flowevervision’s business should be secured by ensuring any highway

improvement works necessary to J14 of the M25, Stanwell Moor Junction and the

road between (A3113 Airport Way) are positioned on the agricultural land to the

North of A3113 Airport Way.

Community groups

14.3.44 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 land use or the relocation of the IRC.

General Comments

14.3.45 Stanwell’s Green Lungs expressed opposition to the use of more Greenfield and

brownfield land, in particular at Stanwell, Stanwell Moor and West Bedfont.

14.3.46 Residents Association HVG CA also expressed concern about the further loss of

open green wildlife friendly space and highlighted the importance of this in

redressing the overdevelopment of London and the quality of life for all people

near the airport.



14.3.47 The Camberley Society highlighted the importance of meeting environmental

requirements. Spring Grove Residents Association expressed concern about the

loss of Green Belt.

14.3.48 Eastcote Conservation Panel sought clarity on where the new airport workers and

their families would live and go to school and the services they would use. They

queried whether these facilities would be provided by Heathrow.


14.3.49 Harrow U3A Sustainability Group and Residents Association HVG CA made

general comments about the IRC.

14.3.50 The Pavilion Association Stanwell and Stanwell Moor, Stanwell’s Green Lungs and

Local Conversation in Stanwell all objected or expressed concern about the

relocation of the IRC at or near to Stanwell Moor.


14.3.51 Harrow U3A Sustainability Group considered that energy for waste incineration is

an inefficient use of resources. They highlighted that Lakeside should be replaced

with a recycling facility.

14.3.52 The Colnbrook Community Partnership considered that the Lakeside facilities

need to be suitably relocated where they would not increase HGV traffic within

Brands Hill, Colnbrook and Poyle.

14.3.53 Northumberland Walk Residents Association expressed opposition to the

relocation of Lakeside closer to Richings Park due to increased noise, traffic,

HGVs and air emissions.

Total Fuel Depot

14.3.54 The Colnbrook Community Partnership commented that they had no objection to

the relocation of the Total Fuel Deport at Site is H6 (as detailed in Heathrow’s Our

Emerging Plans Document) to the west of the M25, south of the M4 and east of

the railway line.


14.3.55 Colnbrook Community Partnership expressed opposition to the direct buried option

as the 50m wide working strip would destroy the semi-improved grassland in

Crown Meadow and could affect Colnbrook Recreation Ground. They said that if

Heathrow and National Grid restore Crown Meadow and the recreation ground

and provide net gains in biodiversity then this option would be supported.



14.3.56 They commented that no information was available on the corridor required for the

SSE cables and indicated that the route must avoid impacts on Pippins Park, be

restored along its length and provide net gains in biodiversity in the area north of

the existing Colnbrook Bypass.

14.3.57 They also commented that they have no objection to either option for the new

substation but queried if there would be sufficient land for Option 3 if Option 2a for

the A3044 realignment were pursued and the A4 routed to the north of the runway

(as detailed in Heathrow’s Airport Expansion Consultation Document).

Other Land Uses

14.3.58 Colnbrook Community Partnership suggested that the use of land north of the

Colnbrook Bypass for engineered reedbeds and contaminated flow lagoons could

be incorporated into an area of green and blue infrastructure providing a wildlife

corridor and an attractive route for the Colne Valley Way. They also highlighted

that based on the information currently available, they are not opposed to the use

of the other areas identified, subject to the existing and proposed rights of way

being protected and enhanced.

14.4 Wider/other Consultees

General Comments

14.4.1 The Colne Valley Regional Park highlighted the significant effects of the Project on

land within the Colne Valley Regional Park and the loss of significant parts of

Harmondsworth Moor Country Park. They said that no clear examples had been

provided which address the loss of the key functions of the Colne Valley Regional

Park including the impact on recreational use, agriculture and the rural economy.

14.4.2 They stated that focussing only on the direct effects of the acquisition of

agricultural land lying within the Compulsory Purchase Zone is insufficient and

unsatisfactory and suggested that adequate compensation be provided for

agricultural tenants and farm businesses remaining in and around the Park.

14.4.3 Friends of the River Crane supported the emphasis on efficient land use and

proposed the rationalisation of warehousing facilities, use of shared driveways and

multi-storey car parking to reduce the overall land take and create enlarged and

enhanced areas of natural green space

14.4.4 The National Trust expressed concern that the Project would undermine the

principle of protecting the Green Belt.

14.4.5 The London Wildlife Trust highlighted that the Project will likely cause a significant

impact on existing land uses within the Colne and Crane valleys through

significant losses and changes to land which may affect their future management.



They expressed concerns at the loss of parts of Harmondsworth Moor Country

Park and indicated that no clear examples had been provided that demonstrate

how the loss and stress to the key ecological functions of the surrounding wildlife

habitats and natural environment will be addressed.

14.4.6 The Kingston Environmental Forum commented that housing and green space is

more useful and important to most residents than a huge airport.

14.4.7 The Royal Parks commented that they would need to consider any changes in

land use that affect their land resource prior to any planning stage and that any

encroachment on the river or its freeboard2 would be subject to licence.

14.4.8 Church of England Diocese of London, Oxford and Southwark said that planning

and design work for existing facilities displaced by the Project should seek to

minimise impacts, particularly the loss of open space.


14.4.9 The Colne Valley Regional Park and the London Wildlife Trust both commented

that Site F1 (as detailed in Heathrow’s Our Emerging Plans Document) is within

the Colne Valley Regional Park and Green Belt, has an identified watercourse

running through its centre towards Staines Moor SSSI and currently provides a

green buffer between local communities. They said that no details have been

provided on the effects of stopping the watercourse leading to Staines Moor SSSI

or the removal of the recreational grounds north of Stanwell Moor Village Hall.

They considered that a different site should be used to avoid impacts on Green

Belt, watercourses and recreation.

14.4.10 The Lambeth/Herne Hill Green Party did not offer a view on the location of the IRC

but indicated that they must have humane conditions.


14.4.11 The Colne Valley Regional Park and the London Wildlife Trust said that further

information is needed on the relocation options for Lakeside.


14.4.12 The Colne Valley Regional Park and London Wildlife Trust commented that further

information is needed on the options for the Total Fuel Depot.

2 The height between the river water level and the top of the bank.




14.4.13 The Colne Valley Regional Park indicated that they preferred buried cables to an

increased number of pylons. They said that further information should be provided

in advance of the next consultation to show impacts on existing habitats are

restored to a better state than before construction.



14.5 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 Displaced Land Uses. None of the feedback received in relation to Displaced Land Uses 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 14.1B

Issue Consultee3 Heathrow Response

PC MC WC

Disappointment that the individual site schedules do not reference the Council’s Green Belt Assessment and instead rely on Heathrow’s own assessments.

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated Green Belt. The Airports National Policy Statement (ANPS) is clear that large scale infrastructure projects located in the Green Belt may comprise inappropriate development. In considering the Development Consent Order (DCO) application the Secretary of State will need to assess whether there are very special circumstances to justify inappropriate development. Very special

Further detail should be provided on the methodology used to assess Green Belt sites against the five purposes of Green Belt.

✓

A case for very special circumstances will be needed to demonstrate that the significant harm to the Green Belt will be clearly outweighed by the benefits of the expansion. This should consider not only the harm to individual sites within the Green Belt but also the effect on the wider, ‘strategic arc’ of important green spaces.

✓

If parts of the Green Belt are to be lost to airport related development, all new buildings should be of the highest quality

✓

3 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees




PC MC WC

design with landscaping integral to the development. circumstances will not exist unless the potential harm to the Green Belt, and any other harm, is clearly outweighed by other considerations. Any Green Belt land included in Heathrow's preferred masterplan proposals will need to satisfy the relevant tests, and Heathrow is considering carefully whether very special circumstances exist in relation to each individual site and use. This includes consideration of effects on the wider context of the Green Belt. Heathrow are carefully considering all consultation responses which comment on Green Belt function. This will inform our own assessment which will identify the role and function of any Green Belt sites which might be impacted by expansion. This assessment will ensure that all Green Belt sites are considered on a consistent basis and will form part of the Planning Statement which will accompany the DCO application. The loss of Green Belt land will be addressed in our Green Infrastructure Strategy, which will include consideration of the potential to improve access to and the environmental quality of existing Green Belt. Our Green Infrastructure Strategy will form an integral part of our preferred masterplan which will be presented at Airport Expansion Consultation in June 2019.

The loss of Green Belt should be offset through improvements to the environmental quality and accessibility of remaining Green Belt land. Suggestion that some Green Belt land would benefit from improvements in terms of environmental quality and increased accessibility.

✓

It is important to address impacts on the Green Belt. ✓

Concern expressed about the loss of Green Belt. ✓

Concern that proposals for airport expansion would undermine the principle of protecting the Green Belt.

✓

The improvement of public transport access to the airport from surrounding areas and growth areas in west London was vital to accommodate these displaced uses (i.e. uses which do not need to be located in the immediate vicinity of the airport to operate and function).

✓ 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 options for the transport infrastructure needed to support the project. There is a range of other potential public transport




PC MC WC

improvements which would improve accessibility to growth areas in west London but these fall outside the scope of the Project.

Objected to the site at Bedfont being shortlisted for the IRC relocation. The site provides an opportunity to create a high-density mixed-use employment led development located around a new Southern Access railway. Has consideration been given to co-locating the Feltham Young Offenders facility, the IRC and Immigration Tribunal Centre?

✓ The ANPS is clear that the Immigration Removal Centres (IRC) play a vital role as part of the infrastructure which allows the Government to maintain effective immigration control and secure the UK’s borders (paragraph. 5.128). It states that continuous service provision of the IRCs at Heathrow is necessary and that Heathrow should show, in its DCO application, the means by which they will be provided. Heathrow accepts this requirement and has undertaken a thorough site selection process with the Home Office to identify a relocation site. This process was reported at Airport Expansion Consultation One in Our Emerging Plans (section 12.2) and the Scheme Development Report (section 16.3). The Home Office identified a number of “essential” site selection criteria as part of this process, including that any alternative site must be as close to the boundary of the operational airport as possible. Other site selection criteria included cost, accessibility and avoiding proximity to residential areas. The proposed location for the replacement IRCs will be identified in the preferred masterplan which will be presented at Airport Expansion Consultation in June 2019, and the outcome of the assessment process will be reported in an updated Scheme Development

Site F1 – the relocation of the IRC is an unacceptable use of this site as it would be incompatible with the proposed high-quality offices and hotels (and one of the three proposed locations for a new or expanded terminal).

✓

Site A4 – is a significantly larger site than Site F1 and the IRC could be accommodated further away from existing residents. This site is also separated from West Drayton by the M4, which would act as a barrier. The London Borough of Hillingdon currently houses the two immigration centres associated with the airport and has the infrastructure in place to deal with these sites.

✓

Request for further consultation on the relocation of the IRC when further work on this has been completed.

✓

Site F1 is within the Colne Valley Regional Park and Green Belt, has an identified watercourse running through its centre towards Staines Moor SSSI and currently provides a green buffer between local communities. No details have been provided on the effects of stopping the watercourse leading to Staines Moor SSSI or the

✓




PC MC WC

removal of the recreational grounds north of Stanwell Moor Village Hall. A different site should be used to avoid impacts on Green Belt, watercourses and recreation.

Report. Heathrow’s assessment will consider any land use impacts from the proposed site, including potential loss of open space, if relevant, and how a replacement IRC would function in relation to neighbouring land uses. This will include consideration of any noise or air quality impacts. Home Office policy makes clear that detention must only ever be used sparingly and for the shortest period necessary. There is a presumption of liberty for any individual. These matters are the responsibility of the Home Office, not Heathrow. Consideration has been given to locating the IRC and Immigration Tribunal Centre at the site of the Feltham Young Offenders facility but this was discounted due to distance from the airport.

Concern about the relocation of the IRC given the proximity of the sites to local people or the impacts of the IRC relocation on residential properties, quality of life, green space, traffic, noise and pollution.

✓

The northern sites for IRC are preferable due to their existing developed character and accessibility.

✓

The southern site for IRC would be best as it is not next to residential areas, will have good connectivity to the new central area access tunnel and will distribute service support around the airport in all directions to minimise traffic.

✓

Minimising noise and air quality impacts are important factors in locating the IRC.

✓

Maximising distance to residential properties is an important factor in locating the IRC.

✓

Avoiding loss of residential properties and communities are important factors in locating the IRC.

✓

Minimising effects on local communities is an important factor in locating the IRC.

✓




PC MC WC

Avoiding loss of green spaces is an important factor in locating the IRC.

✓

Avoiding impacts and blight on Stanwell Moor is an important factor in locating the IRC.

✓

Minimising environmental impact is an important factor in locating the IRC.

✓

Minimising impacts on emissions/climate change is an important factor in locating the IRC.

✓

Good access road links to the UK/rest of the airport is an important factor in locating the IRC.

✓

Cost and security is an important factor in locating the IRC. ✓

Operational efficiency is an important factor in locating the IRC. ✓

Alternative locations for the IRC include that that it should be extended below ground, located next to HMP Ashford, at Gatwick, at Stanstead, at Bedfont Lakes, on a Scottish Island, in Hull, in Chelsea or as an Annex to T5.

✓




PC MC WC

Heathrow should buy all properties in Colnbrook and Sipson and use this land for IRC.

✓

Site E1 is not an appropriate location for the IRC. The site is not well located in relation to the motorway network or the main entrance to the airport. It is better placed to provide alternative facilities which would be well related to Hounslow Council’s wider development aspirations.

✓

The two sites identified as suitable for the relocation of the IRC to the south of the airport are not appropriate. If sites are to be released from the Green Belt to the south of the airport then the priority for their use should be for airport supporting facilities and airport related development.

✓

Suez land at Holloway Lane is not an appropriate location for the IRC but does provide a suitable site for a ‘prestigious gateway development’ to the expanded airport.

✓

Concern about the relocation of the IRC at or near to Stanwell Moor. ✓

The IRC must have humane conditions. ✓

Site E3 – is in close proximity to Spelthorne’s borough boundary, Ashford and Staines-upon-Thames. If this site was selected, further information would be required on the process for those who leave the centre and whether there would be housing and homelessness obligations for nearby authorities.

✓




PC MC WC

Further studies are needed to identify suitable relocation sites and that a commitment should be made to ensuring that the replacement facility becomes operational before the existing facility is closed.

✓

Lakeside should be replaced so that there is continuity to the provision of waste treatment capacity in the area.

✓ 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.

Concern that no provision has been made for the replacement of the Lakeside Waste Management Facilities. The simplest solution would be to relocate on a like for like basis north of the third runway next to the M4.

✓

The Borough of Hounslow is not a suitable location for the relocation of the Lakeside facility.

✓

The loss of Lakeside would be detrimental for a number of waste planning authorities.

✓

Energy from waste facility should be improved on the relocated site by improving energy efficiency or increasing capacity.

✓

Firm proposals for the relocation of Lakeside need to be made prior to the start of any works and that there must be engagement with the appropriate authorities.

✓




PC MC WC

Concern about the loss of the Lakeside energy from waste facility and that further studies should be undertaken to identify suitable relocation sites in the local area.

✓

The loss of Lakeside so soon after it was constructed is uneconomic and a waste of money.

✓

Lakeside should be relocated on a like for like basis north of the third runway next to the M4 or near Colnbrook to provide benefits for local employment.

✓

The Lakeside facility needs to be replaced and the only solution for Heathrow is to provide land for this. Heathrow should commit to providing land and fund the replacement of this facility.

✓

Future consultations need to include the Lakeside facility. ✓

Concern that little or no progress has been made in agreeing a suitable site and relocating the Lakeside Facility.

✓

Energy for waste incineration is an inefficient use of resources. The Lakeside incinerator should be replaced with a recycling facility.

✓

The Lakeside facilities need to be suitably relocated where they would not increase HGV traffic within Brands Hill, Colnbrook and Poyle.

✓




PC MC WC

Opposition expressed to the relocation of Lakeside closer to Richings Park due to increased noise, traffic, HGVs and air emissions.

✓

Further information is needed on the relocation options for the Lakeside Waste Management facilities.

✓

The new BA Headquarters could be built in Slough town centre. ✓ Heathrow are currently assessing whether the BA Headquarters meet the tests for Associated Development set out in Government guidance. If it is concluded that the site does not meet the tests required for Associated Development, and therefore cannot be included within our DCO application, then we will support BA to find alternative accommodation outside the DCO application process.

Request for discussions with British Airways about the re-location of their offices. The Heathrow Gateway site or alternative sites along the Great West Road in Brentford as possible options.

✓

Why do the BA Waterside offices need to be relocated? Suggestion that they should stay within the airport boundary.

✓

There is a risk of old landfill at the BA Waterside site ✓

The BA Waterside offices should be relocated east of the airport where there is better rail/underground infrastructure.

✓




PC MC WC

The loss of the housing needs to be addressed with new residential development.

✓ We recognise that the Project will have a range of impacts during construction and operation, and are committed to manage and mitigate these effects wherever practicable, to minimise effects on local communities. We have drafted a number of discretionary compensation policies for eligible homeowners affected by the Project and are seeking to work closely with the most impacted communities to assess, manage and mitigate adverse effects on community facilities. Local planning authorities already have the responsibility to identify and plan for the most suitable locations for additional house building in their areas. The work we are doing with Heathrow Strategic Planning Group (HSPG) to assess the wider growth and infrastructure development which is likely to be generated by expansion, will assist this process. Additional housing demand that might potentially be generated by Heathrow’s expansion will be relatively small in comparison with the overall scale of housing need for which London and adjacent local authorities need to plan (Our Emerging Plans, para. 13.2.10). If there are any likely significant socio-economic impacts arising from the loss of housing these will be assessed in our Environmental Impact Assessment (EIA) and our preliminary findings will be available in the Preliminary Environmental Impact Report (PEIR) at Airport Expansion Consultation in June 2019. Heathrow is working closely with HSPG on these and other growth-related issues.

If the loss of housing is addressed as a wider strategic issue it should not impact housing requirements beyond the Heathrow and Slough Travel to Work Area.

✓

Additional demand for housing (and health and school provision) as a result of expansion need to be assessed.

✓

The Bracknell Forest area should not be required to accommodate additional housing, outside current requirements.

✓

Concern about the lack of detail on the quantity and spatial distribution of additional housing that will be required. Without this detail it is not possible to liaise with adjoining local authorities to determine whether the area around the airport can accommodate the potential additional housing demand.

✓

Clarity is sought on where the new airport workers and their families would live and go to school and the services they would use. Will these facilities be provided by Heathrow?

✓

Sites along its eastern boundary of Colnbrook Parish should be used to re-provide local businesses that would be displaced by the Third

✓ The site-specific comments raised during consultation, including support for specific sites, will




PC MC WC

Runway and M25 widening. be carefully considered alongside the information gathered from our desk studies. The outcomes of this process will be captured in the preferred masterplan and Updated Scheme Development Report which will be available at Airport Expansion Consultation in June 2019.

The area north of Gallymead Road should be used in a way that does not interfere with residential property and the nearby school.

✓

The area south of Poyle New Cottages could be used for the expansion of the Poyle Industrial Estate.

✓

The area south of Horton Road may have development potential for multiple uses.

✓

Support for the proposal to use land at Hithermoor for a construction and logistics site. Further consideration should be given to use the land for future car parking, commercial facilities and a new rail station as part of the southern rail link.

✓

Whilst land north and south of Faggs Road, Hatton is suitable for airport-related development, it should not be limited to such uses.

✓

Land owned by Speedbird Securities Ltd could assist in addressing the identified shortfall in industrial land. This needs to be recognised in the future planning of the area and the development of the Masterplan.

✓

The use of land north of the Colnbrook Bypass for engineered reedbeds and contaminated flow lagoons could be incorporated into an area of green and blue infrastructure providing a wildlife corridor and an attractive route for the Colne Valley Way.

✓

No objection to the use of the other areas identified for other land uses subject to the existing and proposed rights of way being protected and enhanced.

✓

Support for the emphasis on efficient land use and rationalisation of warehousing facilities, use of shared driveways and multi-storey car parking to reduce the overall land take of grey infrastructure and create enlarged and enhanced areas of natural green space.

✓

Support expressed for the proposals to locate the BT Data Centre ✓




PC MC WC

and Maintenance Depot offsite/away from the airport.

A landowner would be happy to explore if its landholdings can assist and be designated as potentially suitable for airport related development.

✓

There is some development potential along the eastern side of Gallymead Road.

✓

The site at the north end of Lakeside Road should not include all the green open land north of the A4 Colnbrook Bypass.

✓ The site was identified as a suitable construction support site at Airport Expansion Consultation One because of its proximity to the rail head and proposed third runway. If this site is taken forward, we will consider the opportunities and need for a green buffer to residential development in Colnbrook. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

Development between the Third Runway and Pippins Park is needed for a protective green envelope separating Colnbrook from the Airport.

✓

In reference to the relocation of the overhead lines and substation, the power lines should be placed underground by Heathrow at their cost.

✓ The SSE Substation is located on the Poyle industrial estate, and close to the M25. The substation is planned to be displaced by the works to the M25. The overhead pylons would be displaced by the third runway. We currently consider that these facilities could be replaced by cable undergrounding and a sealing end compound and are still considering the route options for the underground cabling. We will take into consideration existing land uses and ecological impacts. We will update our position on this in the Updated Scheme Development Report at Airport Expansion Consultation in June 2019.

In reference to the relocation of the overhead lines and substation, it would be safer for the powerlines to remain overhead as any flooding from local rivers may affect an underground cable.

✓

Overhead lines should not be located over or near residential properties due to the effects of electro-magnetic fields on health.

✓

In reference to the relocation of the overhead lines and substation, the proposals were unnecessary if the M25 plans were modified.

✓

In reference to the proposals related to overhead lines and substations, opposition expressed to the direct buried option as the 50m wide working strip would destroy the semi-improved grassland

✓




PC MC WC

in Crown Meadow and could affect Colnbrook Recreation Ground. If Heathrow and National Grid restore Crown Meadow and the recreation ground and provide net gains in biodiversity then this option would be supported.

No information was available on the corridor required for the SSE cables. The route must avoid impacts on Pippins Park, be restored along its length and provide net gains in biodiversity in the area north of the existing Colnbrook Bypass.

✓

No objection to either option for the new substation but queried if there would be sufficient land for Option 3 if Option 2a for the A3044 realignment were pursued and the A4 routed to the north of the runway.

✓

Request for further information and clarification on the relocation of the overhead lines and substation.

✓

Preference for buried cables compared to an increased number of pylons. Further information should be provided in advance of the next consultation to show impacts on existing habitats are restored to a better state than before construction.

✓

The importance of the West London Terminal site as part of the proposed Southampton to London pipeline Project, and as a key strategic asset in the UK for jet and ground fuels to London and the wider South East, should be noted.

✓ The additional fuel storage and distribution facilities necessary for the expansion of the airport will form part of the Project for which we will be seeking development consent. We identified six options for the storage of aviation fuel at Airport Expansion Consultation One, including redevelopment of the West London Terminal site. We have had further engagement with the operators of this facility and have now amended our plans to exclude this site from further consideration. Our plans for fuel storage will be set out in our

Objection to the redevelopment of the West London Terminal site as a dedicated storage facility for aviation fuel.

✓

The impact of the loss of the West London Terminal site on the supply of road and industrial fuels to millions of customers in the South East has not be taken into account.

✓

The provision of additional fuel storage in order to provide sufficient ✓




PC MC WC

resilience to meet current and future fuel demand is supported. preferred masterplan which will be presented at Airport Expansion Consultation in June 2019.

The best location for an additional fuel storage facility would be to expand the Perry Oaks site.

✓

It would be prudent to retain options to build additional fuel storage on Grass Area 17A and/or at a northern apron site.

✓

Concern at the potential relocation of the Perry Oaks fuel storage facility. If this was required Heathrow should find a suitable alternative location, fund the cost of re-provision of comparable facilities and secure all necessary planning permissions, utilities, road access, fire, water, COMAH requirements, security protection, service corridors, connections with the T5 and CTA fuel hydrants, etc.

✓

No objection to the relocation of the Total Fuel Depot at Site H6 to the west of the M25, south of the M4 and east of the railway line.

✓

Further information is needed on the options for the Total Fuel Depot.

✓

The importance of the relocated fuel depot being connected to the railway network was emphasised.

✓

The importance of the Total Fuel Depot was emphasised, including a new rail terminal and a new junction from M25, its location close to the railway and away from residential development.

✓

The existing Total Fuel Depot should be enlarged. ✓

Consideration should be given to piping fuel to locations where it is needed.

✓

Concern that providing extra fuel in the locality at the Total Fuel Depot could lead to a major security issue.

✓




PC MC WC

Support for the use of locations outside the immediate vicinity of the airport for displaced uses that do not need to be close to it. Sites should be chosen that are well served by bus and rail connections and do not require car travel by staff.

✓ Support noted. Heathrow is working closely with HSPG to assess the wider growth and infrastructure development which is likely to be generated by expansion. It will be the responsibility of the local authorities to plan for that growth which is not included in Heathrow’s DCO application, but the expectation would be that they will prioritise sites with good public transport accessibility since this is established planning policy in government guidance and the London Plan.

The closure of hotels and other facilities would have a significant short to medium term impact on employment both locally and within the wider employment catchment area. They requested further detail on how this would be managed.

✓ The DCO application will assess any implications from the closure of any hotels and other facilities displaced by expansion, as required by the ANPS (para. 5.111), including our proposals for helping to manage any negative effects. Our preliminary analysis of any socio-economic impacts arising from this source will be available in our PEIR at Airport Expansion Consultation in June 2019.

Displaced uses 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.

✓ Heathrow is working closely with HSPG to assess the wider growth and infrastructure development which is likely to be generated by expansion. This will include any displaced uses which are not included in our DCO application. In order to be included in the DCO application any displaced uses must meet the tests set for “Associated Development” in accordance with government guidance. Inclusion in the DCO application may provide greater certainty of timing and delivery than inclusion of specific site allocations in individual local development plans.

Request for further clarification on the number and extent of land uses that need to be removed/re-located.

✓ The number and extent of land uses to be removed will only be determined once the proposed masterplan is finalised for the DCO application. The preferred masterplan will be presented at Airport Expansion




PC MC WC

Consultation in June 2019.

Support for the principle of areas needing to be landscaped, planted, restored or enhanced in order to reduce the potential effects of expansion.

✓ Our proposals for new planting, landscaping and enhancement will form an integral part of our masterplan. We are undertaking a landscape and visual impact assessment alongside design development, which considers how the landscape would change as a result of the Project. We are aiming to minimise the effects of the Project on landscape and, wherever possible, improve the landscape. The preferred masterplan will be available at Airport Expansion Consultation in June 2019.

Heathrow should give priority to the provision of a multipurpose rail depot south of the M4. As a result, the site north east of the M4/M25 interchange should be used for the Total Fuel Depot.

✓ We are considering options of re-providing the rail head and the Total Fuel depot in a location on the Colnbrook Branch line close to their current locations and are liaising closely with Network Rail on these plans. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

The severance of the Colnbrook Branch line will affect a number of commercial facilities including the Northern Fuel Receipt site. The relocation of this facility will require careful planning with Network Rail.

✓

The London Borough of Brent has two housing zones that are currently being built that provide an opportunity for commercial/office space in support of the expansion proposals.

✓ Locations in the London Borough of Brent are too remote from Heathrow to meet the tests for Associated Development in accordance with government guidance. There would not be the requisite direct relationship and support for the operation of the airport from a remote location to qualify for Associated Development, which means it therefore cannot be included within our application for Development Consent.

Flood risk will affect which land uses will be appropriate. Table 3 of the National Planning Policy Guidance for Flood Risk and Coastal Change should be used.

✓ We will provide a preliminary flood risk assessment with our PEIR at Airport Expansion Consultation in June 2019. This is feeding into the decision-making




PC MC WC

process leading to a preferred masterplan and is being prepared in accordance with the ANPS and other relevant guidance.

There should be greater consistency in how heritage assets are identified and considered for future land uses. It is important that Heathrow understand the significance of these assets, how they may be affected and ensure integration with the Local Plans of the adjacent local authorities to ensure a plan-led approach to the various elements of new development.

✓ We have discussed our approach with Historic England and set out our proposed methodology in our Request for EIA Scoping Opinion. We are undertaking the assessment in accordance with the PINS Scoping Opinion. Our PEIR will be available at Airport Expansion Consultation in June 2019.

Consideration should be given to soils that are going to be disturbed/harmed and whether ‘best and most versatile’ agricultural land is used. Details of how adverse impacts on best and most versatile agricultural land and soil resources have been be minimised should be provided and that a mechanism to address compensation for loss should be developed.

✓ Our DCO application will identify any effects on soils and agricultural land, including direct and indirect effects, and seek to minimise impacts. In undertaking this we recognise the need to apply the policies set out in the ANPS. Preliminary findings will be available in the PEIR at Airport Expansion Consultation in June 2019. We have developed a suite of draft property compensation policies as well as a Property Hardship Scheme to help minimise and manage any negative impacts. For further information please see Chapter 18.

Focussing only on the direct effects of the acquisition of agricultural land lying within the Compulsory Purchase Zone is insufficient and unsatisfactory.

✓

Adequate compensation should be provided for agricultural tenants and farm businesses remaining in and around the Park.

✓

Demand for additional airport related development such as hotels and offices needs to be taken forward in consultation with local planning authorities as they develop their Local Plans.

✓ Heathrow is working closely with HSPG to assess the wider growth and infrastructure development which is likely to be generated by expansion. In order to be included as ARD in the DCO application proposed uses must meet the tests set for “Associated Development” in government guidance. The alternative is that such uses would be re-provided by market forces or through the local plans process.

The Joint Evidence Base and Infrastructure Study (JEBIS) and the Joint Strategic Planning Framework (JSPF) will identify options to meet demand for land uses on a plan-led basis.

✓

The impact of airport related development should be considered in the multi modal traffic model to ensure appropriate mitigation on the SRN and local road network is developed.

✓ The Airport Expansion Consultation in June 2019 will include our draft Surface Access Strategy and supporting technical information in the Preliminary




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Security measures would need to be incorporated into any designs for locations immediately adjacent to the SRN.

✓ Transport Information Report. The DCO application will be accompanied by a full Transport Assessment (TA) which will analyse any transport effects and put forward any necessary mitigation measures. These assessments will include any transport effects from airport related development. We are working closely with Highways England on our proposals and will incorporate their requirements on any security measures required.

The repositioning of recently constructed infrastructure should be avoided as it is uneconomic.

✓ We are seeking to minimise the impacts of expansion, including by developing within the existing airfield where possible. However, the Project will inevitably impact surrounding land uses and infrastructure because of Heathrow’s location relative to the surrounding area. We have developed a suite of draft property compensation policies as well as a Property Hardship Scheme to help minimise and manage any negative impacts. For further information please see Chapter 18.

The Iver South Sludge Treatment Centre is an integral asset for the treatment of sewage sludge associated with Mogden STW and that further information is needed to understand the effects on this facility.

✓ We are liaising closely with Thames Water on any effects on Iver South Sludge Treatment Centre. Our preferred masterplan will be available at Airport Expansion Consultation in June 2019 and will include details of any implications on the Treatment Centre.

Proposals for land south of Popes Close would interrupt its restoration after mineral extraction.

✓ If this site is required for expansion and there are any implications for an approved minerals restoration scheme, these will be assessed in accordance with the tests set out in the ANPS (para. 5.111). Our preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

Concerns were raised about environmental effects covering impacts on the Green Belt and green open spaces, agricultural land, wildlife

✓ The ANPS is clear (para. 4.31) that “a good design should meet the principal objectives of the scheme by




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and habitats, watercourses, recreational areas and the environment in general.

eliminating or substantially mitigating the adverse impacts of the development, for example by improving operational conditions”. The DCO application will comply with this and will include an Environmental Statement to explain how Heathrow has identified and mitigated any likely significant environmental effects during construction and operation of the airport. Our PEIR will be available at Airport Expansion Consultation in June 2019. We have developed Land Acquisition and Compensation Policies for Residential Property, Agricultural Land and Property, and Commercial Property, as well as a Property Hardship Scheme to help minimise and manage any negative impacts.

Concerns were raised about the effect on residential properties and residential communities (including those in Harmondsworth, Longford, Sipson and Stanwell).

✓

Concerns about the impact on the local economy and impacts on existing land uses and businesses that would need to be relocated as a result of the proposals.

✓

Request that effects on the environment, residential communities and properties and the economy should be minimised.

✓

As much airport land should be used as possible to avoid land take and local impacts.

✓ We have looked to locate appropriate uses within the airport boundary where space is available, but unused space is extremely limited. Moreover, some uses, such as Freight Forwarding for example, do not lend themselves to being on airport, but on sites outside the boundary but in close proximity. For more information on Airport Supporting Facilities (ASF) and Airport Related Development (ARD), please see Chapters 13 and 15.

Greenfield land must be avoided and brownfield locations should be preferred.

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated Green Belt. Heathrow is located in a densely populated area of south east England and on the edge of London, so there is very little unused brownfield land available. We have developed Land Acquisition and

Unused land should be prioritised to reduce the need for to compulsorily purchase of residential or business properties.

✓




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Compensation Policies for Residential Property, Agricultural Land and Property, and Commercial Property, as well as a Property Hardship Scheme to help minimise and manage any negative impacts.

High Wycombe should be used as it has plenty of space and the town would benefit from the employment opportunities.

✓ High Wycombe is too remote from Heathrow to be to meet the tests for Associated Development in accordance with government guidance. This means it therefore cannot be included within our application for Development Consent.

The importance of expansion and the necessity to affect and relocate some land uses to accommodate it is recognised.

✓ Comments duly noted.

The project provides an opportunity to improve the area through better design or by acting as a catalyst for regeneration in the area.

✓

Concern expressed about the impacts of the relocation on local people and communities, on vehicle emissions and on waste management.

✓ We have developed Land Acquisition and Compensation Policies for Residential Property, Agricultural Land and Property, and Commercial Property, as well as a Property Hardship Scheme to help minimise and manage any negative impacts of relocation on local people. The ANPS is clear (para. 5.42) that in order to grant development consent, the Secretary of State will need to be satisfied that, with mitigation, the scheme would be compliant with legal obligations on air quality that provide for the protection of human health and the environment. Heathrow will consult on the PEIR as part of the Airport Expansion Consultation in June 2019. The PEIR will set out early findings of the Community Impact Assessment which assesses the effects of the project construction and operation on communities. An ES will be submitted with the DCO that will set out an assessment on the effects and the mitigation




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measures to be incorporated into the scheme.

The BT Data Centre and Maintenance Depot could be placed in one of the new developments on the site of the expanded Heathrow.

✓ We are working closely with BT to assist them to relocate to other premises. This is likely to be outside the DCO application process.

Heathrow has not engaged with landowners whose land they wish to acquire. Options have been narrowed without proper engagement and due consideration of alternatives.

✓ Heathrow is committed to engage with those whose land may be affected by the Project, and to treat communities fairly. We have continuing to engage with landowners and are working quickly to do this. We are seeking to acquire land by agreement, wherever possible. In addition, the DCO may include powers of compulsory acquisition. Until the preferred masterplan and final design are decided upon, the full extent of affected land is not certain.

Alternative proposals to Heathrow’s expansion plans would achieve a 23% reduction in land take compared to Heathrow’s scheme.

✓ Heathrow’s plans have been through the scrutiny of the rigorous independent Airports Commission and Government’s further analysis as part of the ANPS process. 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 (paragraph. 3.74). Heathrow is developing its preferred masterplan for expansion working closely with communities and is carefully considering efficient use of land. We do not believe that there is a credible alternative scheme which would use less land. Our preferred masterplan will be presented at our Airport Expansion Consultation in June 2019.

How can Heathrow say its options are preferred when there is an alternative scheme that uses less land?

✓

Heathrow has not taken any steps to minimise the impact of its ✓ Heathrow is seeking to minimise additional land take




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proposals on Arora land. Heathrow has an obligation to protect businesses and provide alternatives.

outside the boundary of the existing airport by locating appropriate uses within the airport where space is available, but unused space is extremely limited. Land owned by Arora is affected by the Project as it lies within an area which is required for the third runway and other airfield infrastructure. We have developed a suite of Compensation Policies to help minimise and manage any negative impacts on affected properties. Updated property policies will be published in 2019.

Any commercial use including warehousing and car parking affected by expansion should be relocated on new land adjacent to the proposed airport

✓ In order to be included in the DCO application any proposed commercial uses must meet the tests set for “Associated Development” in accordance with government guidance. Heathrow’s compensation scheme will allow displaced businesses to plan and deliver their relocation if they do not meet the tests for Associated Development.

Any loss of the car parking or offices at the Golf Driving range should be properly notified, new sites identified, and business operations transferred to safeguard employment.

✓ We are still developing our preferred masterplan, which we will be consulting on in our Airport Expansion consultation in June. If this property is required for expansion, where possible we will seek to acquire the land by agreement and explore mitigation options with the landowner. In order to be included in the DCO application any proposed commercial uses must meet the tests set for “Associated Development” in accordance with government guidance. Heathrow’s property compensation schemes will allow displaced businesses to plan and deliver their relocation if they do not meet the tests for Associated Development.

Due regard should be given to both adopted and emerging planning policy at a local level and existing planning permissions to ensure

✓ As well as the ANPS, Heathrow is having regard to the content of neighbouring Local Plans, as well as




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that expansion does not inhibit the delivery of important development and growth.

any emerging plans, although some of these do not take into the need for airport expansion. Heathrow has and will continue to work closely with HSPG to consider the wider growth and infrastructure requirements that may be generated by expansion. This will provide a helpful evidence base for future Local Plan reviews.

If Site E1 is developed any proposed uses should not be in conflict with the existing consent for the provision of a 426-guestroom hotel.

✓ If this site is required for expansion and there are any implications for an existing planning consent these will be assessed in accordance with the tests set out in the ANPS (paragraph. 5.111). We are still developing our preferred masterplan, which will be presented at Airport Expansion Consultation in June 2019.

Concern that a study has not been carried out to identify preferred locations in or around the airport for airport related floorspace. As a result the extent to which these uses could be accommodated within the expanded airport boundary was unknown.

✓ Heathrow is undertaking a thorough and extensive study to assess locations in and around the airport for airport related floorspace. Initial findings were reported in Our Emerging Plans and the Scheme Development Report at Airport Expansion Consultation One and we are continuing to refine our analysis. We have looked to locate appropriate uses within the airport boundary where space is available, but unused space is extremely limited. Moreover, some uses, such as Freight Forwarding for example, do not lend themselves to being on airport, but on sites outside the boundary but in close proximity. An Updated Scheme Development Report will be presented alongside the preferred masterplan as part of the Airport Expansion Consultation in June 2019.

If Heathrow takes forward the widening of the Southern Perimeter Road and use of land for car parking, temporary construction sites and/or airport related developments such as hotels, offices, industrial premises or warehousing, Heathrow must ensure unencumbered access to and from the Heathrow Hydrant depot and

✓ We fully understand the importance of the Heathrow Hydrant depot and will ensure that access is not restricted as a result of the Project.




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all other relevant facilities.

Expansion will result in several existing buildings and facilities being displaced including Segro’s site at the Colnbrook Logistics Centre in Slough. As a result, early engagement on this is requested.

✓ We are engaging regularly with SEGRO on any implications for Colnbrook Logistics Centre and for other properties leased to SEGRO within the airport.

The costs of any works or land purchases must be borne by the scheme promoter until the asset could be used by its customers. A scheme promotor’s shareholders should not be allowed to make early and additional returns because they are regulated.

✓ It will be for the CAA to determine, via Heathrow’s future regulatory settlement and economic license, and through agreement with a range of industry stakeholders, how the cost of any work or land purchase related to the Project will be borne in the future.

Decisions on land use requirements should be made quickly to prevent losses that may be incurred as a result of uncertainty.

✓ We are still developing our preferred masterplan which will be presented at Airport Expansion Consultation in June 2019. We are working quickly to progress the DCO application, engaging with communities, landowners, and other interested parties at every stage of the process.

If a property owned by BMO Real Estate is retained in whole or in part, a clear route for servicing the site must be provided so that businesses there may continue to operate. If the property is to be lost then further information should be provided on how Heathrow proposes to relocate the tenants, particularly those with airport-related operations.

✓ If the site in question is not required for the Project, we will ensure that there is a clear access route for servicing the site. We are in discussion with BMO Real Estate to understand the implications for their landholding and any applicable timescales for relocation.

Concern that the timescales, cost and risk involved in securing the new sites for residential, commercial and public property, as well as obtaining all necessary consents, including release of Green Belt land and constructing replacement property and infrastructure has not been considered.

✓ Heathrow’s DCO application will only include land for airport related development if the proposed uses meet the tests set for “Associated Development” in accordance with government guidance. The timescales, cost and risks involved are all feeding into our decision making on this matter. The preferred masterplan will be available at Airport Expansion Consultation in June.

No reference has been made to Hounslow Council’s wider ✓ We are engaging regularly with the London Borough




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development aspirations or to where the proposed new housing and employment sites would be relocated. Conflicts and considerations should be recognised and addressed in detail within future consultations.

of Hounslow, through HSPG and on a bi-lateral basis. We are aware of the Council’s aspirations for sites in their borough which may be affected by the growth of the airport and are seeking to develop a solution which meets their aspirations as well as the needs of the Project. The preferred masterplan will be available at Airport Expansion Consultation in June 2019.

Any development to the west of Holiday Inn M4/J4 must be sympathetic to the hotel and its customers.

✓ We are liaising closely with the owners of the Holiday Inn. If land is required for expansion to the west of the hotel any implications for neighbouring land uses will be assessed in accordance with the tests set out in the ANPS (para. 5.111). This will include any implications from increased traffic. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

Further consultation on detailed development proposals west of Holiday Inn M4/J4 are needed and any intensification of traffic movements around the Holiday Inn resulting from the development should be accompanied by road improvements.

✓

A large number of sites have been identified for airport supporting facilities which exceed the requirements for these uses and as such some of this could be provided to accommodate displaced uses.

✓ As well as the core airfield facilities, expansion will require additional land for airport supporting facilities. We are producing forecasts of future demand for ASF, based on the increase in passengers and cargo throughput from expansion and these will inform our future plans for ASF. A long list of potential sites was presented at Airport Expansion Consultation One but the intention is to select only the most suitable sites for inclusion in the preferred masterplan. In order to be included in the DCO application any proposed ASF must meet the tests set for “Associated Development” in government guidance. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

Sufficient lead-in time is required for DHL to relocate its facilities. ✓ In order to be included in the DCO application any proposed warehouse uses must meet the tests set for “Associated Development” in government guidance.

There is limited large warehouse space in close proximity to the airport that would be suitable for the relocation and it was unclear if

✓




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sites identified for replacement facilities are already in the ownership of HAL or will need to be bought.

Heathrow does not currently own all the land likely to be required and is seeking to acquire land by agreement, wherever possible. If this is unsuccessful the DCO may include powers of compulsory acquisition for these sites. We will work with affected landowners to understand the timescales for relocation for individual businesses. 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 options for the transport infrastructure needed to support expansion in the context of increasing the use of public transport by passengers and colleagues. The preferred masterplan will also be presented at Airport Expansion Consultation in June 2019. A full transport assessment will accompany the DCO application.

Concern raised about traffic in the vicinity of the DHL Horton Road property during and after construction of the runway. Further detailed traffic study information is needed.

✓

The Cappagh aggregate recycling site should be retained for at least the period of construction to support the sustainable construction of the expanded Heathrow.

✓ This site may be required for the Project. The existing use could support the construction effort, but programming requirements may mean that retention is not possible. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

The ongoing success of Flowevervision’s business should be secured by ensuring any highway improvement works necessary to J14 of the M25, Stanwell Moor Junction and the road between (A3113 Airport Way) are positioned on the agricultural land to the North of A3113 Airport Way.

✓ This site occupied by Flowervision may be required for improvements to junction 14 of the M25. Space is extremely restricted in this location because of the M25 junction works, river diversions and expansion of the western airport campus. The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

Opposition to the use of more greenfield and brownfield land, in particular at Stanwell, Stanwell Moor and West Bedfont.

✓ The Project will inevitably affect both greenfield and brownfield land given the overall scale of land




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Concern about the further loss of open green wildlife friendly space. This is important for redressing the overdevelopment of London and the quality of life for all people near the airport.

✓ required. We are seeking to make efficient use of land within the existing airport boundary, including by using land within the airport where possible. However, some new land outside the airport will be required, as space within the existing boundary is extremely limited. We will comply with ANPS requirements to provide replacement land for open space and biodiversity sites which are affected. Our blue and green infrastructure proposals will form an integral part of the preferred masterplan which will be presented at Airport Expansion Consultation in June 2019.

The importance of meeting environmental requirements was highlighted.

✓

Planning and design work for existing facilities displaced by expansion should seek to minimise impacts, particularly the loss of open space.

✓

No clear examples had been provided which address the loss of the key functions of the Colne Valley Regional Park including the impact on recreational use, agriculture and the rural economy.

✓ At Airport Expansion Consultation One our early thoughts were presented in Our Design Approach to the Natural Environment. Chapter 4 contained examples of well-connected and multi-functional green infrastructure. Heathrow is engaging regularly with the Colne Valley Regional Park Interest Company who are part of the HSPG and we are undertaking an environmental impact assessment, including an assessment of impacts on the Regional Park and any necessary mitigation. Early findings of this process will be reported in the PEIR and the Updated Scheme Development Report which will be presented at Airport Expansion Consultation in June 2019. We will comply with ANPS requirements to provide replacement land for open space and biodiversity sites affected by the Project and will seek to avoid impacts on open space and biodiversity sites as far as possible.

Expansion will likely cause a significant impact on existing land uses within the Colne and Crane valleys through significant losses and changes to land which may affect their future management.

✓

Concern at the loss of parts of Harmondsworth Moor Country Park and that no clear examples have been provided that demonstrate how the loss and stress to the key ecological functions of the surrounding wildlife habitats and natural environment will be addressed.

✓

Housing and green space is more useful and important to most residents than a huge airport.

✓ 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




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best placed to deliver this capacity and that overall it would deliver the greatest net benefits to the UK (para. 3.74). We recognise that a project of this size will have impacts, and we are seeking to manage these effects - including seeking to avoid loss of open space and housing as far as practicable.

Any changes in land use that affect Royal Parks land resource would need to be considered prior to any planning stage and that any encroachment on the river or its freeboard would be subject to licence.

✓ Heathrow will consider and assess all implications of the Project on affected land uses, including the Royal Parks if appropriate, in accordance with the tests in the ANPS (para. 5.111). We will also comply with all applicable consent and licence requirements.



15. AIRPORT RELATED DEVELOPMENT

15.1 Introduction


relation to the locations and sites identified for airport related development (ARD).

A total of 1,107 consultees made comments relating to this topic.

15.1.2 Heathrow provided the following material that is directly related to the location and

sites identified for ARD:




15.1.3 Within Section 14 of the Our Emerging Plans Document Heathrow identified a

number of potential locations and sites for ARD. References to Option Numbers

below are taken from the Our Emerging Plans Document.

15.1.4 Heathrow asked the following questions regarding ARD at Airport Expansion

Consultation One:

1. Please tell us what you think about the locations and sites that we have

identified as being potentially suitable for airport related development.

2. Do you have any views on how the demand for additional airport related

development such as hotels and offices might best be delivered?









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.




Local Authorities

General Comments

15.2.1 The London Borough of Brent suggested proposals for ARD should first consider

the potential of existing business locations and what access improvements/public

transport services could be provided to meet this need within a one hour travelling

distance of the Airport.

15.2.2 The London Borough of Brent, Ealing Council and Runnymede Borough Council

expressed concern at what they consider to be the over-concentration of

development on the airport itself and that Heathrow’s focus appears to be for new

development.

15.2.3 Buckinghamshire County Council expressed concern that ARD and the

construction of mitigation measures would generate additional HGV traffic in the

Ivers and Richings Park areas. They supported the proposal not to bring forward

multiple ARD sites in the Ivers area due to potential harm to the Colne Valley

Regional Park.

15.2.4 They also commented that the area around the new runway and ARD should

provide as few barriers as possible to walking and cycling and suggested

commuter cycling access from residential areas in Richings Park and Iver and to

the areas earmarked for ARD in Slough and Langley be provided.

15.2.5 Essex County Council welcomed that the Airport Expansion Consultation

Document addressed ARD both on and off-site and that Heathrow are considering

the wider impact of the Project on the local and wider economy.

15.2.6 The London Borough of Hounslow expressed concern that the proposals for ARD

outside the existing airport boundary do not align with those set out in the

emerging Local Plan review for the west of the Borough and urged Heathrow to

review the plans to ensure consistency with the Local Plan proposals rather than

taking a narrow airport operations-centric approach to site allocation.

15.2.7 They supported the development of new terminal-linked hotels and the expansion

of office space within the borough. They suggested that connecting new hotels

with private shuttle services would increase local traffic congestion and suggested

more distantly sited hotels should be near to town centres so that public transport

links could be used.

15.2.8 They commented that at least 160,000 sq. m of additional office space could be

accommodated within the Hounslow side of the Heathrow Opportunity Area and

said that transport accessibility should be a primary consideration when planning



office locations. They also suggested consideration be given to a site at the

Airport Business Park for airport related logistics, warehousing and industrial uses

and identified a number of sites in the west of the borough that could help deliver a

further 56,000 square meters of industrial floor space.

15.2.9 Runnymede Borough Council suggested that proposals for ARD should consider

the potential of existing business locations and what access improvements/public

transport services could be provided to meet this need within a one hour travelling

perimeter, utilising the sustainable transport links. They also suggested that

development at Heathrow should be restricted to areas with a functional link to its

operations.

15.2.10 Slough Borough Council said that hotels and offices could be sited in Slough. It felt

that these would have excellent transport link once the Western Rail Link to

Heathrow was completed.

15.2.11 Spelthorne Borough Council considered that Heathrow have constrained

themselves by only considering locations very close to the airport. They

suggested that a station at the centre of Staines-upon-Thames would offer the

opportunity for airport hotels and international headquarters to be built there and

linked to Heathrow with a 7-minute journey time. They considered that this

approach would encourage sustainable transport and the modal shift that

Heathrow needs to deliver to help mitigate the deterioration in air quality.

15.2.12 The Royal Borough of Windsor and Maidenhead commented that they have

limited capacity to provide land for the economic activities, such as logistics

depots, cargo facilities, hotels that will come with an expanded airport. They

considered that Heathrow should support the local authorities and the Local

Economic Partnerships (LEPs) in the area agree an area wide response to the

spatial distribution of this economic activity rather than leave it to local authorities

to bear the risk and cost of dealing with individual planning applications.

Locations and sites identified as being potentially suitable for ARD

15.2.13 The London Boroughs of Brent and Ealing Council stated that the intensification of

Park Royal could provide opportunities for supporting airline services such as

catering, due to the existing uses and skilled workforce already in place.

15.2.14 Slough Borough Council stated that all potential ARD sites north of the A4 should

be reserved for the proposed rail depot and possible relocation of Grundon’s

Waste Management Facility. They said they did not support development on sites

near Colnbrook Village but supported the potential for sites east, west and south of

Poyle Trading Estate. They also said that some ARD could be accommodated in

places like Slough town centre which will have very good access to Heathrow

once the Western Rail Connection has been built.



15.2.15 Spelthorne Borough Council said that some of the sites identified may have

potential for ARD but considered a robust case to demonstrate very special

circumstances is required to justify development in the Green Belt and that the

impact of development needs to be mitigated and compensated.

15.2.16 The London Borough of Hounslow commented on a number of the sites detailed in

Heathrow’s Our Emerging Plans Document stating that:

1. Site 2 provides an opportunity to create a high-density mixed-use employment

led development around a new Southern Access railway station;

2. Site 3 has the potential for the intensification of industrial uses to service

Heathrow whilst delivering employment and business growth for the borough;

3. Site 5 has the potential to deliver industrial uses and is identified in the

emerging plan as an Airport Business Park;

4. Site 7 has the potential to intensify industrial uses; and

5. Site 11 has the potential to provide not only hotel uses but offices, apartments,

shops, bars and restaurants as part of the proposed Heathrow Gateway

development.

15.2.17 Spelthorne Borough Council commented on a number of the sites detailed in

Heathrow’s Our Emerging Plans Document stating that:

1. Site E3 lies within an area of strategic green belt and will need to be subject to

a robust green belt case to outweigh the harm and ensure that noise, traffic

and air quality are appropriately addressed.

2. Site E4 performs an important green belt function and the most practical form

of ARD would be cargo facilities. The site was not considered suitable for

other uses.

3. Site F1 performs a moderate green belt function and the proposed hotels and

offices must be designed to the highest standards and include landscape

features to mitigate the impact of development.

4. Site F2 performs a strong green belt function. It is also a safeguarded minerals

and waste site where restoration is expected in 10 years. The creation of a new

defensible boundary would be integral to the consideration of very special

circumstances.

5. Site F5 performs a moderate green belt function. It is an operational minerals

and waste site with detailed restoration to high quality landscape with

biodiversity areas complementing the natural areas of Staines Moor and the

River Colne and with extensive public access required by 2023. The site does

not have development potential.



6. Site F7 performs a moderate green belt function and is partly used as a lorry

park. Use of the site for more intensive development would need to enhance

the setting of the Wraysbury River and adjoining SSSI.

7. Site NS7 performs a weak green belt function. Development for ARD would

not undermine the strategic function of the green belt and could provide the

opportunity for environmental enhancement.

8. Site NS8 performs a weak green belt function. The site has potential for

residential or commercial development but also provides an opportunity for

landscape enhancement.

15.2.18 Surrey County Council also put forward a detailed list of comments about sites

identified for ARD in Heathrow’s Our Emerging Plans Document and listed the

important things to consider for each (e.g. proximity to areas of historic interest

and proximity to contaminated land).

1. Site E3 is a Mineral Local Plan site with consent for extraction. The Council

wish to extract the minerals in advance of any development. It is located in the

green belt and has a former Roman Road adjacent to the site and Areas of

High Archaeological Potential within 500m. It lies adjacent to a contaminated

site and the Longford to Walton fuel pipeline affects the northern and western

corners.

2. Site E4 is a restored former minerals site in the Green Belt. There site is

potentially contaminated with engine oil from previous lorry dismantling

activities.

3. Site F1 lies in the Green Belt and is a restored minerals site. It lies within the

Colne Valley Regional Park and the Thames Valley Biodiversity Opportunity

Area.

4. Site F2 is a mineral site that is being backfilled with inert waste for restoration.

The site is within the Green Belt and the majority of it is being restored to

agricultural use as a buffer between Stanwell and the airport. It lies in the

Thames Valley Biodiversity Opportunity Area adjacent to the Colne Valley

Regional Park. Should this site go ahead for development compensatory

provision should be made for extending the historic garden and SNCI and a

woodland buffer to help mitigate the impact on Stanwell.

5. Proposals for Sites NS7 and NS8 could have implications for traffic and air

quality on Stanwell Fields Primary School that would need mitigation.



The demand for ARD and how this might best be delivered

15.2.19 Ealing Council suggested that Heathrow should consider evidence of other sites

emerging through the proposed Joint Spatial Planning Framework4 to produce a

holistic rather than a fragmented strategy. Surrey County Council expressed a

similar view stating that the plans should take account of local plans from local

authorities and the Heathrow Strategic Planning Group.

15.2.20 Essex County Council supported the scope of the planning for airport related

facilities.

15.2.21 Kent County Council noted that ARD outside of the airport boundary will be

managed through the planning process.

15.2.22 Surrey County Council commented that the delivery of ARD needs to take account

of adopted and emerging Local Plans (including site allocations) and through

working with the Heathrow Strategic Planning Group (HSPG) on a joint strategic

planning framework.


General Comments

15.2.23 The Environment Agency commented that potential habitat loss will need to be

considered for any ARD location or site.

15.2.24 Highways England expressed concern with the integration of ARD into the local

transport system, making the best use of public transport and discouraging the use

of private cars. They said encouraging public transport and discouraging private

car use were important considerations for the siting and integration of ARD both

on and off the airport campus.

15.2.25 They went on to suggest that ARD outside the airport boundary should be sited

along public transport corridors linked to the airport and close to public transport

hubs. They also said consideration should be given to providing public transport

options tailored to the particular needs of airport users (e.g. transfer of luggage

to and from the airport) and that ARD should be considered in the multi modal

traffic model.


15.2.26 Historic England made the following detailed comments on the sites identified in

Heathrow’s Our Emerging Plans Document for ARD:

4 A strategic planning document that provides an overarching development framework to guide housing, employment and infrastructure requirements.



