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A Third Runway at Heathrow?

Heathrow Airport is proposing to expand by adding a third runway. In 2012 the UK Government established its Aviation Commission, led by Sir Howard Davies. The commission’s objective was to consider how the UK could maintain its status as an international hub for aviation, and what immediate actions could be taken to improve the use of existing runway capacity in the next 5 years.

The commission issued its final report in July 2015. The modelling in the report demonstrated that expanding Heathrow would deliver no significant return to the UK’s economy. Instead, Heathrow’s third runway would divert flights and wealth to London at the expense of the rest of the country.

It would reduce growth of the UK’s aviation sector, leave unchanged the growth in UK’s long-haul destinations, and reduce growth in the UK’s short-haul destinations. It would not improve connectivity in terms of number of destinations served from the UK. Instead a new runway would result in higher frequencies of flights to the already most popular routes. Around 50% of the new capacity would be used for International-to-International transfer passengers which are of little or no value to the UK.

Nevertheless, the report’s Executive Summary recommended expansion at Heathrow.

In addition to there being no economic case for a third runway at Heathrow, there are many other reasons why there should not be any further expansion at the airport. These include air pollution, noise, carbon emissions, surface access and traffic/public transport congestion, the likelihood of a large public subsidy being needed, and the suppression of competition from other airports leading to higher costs to airlines and passengers.


Responses to consultations submitted in 2018


Economic regulation of capacity expansion at Heathrow: policy update and consultation CAP 1658

Consultation from the CAA.

This follows on from the June and December consultations that the RHC responded to -
CAP 1610, December 2017
CAP 1541, June 2017

It confirms the CAA’s approach in respect of key elements of the regulatory framework for Heathrow Airport Limited and discusses issues around the relationship between the regulatory framework and alternative delivery mechanisms, the cost of capital, financeability, financial resilience, the regulatory treatment of early construction costs and the further extension of existing price control.

The consultation can be found
on the CAA’s website.

Due 29th June 2018

RHC Response

Reiterates the evidence that DfT and CAA data does not support any economic case for additional runway capacity at Heathrow.

Urges the CAA to focus on passengers arriving and departing from London and not on passengers transiting Heathrow who add negligible economic value.

Quantifies the excess profits made by Heathrow and urges the need to reduce the aero charge at Heathrow, which is one of the highest in the world for a major airport.

For the CAA’s economic assessment to be valid, all costs should be included, including the costs of carbon emissions, surface access, and lowered air quality. Currently they are absent.

The Treasury – and by implication all British taxpayers – are exposed to two major financing risks arising from Heathrow Airports Limited’s excessive debt leverage and the substantial support given to its shareholders in the form interest tax relief.

Heathrow Airport Limited has not provided an adequate assessment of the investment needed for surface access. Substantial public investment of up to £25Bn in public transport capacity and in shifting travellers from road to public transport is missing from the costs and should be included.

The affordability and financeability of Heathrow’s expansion should already have been fully determined at an earlier stage but wasn’t. It needs to be addressed now, not later.

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RHC  response


Heathrow Airport Expansion

This consultation presents Heathrow’s options and proposals to expand and build a new north west runway and requests views to help shape the emerging proposals.

The consultation can be found
on the Heathrow Consultation website.

Due 28th March 2018

RHC Response

1. The options provided are descriptive and not sufficiently developed for objective response. For the most part, it is impossible for individuals or communities to assess the assumptions and decision criteria for choosing between options because the evidence is missing from the consultation and its supporting documents. It is not clear why the proposed options have been selected.

2. The topics are not linked into an overall decision framework making it impossible to discern and balance the priorities and assess the economic and environmental uncertainties and risks.

3. The Consultation fails to establish the strategic need or consequences of expansion and the choice of Heathrow and its hub model. Heathrow’s north-west runway expansion has a substantially negative outcome at UK level, taking passengers from UK regional airports, delivering no additional long haul passengers for the UK as a whole, and principally only benefiting airlines who choose to route transfer passengers through Heathrow

4. The Foreword and Section 1 of the consultation establishes a bias without evidence in favour of a third runway and makes statements that are incomplete, misleading and unsubstantiated.

5. The claims by Heathrow regarding the environmental impact on communities are incomplete or misleading.

6. It is not clear how the results of the consultation will be used by Heathrow.

7. Conditions are vague and provide little assured protection for those potentially harmed by a third runway.

8. The consultation makes no mention of the costs and financial viability of a north-west runway expansion. Responses are likely to be overridden by financeability constraints, potentially making them irrelevant.

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RHC  response


Heathrow Airspace Principles Design

Consultation on the design principles that could be used as the basis for developing Heathrow7rsquo;s future airspace design, and requests views and preferences relating to them.

The consultation can be found
on the Heathrow Consultation website.

Due 28th March 2018

RHC Response

1. The consultation does not make it clear whether it concerns airspace modernisation for a two runway Heathrow or a three runway Heathrow.

2. We believe it is important when designing flight paths to distinguish between communities experiencing reduced and increased noise and not merely to net them off.

3. The options provided in the consultation are descriptive and not sufficiently developed for objective response.

4. The topics are not linked into an overall decision framework making it impossible to discern and balance the priorities and assess the economic and environmental uncertainties and risks.

5. Objectives come before principles but the objectives are missing from the consultation and are in the process of being reviewed for possible change later in 2018.

6. The rate of reduction in noise from source is much slower than it used to be. It will be that much harder to re-structure Heathrow’s flight paths and even more difficult with an increase in flights and noise from a potential third runway.

7. We understand the consultation is being treated as the first portal of the CAA’s airspace change process. There is no statement of need as is required by the change process.

8. The foreword of the consultation establishes a bias without evidence in favour of a third runway. The consultation provides no evidence to support their positive statements, which we believe to be incomplete and misleading.

9. The claims by Heathrow regarding the environmental impact on communities are absent or misleading.

10. It is not clear how the Heathrow will use the results of the consultation. The However, using this serial approach there will be no scope for going back to reconsider earlier decisions.

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RHC  response


Consultation on economic regulation of capacity expansion at Heathrow: policy update and consultation, December 2017 (CAP 1610)

Consultation from the CAA.
This follows on from the June consultation that the RHC responded to - see below.

It confirms the CAA’s approach in respect of key elements of the regulatory framework for Heathrow Airport Limited and discusses issues around the relationship between the regulatory framework and alternative delivery mechanisms, the cost of capital, financeability, financial resilience, the regulatory treatment of early construction costs and the further extension of existing Q6 price control.

The consultation can be found
on the CAA’s website.

Due 2nd March 2018

RHC Response

We broadly support the CAA’s approach to developing the regulatory model of Heathrow to manage the North West Runway expansion. It is key to controlling Heathrow’s monopoly position.

We do not believe the North West Runway expansion can be developed without increasing aero charges, which would be unacceptable to airlines, passengers and the Government. To achieve financeability and breakeven on the North West Runway expansion, Heathrow would need to approximately double existing charges, already the highest in the world for any major airport.

As yet we have not seen estimates of expansion costs including surface access costs that have been reduced sufficiently to ensure financial viability. Over and above this, the CAA should take environmental costs into consideration.

We are not clear that Heathrow’s total £56bn of capital expenditure for the North West Runway and other projects s factored into the CAA’s assessment but we believe it should be.

We reiterate our doubts about the value of International-to-International transfer passengers. We believe that CAA data confirms that very few thin routes have such transfers and 99% of such transfers are on popular daily routes. A large proportion of the increased passengers as a result of a third runway are likely to be International-to-International.

We reiterate that Heathrow cannibalises aviation activity from other UK airports and harms their economic viability. Of the 43 million passengers a year served by the North West Runway, 16 million are additional International-to-International transfers and 27 million are additional UK terminating passengers. But 17 million of these are sourced from reduced growth at other UK airports, resulting in just 10 million net additional UK terminating passengers as a result of building a third Heathrow runway.

It is important that before parliament considers the NPS, the financial viability of Heathrow expansion be properly assessed. If parliament approves the NPS supporting Heathrow expansion it should simultaneously guarantee that the Treasury will not assist the funding of the expansion even as last resort. Not only is this a state aid issue, but Heathrow Airport Limited is a private enterprise and 90% owned by overseas shareholders.

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RHC  response


Mayor of London: London Plan

Consultation from the Mayor of London.

The London Plan covers areas of strategic importance to Greater London:

• promoting economic development and wealth creation in Greater London

• promoting social development in Greater London

• promoting the improvement of the environment in Greater London

The consultation can be found
on the Mayor of London’s website.

Due 2nd March February 2018

RHC Response

The tension between the need for housing and additional flights has to be resolved. Whether this means fewer houses or fewer flights is the issue. Local Authorities cannot deliver enough land to meet housing targets and provide the accompanying schools and infrastructure while still ensuring an acceptable noise environment.

Additionally, it is not clear from the draft plan whether Heathrow expansion is taken into account by the projected housing needs. The Airports Commission recognised that providing the number of houses required and the related infrastructure in the boroughs around Heathrow could be challenging.

We believe that many of the residents of new housing in Greater London will experience significant levels of aircraft noise. This matter needs to be given much greater attention in the London Plan, and needs to be addressed before Heathrow is granted planning permission to expand. The design of flight paths needs to be accelerated to run in parallel with decisions on housing.

Given the intractable problem of housing and aircraft noise we believe serious consideration should be given to not expanding Heathrow.

Finally, we recommend the London Plan extend its consideration of parks and open spaces to include the impact of overhead flight paths taking into account Quiet Areas.

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RHC  response


Proposed changes to the TfL Ultra Low Emission Zone and Low Emission Zone

Consultation from TfL.

The consultation can be found
on TfL’s website.

Due 28th February 2018

RHC Response

We agree with the ULEZ consultation’s premise that poor air quality is causing harm to people’s health and needs to be reduced as soon as possible.