1. Sites A2 and A4 are adjacent to Harmondsworth Conservation Area and lie

within the Heathrow Archaeological Priority Zone. Heathrow should give careful

consideration to impacts on the conservation area and its setting.

2. Sites A5, C2, G7 and E2 are within the Heathrow Archaeological Priority Zone

and should be assessed for archaeological interest

3. Site A7 is within the Sipson Archaeological Priority Zone and should be

assessed for archaeological interest

4. Site B2 is adjacent to a number of listed buildings and Harlington Conservation

Area. Heathrow should give careful consideration to impacts on the

conservation area and its setting.

5. Site C1 is adjacent to Harlington and Cranford Conservation Areas which

contain a number of listed buildings. Heathrow should give careful

consideration to impacts on the conservation areas and its setting.

6. Site D1 is a large partly quarried site and should be assessed for

archaeological interest.

7. Site E1 lies within the East Bedfont Archaeological Priority Area and is likely to

contain considerable archaeological potential. Any proposed development will

require appropriate investigation to ensure that harm is not caused to the

significance of the Scheduled Monuments. They encourage imaginative green

infrastructure design to better reveal the sites’ significance as a potential

positive benefit and offset harm elsewhere.

8. Site E3 is wholly within and Site E4 is partly within a site of High Archaeological

Potential.

9. Site F2 includes a major undesignated Neolithic monument.

10. Site G4 lies adjacent to the Colnbrook Conservation Area and there is a Grade

II marker post in the south-western corner of the site. Heathrow should give

careful consideration to impacts on these assets and their setting.

11. Site G5 contains the grade II Poyle Farmhouse. Heathrow should give careful

consideration to impacts on this asset and its setting.

12. Site H3 appears to be partly within the Colnbrook Conservation Area and

contains two listed buildings. Heathrow should give careful consideration to

impacts on these assets and their setting.

13. Site I5 lies adjacent to West Drayton Green Conservation Area and the listed

buildings within it.



14. Site J1 lies within the Cranford Archaeological Area and includes a listed

drinking fountain.


15.2.27 Highways England stated that demand for ARD should be managed in close

consultation with local planning authorities as part of the Local Plan process. They

requested confirmation that vehicle journeys to and from these locations will be

classified as airport related traffic.

15.2.28 Historic England suggested ARD should be integrated with the local plans of the

adjacent local authorities, to ensure a plan-led approach to new development

outside the boundaries of the expanded airport.

Other Prescribed

General Comments

15.2.29 Bray Parish Council expressed concern as to whether surrounding infrastructure

will be sufficient to service the proposed ARD. Windlesham Parish Council

expressed similar concerns identifying increases in the levels of traffic along the

A30 and the M3 and that congestion will cause loss of local business.


15.2.30 Colnbrook with Poyle Parish Council commented that sites to the west of the

M25 have limited development potential and that priority should be given to

businesses displaced due to the new runway and the M25 widening. They also

highlighted that:

1. The site to the north end of Lakeside Road should not include land north of the

A4 Colnbrook bypass and would need to be re-connected to the A4.

2. The area north of Gallymead Road would be suitable for uses that do not

interfere with residential properties and the school. This site would require

connection with Junction 14 of the M25 via a new road to the east of Poyle

Industrial Estate.

3. The area east of Gallymead Road has development potential but there is an

existing proposal to support the Western Rail Link to Heathrow that would

affect this land.

4. The area south of Poyle New Cottages and east of the Poyle Industrial Estate

could be suitable for the expansion of the Industrial Estate, improving

connectivity to Junction 14 and internal roads but land between the new

runway and north of Pippins Park is needed for a protective green envelope.



5. The area south of Horton Road and west of the M25 may have potential for

multiple uses including housing or hotel accommodation.

6. The use of the area to the west of Poyle Road is not supported as it would

bring new development onto greenbelt land close to residential properties.

7. The area south of Popes Close and east of Horton Road would interrupt

mineral restoration. Any further development in connection with this site would

add to the sense of enclosure by ARD.

15.2.31 Iver Parish Council were supportive of the use of Thorney Mill Road Aggregate

Site (Old Aggregate Site & Thorney Sidings) for office development as it is well

located and a transport management plan can be implemented. They considered

traffic associated with a railhead or aggregate uses as unacceptable.


15.2.32 The Heathrow Strategic Planning Group suggested that Heathrow should work

with its members to develop options that best align with Local Plans. They stated

that the Joint Evidence Base and Infrastructure Study will identify demand arising

from the airport and wider growth, and will inform the development of a joint spatial

planning framework which together with the policy framework and development

plan outputs of this process should form part of the basis for the DCO and related

development proposals.



General Comments

15.3.1 Responses from members of the public in relation to ARD provided both positive

and negative feedback about the extent of development or the Project.

15.3.2 Those that provided positive comments indicated broad support for the proposals.

They considered that it was needed or commented that the locations seemed

suitable. Suggestions were received that ARD will support local businesses and

help to deliver economic growth both locally and nationally. There was also

support for the clustering of offices to reduce land take, transport needs and local

impacts, and that hotels should be located close to terminals and should be given

priority over office developments.

15.3.3 Members of the public also suggested that hotels should be provided in a range of

sizes and rental values to meet the needs of a wide market and that the plans

should encompass long term development needs and any future expansion.



15.3.4 Members of the public also provided conditional support for ARD subject to it

reducing the impact of traffic, noise and air pollution, improving public transport

links or minimising the impact on existing infrastructure and additional traffic.

15.3.5 Other comments expressed concern about the potential increase in house prices

as a consequence of the Project and increased competition for property. They

suggested that this would be mitigated if jobs were located close to stations and

bus routes.

15.3.6 Members of the public who commented on ARD often criticised the proposals,

suggesting that they were opposed to the Project or that it should be delivered

elsewhere to stimulate the economy in other parts of the UK. Some said that none

of the selected sites were suitable and that they were unnecessary. Comments

were also received that suggested the needs of local people should take

precedent over those of businesses, that ARD would operate for 24 hours per day

further blighting and polluting the local area and that it would impact an already

crowded and congested area.

15.3.7 Members of the public also raised concerns about the effects on the environment,

the amount of land being taken for ARD, that hotel development will have an

adverse impact on the environment and that Green Belt land should not be used to

accommodate ARD.

15.3.8 Other general comments related to public transport, traffic and congestion.

These frequently expressed concern regarding the impact on local towns and

villages and the capacity of existing public transport links for the proposed scale

of development.


15.3.9 Responses from members of the public on the locations or sites for ARD were

varied. Specific sites were not often identified and broad locations or suggestions

and generalised comments were received instead. The positive comments

received were:

1. Sites along the eastern boundary of Colnbrook-with-Poyle Parish Council have

potential for longer term development, such as hotel accommodation, housing

and footpaths.

2. Housing or hotel accommodation would be appropriate in an area to the south

of Horton Road, to the south west of the proposed runway.

3. North East of the new runway would appear to be best for ARD due to its

connections to existing road infrastructure.

4. The Coach Park on Horton Road has potential for multiple uses including

businesses displaced by the new runway.



5. ARD can be built at Stanwell Moor but compensation should be paid.

6. Development should take place to the north and near major road junctions to

avoid excessive local traffic.

7. Hotel sites could be provided in Stanwell Moor and Staines linked with high

quality public transport

8. Existing hotel sites along Bath Road towards Colnbrook have capacity

to expand

9. ARD could be located along the stations of the Piccadilly line and Crossrail.

10. There should be a concentration of development alongside the M25/A4

junction to take advantage of accessibility and visibility.

11. Alternative locations including Chertsey, Colnbrook, Feltham, Gatwick, London,

Reading, Slough, Staines, West London, Woking and Hounslow are suggested

for hotel development.

12. Heathrow should reuse existing empty buildings and land for new office

development in Hillingdon, Slough and Stockley.

15.3.10 A number of negative comments were provided on the locations or sites identified

for ARD. Specific sites were not often referenced but broad locations were given.

The comments received were:

1. Development north of the M4 or south of the A30 is not favoured. Both areas

would conflict with the local population and compete for sites that would be

better used for housing or other community needs.

2. The area to the North East is too distant from the airport and transport links will

be difficult to establish.

3. ARD should not be located in Horton and Poyle as local roads do not have the

capacity to cope with current traffic levels.

4. Stanwell has enough cargo warehousing and local roads will not sustain any

further development.

5. Public transport is poor in Horton and Horton Road to Junction 14 is already

busy. The area is not suitable for ARD.

6. Industrial and warehousing development will create congestion and will have a

detrimental effect on residential areas and pollution.

7. There is no need to acquire additional sites as the airport already has ample

space. If more is required then Slough and London can meet this need.

8. Land to the south and east is not best placed serve the Project.




15.3.11 No comments were received from members of the public in relation to how ARD

would be delivered.

Businesses

General Comments

15.3.12 The Airport Industrial Property Unit Trust (AIPUT) said that hotels and offices

should be located in areas served by public transport to minimise traffic.

They suggested that locations identified for ARD have not considered economic

viability factors and have prioritised land use analysis. They considered that

market factors and advances in aviation technology should be considered within

the analysis.

15.3.13 The Arora Group said that Heathrow has not done enough to limit the effects on its

T5 Sofitel property and stated that Heathrow has an obligation to protect their

business and provide alternatives. They suggested that their alternative expansion

proposals could achieve a 23% reduction in land take when assessed against the

Heathrow’s and were unclear how Heathrow could call its proposals the most

preferred when there is an alternative scheme that uses less land.

15.3.14 The London (Heathrow) Airline Consultative Committee (LACC) and the Board of

Airline Representatives UK (BAR UK) said that sites for ARD should tie in with the

local road strategy so that access to the airport is convenient and does not

compromise efforts in tackling air quality and congestion.

15.3.15 GlaxoSmithKline commented that ARD would have a positive effect on economic

development and employment but recognised the potential increases in traffic and

housing demand that might result. They suggested strategies to address these

issues must be developed.

15.3.16 Global Grange Limited said that consideration should be given to the longer term

proposals for the land in their clients ownership to be brought forward for

residential led mixed use development within the West of the Borough Plan. They

requested the opportunity to meet with Heathrow to discuss their concerns further.

15.3.17 Hatton Farm Estates Limited suggested removal of restrictions on Green Belt

allocations may be required to provide employment land.

15.3.18 Huseyin Ulus commented that they are currently in discussions with Hilton Hotels

UK to develop a hotel at a strategic point on the local road and motorway network

around Heathrow. They requested that Heathrow consider their plans and provide

access to the site as part of the Project.



15.3.19 Lapithus Hotels Managements UK Limited expressed concern over Heathrow’s

prediction that 8,300 new hotel rooms are required by 2040. They considered that

this number of new rooms would continue a pattern of over-supply and indicated

that there are currently in excess of 3,000 hotel rooms currently in the pipeline for

construction between now and 2020.

15.3.20 They stated that due to the scheduled and planned improvements in transport

infrastructure between central London and Heathrow, future demand for hotel

rooms by those travelling to and from Heathrow is likely to be spread over a wider

geographical area. They suggested that Heathrow should work with hotel

operators in order to learn from their experience and explore how the provision of

bed spaces at existing hotel facilities can be maximised.

15.3.21 Sapcote Developments stated that they would be pleased to assist in exploring

whether any of their landholdings could be designated as potentially suitable

for ARD.

15.3.22 Segro suggested that as a large proportion of the land identified as potentially

suitable for ARD falls within the Green Belt greater clarity is required on how

development will be delivered on these sites, particularly given the enhanced

Green Belt safeguarding policies in the draft London Plan and draft NPPF.

15.3.23 Staffordshire Chambers of Commerce said that the Project will provide demand for

ARD which will generate local growth and employment. They stated that Heathrow

should use a variety of firms from across the UK to ensure that all areas could

achieve some prosperity from the Project and develop a sustainable approach to

supporting local firms.

15.3.24 Suez UK suggested that Heathrow should engage with surrounding landowners in

order to achieve the best design and delivery of the required supporting

infrastructure for the expanded airport. They considered that this could be manged

through a framework between Heathrow and local landowners.

15.3.25 The Surrey Chamber of Commerce stated that the area around the airport is great

for development and employment and that development should commence as

soon as possible.

15.3.26 The Thames Valley Chamber of Commerce stated that an increase in demand for

ancillary, associated development will generate employment opportunities. They

emphasised that Heathrow must work closely with providers across the Thames

Valley area to have the opportunity to help meet growing demand. They also

stated that improved public transport accessibility will strengthen the accessibility

of points ‘west’.

15.3.27 Virgin Atlantic Airways Limited (Virgin) said that additional development, such as

hotels, would have an important role in the support services and facilities



passengers need. They stated that future development should be led by market

demand and undertaken by those with the greatest experience and best track

record for this type of development.


15.3.28 Most businesses that commented on the sites identified for ARD did so positively,

expressing a willingness to work with Heathrow to develop the sites and often

sharing recommendations for delivery.

15.3.29 The Brett Group suggested that their land at Hithermoor was an ideal location to

link the proposed southern rail link to Heathrow and is well connected to the M25

via Junction 14 and should be considered for ARD.

15.3.30 Cappagh Companies expressed broad support for car parking and ARD on

underused land close to the expanded Airport. They suggested that the current

Stanwell recycling facilities should be retained rather than being used for ARD, as

the aggregate recycling services provided are likely to be essential for the

sustainable construction of the expanded Heathrow.

15.3.31 Crane Road Properties LLP said that although their land at Green Acre Farm is

currently within the Green Belt they would like to make the site available for

development as part of the Project.

15.3.32 Emerson Group on behalf of Orbit Developments expressed concern over the

identification of the property at Heathrow Boulevard, Bath Road for the provision of

ARD suggesting that it should be retained for its current use.

15.3.33 Global Grange Limited requested that the development of Site E1 as detailed in

Heathrow’s Our Emerging Plans Document should not conflict with the consent for

the provision of a 426-guestroom hotel.

15.3.34 Hatton Garden Trustees Limited and Pickering Properties Limited proposed that

sites considered that sites on north western edge of the airport would be more

suitable for corporate office space.

15.3.35 Landchain objected to land uses on their client’s site being restricted to those

prescribed or required to service Heathrow.

15.3.36 The Lanz Group were supportive of the inclusion of land at Longford II, Golf

Driving Range and land to the North of Sipson for ARD. They identified that any

site would require proper connection to existing or new road networks and that any

loss of land within the Lanz landholding would need to be considered.

15.3.37 Lapithus Hotels Managements UK Limited stated that they had no objection in

principle to the development of its sites and would be willing to work with Heathrow

to take forward sites such as A4, A7, B1 and GC5 (as detailed in Heathrow’s Our



Emerging Plans Document). They said they have already prepared indicative

plans for Site GC5 and suggested that there was no case for Heathrow to use

compulsory powers. They asked that impacts on their hotels be kept to a minimum

and that improvements to the local road network would be required to support

further development.

15.3.38 Lewdown Holdings Limited welcomed the acknowledgement of the development

potential of the Sipson Farm site and supported the conclusion that it has limited

value as Green Belt land. They stated that the site has the potential for a

significant volume of minerals to be extracted but that any such development

should not prejudice the subsequent development of the site in the longer term.

15.3.39 Link Park LLP expressed support for the inclusion of the Link Park Site at Thorney

Mill Road for ARD.

15.3.40 Poyle Manor Farm/Wiggins Building Supplies Limited suggested that Poyle Manor

Farm should be considered for the location of an increased supply of floorspace

required directly or indirectly for the Project.

15.3.41 Richings Park Golf Club considered that although situated in the Green Belt there

is potential for a hotel on their land. They suggested that there will be a huge

demand for hotel rooms and a lack of areas where they can be built.

15.3.42 RTL Holdings Limited noted that work would be required to release their land at

Bedfont Road/Long Lane (Site E4 in Heathrow’s Our Emerging Plans Document)

from the Green Belt. The stated that the site has willing landowners who will look

to bring the site forward at the earliest possible opportunity for employment-

generating uses and uses to support the function, ongoing viability and success of

the airport.

15.3.43 Segro stated that a number of their Hatton Cross sites (D1, D2 and HS3 as

detailed in Heathrow’s Our Emerging Plans Document) had been identified as

being suitable for ARD but given the current demand, they considered that these

sites need to be developed irrespective of the third runway. They went on to state

that they would object to an airport-related user restriction on these sites as they

could equally be required for a range of sector needs, not all of which were

airport related.

15.3.44 Speedbird Securities Limited expressed a similar view, stating that whilst their

sites are suitable for ARD, land uses must not be restricted to those prescribed

or those required by the Project. They considered that reserving the land for

Heathrow’s related or ancillary uses is not justified as there is a need for other

commercial developments, emerging business demands and substantial

housing growth.



15.3.45 Suez UK proposed that with a realigned A4, the area around the M4 junction and

M4 spur would be an ideal opportunity for a gateway development for the

expanded airport. They suggested that this area has the potential to be the entry

point to Heathrow and should not accommodate relocated support facilities.

15.3.46 UCH Logistics identified that UCH 1 Skylink House lies within areas identified for

construction uses and ARD. The property also lies within the land take identified

for both families of options for the M25 junctions 14 and 14a. They suggested that

careful design consideration be given to their property so that it could be retained

and this would avoid the need to relocate the business and a compensation claim.


15.3.47 The Copas Partnership considered that ARD should be built as soon as possible

with no planning restrictions or delays and that the proposed sites were unlikely to

be sufficient.

15.3.48 LACC and BAR UK recognised the importance of ARD in supporting the airport

ecosystem and agreed with the importance of identifying areas where this could

be accommodated. They considered that the delivery of ARD should be demand

and market led and that Heathrow should only consider doing so where there

would be significant benefits.

15.3.49 Global Grange expressed concern that little consideration had been paid to the

proposals included within Hounslow’s ‘West of the Borough Plan’. They suggested

that given the need for growth, development and regeneration within this part of

Hounslow, the airport must carefully consider the provisions of the emerging

planning policy framework and seek to work with Hounslow Council and

landowners to deliver the vision for development within this part of the Borough.

15.3.50 They stated that Heathrow should acknowledge there is insufficient land to meet

its development requirements and that it is imperative to work with adjacent land

owners to secure suitable locations for new development without compromising

local Council development aspirations and existing planning consents.

15.3.51 The Lanz Group said that an assessment of current provision and projection of

future use should be the starting point. Based on this information a new demand

quantum could be produced. This could be used to demonstrate the amount of

ARD which was required.

15.3.52 Segro suggested that given the timings of the Project, immediate action is needed

to address additional floorspace demand. They recommended Heathrow’s

floorspace demand assessment be integrated with the Councils’ (that are

members of the Heathrow Spatial Planning Group) own ‘business as usual’

assessments to establish a complete picture of total demand.



Community Groups

General Comments



include specific feedback on ARD

15.3.54 Wentworth Residents Association commented that there is already sufficient

business and hotel accommodation within easy access of the airport and no

more is needed.

15.3.55 Slough and District Against Runway 3 stated that none of the options are

acceptable due to the massive landgrab from Colnbrook and Poyle, and

neighbouring communities.

15.3.56 Harrow U3A suggested that Heathrow should consider easily accessible locations

close to the airport.

15.3.57 The Camberley Society stated that hotels are needed but environmental

requirements must be met. They stated that offices should be located away from

the airport with better transport links.

15.3.58 HFT suggested that proposals for ARD should consider accessibility, people

with learning disabilities and ensure that public spaces are designed to be

autism-friendly. They also requested further information on how Heathrow

would ensure that businesses looking to support the Airport will seek to employ

disabled employees.

15.3.59 The Friends of the River Crane stated that indirect growth associated with the

project is a greater risk to the open space network than the runway because much

of this growth could be ad hoc without any overarching plan. As a result, they

considered that Heathrow must assess and seek to mitigate the negative impacts

of this associated growth.


15.3.60 Local Conversation in Stanwell stated that options further from the airport which

could stimulate economic growth and benefit the locality should be considered for

ARD. They cited the example of Staines-upon-Thames which if linked via a new

station to the Southern Rail Link could offer the opportunity for airport hotels and

international headquarters linked to Heathrow with a 7-minute journey time. They

considered that such options would provide economic benefit to the wider area

around Heathrow, reduce the need for as much development immediately south of

the airport, encourage sustainable transport and would help to mitigate the

deterioration in air quality.



15.3.61 Stanwell’s Green Lungs stated that the impacts from the sites identified for

ARD are overwhelmingly negative. They suggested that an open area should

be maintained to create a barrier between the airport and populated areas on

its boundary.

15.3.62 Colnbrook Community Partnership made the following comments on sites detailed

in Heathrow’s Our Emerging Plans Document:

1. They expressed opposition to the designation of all the land north of the

Colnbrook Bypass, west of the lakes (Sites H1 and H2) for airport related

development.

2. They indicated they would not be opposed to only some of Sites H1 and H2

being developed.

3. They expressed opposition to the use of land located between Colnbrook

and the existing Colnbrook Bypass (part of Site H3) and stated that this

area should be reserved as a buffer with appropriately landscaped bunds or

noise barriers.

4. They expressed opposition to the use of part of Sites G4 and G5 for ARD as

development of these sites would have a negative impact on Poyle and the

Colne Valley Regional Park.

5. They expressed opposition to the use of Site H4 and stated that not much of it

would remain following the construction of the M25 and any spare land should

be used for landscaping.

6. They considered that designating part of Sites H3, G4 and G5 for ARD would

be contrary to Slough Borough Council’s planning principles of improving air

quality, preventing through traffic, and protecting Colnbrook and Poyle villages

in a Green Envelope.

7. They confirmed that they had no objection to Sites F7, G8 (subject to no

access to the site being provided from the north or through Poyle Industrial

Estate) or H6, assuming the site would have access to a realigned A4.


15.3.63 The Colnbrook Community Partnership was the only community group to comment

on how ARD would best be delivered. They said that demand for terminal-based

hotel rooms and office space directly related to the airport’s operation should be

delivered by Heathrow through its DCO.




General Comments

15.4.1 The Herts and Middlesex Wildlife Trust stated that all ARD must deliver a

measurable net gain in biodiversity by applying the biodiversity impact calculator

or a similar locally approved metric.

15.4.2 West London Friends of the Earth expressed opposition to the Project highlighting

the impacts associated with ARD would be overwhelmingly negative and would

not be needed without a third runway.

15.4.3 Lambeth/Herne Hill Green Party did not comment on the sites identified for ARD

but stated local consultation on the sites is needed.

15.4.4 The Chartered Institute of Logistics and Transport highlighted that new hotel

locations should be chosen in part based on the ease of inclusion in the Hotel

Hoppa arrangements. They also stated that the Hotel Hoppa service should be

developed to use electric buses with opportunities for autonomous operation.

15.4.5 The Road Haulage Association said that existing lay-bys on surrounding roads are

inadequate for drivers to take rest breaks. They considered it essential that ARD

makes full provision for lorry parking, rest and hygiene facilities and places for

freight vehicles to wait to collect and deliver goods.

15.4.6 The Colne Valley Regional Park and the London Wildlife Trust commented that

hotels and offices should only be built within the airport boundaries or in urban

areas and be well-connected to Heathrow by public transport.

15.4.7 They suggested that any ARD sites should:

1. avoid land-take from the Colne Valley Regional Park, Green Belt and any other

protected sites;

2. provide strategic green corridors within the Colne Valley Regional Park and

cross boundary;

3. provide safeguarding buffer zones along the rivers for biodiversity benefit; and

4. provide habitat and recreational connectivity between green spaces and avoid

or reduce any impact on green/recreational space around local communities.


15.4.8 The Colne Valley Regional Park made the following detailed comments on the

sites identified in Heathrow’s Our Emerging Plans Document for ARD:

1. The development of Site A2 is unacceptable as the site is bordered by the

Colne and Duke of Northumberland Rivers. Heathrow should provide



clarification on how it will deliver a buffer to the rivers to reduce risk of pollution

incidents.

2. Site A4 contains an important buffer of Green Belt land, Saxon Lake and Grade

I agricultural land. Agricultural land needs to be protected, green infrastructure

on Harmondsworth Moor should be enhanced and a Green Belt buffer that can

provide strategic green and blue infrastructure connectivity between the Colne

Valley and the Crane Valley should be kept.

3. Site F1 has a watercourse running through its centre towards Staines Moor

SSSI and provides a green buffer between local communities. Heathrow

should explain what would happen if the watercourse to Staines Moor SSSI is

cut off and the effects of removing the recreational grounds north of Stanwell

Moor Village Hall from local use.

4. Site F7 is bordered by the Wraysbury River, buffer zones and there is a SSSI

to the east. Development on this site must consider proximity to two SSSIs and

allocate enough buffer zones for the Wraysbury River for a functional

ecological corridor.

5. Sites G4 and G5 include the Poyle Channel on the southern boundary and the

Colne Brook along the west. Buffer zones should be provided for all rivers.

6. Site G7 includes the Wraysbury River along the North West boundary

and buffer zones should be provided. The site could play an important role

for biodiversity to the south where the rivers emerge from under the

proposed runway.

7. Site G8 includes the Poyle Channel to the north and buffer zones should be

provided for the river. There is a former railway line to the west which could

form a new footpath and/or cycle route.

8. The River Colne runs through Site G9 and a river buffer zone should be

provided. The site is not isolated and is linked to the path network.

9. The Horton Brook flows through the northern part of Sites H1, H2 and H6

which also contains ancient woodland. The Colne Valley Trail and the Colne

Brook form the western boundary. These areas must be protected and any

developments must not damage or affect these features.

10. Site H3 includes the Colne Brook and Horton Brook and a watercourse along

the southern boundary. Buffer zones should be provided for all rivers. Any

development on this site should consider green areas around residential areas

and green wildlife corridors.



11. Site I5 provides an opportunity for a buffer zone adjacent to the River Colne

that can improve the connectivity between Mabey’s Meadow nature reserve

and green space to the west.

15.4.9 These comments were echoed by the London Wildlife Trust in relation to Sites A2,

A4, F1, F7, G7, G8, GP and I5. They also commented that Site C2 abuts

Huckerby’s Meadows Nature Reserve and as a result consideration needs to be

given to any ecological impacts and the wider River Crane corridor, as the land is

integral to the future ecological integrity of the nature reserve. They expressed a

preference for this site to be retained as potential mitigation land for habitat

enhancement.





consultees in relation to Airport Related Development5. None of the feedback received in relation to Airport Related

Development 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 15.1B


PC MC WC

Proposals for ARD should first consider the potential of existing business locations and what access improvements/public transport services could be provided to meet this need within a one hour travelling perimeter, utilising the sustainable transport links.

✓ Heathrow has undertaken research, with the Heathrow Strategic Planning Group (HSPG) input, to establish the scale of existing airport related development (ARD) today, which supports the airport, and to make predictions on the future scale of potential demand resulting from the airport’s expansion. The research identified the spread and scale of

Hotels and offices could be sited in Slough. These would have excellent transport link once the Western Rail Link to Heathrow was completed.

✓

The intensification of Park Royal could provide opportunities for ✓

5 Airport Related Development (ARD) refers to facilities such as hotels, offices and warehousing, for which we expect see an increase in demand because of Heathrow expansion. ARD sites could be inside or outside the airport boundary, and brought forward by either Heathrow as part of the DCO, if it meets the tests for Associated Development, or by other organisations outside of the DCO application process. 6 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees




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supporting airline services such as catering, due to the existing uses and skilled workforce already in place.

ARD around the airport. The research has also shown that in general terms businesses closer to the Airport are more likely to have a direct relationship between their operations and those of the Airport, in comparison to businesses located further away. However, the precise nature of the relationship must always be looked at on a case by case basis. Businesses located further from the airport were attracted not just by proximity to Heathrow but also the accessibility afforded by the M25/M4 and the proximity to London. They therefore had a more diverse customer base and a weaker relationship to the airport’s operations. Heathrow's view in relation to the functions and uses it is considering including in the Development Consent Order (DCO), is that empty buildings in adjacent town centres or more remote sites up to a one hour travel distance from the airport would not function effectively for the specific uses that Heathrow is seeking to accommodate. These locations will not therefore form part of our DCO application. We intend to include a number of sites for ARD within our DCO application where the proposed uses meet the criteria for Associated Development in Government guidance, and the sites are considered suitable for development. We are seeking to locate appropriate uses within the airport where space is available, but unused space is extremely limited. Moreover, some uses, such as Freight Forwarding for example, do not lend themselves to being on

Suggestion that a station at the centre of Staines-upon-Thames would offer the opportunity for airport hotels and international headquarters to be built there and linked to Heathrow with a 7-minute journey time.

✓

ARD could be located along the stations of the Piccadilly line and Crossrail.

✓

Alternative locations including Chertsey, Colnbrook, Feltham, Gatwick, London, Reading, Slough, Staines, West London, Woking and Hounslow are suggested for hotel development.

✓

Heathrow should reuse existing empty buildings and land for new office development in Hillingdon, Slough and Stockley.

✓

There is no need to acquire additional sites as the airport already has ample space. If more is required then Slough and London can meet this need.

✓

Heathrow should consider easily accessible locations close to the airport for ARD.

✓

Offices should be located away from the airport with better transport links.

✓

Options further from the airport which could stimulate economic growth and benefit the locality should be considered for ARD.

✓




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airport, but on sites outside the boundary but in close proximity to the airport. Heathrow is working closely with HSPG to assess the wider growth and infrastructure development which is likely to be generated by expansion. Planned rail and other transport improvements will improve the accessibility of surrounding areas to Heathrow, but are outside the scope of our DCO application. The potential for a new station and associated development at Staines is however relevant to the wider planning work which Heathrow is undertaking with HSPG. Our preferred masterplan will identify preferred sites for ARD and will be presented at Airport Expansion Consultation in June 2019.

Concern at the over-concentration of development on the airport itself and that Heathrow’s focus appears to be for new development.

✓ The primary focus of Heathrow expansion is delivering the proposed north west runway and associated airport infrastructure that would deliver new capacity, as set out in the Airports National Policy Statement (ANPS). However, beyond the primary aviation infrastructure there are other essential activities (such as elements of ARD) which support the efficient functioning and operation of the airport. We are seeking to make efficient use of land within the existing airport boundary, including by using land within the airport where possible. However, some new land outside the existing boundary will be required. Whilst not strictly ARD, the use of remote

ARD should be delivered elsewhere to stimulate the economy in other parts of the UK.

✓

None of the ARD selected sites were suitable and they are unnecessary. ✓

ARD would impact an already crowded and congested area. ✓

Concerns about the effects of ARD on the environment. ✓

Concern about the amount of land being taken for ARD. ✓

Concern regarding the impact of ARD on local towns and villages. ✓

Development north of the M4 or south of the A30 is not favoured. Both areas would conflict with the local population and compete for sites that would be better used for housing or other community needs.

✓




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Land to the south and east is not best placed to serve the future expansion plans

✓ logistics hubs - offsite centres for manufacture and pre-assembly across the UK - will help to spread the economic benefits of expansion to the whole country. Heathrow will justify the land it seeks to acquire as part of its DCO application as envisaged in the ANPS. Heathrow are carefully considering all consultation responses which raise site specific issues in relation to sites being considered for ARD. Our DCO application proposals are emerging through consultation and extensive engagement with local communities, statutory stakeholders and all interested parties. We recognise a project of this size will have potential effects on local communities and the environment which we will need to manage and mitigate, including by providing buffer zones where appropriate. Through a process of careful scheme selection and design we aim to limit the impacts of our physical masterplan as far as practical and to embed high quality design and mitigation into our proposals. Our preferred masterplan will be available at Airport Expansion Consultation in June 2019 and the Updated Scheme Development Report will explain which sites have been taken forward, and why.

Suggestion that an assessment of current provision of ARD would enable the amount of future use to be derived.

✓

None of the options are acceptable due to the massive land grab from Colnbrook and Poyle, and neighbouring communities.

✓

The impacts from the sites identified for ARD are overwhelmingly negative. Suggestion that an open area should be maintained to create a barrier between the airport and populated areas on its boundary.

✓

Opposition to the designation of all the land north of the Colnbrook Bypass, west of the lakes (Sites H1 and H2) for airport related development.

Opposition to expansion given the impacts associated with ARD would be overwhelmingly negative and would not be needed without a third runway.

✓

Local consultation on ARD sites is needed. ✓ Airport Expansion Consultation One included information on potential ARD sites and since then we have continued to engage regularly with HSPG, other stakeholders and local communities on all aspects of our masterplan.




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We will present a detailed preferred masterplan for further public consultation as part of Our Airport Expansion Consultation in June 2019 which will include the ARD sites selected. Please refer to Chapter 29 for a summary of engagement with third parties, including local communities.

ARD sites should avoid land-take from the Colne Valley Regional Park, Green Belt and any other protected sites.

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated as such. Any Green Belt land included in Heathrow's preferred masterplan proposals will need to satisfy the relevant tests, and Heathrow is considering carefully whether very special circumstances existing in relation to each individual site and use. Heathrow is seeking to minimise additional land take, including by utilising land within the airport where possible, and is also considering what mitigation may be necessary or appropriate in relation to any impacts on areas affected.

All ARD must deliver a measurable net gain in biodiversity by applying the biodiversity impact calculator or a similar locally approved metric.

✓ The detailed design of the preferred scheme (including ARD) will include appropriate amounts of replacement habitat as required by the ANPS and necessary to mitigate effects on ecology.

Concern that ARD and the construction of mitigation measures would ✓ The transport implications of sites being




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generate additional HGV traffic in the Ivers and Richings Park areas. considered for development are being thoroughly considered at every stage of the process leading up to our DCO application. This includes sites being considered for ARD. The Masterplan Scheme Development Manual (MSDM) sets out the process and methodology for developing the preferred masterplan and this includes transport in the evaluation criteria used to identify and evaluate scheme options. The chapter on masterplan issues contains further detail on this process. The outputs of the assessment process were reported in the Scheme Development Report at Airport Expansion Consultation One. We are having regard to responses to Airport Expansion Consultation One in developing the draft Surface Access Strategy and Preliminary Transport Information Report which will be available at Airport Expansion Consultation in June 2019. This will explain Heathrow’s preferred options for the transport infrastructure needed to support expansion 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. The DCO application will be accompanied by a full Transport Assessment (TA) which will analyse any transport effects and put forward any necessary mitigation measures. This will reflect our ongoing engagement with stakeholders and any responses to the Airspace

Transport accessibility should be a primary consideration when planning office locations.

✓

ARD should not be located in Horton and Poyle as local roads do not have the capacity to cope with current traffic levels.

✓

Stanwell has enough cargo warehousing and local roads will not sustain any further development.

✓

Public transport is poor in Horton and Horton Road to Junction 14 is already busy. The area is not suitable for ARD.

✓

Concern about the integration of ARD into the local transport system, making the best use of public transport and discouraging the use of private cars.

✓

Encouraging public transport and discouraging private car use were important considerations for the siting and integration of ARD both on and off airport.

✓

ARD outside the airport should be sited along public transport corridors linked to the airport and close to public transport hubs.

✓

Consideration should be given to providing public transport options tailored to the particular needs of airport users (e.g. transfer of luggage to and from the airport).

✓

ARD should be considered in the multi modal traffic model. ✓

Concern about existing public transport links for the proposed scale of development.

✓

Development should take place to the north and near major road junctions to avoid excessive local traffic.

✓

There should be a concentration of development alongside the M25/A4 ✓




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junction to take advantage of accessibility and visibility. and Future Operations Consultation in January and the Airport Expansion Consultation in June 2019 which relate to transport issues. Transport accessibility is an important factor when considering locations for future development, along with other important aspects including social, economic and environmental factors. The masterplan is being prepared on a multi-disciplinary basis with no pre-set weightings. The Surface Access Strategy will set out our proposals to encourage public transport, which will help to address both congestion and air quality issues. Heathrow is fully committed to meeting the public transport mode share targets contained in the ANPS. We are examining all feasible public transport options. The Surface Access Strategy will also consider opportunities to provide improved facilities for walking and cycling wherever feasible, although inevitably there will be restrictions on access within the airfield. The Heathrow shuttle bus service (Hoppa) and free travel zone around the airport play a major role in reducing private car usage and therefore congestion. In order to be included in the DCO application all proposed uses must be able to meet the tests set for “Associated Development” in government guidance, including demonstrating a direct relationship with the expanded airport. Heathrow is only able therefore to directly influence that element of ARD which is included

The area to the North East is too distant from the airport and transport links will be difficult to establish.

✓

Industrial and warehousing development will create congestion and will have a detrimental effect on residential areas and pollution.

✓

Hotels and offices should be located in areas served by public transport to minimise traffic.

✓

Sites for ARD should tie in with the local road strategy so that access to the airport is convenient and does not compromise efforts in tackling air quality and congestion.

✓

Existing lay-bys on surrounding roads are inadequate for drivers to take rest breaks. It is essential that ARD makes full provision for lorry parking, rest and hygiene facilities and places for freight vehicles to wait to collect and deliver goods.

✓

The area around the new runway and ARD should provide as few barriers as possible to walking and cycling.

✓

Commuter cycling access from residential areas in Richings Park and Iver and to the areas earmarked for ARD in Slough and Langley should be provided.

✓

Concern that connecting new hotels with private shuttle services would increase local traffic congestion.

✓




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in the DCO application. If sites are not included in the DCO application they could still be delivered by the market and through the Local Plan process, over which the local planning authorities have control. NB lorry parking is treated as an Airport Support Facility, not ARD. Our plans for lorry parking will be contained in the preferred masterplan which will be available at Airport Expansion Consultation in June 2019.

Heathrow Gateway Site would be an ideal location for a close, transport-linked hotel site.

✓ Heathrow is carefully considering all consultation responses which propose alternative or additional uses on land which is being considered for ARD. This will inform our decision making on whether to take these sites forward into the DCO application and what their potential uses might be. Our DCO application proposals are emerging through consultation and extensive engagement with local communities, statutory stakeholders and other interested parties. We recognise that a project of this size will result in some impacts to local communities and the environment, and Heathrow are committed to manage these effects wherever practicable. Through a process of careful scheme selection and design we aim to limit the impacts of our physical masterplan as far as practical and to embed high quality design and mitigation into our proposals.

Site 2 provides an opportunity to create a high-density mixed-use employment led development around a new Southern Access railway station.

✓

Site 3 has the potential for the intensification of industrial uses to service Heathrow whilst delivering employment and business growth for the borough.

✓

Site 5 has the potential to deliver industrial uses and is identified in the emerging plan as an Airport Business Park.

✓

Site 7 has the potential to intensify industrial uses. ✓

Consideration should be given to a site at the Airport Business Park for airport related logistics, warehousing and industrial uses.

✓

A number of sites in the west of the borough of Hounslow could help deliver a further 56,000 square meters of industrial floor space.

✓

Site 11 has the potential to provide not only hotel uses but offices, apartments, shops, bars and restaurants as part of the proposed

✓




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Heathrow Gateway development. Our preferred masterplan will be available at Airport Expansion Consultation in June 2019 and the updated Scheme Development Report will explain which sites have been taken forward, and why. In order to be included in the DCO application all proposed ARD uses must meet the tests set for “Associated Development” in government guidance and have a direct relationship with the expanded airport. Sites which are not included in Heathrow's DCO application but which are otherwise suitable for development may still be brought forward for development by others through the Local Plan process and via planning applications to the relevant local authorities. Heathrow is actively considering how to ensure that its proposals do not sterilise any land not included in the DCO for future development.

Site F7 is bordered by the Wraysbury River, buffer zones and there is a SSSI to the east. Development on this site must consider proximity to two SSSIs and allocate enough buffer zones for the Wraysbury River for a functional ecological corridor.

✓

A robust case to demonstrate very special circumstances is required to justify ARD in the Green Belt and the impact of development needs to be mitigated and compensated.

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated Green Belt. The ANPS is clear that large scale infrastructure projects located in the Green Belt may comprise inappropriate development. In considering the DCO application the Secretary of State will need to assess whether there are very special

Removal of restrictions on Green Belt allocations may be required to provide employment land.

✓

A large proportion of the land identified as potentially suitable for ARD falls within the Green Belt leading to requests for greater clarity on how development will be delivered on these sites.

✓

Site E3 lies within an area of strategic green belt and will need to be subject to a robust green belt case to outweigh the harm and ensure that noise, traffic and air quality are appropriately addressed.

✓




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Site E4 performs an important green belt function and the most practical form of ARD would be cargo facilities. The site is not considered suitable for other uses.

✓ circumstances to justify inappropriate development. Very special circumstances will not exist unless the potential harm to the Green Belt, and any other harm, is clearly outweighed by other considerations. Heathrow will be carefully assessing the suitability of any use proposed on Green Belt land and evaluating whether the relevant tests have been met. Heathrow are carefully considering all consultation responses which comment on the Green Belt function and importance of these sites. This will inform our own assessment which we plan to undertake of the role and function of any Green Belt sites which might be impacted by expansion. This assessment will ensure that all Green Belt sites are considered on a consistent basis and will form part of the Planning Statement which will accompany the DCO application.

Site F1 performs a moderate green belt function and the proposed hotels and offices must be designed to the highest standards and include landscape features to mitigate the impact of development.

✓

Site F2 performs a strong green belt function. It is also a safeguarded minerals and waste site where restoration is expected in 10 years. The creation of a new defensible boundary would be integral to the consideration of very special circumstances.

✓

Site F5 performs a moderate green belt function. It is an operational minerals and waste site with detailed restoration to high quality landscape with biodiversity areas complementing the natural areas of Staines Moor and the River Colne and with extensive public access required by 2023. The site does not have development potential.

✓

Site F7 performs a moderate green belt function and is partly used as a lorry park. Use of the site for more intensive development would need to enhance the setting of the Wraysbury River and adjoining SSSI.

✓

Site NS7 performs a weak green belt function. Development for ARD would not undermine the strategic function of the green belt and could provide the opportunity for environmental enhancement.

✓

Site NS8 performs a weak green belt function. The site has potential for residential or commercial development but also provides an opportunity for landscape enhancement.

✓

Any site would require proper connection to existing or new road networks and that any loss of land within the Lanz landholding would need to be considered.

✓ Heathrow is grateful to receive further information relating to prospective sites for ARD and on the specific site constraints, planning history and mitigation opportunities and requirements. The information provided is being

Site E3 is a Mineral Local Plan site with consent for extraction. Minerals would be extracted in advance of any development. It is located in the

✓




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green belt and has a former Roman Road adjacent to the site and Areas of High Archaeological Potential within 500m. It lies adjacent to a contaminated site and the Longford to Walton fuel pipeline affects the northern and western corners.

evaluated and factored into our decision making on which sites will be presented as part of the preferred masterplan proposals during the Airport Expansion Consultation in June 2019. Our DCO application proposals are emerging through consultation and extensive engagement with local communities, statutory stakeholders and other interested parties. We recognise a project of this size will have potential effects for local communities and the environment and which we will manage and mitigate wherever practicable. Through a process of careful scheme selection and design we aim to limit the impacts of our physical masterplan as far as practical and to embed high quality design and mitigation into our proposals. Where sites are proposed for inclusion in the DCO application their development will be included as part of a Transport Assessment to ensure that there are no unacceptable impacts on the local or strategic road network. Our Surface Access Strategy will ensure that suitable measures are implemented to encourage use of public transport and other non-motorised means of transport. The EIA which will accompany the DCO application will assess any likely significant environmental effects and put forward any necessary mitigation measures to reduce or manage these effects. Our PEIR will be available at Airport Expansion Consultation in June 2019. In developing the detailed plans for these sites, we

Site E4 is a restored former minerals site in the Green Belt. There site is potentially contaminated with engine oil from previous lorry dismantling activities.

✓

Site F1 lies in the Green Belt and is a restored minerals site. It lies within the Colne Valley Regional Park and the Thames Valley Biodiversity Opportunity Area.

✓

Should site F2 go ahead for development, compensatory provision should be made for extending the historic garden and SNCI and a woodland buffer to help mitigate the impact on Stanwell.

✓

Proposals for Sites NS7 and NS8 could have implications for traffic and air quality on Stanwell Fields Primary School that would need mitigation.

✓

Sites to the west of the M25 have limited development potential, priority should be given to businesses displaced due to the new runway and the M25 widening.

✓

The site to the north end of Lakeside Road should not include land north of the A4 Colnbrook bypass and would need to be re-connected to the A4.

✓

The area north of Gallymead Road would be suitable for uses that do not interfere with residential properties and the school. This site would require connection with Junction 14 of the M25 via a new road to the east of Poyle Industrial Estate.

✓

Not opposed to only some of Sites H1 and H2 being developed. ✓

Opposition to the use of land located between Colnbrook and the ✓




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existing Colnbrook Bypass (part of Site H3). This area should be reserved as a buffer with appropriately landscaped bunds or noise barriers.

will also ensure that the siting, layout and design of any built structures avoid sensitive areas and use landscaping and other measures to enhance the environment, wherever practicable.

Opposition to the use of part of Sites G4 and G5 for ARD as development of these sites would have a negative impact on Poyle and the Colne Valley Regional Park.

✓

Opposition to the use of Site H4 as not much of it would remain following the construction of the M25 and any spare land should be used for landscaping.

✓

Designating part of Sites H3, G4 and G5 for ARD would be contrary to Slough Borough Council’s planning principles of improving air quality, preventing through traffic, and protecting Colnbrook and Poyle villages in a Green Envelope.

✓

The area east of Gallymead Road has development potential but there is an existing proposal to support the Western Rail Link to Heathrow that would affect this land.

✓

The area south of Poyle New Cottages and east of the Poyle Industrial Estate could be suitable for the expansion of the Industrial Estate, improving connectivity to Junction 14 and internal roads but land between the new runway and north of Pippins Park is needed for a protective green envelope.

✓

ARD sites should provide strategic green corridors within the Colne Valley Regional Park and cross boundary.

✓

ARD sites should provide safeguarding buffer zones along the rivers for biodiversity benefit.

✓

ARD sites should provide habitat and recreational connectivity between green spaces and avoid or reduce any impact on green/recreational space around local communities.

✓




PC MC WC

The development of Site A2 is unacceptable as the site is bordered by the Colne and Duke of Northumberland Rivers. Heathrow should provide clarification on how it will deliver a buffer to the rivers to reduce risk of pollution incidents.

✓

Site A4 contains an important buffer of Green Belt land, Saxon Lake and Grade I agricultural land. Agricultural land needs to be protected, green infrastructure on Harmondsworth Moor should be enhanced and a Green Belt buffer that can provide strategic green and blue infrastructure connectivity between the Colne Valley and the Crane Valley should be kept.

✓

Sites G4 and G5 include the Poyle Channel on the southern boundary and the Colne Brook along the west. Buffer zones should be provided for all rivers.

✓

Site G7 includes the Wraysbury River along the North West boundary and buffer zones should be provided. The site could play an important role for biodiversity to the south where the rivers emerge from under the proposed runway.

✓

Site G8 includes the Poyle Channel to the north and buffer zones should be provided for the river. There is a former railway line to the west which could form a new footpath and/or cycle route.

✓

The River Colne runs through Site G9 and a river buffer zone should be provided. The site is not isolated and is linked to the path network.

✓

The Horton Brook flows through the northern part of Sites H1, H2 and H6 which also contains ancient woodland. The Colne Valley Trail and the Colne Brook form the western boundary. These areas must be protected and any developments must not damage or affect these features.

✓

Site H3 includes the Colne Brook and Horton Brook and a watercourse along the southern boundary. Buffer zones should be provided for all

✓




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rivers. Any development on this site should consider green areas around residential areas and green wildlife corridors.

Site I5 provides an opportunity for a buffer zone adjacent to the River Colne that can improve the connectivity between Mabey’s Meadow nature reserve and green space to the west.

✓

Site C2 abuts Huckerby’s Meadows Nature Reserve and as a result consideration needs to be given to any ecological impacts. Preference expressed for this site to be retained as potential mitigation land for habitat enhancement.

✓

ARD would have a positive effect on economic development and employment but potential increases in traffic and housing demand might arise. Strategies to address these issues must be developed.

✓

The scope of the planning for airport related facilities is supported. ✓ Comments duly noted.

Potential habitat loss will need to be considered for any ARD location or site.

✓ The policies in the ANPS, the National Planning Policy Framework (NPPF) and Local Plans apply to ARD, and this includes the effects of habitat loss. The PEIR which will be available at Airport Expansion Consultation in June 2019 will include an early assessment of habitat loss and indicative proposals for mitigation where relevant.

Sites A2 and A4 are adjacent to Harmondsworth Conservation Area and lie within the Heathrow Archaeological Priority Zone. Heathrow should give careful consideration to impacts on the conservation area and its setting.

✓ Heathrow is grateful to receive further information relating to prospective sites for ARD and on the specific information on heritage aspects which has been provided. The information provided is being evaluated and factored into our decision making on which sites

Sites A5, C2, G7 and E2 are within the Heathrow Archaeological Priority Zone and should be assessed for archaeological interest.

✓




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Site A7 is within the Sipson Archaeological Priority Zone and should be assessed for archaeological interest.

✓ will be presented at part of the preferred proposals during the Airport Expansion Consultation in June 2019. This will supplement our ongoing baseline studies of heritage assets which will feed into our PEIR, which will also be available as part of our Airport Expansion Consultation in June 2019. If sites are proposed for inclusion in our masterplan which might impact heritage resources, they will be fully evaluated in the ES which will accompany the DCO application. This will assess any significant likely environmental effects and put forward any necessary mitigation measures. In considering potential ARD sites which relate to heritage assets, Heathrow recognise the need to apply the policies set out in the ANPS (and where relevant the NPPF and local heritage policies).

Site B2 is adjacent to a number of listed buildings and Harlington Conservation Area. Heathrow should give careful consideration to impacts on the conservation area and its setting.

✓

Site C1 is adjacent to Harlington and Cranford Conservation Areas which contain a number of listed buildings. Heathrow should give careful consideration to impacts on the conservation areas and its setting.

✓

Site D1 is a large partly quarried site and should be assessed for archaeological interest.

✓

Site E1 lies within the East Bedfont Archaeological Priority Area and is likely to contain considerable archaeological potential. Any proposed development will require appropriate investigation to ensure that harm is not caused to the significance of the Scheduled Monuments.

✓

Encourage imaginative green infrastructure design to better reveal site E1’s (Mayfield Farm, which contains two Scheduled Ancient Monuments) significance as a potential positive benefit and offset harm elsewhere.

✓

Site E3 is wholly within and Site E4 is partly within a site of High Archaeological Potential.

✓

Site F2 includes a major undesignated Neolithic monument. ✓

Site G4 lies adjacent to the Colnbrook Conservation Area and there is a Grade II marker post in the south-western corner of the site. Heathrow should give careful consideration to impacts on these assets and their setting.

✓

Site G5 contains the grade II Poyle Farmhouse. Heathrow should give careful consideration to impacts on this asset and its setting.

✓




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Site H3 appears to be partly within the Colnbrook Conservation Area and contains two listed buildings. Heathrow should give careful consideration to impacts on these assets and their setting.

✓

Site I5 lies adjacent to West Drayton Green Conservation Area and the listed buildings within it.

✓

Site J1 lies within the Cranford Archaeological Area and includes a listed drinking fountain.

✓

Demand for ARD should be managed in close consultation with local planning authorities as part of the Local Plan process.

✓ Heathrow is working closely with HSPG to assess the wider growth which is likely to be generated by expansion. This wider growth will be brought forward independently of the DCO process. As well as the ANPS, Heathrow is having regard to the content of neighbouring Local Plans, as well as any emerging plans, although some of these do not take into the need for airport expansion. The timing of the Local Plan process is uncertain and there is a risk that the various Local Plans may not respond quickly enough and identify the additional land needed for ARD, particularly given the current Green Belt status of the sites. ARD is essential to support the efficient functioning of the airport so it is appropriate to include an element in the DCO application. This will ensure that sufficient land is brought forward in a planned and co-ordinated manner taking account all relevant planning considerations.

ARD should be integrated with the local plans of the adjacent local authorities, to ensure a plan-led approach to new development outside the boundaries of the expanded airport.

✓

Heathrow should work with its members to develop options that best align with Local Plans.

✓

Heathrow should be aware that the Joint Evidence Base and Infrastructure Study will identify demand arising from the airport and wider growth, and will inform the development of a joint spatial planning framework.

✓

Heathrow should consider evidence of other sites emerging through the proposed Joint Spatial Planning Framework to produce a holistic rather than a fragmented strategy.

✓

Heathrow’s plans should take account of local plans from local authorities and the Heathrow Strategic Planning Group.

✓

Consideration should be given to the longer term proposals for the land to be brought forward for residential led mixed use development within the West of the Borough Plan.

✓




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Confirmation requested that vehicle journeys to and from ARD locations will be classified as airport related traffic.

✓ The ANPS (paragraph. 5.17) public transport mode share targets apply to passengers and colleagues working at the airport




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Concern as to whether surrounding infrastructure will be sufficient to service the proposed ARD.

✓ Heathrow will assess the infrastructure demands which may arise from any ARD which is included in our masterplan and ensure that there is either adequate spare capacity in the network or make provision for any additional capacity required in our DCO application. We are also working closely with HSPG and are jointly undertaking a study to assess wider growth and infrastructure development which is likely to be generated by the Heathrow Expansion Project.




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Concern about the levels of traffic along the A30 and the M3 and that congestion will cause loss of local business.

✓ Heathrow are committed to meeting the public transport mode share targets as set out in the ANPS. We are assessing the transport implications of our emerging masterplan to ensure that there are no unacceptable impacts. The Airport Expansion Consultation in June 2019 will include our draft Surface Access Strategy and supporting technical information in the Preliminary Transport Information Report. The DCO application will be accompanied by a Transport Assessment and Surface Access Strategy to ensure that growth can occur without unacceptable impacts on the local and strategic road network.

The area south of Horton Road and west of the M25 may have potential for multiple uses including housing or hotel accommodation.

✓ Support for the use of these sites for various activities is welcomed. If Heathrow is satisfied that there is a need for ARD to support airport operations and that the uses proposed are suitable to be brought forward in these locations, then Heathrow may propose these sites for ARD in the preferred masterplan published in June. Heathrow will seek to acquire any sites proposed for inclusion in the preferred masterplan by negotiation with the landowner, if the land is not already in Heathrow's ownership or control. In the event that Heathrow cannot acquire sites by agreement Heathrow will consider including powers of compulsory acquisition in the DCO application. Compensation would be payable for land

Support for the of the use of Thorney Mill Road Aggregate Site (Old Aggregate Site & Thorney Sidings) for office development as it is well located and a transport management plan can be implemented.

✓

ARD will support local businesses and help to deliver economic growth both locally and nationally.

✓

Sites along the eastern boundary of Colnbrook-with-Poyle Parish Council have potential for longer term development, such as hotel accommodation, housing and footpaths.

✓

Housing or hotel accommodation would be appropriate in an area to the south of Horton Road, to the south west of the proposed runway.

✓

North East of the new runway would appear to be best for ARD due to its connections to existing road infrastructure.

✓




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The Coach Park on Horton Road has potential for multiple uses including businesses displaced by the new runway.

✓ acquired using compulsory acquisition powers. The updated property compensation policies will be published in 2019.

ARD can be built at Stanwell Moor but compensation should be paid. ✓

Landowners commented that they would be pleased to assist in exploring whether any of their landholdings could be designated as potentially suitable for ARD.

✓

The area around the airport is great for development and employment and that development should commence as soon as possible.

✓

An increase in demand for ancillary, associated development will generate employment opportunities. Heathrow must work closely with providers across the Thames Valley area to have the opportunity to help meet growing demand.

✓

Land at Hithermoor is an ideal location to link the proposed southern rail link to Heathrow and is well connected to the M25 via Junction 14 and should be considered for ARD.

✓

Support for car parking and ARD on underused land close to the expanded Airport.

✓

Green Acre Farm is currently within the Green Belt but the site should be made available for development as part of the expansion plans.

✓

No objection in principle to the development of sites and willingness expressed to work with Heathrow to take forward sites A4, A7, B1 and GC5.

✓

Indicative plans for Site GC5 have already been prepared. Suggestion that there was no case for Heathrow to use compulsory powers to acquire it.

✓

The acknowledgement of the development potential of the Sipson Farm site is welcomed and support expressed for the conclusion that it has limited value as Green Belt land. The site has the potential for a

✓




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significant volume of minerals to be extracted but that any such development should not prejudice the subsequent development of the site in the longer term.

Support for the inclusion of the Link Park Site at Thorney Mill Road for ARD.

✓

Poyle Manor Farm should be considered for the location of an increased supply of floorspace required directly or indirectly for the expansion of the airport.

✓

There will be a huge demand for hotel rooms and a lack of areas where they can be built. There is potential for a hotel on Green belt land.

✓

For site E4 there is an intention to bring the site forward at the earliest possible opportunity for employment-generating uses to support the function, ongoing viability and success of the airport.

✓

ARD should be built as soon as possible with no planning restrictions or delays and that the proposed sites were unlikely to be sufficient.

✓

No objection to Sites F7, G8 (subject to no access to the site being provided from the north or through Poyle Industrial Estate) or H6, assuming the site would have access to a realigned A4.

✓

Demand for terminal-based hotel rooms and office space directly related to the airport’s operation should be delivered by Heathrow through its DCO.

✓

Hotels should be located close to terminals and should be given priority over office developments.

✓ Hotels are an important form of airport related development, which support operations at the airport. It is important that we can rely on the timely delivery of a range of different hotels in different locations as airline and passenger numbers grow and the airport expands. The

Request that more distantly sited hotels should be near to town centres so that public transport links could be used.

✓

Hotels should be provided in a range of sizes and rental values to meet ✓




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the needs of a wide market and that the plans should encompass long term development needs and any future expansion.

airport relies on hotel rooms for passengers and colleagues, including airline crew. As the airport grows with expansion we need to replace the existing hotels which will be lost by expansion and provide new hotels to cater for the growth in airlines, passengers and cargo. Heathrow has undertaken research, with HSPG input, to establish the scale of existing airport-related development today which supports the airport, and to make predictions on the future scale of potential demand resulting from the airport’s expansion. The research identified the spread and scale of different types of hotels around the airport and sub-divided them as:

• Terminal-linked hotels: almost all of the hotel rooms at these hotels are likely to be predominantly used by passengers or colleagues at the airport, crew or other airport users;

• Bus-linked hotels: identified based on their connection to a direct and highly regular bus service to the terminals and located just outside the operational boundary. It is highly likely that up to 85% or more of customers are users or colleagues of the airport; and

• More distant hotels: serving airport users’ needs, which are often located further afield from the airport, but nonetheless partially related to Heathrow Airport. We estimate that around 35% of rooms in these hotels

Hotel development will have an adverse impact on the environment. ✓

Hotel sites could be provided in Stanwell Moor and Staines linked with high quality public transport.

✓

Existing hotel sites along Bath Road towards Colnbrook have capacity to expand.

✓

Request that Heathrow consider the plans for a Hilton Hotel and provide access to the site as part of the expansion project.

✓

Concern over Heathrow’s prediction that 8,300 new hotel rooms are required by 2040. This would continue a pattern of over-supply. There are currently in excess of 3,000 hotel rooms currently in the pipeline for construction between now and 2020.

✓

Due to the scheduled and planned improvements in transport infrastructure between central London and Heathrow, future demand for hotel rooms by those travelling to and from Heathrow is likely to be spread over a wider geographical area. Heathrow should work with hotel operators in order to learn from their experience and explore how the provision of bed spaces at existing hotel facilities can be maximised.

✓

Hotels are needed but environmental requirements must be met. ✓

New hotel locations should be chosen in part based on the ease of inclusion in the Hotel Hoppa arrangements.

✓

Hotels and offices should only be built within the airport boundaries or in urban areas and be well-connected to Heathrow by public transport.

✓




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are used by our passengers or colleagues.

Preliminary estimates of the number of hotel beds likely to be needed were included in Our Emerging Plans at Airport Expansion Consultation One, based on the degree of functional relationship with airport operations. The preferred masterplan which will be available at Airport Expansion Consultation in June 2019 will set out our proposals on the level of hotel provision required and the proposed location.

The Hotel Hoppa service should be developed to use electric buses with opportunities for autonomous operation.

The shuttle bus service not currently electric, but this is not something that is currently linked to our DCO application. We will examine opportunities in the future to replace this service with electric vehicles. Heathrow already operates a fleet of electric vehicles on the airport, and has over 80 charging points available to passengers, colleagues and airside vehicles.

Concern about the potential increase in house prices as a consequence of expansion and increased competition for property. This would be mitigated if jobs were located close to stations and bus routes.

✓ Our work has shown that any additional demand for housing resulting from Heathrow’s expansion will be negligible. The area around Heathrow is already projected to have significant population growth for which London and adjacent local authorities need to plan for. Heathrow’s expansion will help provide jobs for the increasing population but doesn’t require additional homes to be built.




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Heathrow is undertaking a study with HSPG to assess wider growth which is likely to be generated by expansion, including housing growth and is committed to increasing the proportion of journeys made to the airport by public transport, cycling and walking.

The needs of local people should take precedent over those of businesses.

✓ Heathrow are working closely with neighbouring local authorities and communities to avoid and minimise negative impacts on existing residential communities. Business needs are being balanced with social and environmental factors and do not take precedence.

ARD would operate for 24 hours per day further blighting and polluting the local area.

✓ The operating hours for ARD will be determined on a case by case basis according to the nature of the use itself and the relationship with airport operations

Locations identified for ARD have not considered economic viability factors and have prioritised land use analysis. Market factors and advances in aviation technology should be considered within the analysis.

✓ Economic viability and market factors are part of the criteria used to assess masterplan components and options. These are contained in the Evaluation Criteria which form part of Appendix B of the Masterplan Scheme Development Manual. Land use analysis has not been prioritized; the process is being undertaken on a multi-disciplinary basis with no pre-set weightings.

Heathrow has not done enough to limit the effects on its T5 Sofitel property. Heathrow has an obligation to protect businesses and provide alternatives.

✓ The T5 Sofitel property may be affected by expansion as it lies within an area which may be required to expand the western campus. We have developed a suite of Land Acquisition and Compensation Policies to help minimise and manage any negative impacts on affected




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properties. We are currently planning to include provision in the DCO application for a number of hotels to ensure that displaced accommodation is re-provided. Our land compensation policies are designed to help address any unavoidable impacts.

Alternative expansion proposals could achieve a 23% reduction in land take when assessed against the Heathrow’s proposals. It is unclear how Heathrow could call its proposals the most preferred when there is an alternative scheme that uses less land.

✓ Heathrow’s plans have been through the scrutiny of the rigorous independent Airports Commission and Government’s further analysis as part of the ANPS process. 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 is developing its preferred masterplan for expansion working closely with communities and is carefully considering efficient use of land. We do not believe that there is a credible alternative scheme which would use less land. Our preferred masterplan will be presented at our Airport Expansion Consultation in June 2019.

Requests to meet with Heathrow to discuss land proposals. ✓ We are continuing to meet affected landowners on a regular basis and have agreements in place with a number of them. Our preferred masterplan, including our proposals for supporting infrastructure, will be presented at Airport Expansion Consultation in June 2019.

Heathrow should engage with surrounding landowners in order to achieve the best design and delivery of the required supporting infrastructure for the expanded airport. This could be managed through a framework between Heathrow and local landowners.

✓

Expansion will provide demand for ARD which will generate local ✓ Comments duly noted.




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growth and employment.

Heathrow should use a variety of firms from across the UK to ensure that all areas could achieve some prosperity from Heathrow Expansion and develop a sustainable approach to supporting local firms.

✓ Heathrow will be the first major infrastructure project in the UK to pioneer the large-scale use of logistics hubs – aiming to build as much of the project off-site as possible and helping businesses across the country to become part of our supply chain. To support local firms, for over 20 years we have held the annual Heathrow Business Summit to connect local small and medium sized businesses (SMEs) to our supply chain, and help them win business from our largest suppliers. We are committed to continue this event over the course of the Project, and have in recent years expanded the Summit programme to include additional events across the UK.

Future development should be led by market demand and undertaken by those with the greatest experience and best track record for this type of development.

✓ Heathrow is one of the UK’s most experienced major infrastructure investors, and over the last decade has successfully delivered Terminal 5 and Terminal 2. In 2018, passengers named us as the Best Airport in Western Europe, Terminal 2 as the World’s Best Terminal and Terminal 5 as the fourth best terminal in the world. We have achieved our highest passenger satisfaction scores on record – with 84% of passengers rating their experience as “very good” or “excellent”. We will include sites for ARD in our DCO application if a site meets the relevant tests for Associated Development, in accordance with Government guidance. If consented, there are then options on how this might be delivered.




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The current Stanwell recycling facilities should be retained rather than being used for ARD, as the aggregate recycling services provided are likely to be essential for the sustainable construction of the expanded Heathrow.

✓ The Stanwell aggregate recycling facilities will be retained as long as possible because this facility does have potential to contribute to construction of the Project. Our current thinking is that the site is likely to be required for other construction purposes.

Concern expressed over the identification of a properties for the provision of ARD. Request current uses should be retained.

✓ Current land uses and planning consents will be retained wherever possible but inevitably a number of properties will need to be acquired for airport expansion, given that this is a densely developed part of the South East. If the Project results in any implications for existing planning consents these will be assessed in accordance with the tests set out in the ANPS (paragraph. 5.111). We are still developing our preferred masterplan, which will be presented at Airport Expansion Consultation in June 2019.

Request that the development of Site E1 should not conflict with the consent for the provision of a 426-guestroom hotel.

✓

Sites on north western edge of the airport would be more suitable for corporate office space.

✓ Our current view is that this area is best suited to construction related land uses, not corporate offices, because the northern western edge of the airport is immediately adjacent to the rail line and the third runway and is therefore ideally located to support construction. Suitable construction sites are very limited and our view is that this should take precedence over other types of development which could be located in a number of potential locations.

Objection to land uses being restricted to those prescribed or required to service Heathrow.

✓ ARD land uses selected for inclusion in the DCO application will be those that are directly related to the airports operation and which are required to support its efficient functioning. To

Sites (D1, D2 and HS3) have been identified as being suitable for ARD but given the current demand these sites need to be developed

✓




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irrespective of the third runway. There would be objections to airport-related user restriction on these sites as they could equally be required for a range of sector needs, not all of which were airport related.

be included in the DCO, they must meet the tests for Associated Development according to government guidance. If adequate ARD uses are not included in the DCO, there would be a negative impact on the operation of the airport.

Whilst sites are suitable for ARD, land uses must not be restricted to those prescribed or those required by the expansion project. Reserving the land for Heathrow’s related or ancillary uses is not justified as there is a need for other commercial developments, emerging business demands and substantial housing growth.

✓

Request that the impacts on certain hotels be kept to a minimum and that improvements to the local road network would be required to support further development.

✓ Inevitably expansion will impact a number of hotels. We are currently planning to include provision in the DCO application for a number of hotels to ensure that displaced accommodation is re-provided.

With a realigned A4, the area around the M4 junction and M4 spur would be an ideal opportunity for a gateway development for the expanded airport. This area has the potential to be the entry point to Heathrow and should not accommodate relocated support facilities.

✓ We are not currently planning provision for any gateway development around the M4 spur because this does not meet the criteria for ARD. However, as we develop our designs in detail and select a preferred masterplan we will ensure that any uses proposed in prominent locations create the right "entry point" to the airport and are sympathetic to neighbouring uses and the environment. Our preferred masterplan will be available at Airport Expansion Consultation in June 2019.

Careful design consideration is required to ensure that properties are retained to avoid the need to relocate businesses and compensation claims coming forward.

✓ We are attempting to minimise the number of properties affected by expansion through careful site selection and design. Our land compensation policies are designed to help address any unavoidable impacts.

Concern that little consideration had been paid to the proposals ✓ Heathrow is engaging regularly with Hounslow




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included within Hounslow’s ‘West of the Borough Plan’. The airport must carefully consider the provisions of the emerging planning policy framework and seek to work with Hounslow Council and landowners to deliver the vision for development within this part of the Borough.

Council, through HSPG and on a bilateral basis. We are seeking to develop proposals that meet both the needs of the Project and the Council’s aspirations for specific development in the Borough.

Heathrow should acknowledge there is insufficient land within the existing parameters to meet its development requirements and that it is imperative to work with adjacent land owners to secure suitable locations for new development without compromising local council development aspirations and existing planning consents.

✓ Heathrow is engaging with affected landowners and is seeking to acquire any land needed by negotiation. We are also working with adjacent landowners and local authorities to ensure as much compatibility as possible between our plans.

Given the timings of expansion, immediate action is needed to address additional floorspace demand. Heathrow’s floorspace demand assessment be integrated with the Councils’ (that are members of the Heathrow Spatial Planning Group) own ‘business as usual’ assessments to establish a complete picture of total demand.

✓ We are working quickly to progress the DCO application, engaging with communities, landowners, and other interested parties at every stage of the process. We are engaging regularly with HSPG and other interested parties. Rather than relying on existing information, which takes no account of expansion, we have undertaken research with HSPG to understand additional floorspace demand which will be driven by expansion. The local authority has powers to respond to any immediate demands for additional floorspace.

There is already sufficient business and hotel accommodation within easy access of the airport and no more is needed.

✓ Our research suggests that expansion will generate demand for additional floorspace.

Proposals should consider accessibility, people with learning disabilities and ensure that public spaces are designed to be autism-friendly.

✓ In accordance with legal and best practice in relation to accessibility, the ANPS requires our DCO application to include clear details of how plans will address the accessibility needs of all passengers and colleagues, including those with physical and/or mental impairments as well

Further information is needed on how Heathrow would ensure that businesses looking to support the Airport will seek to employ disabled

✓




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employees. as older users. This information will be contained in our Design and Access Statement which will accompany the DCO application. We will publish our preliminary thoughts in a Jobs and Skills Information Paper at Airport Expansion Consultation in June 2019.

Indirect growth associated with the project is a greater risk to the open space network than the runway because much of this growth could be ad hoc without any overarching plan. As a result, Heathrow must assess and seek to mitigate the negative impacts of this associated growth.

✓ Heathrow is not responsible for other development that may come forward, and the DCO cannot control development that is outside of the scope of the application. The relevant local planning authorities are able to control new development via the planning process. Planning policy already contains strong protection for green belt and public open space. Heathrow is engaging with the HSPG to seek to ensure that updated local plans come forward in a timely manner to guide future applications for development in the surrounding area in an appropriate way.

Site F1 has a watercourse running through its centre towards Staines Moor SSSI and provides a green buffer between local communities. Heathrow should explain what would happen if the watercourse to Staines Moor SSSI is cut off and the effects of removing the recreational grounds north of Stanwell Moor Village Hall from local use.

✓ It is a requirement of the Water Framework Directive to protect and enhance biodiversity associated with the water environment and we are seeking to comply with this requirement. We will publish our PEIR at Airport Expansion Consultation in June 2019.

The importance of ARD in supporting the airport ecosystem is recognised as is the importance of identifying areas where this could be accommodated.


The delivery of ARD should be demand and market led and that Heathrow should only consider doing so where there would be significant benefits.

✓ Agreed, Heathrow has undertaken demand and market research to determine the future need for ARD and will only include ARD in the DCO




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application where this is necessary and appropriate, all the relevant tests are met and there would be operational and other benefits from its inclusion.

Support for the proposal not to bring forward multiple ARD sites in the Ivers area due to potential harm to the Colne Valley Regional Park.

✓ Support noted.

Support for the development of new terminal-linked hotels and the expansion of office space within the borough.

✓ Support noted.

At least 160,000 sq. m of additional office space could be accommodated within the Hounslow side of the Heathrow Opportunity Area.

✓ Noted. ARD land uses selected for inclusion in the DCO application will be those that are directly related to the airport's operation, which are required to support its efficient functioning and which meet the other tests set in government guidance. Other sites within the Hounslow Opportunity Area could make an important contribution to meeting wider needs.

Consideration of the wider impact of expansion on the local and wider economy welcomed.

✓ Support noted. Heathrow is undertaking a study with HSPG to assess the wider growth which is likely to be generated by expansion. The local authorities will then need to plan for this growth in their Local Plans.

Development at Heathrow should be restricted to areas with a functional link to its operations.

✓ ARD land uses selected for inclusion in the DCO application will be those that are directly related to the airport’s operation, which are required to support its efficient functioning and which meet the other tests set in government guidance.

Heathrow have constrained themselves by only considering locations very close to the airport.

✓ The DCO application will focus on areas close to the airport because our research suggests that these locations are most suitable for the




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uses which Heathrow has identified as being necessary to support the operation of the airport. .

All potential ARD sites north of the A4 should be reserved for the proposed rail depot and possible relocation of Grundon’s Waste Management Facility.


Whilst there is no support for development on sites near Colnbrook Village, there is support for sites east, west and south of Poyle Trading Estate.

✓ Support for sites east, west and south of Poyle Trading Estate is noted. The proposed runway and taxiways extend into land north and south of the A4, near Colnbrook and two temporary construction support sites are under consideration near Colnbrook as these would be located close to the main construction zone.

In developing the Scheme that will be presented in the Development Consent Order (DCO) application, Heathrow has been undertaking a process of evaluating many options, including potential use of the sites referred to. In doing so, the full range of environmental disciplines




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are included within the evaluation criteria (as outlined in the Scheme Development Report). This has and will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the environmental effects of the construction phase and community impacts, including impacts on existing uses.

The PEIR, which will be published as part of the Airport Expansion Consultation (June 2019) will identify any potential effects associated with the site and any mitigation measures. This will include consideration of any potential effects on Colnbrook associated with construction sites, as set out in the Scoping Report (May 2018). Consultation feedback will be taken into account in producing the Environmental Statement (ES) which is submitted with the DCO application.

The use of the area to the west of Poyle Road is not supported as it would bring new development onto greenbelt land close to residential properties

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated Green Belt. Any Green Belt land included in Heathrow's preferred masterplan proposals will need to satisfy the relevant tests, and Heathrow is considering carefully whether very special circumstances exist in relation to each individual site and use. Suitable buffers

Green Belt land should not be used to accommodate ARD. ✓




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will be employed next to residential properties, if required, to avoid any impacts on amenity.

The area south of Popes Close and east of Horton Road would interrupt mineral restoration. Any further development in connection with this site would add to the sense of enclosure by ARD.

✓ We recognise that a project of this size will create some impacts for communities and the environment, which we are committed to manage and mitigate. Through a process of careful scheme selection and design we aim to limit the impacts of our physical masterplan as far as practical and to embed high quality design and mitigation into our proposals.

Traffic associated with a railhead or aggregate uses is unacceptable. ✓ 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 options for the 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. Use of the rail head, and the use of remote logistics hubs around the UK which will consolidate materials for transport, are expected to considerably reduce HGV traffic during construction.



16. CONSTRUCTION

16.1 Introduction

16.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback

in relation to the potential construction sites and the approaches to managing

the effects of construction. A total of 848 consultees made comments relating to

this topic.

16.1.2 Heathrow provided the following material that is directly related to the potential

construction sites and the approaches to managing the effects of construction:




16.1.3 Within Section 16 of the Our Emerging Plans Document Heathrow identified a

number of potential construction sites. References to Option Numbers below are

taken from the Our Emerging Plans Document.

16.1.4 Heathrow asked the following question regarding the sites and approaches to

managing the effects of construction:

1. Please tell us what you think about the sites we have identified as potential

construction sites and the approaches we are considering to manage the

effects of construction.

















Local Authorities

General comments

16.2.1 A range of detailed comments were received from local authorities on the

approaches to managing the effects of construction and the potential construction

sites. The majority of comments highlighted the importance of reducing the impact

of construction on local communities and the need for a construction

environmental management plan (CEMP).

16.2.2 The London Borough of Brent welcomed the intention to ensure a sustainable

approach to construction. They supported the production of a Code of

Construction Practice and commitments to using low emission vehicles. They

went on to express concerns about the impact of construction workers on local

traffic levels and suggested that the construction workforce should be encouraged

to use public transport or car-share whenever possible.

16.2.3 Buckinghamshire County Council expressed support for the movement of

construction materials by rail and indicated that this should be written into tender

documents for Heathrow’s main works contractor(s). They also noted that if lake

restoration of Borrow Pits is preferred it will need to be designed not to encourage

nesting birds.

16.2.4 Ealing Council commented that appropriate channels of communication must be

established with key stakeholders to ensure efficient and effective management

and control of construction related activity.

16.2.5 Hampshire Services who responded on behalf of the Central and Eastern

Berkshire Authorities recognised the importance of utilising nearby materials.

They noted that it is important to do so in a sustainable and efficient way that limits

the potential impacts on local communities. They also highlighted that

consideration should be given to the source of the materials for infilling as part of

restoration and that there was a need for a more comprehensive statement about

the use of recycled materials in order to reduce the need for new aggregates.

16.2.6 They recognised the importance of rail freight to reduce movements by road and

welcomed the potential for the construction rail depot to be used as an aggregate

rail depot to serve the wider Thames Valley area in the future.

16.2.7 The London Borough of Hounslow commented that all car parking should be to the

west of the airport to encourage workers based in London to use public transport.

It went on to highlight that construction worker access by public transport and the

timing of HGV movements to avoid network and school peaks require further

consideration.



16.2.8 They also indicated that construction must not impact river environments and that

site plant, vehicles and site operations should be in accordance with relevant

sustainability, emission and environmental health standards, and carbon neutral

if possible.

16.2.9 Kent County Council supported the use of rail freight to import bulk materials to the

construction sites but indicated that these should avoid any disruption to peak

passenger services. It also supported the other construction practices put forward

that could reduce the impacts of construction on local communities, on local and

strategic traffic, air passengers and the environment. They also expressed support

for apprentices and training programmes for people local to both the airport and

the use of logistics hubs.

16.2.10 The Royal Borough of Kingston-upon-Thames identified that the key challenge will

be the timely delivery of effective mitigation capable of dealing with the increased

numbers of people and the impacts on the local and national transport networks of

congestion and environmental impacts including during the construction period.

16.2.11 South Bucks District Council highlighted the proximity of the main construction

sites and expressed concerns that they could result in pressure on housing, traffic

and services. It is suggested that permanent housing should be constructed for

workers close to good public transport locations, which can be reused for

affordable housing in the future.

16.2.12 The South East Councils expressed concerns about the risks of increased traffic

congestion and pollution and greater pressure on local services during

construction. They highlighted the need for more comprehensive proposals for

transport investment, performance targets for noise and air pollution and proposals

for infrastructure that will be needed to support local communities.

16.2.13 Slough Borough Council supported the overall approach to construction but

highlighted a number of detailed points that it felt should be considered further.

1. Slough should benefit from the majority of apprenticeship schemes that will be

run by construction companies awarded contracts.

2. A dedicated low emission bus service should be implemented to transport

construction workers along the A4, linked to the Slough Mass Rapid Transit

(MRT) A4. It should be accessible to the whole community during the day and

weekend.

3. Detailed air quality impact assessments should be carried out including for

heavy good vehicle (HGV) movements on the public highway.



4. All construction vehicles must meet Clean Air Zone (CAZ) standards as they

will need to travel through the M4 Air Quality Management Area (AQMA) and

Brands Hill AQMA.

5. Construction HGV Routes shall be agreed and legally binding and enforceable

though Automatic Number Plate Recognition (ANPR) cameras they shall avoid

Colnbrook, Poyle and Langley Villages.

6. All plant and equipment above 37kW shall meet Non-Road Mobile Machinery

(NRMM) London Standards on site.

7. All Cement batching works should take place a minimum of 400m from

residential properties to avoid dust impacts.

8. Dust and Particulate monitoring should be carried out on construction site

boundaries and beyond if necessary within residents gardens.

9. A CEMP must be developed and consulted on with Slough and other

neighbouring authorities to ensure all practicable measures to minimise

environmental harm are taken.

10. There should be enforceable noise limits that cannot be breached during the

construction phase.

11. Consideration to temporary housing and compensation should be given for

residents who are significantly impacted by the construction work.

12. Construction operating hours should be legally binding, night time works

shall only be permitted for special operational circumstances (i.e. wide loads)

and emergencies.

13. Care should be taken in the siting (and hours) of floodlights to avoid glare and

nuisance impacts to residents.

14. Adequate provision must be made for temporary accommodation for

construction workers as part of the overall strategy in order to avoid existing

residential areas becoming swamped with Houses in Multiple Occupation.

16.2.14 Spelthorne Borough Council made a number of suggestions about the content of

the CEMP. This included that it should include traffic management measures

(including designated routes for HGVs), site management, accommodation for

workers and effective communications to minimise effects on local residents.

16.2.15 Spelthorne Borough Council suggested that Heathrow must ensure robust plans

were in place to minimise any temporary impacts on local roads and local

communities during construction of a new runway.



16.2.16 The Royal Borough of Windsor and Maidenhead considered that the impact of the

mineral extraction (‘grab pits’) sites within the Borough were not adequately set

out. It commented that together with Reading Borough Council, Bracknell Forest

Council and Wokingham Borough Council it was preparing a Minerals and Waste

local plan for the combined area and that the sites identified by Heathrow were

being considered through this process. They highlighted that additional sites to

supply Heathrow’s needs should be identified which do not compromise the

councils’ capacity to meet local needs.

16.2.17 They requested further information on the timescales for use of the borrow pits

and the capacity of the transport network to cope with transport to and from the

construction sites.

16.2.18 They also raised concerns that the construction phase would generate additional

pressure on the existing housing stock and indicated that any proposals for the

airport should include detailed provisions to address this issue.

16.2.19 Wokingham Borough Council considered that the principles outlined were sound

and will help to minimise additional construction traffic. Essex County Council also

welcomed that the consultation document sought to demonstrate an appreciation

of the likely impacts during the construction phase.

Comments on specific sites

16.2.20 Hampshire Services who responded on behalf of the Central and Eastern

Berkshire Authorities highlighted that the borrow pits identified within the Royal

Borough of Windsor and Maidenhead are under consideration as part of the

preparation of the Central and Eastern Berkshire Joint Minerals and Waste Plan to

meet the demand for aggregates within the plan area. They highlighted that

consideration should be given to other sources of aggregates outside the area of

JCEB minerals and waste plan area.

16.2.21 The London Borough of Hounslow requested assurance that Sites C2 and D2 as

detailed in Heathrow’s Our Emerging Plans Document were adequate and that

further sites to the east of airport would not be to be identified. They noted that

Site D2’s proximity to residential development may make it unsuitable.

16.2.22 Slough Borough Council did not provide specific comments on the sites identified

but highlighted the following areas that it considered should either be avoided or

should be a focus for construction activities:

1. The area north of the runway and A4 should be one of the primary areas for

construction activity focused upon the rail head.

2. The area south of the A4 within the Colnbrook “Green Envelope” should not be

used for construction because of the need to protect existing residents and the



school and carry out appropriate planning and mitigation measures as soon as

possible.

3. The area south of Poyle Trading Estate could be used as a temporary

construction site provided there is no traffic routed from here through

Colnbrook and Poyle.

16.2.23 Spelthorne made a number of comments on the sites identified:

1. Sites F1, F2 and F5 as detailed in Heathrow’s Our Emerging Plans Document

should be used temporarily as opposed to being permanently developed but

even temporary work could have a detrimental effect on biodiversity and Green

Belt functions.

2. Even temporary work could have a detrimental effect on biodiversity and Green

Belt functions. F2 and F5 should be avoided if possible due to their higher

biodiversity value.

3. The site south of Horton Road and north of King George VI Reservoir is

bounded to the north and west by residential properties. These are very

sensitive to odour issues, noise and vehicle movements from the site. Oak Leaf

Farm, as the site is known, is a historic landfill known as Land South of Horton

Road Landfill. Widespread serious contamination is unlikely and contamination

is unlikely to constrain development, particularly in respect of any construction

related uses.

16.2.24 Surrey CC commented that Site F2 as detailed in Heathrow’s Our Emerging Plans

Document is an extant mineral site that is being backfilled with inert waste to

facilitate restoration with an existing recycling facility. They indicated that

Heathrow’s proposals would result in the loss of garden/open space and habitat

areas created as part of the recent 10-year extension of recycling on the site and

would need to be compensated.

16.2.25 They also commented that Hithermoor Quarry (Site F5 in Heathrow’s Our

Emerging Plans Document) is a land raised mound of waste that has been subject

to longstanding restoration and woodland planting. They indicated that there

should be additional environmental compensation for losses that in effect would

put the clock back. They identified that the site includes a SNCI (Greenham’s

Fishing Pond), that there is archaeological potential on the northern part and that

part of the site could be a potential route for Southern Rail Access.




General comments on approach

16.2.26 The Environment Agency highlighted that appropriate pollution prevention

measures should be put in place during construction to protect the environment.

They also highlighted that the construction of the new runway and associated

development will likely generate significant volumes of waste and as a result

material re-use should be maximised to minimise waste where appropriate.

16.2.27 Historic England identified that until further details were available in relation to

access points for both road and rail, it was not possible to comment meaningfully

on any potential effects on the historic environment. In relation to the criteria set

out for the selection of potential construction sites, it recommended that Heathrow

make a commitment that sites should not have an adverse impact on any

designated or non-designated heritage assets.

16.2.28 Highways England expressed concerns about the impact of construction activities

on the Strategic Road Network. They considered that if demand on sections of the

network was not managed, the impact would be to displace other traffic which

would have a serious impact on road network and drivers. As a result, they wanted

consideration to be given to managing down demand from other airport uses so

that displacement would be contained within the overall demand of the airport.

16.2.29 They also commented that during each phase of construction the necessary road

infrastructure and traffic management measures should be put in place to maintain

the safe and effective operation of the network. Construction plans should also

take into account works by other parties elsewhere on the transport network and

which have the potential to affect the Heathrow area.

16.2.30 They also requested that Heathrow share its construction plans and proposed

vehicle movement strategy prior to the DCO application and provide more

information on the location of the logistics hubs and their associated impacts.


16.2.31 The Heathrow Strategic Planning Group (HSPG) highlighted that greater

consideration should be given to construction impacts over an extended period,

with further emphasis on how to manage the workforce. They indicated that there

was a need for a coordinated construction strategy which should include the

following:

1. Construction worker accommodation – including ‘Olympic model’

legacy housing.

2. Travel plan for workers.



3. An assessment of local impacts on the housing market and social cohesion –

including changes in tenure and occupation of family housing to shared letting,

HMOs etc.

4. Action to stop unauthorised temporary housing camps with caravans,

mobiles etc.

5. Temporary HGV and LGV routes and parking arrangements.

6. Rail network usage – a presumption that construction material will be

transported by rail and investigation of rail head options.

7. The phases and duration of each construction stage.

8. Consideration to other major infrastructure projects within the area together

with their construction programmes.

9. special consideration for Iver which is already subject to an array of major

infrastructure projects.

16.2.32 The Royal Mail highlighted that a number of its sites will be affected during

construction works and requested that Heathrow engage with them at the earliest

opportunity identify the impacts on its operations, mitigation measures and agree a

formal process for ongoing dialogue.

16.2.33 Network Rail recommended that planning of the proposed railhead with Network

Rail and the railway industry on the Colnbrook Branch to service the construction

of the Project should commence now.

16.2.34 Bray Parish Council considered that the construction proposals were badly thought

out and that sufficient discussion or review of the areas involved has not taken

place. They cited the proposed ‘borrow pits’ in Old Windsor which are either

located on Crown owned working farmland or on the site of the sewerage pits that

serve the whole of Windsor.

16.2.35 Colnbrook with Poyle Parish Council highlighted the importance of regular on-

going dialogue with stakeholders, and transparency in areas that are not

commercially confidential. They also expressed concern that the proposals appear

to be maximising development land-take and that carparks and construction sites

all need to be moved out of the development area, mainly in the Parish of

Colnbrook with Poyle.

16.2.36 Iver Parish Council expressed concern that disruption to traffic during the

construction phase will be considerable and will displace traffic onto local

residential roads. They indicated that the Parish already suffers from intolerable

levels of traffic, especially HGVs and OGVs and rat-running caused by motorway

congestion and that the area cannot tolerate any further increases.



16.2.37 Chobham Parish Council highlighted that minimising disruption to the local

residents and businesses should be biggest concern.


16.2.38 Thames Water Utilities Limited highlighted that it owns the freehold of the majority

of the Ham Island potential borrow pit site. It expressed support for the

identification of the site as a potential borrow pit site but highlighted that any

proposals must not detrimentally impact upon the Sewage Treatment Works

operations and will need to carefully consider potential archaeological remains.

16.2.39 They also highlighted that consultation with the Reservoir Safety Team will need

to be undertaken in order to understand if there would be any stability concerns

associated with the potential borrow pit immediately east of the Queen Mother

Reservoir.

16.2.40 They also commented that there was insufficient detail in relation to some of the

construction sites, specifically Sites 5, 6 and 11 as detailed in Heathrow’s Our

Emerging Plans Document. They identified that once the detail of these sites is

known consultation should be undertaken with the Reservoir Safety Team to

understand whether there are any concerns.



General comments

16.3.1 Almost two thirds of members of the public that made comments in relation to

construction expressed concerns about the impacts of the Project on the local

area or stated that the measures or sites proposed for construction were

unsuitable or unnecessary.

16.3.2 The concerns raised were wide ranging and comprised impacts on local

communities at Stanwell Moor, Longford, West Drayton, Colnbrook, West London,

Harlington and Sipson, effects on health and well-being, the duration of the

construction period, impacts on the environment and existing land uses, impacts

on traffic flow, congestion and local roads and impacts on the local economy.

16.3.3 Members of the public also raised concerns about construction working hours.

This comprised suggestions that these should be limited to between 09:00-17:00

and that weekend working should be avoided. Contrary comments were also

received which suggested that 24/7 working should be introduced as this will

cause less disturbance, enable the project to be delivered sooner and account for

time to be made up when the project is delayed.



16.3.4 Members of the public also expressed general support for the proposed

approaches to managing construction or sites identified though these were not

clarified or expanded upon.

16.3.5 As well as raising general concerns or expressing support for the proposed

approaches to managing construction or sites identified, some members of the

public provided suggestions about factors that should be considered further, these

comprised:

1. effects on air pollution and noise pollution need further consideration;

2. effects on the environment should be minimised;

3. impacts on wildlife and habitats should be minimised;

4. effects on local communities should be minimised;

5. effects on local roads should be minimised;

6. construction time should be reduced as much as possible;

7. prefabricated construction should be used as much as possible;

8. construction sites should be sited as close to the airport as possible;

9. construction sites should be reclaimed and restored post construction;

10. advance planning and logistics should be employed;

11. construction workers should use low emission vehicles;

12. sites that become brownfield after construction should be used for residential

development or community facilities;

13. consideration should be given to phasing of the construction sites;

14. the houses which are up for sale now should be bought and used for the

temporary workers during the construction;

15. construction screens/hoardings should be adorned with art displays from

local artists;

16. construction should be outsourced to countries with a proven track record;

17. construction should boost local jobs by encouraging apprenticeships and

providing training for young people;

18. measurable SMART criteria must be set out that will hold the contractors

responsible; and

19. the Crossrail and HS2 considerate constructor schemes have developed

standards for employment and these examples should be followed.




16.3.6 Few members of the public provided specific comments on the proposed

construction sites. Those that did focussed on the sites at Ham Island and

Stanwell Moor.

16.3.7 Members of the public expressed concern about the suitability of the western sites

on Ham Island and Southsea Farm due to their proximity to property and likely

impacts on traffic in Datchet and Runnymead. Members of the public also

considered that Ham Island was not suitable as a borrow pit as the access is via a

congested residential road which cannot cope with extra traffic. A specific concern

was also raised about the potential borrow pit BP-19 which it was considered

would affect the scenic entrance into Datchet from Old Windsor.

16.3.8 Members of the public commented that Stanwell Moor land should not be used as

a construction site as it will destroy existing greenery and wildlife which will not be

restored. Respondents commented that traffic must avoid Stanwell and there

should be no use outside normal hours.

16.3.9 A suggestion was received that Site F7 could provide multiple-land uses during

construction including car/lorry parking and construction base, notably for (M25

works) whilst post-construction the site could be repurposed to accommodate

businesses/land use displaced by the third runway.

16.3.10 Members of the public raised specific concerns that Old Windsor is unsuitable as a

construction route as it is a single-track road and bridge.

16.3.11 Members of the public also suggested that one of the construction sites to the

south of the existing airport would be ideal for a purpose-built construction workers

camp, that West Drayton is a suitable location for construction sites given the

highway links/connections and that land around the reservoirs (Staines and

Wraysbury) should be considered for construction locations to the south-west of

the airport.

Businesses

General comments

16.3.12 Segro requested that construction sites are located as close to the third runway as

possible to reduce travel distances for construction traffic and ensure they do not

conflict with key cargo and freight routes. They highlighted that Heathrow should

explore the re-use of the freight line at Colnbrook Logistics Centre that was used

to transport bulk goods for the construction of Terminal 5 as this could help to

mitigate the number of vehicles required during construction.




Representatives UK expressed support for a sustainable approach to construction.

They identified that minimising the impact of construction on the current operation

and running of the airport must be a key consideration and will require close

coordination with the Airline Community. GlaxoSmithKline indicated the

construction period will be lengthy with significant disruption, varying in type and

extent. They highlighted that car-based travel to either the airport or their other

sites will be affected and there will be a need for mitigation measures to offset any

negative impact on this throughout the construction period.

16.3.14 Land North of Moor Lane Harmondsworth sought clarity on how any local

road diversions or infrastructure works involving their site would be delivered

and whether these works would be approved as part of the development

consent process.

16.3.15 Heathrow Hub highlighted that the options assessment of the various road and

runway options should contain information on how construction could be carried

out without major disruption to traffic, the arrangements for remediation or removal

of contaminated material that is required and the noise impacts of a runway

elevated above ground level.

16.3.16 The Arora Group also made similar comments, highlighting that no reference had

been made to the predicted construction costs. They considered that this made it

impossible to respond meaningfully to options and approach as the costs and the

benefits cannot be analysed. They went on to request that cost estimates and

transparent information on each of the components be published.

16.3.17 The Thames Valley Chamber of Commerce emphasised the importance of

Heathrow delivering against its promises to ensure that impacts are minimised.

They also questioned what is being done to identify, source and train the next

generation of skilled labour that will be needed during construction and by 2030.

16.3.18 Fulcrum Pipelines identified that trial holes and hand digging was required during

construction to locate their assets. They also requested that if their assets are

exposed during construction adequate protection (e.g. sand covering) should be

inserted once work is completed. They also highlighted that additional costs may

be incurred if the plant has to be relocated due to construction works.

16.3.19 Heathrow Airport Fuel Company Limited highlighted that appropriate provisions

will need to be put in place during construction to minimise and manage the risks

and ensure access is maintained to and from all relevant facilities at all times.

16.3.20 The Fuel Trading Company highlighted that renewable diesel should be used

during construction wherever possible to reduce emissions.



16.3.21 The Heathrow Hydrant Operating Company highlighted that any fuel related

developments will need to be implemented in line with stringent codes and

standards and without creating any detrimental impacts on the quality or supply of

aviation fuel at Heathrow.

16.3.22 Passiflora expressed concerns about the effects of construction on their business

and indicated that this disruption will have financial consequences.

16.3.23 Virgin Atlantic Airways Limited (Virgin) highlighted that it would not support any

phasing plan that places it at a competitive disadvantage, due to sub-optimal

quality of its facilities compared to other airlines or sub-optimal infrastructure for

transfer passengers moving between terminals.


16.3.24 Hatton Garden Trustees Limited and Pickering Properties Limited considered that

the temporary construction site north east of the airport boundary has the potential

to limit the scale and potential of car parking at the adjacent Terminal 1-3. They

highlighted that if this site is taken forward as a construction site access to the

Magnatex and Pionair sites must not be impeded.

16.3.25 The Lanz Group commented that the construction site identified on land north of

Harmondsworth Lane may be an appropriate site and indicated that they would be

willing to discuss the inclusion of the Sipson land within this designation to ensure

connectivity with the new airport.

16.3.26 Goodman commented that its land to the north of the A4 Colnbrook Bypass has

the potential to perform a role as part of managing the construction stage, in

advance of its permanent use for airport related development. They considered

that this land was unlikely to be suited for use as a borrow pit due to its landfill

history and that the site has previously been confirmed by the Secretary of

State as capable of accommodating successful rail freight connectivity and rail

freight facilities.

16.3.27 Jayflex Construction Limited considered that its site at Horton Brook Quarry,

Colnbrook would be suitable as a site to aid construction or for use as an

aggregates borrow pit. They highlighted that the site would be suitable as a

location for the development of replacement housing and light industrial units that

will require relocation because of the Project.

16.3.28 Cappagh Companies highlighted that the current recycling use of Stanwell

Recycling Facility should be retained for the period of construction as the

aggregate recycling services at this site are likely to be essential for the

sustainable construction of the expanded Heathrow.



16.3.29 Lapithus Hotels Managements UK Limited expressed concerns about the use of

land immediately to the west of Holiday Inn M4/J4 as potential site for

construction, borrow pits and stockpiling. They considered that this would have a

material impact on the hotel throughout the period of the construction but

highlighted that the impact could be minimised if construction workers were

encouraged to use the hotel during construction.

16.3.30 Harleyford Aggregates Limited highlighted that Heathrow’s proposals at Mayfield

Farm (Site E2 in Heathrow’s Our Emerging Plans Document) do not acknowledge

the safeguarded status of the mineral resource and are therefore contrary to the

requirements of the NPPF, the London Plan and the adopted Local Plan. They

also highlighted that Mayfield Farm has the potential to play a significant role in

supplying construction aggregates for the project but does not appear to have

been considered.

16.3.31 The Brett Group supported the use of its land at Hithermoor for temporary

construction and logistic. They highlighted that the land could also be used for

stockpiling of construction materials and recycled inert materials.

16.3.32 Poyle Manor Farm requested that consideration be given to a separate application

for temporary permission for airport related car parking on land at Poyle Manor

Farm during the construction period, in order to meet demand for those travelling

to the Airport by private car.

16.3.33 Segro supported the use of the northern part of the Colnbrook Logistics Centre

(Site H6 in Heathrow’s Our Emerging Plans Document) as a temporary

construction site. They requested further information on the timescales and

phasing for the use of this site and what will happen to the site when it is no longer

needed for construction uses.

16.3.34 Segro highlighted that it did not support the use of its site at Hatton Cross (Site D2

in Heathrow’s Our Emerging Plans Document) for temporary construction given its

location is unsuitable and unsustainable in relation to the third runway. They

considered that this site would be suitable for providing low-occupancy supporting

uses (Class B1c/B8), such as warehouse storage and lorry parking.

16.3.35 Suez UK indicated support for the temporary use of its land at Holloway Lane and

Harmondsworth Lane.

Community groups



include specific feedback relating to the sites and approaches to managing the

effects of construction.



General comments

16.3.37 SCR Residents for a Fair Consideration of Heathrow Expansion expressed

concern that the volume of traffic required during construction will severely impact

local residents and road users. This concern was echoed by the Ealing Aircraft

Noise Action Group.

16.3.38 Englefield Green Action Group expressed concerns about the effects on the local

roads, highlighting that the potential construction sites will put pressure on badly

maintained local roads as motorists try to avoid the inevitable congestion caused

by the Project.

16.3.39 The Hitcham and Taplow Society suggested that there should be a ban on

construction traffic travelling to and from Heathrow along the Bath Road (A4) over

the ancient and much-valued Maidenhead Bridge. They highlighted that in the

event of a temporary closure of the M4 this bridge is the only current alternative

route to Heathrow from the west and this should be considered in Heathrow’s

assessments.

16.3.40 Northumberland Walk Residents Association expressed concern that the effect of

the proposals on Richings Park had not been sufficiently considered. They

highlighted that further consideration should be given to the potential for increased

traffic on the local area during diversion of the existing roads, the effects of

additional traffic and HGVs on noise, air pollution and road safety and noise and

visual impact from a temporary construction site south of Richings Park, which

they considered would likely operate 24 hours per day.

16.3.41 Harrow U3a Sustainability Group welcomed the proposals for rail freight, pre-

booked delivery slots, workers' bus services, off-site assembly, construction code

of practice, training, skills, site safety, workers' rights and apprenticeships.

16.3.42 Local Conversation in Stanwell highlighted that the effects of the temporary

construction sites and the sites where development is taking place must be

effectively controlled to minimise the effects on local communities and the local

environment. They went on to highlight that where the loss of a local

wildlife/biodiversity site does happen there should be a commitment to provide

alternative sites around Stanwell and Stanwell Moor.

16.3.43 Camberley Society highlighted the need to minimise damage to the environment

and the Pavilion Association for Stanwell and Stanwell Moor highlighted that the

construction approach should minimise effects on local people.




16.3.44 The Colnbrook Community Partnership expressed opposition to the proposed

construction sites north of the communities of Colnbrook and Poyle (Sites H3, CS-

1 and CS-2 in Heathrow’s Our Emerging Plans Document) due to their proximity to

residential properties, Colnbrook Conservation Area, Pippins Park, Albany Park,

St. Thomas’s Quiet Garden and Colnbrook Recreation Ground. They considered

that these sites did not meet Heathrow’s criteria for construction sites set out in

Our Emerging Plans and that the area should be reserved as a buffer with

appropriately landscaped bunds/noise barriers. They also considered that Site G1

would not meet the requirement set out in Our Emerging Plans for borrow pits.

16.3.45 The Colnbrook Community Partnership were ‘not opposed’ to the use of Sites H1,

H2, H6 and F7 as temporary construction sites or to the use of Site G3 as a

borrow pit. They indicated that HGV movements should be south on Poyle Road

and not along the Old Bath Road to avoid residential areas.

16.3.46 Stanwell’s Green Lungs expressed concern that the construction sites at Stanwell

and Stanwell Moor will destroy existing greenery and wildlife which will not be

restored as construction land identified is planned to be re-used as part of the

overall development plan.


General comments

16.4.1 The Colne Valley Regional Park identified that construction has the potential to

seriously affect and sever the Colne Valley Regional Park. They considered that

impacts should be minimised by returning temporary construction sites to use in

service of the park’s objectives and treating topsoil in a way that will allow for land

to be returned to its pre-construction state or better.

16.4.2 They also considered that the reputational impact of construction on the Park must

also be mitigated and requested that Heathrow provides funding to appoint a

Marketing & Community events officer throughout the construction period.

16.4.3 Friends of the River Crane accepted that planning and design work would seek to

minimise risks and impacts but indicated that there remains a residual risk and

inevitable impacts associated with construction activities on surface water

pollution, open land valued for its environmental and community value and from

the creation of new gravel extraction sites in the local area.

16.4.4 The London Wildlife Trust made similar comments to the Colne Valley Regional

Park identifying that construction has the potential to significantly impact and

fragment the natural environment in and around the airport. They highlighted that

all temporary construction sites should be returned to wildlife habitats (or other



multi-functional green infrastructure) as part of the final masterplan. They also

identified that soils should be treated in a way that will allow land to be returned to

its pre-construction state or better.

16.4.5 The Buckinghamshire and Milton Keynes Natural Environment Partnership

commented that Heathrow should maximise biodiversity, habitats and ecosystem

benefits through clever and careful location and design of infrastructure and during

construction and operation.

16.4.6 The Lambeth/Herne Hill Green Party suggested that Heathrow should be guided

by environmental experts at all levels to manage the impact of construction.


16.4.7 The Royal Parks identified that the location of a construction site south of the

airport will be adjacent to the river. They commented that these sites must be

managed properly and take into account the proximity to the River.

16.4.8 Surrey Wildlife Trust commented that Site F7 as detailed in Heathrow’s Our

Emerging Plans Document would impact the Staines Moor SSSI and West of

Poyle Meadows SNCI. They also commented that Site F2 as detailed in

Heathrow’s Our Emerging Plans Document would impact the Stanwell II SNCI.





consultees in relation to Construction. None of the feedback received in relation to Construction 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 16.1B


PC MC WC

Reducing the impact of construction on local communities is important.

✓ ✓ In developing its proposals Heathrow is seeking to minimise the impact of construction on local communities as far as practicable. Heathrow aims to manage potential impacts to people, businesses and the natural and historic environment during construction through measures outlined within the Code of Construction Practice (CoCP). Heathrow will consult on the draft CoCP as part of the Preliminary Environmental Information Report (PEIR), to be published as part of the Airport Expansion Consultation in June 2019, and will engage with statutory bodies on its content before this. In developing the Scheme that will be presented in the Development Consent Order (DCO) application, Heathrow has been undertaking a process of evaluating many options, including the location and size of construction sites.

The effects of the temporary construction sites and the sites where development is taking place must be effectively controlled to minimise the effects on local communities and the local environment.

✓

Minimising disruption to the residents and businesses should be the biggest concern.

✓

Concern about the duration of the construction period.

✓

Concern about existing land uses. ✓





PC MC WC

It is important that Heathrow deliver against its promises to ensure that impacts are minimised.

✓ In doing so, the full range of environmental disciplines are included within the evaluation criteria (as outlined in the Scheme Development Report). This has and will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the environmental effects of the construction phase and community impacts, including impacts on existing uses. The DCO application will comply with the Airports National Policy Statement (ANPS) and will include an Environmental Statement (ES) to explain how Heathrow will identify and mitigate any likely significant environmental effects during construction of the airport. The ES will assess potential impacts on local communities associated with each phase of construction by undertaking a community impact assessment (CIA). Heathrow will also employ good practice management and delivery systems to manage the effects of construction. Measures will be developed to avoid or reduce the likely impacts of construction on communities and the environment as the DCO application becomes more developed. Heathrow will employ a variety of measures to reduce the effects of many activities taking place at the same time, including use of rail freight to import goods and materials for construction, reducing the vehicle movements and effects on local roads and use of on, near and off-site logistic hubs. In terms of the duration of the construction phase, the PEIR will provide information on specific areas where the construction activities are adjacent to residential areas. It will set out which construction activities are to take place at the areas identified, and the potential length of time for which these elements would be required. As part of the Environmental Impact Assessment (EIA) process, a CoCP 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 programme, such as construction noise, dust generation and traffic management.




PC MC WC

There is a need for infrastructure that will support local communities.

✓ The likely impacts of the Project on local communities are being considered through a community impact assessment, which will form part of the ES to be submitted with the DCO application. It will identify effects on people, homes and community facilities/ public services (including schools), public open space and routes (including recreation) as a result of the construction and operation of the Project. A draft of the CIA will be included in the PEIR, which will be published as part of the Airport Expansion Consultation in June 2019. Heathrow will develop a community compensation fund (CCF) in accordance with the ANPS.

Concern about the risks of increased traffic congestion and pollution and greater pressure on local services during construction.

✓ Heathrow will employ a variety of measures to reduce the effects of numerous construction activities taking place at the same time, including use of rail freight to import goods and materials for construction, reducing the vehicle movements and effects on local roads and use on, near and off-site logistic hubs and measures to encourage construction workers to use public transport, including additional construction-dedicated services to avoid congestion on existing services. As part of the DCO application, Construction Workforce Travel Plans will be developed to encourage the use of the public transport and sustainable modes of transport, and Construction Logistics Plans will also be developed. The PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 will provide further detail in relation to effects arising from congestion and pollution during the construction phase, including proposed mitigation and monitoring measures, which will be set out in a draft CoCP. The likely impacts of the Project on local communities are being considered through a CIA, which will form part of the ES to be submitted with the DCO application. It will identify effects on people, homes and community facilities/ public services (including schools), public open space and routes (including recreation) as a result of the construction and operation of the Project. This will include the potential for effects on public services associated with the provision of new worker accommodation, which the Scoping Opinion from the Planning




PC MC WC

Inspectorate (PINS) highlighted as an important consideration. A draft of the CIA will be included in the PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

The construction sites could result in pressure on housing, traffic and services.

✓ Heathrow’s location in London benefits from a well-developed housing market and public transport links, so the requirement for construction accommodation facilities is less than for more remote infrastructure construction sites. The majority of the construction workforce are expected to be drawn from the existing construction labour market and would not require accommodation to be provided. Heathrow is considering the possibility of using accommodation owned by Heathrow in the areas around the site for accommodating construction workers. Given existing networks, a significant proportion of the construction workforce would travel to site each day by public and sustainable transport modes. Existing bus routes could be supplemented by the Project to preserve capacity for other passengers. Where a route terminates at a Heathrow surface transport hub, internal bus services could transport the workforce from the Central Terminal Area (CTA) to their work location. As part of the DCO application, Construction Workforce Travel Plans will be developed to encourage the use of the public transport and sustainable modes of transport. The likely impacts of the Project on local communities are being considered through a CIA, which will form part of the ES to be submitted with the DCO application. It will identify effects on people, homes and community facilities/ public services (including schools), public open space and routes (including recreation) as a result of the construction and operation of the Project, this will include the potential for significant effects on public services associated with the provision of new worker accommodation, which the Scoping Opinion from PINS highlighted as an important consideration. A draft of the CIA will be




PC MC WC

presented as part of the PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

The key challenge will be the timely delivery of effective mitigation capable of dealing with the increased numbers of people and the impacts on the local and national transport networks of congestion and environmental impacts including during the construction period.

✓ Heathrow recognises the need to manage and mitigate the increased numbers of people, impacts on the transport network and environmental impacts during the construction period. The full range of environmental disciplines are included within the evaluation criteria in the Masterplan Scheme Development Manual in June 2018. This will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the construction phase. The DCO application will include an ES to explain how Heathrow will identify and mitigate any likely significant environmental effects during construction of the airport. The PEIR, published as part of the Airport Expansion Consultation in June 2019 will provide further details on potential significant effects during the construction phase and proposed avoidance, monitoring and mitigation measures, including in relation to the community. This will be accompanied by a draft of the CoCP that will include consideration of the matters highlighted in this response. This will make clear when mitigation measures will be put in place to ensure they are delivered in a timely manner. A Construction Workforce Travel Plan will also be developed to encourage the use of the public transport and sustainable modes of transport.

The construction environmental management plan should include traffic management measures (including designated routes for HGVs), site management, accommodation for workers and effective communications to minimise effects on residents.

✓ As part of the EIA, a CoCP will be prepared, which will outline how construction activities will be managed and address the matters raised in the comments, including hours of working and relevant standards. This document will set out the requirements for mitigation and the monitoring of potential environmental impacts throughout the construction programme, such as HGV parking areas, hours of




PC MC WC

Appropriate pollution prevention measures should be put in place during construction to protect the environment.

✓ working, construction noise, pollution control and dust generation. and traffic management and routing. Heathrow is considering the nature and extent of working hours including the potential for extended working hours associated with constructing the project and will present further information on this in the draft CoCP at the Airport Expansion Consultation in June 2019. The draft CoCP will also include a commitment to the use of considerate constructor schemes.

The need for a construction environmental management plan is important.

✓

Damage to the environment should be minimised. ✓

Temporary HGV and LGV routes and parking arrangements is needed as part of a coordinated construction strategy.

✓

Concern about construction working hours. Suggestion that these should be limited to between 09:00-17:00 and that weekend working should be avoided.

✓

Suggestion that 24/7 working should be introduced as this will cause less disturbance, enable the project to be delivered sooner and account for time to made up when the project is delayed.

✓

The duration of construction activities should be minimised.

✓

In respect of construction and the sites identified, measurable SMART criteria must be set out that will hold the contractors responsible.

✓

In respect of construction and the sites identified, the Crossrail and HS2 considerate constructor schemes have developed standards for employment and these examples should be followed.

✓

Support expressed for the use of rail freight to import bulk materials to the construction sites but

✓ The support for the use of rail to import construction goods and materials, is noted. Heathrow acknowledges the need to ensure that




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these should avoid any disruption to peak passenger services.

the use of rail freight avoids disruption to peak passenger services by utilising available train paths on the rail networks. The PEIR, to be published as part of the Airport Expansion Consultation in June 2019 will provide more information on assumptions about the role of the rail network.

Support for the movement of construction materials by rail. This should be written into tender documents for Heathrow’s main works contractor(s).

✓ The support for the use of rail to import goods and materials is noted. Further work is required with Network Rail to establish capacity. Much of the material required for construction will be transported from Logistic Hubs located across the UK. The draft CoCP will be published as part of the Airport Expansion Consultation in June 2019 will include relevant measures and standards of work. Implementation of the CoCP will be monitored by Heathrow.

Rail freight is important to reduce movements by road.

✓ Heathrow welcomes recognition of the vital contribution rail freight will play in reducing the need to move goods by road. The PEIR, to be published as part of the Airport Expansion Consultation in June 2019 will provide more information on assumptions about the role of the rail network.

The potential for the construction rail depot to be used as an aggregate rail depot to serve the wider Thames Valley area in the future is welcomed.

✓ Heathrow is considering the potential role of rail aggregate depots to support the construction of the Project. Further detail will be presented in the PEIR which will be published as part of the Airport Expansion Consultation in June 2019.

Support for the other construction practices put forward that could reduce the impacts of construction on local communities, on local and strategic traffic, air passengers and the environment.

✓ Support for the other construction practices put forward in Our Emerging Plans (January 2018), presented as part of Airport Expansion Consultation One in January 2018 is welcomed.