We support the proposed strengthening of LEZ standards for heavy vehicles in the zone that already covers wider London, that is all 33 boroughs and including Heathrow. We propose that this be brought forward by one year to October 2019.

We believe that the ULEZ area for lighter vehicles and cars should expand to cover wider-London and not just the area bounded by the north and south circular roads as proposed by the Mayor. Also, we propose that its expansion be brought forward by one year to October 2020.

We reiterate that there is no credible plan for the investment in surface access to Heathrow in either the two or three runway cases. The negative impact on air quality and comfort and convenience of Londoners and Heathrow passengers will be severe without considerable investment of at least £10 billion in surface access.

We do not believe the introduction will be fast enough to prevent an increase in air pollution in either the two or three runway cases. It is essential that Heathrow’s growth is constrained within a pollution envelope.

We point out that the law does not only require compliance with fixed emission limits. It also requires developments to reduce emissions.

We support the Kew Society’s response to the consultation, which we present as an appendix.

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RHC  response


Revised Draft Airports National Policy Statement (NPS)

Consultation from the Department for Transport on new runway capacity and infrastructure at airports in the South East of England.

The consultation can be found
on the Department for Transport’s website.

Initial deadline 19th December 2017

First Addendum 1st January 2018

Second Addendum 2nd February 2018

Summary of RHC response

1.The Revised Draft NPS fails to assess the need for additional runway capacity notwithstanding that a main purpose of the NPS is to establish need. UK passenger demand can be met to 2050 without additional runways.

2. The Revised Draft NPS fails to address the negative impact of the North West Runway on the UK aviation market and the demand risk. The consequences of the North West Runway for the UK aviation market are dire.

3. The Revised Draft NPS fails to examine the hub activities of Heathrow. Heathrow’s 16 million additional International-to-International transfers a year resulting from the North West Runway are substantially negative for UK aviation.

4. The Revised Draft NPS fails to assess adequately the surface access needed for the North West Runway and who should pay for the additional capacity. The risk is the Government will end up paying heavily.

5. The Revised Draft NPS fails to demonstrate that the environmental impact of the North West Runway can be adequately controlled.

6. The Revised Draft NPS fails to recognise its own estimates of poor economic value when justifying the North West Runway, and overstates the economic value in the first place. The Revised draft NPS estimates the North West Runway economic value ranges between minus £2.2bn and plus £3.3bn. This very poor value is diminished still further to result in an economic loss of between £20bn and £25bn after taking account of overestimates for the value of suppressed demand, International-to-International transfers, and wider economic benefits, and underestimates of surface access, environmental costs, and the accelerated value of unrealistically fast growth.

7. The Revised Draft NPS fails to assess the affordability and financability of the North West Runway and hence the project’s financial deliverability. Regulation is unfit for purpose as demonstrated by Heathrow’s current excess profits and the failure to control costs making it the most expensive airport in the world.

8. The Decision Process is unsound in many substantive ways. The process is not transparent, it is biased and selective in the options and evidence considered. In many important respects is back to front with decisions being made before the evidence is gathered or assessed. It would be unacceptable for necessary conditions to be curtailed so as not to challenge parliament’s decision to support the North West Runway.

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RHC  response
5-page summary)


Responses to consultations submitted in 2017


Draft London Environment Strategy

Consultation from the Mayor of London on the draft London Environment Strategy. This is the first integrated strategy for London, bringing together air quality, green infrastructure, climate change mitigation and energy, waste, adapting to climate change and ambient noise.

The consultation can be found
on the Greater London Authority’s website.

Due 17th November 2017

Summary of RHC response

We find the strategy thorough in scope and approach with the exception of Heathrow. We reiterate the principle that the polluter should pay.

We believe Heathrow has such a major impact on the London environment that there should be a section in the Environment Strategy that more fully deals with Heathrow or defers to some such section in another component part of the emerging London Plan.

We review in detail how Heathrow’s operations add to pollution, and how pollution would increase if a third runway were built.

We urge that the Greater London Authority:

(a) Seek from the Government binding assurance that there will be no Government financial assistance for the expansion of Heathrow whether by guarantee or other means, whether or not this is to mitigate pollution.

(b) Seek from the Government binding assurance that the expansion of Heathrow will not be allowed to increase the emissions and concentrations of NOx and particulates (PM10 and PM2.5) compared not just with today’s levels but future levels.

Pollution has too great an impact on health for there to be any trade off with expansion of Heathrow.

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RHC response


Improving Air Quality

Joint consultation from four parliamentary select committees reviewing evidence on how effective the Government’s plans are for tackling the health and environmental impacts of outdoor air pollution.

The four committees are:
Environment Food and Rural Affairs, Environmental Audit Committee,
Health, and Transport.

The consultation can be found
on Parliament’s website.