A presumption that construction material will be transported by rail and investigation of rail head options is needed as part of a coordinated construction strategy.

✓ Heathrow is investigating how to optimise the use of a relocated railhead to move construction materials. Further detail will be presented in the PEIR which will be published as part of the Airport Expansion Consultation in June 2019.

It is recommended that planning of the proposed railhead with Network Rail and the railway industry

✓ Discussions have been undertaken with Network Rail in relation to the railhead and will continue as the Project develops. Further detail will be




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on the Colnbrook Branch to service the construction of Heathrow Expansion should commence now.

presented in the PEIR which will be published as part of the Airport Expansion Consultation in June 2019.

In respect of construction and the sites identified, construction should boost local jobs by encouraging apprenticeships and providing training for young people.

✓ Heathrow has set up a Skills Taskforce under the leadership of Lord Blunkett, bringing together schools, colleges, universities, unions, local authorities and the voluntary and private sectors to deliver recommendations to help shape the airport’s future employment and skills strategy. The Taskforce published its recommendations in September 2018 and Heathrow will respond in 2019. A focus of Heathrow’s skills strategy will be on how expansion can deliver 5,000 additional apprenticeships. This is consistent with paragraph 5.263 of the ANPS (June 2018), bringing the total to 10,000 by 2030. Support for apprentices and training programmes for people local to the airport is welcomed.

What is being done to identify, source and train the next generation of skilled labour that will be need during construction and by 2030?

✓

Support for apprentices and training programmes for people local to the airport.

✓

Slough should benefit from the majority of apprenticeship schemes that will be run by construction companies awarded contracts.

✓

Support for the use of logistics hubs. ✓ Support for the use of logistics hubs is welcomed. Logistics hubs will be delivered with the aim of increasing off site activities and overall productivity and spreading the economic benefit of the expansion project. Remote sites would assist Heathrow to manage the flow of materials and workforce with the objective to maximise productivity and reduce adverse effects on the public, the environment and airport operations.

Request that Heathrow provide more information on the location of the logistics hubs and their associated impacts.

✓ Heathrow has started a process to identify locations for four regional logistics hubs. Following a call for expressions of interest, Heathrow published a longlist of over 60 potential locations. Heathrow has visited each of these sites in 2018. Heathrow is continuing to evaluate the sites and a shortlist will be announced in 2019.




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The intention to ensure a sustainable approach to construction is welcomed.

✓ Support for a sustainable approach to construction and site management, the production of a CoCP and commitments to using low emission vehicles is welcomed. Heathrow will consult on the draft CoCP as part of the PEIR to be published as part of the Airport Expansion Consultation in June 2019, and will engage with statutory bodies on its content before this.

Support to produce a Code of Construction Practice and commitments to using low emission vehicles.

✓

A sustainable approach to construction is supported.

✓ ✓

General support for the proposed approaches to managing construction or sites.

✓

Concerns about the impact of construction workers on local traffic levels. The construction workforce should be encouraged to use public transport or car-share whenever possible.

✓ The ES will assess potential effects associated with the Project including potential for journey delay, congestion and severance as well as the potential for increased usage of public transport services. The Transport Assessment will include consideration of the impact of construction workers on local traffic levels. A significant majority of the construction workforce would travel to site each day by public and sustainable transport modes. Existing bus routes could be supplemented by the Project, or Project-dedicated services provided, to preserve capacity for other passengers. Where a route terminates at existing Heathrow surface transport hubs, internal bus services could transport the workforce from the CTA to their work location. As part of the DCO application, Construction Workforce Travel Plans will be developed to encourage the use of the public transport and sustainable modes of transport. The PEIR to be published as part of the Airport Expansion Consultation in June 2019 will set out early findings regarding the assessment of such impacts and proposed mitigation.

All car parking should be to the west of the airport to encourage workers based in London to use public transport.

✓ The ANPS (paragraph 5.17) requires that any application for development consent and accompanying airport surface access strategy must include details of how Heathrow will (from a 2013 baseline level) achieve a 25% reduction of all colleague car trips by 2030, and a reduction of 50% by 2040; therefore reducing the need for car parking.




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The draft Transport Assessment and PEIR to be published as part of the Airport Expansion Consultation in June 2019, will provide further detail in relation to construction worker car parking and will explain how public transport provision will be improved and enhanced so that Heathrow can meet the passenger mode share and colleague car trip targets set out in the ANPS.

Further consideration of construction worker access by public transport and the timing of HGV movements to avoid network and school peaks is required.

✓ Heathrow recognises the need to avoid network and school peaks. A draft CoCP will be published as part of the Airport Expansion Consultation in June 2019 and this will include more information on proposed transport arrangements for construction workers. As part of the DCO application, Construction Workforce Travel Plans will be developed to encourage the use of public transport and sustainable modes of transport, and Construction Logistics Plans will consider the timing of HGV movements.

A travel plan for workers is needed as part of a coordinated construction strategy.

✓

A dedicated low emission bus service should be implemented to transport construction workers along the A4, linked to the Slough Mass Rapid Transport A4. It should be accessible to the whole community during the day and weekend.

✓ Construction Workforce Travel Plans will be developed to encourage the use of public transport and sustainable modes of transport. The use of low or zero emission vehicles is being considered as part of the development of these plans. It is not anticipated that such services would be available to the wider community.

Appropriate channels of communication must be established with key stakeholders to ensure efficient and effective management and control of construction related activity.

✓ As part of the development of its proposals, Heathrow is undertaking an ongoing programme of engagement with key stakeholders, partners and community groups. This engagement will help inform Heathrow’s preferred masterplan and its approach to the management and control of construction activities. Engagement with the Heathrow Community Engagement Board (HCEB) will also ensure the widest possible community engagement throughout the planning process for expansion and longer-term into the construction and operational phase of the expanded airport. It will play an important role in engagement between the airport and its communities and ensure Heathrow delivers on its commitments today and in the future. This approach is in accordance with the ANPS




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(paragraph 5.258) which is clear that the HCEB should be engaged throughout the planning process. HCEB, the Heathrow Strategic Planning Group (HSPG) and others, including the Greater London Authority, Natural England, Highways Agency and Historic England will receive an early draft of the CoCP for review and comment in December 2018 and comments will help shape the draft CoCP which will be made available as part of the Airport Expansion Consultation in June 2019.

Construction must not impact river environments. ✓ Heathrow is committed to protecting the quality of river environments during both construction and operation and is working with the Environment Agency and other third parties to deliver appropriate solutions. The construction phase will accord with the environmental objectives of the Water Framework Directive (WFD), which are reiterated in the ANPS at paragraph 5.184. The ANPS identifies the need to prevent the deterioration in status of water bodies and not to jeopardise the future achievement of good status for any affected water bodies. Further information on the construction phase and potential significant effects on river environments will be provided in the PEIR which will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

The location of a construction site south of the airport will be adjacent to the river. These sites must be managed properly and take into account the proximity to the River.

✓

The impact of the mineral extraction (‘grab pits’) sites within the Royal Borough of Windsor and Maidenhead were not adequately set out. Reading Borough Council, Bracknell Forest Council and Wokingham Borough Council are preparing a Minerals and Waste local plan for the combined area and that the sites identified by the Heathrow were being considered through this process. Additional sites to supply Heathrow’s needs should be

✓ Heathrow is continuing to develop its construction strategy which includes relevant earthworks and is seeking to minimise the use of off-site locations wherever practicable. Further information will be presented as part of the preferred masterplan in our Airport Expansion Consultation in June 2019.




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identified which do not compromise the councils’ capacity to meet local needs.

The borrow pits identified within the Royal Borough of Windsor and Maidenhead are under consideration as part of the preparation of the Central and Eastern Berkshire Joint Minerals and Waste Plan to meet the demand for aggregates within the plan area. Consideration should be given to other sources of aggregates outside the area of JCEB minerals and waste plan area.

✓

Ham Island was not suitable as a borrow pit as the access is via a congested residential road which cannot cope with extra traffic.

✓

Concern about the potential borrow pit BP-19 as it could affect the scenic entrance into Datchet from Old Windsor.

✓

Further information on the timescales for the use of the borrow pits and the capacity of the transport network to cope with transport to and from the construction sites is needed.

✓

The importance of utilising nearby materials is recognised. It is important to do so in a sustainable and efficient way that limits the potential impacts on local communities.

✓

If lake restoration of Borrow Pits is preferred it will need to be designed not to encourage nesting birds.

✓

Construction proposals were badly thought out and that sufficient discussion or review of the areas involved has not taken place. An example is the ‘borrow pits’ in Old Windsor which are either located on Crown owned working farmland or on the site of

✓




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the sewerage pits that serve the whole of Windsor.

Support for the identification of the Thames Water site as a potential borrow pit site. However, any proposals must not detrimentally impact upon the Sewage Treatment Works operations and will need to carefully consider potential archaeological remains.

✓

Consultation with the Thames Water’s Reservoir Safety Team will need to be undertaken in order to understand if there would be any stability concerns associated with the potential borrow pit immediately east of the Queen Mother Reservoir.

✓

Site G1 would not meet the requirement set out in Our Emerging Plans for borrow pits.

✓

Heathrow’s proposals at Mayfield Farm (Site E2) do not acknowledge the safeguarded status of the mineral resource and are therefore contrary to the requirements of the NPPF, the London Plan and the adopted Local Plan.

✓

Mayfield Farm has the potential to play a significant role in supplying construction aggregates for the project but does not appear to have been considered.

✓

The construction phase would generate additional pressure on the existing housing stock. Any proposals for the airport should include detailed provisions to address this issue.

✓ Heathrow’s location in London benefits from a well-developed housing market and public transport links, so the requirement for construction accommodation facilities is less than for more remote infrastructure construction sites. Heathrow is working with the planning authorities that make up the HSPG to assist in the planning of new housing in the wider area through local plan reviews, which take account of growth

Adequate provision must be made for temporary accommodation for construction workers as part of

✓




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the overall strategy in order to avoid existing residential areas becoming swamped with Houses in Multiple Occupation.

associated with the airport alongside other housing and employment needs for which the authorities already need to plan. A range of alternative responses will be considered including the reuse of existing assets (e.g. residential properties, hotels). The PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 will consider temporary impacts on the housing market, including the issues identified by the consultee and social cohesion. The approach to consideration of these matters was set out in the EIA Scoping Report (May 2018). Consultation feedback will be taken into account in producing the ES which will be submitted with the DCO application.

Permanent housing should be constructed for workers close to good public transport locations, which can be reused for affordable housing in the future.

✓

Construction worker accommodation – including ‘Olympic model’ legacy housing is needed as part of a coordinated construction strategy.

✓

In respect of construction and the sites identified, the houses which are up for sale now should be bought and used for the temporary workers during the construction.

✓

An assessment of local impacts on the housing market and social cohesion – including changes in tenure and occupation of family housing to shared letting, HMOs etc is needed as part of a coordinated construction strategy.

✓

Action to stop unauthorised temporary housing camps with caravans, mobiles etc is needed as part of a coordinated construction strategy.

✓

Consideration should be given to the source of the materials for infilling as part of restoration.

✓ Heathrow is committed to ensuring that construction is sustainable. Our Emerging Plans (2018), which was published as part of Airport Expansion Consultation One in January 2018 highlighted that this will include the use of recycled and excavated materials on site. A draft Materials Management Plan will be published as part of the Airport Expansion Consultation in June 2019 together with the emerging mitigation and remediation strategy.

There is a need for a more comprehensive statement about the use of recycled materials in order to reduce the need for new aggregates.

✓

The construction of the new runway and associated ✓




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development will likely generate significant volumes of waste and as a result material re-use should be maximised to minimise waste where appropriate.

Soils should be treated in a way that will allow land to be returned to its pre-construction state or better.

✓

The options assessment of the various road and runway options should contain information on the arrangements for remediation or removal of contaminated material that is required.

✓

There is a need for more comprehensive proposals for transport investment.

✓ The delivery of the surface access strategy will require Heathrow 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. A Surface Access Strategy will be published as part of the Airport Expansion Consultation in June 2019. This will provide more detail on proposals for transport investment.

There should be a ban on construction traffic travelling to and from Heathrow along the Bath Road (A4) over the ancient and much-valued Maidenhead Bridge. In the event of a temporary closure of the M4 this bridge is the only current alternative route to Heathrow from the west and this should be

✓ Maidenhead bridge is located approximately 10km to the west of the airport and is within the area that will be subject to detailed transport modelling. A draft Transport Assessment will assess the suitability of all construction routes likely to be affected will be published as part of the Airport Expansion Consultation in June 2019.




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considered the Heathrow’s assessments.

Concern that Old Windsor is unsuitable as a construction route as it is a single track road and bridge.

✓ As part of the Construction Logistics Plan designated delivery routes will be mandated to ensure construction traffic uses appropriate and defined routes.

Site plant, vehicles and site operations should be in accordance with relevant sustainability, emission and environmental health standards, and be carbon neutral if possible.

✓ As part of the EIA process, a CoCP will be prepared, which will outline how construction activities will be managed. Opportunities to reduce impacts associated with the construction phase being considered include low emission vehicles, plant and construction techniques and will consider as far as reasonably practicable the use of recycled materials, measures to reduce water and energy consumption on site. Emissions associated with the construction phase and how to minimise them through mitigation will be considered in the PEIR, published as part of the Airport Expansion Consultation in June 2019.

In respect of construction and the sites identified, construction workers should use low emission vehicles.

✓

There is a need for performance targets for noise and air pollution.

✓ The EIA Scoping Report (May 2018) sets out relevant noise thresholds based on the concepts of Lowest Observed Adverse Effect Level (LOAEL) and Significant Observed Adverse Effect Level (SOAEL). These will be used to identify likely significant effects during the construction phase, with residual effects identified after mitigation measures have been applied. As part of the EIA process, a CoCP will be prepared, which will outline how construction activities will be managed. This document will set out the requirements and processes for mitigation and the monitoring of potential environmental impacts throughout the construction programme, such as construction noise, dust generation and air quality. A draft CoCP will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the final ES which is submitted with the DCO application.

There should be enforceable noise limits that cannot be breached during the construction phase.

✓

The principles outlined are sound and will help to minimise additional construction traffic.

✓ Support for the principles outlined in the Airport Expansion Consultation One in January 2018 is welcomed.

It was welcomed that the consultation document ✓ Support for the approach taken in the Airport Expansion Consultation




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sought to demonstrate an appreciation of the impact the construction phase.

One in January 2018 consultation material is welcomed.

Detailed air quality impact assessments should be carried out including for HGV movements on the public highway.

✓ The PEIR, which will be published as part of the Airport Expansion Consultation in June 2019, will include consideration of air quality impacts associated with construction related activity. Consultation feedback received will be taken into account in producing the ES which is submitted with the DCO application.

All construction vehicles must meet CAZ standards as they will need to travel through the M4 AQMA and Brands Hill AQMA.

✓ Heathrow is considering the use of Low emission vehicles as one measure to reduce air quality impacts, alongside a range of other measures, including the use of freight consolidation centres, just in time delivery, off-site manufacturing and the use of rail to move materials. Further details will be presented in the PEIR that will be presented as part of the Airport Expansion Consultation in June 2019.

Renewable diesel should be used during construction wherever possible to reduce emissions.

✓

Concern that the volume of traffic required during construction will severely impact local residents and road users.

✓ A draft Construction Logistics Plan will be produced at the Airport Expansion Consultation in June 2019 (as part of the PIER) and this will include details on the mechanisms by which HGV routes will be developed with stakeholders.

Concern about the effects on the local roads given that potential construction sites will put pressure on badly maintained local roads as motorists try to avoid the inevitable congestion caused by any expansion.

✓

Construction HGV Routes shall be agreed and legally binding and enforceable though ANPR cameras they shall avoid Colnbrook, Poyle and Langley Villages.

✓

All plant and equipment above 37kW shall meet NRMM London Standards on site.

✓ Heathrow will ensure compliance with all relevant standards that are in force over the construction period.

All Cement batching works should take place a minimum of 400m from residential properties to avoid dust impacts.

✓ Generally, Heathrow would not seek to locate concrete production plants within 400m of residential properties. However, where this is not possible Heathrow will introduce mitigation measures to manage




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potential dust impacts.

Dust and Particulate monitoring should be carried out on construction site boundaries and beyond if necessary within residents’ gardens.

✓ Monitoring of baseline particulate matter and dust deposition levels will be undertaken in advance of commencement of the construction programme. The draft CoCP will be consulted on as part of the Airport Expansion Consultation in June 2019 and will include arrangements for monitoring.

A Construction Environmental Management Plan must be developed and consulted on with Slough and other neighbouring authorities to ensure all practicable measures to minimise environmental harm are taken.

✓ Heathrow confirms that the draft CoCP will be consulted on as part of the Airport Expansion Consultation in June 2019.

Consideration to temporary housing and compensation should be given for residents who are significantly impacted by the construction work.

✓ Heathrow is considering a range of measures to manage and mitigate any potential effects during the construction period. These include implementing noise insulation and the possibility of temporary re-housing policy. This would be to provide additional protection to residents in the event that it is not practicable to avoid adverse effects through onsite noise controls. As part of the EIA process, a CoCP will be prepared, which will outline how construction activities will be managed. This document will set out the requirements and processes for mitigation and the monitoring of potential environmental impacts throughout the construction programme, including construction noise. A draft CoCP will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the final ES which is submitted with the DCO application.

Construction operating hours should be legally binding, night time works shall only be permitted for special operational circumstances (i.e. wide loads) and emergencies.

✓ The draft CoCP will be consulted on as part of the Airport Expansion Consultation in June 2019. This will include proposals for night time work.

Care should be taken in the siting (and hours) of floodlights to avoid glare and nuisance impacts to residents.

✓ Heathrow will have regard to Guidance Notes for the Reduction of Obtrusive Light (GN01:2011), Institution of Lighting Professionals (2011). The PEIR, which will be published as part of the Airport




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Expansion Consultation in June 2019 will include consideration of impacts from lighting associated with construction related activity in order to avoid significant effects on residents. Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

Assurance sought that Sites C2 and D2 were adequate and that further sites to the east of airport would not be to be identified. Site D2’s proximity to residential development may make it unsuitable.

✓ A detailed evaluation considering a range of criteria (as detailed in the Scheme Development Report) is being undertaken to identify the preferred locations for construction sites, taking into account the consultation responses. This includes consideration of strategic location, proximity to the development boundary, access to the existing road network, access to existing services and utilities and low likelihood of ground remediation and/or extensive site enabling. The findings of this assessment will be presented in the Updated Scheme Development Report that will be published to accompany the Airport Expansion Consultation in June 2019. Where sites are required the PEIR will explain the potential range of uses that will take place and the length of time for which each of these elements would be required. Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

Site F2 is an extant mineral site that is being backfilled with inert waste to facilitate restoration with an existing recycling facility. Heathrow’s proposals would result in the loss of garden/open space and habitat areas created as part of the recent 10 year extension of recycling on the site and would need to be compensated.

✓

Hithermoor Quarry (Site F5) is a land raised mound of waste that has been subject to longstanding restoration and woodland planting. There should be additional environmental compensation for losses that in effect would put the clock back. The site includes a SNCI (Greenham’s Fishing Pond), archaeological potential on northern part of the site, and part of the site could be a potential route for Southern Rail Access.

✓

Site F1 should be used temporarily as opposed to being permanently developed. However, even temporary work could have a detrimental effect on biodiversity and Green Belt functions.

✓

Site F2 should be used temporarily as opposed to ✓




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being permanently developed. Even temporary work could have a detrimental effect on biodiversity and Green Belt functions. F2 should be avoided if possible due to its higher biodiversity value.

Site F5 should be used temporarily as opposed to being permanently developed but even temporary work could have a detrimental effect on biodiversity and Green Belt functions. F5 should be avoided if possible due to its higher biodiversity value.

✓

The site south of Horton Road and north of King George VI Reservoir is bounded to the north and west by residential properties. These are very sensitive to odour issues, noise and vehicle movements from the site. Oak Leaf Farm, as the site is known, is a historic landfill known as Land South of Horton Road Landfill. Widespread serious contamination is unlikely and contamination is unlikely to constrain development, particularly in respect of any construction related uses.

✓

The area north of the runway and A4 should be one of the primary areas for construction activity focused upon the rail head.

✓

The area south of the A4 within the Colnbrook “Green Envelope” should not be used for construction because of the need to protect existing residents and the school and carry out appropriate planning and mitigation measures as soon as possible.

✓

The area south of Poyle Trading Estate could be used as a temporary construction site provided there is no traffic routed from here through Colnbrook and Poyle.

✓




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The construction sites at Stanwell and Stanwell Moor will destroy existing greenery and wildlife which will not be restored as construction land identified is planned to be re-used as part of the overall development plan.

✓

Stanwell Moor land should not be used as a construction site as it will destroy existing greenery and wildlife which will not be restored.

✓

Site F7 could provide multiple-land uses during construction including car/lorry parking and construction base, notably for (M25 works) whilst post-construction the site could be repurposed to accommodate businesses/land use displaced by the third runway.

✓

Concern about the about the suitability of the western sites on Ham Island and Southsea Farm due to their proximity to property and likely impacts on traffic in Datchet and Runnymede.

✓

One of the construction sites to the south of the existing airport would be ideal for a purpose-built construction workers camp.

✓

West Drayton is a suitable location for construction sites given the highway links/connections.

✓

Land around the reservoirs (Staines and Wraysbury) should be considered for construction locations to the south-west of the airport.

✓

The construction site identified on land north of Harmondsworth Lane may be an appropriate site. Heathrow should discuss with Lanz Group the inclusion of the Sipson land within this designation to ensure connectivity with the new airport.

✓




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Land to the north of the A4 Colnbrook Bypass has the potential to perform a role as part of managing the construction stage, in advance of its permanent use for airport related development. This land was unlikely to be suited for use as a borrow pit due to its landfill history and the site has previously been confirmed by the Secretary of State as capable of accommodating successful rail freight connectivity and rail freight facilities.

✓

The Jayflex site at Horton Brook Quarry, Colnbrook would be suitable as a site to aid construction or for use as an aggregates borrow pit.

✓

The Jayflex site at Horton Brook Quarry, Colnbrook would be suitable as a location for the development of replacement housing and light industrial units that will require relocation because of the expansion programme.

✓

The temporary construction site north east of the airport boundary has the potential to limit the scale and potential of car parking at the adjacent Terminal 1-3. If this site is taken forward as a construction site access to the Magnatex and Pionair sites must not be impeded.

✓

Request that construction sites are located as close to the third runway as possible to reduce travel distances for construction traffic and ensure they do not conflict with key cargo and freight routes.

✓

Opposition to the proposed construction sites north of the communities of Colnbrook and Poyle (Sites H3, CS-1 and CS-2) due to their proximity to residential properties, Colnbrook Conservation Area, Pippins Park, Albany Park, St. Thomas’s Quiet

✓




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Garden and Colnbrook Recreation Ground. These sites did not meet Heathrow’s criteria for construction sites set out in Our Emerging Plans and that the area should be reserved as a buffer with appropriately landscaped bunds/noise barriers.

The use of Sites H1, H2, H6 and F7 as temporary construction sites or to the use of Site G3 as a borrow pit is not opposed.

✓

The use of the northern part of the Colnbrook Logistics Centre (Site H6) as a temporary construction site is supported.

✓

Request for further information on the timescales and phasing for the use of Site H6 and what will happen to the site when it is no longer needed for construction uses.

✓

The use of Segro’s site at Hatton Cross (Site D2) for temporary construction is not supported given its location is unsuitable and unsustainable in relation to the third runway. The site would be suitable for providing low-occupancy supporting uses (Class B1c/B8), such as warehouse storage and lorry parking.

✓

The temporary use of Suez land at Holloway Lane and Harmondsworth Lane is supported.

✓

The use of Brett Group land at Hithermoor for temporary construction and logistics is supported. The land could also be used for stockpiling of construction materials and recycled inert materials.

✓

There is insufficient detail in relation to some of the construction sites, specifically Sites 5, 6 and 11. Once the detail of these sites is known consultation

✓ Thames Water’s Reservoir Safety Team will be consulted on all matters relating to the safety of their reservoirs and associated infrastructure.




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should be undertaken with the Reservoir Safety Team to understand whether there are any concerns.

Heathrow are in regular dialogue with Thames Water with regards the potential impacts of the Project on their assets and interests. This is ongoing engagement to identify potential impacts and where conflicts such as this are identified it often results in changes to Heathrow’s plans. Where impacts cannot be avoided by changes to Heathrow’s plans, mitigation measures and actions that Heathrow must take will be agreed. These agreements are referred to as Protective Provisions and will ensure Thames Water’s assets are not negatively impacted, thus ensuring that Thames Water are not prevented from performing their statutory duties by the construction or operation of the project. Protective provisions will be included in the DCO application to protect the interests of statutory bodies whose assets and facilities might be affected by the construction or operation of the project. These provisions will be worked up in detail in consultation with the relevant statutory bodies, in this case Thames Water. If a DCO consent is granted, these protective provisions become legally enforceable.

Until further details are available in relation to access points for both road and rail, it is not possible to comment meaningfully on any potential effects on the historic environment.

✓ Heathrow recognises that effects on the historic environment is an important area for to consider, and any potential effects will need to be assessed. Additional details in relation to access points for both road and rail will be provided as part of the Airport Expansion Consultation in June 2019. Further information on the historic environment will be provided in the PEIR, which will also be published in June’s consultation.

In respect of the criteria set out for the selection of potential construction sites, it is recommended that Heathrow make a commitment that sites should not have an adverse impact on any designated or non-designated heritage assets.

✓ The ANPS gives great weight to heritage conservation (5.200). As part of the identification of the preferred masterplan, consideration is being given to the potential impacts on the historic environment. Further information will be presented in the Updated Scheme Development Report and in the PEIR published as part of the Airport Expansion Consultation in June 2019.

Concerns about the impact of construction activities ✓ A draft Surface Access Strategy will be published as part of the Airport




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on the Strategic Road Network. If demand on sections of the network was not managed, the impact would be to displace other traffic which would have a serious impact on road network and drivers. As a result, consideration should be given to managing down demand from other airport uses so that displacement would be contained within the overall demand of the airport.

Expansion Consultation in June 2019 and this will provide more detail in relation to measures to down demand from other airport uses. The CoCP, which will be published as part of the Airport Expansion Consultation in June 2019 will explain what controls will be put in place to manage the impacts during the construction stage. As part of the DCO application, Construction Workforce Travel Plans will be developed to encourage the use of the public transport and sustainable modes of transport by the construction workforce. A Construction Logistics Plan will set out measures to manage construction related traffic, including proposed routes and a draft will be available at the Airport Expansion Consultation in June 2019. Heathrow will also aim to reduce the effects of construction traffic using existing roads by creating an internal construction road system.

During each phase of construction the necessary road infrastructure and traffic management measures should be put in place to maintain the safe and effective operation of the network.

✓

Construction plans should also take into account works by other parties elsewhere on the transport network and which have the potential to affect the Heathrow area.

✓

Request the Heathrow share its construction plans and proposed vehicle movement strategy prior to the DCO application.

✓

Greater consideration should be given to construction impacts over an extended period, in particular with further emphasis on how to manage the workforce.

✓

Concern about impacts on traffic flow. ✓

In respect of construction and the sites identified, effects on local roads should be minimised.

✓

Concern about congestion and local roads. ✓

Car-based travel to either the airport or GlaxoSmithKline sites will be affected by construction and there will be a need for mitigation

✓




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measures to offset any negative impact on this throughout the construction period.

The phases and duration of each construction stage is needed as part of a coordinated construction strategy.

✓ The draft CoCP will be published as part of the Airport Expansion Consultation in June 2019 and will explain what controls will be put in place to manage and mitigate the impacts during the construction stage. This includes measures to manage the disruption of construction to local communities and airport operations.

Consideration of other major infrastructure projects within the area together with their construction programmes is needed as part of a coordinated construction strategy.

✓ The EIA will consider the potential for cumulative effects, including those that might occur during the construction phase.

Special consideration for Iver, which is already subject to an array of major infrastructure projects, is needed as part of a coordinated construction strategy.

✓ A draft Cumulative Impact Assessment will be prepared as part of the PEIR and will be published as part of the Airport Expansion Consultation in June 2019. This will include consideration of potential cumulative impacts with other projects and measures to mitigate potential impacts during the construction phase, this will include proposals for the routing of vehicles during the construction phase. Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application. The Construction Logistics Plan will include proposals in relation to routing and the management of construction traffic. A draft will be available as part of the Airport Expansion Consultation in June 2019.

Concern that disruption to traffic during the construction phase will be considerable and will displace traffic onto local residential roads in the Iver Parish area. The Parish already suffers from intolerable levels of traffic, especially HGVs and OGVs and rat-running caused by motorway congestion. The area cannot tolerate any further increases.

✓

Concern about the impacts on local communities at Stanwell Moor, Longford, West Drayton, Colnbrook, West London, Harlington and Sipson.

✓

Traffic must avoid Stanwell and there should be no use outside normal hours.

✓

HGV movements should be south on Poyle Road and ✓




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not along the Old Bath Road to avoid residential areas.

A number of Royal Mail sites will be affected during construction works. It is requested that Heathrow engage with Royal Mail at the earliest opportunity to identify the impacts on its operations, mitigation measures and agree a formal process for ongoing dialogue.

✓ Heathrow has and will continue to engage with all of those business owners and occupiers who may be affected during the construction of the Project to ensure they kept up date on the expansion proposals.

Concern about construction impacts on the local economy.

✓

It is important that regular on-going dialogue with stakeholders occurs and there is transparency in areas that are not commercially confidential.

✓ Heathrow remains committed to a meaningful programme of consultation and will continue to engage with key stakeholders, partners and community groups as its proposals progress.

Concern that the proposals appear to be maximising development land-take and that carparks and construction sites all need to be moved out of the development area, mainly in the Parish of Colnbrook with Poyle.

✓ A detailed evaluation considering a range of criteria (as detailed in the Scheme Development Report) is being undertaken to identify the preferred locations for construction sites, taking into account the consultation responses. Heathrow is seeking to minimise the amount of land required for the construction and operation of the Project. Further information will be contained within the PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 and consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

Concern about effects on health and well-being. ✓ The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (the ‘EIA Regulations’), requires health to be considered within the EIA process. The ANPS (paragraphs 4.70 to 4.73) also requires health impacts to be assessed. To meet the




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statutory and policy requirements, Heathrow are preparing a health impact assessment (HIA) which will identify, assess and manage any health impacts as a result of the construction and operation of the Project. Drawing on the analysis in the HIA, the ES will report likely significant health effects and the measures taken by the 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 ES. The PEIR, to be published as part of the Airport Expansion Consultation in June 2019 will provide early findings of the health impact assessment and consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

In respect of construction and the sites identified, the effects on air pollution and noise pollution need further consideration.

✓ Heathrow is committed to balancing economic benefits with growing sustainably, and managing and mitigating environmental impacts. Heathrow will assess potential impacts on local communities associated with each phase of construction by undertaking an assessment of impacts on communities as part of the EIA, early findings will be reported in the PEIR, to be published at the Airport Expansion Consultation in June 2019. Heathrow will also employ good practice management and delivery systems to manage the effects of construction. Measures will be developed to avoid or reduce the likely impacts of construction on communities and the environment as the DCO application becomes more developed, such as noise controls, dust suppression and traffic management measures; all of which will be set out in a CoCP. A draft of the CoCP will be available as part of the Airport Expansion Consultation in June 2019. Heathrow is giving further consideration to air pollution and noise pollution, including any associated with the construction phase. The preliminary findings of the air quality assessment together with further details and development of Heathrow’s proposed mitigation measures will be provided in the PEIR, which will be published as part of the




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Airport Expansion Consultation in June 2019. This will include information on likely local air quality and noise impacts and proposed mitigation. This information will be used to inform more detailed air quality and noise impact assessments, which will be published as part of the ES submitted with the DCO application.

Concern about impacts on the environment. ✓ Heathrow is seeking to minimise the environmental effects of expansion as far as practicable. As part of the development of its proposals, Heathrow is undertaking a detailed evaluation considering a range of criteria (as detailed in the Scheme Development Report) to identify the preferred locations for construction sites, taking into account the consultation responses. The full range of environmental disciplines are included within the evaluation criteria in the Scheme Development Report. This has and will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the environmental effects of the construction phase and community impacts, including impacts on existing uses. The DCO application will comply with the ANPS and will include an ES to explain how Heathrow will identify and mitigate any likely significant environmental effects during construction of the airport. It will assess potential impacts on local communities associated with each phase of construction by undertaking a CIA. Heathrow will also employ good practice management and delivery systems to manage the effects of construction. Measures will be developed to avoid or reduce the likely impacts of construction on communities and the environment as the DCO application becomes more developed, such as noise controls, dust suppression and traffic management measures. Heathrow will employ a variety of measures to reduce the effects of a large number of activities taking place at the same time, including use of rail freight to import construction goods and materials, reducing the vehicle movements and effects on local roads and use of on, near and off-site logistic hubs. In terms of the duration of the construction phase, the PEIR will provide




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information on which construction activities are to take place at the various sites identified, and the potential length of time for which these elements would be required. As part of the EIA, a CoCP 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 programme, such as construction noise, dust generation and traffic management and routing. The draft CoCP will form part of the PEIR which will be published as part of the Airport Expansion Consultation in June 2019, and will be engaging with statutory bodies on its content before this.

In respect of construction and the sites identified, prefabricated construction should be used as much as possible.

✓ Heathrow is considering a range of techniques to reduce impacts during the construction phase, including the use of prefabricated construction techniques.

In respect of construction and the sites identified, construction sites should be sited as close to the airport as possible.

✓ As part of Airport Expansion Consultation One a number of potential construction sites were set out in Figure 15.2 of Our Emerging Plans (January 2018). Many of these are located close to the expansion area to reduce travel distances and construction impacts. The performance of these sites is being against a range of criteria (as identified in the Scheme Development Report) and Heathrow’s preferred options will be detailed in the Updated Scheme Development Report published as part of the Airport Expansion Consultation in June 2019.

In respect of construction and the sites identified, construction sites should be reclaimed and restored post construction.

✓ If construction sites are not re-used for some other form of permanent development, they will be restored to an appropriate after-use which is compatible with their surroundings. The PEIR which will be published as part of the Airport Expansion Consultation in June 2019 will provide more information on the proposed after-use of sites. Consultation feedback received on this will be taken into account in producing the ES which is submitted with the DCO application.

In respect of construction and the sites identified, sites that become brownfield after construction should be used for residential development or community facilities.

✓

In respect of construction and the sites identified, ✓ Heathrow is exploring the use of a range of measures, including the




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advance planning and logistics should be employed. use of freight consolidation centres, just in time delivery, off-site manufacturing and the use of rail to move materials.

In respect of construction and the sites identified, consideration should be given to phasing of the construction sites.

✓ Heathrow recognises the potential role of phasing of construction sites and will consult on proposals in this respect as part of the Airport Expansion Consultation in June 2019.

In respect of construction and the sites identified, construction screens/hoardings should be adorned with art displays from local artists.

✓ Heathrow will give consideration to the potential for local artists to contribute in this way, having regard to other factors, including health and safety and security.

In respect of construction and the sites identified, construction should be outsourced to countries with a proven track record.

✓ The aim is for an expanded Heathrow to engage with a supply chain that will provide the required quality whilst delivering value for money. As part of Heathrow’s procurement approach, it will also recognise the requirements of the ANPS.

Heathrow should explore the re-use of the freight line at Colnbrook Logistics Centre that was used to transport bulk goods for the construction of Terminal 5 as this could help to mitigate the number of vehicles required during construction.

✓ Heathrow intends to use the existing line and develop a new railhead at Colnbrook for the import of construction goods and materials.

Minimising the impact of construction on the current operation and running of the airport must be a key consideration and will require close coordination with the Airline Community.

✓ Heathrow recognises the need to avoid impacts on the operation and running of the airport. The Masterplan Scheme Development Report sets out the range of factors that construction proposals will be assessed against and these include impacts on operations and service, including airfield performance and efficiency. Heathrow is also undertaking an ongoing programme of engagement airlines which will inform Heathrow’s preferred masterplan and its approach to construction.

Clarity sought on how any local road diversions or infrastructure works at land North of Moor Lane Harmondsworth would be delivered and whether these works would be approved as part of the development consent process.

✓ If any local road diversions or infrastructure works are required on land North of Moor Lane these will be included in the DCO application as Associated Development.

The options assessment of the various road and ✓ The assessment of road and runway options has included




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runway options should contain information on how construction could be carried out without major disruption to traffic.

consideration of disruption to the road network during delivery of the proposals. The Scheme Development Report sets out the approach.

The options assessment of the various road and runway options should contain information on noise impacts of a runway elevated above ground level.

✓ Heathrow are committed to meet the aims set out in the ANPS (paragraph 5.68) for the effective management and control of noise (these are unchanged from those set out at paragraph 5.66 of the draft ANPS), within the context of Government policy of sustainable development. As such, Heathrow aims to:

• 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 the improvement of health and quality

of life. The PEIR, which will be published as part of the Airport Expansion Consultation in June 2019 will set out Heathrow’s assessment of noise impacts undertaken to date, which arise from the Project, including the runway. It will also present mitigation measures to reduce noise effects during construction. In line with government policy aims, adverse noise effects on people are those related to health and quality of life and consultation feedback will be taken into account in producing the ES which will be submitted with the DCO application. The reasonable and practicable mitigation measures envisaged for avoiding and reducing significant effects on health and quality of life from aviation noise include both mitigation incorporated into the Project and noise insulation provided in homes and community buildings. These mitigation measures will be set out in the PEIR. Consultation feedback received will be taken into account in producing the final ES which is submitted with the DCO application.

Concern that no reference had been made to the predicted construction costs. This has made it impossible to respond meaningfully to options and approach as the costs and the benefits cannot be

✓ The cost and cost effectiveness of the proposals is at the heart of the plans for expansion and is being considered at every stage of the masterplan scheme development. In preparing its DCO application Heathrow will satisfy the ANPS test (paragraph 4.39) in this regard.




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analysed. Request that cost estimates and transparent information on each of the components be published.

Heathrow will demonstrate in its DCO application that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime. Cost is an important consideration, among others, and the masterplan is being carefully prepared to balance all the different design requirements, in line with the Scheme Development Report that was published at Consultation One.

Trial holes and hand digging is required during construction to locate Fulcrum pipelines and assets.

✓ Heathrow is in discussion with all utility providers whose assets might be affected by expansion, including gas suppliers, and will take suitable measures to protect or relocate existing facilities.

If Fulcrum pipelines assets are exposed during construction, adequate protection (e.g. sand covering) should be inserted once work is completed.

✓

Additional costs may be incurred if the plant has to be relocated due to construction works.

✓

Appropriate provisions will need to be put in place during construction to minimise and manage the risks and ensure access is maintained to and from all relevant Heathrow Airport Fuel Company Limited facilities at all times.

✓

Any fuel related developments will need to be implemented in line with stringent codes and standards and without creating any detrimental impacts on the quality or supply of aviation fuel at Heathrow.

✓ Heathrow recognises that the fuel related development will need to comply with stringent design regulations, including those relating to fuel storage facilities. Section 10 of the Scheme Development Report explains the work done to shortlist six options. The evaluation of alternatives and preferred option will be detailed in the Updated Scheme Development Report which will be published as part of the Airport Expansion Consultation in June 2019.

Concerns about the effects of construction on the Passiflora business and that disruption will have financial consequences.

✓ Heathrow has and will continue to engage with all of those business owners and occupiers who may be affected during the construction of the Project to ensure they kept up date on the expansion proposals.




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Any phasing plan that places airlines at a competitive disadvantage, due to sub-optimal quality of facilities or sub-optimal infrastructure for transfer passengers moving between terminals would not be supported.

✓ As a multi-terminal airport there will be differences in the terminal infrastructure. However, Heathrow provides competitive equivalence across terminals. Transfer connecting times are competitive across all terminals to enable connection flows. Heathrow will work with airlines to understand their requirements for phasing and connections. Further detail on the phasing and capacity of the proposed terminals will also be provided in the PEIR that will be published to accompany the Airport Expansion Consultation in June 2019.

The current recycling use of Stanwell Recycling Facility should be retained for the period of construction as the aggregate recycling services at this site are likely to be essential for the sustainable construction of the expanded Heathrow.

✓ The site of the Stanwell recycling facility is likely to be required for expansion and was shown as such at Airport Expansion Consultation One. The exact timing and use of this site will be clarified as the scheme design progresses to DCO application. Existing uses will be retained as long as possible, provided this is consistent with the expansion programme.

Concern about the use of land immediately to the west of Holiday Inn M4/J4 as potential site for construction, borrow pits and stockpiling. This would have a material impact on the hotel throughout the period of the construction but the impact could be minimised if construction workers were encouraged to use the hotel during construction.

✓ Heathrow is exploring a range of options for accommodation of construction workers, including the use of local hotels. Options for construction worker accommodation will be presented as part of the Airport Expansion Consultation in June 2019.

Consideration should be given to a separate application for temporary permission for airport related car parking on land at Poyle Manor Farm during the construction period, in order to meet demand for those travelling to the Airport by private car.

✓ Heathrow will give consideration to this proposal as part of the development of the approach to temporary car park provision.

Concern that the effect of the proposals on Richings Park had not been sufficiently considered. Further consideration should be given to the potential for increased traffic on the local area during diversion of

✓ In developing the Scheme that will be presented in the Development Consent Order (DCO) application, Heathrow has been undertaking a process of evaluating many options, including potential use of this site. In doing so, the full range of environmental disciplines are




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the existing roads, the effects of additional traffic and HGVs on noise, air pollution and road safety and noise and visual impact from a temporary construction site south of Richings Park, which would likely operate 24 hours per day.

included within the evaluation criteria (as outlined in the Scheme Development Report). This has and will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the environmental effects of the construction phase and community impacts, including impacts on existing uses.

The PEIR, which will be published as part of the Airport Expansion Consultation (June 2019) will identify any potential effects associated with the site and any mitigation measures. This will include consideration of any potential effects on Richings Park associated with noise, air pollution, road safety and visual impact, as set out in the Scoping Report (May 2018). Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application.

The proposals for rail freight, pre-booked delivery slots, workers' bus services, off-site assembly, construction code of practice, training, skills, site safety, workers' rights and apprenticeships are welcomed.

✓ Support for these aspects of the Project are welcomed.

Construction has the potential to seriously affect and sever the Colne Valley Regional Park. The impacts should be minimised by returning temporary construction sites to use in service of the park’s objectives and treating topsoil in a way that will allow for land to be returned to its pre-construction state or better.

✓ The need to avoid significant impacts on the Colne Valley Regional Park during the construction phase is recognised. 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. The PEIR, published as part of the Airport Expansion Consultation in




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June 2019 will set out early findings regarding the assessment of recreational spaces and likely effects. Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application. The draft CoCP and Materials Management Plan will also be published as part of the Airport Expansion Consultation in June 2019. These will provide details on the proposals for topsoil.

The reputational impact of construction on the Colne Valley Regional Park must also be mitigated. It is requested that Heathrow provides funding to appoint a Marketing & Community events officer throughout the construction period.

✓ Heathrow will develop a community compensation fund (CCF) in accordance with the ANPS. We will be seeking feedback on proposals for the community compensation fund as part of our Airport Expansion consultation in June 2019.

It is accepted that planning and design work would seek to minimise risks and impacts but there remains a residual risk and inevitable impacts associated with construction activities on surface water pollution, open land valued for its environmental and community value and from the creation of new gravel extraction sites in the local area.

✓ Heathrow is committed to protecting the quality of the water environment and is working with the Environment Agency and other third parties to deliver appropriate solutions. This will include measures to avoid and manage surface water pollution. The Scheme Development Report includes a wide range of considerations in the evaluation criteria used for appraising different options and masterplan components, including the future use of temporary construction sites, 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 significant issues which are considered to prejudice the deliverability of the scheme. The PEIR, published as part of the Airport Expansion Consultation in June 2019 will set out early findings regarding the assessment of impact on open spaces and surface water and likely effects and suggested mitigation measures.

Minimising the impact of construction on the current operation and running of the airport must be a key consideration and will require close coordination

✓ Heathrow recognises the need to minimise the impact of construction on the current operation and running of the Airport, and is committed to work closely with airlines, communities, and other interested parties




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with the Airline Community. throughout this process.

Heathrow should be guided by environmental experts at all levels to manage the impact of construction.

✓ Heathrow has used suitably qualified and experienced individuals to advise on the evaluation framework for the assessment of options and their evaluation. Suitably qualified and experienced individuals are working on the design of the masterplan and production of the Scoping Report, PEIR and other technical documents associated with the Project. Heathrow has and will continue engage with a range of external organisations including Natural England, the Environment Agency, the HSPG and the Planning Inspectorate. Invitations to participate in technical discussions have also been extended other organisations including the Royal Society for the Protection of Birds (RSPB) and the Wildlife Trust. Technical consultations with all stakeholders will continue throughout the pre-application process, with the frequency and topics of discussions being tailored to fit with the Project programme and with the interests and the desired level of engagement of each organisation.

Heathrow should maximise biodiversity, habitats and ecosystem benefits through clever and careful location and design of infrastructure and during construction and operation.

✓ Heathrow has committed to achieving an overall net gain in biodiversity (Scoping Report, May 2018) and this will include the creation of new and enhanced habitats. The PEIR which will be published as part of the Airport Expansion Consultation in June 2019 will provide further details of the preferred construction sites and their proposed after uses.

All temporary construction sites should be returned to wildlife habitats (or other multi-functional green infrastructure) as part of the final masterplan.

✓

In respect of construction and the sites identified, the impacts on wildlife and habitats should be minimised.

✓

Where the loss of a local wildlife/biodiversity site does happen there should be a commitment to provide alternative sites around Stanwell and

✓




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Stanwell Moor.

Site F7 would impact the Staines Moor SSSI and West of Poyle Meadows SNCI and that Site F2 would impact the Stanwell II SNCI.

✓ The full range of environmental disciplines are included within the evaluation criteria as detailed in the Scheme Development Report. This will ensure that environmental considerations are fully integrated into all stages of masterplan scheme development, including the construction phase. Potential effects on Staines Moor site of special scientific interest (SSSI) have been factored into the appraisal of options (including Site F7 and Site F2) as the masterplan has developed. The Updated Scheme Development Report, which will be published as part of the Airport Expansion Consultation in June 2019 will provide more information on the appraisal and selection of sites with these factors in mind. If necessary on the basis of the preferred construction sites, the PEIR, to be published at the Airport Expansion Consultation in June 2019 will consider the potential for significant effects on the SSSI and site of nature conservation importance (SNCI). Consultation feedback will be taken into account in producing the ES which is submitted with the DCO application. The mitigation hierarchy will be used in instances where likely significant negative effects are identified.



17. MASTERPLANNING

17.1 Introduction


relation to how the components of the development could be brought together to

form a masterplan for the Heathrow Expansion Project (the Project). A total of

1,248 consultees made comments relating to this topic.

17.1.2 Heathrow provided the following material that is directly related to the Project

masterplan:


2. Our Emerging Plans;

3. Scheme Development Report;

4. Community Information Booklet – North;

5. Community Information Booklet – East;

6. Community Information Booklet – South West; and

7. Community Information Booklet – West.

17.1.3 Heathrow asked the following questions regarding the Project masterplan at

Airport Expansion Consultation One:

1. Please tell us how you think we should best bring the various components

together to build our masterplan for the Project and what factors you think

should be most important in our decision-making.
















Local Authorities


17.2.1 The London Borough of Hammersmith and Fulham said that the Project

masterplan should follow the requirements and timetable set out by the

government in the NPS.

17.2.2 The London Borough of Hounslow commented that activities which generate noise

and pollution should be located where they generate the least harm for their

residents. They also highlighted that an important consideration should be the

objectives set out in neighbouring authorities’ local plans, particularly when

identifying appropriate sites for off-airport development.

17.2.3 Slough Borough Council expressed concern that the component options are not

presented as coherent strategies and indicated that it is important to understand

how these fit together to enable comment.

17.2.4 Spelthorne Borough Council agreed that the various components need to be

looked at together to establish whether there are interdependencies. They also

supported the assembly of components to form a Project masterplan in four sub

zones (north/north east, south west, west/north west and east/south east) but said

that the links between them need to be considered.

17.2.5 They also expressed concern that the seven proposed masterplanning themes as

detailed in Heathrow’s Scheme Development Report are inward looking and do

not give sufficient regard to the wider area outside the airport or the communities

of Stanwell Moor and Stanwell. They also queried whether community integration

will require physical access and connectivity or the provision of community

facilities.

Comments on specific factors/sites

17.2.6 Buckinghamshire County Council highlighted that historic environment field

evaluation should take place at an early a stage to inform the masterplan and

proposals for mitigation.

17.2.7 Kent County Council highlighted that safety must be the primary concern for the

Project masterplan. After safety has been considered, decisions will have to strike

a careful balance between operational efficiency and benefit to the communities

surrounding the airport. In order to achieve this, they suggested that Heathrow, the

CAA and the government work closely with community representatives and Local

Authorities to fully explore all possible options and, if unavoidable impacts are

identified, communities should be fully compensated.



17.2.8 Slough Borough Council considered that for the Colnbrook and Poyle areas, the

proposed Project masterplan should:

1. Protect Colnbrook and Poyle villages in a “Green Envelope”;

2. Enhance the Conservation Area and built realm;

3. Prevent all through traffic but provide 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

connectivity is maintained through Crown Meadow;

8. Develop tangible measures to improve air quality; and

9. Ensure that all homes in the Borough that are eligible for noise insulation are

provided for under the Quieter Homes Scheme.

17.2.9 They also highlighted that Clean Air Zone Emission standards should be required

on all airport related development and dedicated Ultra Low Emissions Zone

corridors for public transport and shuttle services.

17.2.10 The South East England Councils suggested that there should be clearer and

more comprehensive proposals for transport investment, improved road and rail

surface access and routes for non-airport traffic. They also suggested that clear

performance targets for noise and air pollution and proposals for how Heathrow

will work with the public sector to secure the non-transport infrastructure are

needed.

17.2.11 Spelthorne Borough Council suggested the inclusion of an additional

masterplanning theme on the wider impacts on local communities. They

highlighted that there should be more emphasis on how the development will

minimise the impact on local road networks, how noise or air quality impacts will

be minimised and mitigated, wider connectivity issues and the need for the modal

shift to be delivered by other options such as the southern rail route. They also

highlighted that consideration should be given to the temporary impacts of

construction as this may affect different communities to a greater or lesser extent

than the final expanded airport.



17.2.12 Surrey County Council highlighted that the Project masterplan needs to focus on

the interdependencies of specific elements and to be fully integrated with a

detailed surface access strategy that looks at both local and wider connectivity.

17.2.13 The London Borough of Sutton suggested the focus should be on improving public

transport access to the airport, reducing the impact of associated traffic on the

motorway and local road network and reducing jet noise corridors and associated

emissions.



17.2.14 Highways England said that surface access requirements must be a fundamental

basis of the Project masterplan and that it should not be fixed until robust traffic

modelling has been completed and reviewed by them. They suggested that there

should be weightings assigned to each of the discipline areas in Project

masterplan development and sought clarity on how discontinuation rules8 have

been established and applied.

17.2.15 Highways England also queried why discontinuation rule 1 rules out ‘AD’ options

for the diversion of the M25 (as detailed in Section 6 of Heathrow’s Scheme

Development Report), when in their view the re-design of the M25 J15 doesn’t

necessarily cause more deterioration in level of service than other options

considered.

17.2.16 Natural England suggested the role green infrastructure can play in storing carbon

and increasing the resilience of the development to the effects of climate change

should be considered as part of masterplanning.


17.2.17 Highways England said that the following should be considered:

1. Resilience of road access to Heathrow during incidents;

2. The use of other access points for people and freight during disruption;

3. Funding infrastructure improvements to minimise the impact of the Project

proposals on the surrounding road network during incidents;

4. Contingency planning for a major incident so that emergency vehicles can

avoid being caught up in road congestion; and

8 Discontinuation rules form part of the masterplanning process and are formulated so that options are discontinued if there is a high degree of confidence that the option is not feasible or prohibitively costly.



5. Surface access requirements.



17.2.18 The Heathrow Strategic Planning Group (HSPG) expressed concern at the lack of

an overall coherent strategy and that the options for specific components

appeared to be considered in isolation. They said that a set of objectives for a

‘reasonable alternative’ package of scheme options should be set out.


17.2.19 The HSPG considered that airport operations were important to understand the

implications of the components and packaged options on surrounding

communities and the environment.

17.2.20 Chobham Parish Council said that the public transport should be the basis for the

Project masterplan.

17.2.21 Colnbrook with Poyle Parish Council highlighted the importance of regular on-

going dialogue with stakeholders and transparency in areas that are not

commercially confidential. They also highlighted the importance of mitigating

adverse impacts and providing fair and adequate compensation where mitigation

is not possible.




17.3.1 Members of the public who made general comments, expressed support for the

development of a Project masterplan or recognised the need for one.

Respondents also expressed opposition to the Project generally or the

development of a Project masterplan due to its environmental or community

impacts.


17.3.2 Members of the public highlighted the impact of the Project on towns, villages and

residential properties, that the footprint of the development should be minimised to

reduce the loss of residential properties and that effects on quality of life should be

key factors. A number also highlighted that the Project masterplan should consider



the effect on local housing and include facilities for the community such as open

spaces, enhanced recreation, community halls and new leisure facilities.

17.3.3 There were a number of comments on the need to consider and minimise impacts

on the environment. The impact of noise, light and air pollution together with

impacts on wildlife/habitats, the landscape, the historic environment, watercourses

and flood risk were identified as important issues. Suggestions that the Project

masterplan should be undertaken to a unified plan, include a green ring around the

airport to reduce noise pollution and that noisy airport activities should be

positioned away from residential areas were also received.

17.3.4 Transport connections and access to the airport were also frequently highlighted.

Some members of the public said that the Project masterplan should be designed

to reduce or discourage car use. Others highlighted the importance of improved

and integrated public transport links including suggestions that there should be

high speed train links and improved access from the Great Western and South

Western mainlines, that connections to Stansted and Gatwick should be

considered, that a rail link to Crossrail should be provided from the new terminal

and that public transport to the terminals should be improved. A number of

respondents also highlighted that consideration should be given to monorail links

between the terminals.

17.3.5 Members of the public also highlighted the importance of minimising disruption for

local road and motorway users and the improvement of local roads and the

surrounding road network. Some suggested that the construction of underground

road connections should be maximised as a priority for the Project masterplan.

17.3.6 The importance of cost effectiveness, benefits to the economy, effects on

employment or jobs and ensuring local economic benefits were highlighted. A

small number of respondents also identified the cost to airlines and passengers as

important considerations.

17.3.7 Other factors highlighted by members of the public as important considerations in

the development of the Project masterplan were:

1. the safety and efficiency of the airport;

2. future capacity requirements;

3. long-term maintenance requirements;

4. use of renewable energy;

5. the creation of cycle paths;

6. the effects of nuisance parking/taxis;

7. minimising vehicle mileage by freight;



8. the creation of underground car parking;

9. fuel efficiency for both aircraft and vehicles;

10. reducing time for people to travel within the airport;

11. ensuring high quality design and buildings;

12. passenger experience;

13. flexibly priced hotel accommodation in appropriate locations;

14. the creation of a major high-rise mixed-use development and road tunnel in the

Stanwell and Stanwell Moor area; and

15. the replacement of the Grundon energy from waste plant.

17.3.8 A small number of comments were also received which suggested that the Project

masterplan was premature and that it should have greater regard to the objectives

set out in local plans.

Businesses


17.3.9 Segro supported the need for holistic masterplanning to ensure that the individual

elements of the Project masterplan are not planned in isolation and instead form

part of a bigger picture that boosts efficiency and productivity.

17.3.10 The Arora Group expressed concern that there has been a linear approach to

masterplanning and that the evaluation criteria have been inconsistently applied in

the assessment and refinement of scheme components. They queried why

variations of the Family C option for the runway (as detailed in Section 3 of

Heathrow’s Scheme Development Report) were excluded due to inconsistency

with the draft ANPS but other options that were also inconsistent were

taken forward.


17.3.11 Greengauge 21 highlighted the importance of consistency with the ANPS. They

also suggested that the adoption of a “two gateway” concept designed to serve

both those parking their cars and those dropping off passengers would result in a

higher level of security and safety.

17.3.12 Segro said that the Project masterplan should be based on a long-term vision that

embodies efficiency, productivity, prosperity and functionally whilst mitigating and

compensating for its impacts. They also said that consideration should be given to



how the Project masterplan links into other future infrastructure initiatives such as

western and southern rail access, to ensure these can be accommodated.

17.3.13 They considered that businesses, landowners, service and infrastructure providers

should be engaged throughout the masterplanning process and that it must

incorporate measures to mitigate disruption to existing communities and business

operations.

17.3.14 Airport Industrial Property Unit Trust highlighted that Heathrow should consider

how expert third parties could assist with the formulation and delivery of its Project

masterplan. They considered that the following criteria should be considered:

1. proximity to the principal road network for commercial, warehouse and

industrial uses;

2. proximity to control posts for airside access for commercial/cargo uses;

3. a defensible and rational new boundary to the greenbelt;

4. minimise traffic circulation on local and airport perimeter roads to reduce

congestion, emissions and noise;

5. maximising employment opportunities; and

6. minimising the effects on existing infrastructure during construction.

17.3.15 Virgin Atlantic Airways Limited (Virgin) highlighted that they (and their partners)

must have a fundamental role in the development of the Project masterplan to

ensure that the Project is able to deliver increased choice, competition and more

flights to new and existing destinations.

17.3.16 They said that important considerations in the development of the Project

masterplan were:

1. promoting choice and competition for passengers;

2. maximising the ability of transfer passengers to move quickly and efficiently

around the airport;

3. cost;

4. maximising operational efficiency (e.g. location of runway, taxiways, and

maintenance facilities);

5. ensuring passengers have a quality experience regardless of the terminal they

are using; and

6. competitive equivalence for all airlines using the airport.



17.3.17 They also highlighted that they would not support a Project masterplan that

prioritises development of the Western campus at the expense of the East or any

phasing plan that places Virgin and its partner airlines at a competitive

disadvantage. They also considered that it would not be in the best interest of

passengers for the newer and modern facilities in Terminals 2 and 5 to be further

improved, unless the rest of the Central Terminal Area receives similar focus and

investment.

17.3.18 The London Airline Consultative Committee and the Board of Airline

Representatives UK said that the views of the airline community must be a

significant factor in the decision-making process and that the Project masterplan

should:

1. be sustainable and fit for purpose for passengers, airlines and local

communities;

2. maintain (or reduce) airport charges at today’s level, preferably via a

passenger charges guarantee;

3. deliver safe, secure, resilient and efficient operations;

4. enable growth and the advancement of airlines strategic goals;

5. ensure equitable competition between airlines;

6. promote a sustainable approach to aviation; and

7. meet the requirements as put forward by the airline community.

17.3.19 The Surrey Chamber of Commerce highlighted the importance of access to the

airport, access to other facilities and quick access from Heathrow to London and

Surrey.

17.3.20 The Lanz Group suggested that a single plan should be produced showing how

each element relates to each other. They highlighted that any new land

designations need to ensure the proposed development is in keeping and that any

land for airport related development needs to demonstrate how it can be delivered

within a short space of time.

17.3.21 The Emerson Group considered that the demolition of office accommodation

(together with an adjoining landowner's hotel) was unjustified as they would be

replaced by facilities offering the exact same uses.

17.3.22 Easyjet highlighted the views of the community on the local effects and the cost

impact to passengers as the key factors.

17.3.23 Heathrow Airport Fuel Company highlighted the importance of fuel related

developments to the Project masterplan and requested further engagement.



17.3.24 The Heathrow Hydrant Operating Company highlighted the importance of ensuring

unrestricted access to and from its sites at all times.

17.3.25 Suez UK highlighted design and deliverability of a sustainable expanded airport.

17.3.26 Hatton Farm Estates Limited highlighted speed and minimising the risks of delay

as important factors.

17.3.27 The Copas Partnership highlighted safety and efficiency as important factors in the

development of the Project masterplan.

Community groups




include specific feedback on the masterplan.

17.3.29 Stanwell’s Green Lungs, Teddington Action Group and Aircraft Noise 3 Villages all

expressed opposition to the development of a Project masterplan until parliament

agrees to the Project and until actual conditions for building the new runway are

finalised. AN3V commented that if parliament does approve the Project, Heathrow

should concentrate on better management of night flights, air pollution, noise

pollution and flight paths.


17.3.30 The Local Authorities Aircraft Noise Council said that any Project masterplan

should follow the framework of requirements and timetable set out by the

government in its final NPS.

17.3.31 Englefield Green Action Group requested a guarantee that there will be no

increase in night flights, noise or air pollution, that public money would not be used

to cover any budget shortfalls and that Heathrow will stop its continual drive for

growth.

17.3.32 The Richmond Heathrow Campaign said that the most important factors for the

Project masterplan were the impacts on local and wider communities, noise

reduction, air quality, reducing carbon emissions and incentivising the “greenest”

aircraft operations. Costs for passengers and taxpayers should also be an

important consideration.

17.3.33 The Colnbrook Community Partnership said the key factors in the development of

the Project masterplan should be:



1. consideration of the cumulative impacts arising from other major developments

in the area;

2. ensuring the continuity of the ecological network through Crown Meadow, the

land between the Bath Road and the Colnbrook Bypass, and the area between

the Colnbrook Bypass and the M4;

3. protecting the communities of Brands Hill, Colnbrook and Poyle within a Green

Envelope;

4. providing mitigation for the Colne Valley Park in Slough, Spelthorne, South

Bucks and Hillingdon; and

5. ensuring that air quality is not made worse for the communities of

Colnbrook/Poyle/Brands Hill.

17.3.34 The Camberley Society highlighted benefits to the economy, the protection of

people, transport links (rail and bus) to the West, South West and South and

protecting biodiversity and wildlife as important factors.

17.3.35 Local Conversation in Stanwell expressed concern that the masterplanning

themes do not give sufficient prominence to the wider impacts on the communities

of Stanwell Moor and Stanwell. They suggested the inclusion of an additional

theme on the wider impacts to local communities and said that there should be

more emphasis on how the development will minimise the impact on local road

networks, how noise or air quality impacts will be minimised and mitigated, wider

connectivity issues and the need for the modal shift to be delivered by other

options such as the southern rail route.

17.3.36 They queried whether community integration means opening up physical access

and connectivity or the delivery of community facilities. They said that Stanwell

and Stanwell Moor would benefit from a shared leisure facility.



17.4.1 The London Parks and Gardens Trust questioned the overall scale of the Project

and said that development should be confined within the envelope of the airport

site.

17.4.2 The Buckinghamshire and Milton Keynes Natural Environment Partnership

highlighted the importance of ensuring that all aspects of the environment and the

benefits it provides to people, wildlife and the economy are taken into account in

options development and any future stages of the Project.



17.4.3 West London Friends of the Earth commented that a Project masterplan should

not be developed until the government agrees to a third runway and any

conditions, such as limits on use due to air pollution, are finalised.

17.4.4 Friends of the River Crane highlighted the urgent need for an overall Project

masterplan for open spaces to ensure that protection of and value of green

infrastructure9 is considered as part of the wider plans for Heathrow. They

highlighted that this needs to be developed with key interested parties – including

the partnerships that have been operating over the last ten to fifteen years to

protect and enhance these corridors and catchments.

17.4.5 The Kingston Environment Forum expressed opposition to the Project and

suggested that Heathrow should consider the environment, air quality, climate

change, and the needs of Londoners by not expanding.


17.4.6 The Colne Valley Regional Park and the London Wildlife Trust both said that

Heathrow must implement a Green and Blue Infrastructure Plan that takes a

landscape-scale vision and multi-functional approach to mitigation and long-term

management. Green and Blue Infrastructure must connect and function together in

its own right, rather than simply be located in the parcels of land left over once

other airport-related development has been planned. They also highlighted that

the Project masterplan needs to give consideration to strategic green corridors that

connect both habitats and recreational routes across the Colne and Crane

catchments and further afield.

17.4.7 They also identified that individual airlines own growth projections, technological

developments, and assessments of future needs should be considered and

assessed as part of the Project masterplan process.

17.4.8 The London Parks and Gardens Trust requested further consideration be given to

the visual intrusion of the Project from nearby historic landscapes such as

Cranford Country Park, Victoria Lane Burial Ground, St Mary's Churchyard,

Harmondsworth Burial Ground and Harmondsworth Village Green.

17.4.9 The Chartered Institution of Highways and Transportation considered the effects

on public health and the impact on the road network are important considerations.

They highlighted that surface transport must contribute to an overall network that

is more accessible, more resilient and delivers for people.

9 Green Infrastructure refers to a strategically planned and managed network of green spaces and other environmental features vital to the sustainability of any urban area. Green Infrastructure also encompasses river systems and coastal environments (these are sometimes also refer to as Blue Infrastructure).



17.4.10 Aviation Safety Investigations commented that the Project masterplan must learn

the lessons from bad runway and taxiway design in the past at other airports and

include modern risk management techniques. They expressed concern that none

of this was included within the current Project masterplan.

17.4.11 Lambeth/Herne Hill Green Party commented that the Project masterplan must

enable Heathrow to achieve its aim of ensuring that by 2030 at least 50% of those

travelling to and from the airport will use public transport.




Tables 17.1A and 17.1B present a summary of the main issues raised by prescribed consultees, local communities and

wider/other consultees in relation to Masterplanning.

Table 17.1A 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 17.1B 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 17.1A


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Request for a guarantee that there will be no increase in night flights.

✓ In the January 2019 Airspace and Future Operations Consultation, Heathrow has provided more information about our emerging proposals in relation to the management of night flights. For more information, please see Heathrow's Airspace and Future Operations Consultation Document and the Runway Operations - Night Flights documents which are part of the January 2019 Airspace and Future





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Operations Consultation.

If parliament does approve expansion, Heathrow should concentrate on night flights, air pollution, noise pollution and flight paths.

✓ In relation to Night Flights In the January 2019 Airspace and Future Operations Consultation, Heathrow has provided more information about our emerging proposals on relation to the management of night flights. For more information, please see Heathrow's Airspace and Future Operations Consultation Document and the Runway Operations - Night Flights documents which are part of the January 2019 Airspace and Future Operations Consultation. In relation to flight paths This consultation (Airspace and Future Operations Consultation 2019) is seeking feedback on proposals for night flights, as well as what local factors Heathrow should take into account when designing flight paths for expansion. For more detail please refer to the Airspace and Future Operations Consultation Document. In relation to noise pollution Heathrow is committed to introducing noise mitigation measures to reduce the impact of noise over London. For example, Heathrow has committed to providing respite through alternation in order to provide overflown communities with predictable periods of relief from aircraft noise. In the January 2019 Airspace and Future Operations Consultation, Heathrow has provided more information about some of the operational measures we plan to take to mitigate operational noise at an expanded Heathrow. More information can be found in the Heathrow's Airspace and Future Operations Consultation Document, and related documents.




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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. For responses in relation to air quality, please see Chapter 21 of this Consultation One Interim Consultation Feedback Report.

Clean Air Zone Emission standards should be required on all airport related development. There should be clear performance targets for noise and air pollution.

✓ As part of the DCO application, Heathrow proposes to include legally binding obligations to ensure that the growth of the airport is only allowed to take place within the boundaries of the environmental criteria set out in the ANPS. This will include noise and air quality. We have described this concept further in the Airspace and Future Operations Consultation Document, which is part of the January 2019 consultation We will set out detailed proposals for how future growth will be managed as part of our Airport Expansion Consultation planned for June 2019.



Table 17.1B

Issue Consultee Heathrow Response

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Support expressed for the development of four sub zonal assemblies but the links between them need to be considered.

✓ Airport Expansion Consultation One was undertaken early in the design process and therefore focused on individual components. The Masterplan Scheme Development Manual (MSDM) sets out the process and methodology for identifying and evaluating scheme options and selecting the scheme that will be the subject of the DCO application. This process was summarised in section two of the Scheme Development Report presented at Airport Expansion Consultation One. Individual masterplan components are considered first in isolation but then combined and tested both geographically and thematically. As part of this process, interdependencies and/or conflicts between options are being identified and considered as we progress towards a preferred masterplan, which will form the basis of the Airport Expansion Consultation in June 2019.

Concern that the component options are not presented as coherent strategies. It is important to understand how these fit together to enable comment.

✓

The masterplan needs to focus on the interdependencies of specific elements and be fully integrated with a detailed surface access strategy that looks at both local and wider connectivity.

✓

Concern at the lack of an overall coherent strategy and that the options for specific components appeared to be considered in isolation.

✓

The masterplan should be undertaken to a unified plan. ✓

There is a need for a holistic masterplan to ensure that the individual elements of the masterplan are not planned in isolation and instead form part of a bigger picture that boosts efficiency and productivity.

✓

A single plan should be produced showing how each element relates to each other.

✓

In developing a masterplan various components need to be looked at together to establish whether there are interdependencies.

✓

The wider impacts on local communities should be included as an additional masterplanning theme.

✓ The MSDM sets out the process and methodology for identifying and evaluating scheme options and selecting the scheme that will be the subject of the DCO application. Prior to Airport Expansion Consultation One, Heathrow consulted local authorities, certain statutory bodies and the airline community on the process set out in the MSDM and had regard to all

There should be more emphasis on how noise impacts will be minimised and mitigated.

✓

There should be more emphasis on how the air quality impacts will be minimised and mitigated.

✓




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There should be more emphasis on wider connectivity issues as part of the masterplan process.

✓ feedback received and lessons learned in updating it.

Appendix B of the MSDM comprises the Evaluation Criteria Handbook, which sets out the evaluation criteria that have been applied to assess both the component options and the masterplan assemblies. The criteria were generated by the Subject and Discipline Leads for each of the following Discipline Areas:

• Operations and Service Discipline;

• Business Case Discipline;

• Sustainability Discipline;

• Community Discipline; and

• Planning and Property Discipline.

Each of these Discipline Areas has developed detailed sub-criteria, to ensure the assessment is as robust and comprehensive as possible.

The criteria seek to ensure that all the important and relevant considerations in the development of the masterplan are given proper and full consideration. We are confident that we have undertaken an extensive, transparent and thorough evaluation of all feasible masterplan options and have properly considered all relevant considerations. The outcome of the assessment process will be contained in the Updated Scheme Development Report which, together with the preferred masterplan, will be presented as part of the Airport Expansion Consultation in June 2019.

There should be more emphasis on the need for the modal shift to be delivered by other options such as the southern rail route.

✓

The role green infrastructure can play in storing carbon and increasing the resilience of the development to the effects of climate change should be considered as part of masterplanning.

✓

In developing a masterplan resilience of road access/contingency planning to Heathrow during incidents should be considered, specifically for emergency vehicles.

✓

In developing a masterplan the use of other access points for people and freight during disruption should be considered.

✓

Surface access requirements should be considered as part of developing a masterplan.

✓

The views of the community on the local effects are key factors for the masterplan.

✓

The effects on people’s quality of life should be key factor in the development of the masterplan.

✓

The masterplan should consider the effect on local housing. ✓

In developing a masterplan there is a need to consider and minimise impacts on the environment.

✓

In developing a masterplan there is a need to consider the impact of noise.

✓

In developing a masterplan there is a need to consider light and air pollution.

✓

In developing a masterplan there is a need to consider impacts on wildlife/habitats.

✓

In developing a masterplan there is a need to consider the ✓




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landscape.

In developing a masterplan there is a need to consider the historic environment.

✓

In developing a masterplan there is a need to consider watercourses and flood risk.

✓

The importance of cost effectiveness, benefits to the economy, effects on employment or jobs and ensuring local economic benefits are important factors for the masterplan.

✓

The cost to airlines and passengers are important considerations in developing a masterplan.

✓

Important considerations in the development of the masterplan include the safety and efficiency of the airport.

✓

Important considerations in the development of the masterplan include future capacity requirements.

✓

Important considerations in the development of the masterplan include long-term maintenance requirements.

✓

Important considerations in the development of the masterplan include use of renewable energy.

✓

Important considerations in the development of the masterplan include the creation of cycle paths.

✓

Important considerations in the development of the masterplan include the effects of nuisance parking/taxis.

✓

Important considerations in the development of the masterplan include minimising vehicle mileage by freight.

✓

Important considerations in the development of the masterplan include the creation of underground car parking.

✓

Important considerations in the development of the masterplan include fuel efficiency for both aircraft and vehicles.

✓




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Important considerations in the development of the masterplan include reducing time for people to travel within the airport.

✓

Important considerations in the development of the masterplan include ensuring high quality design and buildings.

✓

Important considerations in the development of the masterplan include passenger experience.

✓

Important considerations in the development of the masterplan include flexibly priced hotel accommodation in appropriate locations.

✓

Important considerations in the development of the masterplan include the creation of a major high-rise mixed-use development and road tunnel in the Stanwell and Stanwell Moor area.

✓

In developing a masterplan, consistency with the ANPS is important.

✓

The masterplan must incorporate measures to mitigate disruption to existing communities and business operations.

✓

In delivering a masterplan proximity to the principal road network for commercial, warehouse and industrial uses should be considered.

✓

In delivering a masterplan proximity to control posts for airside access for commercial/cargo uses should be considered.

✓

In delivering a masterplan minimising traffic circulation on local and airport perimeter roads to reduce congestion, emissions and noise should be considered.

✓

In delivering a masterplan maximising employment opportunities should be considered.

✓

In delivering a masterplan minimising the effects on existing infrastructure during construction should be considered.

✓

Promoting choice and competition for passengers is an important ✓




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consideration in the development of the masterplan.

Maximising the ability of transfer passengers to move quickly and efficiently around the airport is an important consideration in the development of the masterplan.

✓

Maximising operational efficiency (e.g. location of runway, taxiways, and maintenance facilities) is an important consideration in the development of the masterplan.

✓

Ensuring passengers have a quality experience regardless of the terminal they are using is an important consideration in the development of the masterplan.

✓

Competitive equivalence for all airlines using the airport is an important consideration in the development of the masterplan.

✓

The importance of access to the airport, access to other facilities and quick access from Heathrow to London and Surrey is an important factor for the masterplan.

✓

Ensuring unrestricted access to and from businesses sites is an important factor.

✓

The design and deliverability of a sustainable expanded airport is an important factor.

✓

Speed and minimising the risks of delay are important factors. ✓

Safety and efficiency are important factors in the development of the masterplan.

✓

Costs for passengers and taxpayers should be an important consideration.

✓

Consideration of the cumulative impacts arising from other major developments in the area are key factors in the development of the masterplan.

✓

Concern that the masterplanning themes do not give sufficient prominence to the wider impacts on the communities of Stanwell

✓




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Moor and Stanwell

The inclusion of an additional theme on the wider impacts to local communities is needed for the masterplan.

✓

The effects on public health are important considerations. ✓

The most important factors for the masterplan were the impacts on local and wider communities.

✓ Heathrow recognises that there are a wide range of complex factors to be considered, and the responses received highlight how different aspects are important to different stakeholders. Heathrow is following a rigorous approach to masterplan development supported by the MSDM. A key aspect of this is the recognition that there are many competing priorities which need to be balanced in order to arrive at the scheme which will form the basis of the DCO application. The masterplan scheme development process is therefore being approached on a multi-disciplinary basis with equal weighting between all disciplines. All factors are being considered on an equal basis and weighed in the balance in the overall assessment of options. This process is ongoing and the updated assessment of masterplan assembly options will be contained in the Updated Scheme Development Report which, together with the preferred masterplan, will be presented as part of the Airport Expansion Consultation in June 2019.

The most important factors for the masterplan were noise reduction.

✓

The most important factors for the masterplan were air quality. ✓

The most important factors for the masterplan were reducing carbon emissions.

✓

The most important factors for the masterplan were incentivising the “greenest” aircraft operations.

✓

Ensuring the continuity of the ecological network through Crown Meadow, the land between the Bath Road and the Colnbrook Bypass, and the area between the Colnbrook Bypass and the M4 are key factors in the development of the masterplan.

✓

Protecting the communities of Brands Hill, Colnbrook and Poyle within a Green Envelope in the area are key factors in the development of the masterplan.

✓

Providing mitigation for the Colne Valley Park in Slough, Spelthorne, South Bucks and Hillingdon are key factors in the development of the masterplan.

✓

Ensuring that air quality is not made worse for the communities of Colnbrook/Poyle/Brands Hill in the area are key factors in the development of the masterplan.

✓

Benefits to the economy are important factors for the masterplan. ✓




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Protection of people are important factors for the masterplan. ✓

Protecting biodiversity and wildlife as important factors are important factors for the masterplan.

✓

There should be more emphasis on how the development will minimise noise.

✓

There should be more emphasis on how air quality impacts will be minimised and mitigated.

✓

The importance of ensuring that all aspects of the environment and the benefits it provides to people, wildlife and the economy are taken into account in options development and any future stages of Heathrow expansion.

✓

Further consideration should be given to the visual intrusion from nearby historic landscapes such as Cranford Country Park, Victoria Lane Burial Ground, St Mary's Churchyard, Harmondsworth Burial Ground and Harmondsworth Village Green.

✓

There should be more emphasis on how the development will minimise the impact on local road networks.

✓ Heathrow understands the importance of ensuring that passengers, colleagues and other people can get to and from the airport with a choice of safe, reliable, efficient and sustainable options. At Airport Expansion Consultation One we set out our approach to the development of our Surface Access Strategy (SAS). Work on this has continued and the Airport Expansion Consultation in June 2019 will present our draft SAS and supporting technical information in a Preliminary Transport Information Report. This will explain Heathrow’s preferred options for the transport infrastructure needed to support expansion 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. The

A dedicated Ultra Low Emissions Zone corridors for public transport and shuttle services should be required.

✓

There should be clearer and more comprehensive proposals for transport investment.

✓

There should be improved road and rail surface access. ✓

There should be routes for non-airport traffic. ✓

Surface access requirements must be a fundamental basis of the masterplan.

✓

The masterplan should not be fixed until robust traffic modelling has been completed and reviewed by consultees.

✓




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Public transport should be the basis for the masterplan. ✓ draft SAS 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 draft Surface Access Strategy (SAS) will also consider opportunities to provide improved facilities for walking and cycling wherever feasible, although inevitably there will be restrictions on access within the airfield. In parallel with this we are carefully assessing the transport implications of the emerging masterplan proposals using traffic modelling and this will be reflected in the draft SAS. Underground road links are being considered where necessary (e.g. one option for the A4 diversion and for the Southern Access tunnel to the Central Terminal Area) but the additional costs involved in underground construction are a consideration. The Western Rail Link to Heathrow is being developed by Network Rail as a separate DCO application and does not form part of the Project. Likewise, the Southern Rail Link is an aspiration that others have to deliver additional rail capacity. Heathrow supports the principle of both schemes and is working closely with all interested parties to seek to ensure compatibility with the preferred masterplan which will be presented as part of Our Airport Expansion Consultation in June 2019.

The masterplan should be designed to reduce or discourage car use.

✓

The masterplan should focus on improved and integrated public transport links.

✓

There should be high speed train links and improved access from the Great Western and South Western mainlines.

✓

Connections to Stanstead and Gatwick should be considered. ✓

A rail link to Crossrail should be provided from the new terminal. ✓

Public transport to the terminals should be improved. ✓

Disruption to local road and motorway users and the improvement of local roads and the surrounding road network should be minimised.

✓

Construction of underground road connections should be maximised as a priority for the masterplan.

✓

Transport links (rail and bus) to the West, South West and South are important factors for the masterplan

✓

There should be more emphasis on how the development will minimise the impact on local road networks.

✓

There should be more emphasis on wider connectivity issues and the need for the modal shift to be delivered by other options such as the southern rail route.

✓

The impact on the road network are important considerations. ✓

Surface transport must contribute to an overall network that is more accessible, more resilient and delivers for people.

✓

The masterplan must enable Heathrow to achieve its aim of ensuring that by 2030 at least 50% of those travelling to and from the airport will use public transport.

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In developing a masterplan funding infrastructure improvements to minimise the impact of airport expansion proposals on the surrounding road network during incidents should be considered.

✓

For the Colnbrook and Poyle areas the proposed masterplan should protect Colnbrook and Poyle villages in a “Green Envelope”.

✓ Heathrow are grateful to receive further information relating to prospective sites for Airport Related Development (ARD) at Poyle and Colnbrook. We are carefully considering the points raised and will have regard to these in deciding whether to take these sites forward into the DCO application and what their potential uses might be. Our preferred masterplan will be available at Airport Expansion Consultation in June 2019 and the Updated Scheme Development Report will explain the basis on which particular sites have been taken forward. The likely significant environmental effects from the Project will be assessed as part of the environmental impact assessment (EIA) and this will include mitigation proposals, including for air quality, if appropriate. Early findings will be reported in the PEIR at Airport Expansion Consultation in June 2019. 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.

For the Colnbrook and Poyle areas the proposed masterplan should enhance the Conservation Area and built realm.

✓

For the Colnbrook and Poyle areas the proposed masterplan should prevent all through traffic but provide good public transport and cycle routes to the airport.

✓

For the Colnbrook and Poyle areas the proposed masterplan should provide for the replacement of Grundon energy from waste plant and the rail deport north of the new runway.

✓

For the Colnbrook and Poyle areas the proposed masterplan should ensure that there are good public transport links into Heathrow from Slough.

✓

For the Colnbrook and Poyle areas the proposed masterplan should enlarge the Poyle Trading Estate for airport related development but with access only from the M25.

✓

For the Colnbrook and Poyle areas the proposed masterplan should provide mitigation for the Colne Valley Park and ensure that existing connectivity is maintained through Crown Meadow.

✓

For the Colnbrook and Poyle areas the proposed masterplan should develop tangible measures to improve air quality.

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A replacement facility will require consent from the relevant local planning authority.

For the Colnbrook and Poyle areas the proposed masterplan should ensure that all homes in the Borough that are eligible for noise insulation are provided for under the Quieter Homes Scheme.

✓ All areas that are eligible under the Quieter Homes Scheme will be offered noise insulation.

Important considerations in the development of the masterplan include the replacement of the Grundon energy from waste plant.


In delivering a masterplan a defensible and rational new boundary to the greenbelt should be considered.

✓ Where practicable, Heathrow will seek to minimise the amount of Green Belt which is required for the Project, but the use of some Green Belt land is unavoidable given that almost all the land surrounding the airport (and including part of the existing airport) is designated as such. Defining a rational or defensible boundary to the green belt is a function of the statutory Development Plan process. It is not something that can be achieved through promotion of a DCO application, but as part of that application, we will be seeking to demonstrate that the urgent need for the Project comprises very special circumstances in greenbelt




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policy terms.

The views of the Airline Community must be a significant factor in the decision-making process.

✓ Heathrow considers that the views of all those with an interest in the project are important and are engaging regularly with the airline community on the emerging masterplan. We are fully aware of the opportunity for expansion to deliver increased choice and competition for passengers and are also engaging regularly with the Civil Aviation Authority (CAA), which has responsibility for overall economic regulation, including competition between airlines.

The masterplan should enable growth and the advancement of airlines strategic goals.

✓ ✓

The masterplan should ensure equitable competition between airlines.

✓ ✓

The masterplan should meet the requirements as put forward by the Airline Community.

✓ ✓

Individual airlines own growth projections, technological developments, and assessments of future needs should be considered and assessed as part of the masterplan process.

✓

Airlines should have a fundamental role in the development of the masterplan to ensure that Heathrow expansion is able to deliver increased choice, competition and more flights to new and existing destinations.

✓

Fuel related developments are important to the masterplan and further engagement on this topic is requested.

✓ Our early options for Fuel related development were presented at Airport Expansion Consultation One. We are continuing to develop our proposals and the preferred options will be presented as part of Airport Expansion Consultation in June 2019.

There is a need for an overall Masterplan for open spaces to ensure that protection of and value of green infrastructure is considered as part of the wider plans for Heathrow.

✓ We set out our design approach to the natural environment at Airport Expansion Consultation One. This document was clear that we were following a multi-functional approach to the design of the natural environment. We have continued to develop our

The Masterplan for open spaces needs to be developed with key interested parties – including the partnerships that have been

✓




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operating over the last ten to fifteen years to protect and enhance these corridors and catchments.

thinking since then, in consultation with our stakeholders, and our plans for blue and green infrastructure are an integral part of the overall masterplan that we will share at Airport Expansion Consultation in June 2019.

Heathrow must implement a Green and Blue Infrastructure Plan that takes a landscape-scale vision and multi-functional approach to mitigation and long-term management.

✓

Green and Blue Infrastructure must connect and function together in its own right, rather than simply located in the bits left over once other airport-related development has been planned.

✓

The Masterplan needs to give consideration to strategic green corridors that connect both habitats and recreational routes across the Colne and Crane catchments and further afield.

✓

Activities that generate noise and pollution should be located where they generate the least harm for their residents.

✓ Quieter airport design will encompass the location of noisy activities (e.g. areas for engine testing) in suitable locations and this factor is being considered in masterplan scheme development. The EIA which will accompany the DCO application will include an assessment of likely significant environmental effects during both construction and operation of the expanded airport. Preliminary findings will be presented in the PEIR in the Airport Expansion Consultation in June 2019.

Noisy airport activities should be positioned away from residential areas.

✓

An important consideration for the masterplan should be the objectives set out in neighbouring authorities local plans, particularly when identifying appropriate sites for off-airport development.

✓ Heathrow is working closely with HSPG and will continue to do so throughout the DCO process. ARD is essential to support the efficient functioning of the airport so it is appropriate to include an element of ARD in our proposals. This will ensure that sufficient land is brought forward in a planned and co-ordinated manner.

Concern that the seven proposed masterplanning themes are ✓ The seven masterplanning themes referred to were not




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inward looking and do not give sufficient regard to the wider area outside the airport or the communities of Stanwell Moor and Stanwell.

part of Consultation One but were shared with HSPG during engagement. The MSDM includes a wide range of considerations in the evaluation criteria used for appraising different options and masterplan components, including community impacts. This has ensured that the impacts on local communities are being fully considered and weighed in the balance at all stages of masterplan scheme development.

Query whether community integration will require physical access and connectivity or the provision of community facilities.

✓ Community integration could involve both physical access and connectivity or the provision of community facilities. In 2018 we held community engagement workshops to discuss our emerging plans further. We will provide more detail on how we will manage the interaction between expansion and local communities through the preferred masterplan and the other material which we will present at Airport Expansion Consultation in June 2019.

The masterplan should follow the requirements and timetable set out by the Government in the ANPS.

✓ Agreed, the DCO application will comply with the policy tests in the ANPS and, in view of the urgent need for expansion which is recognised in the ANPS, we are working quickly to progress the DCO application, engaging with communities, landowners, and other interested parties at every stage of the process.

Any emerging airport expansion strategy should seek to capitalise on the airport as a catalyst for regeneration and inward investment whilst mitigating any adverse environmental impacts.

✓ Agreed, both these factors are recognised in the ANPS and by Heathrow and through the development of the preferred masterplan we are seeking to strike the right balance between all the competing requirements for expansion.

After safety has been considered, decisions will have to strike a ✓ Heathrow recognises that safety is key to airfield




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careful balance between operational efficiency and benefit to the communities surrounding the airport. In order to achieve this Heathrow, the CAA and the Government should work closely with community representatives and Local Authorities to fully explore all possible options and if unavoidable impacts are identified communities should be fully compensated.

operations and this has been factored into the masterplan scheme development process. This has included consideration of international safety standards, which are overseen by the CAA. We recognise that the Project may have a range of impacts during construction and operation, and we are committed to manage and mitigate them to minimise effects on local communities. We are seeking to work closely with local communities and local authorities, as well as the CAA and Government throughout the DCO process. The new Community Engagement Board will ensure the widest possible community engagement throughout the planning process for expansion and longer-term into the construction and operational phase of the Project.

Historic environment field evaluation should take place at an early a stage to inform the masterplan and proposals for mitigation.

✓ Agreed, historic environment field evaluation is informing the masterplan and our proposals for mitigation. Further information on the historic environment is presented in Chapter 24.

Consideration should be given to the temporary impacts of construction as this may affect different communities to a greater or lesser extent than the final expanded airport.

✓ The EIA which will accompany the DCO application will include an assessment of likely significant environmental effects during both construction and operation of the expanded airport. Preliminary findings will be presented in the PEIR in the Airport Expansion Consultation in June 2019.

Heathrow should set out proposals for how it will work with the public sector to secure the non-transport infrastructure that is needed.

✓ Heathrow is working closely with HSPG as well as the statutory utility companies to ensure that appropriate provision is made for all infrastructure required by the




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Project. We are working closely with the HSPG to assess the wider growth and infrastructure development which is likely to be generated by the Project.

Weightings should be assigned to each of the discipline areas in masterplan development.

✓ The masterplan scheme development process is being approached on a multi-disciplinary basis with equal weighting between all disciplines. This will ensure that an appropriate weighing of relevant issues takes place on a case by case basis.

Clarity sought on how discontinuation rules have been established and applied.

✓ The MSDM explains how the back-check process works to reconsider previously discontinued options if new material information comes to light. The Scheme Development Report at Airport Expansion Consultation One demonstrated how this worked in practice and an Updated Scheme Development Report will be available at the Airport Expansion Consultation in June 2019. The reference to “AD options” is believed to be a reference to an M25 Junction 15 option which was presented at Airport Expansion Consultation One. This was discontinued because it would have involved costly and disruptive works to J15 during construction. This was explained in the Scheme Development Report at paragraph. 6.4.20.

Why does discontinuation rule 1 rule out ‘AD’ options, when the re-design of the M25 J15 doesn’t necessarily cause more deterioration in level of service than other options considered?

✓

A set of objectives for a ‘reasonable alternative’ package of scheme options should be set out. Airport operations were important to understand the implications of the components and packaged options on surrounding communities and the environment.

✓ The MSDM sets out the process and methodology for identifying and evaluating scheme options and selecting the scheme that will be the subject of the DCO application. This includes evaluation criteria designed to capture impacts on surrounding communities. Heathrow have consulted local authorities, certain statutory bodies and the airline




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community on the process set out in the MSDM and have had regard to all feedback received and lessons learned in updating it. We are confident that we have undertaken an extensive, transparent and thorough evaluation of all feasible options.

The importance of regular on-going dialogue with stakeholders and transparency in areas that are not commercially confidential should be considered.

✓ Heathrow recognises that consultation and engagement with external stakeholders is an integral part of the masterplan scheme development process. We are engaging regularly with affected businesses, landowners, service and infrastructure providers.

Businesses, landowners, service and infrastructure providers should be engaged throughout the masterplanning process.

✓

The importance of mitigating adverse impacts and providing fair and adequate compensation where mitigation is not possible should be considered.

✓ The Environmental Statement (ES) which will accompany the DCO application will assess any significant likely environmental effects and put forward any necessary mitigation. Preliminary findings will be presented in the PEIR in the Airport Expansion Consultation in June 2019. Heathrow has developed Land Acquisition and Compensation Policies for Residential Property, Agricultural Land and Property, and Commercial Property, as well as a Property Hardship Scheme to help minimise and manage any unavoidable negative impact. Updated policies will also be presented in 2019.

Support expressed for the development of a masterplan or recognition of the need for one.

✓ Support noted.

Opposition to expansion generally or the development of a masterplan due to its environmental or community impacts.

✓ The ANPS recognises that there is an urgent need for new airport capacity in the South East (paragraphs. 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 (paragraph. 3.74). The ES which will accompany the




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DCO application will assess any significant likely environmental effects and put forward any necessary mitigation. Preliminary findings will be presented in the PEIR in the Airport Expansion Consultation in June 2019.

Concern about the impact of expansion on towns, villages and residential properties.

✓ Heathrow will need to acquire areas of land which currently include residential, commercial and agricultural properties. We are aiming to minimise the scale of such acquisition but recognise it will be considerable given that the airport lies in a densely populated sub-region. The preferred masterplan will be available as part of Airport Expansion Consultation in June 2019.

The footprint of the development should be minimised to reduce the loss of residential properties.

✓

The masterplan should include facilities for the community such as open spaces, enhanced recreation, community halls and new leisure facilities.

✓ The preferred masterplan to be presented at Airport Expansion Consultation in June 2019 will include provision for community facilities if these are displaced by expansion, in accordance with the policy requirements in the ANPS.

The masterplan should include a green ring around the airport to reduce noise pollution.

✓ Heathrow set out our design approach to the natural environment at Airport Expansion Consultation One. We have continued to develop our thinking since then, in consultation with our stakeholders, and our plans for blue and green infrastructure are an integral part of the preferred masterplan that will be presented at Airport Expansion Consultation in June 2019.

Consideration should be given to monorail links between the terminals.

✓ Efficient linkages between terminals are important. Heathrow will share our thinking on the detailed airfield layout as part of the preferred masterplan that will be presented at Airport Expansion Consultation in June




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2019.

The masterplan was premature and it should have greater regard to the objectives set out in local plans.

✓ 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). In the light of these factors the programme for the masterplan and DCO application is considered appropriate. In developing the preferred masterplan we had regard to the ANPS, the National Planning Policy Framework (NPPF) and the objectives of the surrounding Local Plans, wherever practicable.

Concern that there has been a linear approach to masterplanning and that the evaluation criteria has been inconsistently applied in the assessment and refinement of scheme components.

✓ Heathrow are working through a transparent and logical process of strategic definition, component options development, masterplan options development and masterplan finalisation, leading to a DCO application. This is a transparent process and the way that the evaluation criteria have been applied was clear at Airport Expansion Consultation One from the analysis set out in the Scheme Development Report. An Updated Scheme Development Report will be available at the Airport Expansion Consultation in June 2019.

Why have variations of the Family C option been excluded due to inconsistency with the draft ANPS but other options that were also inconsistent been taken forward?

✓ Family C options related to a set of runway options which were presented at Airport Expansion Consultation One which extended to the east of the M4 spur. These were discontinued as they were not considered to be consistent with the principles of a north west runway scheme and because of significantly increased property loss, noise, air quality and community impacts, particularly in Sipson and Harlington. This analysis was set out in the Scheme




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Development Report published as part of Airport Expansion Consultation One. The ANPS has now been designated and our masterplan scheme development process will seek to ensure consistency with the ANPS as we continue to develop our plans in detail.

Suggestion that a “two gateway” concept, designed to serve both those parking their cars and those dropping off passengers, would result in a higher level of security and safety.

✓ Safety and security are key to airfield operations and have been factored into the masterplan scheme development process (guided by the MSDM). The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

The masterplan should be based on a long-term vision that embodies efficiency, productivity, prosperity and functionally whilst mitigating and compensating for its impacts.

✓ The Strategic Brief is Heathrow’s long term strategic vision for an expanded airport in order to realise its vision of giving passengers the best airport service in the world. The Brief contains five overarching propositions relating to airlines, passengers, community and environment, investors and colleagues. The Brief outlines a number of outcomes and benefits which an expanded Heathrow will bring for each of these propositions.

Consideration should be given to how the masterplan links into other future infrastructure initiatives such as western and southern rail access, to ensure these can be accommodated.

✓ The Western Rail Link to Heathrow is being developed by Network Rail as a separate DCO application and does not form part of the Project. Likewise, the Southern Rail Link is an aspiration that others have to deliver additional rail capacity. Heathrow supports the principle of both projects and is working closely with all interested parties to ensure compatibility with the preferred masterplan that will be presented at Airport Expansion Consultation in June 2019.

Heathrow should consider how expert third parties could assist ✓ Heathrow is engaging with expert third parties where




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with the formulation and delivery of its masterplan. necessary – e.g. in relation to specialist aspects of noise and air quality assessment and earthworks engineering.

Objection to a masterplan that prioritises development of the Western campus at the expense of the East or any phasing plan that places some airlines at a competitive disadvantage.

✓ Three areas for future terminal capacity and apron space are being considered (Area 1 East, Area 2 West and Area 3 North) and at Airport Expansion Consultation One, the Consultation Booklet, section 2.2, explained that it is possible that all three areas may be needed to support the expanded airport. Our preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

It would not be in the best interest of passengers for the newer and modern facilities in Terminals 2 and 5 to be further improved, unless the rest of the Central Terminal Area receives similar focus and investment.

✓ Heathrow’s Strategic Brief sets out our vision to give passengers the best airport service in the world and this applies equally to all passengers.

The masterplan should promote a sustainable approach to aviation. ✓ ✓ Heathrow is committed to a Sustainability Strategy entitled Heathrow 2.0, which is a plan for sustainable growth. This is a plan to expand the airport in a way that creates a positive impact on the community, environment and economy. The MSDM contains a wide range of criteria relating to sustainability and these two documents will ensure that sustainability considerations are fully factored into all aspects of the Project.

The masterplan should be sustainable and fit for purpose for passengers, airlines and local communities.

✓ ✓

The masterplan should maintain or better airport charges at today’s level, preferably via a passenger charges guarantee.

✓ ✓ Heathrow will comply with the ANPS (paragraph 4.39) which states “the applicant should demonstrate in its application for development consent that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime”.

The cost impact to passengers are key factors for the masterplan. ✓




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The masterplan should deliver safe, secure, resilient and efficient operations.

✓ ✓ The MSDM includes a wide range of considerations in the evaluation criteria used for appraising different options and masterplan components, including safety, security, resilience and efficiency. This will ensure these factors are properly considered and incorporated into the masterplan.

Any new land designations need to ensure the proposed development is in keeping.

✓ The decision to propose new land designations is a matter for the relevant local planning authorities and not something arising through the DCO. The DCO application will include an EIA which will assess any likely significant environmental effects and put forward necessary mitigation to ensure new development is in keeping with its context, wherever practicable. The PEIR will be available at Airport Expansion Consultation in June 2019.

Any land for airport related development needs to demonstrate how it can be delivered within a short space of time.

✓ Heathrow are carefully considering to what extent the DCO application should include provision for ARD, in the light of the principles set out in the Guidance on “associated development” applications for major infrastructure projects (April 2013: CLG). The preferred masterplan will be presented at Airport Expansion Consultation in June 2019.

The demolition of office accommodation and hotel(s) would be unjustified as they would be replaced by facilities offering the exact same uses.

✓ There are a number of offices and hotels which will be displaced by expansion. Heathrow are carefully considering to what extent the DCO application should include provision for their replacement, in the light of the principles set out in the Guidance on “Associated Development” applications for major infrastructure projects (April 2013: CLG) and all other relevant considerations.




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Any masterplan should follow the framework of requirements and timetable set out by the Government in its final NPS.

✓ At the time of Airport Expansion Consultation One the ANPS was in draft only. Parliament has now approved the ANPS, by an overwhelming majority. The DCO application will follow the requirements of the ANPS.

Request that public money would not be used to cover any budget shortfalls.

✓ Heathrow airport expansion will be entirely privately funded. We have the largest private infrastructure investor in the world, two of the largest pension funds and three of the largest sovereign wealth funds as shareholders, and they are fully committed to the Project.

Request that Heathrow will stop its continual drive for growth. ✓ Paragraph. 5.275 of the ANPS is clear that “the Government agrees with the Airports Commission’s recommendation and the analysis that underpins it, and therefore does not see a need for a fourth runway at Heathrow Airport”. Heathrow accepts this conclusion.

The overall scale of expansion is questioned. ✓ 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, and associated infrastructure and surface access facilities (paragraph. 4.3) The overall scale of the Project is determined primarily by these policy requirements.

Development should be confined within the envelope of the airport site.

✓ The existing airport is operating at full capacity and there is no space available to accommodate a third runway and associated infrastructure and associated development within the existing envelope.

A masterplan should not be developed until the government agrees ✓ Given the urgent need for expansion which is




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to a third runway and any conditions, such as limits on use due to air pollution, are finalised.

recognised in the ANPS, and the complexity of the expansion proposals, Heathrow commenced preparation of the masterplan whilst the ANPS was still in draft form. Following a parliamentary vote, the ANPS has now been designated and this establishes the needs case for Heathrow expansion, provided it adheres to the detailed policies and protections set out in the ANPS, and the legal constraints contained within the Planning Act 2008.

Opposition to the development of a masterplan until parliament agrees to expansion and until actual conditions are finalised.

✓

Heathrow should consider the environment, air quality, climate change, and the needs of Londoners by not expanding.

✓ The ANPS recognises that there is an urgent need for new airport capacity in the South East (paragraphs. 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 (paragraph. 3.74). The ANPS sets out a series of requirements which Heathrow must adhere to, which include requirements the environment, air quality, carbon and the needs of local communities.

The masterplan must learn the lessons from bad runway and taxiway design in the past at other airports and include modern risk management techniques. There is a concern that none of this was included within the current masterplan.

✓ Heathrow consider it important that the experience and lessons learnt from other airport developments are understood and incorporated into expansion. As such, the Heathrow management and design teams have engaged with various airports including but not limited to Hong Kong, Singapore, New York, Los Angeles, Melbourne, Munich and Frankfurt. In addition, we are active members of international design standard review panels which regularly assess the appropriateness of design standards to ensure that safety standards are maintained and take into account the latest technology. Learning from these forums and panels has been taken into account during the masterplan process.




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Clean Air Zone Emission standards should be required on all airport related development. There should be clear performance targets for noise and air pollution.

✓ As part of the DCO application, Heathrow proposes to include legally binding obligations to ensure that the growth of the airport is only allowed to take place within the boundaries of the environmental criteria set out in the ANPS. This will include noise and air quality. We have described this concept further in the Airspace and Future Operations Consultation Document, which is part of the January 2019 consultation We will set out detailed proposals for how future growth will be managed as part of our Airport Expansion Consultation planned for June 2019.



18. PROPERTY POLICIES

18.1 Introduction


relation to its proposed property compensation policies, including the interim

Property Hardship Scheme (the Property Policies). A total of 1,272 consultees

made comments relating to this topic.

18.1.2 Heathrow provided the following material that is directly related to its Property

Policies:


2. Property Policies Information Paper;

3. Interim Property Hardship Scheme – Panel Guidance and Policy Terms;

4. Fees and Costs Policy;

5. Commercial Property Policy;

6. Agricultural Land and Property Policy; and

7. Residential Property Policy.

18.1.3 Heathrow asked the following questions regarding its Property Policies at Airport

Expansion Consultation One:

1. Please tell us what you think about our property policies.

















Local Authorities

General comments

18.2.1 Ealing Council did not have specific comments on Property Policies but

considered that residents whose homes will be compulsorily acquired should be

fairly compensated. In addition, they highlighted that there needs to be a

community compensation package including noise insulation for residential

properties and other sensitive uses (e.g. schools).

18.2.2 Essex County Council welcomed the information about the Property

Policies provided in Airport Expansion Consultation One but did not make

any specific comments.

18.2.3 The London Borough of Hammersmith and Fulham said that the impacts of the

existing operating airport have never been managed and adequate compensation

measures have not been provided. The Council noted that the information in the

draft Airports National Policy Statement and Heathrow’s consultation is inadequate

in scope and coverage and asked for further information on the noise insulation

package and community fund.

18.2.4 The London Borough of Harrow said that the approach to compensation needs to

address the wider sub-regional impacts that the proposed Heathrow Expansion

Project would create.

18.2.5 Kent County Council welcomed the commitment to deliver a compensation

package that goes beyond statutory requirements and asked that the Property

Policies be agreed in consultation with the local communities and representative

bodies in the areas directly affected.

18.2.6 Slough Borough Council considered that it is too simplistic a policy to assume that

only properties within the Project boundary will be located within the Compulsory

Purchase Zone. They said that works to divert roads as well as the proposed other

associated development to enable the Heathrow Airport Expansion Project would

mean that other properties need to be compulsory purchased.

18.2.7 They also noted that the Property Policies do not allow for the loss of community

buildings and schools and suggested that they should be updated to allow for the

purchase of these buildings where they are likely to be adversely affected. They

also considered Pippins School may need to be purchased and moved to a more

sustainable location.

18.2.8 Surrey Heath Borough Council considered that any loss of housing needs to be

addressed through new residential development to compensate for the loss.



Residential Property Policy

18.2.9 Spelthorne Borough Council supported the principle of a wider Property Offer

Zone (WPOZ) but did not consider that the boundary covers a wide enough area.

They suggested that their two most impacted communities, Stanwell Moor and

Stanwell should be included.

18.2.10 Surrey County Council expressed a similar view about the expansion of the WPOZ

and commented that the residents of Stanwell Moor and Stanwell will be

significantly adversely impacted by the expansion of the airport during construction

and operation.

Interim Property Hardship Scheme

18.2.11 The London Borough of Hounslow expressed concern about the potential new

flight paths and/or the intensification of air movements as they considered that this

already hampers the local housing market. They indicated that the policy should

be implemented in a flexible manner and if there is compelling evidence of

hardship in areas outside of the prescribed zones these be given real

consideration for compensatory payments.

18.2.12 Spelthorne Borough Council accepted the principle of an Interim Property

Hardship Scheme which gives the value of the property without the expanded

airport but no uplift. However, they considered that the qualification criteria set out

in the Interim Property Hardship Scheme of being “substantially adversely affected

by the construction or operation of the runway” is too high a threshold for

compensation and should be lowered to “adversely affected”.

Statutory consultees

General comments

18.2.13 Highways England requested further information about which compensation

regime(s) apply to their property, the proposed method of engagement, land

transfer and timescales. They also asked to be kept informed of the progress of

acquisition of residential properties for the realignment of the M25.

Other Prescribed bodies

General comments

18.2.14 Bray Parish Council did not consider that any compensation policy would

adequately cover residents losing both their homes and community.



18.2.15 Horton Parish Council said that compensation and restoration schemes for

previous gravel extraction works have never been fulfilled and the proposed

Heathrow expansion will exacerbate this.

18.2.16 Windlesham Parish Council understood that properties will be needed for the

expansion of Heathrow but expressed concern at the displacement of

communities. They said that the compensation scheme makes it easier for home

and business owners to sell their properties but does not consider the impact the

Heathrow Expansion Project will have on established communities or how to

solve it.

18.2.17 They also said that the housing supply in their area is already constrained due to a

number of factors and that any new housing requirement, as a result of the

Heathrow Expansion Project, should not impact the area.


18.2.18 Colnbrook with Poyle Parish Council said that more clarity is needed on

the compensation offer and how the unblighted market value of a property will

be established.

18.2.19 They stated that the WPOZ covers approximately 99% of the Parish but that the

zone should be increased to cover all properties. They also asked for greater

clarity as to when the schemes would be operational.

Interim Property Hardship Scheme

18.2.20 The Heathrow Strategic Planning Group said that the Heathrow Airport Expansion

proposals are currently impacting people and the property market so greater

flexibility should be offered including earlier action in cases of hardship. They said

that further attention may be required regarding impacts on tenant occupiers,

private and social landlords.



General comments

18.3.1 Comments on the Property Policies from members of the public were either

general comments or focussed on the Residential Property Policy or Interim

Property Hardship Scheme.

18.3.2 The main positive comments received were that the property policies were well

suited and/or well considered and that they were fair. Other comments received

said that the policies were necessary to compensate people, that they were



sufficient, generous and that there were more advantages than disadvantages for

those affected by the proposed expansion of Heathrow.

18.3.3 Consultees who responded negatively said that the amount of compensation

offered is inadequate or insufficient. Other negative comments said that the

polices were unnecessary, unfair and unsuitable. Some people also said that the

polices failed to consider impact on people’s quality of life, health and well-being,

that the WPOZ was not large enough and that the compensation would fail to

make up for disruption.

18.3.4 Consultees also said that property policies failed to consider:

1. the impact of noise, air and light pollution;

2. the cost of relocation of people’s homes;

3. impacts on historic and listed buildings;

4. the impact on business, the economy, and local jobs;

5. higher property prices elsewhere, away from Heathrow Airport;

6. indoor and outdoor leisure space/facilities;

7. impacts on quality of life and well-being;

8. the higher costs for business that may have to locate elsewhere; and

9. the impact of additional traffic and congestion.


18.3.5 Respondents who expressed support for the Residential Property Policy said that

that the additional 25% home loss payment on top of the 100% full market value

was fair compensation.

18.3.6 Comments received by those who opposed to the policy said that that people

should not be forced to leave their homes and that compensation would not make

up for this.

18.3.7 Comments were received that the policy fails to consider impacts on quality of life,

health and well-being, noise and disruption, green spaces and recreational

facilities and that people would have to move further away from their local

community and possibly to more expensive areas, which compensation would not

adequately cover. Respondents also highlighted that the policy fails to consider

disruption of social, support and caring networks and the vulnerability of elderly

and disabled people.

18.3.8 Respondents suggested that residents should be compensated above market

value and that the home loss payment should be more than 25%. No single figure



predominated with some suggesting the home loss payments should be 40% and

other suggesting 50% and 100%. Feedback was also received that considered

the 25% home loss payment exceptionally generous and highlighted the need to

also consider the impact on the taxpayer.

18.3.9 The expansion of the WPOZ was also mentioned by respondents. Suggestions

were received that the WPOZ should be extended to cover various settlements as

well as more general comments which suggested that it should be extended to a

six to eight mile radius, a ten mile radius, a 20 mile radius as well as the whole

south east of England. Feedback was also received that the WPOZ is too wide

given the importance of the Heathrow Expansion Project to the national economy.

18.3.10 Concern was also raised that properties are likely to have depreciated since the

expansion of the airport was first mentioned, lowering the unblighted market value.

Comments were received that market values must be robustly and fairly calculated

and that Heathrow must make available independent advisers to those facing

displacement. Respondents suggested that the 2013 threshold should be relaxed

and instead Heathrow should investigate the owner-occupation of property prior to

this date.

18.3.11 Respondents highlighted impacts on tenants, suggesting that they should be

compensated to cover moving costs or rents in more expensive areas and that

landlords who do not live in properties should not be compensated.

Interim Property hardship scheme

18.3.12 Comments about the Interim Property Hardship Scheme were both positive and

negative. Positive comments considered it was needed and fair. Negative

comments said that it was difficult to prove who was substantially adversely

affected by the construction or operation of the Project and therefore eligible for

the Scheme.

Businesses

General comments

18.3.13 The Copas Partnership, Hatton Farm Estates Limited, the Surrey and Thames

Valley Chambers of Commerce and Sapcote Developments (the trading name

of London and Strategic Estates Limited) expressed support for the Property

Policies.

18.3.14 The Arora Group asked for meaningful engagement with them over the acquisition

of their land and for due consideration of alternatives.

18.3.15 BMO Real Estate Partners did not comment on the Property Policies. However,

they welcomed the opportunity to continue discussions and for decisions to be



taken quickly so as to prevent losses that may be incurred as a result of a period

of prolonged uncertainty over the future of their land interests.

18.3.16 They also said that demand for existing commercial property in the vicinity of

Heathrow Airport is high and land that is suitable for re-development is already

limited. They said the relocation of businesses which are dependent on the airport

will therefore be essential to meet commitments made in relation to the

safeguarding and generation of local employment.

18.3.17 Emerson Group (on behalf of Orbit Developments – Southern Limited) expressed

concern about the impact of the proposed Heathrow Expansion Project on their

property. They indicated that they did not consider that development of their

land is necessary for the proposed expansion of Heathrow or for airport

supporting facilities.

18.3.18 The Fuel Trading Company said that the Property Policies are well thought out,

but property owners should be automatically enrolled to the scheme so that the

onus is not placed on them to do so.

18.3.19 Goodman said that it supports the principle of an approach which seeks to work

together and reach agreement in respect of future development and envisaged

that further discussions on land ownership and delivery would be required in

due course.

18.3.20 Passiflora expressed concerns that future development will surround their

business. They also noted that they are not included in the WPOZ and considered

that they and the more distant villages should be included.

18.3.21 Premier Inn Hotels Limited (Bath Road) expressed concern at the prospect of the

acquisition of their property. They asked that if new hotels are to be constructed as

part of the proposed expansion of Heathrow, or sites are to be made available for

such developments and indicated that the opportunity to secure new hotels or

hotel sites should be afforded first to existing operators. They also asked that a

minimum of 18 to 24 months advance notice is given before acquisition to ensure

that advance bookings which could not be honoured are not taken and an orderly

closure can be carried out.

18.3.22 RTL Holdings Limited agreed that their site should be considered for airport

related development and suggested that attempts should be made to have a site

released from the green belt and allocated in Spelthorne’s Local Plan.

18.3.23 Segro supported the commitment to work with property and land owners to

purchase properties by agreement rather than compulsorily.

18.3.24 Suez UK highlighted that there is currently insufficient detail to comment on this

issue and requested dialogue with Heathrow over their property interests.




18.3.25 Virgin Atlantic Airways Limited agreed that communities affected by the proposed

Heathrow Expansion should be fairly compensated but stated that the approach

adopted is generous and goes beyond what has been offered for similar

infrastructure developments (such as High Speed Two Limited (HS2)). They did

not believe that there is a business case for any extensions to the current

compensation package.


Representatives said that it is difficult to reconcile the 125% level of property

compensation offered by Heathrow with the 110% figure established by HS2.