Due 9th November 2017

Summary of RHC response

Our principal concern is with Heathrow and the adverse economic and environmental impact of any Heathrow expansion. Our response therefore focusses on the impact Heathrow has on air quality and in particular the NOx pollution from road traffic accessing Heathrow.

We propose that the Air Quality objectives should go further than the statutory threshold and seek to reduce NO2 levels whatever they might be and not just those above the statutory limits.

At present, monitoring locations in the UK are agglomerated. This has the unintended consequence of discouraging the reduction of NOx levels elsewhere within areas where one sensor show a high reading but others may also be over legal limits.

The UK Plan should state meaningful targets for compliance in the shortest possible time. There is no target time-table for compliance by each of the 43 zones.

Heathrow expansion is not considered by the Plan. This omission needs to be rectified.

Delegation of the problem to local authorities may not always work. For example pollution from buses is largely out of the control of Richmond Council. Nor does Richmond Council have significant control of pollution caused by access to Heathrow.

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RHC response


Richmond Air Quality Action Plan

Consultation from the London Borough
of Richmond upon Thames on their
Air Quality Action Plan for 2017 to 2022.

The consultation can be found
via the Citizen Space website.

Due 30th October 2017

Summary of RHC response

We believe that Heathrow expansion has a negative impact on the UK economy, carbon, noise and air quality and accordingly is unjustified on all four counts. Efforts should be made to reduce air pollution as soon as possible and Heathrow should contribute its full share of the mitigation costs and not be allowed to take advantage of any reduction in background emissions and concentrations by slowing the reduction with its own emissions. Heathrow’s full share of the cost of mitigation and residual pollution should be included in the decision on whether or not to expand the airport.

Our response goes into further detail on the points raised in our response to Improving Air Quality - Joint Parliamentary Committees above.

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RHC response


Beyond the Horizon -
The Future of UK Aviation

Department for Transport (DfT) consultation seeking views on the UK’s future national aviation strategy.

The consultation can be found
on the DfT’s website.

Due 13th October 2017

Summary of RHC response

The UK Aviation industry has had its failures as well as its successes. The benefits stated for it are overstated and the harm - for example to the environment - understated. Too many of the objectives for the industry are proposed without critical assessment.

We agree there is a need for a new Aviation Strategy. However, the sequencing of decisions and the gathering of evidence and the public consultation to support these appear haphazard. Moreover, too often decisions appear to be based on political expediency or lobbying from business - for example the Airports Commission’s proposal to expand Heathrow despite its own evidence.

While we do not cover safety in detail, we observe that it is unacceptable that a Safety Case for an expanded Heathrow has not yet been published.

We believe Heathrow’s hub concept is vastly over-rated and that there should be a full review of the pros and cons of the hub system.

We believe Heathrow exhibits market dominance leading to excess profits and inefficient allocation of resources, and that this should be addressed.

There is virtually nothing in the consultation on the essential framework for comparing and reconciling the economic benefits of aviation and its growth with the environmental harm and its reduction. We regard this as a major failing of the consultation.

RHC believes it would be preferable to improve the surface access to London’s five airports rather than spend money on an additional runway.

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RHC response


Mayor’s Draft Transport Strategy

Transport for London consultation seeking views on the draft Mayor’s Transport Strategy. The strategy covers three themes:
   1. Healthy Streets and healthy people
   2. A good public transport experience
   3. New homes and jobs

The consultation can be found
on TfL’s website.

Due 2nd October 2017


We have responded only to those sections that involve Heathrow: policy 20 and proposal 96, which set out the Mayor’s proposed position on the expansion of Heathrow Airport.

Summary of RHC response

We restate the reasons why Heathrow should not be expanded, in the context of the Mayor’s Draft Transport Strategy.

1. CO2 from the use of an additional runway will breach UK Climate Change limits.

2. Substantial capacity at Heathrow could be released by reducing transfers, which contribute very little to the route network or the UK economy.

3. A 3rd runway at Heathrow will take growth from other London airports and from regional airports with a negative impact on the UK aviation market and local economies.

4. A 3rd runway does not increase UK connectivity (number of routes) and in the carbon capped case reduces UK passenger numbers, UK inbound tourism and UK business travel.

5. The expansion of Heathrow will make it even harder (if not impossible) for local authorities to plan additional homes to avoid excessive noise.

6. Heathrow expansion results in a loss to the UK economy of at least £10 billion (NPV) and puts the viability of Heathrow Airport Limited at risk.

7. There should be no support for Heathrow expansion through subsidies, guarantees, contingent liabilities, favourable tax treatment or any other means - especially in relation to surface access. It is a private company, 90% owned by overseas shareholders.

8. There is no credible plan for the investment in surface access required for the existing or an expanded Heathrow. At least £10 billion needs to be spent on improved surface access.

9. Heathrow expansion will inevitably result in more noise. There will be no scope for the community to share the benefits of less noisy aircraft and operational improvements - the aviation industry will take all the benefits.

10. Mitigation of noise and air pollution and investment in surface access would not materially change the overall arguments that a 3rd runway at Heathrow should not be built.

11. We recommend investment for better access to London’s five airports and that the airports should reduce the environmental harm from noise and air pollution. Such a Policy should also contribute to containing aviation carbon and the very significant negative impact it has on climate change.

12. We urge the mayor to include in the Policy a timetable to reduce noise levels from Heathrow to WHO limit levels and to ban scheduled night flights between 11pm and 7am. At the very least there should be no increase in the number of flights in this period.

13. We urge the mayor to include in the Policy a provision that there should be no increase in the number of passengers and staff travelling to/from Heathrow, in order to contain air pollution.

14. Should Heathrow get permission for a 3rd runway, we urge the Mayor to support legally binding conditions to limit and where possible reduce the environmental harm. Also, we urge the mayor to consider how the ICAO Balanced Approach on Land Use planning can be integrated with local authority Local Plans for housing in the boroughs surrounding the airport.

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RHC response


Regulatory framework for capacity expansion at Heathrow (CAP1541)

Civil Aviation Authority (CAA) consultation seeking views on the priorities and timetable for their programme of work on the economic regulation of new capacity at Heathrow.

The consultation can be found
on the CAA’s website.

Due 22nd September 2017

Summary of RHC response

We review the economic processes in Heathrow’s market in detail, including the impact of the CAA’s regulation, and assess that Heathrow Airport Limited is making an excess profit of £300 million per year. Regulation is not preventing this; indeed, it is actually supporting it.

As part of this, Heathrow is not contributing enough to mitigate the environmental costs of its operations - up to £150 million annually. Regulation should better ensure these costs are met in future.

If an additional Heathrow runway is built, we assess that airlines are unlikely to generate a scarcity rent and excess profits. There is no financial capacity within the airlines to absorb higher aero charges from Heathrow and they would have to be passed on to passengers and freight owners.

If there is to be no increase in the aero charge to support a new runway then Heathrow’s shareholders are likely to experience a drop in value of at least £12bn, which approximates most of the debt and equity of Heathrow and clearly is untenable.

To break even on the expansion requires the aero charge to be increased by 38% from first flight in 2026 compared to the charge with no additional runway. We believe a charge of £37.67 per passenger (real 2016 prices) would be unacceptable to airlines and passengers.

Any substantial reduction in capital expenditure in an attempt to address this would likely result in a material reduction in service and inefficient allocation of resources.

We therefore urge the Government to confirm without delay that it will not provide any financial support for Heathrow expansion, including, subsidies, guarantees, contingent liabilities or favourable tax treatment.

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RHC response


Draft Airspace Design Guidance

Civil Aviation Authority (CAA) consultation seeking views on the new guidance that the CAA drafted following consultations in 2016 to support the new airspace change decision-making process.

The consultation can be found
on the CAA’s website.

Due 2nd July 2017

Summary of RHC response

Heathrow must follow a process regulated by the CAA for Permanent Change to ‘Notified’ Airspace Design, that is, lateral structure of flight paths defined as Tier 1. The CAA makes the change decision and includes noise and carbon emissions and safety. Communities are consulted. There is no Guidance yet for Tier 2 and 3 changes, which include vectoring and traffic volumes.

Guidance, as drafted, is not fit for purpose: it omits potentially harmful Tiers 2 and 3 and cannot be scaled up for multiple flight path changes anticipated by airspace modernisation and Heathrow expansion. The CAA is subject to conflicts of interest. The environmental objectives are flawed and Government decisions on expansion will be made before objectives are updated and there is a comprehensive process for airspace change.

Other deficiencies include altitude tests, noise metrics and flight path evaluation process. Choice of design principles and consultation should involve independent bodies and not depend on Heathrow.

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RHC response summary

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RHC answers


Draft Revised UK Air Quality Plan
for Tackling Nitrogen Dioxide

Department for Environment, Food & Rural Affairs (DEFRA) consultation seeking views on a revised UK Plan to reduce levels of nitrogen dioxide around roads within the shortest possible time - the most immediate air quality challenge.

The consultation can be found
on DEFRA’s website.

Due 15th June 2017

Summary of RHC response

The Richmond Heathrow Campaign believes that it is unacceptable that a decision by parliament and government should be made on Heathrow expansion before the air quality issue is addressed.

The draft Plan’s proposed objective is deficient in three areas: thresholds, granularity and uncertainty of future compliance. It is too weak to deal with the NO2 problem, and indeed it has not been possible to establish from the draft Plan the size and nature of the NO2 problem.

It fails to make explicit how mitigation measures will be applied to specific sensitive locations, such as London and the area around Heathrow. It fails to assess the very substantial cost implications of Heathrow’s proposal to mitigate the impact of a third runway on air quality by greatly increasing the use of public transport for accessing the airport.

The Richmond Heathrow Campaign questions whether local authorities could implement the draft Plan’s proposed Clean Air Zones mitigation proposals in practice. Moreover, the RHC doubts whether the use of a Clean Air Zone or speed measures by Highways England could have sufficient impact in countering the increase in surface access NO2 from the expansion of Heathrow.