They considered that additional costs above the 110% public sector compensation

precedent should not be included in the charges to airlines as part of the regulated

asset base, instead remaining the responsibility of Heathrow’s investors.

Commercial Property Policy

18.3.27 Airpets welcomed the support for businesses in their relocation plans but asked

that more than the minimum three months’ notice period for taking possession be

provided where practicable to do so. They said that Heathrow should assist

businesses who have a requirement to be located close to the Airport. A similar

view was shared by Segro who noted that the proposed minimum notice period for

acquisition of three months is unreasonably short and provides an unrealistic

timetable for relocation of significant businesses.

18.3.28 Global Grange Limited said that the policy fails to make the same commitment to

commercial landowners as they have for homeowners. They expressed concern

that employment and other business interests could be undermined or lost as a

result of the Heathrow Expansion plans. They went on to assert that detailed

proposals to compensate non-residential uses will need to be brought forward and

agreed, to limit impacts upon the wider local economy and the viability of

development.

18.3.29 Heathrow Airport Fuel Company Limited and the Heathrow Hydrant Operating

Company Limited noted that their facilities may have to be relocated. They hoped

this would not be necessary but indicated that if it is Heathrow must find a suitable

alternative location and fund the cost of re-provision of comparable facilities and all

other costs. They also requested clarification over the proposals for their other

facilities and expected the same re-provision terms as those previously described.

18.3.30 Lapithus Hotels Managements UK Limited (LHMUK) raised concerns that

Heathrow’s Commercial Property Policy is entirely focused towards properties in

the Compulsory Purchase Zone (CPZ) and there is no currently documented

policy to provide financial or other assistance to businesses within the WPOZ. This



could mean that whilst businesses in the WPOZ could be significantly affected by

development proposals, they might not be compensated, either under the

Statutory Compensation Code or through any of the voluntary compensation

schemes currently being proposed by Heathrow.

Professional Fees Policy

18.3.31 Airpets welcomed the principle of Heathrow’s draft Professional Fees policy which

clarifies the approach.

18.3.32 DHL Group said that withholding fees that are not pre-approved by Heathrow

would conflict with good practice guidance set out by the government and that this

part of the draft proposal should be removed from the fees policy. They also said

that property owners who have exclusive property service agreements in place

with their professional advisors should not be required to seek additional quotes

and that Heathrow should commit to reimburse fees that could be incurred during

the DCO process including the consultation stages.

18.3.33 LHMUK noted that whilst Heathrow is willing to meet the cost of professional

advice for businesses within the CPZ, it is not intending to provide similar

assistance to businesses in the WPOZ. They considered that Heathrow should

extend its fee reimbursement policy to businesses within the WPOZ in cases

where there is a demonstrable need for those businesses to engage and incur

costs in engaging with Heathrow.

Community Groups

General comments



include specific feedback on the Property Policies.

18.3.35 Aircraft Noise Three Villages suggested that the compensation policies cannot

compensate for polluted air and sleep disturbance and that the measures

proposed are ‘pathetic’ compared to the number of people affected. The Kingston

Environment Form added the long-term effects on climate change to the list of

reasons why the compensation package is inadequate.

18.3.36 The Colnbrook Community Association said the compensation proposals are

totally inadequate and lack any acceptable definitions. They also reiterated that

they cannot support any plans for the expansion of Heathrow Airport.

18.3.37 The Colnbrook Community Partnership said that the CPZ as shown in the

consultation excludes commercial and residential properties which will need to be

acquired for the realignment of the M25 and the A3044.



18.3.38 Englefield Green Action Group suggested that if Heathrow are serious about being

good neighbours then they should offer to buy any property within ten miles of the

runway at full unblighted market value plus the 25% premium and that the offer

should be open for a period of three years. They suggested that if the increase in

disturbance from a third runway is minimal, as Heathrow claims, then their

financial risk is low. The Wentworth Residents Association also considered that

compensation should be extended to properties within a ten mile radius.

18.3.39 Heathrow Association for the Control of Aircraft Noise considered that the

timetable for noise insulation needs to be accelerated significantly but did not have

a view on Heathrow’s proposals for property compensation.

18.3.40 Residents Association HVG CA said that the Property Policies are inconsiderate

as people do not want to lose their homes or their community.

18.3.41 The Richmond Heathrow Campaign suggested that the extent, timing and

administration of the compensation is not extensive enough.

18.3.42 Slough and District Against Runway 3 suggested that none of the options

presented are acceptable due to the massive landgrab from Colnbrook with Poyle

and the neighbouring communities of the Harmondsworth, Longford and Stanwell.

They indicated that they could not support a third runway at Heathrow under any

circumstance and do not wish to respond to the consultation as they believe that

this would give Heathrow the ability to claim that residents support expansion

simply by responding.

18.3.43 The Dover House Estate Residents Association and Harrow U3A Sustainability

Group indicated that they were supportive of the property policies.

18.3.44 The Local Authorities’ Aircraft Noise Council (LAANC) said that the proposal to

offer compensation of up to £3000 for those within the 55dB contour for double

glazing is derisory. The average cost of effective double glazing to a house within

the affected contour area is around least £25,000. £3000 does not even cover the

cost of replacing a couple of upstairs windows.

18.3.45 St Albans Quieter Skies expressed disappointment that the policies did not take

into account significant effects to the communities to the north of London.


18.3.46 The Harmondsworth and Sipson Residents Association said that the emotional

impact of losing your home, your family, your friends and community should be

understood. They suggested that the financial incentive offered is inadequate to

compensate for what some have spent a lifetime investing in and that money

should be set aside to give homeowners or tenants security and counselling in

finding a home and community which matches what they already enjoy.



18.3.47 Local Conversation in Stanwell said that the WPOZ needs to include Stanwell

Moor and Stanwell. They also said that there is no information on the decision

making process for the drawing of the WPOZ boundaries. Stanwell’s Green Lungs

also supported increasing the WPOZ to include the two communities.

18.3.48 They also pointed out that the residents of these areas will be significantly

impacted by the proposed Heathrow Expansion not only during construction but

because of greater noise from the western taxiways, likely air quality impacts,

infrastructure and changes to M25, additional traffic from re-routed traffic flows,

airport support facilities and airport related development. Because of these factors

they suggested expanding the WPOZ to include the whole of Stanwell Moor and

large parts of Stanwell.

18.3.49 SCR Residents for a Fair Consideration of Heathrow Expansion said that the

compensation will not include affected people in south London who are

inconvenienced by the Heathrow Expansion proposals.

18.3.50 Teddington Action Group expressed concern that the 125% of unblighted market

value may be based on a depressed value to begin with. They requested more

information on how an unblighted market value is determined and on what is

available for people who are to remain in their properties. They went on to say that

the thresholds for the entitlement are too narrow so that the mitigation proposals

do not apply to the majority of people affected and that the mitigation packages

are ‘pitiful’.

18.4 Wider/other consultees

General comments

18.4.1 The Lambeth/Herne Hill Green Party said that local consultation should flesh out

the minutiae of the offer to those affected. The compensation needs to be fair,

proportionate and not exploitative.

18.4.2 The World Federalist Party commented that the compensation proposals are

inadequate, misguided, heartless and susceptible to being successfully challenged

by those Heathrow is seeking to displace.

18.4.3 The Royal Parks noted that the title of the Longford River must be established

before any final plans for the expansion are agreed. They indicated that an

easement at the very least would be required to ensure they maintain a legal

right to the passage of water. They also noted that all costs for this should be

borne by Heathrow.





consultees in relation to Property Policies. None of the feedback received in relation to Property Policies 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

Heathrow will publish updated Property Policies in 2019 along with information on how we have taken into account

consultation feedback.

Table 18.1B


PC MC

WC

The commitment to deliver a compensation package that goes beyond statutory requirements is welcomed.

✓

Heathrow notes these comments and is committed to delivering a fair property compensation package.

Support for the property compensation policies. ✓

The information about the property policies provided in the consultation is welcomed.

✓

The property policies were well suited and/or well considered and are fair.

✓

The property policies were necessary to compensate people, they were sufficient, generous and there were more

✓





PC MC

WC

advantages than disadvantages for those affected by the expansion of Heathrow.

The hardship policy was needed and fair. ✓

The policies were unnecessary, unfair and unsuitable. ✓ Heathrow prepared draft Property Policies taking account of feedback and lessons learnt from Heathrow’s previous compensation schemes and from compensation schemes implemented by other major infrastructure projects.

Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation measures. The schemes will be launched from 2019 onwards together with the updated policies.

The property policies are inadequate, have shortcomings and don’t go far enough.

✓

There is currently insufficient detail to comment on this issue and requested dialogue with Heathrow over their property interests.

✓

The extent, timing and administration of the compensation is not extensive enough.

✓

There needs to be a community compensation package including noise insulation for residential and other sensitive uses (e.g. schools).

✓ Heathrow will also develop a community compensation fund (CCF) for the expanded airport. The scale of the fund and how it is to be distributed are matters that are yet to be established. The fund will be proportionate to the residual impacts caused by the Project. The remit of the fund could encompass suggestions such as the provision of quiet indoor play space for schools.

Heathrow is proposing a Noise Insulation Scheme as part of our compensation package for the Project. The scheme will include provision for insulating eligible residential properties and community buildings.

We are currently refining our approach to the implementation of the scheme, including in regard to the eligibility criteria, and will consult on the updated Noise Insulation Scheme as part of the Airport Expansion Consultation in June 2019.

Further information on the noise insulation package and community fund is needed.

✓

The timetable for noise insulation needs to be accelerated significantly.

✓




PC MC

WC

If Heathrow is serious about being good neighbours then they should offer to buy any property within 10 miles of the runway at full unblighted market value plus the 25% premium and that the offer should be open for a period of three years.

✓ Heathrow is proposing an enhanced compensation offer for eligible properties within the Compulsory Purchase Zone (CPZ) and the Wider Property Offer Zone (WPOZ which is within very close proximity to the proposed boundary of the expanded airport.

Properties which are located outside the WPOZ may be eligible for Heathrow’s Noise Insulation Scheme or to make a claim in accordance with the Compensation Code.


Compensation should be extended to properties 10 miles from the runway.

✓

The compensation will not include affected people in south and north London who are inconvenienced by the expansion proposals.

✓

The approach to compensation needs to address the wider sub-regional impacts that the expanded airport will create.

✓

Local consultation should flesh out the minutiae of the offer to those affected. The compensation needs to be fair, proportionate and not exploitative.

✓ Heathrow will continue to engage with people whose properties are within the expansion footprint and within close proximity to the Project to understand local and individual needs.


It is difficult to reconcile the 125% level of property compensation offered by Heathrow with the 110% figure established by HS2.

✓ ✓ Our property policies are designed to be part of a world class compensation package in line with the recommendations of the Airports Commission. This includes setting out a range of schemes




PC MC

WC

Additional costs above the 110% public sector compensation precedent should not be included in the charges to airlines as part of the regulated asset base and should instead remain the responsibility of Heathrow’s investors.

✓ ✓ from statutory compensation up to an enhanced compensation offer of 25% for eligible home owners and reimbursement of fees and other costs. Heathrow is also considering how to provide support to those affected, including relocation services.

We are working very closely with our airline partners to keep airport charges as close as possible to 2016 levels. This is a requirement of the ANPS. Heathrow is the largest privately financed airport operation in the world and the expansion of Heathrow is not taxpayer funded.

Agreement that communities affected by the proposed Heathrow expansion should be fairly compensated but the approach adopted is generous and goes beyond what has been offered for similar infrastructure developments (such as HS2). There is not a business case for any extensions to the current compensation package.

✓

Support for the residential property policy. The additional 25% home loss payment on top of the 100% full market value was fair compensation.

✓

Residents should be compensated above market value and the home loss payment should be more than 25%.

✓

The home loss payments should be 40% or 50% or 100%. ✓

The 25% home loss payment is exceptionally generous and has an impact on the taxpayer.

✓

Tenants should be compensated to cover moving costs or rents in more expensive areas.

✓ Under the draft Property Policies, people who are not eligible for the enhanced compensation offer, are still able to seek compensation in accordance with the Statutory Compensation Code. For qualifying tenants this may include a loss payment and disturbance costs.


Further attention may be required regarding impacts on tenant occupiers, private and social landlords.

✓




PC MC

WC

The compensation proposals are inadequate, misguided, heartless and susceptible to being successfully challenged by those Heathrow is seeking to displace.

✓ Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation measures. The schemes will be launched from 2019 onwards together with the updated policies.

Heathrow will continue to engage with residents and business owners directly and through forums such as the Heathrow Community Engagement Board to ensure individual needs and the views of local residents and businesses are heard.

The compensation package is inadequate given the long-term effects on climate change.

✓

The compensation proposals are totally inadequate and lack any acceptable definitions.

The amount of compensation offered is inadequate or insufficient.

✓

The proposal to offer compensation of up to £3,000 for those within the 55dB contour for double glazing is derisory. The average cost of effective double glazing to a house within the affected contour area is around £25,000. £3,000 does not even cover the cost of replacing a couple of upstairs windows.

✓ The final boundary of the noise insulation scheme will be dependent on the design of flight paths around the expanded airport. Updates to the Noise Insulation Scheme will be presented as part of the Airport Expansion Consultation in June 2019.

The emotional impact of losing your home, your family, your friends and community should be understood. The financial incentive offered is inadequate to compensate what some have spent a lifetime investing in and that money should be set aside to give homeowners or tenants security and counselling in finding a home and community which matches what they already enjoy.

✓ Heathrow recognises the uncertainty and impact the expansion proposals may have on the health and wellbeing of people in the local communities, particularly on those whose homes are potentially affected.

As we develop the Property Policies and the detailed compensation schemes, we are considering what support services we can put in place to assist people affected in moving to a new property.

Heathrow is also undertaking an environmental impact assessment of the Project. This will include assessment of the effects of the Project on health and quality of life. This will also outline measures that we would look to implement to mitigate adverse significant

Property policies failed to consider the cost of relocation of people’s homes.

✓

Opposition to the residential property policy as people should not be forced to leave their homes. Compensation would not make up for this.

✓




PC MC

WC

The compensation would fail to make up for disruption. ✓ impacts.

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.


Property policies failed to consider impacts on quality of life and well-being.

✓

The policies failed to consider impact on people’s quality of life, health and well-being.

✓

The residential property policy fails to consider disruption of social, support and caring networks and the vulnerability of elderly and disabled people.

✓

The residential property policy fails to consider impacts on quality of life, health and well-being.

✓

The compensation policy will not adequately cover residents losing both their homes and community.

✓ ✓

The compensation scheme makes it easier for home and business owners to sell their properties but does not consider the impact expansion will have on established communities or how to solve it.

✓

It is understood that properties will be needed for the expansion of Heathrow but concern is expressed at the displacement of communities.

✓




PC MC

WC

Landlords who do not live in properties should not be compensated.

✓ The draft Property Policies set out that eligible private landlords and social housing landlords will be entitled to statutory compensation. The draft property polices also allow the discretionary enhanced compensation offer to remain with the property if an eligible owner-occupier sells to a private landlord.


Compensation policies cannot compensate for polluted air and sleep disturbance and the measures proposed are ‘pathetic’ compared to the number of people affected.

✓ Heathrow continues to seek to minimise adverse impacts through the design, assessment and evaluation process for the Project.

Heathrow is undertaking an environmental impact assessment 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 include assessment of the likely significant effects of noise on health and quality life, and of the Project on human health. This will also outline measures to mitigate adverse significant impacts. Impacts on green spaces and recreational facilities are also being assessed as part of the EIA, with preliminary findings presented in the PEIR. This will include possible mitigation measures for adverse effects.

The residential property policy fails to consider impacts on green spaces and recreational facilities.

✓

Property policies failed to consider the impact of noise, air and light pollution and disruption.

✓

Property policies failed to consider the impact of additional traffic and congestion.

✓




PC MC

WC

The impacts of the airport’s operation have never been managed and it has never provided adequate compensation measures.

✓ Heathrow currently provides a package of measures to mitigate the impacts of the operation of the airport. This includes a day and night noise insulation scheme which together are available to approximately 48,500 homes. Heathrow also provides a Quieter Homes Schemes, which covers approximately 1,200 homes.


Compensation and restoration schemes for previous gravel extraction works have never been fulfilled and Heathrow expansion will exacerbate this.

✓ Securing restoration of existing mineral sites is the responsibility of the relevant minerals planning authority. Heathrow is committed to restoring the borrow pits that will be required for the Project, as described on the document Our Emerging Plans. The EIA Scoping Report (May 2018) for the Project identified that the impacts of construction, including from borrow pits, will be included within the EIA that Heathrow is undertaking of the Project.

The compensation policy is too simplistic and assumes that only properties within the Heathrow airport expansion boundary will fall within the Compulsory Purchase Zone.

✓ The CPZ and WPOZ will continue to be refined until the land required for the Project is determined by the final masterplan for the DCO application. The preferred masterplan for the proposed expansion of Heathrow will be available at the Airport Expansion Consultation in June 2019, and this will include the proposed boundaries for properties and land required to deliver the Project

The preferred masterplan will identify the land required for the M25 realignment (both for construction and operation of these works).

Works to divert roads as well as the proposed associated development to enable expansion will mean that other properties need to be compulsory purchased.

✓




PC MC

WC

The CPZ as shown in the consultation excludes commercial and residential properties which will need to be acquired for the realignment of the M25 and the A3044.

✓

Property owners should be kept informed of the progress of acquisition of residential properties for the realignment of the M25.

✓

Further information about which regime(s) apply to Highways England property is needed including the proposed method of engagement, land transfer and timescales.

✓

Property policies failed to consider higher property prices elsewhere, away from Heathrow Airport.

✓ Heathrow’s proposed enhanced compensation offer for eligible properties of 25% payment above the unaffected open market value is a significant uplift to market value, together with payment of stamp duty costs and reimbursement of legal fees and removal or other disturbance costs.

Heathrow’s draft Property Policies set out the proposed process for obtaining property valuation and Heathrow is assessing the detailed process for valuation as part of the development of the compensation schemes and mitigation measures.

Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation measures. The schemes will be launched in 2019 together with

More clarity is needed on the compensation offer and how the unblighted market value of a property will be established.

✓

Properties are likely to have depreciated since the expansion of the airport was first mentioned, lowering the unblighted market value.

✓

Market values must be robustly and fairly calculated. ✓




PC MC

WC

Concern that the 125% of unblighted market value may be based on a depressed value to begin with. Therefore, requests for more information on how an unblighted market value is determined and on what is available for people who are to remain in their properties.

✓ the updated policies.

Greater clarity is needed about when the compensation schemes would be operational.

✓ Heathrow notes these comments.

Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation measures. The schemes will be launched in 2019 together with the updated policies.

Being substantially adversely affected by the construction or operation of the runway is a very high threshold for compensation and should be lowered to adversely affected.

✓ Heathrow’s proposed enhanced compensation offer for eligible properties of 25% payment above the unaffected open market value is a significant uplift to market value, together with payment of stamp duty costs and reimbursement of legal fees and removal or other disturbance costs.


The thresholds for the entitlement of compensation are too narrow so that the compensation will not apply to the majority of people affected, the compensation proposals are therefore ‘pitiful’.

✓




PC MC

WC

Property owners who have exclusive property service agreements in place with their professional advisors should not be required to seek additional quotes.

✓ Heathrow's draft fee policy is intended to be a proactive measure to address provide certainty for property owners in advance of consent for the DCO and the granting of compulsory acquisition powers.


Property policies failed to consider impacts on historic and listed buildings.

✓ Provided the heritage asset meets the eligibility terms of Heathrow’s draft property policies, the compensation measures set out in the draft Policies will be available to all eligible properties including heritage assets.

Chapter 24 of this Interim Consultation Feedback Report sets out the feedback received on the historic environment and Heathrow’s response.

Early findings and potential mitigation proposals will be set out in the PEIR as part of the Airport Expansion Consultation in June 2019. The detailed assessment will be presented in the historic environment chapter of the Environmental Statement that will accompany Heathrow’s DCO application.

It is important that heritage assets are properly considered as part of any compensation scheme and eligible wherever possible.

✓

Innovative and successful mitigation measures to address noise impacts on the historic environment are needed.

✓




PC MC

WC

Property policies are well thought out, but property owners should be automatically enrolled to the scheme so that the onus is not placed on them to do so.

✓ Heathrow is undertaking a process known as Land Referencing and through this process will seek to engage directly with those whose properties and land are identified within the CPZ and WPOZ. Through this engagement we will discuss enrolment into the relevant compensation scheme(s).

However, it will be for the property owner to make the decision on whether they apply for the compensation scheme.

Property policies should be agreed in consultation with the local communities and representative bodies in the area directly affected.

✓ Heathrow will continue to consider feedback from consultation and engagement with individuals and wider stakeholders in developing the Property Policies.


The principle of a wider property offer zone (WPOZ) is supported. But its boundary does not cover a wide enough area. Stanwell Moor and Stanwell should be included.

✓ The communities included in the current proposed WPOZ boundary were those considered to have the greatest impacts from the expansion, based on our 2014 Airports Commission submission.

We are now in the process of carefully considering feedback received at our public consultation based on our emerging plans.

We are reviewing the basis on which the WPOZ has been defined and are also considering various ways to minimise adverse impacts of expansion and maximise opportunities for local communities.

We will carefully consider and take account of feedback from the

The WPOZ covers approximately 99% of the Parish but that the zone should be increased to cover all properties.

✓

The WPOZ was not large enough. ✓

The WPOZ needs to include Stanwell Moor and Stanwell. ✓

There is no information on the decision-making process for the drawing of the WPOZ boundaries.

✓

The WPOZ should be extended to cover various settlements. ✓




PC MC

WC

It should be extended to a 6-8 mile radius, a 10 mile radius, a 20 mile radius as well as the whole south east of England.

✓ consultation and develop a clear response, that increases certainty for our communities.

The WPOZ is too wide given the importance of the expansion to the national economy.

✓

Concerns that future development will surround the Passiflora business. The Passiflora business is not included in the WPOZ when it and the more distant villages should be included.

✓

The WPOZ to include the whole of Stanwell Moor and large parts of Stanwell as residents of these areas will be significantly impacted by the expansion of the airport not only during construction but because of greater noise from the western taxiways, likely air quality impacts, infrastructure and changes to M25, additional traffic from re-routed traffic flows, airport support facilities and airport related development.

✓

Residents of Stanwell Moor and Stanwell will be significantly impacted by the expansion of the airport during construction and operation.

✓

Whilst Heathrow is willing to meet the cost of professional advice for businesses within the CPZ, it is not intending to provide similar assistance to businesses in the WPOZ.

✓ Heathrow will continue to engage with owners and occupiers of businesses located both inside and within close proximity of the future expansion footprint. Owners and occupiers of businesses premises located outside of the expansion footprint may be able to make a claim under the statutory compensation provisions.


Heathrow should extend its fee reimbursement policy to businesses within the WPOZ in cases where there is a demonstrable need for those businesses to engage and incur costs in engaging with Heathrow.

✓

Heathrow’s commercial property policy is entirely focused towards properties in the CPZ and there is no currently documented policy to provide financial or other assistance to businesses within the WPOZ.

✓




PC MC

WC

Whilst businesses in the WPOZ could be significantly affected by development proposals, they might not be compensated, either under the Statutory Compensation Code or through any of the voluntary compensation schemes currently being proposed by Heathrow.

✓

Residents whose homes will be compulsorily acquired should be fairly compensated.

✓ Heathrow’s draft Property Policies and the compensation offers are intended to provide clarity to those whose property or land may be affected with the intention to buy properties and land by mutual agreement. Heathrow will also apply for powers of Compulsory Acquisition as part of the application for DCO where mutual agreement cannot be reached


Support for the commitment to work with property and land owners to purchase properties by agreement rather than compulsorily.

✓

The policies do not allow for the loss of community buildings and schools. They need to be updated to allow for purchase of these buildings where they are likely to be significantly impacted.

✓ The draft Property Policies cover residential, commercial and agricultural properties and land. Heathrow will continue to engage on the mitigation of impact of the loss of public properties and land including community buildings and schools.


Pippins School may need to be purchased and moved to a more sustainable location.

✓




PC MC

WC

The information in the draft ANPS and the consultation is inadequate in scope and coverage.

✓ Heathrow provided a range of information at Airport Expansion Consultation One on different topics and at varying levels of detailed. The information reflected the early stage of the Project in terms of design and assessment work, but provided an opportunity for early feedback. Further consultations, led by Heathrow, will provide greater detail on the Project. The introductory chapters (Chapters 2 and 3) of the Consultation Feedback Report provides more information on the scope of Expansion Consultation One and Chapter 28 sets out the next steps in the process.

The principle of a Property Hardship Scheme (PHS) which gives the value of the property without the expanded airport but no uplift is accepted.

✓ Heathrow has implemented an ‘Interim’ Hardship Scheme and established a Hardship Panel which convenes monthly. The Interim Property Hardship Scheme has been amended following designation of the ANPS. An applicant who meets the eligibility criteria will be able to have their property purchased at its unaffected open market value. For those properties wholly or partly within the ANPS Site Boundary, further enhanced compensation will be paid including a 25% home loss payment on the unaffected open market value.

Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation measures. The schemes will be launched in 2019 together with the updated policies. Heathrow will update its policies to include public properties and land.

The policy should be implemented in a flexible manner and if there is compelling evidence of hardship in areas outside of the prescribed zones these should be given real consideration for compensatory payments.

✓

The expansion proposals are currently impacting people and the property market so greater flexibility should be offered including earlier action in cases of hardship.

✓




PC MC

WC

Housing supply is already constrained in the Windlesham area due to several factors and any new housing requirement should not impact the area.

✓ Heathrow has funded the Joint Evidence Base Infrastructure Study (JEBIS) which is being produced in collaboration with the HSPG. This will identify the extent to which Councils are planning for the level of housing needed to accommodate employment growth across the region. It is also looking at the infrastructure that is required to support that growth.

Heathrow does not believe that the proposed expansion of the airport will generate a need for additional homes. Additional housing demand that might potentially be generated by Heathrow’s expansion will be relatively small in comparison with the overall scale of housing need for which London and adjacent local authorities need to plan (Our Emerging Plans, paragraph. 13.2.10). Local planning authorities already have the responsibility to identify and plan for the most suitable locations for additional house building in their areas and the work Heathrow is doing with HSPG to assess the wider growth and infrastructure development which is likely to be generated by expansion will assist this process.




PC MC

WC

Concern about the potential new flight paths and/or the intensification of air movements as this already hampers the local housing market.

✓ Changes to airspace and flight paths are determined under a separate consenting process by the Civil Aviation Authority (CAA) and do not form part of the DCO process. In parallel to the Airport Expansion Consultation, Heathrow undertook a separate consultation on the design principles that could be used as the basis for developing Heathrow’s future airspace design (the Airspace Principles Consultation). A separate report detailing the feedback received in relation to this consultation was published on 19 September 2018. The consultation and engagement was undertaken to establish what the design principles should be for future flight paths and how they should be prioritised. One of the proposed design principles relates to limiting, and were possible reducing local noise effects from flights through measures including minimising the number of people newly overflown, minimising the total population overflown, maximising sharing through predictable respite and managed dispersal.

The Airspace and Future Operations Consultation (January 2019) presents geographic areas within which flightpaths could be positioned. The consultation seeks view on what local factors should be taken into account when developing new flightpaths within these geographically defined areas know as design envelopes. The consultation also seeks views on how we use our runways – operating a three-runway airport will be different to how we operate our two-runway airport today. We are asking for views on subjects including night flights, runway alternation, and directional preference.




PC MC

WC

Heathrow must make available independent advisers to those facing displacement.

✓ In 2017, it was agreed that the Heathrow Airport Consultative Committee (HACC), an existing forum for local authorities, airport users and interest groups, would take on additional responsibilities relating to engagement, to fulfil the requirement of the ANPS to set up an independent community engagement board.

The Heathrow Community Engagement Board was formed at the start of 2018 (relaunching the HACC), as a non-profit company which operates independently from Heathrow.

It aims to enable communities and key stakeholders to scrutinise, challenge and contribute effectively to decision-making at the airport.

The Heathrow Community Engagement Board will have an independent role to play in liaising with residents and ensuring that Heathrow engage with as many of those affected as possible and listen to their views.

Heathrow is also considering how the compensation schemes are launched and what support services could be provided to people whose property or land are affected, including potential for services to support people and businesses through the process of relocation.




PC MC

WC

The “2013 threshold” should be relaxed and instead Heathrow should investigate the owner-occupation of property prior to this date.

✓ The Airports Commission short-listed our north-west runway scheme on 17 December 2013. From this date, prospective purchasers could reasonably be expected to have been aware of the proposals for the Project and that a new north-west runway at Heathrow was a realistic prospect.


It is difficult to prove who was affected and therefore eligible for the scheme.

✓ All those identified as having an interest in the land likely to be required by the Project will be notified of the public consultation formally as part of the Airport Expansion Consultation in June 2019. This is in addition to ongoing engagement with property and land owners likely to impacted by the Project and eligible for compensation.

Impacts on the local market and the ability for businesses to relocate will be considered.

Consideration is being given to how the compensation schemes are launched and what support services can be provided to people whose property or land is identified as potentially affected. This includes services to support individuals and businesses through the process of relocation.

Heathrow is reviewing the feedback from public consultation and stakeholder feedback to refine the draft Property Policies and to develop the detailed compensation schemes and mitigation

Meaningful engagement between Heathrow and businesses over acquisition of land and for due consideration of alternatives is needed.

✓

Businesses welcomed the opportunity to continue discussions and for decisions to be taken quickly to prevent losses that may be incurred as a result of a period of prolonged uncertainty over the future of their interest.

✓

Demand for existing commercial property in the vicinity of the airport is high and land that is suitable for re-development is already limited. The relocation of businesses which are dependent on the airport will therefore be essential to meet commitments made in relation to the safeguarding and generation of local employment.

✓




PC MC

WC

The draft Commercial Property policy fails to make the same commitment to commercial landowners as is made for homeowners.

✓ measures. The schemes will be launched in 2019 together with the updated policies. Heathrow will update its policies to include public properties and land.

Concern about the impact of the expansion of Heathrow on the Emerson Group Property. The development of their land is not necessary for the proposed expansion of Heathrow or for airport supporting facilities.

✓ Heathrow will continue to engage with those business owners and occupiers who are both within the proposed expansion footprint and within close proximity to the Heathrow Expansion Project.

Heathrow will aim to provide more than three months’ notice to affected owners and occupiers.


Businesses support the principle of an approach which seeks to work together and reach agreement in respect of the future implementation of development. Further discussions in respect of ownership and delivery would be required in due course.

✓

Concern about the prospect of acquisition of the Premier Inn Hotel (Bath Road).

✓

If new hotels are to be constructed as part of the expansion of Heathrow, or sites are to be made available for such developments the opportunity to secure new hotels or hotel sites should be afforded first to existing operators.

✓

A minimum of 18 months-2 years notice is required before acquisition of hotels to ensure that advance bookings which could not be honoured are not taken and an orderly closure can be carried out.

✓

The proposed minimum notice period for acquisition of three months is unreasonably short and provides an unrealistic timetable for the relocation of significant businesses.

✓




PC MC

WC

Concern that employment and other business interests could be undermined or lost as a result of the Heathrow Expansion Project.

✓ Heathrow will engage with commercial property owners to understand their needs and to support them in mitigating impacts.


Detailed proposals to compensate non-residential uses will need to be brought forward and agreed to limit impacts upon the wider local economy and the viability of development.

✓

Property policies failed to consider the impact on businesses, the economy, and local jobs.

✓

It is necessary for Heathrow Airport Fuel Company Ltd and the Heathrow Hydrant Operating Company Ltd facilities to be relocated? If it is necessary Heathrow must find a suitable alternative location and fund the cost of re-provision of comparable facilities and all other costs.

✓ Heathrow is considering consultation responses in relation to sites being considered for Airport Supporting Facilities. Chapter 13 of the Consultation Feedback Report summarises the feedback received on Airport Supporting Facilities and Heathrow's response. Heathrow’s preferred masterplan will be available at the Airport Expansion Consultation in June 2019 and the Scheme Development Report will explain which sites have been taken forward, and why.

The RTL Holdings Ltd site should be considered for airport related development.

✓ Heathrow is considering consultation responses in relation to sites being considered for ARD. Chapter 15 of the Consultation Feedback Report summarises the feedback received on ARD and Heathrow's response. Our preferred masterplan will be available at the Airport Expansion Consultation in June 2019 and the Scheme Development Report will explain which sites have been taken forward, and why.




PC MC

WC

Attempts should be made to have a site released from the Green Belt in Spelthorne’s Local Plan.

✓ The Green Belt boundary can only be changed by reviewing a Local Plan or producing a new Local Plan. Spelthorne Borough Council is in the process of preparing a new Local Plan and has consulted on Issues and Options. This is a very early stage of the Local Plan preparation process and does not consider any specific sites in the Green Belt. If the new Local Plan contains proposals to amend the Green Belt boundary, the inspector appointed to examine the Local Plan will need to consider whether it is appropriate. The new Local Plan is to be submitted for examination in May 2020 and adoption of the new Local Plan is anticipated in April 2021. This does not align with the timescales for the Heathrow Expansion Project. The Heathrow Expansion Project will require areas of Green Belt land. In accordance with national policy and guidance, Heathrow will seek to demonstrate that the Heathrow Expansion Project is an exception to the presumption against inappropriate development in the Green Belt as the Heathrow Expansion Project represents very special circumstances.

As set out in the Airports National Policy Statement at paragraph 5.127, 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. As such, where possible Heathrow will seek to minimise the amount of Green Belt which is required.

Heathrow continue to work with Spelthorne Borough Council as part of the Heathrow Strategic Planning Group.

The principle of Heathrow’s draft fees policy is welcomed as it clarifies the approach.

✓ Comments noted.




PC MC

WC

In respect of the Professional fees policy, withholding fees that are not pre-approved by Heathrow would conflict with good practice guidance set out by the Government and that this part of the draft proposal should be removed from the fees policy.

✓ Under the Compensation Code the statutory right for reimbursement of professional fees only arises once compulsory acquisition powers have been granted. Heathrow's fee policy intends to address the timing gap and provide certainty for property owners in advance of consent for the DCO. The draft policy aims to avoid disputes when agreements are nearing completion due to disagreement over the scope or level of fees which have been incurred.


Heathrow should commit to reimburse professional fees to owner-occupiers that could be incurred during the DCO application process including the consultation stages.

✓

Along with compensating householders, Heathrow should compensate local authorities for loss of amenity value of parkland by setting up a fund for public parks.

✓ Heathrow is undertaking an assessment of impacts on communities that includes an assessment of impacts on recreational space. Based on this assessment we will propose mitigation measures. Early findings will be presented at the Airport Expansion Consultation in June 2019. Heathrow will also bring forward proposals for a Community Compensation Fund in accordance with the requirements of the Airports NPS. Details will be set out in our Airport Expansion Consultation in June 2019.

Concern that responding would give Heathrow the ability to claim that residents support expansion simply by responding.

✓ We can confirm that responding to Consultation or Land Referencing requests is not taken to indicate whether or not a respondent supports Heathrow Expansion.

There are anomalies in the title of the Crown Land on the Longford River on the southern side of the airport. Any encroachments would be subject to license.

✓ Heathrow notes the feedback received. Heathrow is required to identify land interests through diligent inquiries and consult all land interests about the proposed DCO application, and is aware of the




PC MC

WC

The title of the Longford River must be established before any final plans for the expansion are agreed. An easement at the very least would be required to ensure a legal right to the passage of water. All costs for this should be borne by Heathrow.

✓ specific statutory controls relating to Crown Land.

Land ownership issues that affect the Royal Parks will need to be considered prior to the planning stage.

✓

None of the options presented are acceptable due to the massive “land grab” from Colnbrook with Poyle and the neighbouring communities of the Harmondsworth, Longford and Stanwell.

✓ Heathrow Expansion will require land that is necessary for the construction and/or operation of the Project. Our preferred masterplan will be available at the Airport Expansion Consultation in June 2019. This will set out the reasons for identifying the land that is required to deliver the Project.

Heathrow will also apply for powers of Compulsory Acquisition as part of the application for DCO where mutual agreement cannot be reached with relevant land interests.

In seeking compulsory acquisition powers Heathrow will be required to justify that there is a compelling case in the public interest for the acquisition of the property or land.



19. NOISE

19.1 Introduction


relation to the proposed approach to reducing, minimising or mitigating the effects

of noise arising from the Heathrow Expansion Project (the Project). A total of 2,491

consultees made comments about Heathrow’s proposed noise envelope and

efforts to mitigate noise pollution, 1,205 consultees made comments on the

provision of respite, 1,110 consultees made comments about noise insulation and

2,189 consultees made comments about the night flight ban.

19.1.2 Heathrow provided the following material that is directly related to the proposed

approach to reducing, minimising or mitigating the effects of noise:



3. Our Approach to Noise.

19.1.3 Heathrow asked the following questions regarding the proposed approach to

reducing, minimising or mitigating the effects of noise at Airport Expansion

Consultation One:

1. A noise envelope is a package of measures that can be used to reduce noise.

Please tell us your views on the objectives of the noise envelope and the

timeline for its development.

2. Is there anything further we should be considering to reduce noise?

3. Please tell us what you think about our suggested approach to the provision of

respite.

4. Please tell us what you think of our proposals for noise insulation and phasing

of delivery.

5. A 6.5 hour night flight ban on scheduled flights is required between 11pm and

7am. Our current preferred option for this is from 11pm to 5.30am. Please tell

us when you think the night-flight ban should be scheduled and why.
















Local Authorities

General Comments

19.2.1 Bracknell Forest Council, Buckinghamshire County Council and Runnymede

Borough Council expressed concern about likely detrimental noise impacts upon

areas and assets within their administrative boundaries.

19.2.2 Elmbridge Borough Council expressed concern that there was no central policy on

performance based navigation (PBN) technology and the absence of flight path

information meant that it is not clear what the noise effects will be or who will be

affected. The Council also considered that the ‘trade-off’ between increased noise

or increased emissions had not been communicated well enough to residents and

supported the formation of an independent regulator to set and enforce targets tied

to penalties.

19.2.3 The London Borough of Hammersmith and Fulham stated that the best approach

to reducing noise impacts is to not expand Heathrow and to reduce the noise

impacts of current operations.

19.2.4 Harrow Council requested further details on mitigation and how Heathrow will

meet the aspirations and targets in the draft London Plan (2017). The London

Borough of Hounslow commented that Heathrow must meet national, EU and

International standards as part of the DCO process. The London Borough of

Sutton found it difficult to identify how noise from the additional runway could be

acceptably managed.

19.2.5 These three Councils also expressed concern that there was no evidence of

how modern navigation technologies including PBN, quieter operating procedures

and aircraft technologies can reduce Heathrow’s impact on quality of life of

residents as far as practicable. This view was also shared by St Albans City and

District Council.

19.2.6 Islington Council commented that it is not appropriate to increase the number of

flights over London and expressed opposition to any increase in flights over the



Borough and any changes that would lead to additional aircraft noise, especially

at night.

19.2.7 The Royal Borough of Windsor and Maidenhead stated that noise intensification is

completely unsustainable to residents in the Borough whose noise burden is

already unacceptable.

Noise Envelope

19.2.8 Brent Council was supportive of the noise envelope and the proposed measures to

address and control noise, especially plans to consider noise caused by road

traffic and construction.

19.2.9 Islington Council stated that existing arrangements have not delivered any

improvements and that the noise envelope will only be of value if it is used to set

challenging targets with consequences if they are missed.

19.2.10 The Royal Borough of Kingston upon Thames expressed concern about the

effectiveness of new technology against the existing baseline.

19.2.11 Runnymede Borough Council and Slough Borough Council requested

representation on the Noise Envelope Design Group (NEDG). Kent County

Council also supported the need for the group and suggested that it should have a

range of noise metrics to engage local communities on the design of the noise

envelope and flight paths to provide respite.

19.2.12 Slough Borough Council also agreed with the package of six noise measures and

considered the framework approach proposed acceptable.

19.2.13 Spelthorne Borough Council and Surrey County Council shared these concerns.

Spelthorne requested further detail on how noise will be managed and clear, on-

going, challenging and regularly reported performance targets to reduce noise

levels below those currently experienced. They welcomed Heathrow’s commitment

to a noise envelope, the International Civil Aviation Organisation’s (ICAO)

“Balanced Approach to Airport Noise Management” and to develop a quieter

airport by design. Surrey County Council stated information on noise effects down

to 51 dB LAeq 16h should be provided and taken into account in the design of

mitigation and noise control measures. They also stated that new operating

procedures and technologies should be explored to reduce noise impacts.

19.2.14 Spelthorne Borough Council pointed to existing conditions along the Compton

route12 where larger, heavier aircraft struggle to manoeuvre to minimise

disturbance. They stated that despite research and a review of procedures, no

12 The Compton route is one of six departure routes used when the Airport is on easterly operations.



improvement has been made. The Council said that the noise envelope must

anticipate and quickly resolve growing noise problems resulting from

developments in new aircraft and technology and secure continuous improvement

in the noise environment.

19.2.15 Wokingham Borough Council and Ealing Council considered the noise envelope

reasonable and broadly acceptable. Reading Borough Council supported the

proposed measures to reduce or mitigate the effects of noise nuisance from both

the existing and expanded airport.

Measures that should be considered to reduce noise

19.2.16 Buckinghamshire County Council stated that the effects on health for communities

not previously overflown is far greater than for communities already overflown.

They considered that minimising the need to affect new populations and

businesses should be the first principle in Heathrow’s redesign of airspace and

then the reduction of the noise envelope for those communities currently affected.

19.2.17 The London Borough of Hounslow and Wokingham Borough Council commented

that changes to aircraft and their management should be considered to reduce

noise. They also considered that CAEP Chapter 3 aircraft should be phased out

and better, quieter aircraft introduced. Wokingham Borough Council felt that this

process should be encouraged through differential pricing of landing charges for

noisier aircraft.

19.2.18 The London Borough of Hounslow also stated that further steps should be taken to

try and improve aircraft occupancy rates replacing under-used aircraft with smaller

aircraft where possible.

19.2.19 Kent County Council and the London Borough of Lambeth stated that recent

evidence shows that people are sensitive at a lower level of noise exposure and

negative health impacts occur at lower exposure levels than previously thought.

Lambeth also commented that the new “noise annoyance” benchmark (the 54dB

contour) shows that an expanded Heathrow will affect more people than

at present.

19.2.20 Reading Borough Council stated that construction and road traffic noise must be

properly assessed and mitigated. They considered this an omission from the

current scope as the over dependence on cars is already experienced and

extends some distance from the airport. They also considered that if the proposed

western and southern rail links are delivered there would be a beneficial noise

reduction across the area. The London Borough of Brent expressed a similar view.

19.2.21 Slough considered that the SOAEL (significant observed adverse effect level)

should be 63 dB LAeq over 16 hours and the LOAEL (lowest observed adverse

effect level) should start at 51 dB LAeq over 16 hours. They highlighted the need



to ensure health impact assessments use the latest peer review evidence and

consider compensation for affected residents where airport operations exceed

LOAEL levels.

19.2.22 They requested that sensitive community buildings and schools affected by noise

(SOAEL levels above 63 dB LAeq, 16 hours) should be identified and

consideration given to relocate them to quieter areas as well provision of noise

insulation and ventilation.

19.2.23 They also stated that construction noise, ground borne noise and road traffic noise

associated with the Project must be properly assessed and mitigated as this can

give rise to significantly effects on local communities.

19.2.24 The South East England Councils stated that clear performance targets for noise

must be independently enforced. They considered these essential to ensure

environmental impacts are minimised for communities impacted by an expanded

airport, locally and over a wider area under flight-paths.

19.2.25 Spelthorne Borough Council stated that noise effects down to 51 dB LAeq 16h

should be highlighted and taken into account in the design of mitigation and

noise control measures. They expressed concern with the 2014 noise attitudes

survey to establish the LOAEL and stated that it would have been greatly

enhanced if people living in areas adversely affected at the lower noise levels had

been included.

19.2.26 They also stated that road traffic noise will be a significant source of increased

environmental noise and will require careful assessment and mitigation.

The provision of respite

19.2.27 Essex and Kent County Councils supported the provision of predictable periods of

respite through runway alternation and welcomed community involvement in

seeking to agree the pattern of respite and the development of appropriate

noise mitigation.

19.2.28 Essex County Council also welcomed noise mitigation measures such as runway

alternation and respite to ensure that local communities have predictable periods

of respite that can be supported.

19.2.29 The London Borough of Hammersmith and Fulham expressed concern that

Heathrow’s report “Respite from aircraft noise: Overview of recent research” had

not been referred to. They considered this essential and important information that

should be communicated and that its findings contradict the approach to respite in

the consultation.

19.2.30 The London Borough of Hounslow stated that runway alternation with three

runways would reduce respite from 33% to 25%.



19.2.31 Reading Borough Council stated the ability to offer respite through runway

alternation would appear to be improved with the three runways and should be

made a significant objective.

19.2.32 Runnymede Borough Council suggested that the wider dispersal of flight paths will

give a greater respite to those that would otherwise be in a concentrated flight

path. Surrey County Council expressed a similar view and stated that reliable

respite is critical in the context of more concentrated PBN based routes in future.

19.2.33 Slough and Spelthorne Borough Councils considered respite critically important

but doubt whether operational constraints would allow this. Both Councils stated

that communities affected by the southern runway and new 3rd runway will be

offered less respite than those affected by the central runway which cannot

operate on mixed mode.

19.2.34 Slough Borough Council stated that during the four operating modes there would

be only one period of predictable respite for communities in Slough. They also

expressed concern about the noise impacts associated with westerly preference

and requested a more equitable balance with easterly operations. They stated that

evidence should be provided in prior to the next stage of consultation that

demonstrates that respite will work.

19.2.35 The Royal Borough of Windsor and Maidenhead stated that for communities under

runway approaches, predictable respite is an absolute requirement. They

considered that the proposals put forward would, for some communities, halve the

current amount of respite.

19.2.36 Wokingham Borough Council commented that the principle factor affecting aircraft

noise is wind direction and as the prevailing winds normally lead to westerly

operations at Heathrow this minimises aircraft noise in the Borough. They stated

that easterly operations rarely last for extended periods and as a result do not see

any requirement for formal respite measures.

Noise Insulation

19.2.37 Local Authorities queried the suitability of using zones to define eligibility for

compensation.

19.2.38 Bracknell Forest Council queried whether eligibility for compensation would be

extended to its boundaries and wanted to understand what penalties will be

imposed for failure to exceed anticipated limits.

19.2.39 The London Borough of Hammersmith and Fulham also alluded to this stating that

the noise insulation scheme is not “world class” and is less generous than the one

offered by Gatwick. They considered that the insulation scheme needs to be



extended to include its communities that would be newly overflown for long

periods daily.

19.2.40 The London Borough of Hounslow was concerned that the proposals for noise

insulation now apply at 60dB’ LAeq, 16hr and that the lower levels of noise

annoyance identified within the Civil Aviation Authority Survey of Noise Attitudes

(SoNA) report do not seem to have had any impact on the noise trigger level for

eligibility for acoustic insulation. They sought clarity on what is meant by ‘full single

mode contour’ and how its operational design would deliver respite.

19.2.41 Kent County Council stated there is evidence that people are now more sensitive

to lower levels of aviation noise and health impacts are more severe than

previously thought. They suggested the level may need to be reduced to the

LOAEL of 51 dB LAeq 16hr.

19.2.42 Slough Borough Council stated there was a lack of clarity on the effects to its

residents as airspace designs are indicative. They indicated that it is currently

unclear where the noise contours will lie and which residents will be eligible for

noise insulation. They commented that a noise relocation scheme for villages

should be targeted to areas where exceedance of the SOAEL is predicted and

sought assurance that the SOAEL will not be exceeded outside of the Compulsory

Purchase Zone (CPZ) and Wider Property Offer Zone (WPOZ).

19.2.43 They commented that it was acceptable to prioritise the Phase 1 inner Zone

following the granting of DCO powers over Phase 2 Outer Zone at the point the

airport becomes operational although hardship cases should be brought forward

on their merits. In addition, they considered that all community building should be

included in Phase 1.

19.2.44 Spelthorne Borough Council said the scheme is unfair for residents living to the

west of the airport who will have to be exposed to higher long term noise levels

before they qualify for sound insulation compared to those living to the east. They

cited the government’s consultation response on UK Airspace Policy which

identified that future policy may require compensation for significantly increased

overflights according to local circumstances and stated that a proper assessment

must be undertaken.

19.2.45 They also stated that the insulation does not offer any relief from noise within

gardens and open spaces close to the airport and considered that mitigation

should include public transport in perpetuity for residents to visit quiet areas.

19.2.46 Surrey County Council echoed this view and identified Elmbridge, Runnymede and

Surrey Heath Boroughs in addition to Spelthorne as areas that could experience

significant increases in overflight and noise and should be offered adequate

compensation. They expressed concern there is no target completion date for



insulation for either the Inner Zone or Outer Zone schemes and cited past poor

performance by Heathrow in the delivery of smaller scale insultation schemes.

19.2.47 Surrey County Council also agreed that mitigation of residual noise impacts was

essential but that the proposed compensation thresholds do not reflect recent

research that shows sensitivity to aircraft noise has increased, with the same

percentage of people reporting to be highly annoyed at a level of 54 dB LAeq 16hr

as occurred at 57 dB LAeq 16 hr in the past.

Night time ban

19.2.48 Bracknell Forest Council stated that its northern area lies under the flightpath and

requested an extension to 8 hours between 11pm to 7am.

19.2.49 Elmbridge Borough Council and the London Borough of Sutton supported a night

time ban of 6.5 hours but did not comment on the timing.

19.2.50 The London Borough of Hounslow said that the ban only applies to scheduled

flights which already allows a high number of night flights, causes significant

adverse effects on residents and should be subject to the proposed ‘design

principles’. This distinction was also made by Elmbridge Borough Council who

stated that there is a need to better educate residents on night flight rulings and be

transparent about scheduled and non-scheduled flights.

19.2.51 The London Borough of Islington requested the proposed 6.5 hour ban be

extended so that flights can be accessed by public transport and reduce the

effects of traffic noise on the wider road network and communities.

19.2.52 Kent County Council considered that a collaborative approach to agreeing the

night time period would be a great success story if the ban on night flights could be

extended to the other London airports. They asked Heathrow to encourage other

airports to implement a voluntary ban.

19.2.53 Runnymede and Wokingham Borough Councils were supportive of a ban between

11:00pm and 5:30am as it is less disruptive and offers the best compromise for

their residents. The London Borough of Harrow was also supportive of a ban of 6.5

hours as well as the statement that the majority of future flights will be between the

hours of 7am and 11pm.

19.2.54 Slough Borough Council and the London Boroughs’ of Hounslow and

Hammersmith and Fulham considered that there should be a complete ban on

night flights for 8 hours from 11pm to 7am to protect residents from significant

noise disturbance and prevent sleep disturbance.

19.2.55 Slough Borough Council went on to comment that if a 6.5 hour ban is progressed

according to the Airports National Policy Statement (ANPS), it should take place

between 11.30pm and 6am to protect children and the elderly being adversely



impacted (sleep disturbed) from aircraft movements at night. They also suggested

that outside of these hours Heathrow should incentivise the use of the quietest

aircraft and that this should be a requirement for DCO consent.

19.2.56 Spelthorne Borough Council said that Heathrow must listen to residents affected

by night flights and fully consider their needs to achieve a compromise on the

timing. Kent County Council also favoured this collaborative approach.

19.2.57 Surrey County Council referenced the Transport Select Committee proposals for a

minimum average period of 7 hours of respite a night.

19.2.58 The Royal Borough of Windsor and Maidenhead considered that the proposed 6.5

hour ban does not offer residents meaningful protection from disturbed sleep.

They pointed out that delayed flights are still able to frequently land within this

period and that scheduled arrivals from the east are likely to be clustered in the

05:30 – 06:00 period which would be highly disruptive to the sleep patterns of

many who surround the airport.


19.2.59 Historic England was the only statutory consultee to respond on issues of noise

and made comments on the noise envelope and noise insulation.

Noise Envelope

19.2.60 Historic England expected that effects on the historic environment are included

within the terms of reference for the NEDG (as referenced in the draft ANPS).

Noise Insulation

19.2.61 Historic England recognised that the noise insulation and compensation schemes

for properties and communities affected by increased noise is at an early stage of

development. They stated that heritage assets should be considered as part of

any scheme and should be informed by an assessment of the significance of the

building in question rather than as part of a wider, standard scheme.


General Comments

19.2.62 Horton Parish Council stated that aircraft noise will be made worse with more air

traffic. They also expressed concern about construction and increased road traffic

noise which will increase during all hours of the day.



19.2.63 Windlesham Parish Council stated that it would support its residents but

appreciated that while the perception of noise may be subjective, they considered

noise levels to be measurable and therefore objective.

19.2.64 Iver Parish Council commented that there is no information about how noise

generated by the Project will affect the local residents in Richings Park and stated

that the lack of any modelling of such impacts makes it impossible to form a view

on many of the proposals.

Noise Envelope

19.2.65 Albury Parish Council expressed concern that the Project will further damage the

tranquillity of the Surrey Hills AONB.

19.2.66 Bray Parish Council stated that the noise proposals are not quantified and that it

can only comment if a noise footprint for the area is provided.

19.2.67 The Heathrow Strategic Planning Group (HSPG) suggested that an independent

noise body should be established involving stakeholders from the immediate and

wider communities, with independent noise experts from both sides. They also

said it is difficult assessing noise impacts when operational patterns and flight

paths are not fixed.


19.2.68 Colnbrook with Poyle Parish Council suggested that moving the runway and

associated taxiways eastward might help reduce noise.


19.2.69 Colnbrook with Poyle Parish Council highlighted the importance of respite and

alternating the direction and timing of aircraft noise. They welcomed Heathrow's

increased commitment to respite but suggested night noise fines should be raised

to more punitive levels.

19.2.70 Cholesbury-Cum-St-Leonards Parish Council stated that departures should be

fanned out over a wider area.

19.2.71 Bray Parish Council commented that there was insufficient information regarding

flight paths.

19.2.72 The HSPG highlighted the need for predictable and meaningful respite.

Noise Insulation

19.2.73 Horton Parish Council considered that the provision of double glazing is

inadequate as it is not reasonable for residents to stay in-doors to avoid noise.



19.2.74 Bray Parish Council stated that regardless of the proposals, increased noise

pollution will prevent local residents from enjoying outside space with ongoing

effects on mental health.

19.2.75 Colnbrook with Poyle Parish Council assumed that people living nearest to the

new runway and new taxiways will be getting most of the extra noise. They said

many of these are on the Toll House Estate in Poyle will already have had some

noise insulation fitted. They welcomed a strong commitment from Heathrow that

any newly affected properties will get state-of-the-art noise insulation but wanted

to see definitive guidance on which properties will be eligible for what and when.

19.2.76 The HSPG stated that noise insultation must happen across a wider area and

include all community buildings including schools, colleges, places of worship,

hospitals, clinics and other medical centres. They also stated that whilst aircraft

noise is the key driver for noise insulation, surface access is another source of

noise to be addressed as part of the overall cumulative assessment of impacts.

Night time ban

19.2.77 Bray Parish Council stated that the night flight ban should be from 11:00pm to

7:00am, should include all flights and be effectively enforced. They commented

that there are numerous flights that come in outside the existing ban and a

northern runway has the potential to impose aircraft noise on many more of

their residents.

19.2.78 Albury Parish Council expressed the same view on the timing of the ban but went

on to state that if a “stack” system is to be used for holding aircraft it should be

higher and further out over sea and not over the Surrey Hills or the Downs. They

also requested a ban on night flights at Gatwick.

19.2.79 Cholesbury-Cum-St-Leonards Parish Council stated that there needs to be a ban

on night departures by noisy aircraft.

19.2.80 The HSPG expressed support for the Airports Commission recommendation that a

full ban is required for 6.5 hours per night between 11.30pm and 6.00am, with

further management in the 11pm to 7am period.

19.3 Members of the Community


General Comments

19.3.1 Members of the public expressed concerns about the noise impacts of the existing

airport, that the Project would make noise worse and affect local communities.

They expressed concern or dissatisfaction with the proposals and said that



Heathrow had not delivered on previous promises, that existing noise levels were

too high and that the measures proposed were inadequate or insufficient to

reduce effects.

19.3.2 Concerns were also raised about an increase in the number of flights, that the

airport should not have any flights over London and the proposals will have

negative effects on businesses, the economy and jobs.