At a UK level, the draft Plan fails to address the challenge that extra electricity generation to replace fossil fuels used in transportation will be substantial and itself potentially polluting.

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RHC response


UK Airspace Policy Consultation

Department for Transport (DfT) consultation on the processes and policies that will govern the redesign of UK airspace to accommodate increasing demand.

The consultation can be found
on the DfT’s website.

Due 25th May 2017

Summary of RHC response

The DfT seeks modernisation and increased capacity of UK airspace, taking account of safety and harm from noise and carbon emissions.

The Richmond Heathrow Campaign focuses on Heathrow.



Noise Objectives - The National Aviation Policy Framework noise objectives are seriously flawed; unacceptable Airspace Policy is being adopted before objectives are reviewed in 2018.



Noise metrics and limit values are not fit for purpose - Government must clarify legal status of WHO noise guidelines and implement noise reduction plans. RHC proposes a set of flight path metrics.



Airspace Design Principles - RHC’s airspace noise model raises many design issues and major change to legacy airspace structure and use, including concentration, multiple flight paths and respite. Re-distribution of noise plus increased noise energy from larger aircraft and more aircraft from expansion will cause much community conflict across heavily populated London. There is insufficient airspace for expansion.



Balanced Approach to reducing noise - Slow reduction in aircraft noise at source and from operational improvements are likely to be offset by London’s population growth resulting in long-term blight up to at least 30 miles from the airport. There exists no good reason to lift the current operating restriction of 480,000 Heathrow flights a year.



Justification for Airspace Modernisation - Increased headroom between current use and capacity to improve resilience may be justifiable but not increased capacity for more flights.

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RHC response


Draft Airports
National Policy Statement

Department for Transport (DfT) consultation on the Airports National Policy Statement (NPS). The NPS provides the primary basis for decision making on development consent applications for a Northwest Runway at Heathrow Airport.

The NPS will be important for applications for new runway capacity and other airport infrastructure in London and the South East of England.

The consultation can be found
on the DfT’s website.

This consultation and our response to it have been superseded by the Revised Draft Airports National Policy Statement consultation of December 2017 - see above.

Due 25th May 2017

Summary of RHC response

The National Policy Statement (NPS) is pursuant to the Planning Act 2008. It requires approval of Parliament and is the basis for an airport’s application for a Development Consent Order (DCO). The DCO is examined by the Planning Inspectorate and then decided by the Secretary of State in accordance with the NPS. The NPS considers need, specific location and related planning matters.

The Richmond Heathrow Campaign raises 3 procedural objections:



The draft NPS was consulted on before assessments of major issues had been published (e.g. demand forecasts and flight paths) and as a result, parliament will decide the NPS before most of the major issues are properly addressed.



The NPS is based on the Airports Commission’s Final Report (with subsequent revision) but the AC’s recommendation for Heathrow’s Northwest runway (NWR) ignored much of the AC’s own evidence.



The draft NPS and associated consultation are biased towards the Government’s stated preference for the Heathrow North West Runway option.

Regarding specific issues, the Richmond Heathrow Campaign demonstrates that there is absence of need for another runway and there is harm to the UK aviation market from Heathrow expansion. The net present value economic loss to the UK of the Heathrow North West Runway option is likely to exceed £15 billion. The NPS assessment principles are unsatisfactory.

The Richmond Heathrow Campaign challenges:



The surface access modal shift to public transport and lack of capacity to accommodate increased traffic demand and consequential failure to contain nitrogen dioxide pollution.



The availability of finance for Heathrow’s substantial investment.



The impact of the most expensive major airport in the world on passenger affordability.



The Heathrow hub model and the absence of value from international-to-international passenger transfers.

The NPS fails to provide meaningful and enforceable conditions mitigating noise, nitrogen dioxide and carbon emissions. The NPS fails to recognise that the Heathrow expansion may self-destruct because of the many unresolved problems. The ‘Do-Minimum’ option of not adding runway capacity may be the best viable alternative and should not be prematurely dismissed.

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RHC response


Economic Regulation
of the New Runway
and Capacity Expansion
at Heathrow

Civil Aviation Authority (CAA) consultation on the priority issues and timetable for the development of the economic regulatory framework for capacity expansion (3rd runway, terminals and associated infrastructure) at Heathrow airport.

The consultation can be found
on the CAA’s website.

Due 15th March 2017

Summary of RHC response

The Civil Aviation Authority (CAA) regulates Heathrow’s market dominance with the aim of protecting airline customers by capping Heathrow’s charges to the airlines. Customer affordability is balanced with Heathrow’s financability. The CAA uses a Regulated Asset Base (RAB) approach to recover Heathrow’s costs from customers and share the risks among stakeholders. The current 5-year regime expires in 2020. The next regime, “H7” needs to regulate expenditure on expansion and the existing business - hence this review.

Heathrow’s substantial future capital expenditure will result in large increases in charges unless capped, but this may make the proposed expansion unviable.