Noise Envelope

19.3.3 A range of comments were received from members of the public about the noise

envelope. Most of these expressed concerns about the noise impacts of the

Project and the impacts on local communities. These were often about the impact

of noise on their quality of life, health and well-being, sleep disruption, disturbance

to local people and their families, negative impacts on children and that noise is a

particular issue in summer when people have open windows or doors. Concerns

were also raised about the increased volume of air traffic and unreliable noise

estimates for newer, quieter or more efficient aircraft and that there was

insufficient detail on the proposed measures.

19.3.4 Feedback received also said that the noise envelope was a suitable and well-

considered approach, that it was needed or necessary and that the approach was

fair and/or it is necessary regardless of the Project.

19.3.5 Specific comments about the noise envelope suggested that there should be

investment in new or modern technology to reduce the impact of noise.

Other related comments referred to aircraft becoming more efficient and quieter

and that flight path alteration would increase flexibility at the airport in future.

Responses also said that a noise envelope would allow for steeper ascent and

descent, reduce the noise footprint on the local area, communities and local

people and would be a useful way for the airport to address concerns from the

local community.

19.3.6 Negative comments focussed on a perceived inadequacy of the proposed

measures, and/or that they were unrealistic or unachievable. Some also said

the noise envelope approach was not favoured, that it would not be enforced,

that the scheme would not work, that it was not credible and that aircraft noise

would increase.


19.3.7 Members of the local community made a range of suggestions relating to

measures that could be considered in order to reduce noise:

1. incentivise new, quieter, and more efficient aircraft;



2. reduce the volume or number of flights;

3. ensure that aircraft take off and land at steeper angles;

4. ban or restrict night-time flights;

5. ban or restrict older, noisier and less efficient aircraft;

6. the respite period should be longer than proposed;

7. the noise burden should be shared over a wider area;

8. the area to be insulated should be extended;

9. impacted residents should be fairy or properly compensated; and

10. all affected areas should receive double glazing or triple glazing.


19.3.8 Most members of the public that commented on respite expressed concerns about

the noise impacts of the Project and the impacts on local communities.

19.3.9 Members of the public made general comments in favour of respite from noise.

Other general comments comprised:

1. favourable comments about the alternation of the runway;

2. that respite was necessary to alleviate aircraft noise;

3. That the approach was fair;

4. respite must be enforced;

5. the proposals would benefit local people and local communities;

6. people directly under flight paths would experience benefits;

7. there would be improvements to peoples’ quality of life;

8. communities to the west of Heathrow would benefit from respite; and

9. sleep disturbance would be reduced.

19.3.10 Members of the public also made the following negative comments or expressed

concerns about respite:

1. concern about negative impacts on quality of life, health, well-being, local

people and communities;

2. concerns that wind direction would affect the ability to alternate runways and

predictable periods of respite;



3. the approach was inadequate, insufficient and/or would not

make a difference;

4. respite would be reduced because of the additional runway;

5. respite will not be enforced; and

6. respite is unrealistic.

Noise Insulation

19.3.11 Most members of the public that commented on noise insulation expressed

concerns about the noise impacts of the Project and the impacts on local

communities.

19.3.12 The main positive comments were that:

1. noise insulation was necessary;

2. that the scheme appeared fair;

3. that it was long overdue; and

4. that is was needed to keep noise levels down regardless of whether the Project

was progressed or not.

19.3.13 Comments also suggested that the scheme should be implemented before any

new/additional flights were permitted, there should be payment for air conditioning

as those affected by flights will not be insulated if they open their windows/doors in

summer months and that its effectiveness was dependant on the enforcement of

the night-time ban.

19.3.14 The main concerns were that:

1. the proposals were unrealistic or unachievable;

2. insulation cannot cover people when outside; and

3. noise insulation was not favoured due to opposition to the Project;

4. the proposals are too restrictive and should cover a wider area;

5. that the proposals do not address open windows and doors;

6. that double-glazing would be ineffective; and

7. that there was not enough information to make an informed opinion; and

8. the measures would be ineffective as they did not take noise from construction,

road traffic and airport users into account.

19.3.15 Respondents also expressed a general lack of trust in any new measures.



Night time ban

19.3.16 The main criticisms from members of the public regarding night flights and the

proposed night flight ban were that noise disturbs sleep for adults and children,

early morning and late-night flights interrupt sleep, night time noise impacts quality

of life, health and well-being and that noise impacts local people and communities.

19.3.17 Respondents commented that 5.30am is too early for flights to resume. Concerns

were also raised over stacking prior to landing, an increased volume of early flights

and that the ban only relates to scheduled flights.

19.3.18 Concerns about the night flight ban were also linked to suggestions about its

timing or extension. The suggestions were that the ban should:

1. be in place between 11pm and 7am;

2. be for longer than 6.5 hours;

3. include all flights, including unscheduled flights;

4. be longer than 8 hours; and

5. be in place between 11pm and 6am.

19.3.19 Some considered that Heathrow’s preferred night period ban (11pm to 5.30am)

was adequate or suitable, that the timing of the ban would suit the working local

community and people’s sleep patterns or that the proposals would reduce noise

which would benefit local communities.

19.3.20 Other comments suggested the night period ban would improve operational

efficiency, be short enough that the airport remains competitive, benefit users of

the airport and still allow early morning flights from overseas. Other suggestions

were that there should not be a ban at all on night flights.

Businesses

General Comments

19.3.21 The Hampshire Chamber of Commerce stated that a commitment to noise control

is vital.

19.3.22 Heathrow Hub stated that the absence of airspace design and flightpaths makes it

impossible to assess the noise impacts of the third runway.

Noise Envelope

19.3.23 The Surrey Chambers of Commerce and Town Centre Securities were supportive

of the objectives of the noise envelope and the timeline for its development.



19.3.24 Virgin Atlantic Airways Limited (Virgin) also supported the principle of a noise

envelope but considered that until airspace design was finalised and agreed it

would not be possible to define, consult on or agree such an envelope. They said

their entire fleet would have the quietest and greenest long-haul aircraft by 2021

and that they remain committed to reducing their impact on local communities and

the environment.

19.3.25 The Fuel Trading Company were also supportive of the noise envelope but asked

what guarantees can be given, such as the delaying of take offs or the levy of a

fine.

19.3.26 Hatton Farm Estates Limited considered that the approach to a noise envelope

was sensible and said that improvements in technology would help reduce noise

in future.

19.3.27 The London (Heathrow) Airline Consultative Committee (LACC) and the Board or

Airline Representatives UK (BAR) stated that until airspace design is agreed it

would not be possible for the airline community to define, consult on or agree to

the noise envelope.

19.3.28 Greengauge 21 considered the coverage of overall noise issues was inadequate

and supported a decrease in the number of residents within the 65 Db contour.


19.3.29 London Biggin Hill Airport stated that there are options for changing the routes of

arriving and departing flights and to reduce noise by increasing the altitude of

aircraft. They recommended that Heathrow should seek to reduce the noise on

existing routes rather than creating new noise impacted areas.

19.3.30 LACC and BAR highlighted the ICAO Balanced Approach to noise mitigation

which they considered provides a transparent process for managing noise on an

airport-by-airport basis.

19.3.31 The Copas Partnership suggested the use of quieter planes should

be encouraged.


19.3.32 Heathrow Hub stated that the complexity of the north west runway operations

makes it impossible to offer alternation throughout the day without sacrificing

significant and unquantifiable capacity. They considered that ‘predictable respite’

is meaningless as it could refer to daily, weekly, monthly or annual respite for

affected communities.

19.3.33 Virgin said that respite is frequently cited by local communities as a primary benefit

and Heathrow must not ignore proposals that focus on providing extended periods



of predictable respite from scheduled night flights, rather than a prescriptive ban

for a set number of hours that ignores alternatives that are more beneficial.

19.3.34 The Fuel Trading Co believed that the suggested approach to respite would offer

some assurance to the local community, but that phasing could be carried out

more quickly and pre-emptively.

19.3.35 The LACC and BAR considered Heathrow’s proposals for respite too narrow and

requested further consultation on this issue.

19.3.36 The Copas Partnership suggested that the approach to respite was very good.

Noise Insulation

19.3.37 The Pavilion Association Stanwell and Stanwell Moor made brief comments on

noise mitigation measures and suggested that loft insulation and triple glazed

windows would help to reduce noise from aircraft.

19.3.38 Orbit Developments considered the noise insulation proposed for community

buildings within the 60LAeq noise contour should be extended to all businesses

within the envelope.

19.3.39 The Thames Valley Chambers of Commerce said it supported proposals for

extensive noise insulation funding and that the appropriate authorities should

determine, with Heathrow, the required scale and degree of mitigation.

Night time ban

19.3.40 Airlines for America and Delta Airlines stated that the proposed blanket night ban

will have economic impacts and is inconsistent with the balanced approach

enshrined in ICAO principles and in Article 15 of the U.S.-EU Air Services

Agreement. They stated that depending on the timing of the ban, airlines would be

forced to cancel flights at the start of the night period and in the early morning

which would affect passengers and cargo. They considered that a better approach

would be to consider further mitigating potential impacts closer to the opening of

the third runway when impacts can be evaluated with more evidence.

19.3.41 They also expressed concern about the proposed early increase of air traffic

movements by 25k per annum in exchange for the early introduction of the night

flight cap, as this proposal would negatively impact resilience and early morning

flight arrivals. A similar view was expressed by Virgin Atlantic Airways Limited.

19.3.42 Virgin considered it essential that the economic damage and technical

consequences of a night flight ban need to be considered. They said that the

airline community has identified an alternative approach to a strict scheduled night

flight ban that would result in greater respite for local communities, improved



resilience for the airport as a whole, increased domestic connectivity and more

convenient flight times for passengers and freight.

19.3.43 They considered that alternatives to the total night flight ban should continue to be

considered to avoid damaging the prospects of economically valuable early

morning flights, connectivity, resilience and the essential competitiveness of

Heathrow as a world-class international hub. They stated that should Heathrow

proceed with the night flight ban as proposed it should operate between 2300 –

0530 to minimise disruption and detriment to current operations at the airport and

minimise the negative impact of an expanded Heathrow.

19.3.44 Segro requested an impact assessment be undertaken to assess the effect on

competitiveness of businesses and the freight sector that rely on late departures

and/or early morning flights.

19.3.45 EasyJet supported a night time ban between 11.30pm and 6am as it would be in

the interests of a greater number of passengers and would maximise utilisation

of the aircraft. WeMoved Limited shared a similar view about the timing of the

ban and considered that noise will become less of an issue with improvements

in technology.

19.3.46 The LACC and BAR said the airline community is not in agreement with a rigid

night ban or the hours of 23:00 to 05:30 due to its economic damage and technical

consequences. They stated that it would introduce operational and commercial

risks as airlines are not able to move flights within the curfew period resulting in

existing and potential markets being lost to Heathrow and the UK.

19.3.47 They commented that raising the ATM cap prior to the third runway should

increase passenger volumes, reduce charges and allow new entrants and

incumbents to apply for slots but said it does not accord with the ICAO Balanced

Approach and achieving this in advance of new runway capacity is challenging

due to the impact on resilience and night flights.

19.3.48 Hatton Farm Estates and the Surrey Chamber of Commerce considered the night

time ban should be 11pm to 5.30am as it would meet most people’s sleep

requirements and the needs of business.

19.3.49 The Fuel Trading Company did not consider there was much difference banning

aircraft between 5.30am and 7am but that the latter would be more acceptable to

local communities.

19.3.50 The Copas Partnership commented that the night flight ban should be

gradually reduced.



Community Groups

General Comments


Consultation One expressed opposition to the Heathrow Expansion Project but did

not necessarily include specific feedback on noise.

19.3.52 SCR Residents stated that the Project would affect more than just local residents

and to mitigate noise, expansion should be at Gatwick. Egham Residents

Association expressed concern that the noise footprint had not been reduced

since the 1970s. Aircraft Noise Three Villages criticised Heathrow for failing to

influence the industry to improve current noise levels and that a noise envelope

is not a package of measures. The Local Authority Aircraft Noise Council (LAANC)

considered noise around Heathrow unacceptable and that this has been the case

for years.

19.3.53 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.

19.3.54 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.

19.3.55 Northumberland Walk Residents Association expressed concern about increased

ground and airborne noise from the third runway operations and the potential for

intensified ground noise from re-siting airport maintenance facilities and traffic from

airport supporting facilities.

Noise Envelope

19.3.56 Heathrow Association for the Control of Aircraft Noise, Teddington Action Group,

Stanwell’s Green Lungs and the Fulham Society suggested that the noise

envelope should minimise total noise for all those overflown or close to flight paths

and set firm limits/performance targets on noise levels.

19.3.57 The LLAANC challenged the idea that a noise envelope can fairly balance

unlimited growth in air traffic movements as long as overall average noise energy

remains constant. They also stated that the noise envelope should have a primary

target of ensuring that total noise energy within the envelope reduces year on year



to ensure that any extra movements do not simply fill the headroom created by

improvements in the noise performance of new aircraft.

19.3.58 The Richmond Heathrow Campaign suggested that noise metrics should be

revised to better reflect the impact on people. Ealing Aircraft Noise Action Group

requested that a firm limit on total noise must be based on an N60 metric not

Leq. They also said that there should be targets to reduce noise to meet

WHO guidelines.

19.3.59 The Residents Association HVG CA considered that the noise envelope should be

extended to all areas affected by aircraft noise. The Fulham Society,

Northumberland Walk Residents Association, The Cheyne Walk Trust, The Ealing

Aircraft Noise Action Group and the Richmond Heathrow Campaign all expressed

concern with the current and future noise impacts in their areas and questioned

whether the envelope would be able to adequately evaluate future impacts.

19.3.60 Englefield Village Action Group, Teddington Action Group, Wentworth Residents

Association, Residents Association HVG CA and Aircraft Noise Three Villages

suggested that there should be greater ascent angles and compulsory noise

abatement procedures with severe financial penalties for flights which depart from

noise preferential routes.

19.3.61 Richmond Environmental Information Centre, Wentworth Residents’ Association,

Colnbrook Community Partnership and the Fulham Society said the noise

envelope must be developed and agreed before the Project is approved.

Colnbrook Community Partnership also supported the formation of a NEDG.


19.3.62 The Richmond Heathrow Campaign and The Camberley Society said that fleets

should be modernised as quickly as possible to reduce noise and other emissions.

19.3.63 Richmond Environmental Information Centre stated that the introduction of electric

engines could be a compulsory source of power for aircraft when landing and this

would help to mitigate aircraft noise.

19.3.64 The Camberley Society requested for the noise footprint not to increase.


19.3.65 Many responses from community groups stated that respite was essential. Egham

Residents Association approved the proposals in principle. Harrow U3A

Sustainability Group suggested that invoking respite shows a lack of proper

planning over many years and Dover House Estate Residents’ Association stated

that the concept of insulation implies harm in the first place.



19.3.66 Heathrow Association for the Control of Aircraft Noise requested guaranteed

respite for all communities within 25 miles. Aircraft Noise Three Villages suggested

that Heathrow's noise nuisance is vast and should include all of London and

communities within a 30-mile radius. St Albans Quieter Skies stated that respite is

essential for affected residents.

19.3.67 Ealing Aircraft Noise Action Group considered that as two runways would be used

for take-off at the same time, respite for departures was unlikely or limited.

Richmond Heathrow Campaign, Local Conversation in Stanwell, Stanwell’s Green

Lungs and Aircraft Noise Three Villages considered that Heathrow had been

disingenuous in its approach and that respite would be reduced from 50% to 33%

through the introduction of an additional runway.

19.3.68 The LAANC queried why the consultation omitted reference to Heathrow’s report

“Respite from Aircraft Noise: Overview of Recent Research”.

Noise Insulation

19.3.69 Wentworth Residents Association and Richmond Heathrow Campaign stated that

the noise insulation proposals are inadequate. They also stated that eligibility

noise contours are too high and that it would be unlikely that Heathrow could

provide insulation to many people for a long time after they experience noise.

19.3.70 Richmond Heathrow Campaign together with Eastcote Conservation Panel and

Residents Association HVG CA also considered noise issues were not being

treated seriously and that insulation does not deal with noise problems in gardens,

parks and open spaces.

19.3.71 Colnbrook Community Partnership asked about the eligibility criteria for insulation

and temporary re-housing during construction. They also considered that the

timeline for insulation of community buildings (including schools not relocated)

should be the same as for all properties within the inner zone13.

19.3.72 Englefield Green Action Group requested that all houses within a 10-mile radius

be offered triple-glazing and/or secondary glazing. A similar view was shared by

Teddington Action Group who asked that Heathrow insulate all properties within

the daytime 51dB + LOAEL.

19.3.73 Heathrow Association for the Control of Aircraft Noise considered that the

timetable for noise insulation needs to be accelerated significantly.

19.3.74 Stanwell’s Green Lungs requested full compensation for anyone affected by noise,

regardless if they receive insulation.

13 properties within the 60dB LAeq (16hr) expanded airport noise contour.



19.3.75 The LAANC suggested that the proposed noise insulation measures were not

‘world class’.

Night time ban

19.3.76 Aircraft Nosie Three Villages, Harrow U3A Sustainability Group, Dover House

Estate Residents’ Association, Stanwell’s Green Lungs, LAANC, Teddington

Action Group and Cheyne Walk Trust stated that a 6.5-hour night ban was

inadequate or unacceptable.

19.3.77 Eastcote Conservation Panel considered that a 6.5-hour night flight ban would

breach human rights.

19.3.78 Wentworth Residents Association, Richmond Heathrow Campaign, Ealing Aircraft

Noise Action Group Slough & District Against Runway 3, Englefield Green Action

Group, Heathrow Association for the Control of Aircraft Noise, Wentworth

Residents’ Association, Ealing Fields Residents’ Association, Colnbrook

Community Association, Colnbrook Community Partnership, Residents

Association HVG CA, Egham Residents Association and Dover House Estate

Residents’ all specified the need for an 8 hour night time ban. The majority of

these stated that this should be between the hours of 11pm and 7am.

19.3.79 A number of these organisations also made the link between interrupted sleep

and health, lost productivity, early deaths, child mental illness and reduced

learning skills.

19.3.80 Local Conversation in Stanwell stated that Heathrow must listen to local residents

in order to achieve compromise.

19.3.81 The Camberley Society favoured the continuation of the present night time ban.

The Fulham Society felt that there should be a minimum ban of 6.5 hours for

night flights.

19.3.82 St Albans Quieter Skies expressed concern that tighter restrictions on night flights

at Heathrow could lead to an increase in night flights at Luton Airport.

19.3.83 West Windsor Residents Association stated that The Davies Commission

recommended a total ban on all night flying and there is no indication of any

reduction in night flights in the proposals.


General Comments

19.4.1 The Church of England Diocese of London, Oxford and Southwark stated that a

fundamentally different approach to the analysis of noise and pollution impacts is

needed that considers how the health and wellbeing of the people is affected.



19.4.2 England’s Economic Heartland, London First, Transport for The South East and

Thames Valley Berkshire LEP support the need for the Project, subject to an

appropriate package of mitigation measures addressing surface access, air quality

and noise impacts on the airport’s neighbours.

19.4.3 The Mayor of London stated that Heathrow’s noise case is based on taking

advantage of quieter aircraft and new navigation technologies being introduced as

part of the London Airspace Management Programme.

19.4.4 The Campaign to Protect Rural England (CPRE) expressed concern that there

would be greater impacts upon the tranquillity of the Surrey Hills area of

outstanding natural beauty (AONB) and that these would be cumulative with

Gatwick. They stated that an important aspect of the AONB is its relative

tranquillity and noise disturbance from air traffic is already harmful to the AONB

rural environment and its setting.

Noise Envelope

19.4.5 West London Friends of the Earth considered that a noise envelope was not a

package of measures but believed that the objective should be to minimise the

totality of noise for people who are overflown. They suggested that flights should

be restricted in line with the present cap.

19.4.6 Dominic Raab, MP stated that clearly defined and legally enforceable limits for

noise must be included in the plans together with independent monitoring to

ensure compliance. He also commented that the noise envelope should include

enforceable and binding limits.

19.4.7 The London Wildlife Trust, Friends of the River Crane Environment, London Parks

and Garden’s Trust and The Royal Parks all expressed concern about impacts

upon the natural environment, open space and its users and asked that this be

acknowledged within the envelope.

19.4.8 The Chartered Institute of Logistics and Transport stated that until noise targets

are set, the number of aircraft movements should be limited below full capacity of

the runways.

19.4.9 The National Trust expressed concern at the lack of detail to the envelope and

requested further details for potential flight path options, the likely environmental

effects such as noise, air quality and health and the airport’s plans to mitigate and

reduce them.


19.4.10 Colne Valley Regional Park stated that noise was a particular concern and an

issue that cannot be over-stated. They requested that a noise benchmark be



established for the creation of attractive and usable natural areas for public

enjoyment and to protect the park as much as possible.

19.4.11 Dominic Raab MP stated that the Project provides an opportunity to shift away

from concentrated flightpaths to disperse them over a wider geographical area.

He considered this would provide relief to local residents most severely impacted

by noise, in particular people in Molesley and Walton.

19.4.12 The London Wildlife Trust commented that innovative thinking needs to be applied

to reduce noise impact and find solutions on how the public can enjoy the natural

environment near to the airport. They welcomed the exploration of options for

sympathetic landscaping that would reduce decibel levels. CPRE suggested that

flights should not be directed over areas of lower population with priority given to

locating any new additional air traffic and spreading the impact of extra aircraft

noise to other geographical areas well north of London and away from South

East England.

Provision of respite

19.4.13 Dominic Raab MP stated that predictable and regular periods of respite including a

strictly enforced night-time ban must be provided.

19.4.14 Justine Greening MP (Putney) stated that any proposals which reduce the number

of hours of respite for her community are unacceptable.

19.4.15 West London Friends of the Earth, the Liberal Democrats and the Hounslow

Green Party considered the consultation was misleading as respite would be

reduced from half to a third and residents would be expected to sacrifice periods of

peace for greater predictability. Noise should be reduced overall and that

mitigation should not be used to justify the Project.

19.4.16 The London Parks and Garden’s Trust welcomed the provision of respite,

particularly for natural areas of land. The London Wildlife Trust and the Colne

Valley Regional Park requested respite be increased during weekends, public

holidays, and when daylight hours are at their longest.

19.4.17 The Chartered Institute of Logistics and Transport and Lambeth/Herne Hill Green

Party agreed that having multiple flight paths, rotated to give each community a

break from noise each day was important.

19.4.18 The Mayor of London said the noise measures appeared largely unchanged and

the proposed respite would mean communities under the final approaches would

have no aircraft flying overhead for just a quarter of the day, half of what is

offered today.



Noise Insulation

19.4.19 The Mayor of London stated that the phasing, extent and threshold for eligibility of

the noise insulation package were too high.

19.4.20 Colne Valley Regional Park stated that there needs to be consideration for users

of open spaces where standard approaches to noise insulation are not applicable.

19.4.21 The London Parks and Gardens Trust stated that the amenity value of public parks

and open land has been overlooked and a fund should be set up in perpetuity for

surrounding London Boroughs to enable them to invest in other public parks in

their areas to compensate for the loss of amenity value for their residents.

19.4.22 West London Friends of the Earth commented that full compensation should be

provided to all citizens affected by noise, whether they get insulation or not.

Night time ban

19.4.23 The Lambeth/Herne Hill Green Party and the Chartered Institute of Logistics and

Transport agreed with a night flight ban from 11pm to 5.30pm.

19.4.24 The Kingston Environmental Forum stated that 5.30am was too early to

resume flights.

19.4.25 The Church of England Diocese of London, Oxford and Southwark supported the

Transport Select Committee’s recommendation of a 7-hour night ban. The World

Federalist Party believed that even 11pm to 7am would be too short.

19.4.26 Justine Greening MP (Putney) highlighted the concerns of her constituents about

aircraft noise at night and in the early morning. She suggested that a ban on night

flights should be implemented immediately and that proposals to start normal

operations at 5.30am were unacceptable to local residents.

19.4.27 The Mayor of London stated that the proposed night flight ban between 11pm and

5.30am will lead to more flights scheduled in the current night quota period. He

commented that without any restrictions on the intensive use of all three runways

after 5.30am, the proposals could result in three times the number of scheduled

night flights (11pm-7am) compared to today.

19.4.28 The Colne Valley Regional Park stated that a night time ban needs to take

into consideration the potential impact of the airport’s activities on its residents

and wildlife.

19.4.29 The London Parks and Garden’s Trust said further consideration should be given

to natural considerations such as birdsong.




Tables 19.1A and 19.1B present a summary of the main issues raised by prescribed consultees, local communities and

wider/other consultees in relation to Noise.

Table A 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 B 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 19.1A


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The coverage of overall noise issues within the consultation was inadequate.

✓ Heathrow have noted this response and we have included additional information in the Airspace and Future Operations (January 2019). However, the full coverage of noise issues will be incorporated in our Statutory Consultation planned for June 2019. 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

14 Prescribed Consultees, Member of the Community and Wider Consultees.




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included information on proposed physical changes to the airport and design principles to inform the airspace design. The primary aim of the Consultation was to seek preliminary feedback to inform the ongoing development of the masterplan and airspace design process. In the January 2019 Airspace and Future Operations Consultation Heathrow are consulting 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. 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’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.

Support for a decrease in the number of residents within the 65 dB contour.

✓ At our Airport Expansion Consultation in June 2019, we will provide a PEIR on the impacts of our proposals, including impacts on noise. This will identify the residential areas that would be affected by noise. The Airports National Policy Statement (ANPS) requires that our proposals will avoid significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission.




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Heathrow Airport must listen to local residents in order to achieve compromise.

✓ We have noted this feedback and are committed to engaging with local

residents.

After this current consultation, we will have regard to the feedback while continuing to develop our detailed proposals in consultation with key stakeholders and local communities, and in the Airport Expansion Consultation planned for June 2019 we will present our updated proposals. Details of how we will continue to develop these proposals is available in the information paper Our Approach to Noise Management. This current Airspace and Future Operations Consultation is the second of three consultations on airspace change for our future operations. The first (Airport Expansion Consultation One) in 2018 was on design principles, this second one is about airspace design envelopes and the third will be about flight path options. This current consultation also covers some noise-related issues on runway operations at an expanded Heathrow, including respite, night flights and directional preference. These airspace consultations can be considered to run in parallel with two consultations on the Development Consent Order (DCO), the first (Airport Expansion Consultation One) was in January 2018 and the second, Airport Expansion Consultation will start in June 2019. The Airport Expansion Consultation in June 2019 will include the masterplan, the PEIR, and proposals on compensation, including noise insulation schemes.

A noise envelope is not a package of measures, the objective should be to minimise the totality of noise for people who are overflown. Flights should be restricted in line with the present cap.

✓ Feedback to Heathrow’s consultations will help us to build a ‘noise envelope’ which will include: • the noise management controls; • the rules we will put in place to use them;




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• the ways we will measure their effectiveness; and • how we will review them as Heathrow grows. In the information paper Developing our approach to noise management which has been published as part of the Airspace and Future Operations Consultation (January 2019), we have explained about how we will develop our noise envelope through engagement with a Noise Envelope Design Group before consulting on the detail at our Airport Expansion Consultation in June 2019. In the Airspace and Future Operations Consultation Document (January 2019), we also explain how we propose that growth at Heathrow should be restricted in line with environmental limitations.

The use of quieter planes should be encouraged, and the approach to respite within the consultation was very good.

✓ Heathrow note this feedback and agree that the use of quieter planes should be encouraged. As part of the Airspace and Future Operations Consultation, which launched in January 2019, we have included some information on how we will continue to incentivise the use of the quietest aircraft at night in Runway Operations - Night Flights document. Respite is discussed further in the Runway Operations – Respite through alternation document, a document also published as part of the Airspace and Future Operations Consultation in January 2019.

The noise footprint of Heathrow Airport should not increase and airlines should be encouraged to use quieter aircraft.

✓ The ANPS requires that noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. This reflects Heathrow’s committed goal that fewer people will be impacted by noise than in the reference year of 2013. As part of the Airspace and Future Operations Consultation, launched in




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January 2019, we have included some information on how we will continue to incentivise the use of the quietest aircraft at night in the Runway Operations – Night Flights document. At our Airport Expansion Consultation in June 2019, we will provide Preliminary Environmental Information on the impacts of the Project, including impacts on noise.

New operating procedures and technologies should be explored to reduce noise impacts.

✓ Operational concepts such as landing gear deployment, Continuous Descent Approach (CDA), Slightly Steeper Approaches (SSA) and Displaced Thresholds, as well as reducing noise impacts from departure procedures taking into account variables such as climb gradients, departure profiles, load factors and vectoring, are important and Heathrow are undertaking work now to better understand the contribution they will make to reducing the impact of aircraft noise. Our proposals for these measures will be explored further in our Airport Expansion Consultation in June 2019, where they are relevant to the DCO application. These issues relate to Heathrow's airspace design principles and their prioritisation and also to the development of the noise envelope. Heathrow's airspace design principles for Expansion were submitted to the Civil Aviation Authority (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 (2018). These issues were considered by Heathrow and were addressed in our submission to the CAA in August 2018.

There are options for changing the routes of arriving and departing flights and to reduce noise by increasing the altitude of aircraft.

✓

To reduce noise levels, it should be ensured that aircraft take off and land at steeper angles.

✓

Aircraft should depart from Heathrow Airport at greater ascent angles and there should be compulsory noise abatement procedures with severe financial penalties for flights which depart from noise preferential routes.

✓




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These issues will also be considered as part of the development of the noise envelope which will be secured by the DCO and which will have a bearing on the air space change process. See further on this in the Developing our approach to noise management document, published as part of the Airspace and Future Operations Consultation.

Support of an aircraft ban between 11:00pm and 5:30am as it is less disruptive and offers the best compromise for residents in the Runnymede and Wokingham areas.

✓ Night flights were an important topic during the Airport Expansion Consultation One and generated a variety of responses. Heathrow have provided further information on our consideration of our approach to night flights as part of the Airspace and Future Operations Consultation (January 2019), including how consultation one feedback has been taken on board. Please see the Airspace and Future Operations Consultation Document and the Runway Operations - Night Flights document for detailed discussion on the issues set out below. Night Flights Today Feedback indicated some uncertainty within communities about the current arrangements for night flights. In the Airspace and Future Operations Consultation Document and the Runway Operations - Night Flights document that are part of this consultation we have explained further the current arrangements for night flights. Duration and Timing of the Ban At Airport Expansion Consultation One we explained that, for a 6.5-hour night flight ban on scheduled flights, our preference would be for it to cover the period of 11pm to 5.30am. We explained that we considered that this approach would be fairer for all local communities as it gives a more equitable distribution of flights to those living under the departure routes as well as those living under the arrivals routes by extending the ban into the late night as well

Support from the Harrow area for a ban of 6.5 hours as well as the statement that the majority of future flights will be between the hours of 7am and 11pm.

✓

Support from the Elmbridge and Sutton areas on the existing night time ban of 6.5 hours but no comment on the timing.

✓

If a 6.5-hour ban is progressed according to the NPS, it should take place between 11.30pm and 6am to protect children and the elderly being adversely impacted (sleep disturbed) from aircraft movements at night. Outside of these hours Heathrow should incentivise the use of the quietest aircraft and that this should be a requirement for DCO consent.

✓

Support expressed for the Airports Commission recommendation that a full ban is required for 6.5 hours per night between 11.30pm and 6.00am, with further management in the 11pm to 7am period.

✓




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The night period ban would improve operational efficiency of Heathrow Airport, be short enough that the Airport remains competitive, benefit users of the Airport and still allow early morning flights from overseas.

✓ as the early morning instead of only the early morning. Generally, community respondents welcomed the concept of periods at night with no overflight, but some expressed that 6.5 hours was not long enough, and others went as far as to say that that less than 8 hours would not provide people with the amount of sleep required for good health. Other stakeholders such as airlines and businesses were concerned at the impact on flights from long haul destinations if a ban were imposed, and suggested alternatives should be considered. On balance from the information and feedback we have had to date we believe our previously stated support for a 6.5-hour ban on scheduled night flights strikes the right balance. We intend to carry out further assessment and consultation on our night restrictions proposals. We have provided more information on this in our Runway Operations - Night Flights document that is part of the Airspace and Future Operations Consultation 2019. The document explains that we consider that the end of the ban should not be later than 06:00. This is because banning scheduled operations during the 06:00-07:00 period would have significant economic implications; would significantly impact on Heathrow’s ability to compete with other European hub airports; and crucially would not enable Heathrow to operate at least 740,000 ATMs, which is a clear ANPS requirement for expansion. Equally this time period is important for both arriving and departing passengers whether travelling for business or leisure. Balancing community and airline and economic impacts We recognise that night flights are important and bring economic benefits, but that we must balance this with the impacts on health when deciding which ban to select and what the rules around it will be. This requirement is also recognised by the International Civil Aviation Organisation (ICAO) Balanced Approach. Complying with the principles of the Balanced Approach when selecting our

Should Heathrow proceed with the night flight ban as proposed it should operate between 2300 – 0530 to minimise disruption and detriment to current operations at the Airport and minimise the negative impact of an expanded Heathrow.

✓

The night time ban should be 11pm to 5.30am as it would meet most people’s sleep requirements and the needs of business.

✓

Approval of the night flight ban from 11pm to 5.30pm expressed.

✓

Heathrow’s preferred night period ban proposals (11pm to 5.30am) is adequate/suitable, the timing of the ban would suit the working local community and people’s sleep patterns and that proposals would reduce noise which would benefit local communities.

✓




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future proposals for night flights is a legal requirement and a requirement of the ANPS. Those legal requirements include an assessment of the 'cost effectiveness' of our proposals, including an assessment of the health impacts and the impact on capacity and the economy. This process is explained further in the information paper Runway Operations – Developing our approach to noise management, which is published as part of the Airspace and Future Operations Consultation (January 2019). Managing Flights within and either side of the ban We received comments about the meaning of scheduled flights, and a request for transparency about the rules for scheduled and non-scheduled flights. As part of the Airspace and Future Operations Consultation, we have explained further what 'scheduled' flights means and have discussed how the periods after the start of the ban (at night) and after end of the ban (in the early morning) could be managed. Incentivising the use of quieter aircraft We have included some information on how we propose to incentivise the use of the quietest aircraft at night in the Runway Operations - Night Flights document, published as part of the Airspace and Future Operations Consultation (January 2019). Night Flights – Next Steps After the Airspace and Future Operations Consultation (January 2019), we will have regard to the feedback while continuing to develop our detailed proposals in consultation with key stakeholders, and in the Airport Expansion Consultation planned for June 2019 we will present our updated proposals. Details of how we will continue to develop these proposals is available in the information paper Runway Operations – Developing our approach to noise




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management.

A night time ban between 11.30pm and 6am is supported as it would be in the interests of a greater number of passengers and would maximise utilisation of the aircraft.

✓ Night flights were an important topic during Airport Expansion Consultation One and generated a variety of responses. Generally, community respondents welcomed the concept of periods at night with no overflight, but some expressed that 6.5 hours was not long enough, and others went as far as to say that that less than 8 hours would not provide people with the amount of sleep required for good health. Other stakeholders such as airlines and businesses were concerned at the impact on flights from long haul destinations if a ban were imposed. Feedback indicated some uncertainty within communities about the current arrangements for night flights. Complying with the principles of the International Civil Aviation Organization (ICAO) Balanced Approach when selecting our future proposals for night flights is a legal requirement and a requirement of the ANPS. Those legal requirements include an assessment of the 'cost effectiveness' of our proposals, including an assessment of the health impacts and the impact on capacity and the economy. This process is explained further in the information paper Developing Our Approach to Noise management, published as part of the Airspace and Future Operations Consultation (January 2019). We have noted and considered the feedback around the various lengths that different respondents felt were appropriate for a ban on night flights. On balance from the information and feedback we have had to date we believe our previously stated support for a 6.5-hour ban on scheduled night flights strikes

There needs to be a ban on night departures by noisy aircraft.

✓

The night flight ban should be gradually reduced.

✓

There should be a minimum ban of 6.5 hours for night flights.

✓

Concerns expressed over the residents of Bracknell Forest as its northern area lies under the flightpath and a request for the night flight ban to be extended to 8 hours of no aircraft flight between 11pm to 7am.

✓

Concerns raised from the Windsor and Maidenhead areas that the proposed 6.5 hour aircraft ban overnight does not offer residents meaningful protection from disturbed sleep as delayed flights still able to frequently land within this period. Additionally, scheduled arrivals from the east are likely to be clustered in the 05:30 – 06:00 period which would be highly disruptive to the sleep patterns of many

✓




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who surround the airport. the right balance. We intend to carry out further assessment and consultation on our night restrictions proposals. We explain in this as part of the Airspace and Future Operations Consultation (see the Runway Operations - Night Flights document) that we consider that the end of the ban should not be later than 06:00. This is because banning scheduled operations during the 06:00-07:00 period would have significant economic implications; would significantly impact on Heathrow’s ability to compete with other European hub airports; and crucially would not enable Heathrow to operate at least 740,000 movements, which is a clear Airports NPS requirement for expansion. Equally this time period is important for both arriving and departing passengers whether travelling for business or leisure.

There should be complete ban on night flights for 8 hours from 11pm to 7am to protect the residents of Slough, Hounslow and Hammersmith and Fulham from significant noise disturbance from aircraft noise and prevent sleep disturbance.

✓

The Transport Select Committee proposals for a minimum average period of 7 hours of respite a night was identified as being required.

✓

The night flight ban should be from 11:00pm to 7:00am and should include all flights and be effectively enforced. There are numerous flights that come in outside the existing ban and a northern runway has the potential to impose aircraft noise on many more of the residents of Bray.

✓

To reduce noise levels there should be a ban/restriction on night-time flights.

✓

Concerns raised over stacking prior to landing, an increased volume of early flights would result from a night flight ban and that

✓




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the ban only relates to scheduled flights.

The night flight ban should be in place between 11pm and 7am.

✓

The night flight ban should be for longer than 6.5 hours.

✓

The night flight ban should include all flights, including unscheduled flights.

✓

The night flight ban should be for longer than 8 hours.

✓

The night flight ban should be in place between 11pm and 6am.

✓

There should not be a ban at all on night flights.

✓

There is little difference banning aircraft to 5.30am or to 7am but that the latter would be more acceptable to local communities.

✓

Comments that a 6.5-hour night ban was inadequate or unacceptable.

✓

A 6.5-hour night flight ban would breach human rights.

✓

View that an 8 hour night time ban is needed and that this should be between the hours of 11pm and 7am.

✓

The Davies Commission recommended a total ban on all night flying and there is no

✓




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indication of any reduction in night flights in the proposals.

Concerns in regard to the night flight ban as 5.30am is too early for flights to resume.

✓ ✓

Support expressed for the Transport Select Committee’s recommendation of a 7-hour night ban.

✓

A night flight ban between 11pm to 7am would be too short.

✓

A ban on night flights should be implemented immediately and that proposals to start normal operations at 5.30am were unacceptable to local residents.

✓

Concerns that the proposed night flight ban between 11pm and 5.30am will lead to more flights scheduled in the current night quota period.

✓

Concerns expressed for the residents of Putney, Roehampton and Southfields in regard to aircraft noise at night and in the early morning.

✓

A night time ban needs to take into consideration the potential impact of the airport’s activities on its residents and wildlife.

✓

Heathrow must listen to residents in the Spelthorne and Kent areas affected by night flights and fully consider their needs to achieve a compromise on the timing.

✓




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A request for better education for residents of Elmbridge on night flight rulings, along with transparency about schedules and non-schedule flights in this regard.

✓

Respite is frequently cited by local communities as a primary benefit and Heathrow must not ignore proposals that focus on providing extended periods of predictable respite from scheduled night flights, rather than a prescriptive ban for a set number of hours that ignores alternatives that are more beneficial.

✓

Heathrow's increased commitment to respite was welcomed but night noise fines should be raised to more punitive levels.

✓

Concerns from the Hounslow area that the ban only applies to scheduled flights which already allows a high number of night flights, causes significant adverse effects on residents should be subject to the proposed ‘design principles’.

✓ As part of the Airspace and Future Operations Consultation we have clearly set out the differences between scheduled and unscheduled flights in the Runway Operations - Night Flights document, and we have discussed how the periods after the start of the ban (at night) and after the end of the ban (in the early morning) could be managed, as well as the reasons why some flights may need to be allowed to land during the period of the ban (the “restricted recovery period”). During 2017 just over 3,200 flights operated after 23:00. Around 590 of these operated after 23:30 when the restrictive night quota period begins. The number of flights that can operate after the start of the night quota period is effectively limited by the fact that around 90% of the permitted quota count points and movements are allocated to scheduled early morning flights. To stay within the limits therefore there is no guarantee that a request to operate will be granted as the allocations need to be carefully managed across the whole season.




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As part of the Airport Expansion Consultation in June 2019 we will present our proposals in relation to how we intend to manage the “restricted recovery period” in the future.

A collaborative approach to agreeing the night time would be a great success story if the ban on night flights could be extended to the other London airports.

✓ The imposition of any restrictions at airports other than Heathrow is not a matter for Heathrow.

Concerns expressed that tighter restrictions on night flights at Heathrow could lead to an increase in night flights at Luton Airport.

✓ We will consider and assess the impacts of our proposals as part of the DCO application process, with preliminary environmental information being presented as part of the Airport Expansion Consultation in June 2019. However, Luton Airport does not provide long-haul hub capacity which as the ANPS recognises is only provided at Heathrow. We do not therefore anticipate that there would be any rerouting to Luton due to any restrictions at Heathrow. The impacts of any restrictions will be considered on a Balanced Approach basis as explained in Developing Our Approach to Noise Management, published as part of the Airspace and Future Operations Consultation (January 2019).

The proposed 6.5-hour ban should be extended so that flights can be accessed by public transport and reduce the effects of traffic noise on the wider road network and communities.

✓ We have noted and considered the feedback around the various lengths that different respondents felt were appropriate for a ban on night flights. On balance from the information and feedback we have had to date we believe our previously stated support for a 6.5-hour ban on scheduled night flights strikes the right balance. We intend to carry out further assessment and consultation on our night restrictions proposals. This response has been noted and will be considered as we develop our proposals in our statutory Airport Expansion consultation planned for June 2019.




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Concerns over the proposed blanket night flight ban and its economic impacts. The proposed ban is inconsistent with the balanced approach enshrined in ICAO principles and in Article 15 of the U.S. EU Air Services Agreement. Depending on the timing of the ban, airlines would be forced to cancel flights at the start of the night period and in the early morning which would affect passengers and cargo.

✓ The Airports NPS sets out a clear expectation for a ban on scheduled night flights. Therefore, it is to be expected that there will be a ban but we are actively consulting to develop the rules for that ban. Complying with the principles of the Balanced Approach when selecting our future proposals for night flights is a legal requirement and a requirement of the Airports NPS. Those legal requirements include an assessment of the 'cost effectiveness' of our proposals, including an assessment of the health impacts and the impact on capacity and the economy. This process is explained further in the information paper Airport Operations – Developing our approach to noise management. We have noted and considered the feedback around the various lengths that different respondents felt were appropriate for a ban on night flights. On balance from the information and feedback we have had to date we believe our previously stated support for a 6.5-hour ban on scheduled night flights strikes the right balance. We intend to carry out further assessment and consultation on our night restrictions proposals. We have provided more information this in our Runway Operations - Night Flights document that is part of this consultation.

It is essential that the economic damage and technical consequences of a night flight ban are considered.

✓

Request for an impact assessment be undertaken to assess the effect on competitiveness of businesses and the freight sector that rely on late departures and/or early morning flights.

✓

The airline community has identified an alternative approach to a strict scheduled night flight ban that would result in greater respite for local communities, improved resilience for the airport as a whole, increased domestic connectivity and more convenient flight times for passengers and freight.

✓

Request for alternatives to the total night flight ban should continue to be considered to avoid damaging the prospects of economically valuable early morning flights, connectivity, resilience and the essential competitiveness of Heathrow as a world-class international

✓




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hub.

Opposition expressed to the proposals on the ‘rigid’ night ban and the hours of 23:00 to 05:30 due to its economic damage and technical consequences. This approach would introduce operational and commercial risks as airlines are not able to move flights within the curfew period resulting in existing and potential markets being lost to Heathrow and the UK.

✓

Opposition expressed to a rigid night time ban or a ban between the hours of 23:00 to 05:30 due to its economic damage and technical consequences. It would introduce operational and commercial risks as airlines are not able to move flights within the curfew period resulting in existing and potential markets being lost to Heathrow and the UK.

✓

Without any restrictions on the intensive use of all three runways after 5.30am, the proposals could result in three times the number of scheduled night flights (11pm-7am) compared to today.

✓ Comments duly noted. In our Airspace and Future Operations Consultation Document we set out our proposals for a noise objective at Heathrow for the Secretary of State to consider. This sets includes the phrase “limit and, where possible, reduce the effects of noise on health and quality of life”. For an expanded Heathrow, this means that we will meet our previous committed goal to ensure that the overall noise impact will be limited to not




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exceed 2013 levels, which is the baseline set by the Airports NPS. This part of the objective also means that as aircraft and navigational technology improves, we will seek to reduce these effects. This includes the effects associated with night flights. In our consultation document Runway Operations – Night Flights we discuss that we have not sought to operate any more flights before 06:00 in the future than we do today. This is evidenced in our submissions to historic consultations undertaken by the Government over the past 20 years and in our statements in relation to expansion. This is an important assumption in considering how we manage future operations before 06:00 and with a ban on scheduled night flights in place. On balance from the information and feedback we have had to date we believe our previously stated support for a 6.5-hour ban on scheduled night flights strikes the right balance. We intend to carry out further assessment and consultation on our night restrictions proposals ensure that the ban duration and timing is optimised. We have provided more information this in Runway Operations - Night Flights document that is part of this consultation.

Continuation of the present night time ban preferred.

✓ There is no present night time general ban at Heathrow. Details of the present night time regime is set out in Runway Operations - Night Flights.

Clear performance targets for noise must be independently enforced. They are essential to ensure environmental impacts are minimised for communities impacted by an expanded airport, locally and over a wider area under flight-paths.

✓ Development of a noise envelope is a requirement of the ANPS. More information about the noise envelope, the Noise Envelope Design Group and how we are developing proposals to ensure that targets and limits in the noise envelope will be monitored can be found in the information paper Runway Operations – Developing our approach to noise management,




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A noise envelope would allow for steeper ascent and descent, reduce the noise footprint on the local area, communities and local people and would be a useful way for the airport to address concerns from the local community.

✓ published as part of the Airspace and Future Operations Consultation in January 2019. We will take all this feedback into account as we develop the noise envelope ahead of our Airport Expansion Consultation in June 2019. In the Airspace and Future Operations Consultation Document, we also explain how we propose that growth at Heathrow should be restricted in line with environmental limitations.

The noise envelope should minimise total noise for all those overflown or close to flight paths and set firm limits/performance targets on noise levels.

✓

The idea that a noise envelope can fairly balance unlimited growth in air traffic movements as long as overall average noise energy remains constant was challenged.

✓

The noise envelope should have a primary target of ensuring that total noise energy within the envelope reduces year on year to ensure that any extra movements do not simply fill the headroom created by improvements in the noise performance of new aircraft.

✓

Request for a firm limit on total noise to be based on an N60 metric not Leq.

✓

The noise envelope should be extended to all areas affected by aircraft noise.

✓

Clearly defined and legally enforceable limits for noise must be included in the plans together with independent monitoring to ensure compliance. The noise envelope should include enforceable and binding limits.

✓




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Considers there to be a lack of detail to the noise envelope proposals and requests further details for potential flight path options, the likely environmental effects such as noise, air quality and health and the airport’s plans to mitigate and reduce them.

✓

The noise envelope was considered to be reasonable and broadly acceptable.

✓

The noise envelope deemed a suitable and well-considered approach and that it is required and necessary. The approach in regard to the noise envelope is fair and/or it is necessary regardless of expansion.

✓

The noise envelope must be developed and agreed with representatives from Richmond Wentworth, Colnbrook and Fulham before expansion is approved.

✓

The approach to a noise envelope was sensible in relation to businesses and said that improvements in technology would help reduce noise in future.

✓

Heathrow Airport have not delivered any improvements through the existing arrangements and that the noise envelope will only be of value if it is used to set challenging targets, with consequences if they are missed.

✓

Concerns and dissatisfaction expressed with the proposals and noise envelope. Heathrow had not delivered on previous promises;

✓




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existing noise levels are too high and that the measures proposed were inadequate or insufficient to reduce effects.

Concerns over the noise envelope approach as it would not be enforced, that the scheme would not work, that it is not credible and that aircraft noise would increase.

✓

Heathrow criticised for failing to influence the industry to improve current noise levels and that a noise envelope is not a package of measures.

✓

Concern expressed with the current and future noise impacts in the areas of Fulham, Ealing, Richmond, Northumberland Park and Chelsea, and questioned whether the envelope would be able to adequately evaluate future impacts.

✓

Comments about the noise envelope in relation to investment in new or modern technology to reduce the impact of noise.

✓

Support expressed from businesses for the noise envelope but queries into what guarantees can be given, such as the delaying of take offs or the levy of a fine.

✓

In regards to the noise envelope: due to the AIRPORTS NPS it is expected that effects on the historic environment are included within the terms of reference for the NEDG.

✓




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A request for more Borough and County Councils to be represented on the Noise Envelope Design Group (NEDG).

✓ This response has been noted and will be considered as Heathrow develop the Noise Envelope Design Group in January 2019. Information will be provided as part of the Airport Expansion Consultation in June 2019.

Concerns about the noise envelope and impacts of expansion and the impacts on local communities in regard to quality of life, health and well-being, sleep disruption, disturbance to local people and their families, negative impacts on children and that noise is a particular issue in summer when people have open windows or doors.

✓ We note this feedback and recognise the importance of the links between

noise and effects on health and quality of life.

In our Airspace and Future Operations Consultation booklet we set out our proposals for a noise objective at Heathrow for the Secretary of State to consider. This sets includes the phrase “limit and, where possible, reduce the effects of noise on health and quality of life.” For an expanded Heathrow, this means that we will meet our previous

committed goal to ensure that the overall noise impact will be limited to not

exceed 2013 levels, which is the baseline set by the Airports NPS. This part of

the objective also means that as aircraft and navigational technology improves,

we will seek to reduce these effects

In our statutory Airport Expansion consultation planned for June 2019 we will

go further and include early findings of our assessments of the likely significant

effects of our proposals on noise on health and quality of life. This will be

presented in a PEIR for consultation. A scoping report for the EIA including

the health impact assessment (HIA) for the project was submitted in June 2018

and can be viewed on the Planning Inspectorate (PINS) website

https://infrastructure.planninginspectorate.gov.uk/wp-

content/ipc/uploads/projects/TR020003/TR020003-000457-HTHR%20-

%20Scoping%20Report%20(Main%20Report).pdf. This Scoping Report

explains how we will undertake our assessment of noise impacts.

The HIA reported in the Environmental Statement (ES) will identify and assess

https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000457-HTHR%20-%20Scoping%20Report%20(Main%20Report).pdf






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the positive and negative health effects of the scheme, reporting on likely

significant health effects and the measures taken by the DCO Project to

enhance positive health effects and reduce negative health effects.

In terms of noise effects on health, the ES will report on a range of health and

quality of life outcomes including annoyance, sleep disturbance, cardiovascular

outcomes, and children’s learning. WebTAG analysis will also be used, as per

policy requirements, to assess the health effects of the project.

The effects of the project on a range of noise sources (including aircraft, road

traffic, railway, construction, aircraft-ground noise, and combined noise) on

these health outcomes will be assessed using the most up-to-date robust

evidence for each health and quality of life outcome. The Lowest Observed

Adverse Effect Level (LOAEL) and Significant Observed Adverse Effect Level

(SOAEL) values for the assessments are set out in the Scoping Report,

informed by policy, standards, empirical evidence and guidelines.

Heathrow’s Airport Expansion Consultation in June 2019 will set out the

preliminary findings of these assessments.

The World Health Organisation (WHO) have recently (October 2018) published the Environmental Noise Guidelines for the European region and values will be taken into account in the assessment as relevant either in terms of setting screening values or by way of sensitivity tests against the assessment methodology set out in the Scoping Report. However, the WHO Guidelines do not take precedence over UK policy requirements for the assessment.

Suggestion that the NEDG should have a range of noise metrics to engage local communities on the design of the noise envelope and flight paths to provide respite.

✓ In Heathrow’s information paper Runway Operations – Developing our approach to noise management, published as part of the Airspace and Future Operations Consultation, we have explained how we propose to develop the noise envelope through engagement with the Noise Envelope Delivery Group.




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This will include consideration of which metrics should be used to monitor and control growth at expanded Heathrow. Our proposed assessment methods and metrics for assessing the noise impacts of our proposed expansion are described in the EIA Scoping Report https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000457-HTHR%20-%20Scoping%20Report%20(Main%20Report).pdf which was submitted to the Planning Inspectorate. The Planning Inspectorate has consulted on the proposed assessment methods and provided feedback. This has raised a number of questions and queries that we will consider and work through, and we will present our approach and early findings at the Airport Expansion Consultation in June 2019 as part of the PEIR. As part of this process, Heathrow will continue to engage with the local authorities and other interest groups to agree the assessment methodologies as far as possible including the Heathrow Strategic Planning Group (HSPG), non-HSPG and the Noise Expert Review Group (NERG).

Aircraft noise will be made worse over the Horton area with more air traffic.

✓ In the Airspace and Future Operations Consultation, we are consulting on airspace design envelopes which indicate the broad areas where there may be overflight. These can be viewed in the Heathrow’s Airspace design envelopes for expansion document.

Concerns raised about an increase in the number of flights, that the airport should not have any flights over London and the proposals will have negative effects on businesses, the economy and jobs.

✓ In the Airspace and Future Consultation, we are consulting on airspace design envelopes which indicate the broad areas where there may be overflight. These can be viewed in the Heathrow’s Airspace design envelopes for expansion document. Our EIA will include an assessment of socio-economic impacts, which will include consideration of how expansions is likely to impact local businesses, the economy and jobs and propose appropriate mitigation measures which adverse impacts are identified. Our early findings of this assessment will be







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presented at our Airport Expansion Consultation in June 2019, as part of a PEIR on the impacts of our proposals.

To reduce noise levels volume or number of flights should be reduced.

✓ The Airports NPS states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. This reflects our committed goal fewer people will be impacted by noise than in the reference year of 2013. In our Airspace and Future Operations Consultation booklet we set out our proposals for a noise objective at Heathrow for the Secretary of State to consider. This sets includes the phrase “limit and, where possible, reduce the effects of noise on health and quality of life”. For an expanded Heathrow, this means that we will meet our previous committed goal to ensure that the overall noise impact will be limited to not exceed 2013 levels, which is the baseline set by the Airports NPS. This part of the objective also means that as aircraft and navigational technology improves, we will seek to reduce these effects. In order to meet the requirements of the Airports NPS the expanded airport will provide capacity for at least an additional 260,000 air transport movements (ATM). The noise envelope we will put forward will include limits to manage the noise impacts of flights while supporting growth over time.

Changes to aircraft and their management should be considered to reduce noise over the Boroughs of Hounslow and Wokingham.

✓ We are still at a relatively early stage of our airspace design process which started from a ‘blank sheet’. This means we do not yet know the position of future overflights. However, we have now identified the ‘design envelopes’, which show the geographical areas which are potentially overflown. This consultation asks for feedback on local information relating to these areas. Local information could




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include suggestions for noise sensitive areas or buildings that stakeholders believe should get special consideration (for example that may include those mentioned). Following this consultation, we will consider all suggestions on a case by case basis. We are also consulting in this consultation on runway operational measures that we can use to mitigate aircraft noise at an expanded Heathrow, including through runway alternation and the introduction of a scheduled ban on night flights. More information is available in the Airspace Expansion Consultation Document.

Aircraft becoming more efficient and quieter and flight path alteration would increase flexibility at the airport in future.

✓ In accordance with the requirements of the Airports NPS, through the noise envelope we propose to share the benefits of future technological improvements between the airport and airlines and the local communities, hence helping to achieve a balance between growth and noise reduction.

Some support from businesses in regard to the principle of a noise envelope but until airspace design was finalised and agreed it would not be possible to define, consult on or agree such an envelope.

✓ Lack of Information about flight paths 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 detail becomes available. Airspace Principles Consultation One (January – March 2018) was on design principles, for those wanting to influence from the outset. The process for the development of the design principles is set out in Heathrow's Airspace Design Principles for Expansion. The Airspace and Future Operations Consultation, which is currently taking

There is a lack of clarity on the effects to residents of Slough as airspace designs are only indicative.