The Richmond Heathrow Campaign disagrees with the CAA opening premise that there is a need to expand Heathrow. The CAA’s RAB model should:



Take account of all UK users of aviation and not just those using Heathrow.



Discount the value of international-to-international transfers.



Include surface access and environmental costs.



Give greater emphasis to shareholders bearing the risks.



Ensure the tax payer provides no financial support.

The Richmond Heathrow Campaign believes that:



Weaknesses in Heathrow’s current balance sheet should be made good by existing stakeholders.



Substantial investment over the longer term (more than 5 years) needs to be recognised by the RAB model.



TA definitive regulatory model that balances affordability and financability needs to be agreed by the CAA and stakeholders before a decision is made by Government to expand Heathrow.

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RHC response


Letter to the Prime Minister

July 2016


In July 2016, the Richmond Heathrow Campaign wrote to the Prime Minister to draw her attention to the absence of any economic case for expanding Heathrow. You can see this letter by clicking on the image or here.


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RHC letter to the PM, July 2016


Richmond Heathrow Campaign
responses to the Airports Commission

Responses submitted in 2015


Air quality assessment

The call for responses is in the Commission’s Extensive Consultation Documentation.

Due 29th May 2015

Summary of RHC response

Heathrow expansion cannot take place without delaying the time when current air quality limits can be met.

The Government would not be in a position to approve the expansion knowing that it will worsen the degree to which air quality fails to meet quality limits.

The report estimates at least 100,000 people would be affected by a worsening of the air quality resulting from Heathrow expansion.

Mitigation can generally be bought but the question is whether it can be afforded at the cost of £20bn estimated by TfL.

The Supreme Court’s recent decision on setting a timetable by the end of 2015 for compliance on air quality as soon as possible is likely to require firm action. Expanding Heathrow under these circumstances seems wildly optimistic and we believe undeliverable.

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RHC response


Increasing the UK’s
long-term aviation capacity

The call for responses is in the Commission’s Extensive Consultation Documentation.

Due 3rd February 2015

Summary of RHC response

Increased runway capacity at Heathrow does not add value to the wider UK economy.

Re-distributing passengers and flights from the regions results in economic dis-benefits.

Noise costs are substantial, impacting 1.5 million people based on WHO standard levels.

The value of international transfers is substantially overstated and with it the single airport hub concept.

A dispersed model that makes best use of all five London airports without any new runways is the best solution.

Building a new runway will need massive public subsidy.

There is still substantial uncertainty regarding the impact of carbon emissions, air pollution and surface access congestion.

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RHC response

Responses submitted in 2013 and 2014


Davies: Criteria for identifying the most plausible Long Term Options

The call for suggestions is in Paragraph 1.19 on page 10 of the Commission’s Guidance Document 01.

Due 15th March 2013

Summary of RHC response

Proposals should be considered on their merits and not who submitted them. Proposals should be considered both in isolation and in combination with other proposals. Criteria should also include political considerations, how proposals meet key end objectives, which market forces could aid or impede delivery, and their effect on competition between airports and airlines.

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RHC response 1


Davies: Discussion Paper 01: Aviation Demand Forecasting

The call for suggestions is in Discussion Paper 01: Aviation Demand Forecasting.

Due 15th March 2013

Summary of RHC response

We agree that the present number of passengers at London airports is likely to increase in the period to 2050 but we do not agree that the DfT forecasts constitute proof that the development of an additional runway or runways in the London area is the only feasible response.

An alternative option, at lower financial and environmental cost than additional runways and terminals, may be to carry larger numbers of passengers per aircraft within the existing runway limits.

We have concerns over the assumed benefit of transfers and hence the so called hub concept.

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RHC response 2


Davies: Expressions of Intent in Developing Proposals
for Airport Capacity in the Longer Term

The call for views and evidence is
in Paragraph 3.13 on page 15
of the Commission’s Guidance Document 01.

Due 28th February 2013

Summary of RHC response

The Richmond Heathrow Campaign expresses its intent to submit by 19 July 2013 proposals for airport capacity in the longer term. We point out that there are four options for handling the additional passenger numbers:
  1. More intensive use of existing runways
  2. Additional runways
  3. Increased proportion of seats filled per flight
  4. Increased average number of seats per aircraft

The public debate about short and medium term passenger capacity has been dominated so far by the first option, and that for long term capacity by the second option.

We consider that it is time for the third and fourth options of increasing the number of passengers per flight to be given equal consideration and to reverse the strategy of attracting ever-more transfers to Heathrow.

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RHC response 3
See also 9. below which represents our full response.


Davies: Discussion Paper 02: Aviation Connectivity and the Economy

The call for suggestions is in Discussion paper 02: Aviation Connectivity and the Economy.

Due 22nd April 2013

Summary of RHC response

Our wide-ranging response covers many issues related to connectivity. London’s international connectivity surpasses other European countries on most counts. We offer criteria by which the connectivity profile of individual airports should be assessed.