✓

Concerns about assessing noise impacts when operational patterns and flight paths are not fixed.

✓

It was considered that the consultation provided insufficient information regarding flight paths.

✓




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It was perceived that the proposed measures are inadequate and that they are unrealistic/unachievable.

✓ 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 Principles for Expansion and Heathrow’s Airspace design envelopes for expansion. The 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 three stage approach to consultation gives stakeholders a number of opportunities to influence the airspace change process in the context of Expansion, to include with reference to flight path design. Defining mitigation without flight paths Our EIA Scoping Report explains how we propose to use indicative flight path designs to undertake our environmental impact assessment. The indicative flight paths we will use have been informed by the airspace macro-design and envelopes that are explained further in this consultation in the Airspace and Future Operations Consultation Document and Heathrow’s Airspace design envelopes for expansion. Using these indicative flight paths within sophisticated noise modelling technology will help us understand the likely significant environmental effects of expansion and therefore what limits and controls the noise envelope must include. Our initial assessment of noise impacts, including the mitigation measures and noise controls we propose, will be made available at our Airport Expansion Consultation in June 2019.

Insufficient detail on the proposed measures have been communicated.

✓

The absence of airspace design and flightpaths makes it impossible for businesses to assess the noise impacts of the third runway.

✓

Until airspace design is agreed, it would not be possible for the airline community to define, consult on or agree to the noise envelope.

✓

If a “stack” system is to be used for holding aircraft it should be higher and further out over sea and not over the Surrey Hills or the Downs.

✓ 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 7000ft upwards and are therefore part of the




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NATS airspace change to modernise airspace above 7000ft. For NATS changes above 7000ft see https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decisions-from-2018/London-Airspace-Management-Programme-Phase-2---ATS-Network/. For more details on how Heathrow expansion is part of the wider UK airspace Modernisation please see our What is airspace modernisation? Information Paper.

The effects on health for communities not previously overflown is far greater than for communities already overflown. Minimising the need to affect new populations and businesses should be the first principle in Heathrow’s redesign of airspace and reduce the noise envelope for those communities currently affected.

✓ These comments on affecting new population have been reported on in our airspace design principles submission to the Civil Aviation Authority (CAA) as part of the CAA’s CAP1616 process for establishing design principles and setting a broad prioritisation. This process involved engagement with a range of stakeholder representatives as well as the Airspace Principles Consultation One in January 2018. This work has been approved by the CAA – full details of the design principle submission 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 further information please see Heathrow's Airspace Design Principles for Expansion.

The provision of predictable periods of respite through runway alternation for the areas of Essex and Kent was supported.

✓ We know that predictable periods of respite are highly valued by local communities. As required by the Airports NPS (paragraph 5.61) providing predictable respite through runway alternation is a key component of our expansion proposals. In this Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can

The proposals for community involvement in seeking to agree the pattern of respite and the development of appropriate noise mitigation was welcomed.

✓

https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decisions-from-2018/London-Airspace-Management-Programme-Phase-2---ATS-Network/



https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decisions-from-2018/London-Heathrow-airspace-departure-and-arrival-procedures/






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The ability to offer respite through runway alternation would appear to be improved with the three runways and should be made a significant objective.

✓ extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents are: Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation. We are seeking feedback about the duration of respite breaks, which is a key component for how a runway alternation pattern operates. It is recognised that for some communities, which benefit from the current pattern of runway alternation, the level of respite that they currently receive each day will be reduced. This is explained in the document Runway Operations – Respite through alternation, published as part of the Airspace and Future Operations Consultation.

Reliable respite is critical in the context of more concentrated PBN based routes in future.

✓

The idea that noise mitigation measures such as runway alternation and respite to ensure that local communities have predictable periods of respite that can be supported, was welcomed.

✓

Concerns expressed that periods of respite would be reduced under the proposals.

✓

The need for predictable and meaningful respite is well established.

✓

Respite from noise is favoured by many in local communities.

✓

Suggestions from Heathrow Airport that alternation of runway usage and that respite is necessary to alleviate aircraft noise was welcomed and these approaches were fair.

✓

Respite is essential for communities in the Heathrow Airport area.

✓

Respite is essential for affected residents. ✓

Predictable and regular periods of respite including a strictly enforced night-time ban must be provided.

✓ ✓




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To reduce noise exposure the respite period should be longer than proposed.

✓ 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 explained in the document Runway Operations – Respite through alternation, published as part of the Airspace and Future Operations Consultation.

For communities under runway approaches, predictable respite is an absolute requirement. They considered that the proposals put forward would, for some communities, halve the current amount of respite.

✓

The communities affected by the southern runway and new 3rd runway will be offered less respite than those affected by the central runway which cannot operate on mixed mode.

✓ In the document Runway Operations – Respite through alternation, we explain how respite periods may differ for communities affected by arrivals and departures from the central runway when compared to those communities affected by the new north runway and the southern runway. We also explain why it is not possible for the centre runway to be used as a mixed mode runway while both of the other two runways are also in use.

During the four operating modes proposed there would be only one period of predictable respite for communities in Slough.

✓ We have noted this feedback and in developing our proposals have had regard to how we can provide predictable respite to all communities affected by aircraft noise. With expansion we will be able to provide respite to communities affected by aircraft noise in two ways:

• By alternating our runways, we will provide respite for those living closer to the airport; and

• By alternating our airspace, we will provide respite for those living further away. Airspace alternation is not currently possible, but with expansion we can provide respite for communities further away from the airport that do not receive any respite today.

As part of the Airspace and Future Operations Consultation, we have explained in the document Runway Operations – Respite through the work that




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we have done to date to test options for a runway alternation pattern, what options are possible and what are not, and we are asking an important question about the duration of respite breaks which will help inform the final proposal we put forward at our next consultation planned for June 2019.

Heathrow has been disingenuous in its approach and that respite would be reduced from 50% to 33% through the introduction of an additional runway.

✓ ✓ 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. Why this is explained in the document Runway Operations – Respite through Alternation. The ANPS also recognises the effects on respite of the new runway.

The approach to respite was considered inadequate, insufficient and would not make a difference to local people.

✓ As part of the Airspace and Future Operations Consultation, we have explained in the document Runway Operations – Respite through the work that we have done to date to test options for a runway alternation pattern, what options are possible and what are not, and we are asking an important question about the duration of respite breaks which will help inform the final proposal we put forward at our next consultation planned for June 2019.

Respite not favoured due to opposition to expansion of Heathrow Airport. It was considered that respite periods would be reduced because of the additional runway. Additionally, concerns that respite would not be enforced and the approach communicated by Heathrow Airport was not realistic.

✓ 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 explained in the document Runway Operations – Respite through alternation. With expansion we will be able to provide respite to communities affected by aircraft noise in two ways:






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Heathrow’s proposals for respite are too narrow and further consultation on this issue is requested.

✓ As part of the Airspace and Future Operations Consultation we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents are the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

Suggestion that invoking respite shows a lack of proper planning over many years.

✓ As part of the Airspace and Future Operations Consultation, we have explained in the document Runway Operations – Respite through the work that we have done to date to test options for a runway alternation pattern, what options are possible and what are not, and we are asking an important question about the duration of respite breaks which will help inform the final proposal we put forward at our next consultation planned for June 2019.

Concerns that as two runways would be used for take-off at the same time, respite for departures was unlikely or limited.

✓ As part of the Airspace and Future Operations Consultation we are consulting on our emerging thinking on runway and airspace alternation. The key documents are Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation. In these documents we explain how respite will be provided with three runways so that respite is provided under departures and arrivals. As part of the Airspace and Future Operations Consultation, we have explained in the document Runway Operations – Respite through the work that we have done to date to test options for a runway alternation pattern, what options are possible and what are not, and we are asking an important question about the duration of respite breaks which will help inform the final proposal we put forward at our next consultation planned for June 2019.

Any proposals which reduce the number of hours of respite for her community are

✓ 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




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unacceptable. each day will be reduced. This is explained in the document Runway Operations – Respite through alternation. A number of other communities who do not receive any respite today from runway alternation will however benefit from airspace alternation in the future. This is explained in the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation. As part of the Airspace and Future Operations Consultation we are consulting on our emerging thinking on runway and airspace alternation. We are seeking feedback about the duration of respite breaks, which is a key component for how a runway alternation pattern operates.

The consultation was misleading as respite would be reduced from half to a third and residents would be expected to sacrifice periods of peace for greater predictability. Noise should be reduced overall and that mitigation should not be used to justify expansion.

✓ 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. Why this is explained in the document Runway Operations – Respite through alternation. A number of other communities who do not receive any respite today from runway alternation will however benefit from airspace alternation in the future. This is explained in the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

Noise measures appeared largely unchanged and the proposed respite would mean communities under the final approaches would have no aircraft flying overhead for just a quarter of the day, half of what is offered today.

✓ 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. Why this is explained in the document Runway Operations – Respite through alternation. A number of other communities who do not receive any respite today from runway alternation will however benefit from airspace alternation in the future. This is explained in the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.




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As part of the Airspace and Future Operations Consultation we are consulting on our emerging thinking on runway and airspace alternation. We are seeking feedback about the duration of respite breaks, which is a key component for how a runway alternation pattern operates.

Respite was considered critically important but I there are doubts as to whether operational constraints would allow for this.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. We are confident that we will be able to deliver a runway and airspace alternation pattern to deliver respite as part of our expansion proposals. The key documents on this topic are Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

Heathrow’s proposals for respite were too narrow and further consultation on this issue is requested.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents on this topic are Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

The suggested approach to respite would offer some assurance to the local community, but phasing could be carried out early and quickly.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents on this topic are Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

A request for guaranteed respite for all communities within 25 miles.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can




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extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. With expansion we will be able to provide respite to communities affected by aircraft noise in two ways:



The key documents are the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation.

The complexity of the north-west runway operations makes it impossible to offer alternation throughout the day without sacrificing significant and unquantifiable capacity.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. In the Runway Operations – Respite through alternation we explain the 'test case' options we are evaluating. Our evaluation includes an assessment of impacts on capacity. We will not put forward a final proposed runway alternation pattern that does not support the capacity required to meet the requirements of the ANPS. The underlying airspace structure we have developed for expansion is specifically designed to be capable of providing both the capacity required and respite. For technical details of this airspace structure (also referred to as the ‘macro’ design) please see the Airspace and Future Operations Consultation Document and Our approach to redesigning our airspace network for an expanded Heathrow.




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Queries as to why the consultation omitted reference to the report “Respite from Aircraft Noise: Overview of Recent Research”.

✓ The paper “Respite from Aircraft Noise: Overview of Recent Research” has been considered and is referenced in the Airspace and Future Operations consultation document Runway Operations – Respite through alternation. It had not been published at the time the previous consultation documents had gone to print.

Concerns that the report “Respite from aircraft noise: Overview of recent research” had not be referred to in consultation. This report is considered essential and important information that should be communicated, and its findings contradict the approach to respite in the consultation.

✓

Concerns over respite were raised particularly in regard to negative impacts on quality of life, health, well-being and local people and communities. Concerns were also raised that wind direction would affect the ability to alternate runways and predictable periods of respite.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation set out our emerging proposals for alternation and the provision of predictable periods of respite and explain that runway alternation will be possible during both easterly and westerly operations.

Concern about the noise impacts associated with westerly preference and requested a more equitable balance with easterly operations. They stated that evidence should be provided in advance of Consultation 2 that demonstrates that respite will work.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on how we might use a directional preference at an expanded Heathrow to help manage noise during the approximately 20% of the time when there is a choice (the rest of the time this is determined by the wind direction). We have produced a document on directional preference called Runway Operations – Directional Preference that discusses this. We are also seeking feedback on whether we should seek to change the direction of operations when it has been in one direction for an extended period of time.




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We are consulting on our emerging thinking on providing respite through runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation set out our emerging proposals for alternation and the provision of predictable periods of respite and explain that runway alternation will be possible during both easterly and westerly operations.

The principle factor affecting aircraft noise is wind direction and as the prevailing winds normally lead to westerly operations at Heathrow this minimises aircraft noise in the Borough of Wokingham. Easterly operations rarely last for extended periods and as a result the requirement for formal respite measures is not seen.

✓ In response to feedback received in relation to the more equitable distribution between easterly and westerly operations, as part of the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on how we might use a directional preference at an expanded Heathrow to help manage noise during the approximately 20% of the time when there is a choice available on the way aircraft arrive at and depart from the airport (the rest of the time this is determined by the wind direction). Information on this can be found in the Airspace and Future Operations Consultation Document and Runway Operations – Directional Preference document. We also seeking feedback on whether we should seek to change the direction when it has been in one direction for an extended period of time.

Request for clarity on what is meant by ‘full single mode contour’ and how it’s operational design would deliver respite.

✓ Full single mode contour The “full single mode contour” is the contour created by combining the full 16 hour day of easterly operations contour with the full 16 hours day of westerly operations contour. Delivering respite In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can




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extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents are the Airspace and Future Operations Consultation Document and Runway Operations – Directional Preference document.

‘Predictable respite’ is meaningless as it could refer to daily, weekly, monthly or annual respite for affected communities.

✓ In the Airspace and Future Operations Consultation, we are consulting on our emerging thinking on runway and airspace alternation, including how we can extend the provision of respite to benefit areas further away from the airport that do not receive respite from runway alternation today. The key documents are the Airspace and Future Operations Consultation Document and Runway Operations – Directional Preference document. We are seeking feedback about the duration of respite breaks, which is a key component for how a runway alternation pattern operates. Specifically, we are seeking feedback on whether people would prefer shorter, daily periods of respite or respite periods which last longer but do not occur every day.

The wider dispersal of flight paths will give a greater respite to those that would otherwise be in a concentrated flight path.

✓ Comments on spreading flight paths and sharing noise were reported on in our airspace design principles submission to the Civil Aviation Authority (CAA) as part of the CAA’s CAP1616 process for establishing design principles and setting a broad prioritisation. This process involved engagement with a range of stakeholder representatives as well as the Airspace Principles Consultation One in January 2018. This work has been approved by the CAA – full details of the design principle submission can be found at: https://www.caa.co.uk/Commercial-

Departures should be fanned out over a wider area to reduce impact on the Cholesbury-Cum-St-Leonards area.

✓

To reduce noise exposure the noise burden should be shared over a wider area.

✓





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Expansion provides an opportunity to shift away from concentrated flightpaths to disperse them over a wider geographical area. This would provide relief to local residents most severely impacted by noise, in particular people in Molesley [sic] and Walton.

✓ industry/Airspace/Airspace-change/Decisions-from-2018/London-Heathrow-airspace-departure-and-arrival-procedures/ For a summary see Heathrow’s airspace design principles for Expansion. In the Airspace and Future Operations Consultation Document and Runway Operations – Respite through alternation, we also introduce the concept of flight path alternation. We are not consulting on this now, but more information will be provided in our final airspace consultation in which we will seek feedback on detailed route options and impacts arising from the specific flight paths. This consultation is scheduled to take place in 2022.

Having multiple flight paths, rotated to give each community a break from noise each day was importance.

✓

Concerns that noise disturbs sleep for adults and children, early morning and late-night flights interrupt sleep, night time noise impacts quality of life, health and well-being and that noise impacts local people and communities.

✓ We recognise that sleep disturbance is an important potential effect on health and in this current consultation we set out the progress in our thinking about a scheduled ban on night flights. An EIA Scoping Report for the EIA and health impact assessment (HIA) for the project was submitted in May 2018 and a Scoping Opinion was received from the Planning Inspectorate on 29th June 2018. The HIA will be reported in the Environmental Statement (ES) and will identify and assess the positive and negative health effects of the scheme, reporting on likely significant health effects and the measures taken by the DCO project to enhance positive health effects and reduce negative health effects. In terms of noise effects on health, the ES will report on a range of health and quality of life outcomes including annoyance, sleep disturbance, cardiovascular outcomes, and children’s learning. WebTAG analysis will also be used, as per policy requirements, to assess the health effects of the project. The effects of the project on a range of noise sources (including aircraft, road traffic, railway, construction, aircraft-ground noise, and combined noise) on these health outcomes will be assessed using the most up-to-date robust evidence for each health and quality of life outcome. LOAEL and SOAEL

Links between interrupted sleep and health, lost productivity, early deaths, child mental illness and reduced learning skills highlighted.

✓






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values for the assessments are set out in the Scoping Report, informed by policy, standards, empirical evidence and guidelines. The PEIR which will be published as part of the Airport Expansion Consultation in June 2019 will set out the preliminary findings of these assessments. The World Health Organisation (WHO) have recently (October 2018) published the Environmental Noise Guidelines for the European region and values will be taken into account in the assessment as relevant either in terms of setting screening values or by way of sensitivity tests against the assessment methodology set out in the Scoping Report. However, the WHO Guidelines do not take precedence over UK policy requirements for the assessment. At this stage, we are not in a position to consult on the specific proposals for early growth. Our ability to bring forward early growth is dependent upon a range of factors, such as changes in the current airfield infrastructure, revised regulation of airlines slots, as well as other matters which are being consulted on in this consultation, including in particular:

• the Noise Objective which is agreed for Heathrow;

• the establishment of required airspace changes relating to the two existing runways, for Independent Parallel Approaches (IPA); and

• the detailed terms of a ban on scheduled night flights at Heathrow.

These matters are the subject of the Airport and Future Operations Consultation and, once we have considered your feedback, we will be able to test the capacity for and implications of early growth. We will need to consider implications for terminal and stand capacity, environmental impacts, and how additional passengers would be accommodated in our surface access strategy. Our intention is to bring forward proposals for early growth as part of our Airport Expansion Consultation in June 2019.



Table 19.1B


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Support for the proposed measures to reduce or mitigate the effects of noise nuisance from both the existing and expanded airport.

✓ Comment duly noted.

The ICAO Balanced Approach to noise mitigation provides a transparent process for managing noise on an airport-by-airport basis.

✓

Heathrow’s commitment to a noise envelope, the ICAO’s “Balanced Approach to Airport Noise Management” and to develop a quieter airport by design was welcomed.

✓

Support for the need for expansion expressed, subject to an appropriate package of mitigation measures addressing surface access, air quality and noise impacts on the airport’s neighbours.

✓

Heathrow’s noise case is based on taking advantage of quieter aircraft and new navigation technologies being introduced as part of the London Airspace Management Programme.

✓

Noise will become less of an issue with improvements in aircraft technology.

✓ Heathrow’s approach to noise in the future is based on the International Civil Aviation Organisation (ICAO) balanced approach and this includes reducing noise at source with the use of quieter planes. Improvements in technology also include the future use of modern navigational technology known as Performance Based Navigation (PBN). PBN is a modern navigation system that uses modern




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satellite technology to direct aircraft.

Approval of the proposals in principle from the Egham area.


The best approach to reducing noise impacts is to not expand Heathrow and to reduce the noise impacts of current operations.

✓ The Government has designated the Airports National Policy Statement (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 Airport. The Airports NPS sets out specific requirements that Heathrow as the applicant for a new north-west runway will need to meet to gain development consent. Regarding current operations of the airport and noise impacts, Heathrow in accordance with the EU Environmental Noise Directive, are required to publish a Noise Action Plan at least every five years that can only relate to the current operation. Heathrow will be publishing a new Noise Action Plan for the period 2019 – 2023 during 2019. This includes mitigation measures to address current noise impacts from the operation of the existing Heathrow Airport. In preparing the preferred masterplan for the Heathrow Expansion Project (the Project) Heathrow are undertaking an ongoing evaluation process to inform the design process, so that design options can be refined in response to a range of criteria including noise considerations. Heathrow are undertaking an assessment of noise impacts of the Project, which will propose mitigation measures. Preliminary findings of this assessment and an outline of mitigation measures will be published in the Preliminary Environmental Information Report (PEIR) at the Airport Expansion Consultation in June 2019.

Heathrow’s proposals are inadequate and the airport should not be expanded.

✓

Expansion would affect more than just local residents and to mitigate noise, expansion should be at Gatwick.

✓

Current noise levels are unacceptable.

✓ Heathrow recognises that noise continues to be an issue for some people in our local communities and remains committed to continuing to seek opportunities to




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Noise levels around Heathrow are considered unacceptable and this has been the case for years.

✓ reduce those impacts. Over several decades we have continued to reduce our noise footprint and we will continue to manage and mitigate noise working on a range of actions. In 2019, Heathrow will publish our third Noise Action Plan (2019-2023) which sets out our next five year plan to continue to address noise issues in collaboration with aviation stakeholders and community groups.

The concept of noise insulation implies harm in the first place.

✓ Heathrow provide noise insulation schemes to provide practical assistance to those local residents experiencing the highest level of aircraft noise. Heathrow will publish updated details in June 2019 of the noise insulation scheme that will be available to residents that would be newly affected by noise from the third runway in addition to those exposed to noise under existing flight paths.

Concerns about the noise impacts of expansion and the impacts on local communities.

✓ Heathrow’s committed goal is to expand Heathrow whilst affecting fewer people with noise than today. Heathrow’s submission to the Airports Commission showed how a combination of quieter planes, quieter airport design, quieter operations and an extended night flight ban mean that it is possible to grow to at least 740,000 ATMs by 2040 while affecting fewer people by noise than were affected in 2013. More information on how this will be achieved will be provided as part of the Airport Expansion Consultation in June 2019. This will include the publication of the Preliminary Environmental Information Report (PEIR) which will set out Heathrow’s preliminary assessment of noise impacts and outline a proposed package of mitigation measures to seek to reduce adverse impacts. Our approach to this assessment is set out in Chapter 16 of Heathrow’s EIA Scoping Report. The PEIR will provide preliminary information on likely significant noise effects in communities.




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Concerns over likely detrimental impacts upon the areas of Bracknell Forest, Runnymede and Buckinghamshire, and their assets.

✓ An Updated Scheme Development Report will also be published as part of the Airport Expansion Consultation and this will set out how the elements of the design and layout of the ground based airport development seek to minimise noise effects, for example runway length, runway position and displaced thresholds for air noise; taxiway locations, bunding, barriers and landscaping for ground noise. The priorities for mitigation are as follows: reduction of noise at source; land use planning and management; noise abatement operational procedures; and operating restrictions. Noise abatement operational procedures relate to the development of proposals for a runway alternation scheme that provides predictable periods of respite from aircraft noise, a night flight ban and the consideration of airspace design and operation. The Airspace and Future Operations Consultation launched in January 2019 seeks feedback on these matters, which are set out in the Consultation Document. The Airport Expansion Consultation in June 2019 will present early findings of the noise impact assessment, undertaken as part of the EIA, in a PEIR, and the EIA will be part of our DCO application.

Concerns about the noise impacts of the existing airport, that expansion would make noise worse and affect local communities.

✓

There is no information about how noise generated by the expansion will affect the local residents in Richings Park and the lack of any modelling of such impacts makes it impossible to form a view on many of the proposals.

✓

Further noise intensification is unsustainable for the residents of the Royal Borough of Windsor and Maidenhead whose noise burden is already unacceptable.

✓

Request for further detail from Heathrow Airport on how noise will be managed and clear, on-going, challenging and regularly reported performance targets requested to reduce noise levels below those currently experienced.

✓ Heathrow’s approach to mitigating noise impacts is underpinned by the development of a “noise envelope” which will include:

• the noise management controls;

• the rules we will put in place to use them;

• the ways we will measure their effectiveness; and

• how we will review them as Heathrow grows noise envelope.

The noise envelope will be legally binding, and will be defined in consultation




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with local communities and relevant stakeholders to respond to the needs of local residents around Heathrow. This is in accordance with the Airports NPS. Details of all this is set out in Developing Our approach to noise management. Our proposals for the noise envelope will be presented at in the Preliminary Environmental Information Report (PEIR) and following feedback will be finalised in our Development Consent Order (DCO) application.

Until noise targets are set, the number of aircraft movements should be limited below full capacity of the runways.

✓ At our Airport Expansion Consultation in June 2019, we will provide Preliminary Environmental Information on the impacts of our proposals, including impacts of noise. The Airports National Policy Statement (ANPS) requires that (within the context of Government policy on sustainable development) our proposals will avoid, as significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. The DCO application and the noise envelope will set out measures that will be used to set targets and incentivise the use of quieter aircraft.

CAEP Chapter 3 aircraft should be phased out and better, quieter aircraft introduced, and this process should be encouraged through differential pricing of landing charges for noisier aircraft.

✓ Over several decades the noise footprint at Heathrow has steadily reduced mainly due to the continual improvement of the noise performance of the fleet of aircraft using Heathrow. We continue to manage and mitigate noise working on a range of actions. In 2019, Heathrow will be publishing our third Noise Action Plan (2019-2023) which sets out our next 5-year plan to continue to address noise issues in collaboration with aviation stakeholders and community groups.

To reduce noise new, quieter, and more efficient aircraft should be incentivised.

✓




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To reduce noise levels older, noisier and less efficient aircraft should be banned/restricted.

✓ The use of the best-in-class aircraft is encouraged through differential landing charges and Heathrow are working toward a voluntary Chapter 3 Aircraft phase out by the end of 2020. To model aircraft noise in future years, assumptions need to be made regarding the aircraft fleet mix in the future operational scenarios with and without the Development Consent Order (DCO) Project. Based on the ICAO requirement to reduce noise at the source, it is expected that noise from next generation aircraft will be quieter than today’s aircraft, however, at this time the actual noise levels of future aircraft are uncertain. A sensitivity analysis (including a worst-case assessment) of noise from future aircraft types will be undertaken for future operational scenarios based on research and analysis of future development of aircraft types. The assumptions used to predict aircraft noise from future aircraft types will be scrutinised by independent parties including the Noise Expert Review Group and the local authorities. The Civil Aviation Authority (CAA) will also provide validation of the way in which future assumptions have been incorporated into the noise models. The DCO application and the noise envelope will set out measures that will be used to set targets and incentivise the introduction of quieter aircraft.

The use of quieter planes should be encouraged to reduce noise impacts on businesses that are overflown.

✓

Fleets should be modernised as quickly as possible to reduce noise and other emissions.

✓

Concern expressed that the noise footprint of Heathrow Airport has not been reduced since the 1970s.

✓ In 1982 the area of the 57dBA Leq (16hr summer day) noise contour was approximately 550 km2. By 2017, this contour area had reduced to 93.2 km2. This is demonstrated in Figure 4.2 in the document Our Approach to Noise from the Airport Expansion Consultation One.

Request for further details on mitigation and how Heathrow will meet the aspirations and targets in the draft London Plan (2017).

✓ Heathrow will provide an outline of noise mitigation measures in the Preliminary Environmental Information Report (PEIR), to be presented at the Airport Expansion Consultation in June 2019. The Airspace and Future Operations Consultation in January 2019 provides specific information relating to operational mitigation measures including alternation, night flight ban and directional




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preference. The Heathrow EIA Scoping Report (2018) (Chapter 16) published by Heathrow sets out the policy documents that will inform the assessment of noise impacts. This includes the draft London Plan, and the PEIR to be published as part of the Airport Expansion Consultation will reference the draft London Plan in regard to the noise assessment.

Concerns that there was no evidence of how modern navigation technologies including PBN, quieter operating procedures and aircraft technologies can reduce Heathrow’s impact on quality of life of residents as far as practicable.

✓ Heathrow’s approach to noise in the future is based on the International Civil Aviation Organisation (ICAO) balanced approach and this includes reducing noise at source with the use of quieter planes. Improvements in technology also include the future use of modern navigational technology known as Performance Based Navigation (PBN). There is a European Aviation Safety Agency (EASA) mandate for the introduction of Precision Based Navigation (PBN), which is being implemented in the UK under the Government's Airspace Modernisation Strategy. While PBN has potential benefits in terms of noise in that populated areas can be better avoided, it also poses challenges, particularly the effects for those directly underneath flight paths experiencing a greater concentration of aircraft. Operational concepts such as landing gear deployment, Continuous Descent Approach (CDA), Slightly Steeper Approaches (SSA) and Displaced Thresholds, as well as reducing noise impacts from departure procedures taking into account variables such as climb gradients, departure profiles, load factors and vectoring, are important and we are undertaking work now to better understand the contribution they will make to reducing the impact of aircraft noise. Our proposals for these measures will be explored further in our Airport Expansion Consultation in June 2019, where they are relevant to the Development Consent Order (DCO) application. These issues relate to Heathrow's airspace design principles and their prioritisation and also to the development of the noise envelope.




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The noise envelope will give certainty to communities about the effects of the airport in the future. The noise envelope will include the noise management controls, the rules we will put in place to use them, the ways we will measure their effectiveness and how we will review them as Heathrow grows. It will be updated regularly (we propose around every 5 years) so that it remains relevant and up to date and takes account of changing technology so that the benefits are shared between communities and industry. The noise envelope will be legally binding, and defined in consultation with local communities and relevant stakeholders to respond to the needs of local residents around Heathrow. This is in accordance with the Airports NPS.

Concerns that there is no central policy on technology likely to be used and as a result it is not clear what the noise effects will be.

✓ Heathrow have been working with industry experts to identify the likely future changes in fleet and technology, and the assumptions that Heathrow have taken from this work will be explained in our Development Consent Order (DCO) application. However, the noise envelope will be the way Heathrow will be able to give certainty to communities about the effects of the airport in the future. The noise envelope will include the noise management controls, the rules we will put in place to use them, the ways we will measure their effectiveness and how we will review them as Heathrow grows. It will be updated regularly (we propose around every 5 years) so that it remains relevant and up to date and takes account of changing technology so that the benefits are shared between communities and industry. The noise envelope will be created in consultation with local communities and stakeholders. Heathrow will continue to seek ways to work with airlines and other partners to make the most of new and quieter technology to reduce our noise impact and how we might incentivise their use.




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Concerns about the effectiveness of new technology against the existing baseline.

✓ Over the last decade there have been improvements in aircraft navigational technology which mean there has been a trend for aircraft to be more concentrated within the specified departure routes. This is a trend that has taken place over time and is something we are likely to see carry on as aircraft technology continues to improve. Moving forward there is an EASA mandate for the introduction of PBN, which is being implemented in the UK under the Government's Airspace Modernisation Strategy. Heathrow are also continuously working hard to reduce the impact of our operations. Our Fly Quiet and Green programme is an example of this. It encourages airlines to use quieter aircraft and to fly them in the quietest possible way. It is the UK's first ever league table which ranks airlines according to their noise and emissions performance. Heathrow also provide a strong financial incentive for airlines to use the quietest planes currently available through the use of variable landing charges. The noise envelope will be the way we will be able to give certainty to communities about the effects of the airport in the future. The noise envelope will include the noise management controls, the rules we will put in place to use them, the ways we will measure their effectiveness and how we will review them as Heathrow grows. It will be updated regularly (we propose around every 5 years) so that it remains relevant and up to date and takes account of changing technology so that the benefits are shared between communities and industry. The noise envelope will be created in consultation with local communities and stakeholders.




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It is not appropriate to increase the number of flights over London and any increase in flights over the Islington Borough would be opposed.

✓ The ANPS requires that (within the context of Government policy on sustainable development) our proposals will avoid significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. In order to meet the requirements of the Airports NPS the expanded airport will provide capacity for at least an additional 260,000 ATMs. The noise envelope we will put forward will include limits to manage the noise impacts of flights while supporting growth over time. The noise envelope will give certainty to communities about the effects of the airport in the future. The noise envelope will include the noise management controls, the rules we will put in place to use them, the ways we will measure their effectiveness and how we will review them as Heathrow grows. It will be updated regularly (we propose around every 5 years) so that it remains relevant and up to date and takes account of changing technology so that the benefits are shared between communities and industry. The noise envelope will be developed in consultation with local communities and stakeholders.

The introduction of electric engines could be a compulsory source of power for aircraft when landing and this would help to mitigate aircraft noise.

✓ Heathrow will continue to seek ways to work with airlines and other partners to make the most of new and quieter technology to reduce our noise impact.

Conditions along the Compton route where larger, heavier aircraft struggle to manoeuvre is a place to minimise disturbance. Despite previous research and a review of procedures, no improvement has been made.

✓ While Heathrow has no control over their aircraft routings, we are currently working with other airports to optimise redesign of SE airspace as directed by FASI-S. One of the aims of FASI-S is to improve efficiency which should result in less interactions between different aircraft routings.




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Until airspace design is agreed it would not be possible for some businesses within the community to define, consult on or agree to the noise envelope.

✓ This current Airspace and Future Operations Consultation is the second of three consultations on airspace change and future operations. The first (Airport Expansion Consultation One) in 2018 was on design principles, this second one is about airspace design envelopes and the third will be about flight path options. Draft flight path options will not be available until the third airspace consultation. This will mean that until then the calculated noise contours must be based on estimated flight tracks such as those used for the Airport Commission. The Airport Expansion Consultation in June 2019 will present early findings of the noise impact assessment, undertaken as part of the EIA, in a Preliminary Environmental Information Report (PEIR). This will be based on estimated flight tracks.

The consultation is unclear on where the noise contours will lie, and which residents will be eligible for noise insulation.

✓

The noise proposals are not quantified and comments can only be provided if a noise footprint for the area is provided.

✓

Agreement for the package of six noise measures and the framework approach proposed was deemed acceptable.


Concerns raised about the increased volume of air traffic.

✓ The Airports NPS requires that (within the context of Government policy on sustainable development) our proposals will avoid significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. In order to meet the requirements of the ANPS the expanded airport will provide capacity for at least an additional 260,000 ATMs. The noise envelope we will put forward will include limits to manage the noise impacts of flights while supporting growth over time. The noise envelope will give certainty to communities about the effects of the airport in the future. The noise envelope will include the noise management controls, the rules we will put in place to use them, the ways we will measure




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their effectiveness and how we will review them as Heathrow grows. It will be updated regularly (we propose around every 5 years) so that it remains relevant and up to date and takes account of changing technology so that the benefits are shared between communities and industry. The noise envelope will be created in consultation with local communities and stakeholders.

Moving the Third Runway and associated taxiways eastward might help reduce noise to the Colnbrook and Poyle areas.

✓ We have noted this feedback and it is being considered in the development of the preferred masterplan for the Heathrow Expansion Project (the Project) Heathrow. The Scheme Development Report published at Consultation One presented the findings of the evaluation process to date. The preference for the Family A option as described in the Scheme Development Report was based on reducing noise impacts on Poyle and Colnbrook while balancing noise impacts to the east. 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.

Heathrow must meet national, EU and International standards as part of the Development Consent Order (Development Consent Order (DCO)) process.

✓ Heathrow’s Development Consent Order (DCO) application will include an assessment of the environmental impacts of our scheme and will set out our package of mitigation measures for construction and operation. Mitigation measures will be identified to mitigate the effects of aircraft noise. The Airports NPS requires that (within the context of Government policy on sustainable development) our proposals will avoid significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission.




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If the proposed western and southern rail links are delivered there would be a beneficial noise reduction across the areas of the Boroughs of Reading and Brent.

✓ 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.

Concerns over increased ground and airborne noise from the third runway operations and the potential for intensified ground noise from re-siting airport maintenance facilities and traffic from airport supporting facilities.

✓ Construction, ground source and road traffic are not a part of the current consultation. In June 2019 we will run our second and statutory consultation on the Development Consent Order (DCO) which will include our Preliminary Environmental Information Report (PEIR) and consideration of these noise sources. Heathrow’s DCO application will include an assessment of the environmental impacts of our scheme and will set out our package of mitigation measures for construction and operation. Mitigation measures will be identified to mitigate the effects of aircraft noise. Elements of the design and layout of the ground-based airport development will be designed to minimise ground noise effects, as far as reasonably practical. For example, taxiway locations, bunding, barriers and landscaping and ground running enclosures and operational procedures controlling engine testing noise which would form part of the Airport Expansion Consultation in June 2019. The expansion proposals may provide opportunities to reduce the effects from existing ground noise and these will be explored as far as practicable. A Code of Construction Practice (CoCP) will form part of the DCO application for expansion. It will set out how construction traffic will be managed to minimise environmental effects. Heathrow’s planning aims to minimise the amount of

Construction noise, ground borne noise and road traffic noise associated with the expansion of the airport must be properly assessed and mitigated as this can significantly affect local communities.

✓

Road traffic noise will be a significant source of increased environmental noise and will require careful assessment and mitigation.

✓

Construction and road traffic noise must be properly assessed and mitigated in the area of Reading. This is an omission from the current scope as the over dependence on cars is already experienced and extends some distance from the airport.

✓




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Concern expressed about construction and increased road traffic noise which will increase during all hours of the day.

✓ construction related traffic on the roads. We will consult on the provisions contained in the CoCP at Expansion Consultation June 2019. The EIA Scoping Report confirms that matters such as the combined and cumulative effects of noise will be assessed as part of the DCO application for expansion. This will include the combination of effects from the Project e.g. combined effects of road traffic noise and aircraft noise and the cumulative effects of the Project and other schemes.

Support for the noise envelope and the proposed measures to address and control noise, especially plans to consider noise caused by road traffic and construction was expressed.

✓

It is recognised that aircraft noise is the key driver for noise insulation, surface access is another source of noise that needs to be addressed as part of the overall cumulative adverse impact.

✓

A general lack of trust was expressed in any new measures and concerns raised that the measures would be ineffective as they did not take noise from construction, road traffic and airport users into account.

✓

Proposals for extensive noise insulation funding are supported and that the appropriate authorities should determine, with Heathrow, the required scale and degree of mitigation.

✓ A comprehensive suite of compensation measures is being developed but these compensation proposals are not a part of the current consultation. In June 2019 we will run our second and statutory Airport Expansion Consultation on the Development Consent Order (DCO) which will include our Preliminary Environmental Information Report (PEIR). The draft proposal will include a property compensation scheme for homeowners living in very close proximity to the expanded airport, who will have the choice to either remain in their home or sell it. We will also have plans for a £700m noise insulation scheme which could include over 160,000 homes and the expansion of our Community Building Noise Insulation Scheme (CBNIS). The threshold

There should be payment for air conditioning as those affected by flights will not be insulated if they open their windows/doors in summer months and that its effectiveness was dependent on the enforcement of the night-time ban.

✓




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A request that sensitive community buildings and schools affected by noise (SOAEL levels above 63 dB LAeq, 16 hours) should be identified and consideration given to relocate them to quieter areas as well provision of noise insulation and ventilation.

✓ noise levels will be defined in the packages and be subject to consultation. We recognise that more detail is needed on the implementation of the Project and we are actively refining our approach. We recognise the need to consider ground noise sources as well as temporary sources associated with the construction phase of the Project. In addition, we also note suggestions regarding the eligibility criteria, phasing, vulnerable groups, product supply and quality, as well as the need to take account of the effectiveness of the Project in addressing noise impacts. We will provide more detail as part of the Airport Expansion Consultation in June 2019.

Noise insulation must happen across a wider area and include all community buildings including schools, colleges, places of worship, hospitals, clinics and other medical centres.

✓ ✓

Concerns in regard to noise insulation expressed about the noise impacts of expansion and the impacts on local communities.

✓

The noise insulation proposed for community buildings within the 60LAeq noise contour should be extended to all businesses within the envelope.

✓

Queries over the suitability of using zones to define eligibility for compensation.

✓

A strong commitment from Heathrow that any newly affected properties will get state-of-the-art noise insulation would be welcomed.

✓

The noise insulation scheme is not “world class” and is less generous than the one offered by Gatwick Airport.

✓ ✓




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Noise insulation is necessary, that the scheme proposed appeared fair, that it was long overdue and that is was needed to keep noise levels down regardless of whether expansion was progressed or not.

✓

The noise insulation scheme proposals should be implemented before any new/additional flights are permitted.

✓

The insulation scheme needs to be extended to include the communities of Hammersmith and Fulham that would be newly overflown for long periods daily.

✓

Mitigation of residual noise impacts was deemed essential but the proposed compensation thresholds do not reflect recent research that shows sensitivity to aircraft noise has increased, with the same percentage of people reporting to be highly annoyed at a level of 54 dB LAeq 16hr as occurred at 57 dB LAeq 16 hr in the past.

✓

Deemed acceptable to prioritise the Phase 1 inner Zone of the compensation proposals following the granting of DCO powers over Phase 2 Outer Zone at the point the airport becomes operational, although hardship cases should be brought forward on their merits. All community building should be included in Phase 1.

✓




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Request to be provided with definitive guidance on which properties will be eligible for what and when.

✓

Views that the proposals are inadequate. The eligibility noise contours are too high and that it would be unlikely that Heathrow could provide insulation to many people for a long time after they experience noise.

✓

Queries about the eligibility criteria for insulation and temporary re-housing during construction. The timeline for insulation of community buildings should be the same as the inner zone.

✓

Heathrow Airport should insulate all properties within the daytime 51dB + LOAEL.

✓

The phasing, extent and threshold for eligibility of the noise insulation package were too high.

✓

All areas affected by noise from Heathrow Airport activities should receive double/triple glazing.

✓

Loft insulation and triple glazed windows would help to reduce noise from aircraft.

✓

All houses within a 10-mile radius should be offered triple-glazing and/or secondary glazing.

✓




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Concerns that the proposals were too restrictive and should cover a wider area, that the proposals do not address open windows and doors, that double-glazing would be ineffective and that there was not enough information to make an informed opinion.

✓

Concerns expressed that the proposals for noise insulation now apply at 60dB’ LAeq, 16hr and that the lower levels of noise annoyance identified within the SoNA report do not seem to have had any impact on the noise trigger level for eligibility for acoustic insulation.

✓

The scheme within the consultation in unfair for residents living to the west of the airport who will have to be exposed to higher long-term noise levels before they qualify for sound insulation compared to those living to the east.

✓

Will the Bracknell Forest area be eligible for compensation for noise exposure?

✓

Concerns expressed that there is no target completion date for insulation for either the Inner Zone or Outer Zone schemes and past poor performance by Heathrow Airport in the delivery of considerably smaller scale insulation schemes was cited.

✓




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Heritage assets should be considered as part of any scheme and should be informed by an assessment of the significance of the building in question rather than as part of a wider, standard scheme.

✓ 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 Project proposals as part of the airspace change process as well as the DCO application. The impacts of aircraft noise on open spaces and tranquillity will be one of several factors that will be considered as part of the development of the airspace design and the siting of flightpaths.

Future policy may require compensation for significantly increased overflights according to local circumstances and a proper assessment must be undertaken.

✓ A comprehensive suite of compensation measures is being developed but these compensation proposals are not a part of the Airspace and Future Operations consultation. In June 2019 we will run our second and statutory Airport Expansion Consultation on the DCO which will include our Preliminary Environmental Information Report (PEIR). Impacts on landscape and townscape amenity will also be considered as part of the Project proposals as part of the airspace change process as well as the DCO application. The impacts of aircraft noise on open spaces and tranquillity will be one of several factors that will be considered as part of the development of the airspace design and the siting of flightpaths. The draft proposal will include a property compensation scheme for homeowners living in very close proximity to the expanded airport, who will have the choice to either remain in their home or sell it. The threshold noise levels will be defined in the packages and be subject to consultation. The Project presents an opportunity for the public transport capacity at Heathrow to be improved and enhanced. This accords with the need to meet the

Elmbridge, Runnymede and Surrey Heath and Spelthorne were identified as areas that could experience significant increases in overflights and noise and should be offered adequate compensation.

✓

Mitigation should include public transport in perpetuity for residents to visit quiet areas.

✓

Residents’ impacts by noise from Heathrow Airport activities should be fairly/properly compensated.

✓

Request for full compensation for anyone affected by noise, regardless if they receive insulation.

✓ ✓




PC MC WC

Concerns that people living nearest to the new runway and new taxiways will receive most of the extra noise. Many of these are on the Toll House Estate in Poyle and will already have had some noise insulation fitted.

✓ passenger mode share targets and colleague car trip reduction targets in the designated Airports National Policy Statement (Airports NPS).

A noise relocation scheme for villages should be targeted to areas where exceedance of the SOAEL is predicted and assurance is requested that the SOAEL will not be exceeded outside of the CPZ and WPOZ.

✓

Concerns over negative impacts on quality of life, health, well-being and local people and communities in relation to the noise insulation scheme.

✓ In our Airport Expansion Consultation in June 2019, we will report preliminary assessments of the likely significant effects of noise on health and quality of life, and of the Project on human health, within the Preliminary Environmental Information Report (PEIR).

Information on noise effects down to 51 dB LAeq 16h should be provided and taken into account in the design of mitigation and noise control measures.

✓

Noise effects from 51 dB LAeq 16h and above should be highlighted and taken into account in the design of mitigation and noise control measures.

✓

Further consideration should be given to natural considerations such as birdsong.

✓




PC MC WC

Concerns raised that the proposals were unrealistic/unachievable, that insulation cannot cover people when outside and that noise insulation was not favoured due to opposition to expansion.

✓ The delivery of the expanded airport will impact on the existing natural environment. 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 (June 2019) will include areas which could be landscaped, planted, restored or enhanced in order to mitigate and off-set the effects of the airport expansion as far as practicable. As part of the development of the Project, 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 working to achieve a net gain in biodiversity. Impacts on landscape and townscape amenity will also be considered as part of the Project proposals as part of the airspace change process as well as the DCO application. The impacts of aircraft noise on open spaces and tranquillity will be one of a number of factors that will be considered as part of the development of the airspace design and the siting of flightpaths. The final airspace designs will be approved by the CAA and ultimately the Secretary of State. This process will ensure that all practical and reasonable steps will be taken to design the airspace around Heathrow to minimise adverse impacts on health and quality of life from noise and where possible, contribute to improvements to health and quality of life. The impacts of noise on landscape amenity (including cumulative impacts) will be assessed in the Preliminary Environmental Information Report (PEIR) and the DCO application as part of a holistic consideration of those factors which influence the perception of landscape character and which make one landscape different from another and includes perceptual aspects such as tranquillity.

Concerns expressed that impacts to public and greenspaces in and around London were not being considered. Respite was requested for greenspaces and for this to be increased during weekends, public holidays, and when daylight hours are at their longest.

✓

Concern expressed about impacts upon the natural environment, open space and its users and asked that this be acknowledged within the noise envelope.

✓

Innovative thinking needs to be applied to reduce noise impact and when find solutions on how the public can enjoy the natural environment near to the airport. The exploration of options for sympathetic landscaping that would reduce decibel levels would be welcomed.

✓

Consideration for users of open spaces where standard approaches to noise insulation are not applicable is needed.

✓ ✓ ✓

Concerns that expansion will further damage the tranquillity of the Surrey Hills AONB.

✓




PC MC WC

Concerns noise issues were not being treated seriously and that insulation does not deal with noise problems in gardens, parks and open spaces.

✓ Heathrow knows that predictable periods of respite are much valued by local communities. As required by the Airports NPS (paragraph 5.61) providing predictable respite through runway alternation is a key component of the Project.

Concerns that there would be greater impacts upon the Surrey Hills AONB and that these would be cumulative with Gatwick.

✓

Noise is a particular concern and an issue that cannot be over-stated. A noise benchmark should be established for the creation of attractive and usable natural areas for public enjoyment and to protect the park as much as possible

✓

Amenity value of public parks and open land has been overlooked in the proposals and a fund should be set up in perpetuity for surrounding London Boroughs to enable them to invest in other public parks in their areas to compensate for the loss of amenity value for their residents.

✓

The provision of double glazing is inadequate as it is not reasonable for residents to stay in-doors to avoid noise.

✓

Regardless of the proposals, increased noise pollution will prevent the local residents of the Bray area from enjoying outside space with ongoing effects on mental health.

✓




PC MC WC

The ‘trade-off’ between increased noise and increased emissions has not been communicated well enough to the residents of Islington.

✓ Our approaches to both noise and emissions were outlined in the Airport Expansion Consultation One in January 2018 and its accompanying documentation. Further detail will be provided in the Airport Expansion Consultation in June 2019 and will include the Preliminary Environmental Information Report (PEIR), which will set out draft assessments of the likely significant effects of noise on health and quality of life, and of the project on human health. Heathrow already has differential charging based on noise and emission criteria and this is something we expect to continue to use to encourage best in class aircraft to operate at Heathrow. We recognise the need to explore further opportunities to drive improvements including the use of incentives. We are currently considering the recommendations made by the CAA in their report “Environmental charging – review of impact of noise and NOx landing charges: update 2017” CAP1576 and expect to respond positively.

Heathrow should encourage other airports to implement a voluntary ban on night flying.

✓ Night flights at the major airports in the SE are regulated by the DfT. Following the Airports NPS, Heathrow’s preferred 6.5-hour night flight ban on scheduled flights would be for the period of 11pm to 5.30am. Other airports have different business models to Heathrow, and must operate within the DfT regulations.

Request for a ban on night flights at Gatwick.

✓ The Airspace and Future Operations consultation relates to the proposals for expansion of Heathrow airport and is not related to the operations of Gatwick Airport.

An independent noise body should be established involving stakeholders from the immediate and wider communities, with independent noise experts from both sides.

✓ The Government has established an Independent Commission on Civil Aviation Noise (ICCAN) and Heathrow will work with this independent noise regulator and envisage that the independent regulator will have a role in the review of the noise envelope and the targets to reduce aircraft noise over time.




PC MC WC

The suggestion of the formation of an independent regulator to set up and enforce targets tied to penalties is supported.

✓

The SOAEL significant observed adverse effect level (SOAEL) should be 63 dB LAeq over 16 hours and the lowest observed adverse effect level (LOAEL) should start at 51 dB LAeq over 16 hours.

✓ Heathrow’s Airport Expansion Consultation in June 2019 will set out draft assessments of the likely significant effects of noise on health and quality of life, and of the project on human health, within the Preliminary Environmental Information Report (PEIR). The effects of the Project from a range of noise sources (including aircraft, road traffic, construction, aircraft-ground noise, and combined noise) will be assessed using the most up-to-date robust evidence for each health and quality of life outcome. LOAEL and SOAEL values for the assessments are set out in the EIA Scoping Report, informed by policy, standards, empirical evidence and guidelines. A scoping report for the EIA and health impact assessment (HIA) for the Project was submitted to the Planning Inspectorate in June 2018 and can be viewed at https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000457-HTHR%20-%20Scoping%20Report%20(Main%20Report).pdf Heathrow’s proposed assessment methods and metrics are described in the EIA Scoping Report (May 2018) which was submitted to the Planning Inspectorate. The Planning Inspectorate has consulted on the proposed assessment methods and provided feedback. This has raised a number of questions and queries that we are working on and can present in the Preliminary Environmental Information Report (PEIR) at the Airport Expansion Consultation in June 2019. As part of this process, Heathrow will continue to engage with the local authorities and other interest groups to agree the assessment methodologies as far as practicable including the Heathrow Strategic Planning Group (HSPG), non-HSPG and the Noise Expert Review Group (NERG).

The need to ensure health impact assessments use the latest peer review evidence and consider compensation for affected residents where airport operations exceed LOAEL levels was highlighted.

✓

A fundamentally different approach to the analysis of noise and pollution impacts is required. It needs to consider how the health and wellbeing of the people is affected.

✓

The new “noise annoyance” benchmark (the 54dB contour) shows that an expanded Heathrow will affect more people than at present.

✓

Noise metrics should be revised to better reflect the impact on people

✓







PC MC WC

The Heath Impact Assessment (HIA) to be reported in the Environmental Statement (ES) will identify and assess the positive and negative health effects of the scheme, reporting on likely significant health effects and the measures taken by the Project to enhance positive health effects and reduce negative health effects. Heathrow’s work has shown that it is possible to affect fewer people than today under all of those scenarios although the exact numbers affected will depend on the final configuration of airspace through the airspace change procedure.

Concern was expressed with the 2014 noise attitudes survey to establish the LOAEL and stated that it would have been greatly enhanced if people living in areas adversely affected at the lower noise levels had been included.

✓ Heathrow’s Airport Expansion Consultation, which is planned for June 2019 will set out draft assessments of the likely significant effects of noise on health and quality of life, and of the project on human health, within the Preliminary Environmental Information Report (PEIR). The best available evidence is considered to include evidence from systematic reviews, as well as individual studies carried out on samples around Heathrow or airports within the UK, as well as internationally important large-scale epidemiological studies. Exposure response functions published in the recent systematic evidence reviews undertaken for the revision of the World Health Organization’s (WHO) Environmental Noise Guidelines (1999) will be considered for use in the assessment, along with recent national publications such as the Survey of Noise Attitudes 2014 and the National Noise Attitude Survey 2012. The ERFs will be used alongside the WebTAG methodology and/or to provide sensitivity analysis, where appropriate.

Recent evidence shows that people are sensitive at a lower level of noise exposure and negative health impacts occur at lower exposure levels than previously thought.

✓

There is evidence that people are now more sensitive to lower levels of aviation noise and health impacts are more severe than previously thought. The level may need to be reduced to the LOAEL of 51 dB LAeq 16hr.

✓

There should be targets to reduce noise to meet World Health Organisation (WHO) guidelines.

✓ The World Health Organisation (WHO) recently published (October 2018) the Environmental Noise Guidelines for the European region and values will be taken into account in the assessment as relevant either in terms of setting screening values or by way of sensitivity tests against the assessment methodology set out in the Scoping Report. However, the WHO Guidelines do




PC MC WC

not take precedence over UK policy requirements for the assessment.

What penalties will be imposed for failure to exceed anticipated noise limits?

Heathrow currently fines aircraft in breach of the departure noise limits and has the power to fine for off track aircraft. Heathrow also operate a differential charging scheme for aircraft operating from Heathrow based on noise and emission criteria. Heathrow also use non-financial techniques to incentivise best practice and this is illustrated by the Fly Quiet and Green Programme. Heathrow support the idea of balancing appropriate penalties and incentives to improve our noise impacts. Heathrow expect to continue to employ a variety of methods and welcome the feedback and ideas suggested within the responses received during Consultation One.

It is thought that a commitment to noise control is vital for local businesses.

✓ The Project is likely to increase the amount of locally collected business rates in the area. The Government will consider how authorities can benefit from this through a business rate retention scheme and the opportunities for authorities to work together to share the benefits. The detailed proposals will also be examined as part of the DCO application process and will be subject to another stage of public consultation.

Some business support expressed for the objectives of the noise envelope and the timeline for its development.

✓

Concerns about the proposed early increase of air traffic movements by 25k per annum in exchange for the early introduction of the night flight cap, as this proposal would negatively impact resilience and early morning flight arrivals.

✓ Heathrow are not currently in a position to consult on the specific proposals for early growth. Our ability to bring forward early growth is dependent upon a range of factors, such as changes in the current airfield infrastructure, revised regulation of airlines slots, as well as other matters which are being consulted on as part of the Airspace and Future Operations Consultation, including in particular:

• the Noise Objective which is established for Heathrow;

• the establishment of required airspace changes relating to the two

Raising the Air Traffic Movement (ATM) cap prior to the third runway should increase

✓




PC MC WC

passenger volumes, reduce charges and allow new entrants and incumbents to apply for slots but it does not accord with the ICAO Balanced Approach and achieving this in advance of new runway capacity is challenging due to the impact on resilience and night flights.

existing runways, for Independent Parallel Approaches (IPA); and

• the detailed terms of a ban on scheduled night flights at Heathrow.

Once Heathrow have considered feedback to the Airspace and Future Operations Consultation, we will be able to test the capacity for and implications of early growth. We will need to consider implications for terminal and stand capacity, environmental impacts, and how additional passengers would be accommodated in our surface access strategy. Our intention is to bring forward proposals for early growth at our next stage of consultation in June. Our proposals for early growth will be submitted as part of our DCO application. These proposals will be examined by the Planning Inspectorate and will need to be approved by the Secretary of State for Transport.

Raising the ATM cap prior to the third runway should increase passenger volumes, reduce charges and allow new entrants and incumbents to apply for slots. However, this does not accord with the ICAO Balanced Approach and achieving this in advance of new runway capacity is challenging due to the impact on resilience and night flights.

✓

Heathrow's noise nuisance is vast and should include all of London and communities within a 30-mile radius.

✓ The proposed study area for the DCO application was set out in our scoping report which can be viewed on the planning inspectorate website. https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000457-HTHR%20-%20Scoping%20Report%20(Main%20Report).pdf We set out our study area for each of the noise sources to be assessed in Section 16.4.5. Based on consideration of today’s operation and our current understanding of the future operation, this results in an area of approximately 40 nautical miles west-east and approximately 20 nautical miles north-south, centred on the airport. If through assessment it is found that the LOAELs extend beyond this area for any indicative airspace design, the study area will be extended accordingly. The Airports National Policy Statement requires that (within the context of Government policy on sustainable development) our proposals will avoid significant adverse impacts on health and quality of life from noise, and also states that our noise mitigation measures should ensure that the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission.




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