We point out that the signs are that aviation does not grow faster than the economy as a whole and therefore does not contribute more to growth than the average non-aviation sector.

We observe that the transfer market has become over-inflated, mainly in response to airline strategies rather than passenger preference. In the capacity debate, particularly at the so-called hub airports, the arguably excessive number of transfer passengers has itself contributed to congestion problems.

We note the substantial potential for new routes contained in the recent DfT passenger demand forecasts that could potentially serve the relatively small proportion of long-haul business passengers at UK airports.

We believe the markets should be the principle drivers in creating economic value. Where policy can help is to reduce or remove barriers and imperfections in the markets e.g. runway slot allocation and use, taxes on aviation, and surface transport capacity. We believe that providing an airport with four or more runways, would unduly concentrate the airport and airline markets so that connectivity would be determined by interests of a handful of key players.

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RHC response 4


Davies: Discussion Paper 03: Aviation and Climate Change

The call for suggestions is in Discussion paper 03: Aviation and Climate Change.

Due 17th May 2013

Summary of RHC response

We ask the Airports Commission to consider what the future impact of aviation would be on climate change if, instead of the projected increase in the number of aircraft movements in order to carry the projected increase in the number of passengers, there were to be a proportionate increase in the number of passengers carried per aircraft movement (either with an increased proportion of seats filled per flight or an increased average number of seats per aircraft), with a relatively small increase in the total number of movements compared with today.

Intuitively, we believe that fewer aircraft movements than are projected should mean less fuel consumption overall (even if the individual movements consume more fuel on account of the increased passenger loads). and this should feed through into fewer CO2 and other emissions.

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RHC response 5


Davies: Proposals for best use in the Short & Medium Term of Existing Capacity

The call for suggestions is in Paragraph 2.5 on page 12 of the Commission’s Guidance Document 01.

Due 17th May 2013

Summary of RHC response

We submit three separate but mutually supporting proposals for the better use of Heathrow capacity in the short and medium term while delivering an overall improvement to the local noise climate:

1. More even distribution of aircraft movements across each hour of the day at Heathrow, in order to avoid disruption and delay in peak hours and to end night flights.

2. Increase the seating capacity of the Heathrow air fleet (i.e. more larger aircraft and fewer small aircraft), in order to increase the number of passengers per aircraft movement within the 480,000 movements limit operating in unbroken segregated mode.

3. Reverse the strategy of attracting ever more transfer passengers to Heathrow, in order to free up terminal and aircraft capacity for more terminating passengers within the legal limit of 480,000 movements limit operating in unbroken segregated mode.

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RHC response 6


Davies: Discussion Paper 04: Airport Operational Models

The call for suggestions is in Discussion paper 04: Airport Operational Models.

Due 11th July 2013

Summary of RHC response

A hub airport can be described as one in which a sizeable proportion of the passengers are transfers. Our case is that international transfers are not needed as an ever increasing number of passengers at a single airport.

Instead the issue is how might the existing capacity of London’s five airports and regional airports best share in growing point-to-point demand which is broadly the dispersed model described by the Commission’s Paper and the one we support.

A reduction of international transfers at Heathrow would free up capacity for growth in local demand and connectivity and we submit that this is one of several reasons that no new runways are needed until at least 2050 and possibly beyond.

Therefore, concentrating demand growth at a single hub airport is not justified either by there being unmet demand or by the need for transfer aggregation.

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RHC response 7


Davies: Outline proposals for Long term Additional Capacity

The call for suggestions is in Paragraph 3.7 on page 15 of the Commission’s Guidance Document 01.

Due 19th July 2013

Summary of RHC response

The DfT’s forecast states that for unconstrained demand will exceed capacity by 95 million passengers per year in South East England by 2050.

1. We propose that passenger demand will continue to be inflated by aviation’s exemption from fuel duty and VAT on tickets. We estimate that a fairer level of aviation taxation would slow the rate of growth in passenger numbers by at least 95 million per year in the South East.

2. We propose that the DfT forecasts are unrealistic in assuming that the present 3::2 split between the number of passengers in the South East and other UK regions will remain unchanged through to 2050. We estimate that a more even 1::1 split would reduce the surplus demand in the South East from 95 million to 44 million passengers per year.

3. We propose that limited expansion of terminal capacity by 15 million passengers at Heathrow and by 15 million in total at Gatwick, Stansted, Luton and London City would enable an additional 30 million passengers to be handled per year, to be carried by increasing the number of passengers per aircraft movement, and reducing the surplus demand in the South East from 44 million to 14 million.

4. We propose that the growth in passenger demand be met with a London Dispersed Airport Structure without a hub airport. Reducing international transfers at Heathrow would release capacity for around 35 million terminating passengers per year. The proposal includes re-distribution of demand between the five main South East airports so as to better balance demand with existing capacity without the need for additional runways.

In summary, either the first proposal on its own or the other three proposals together would entirely remove the forecast surplus passenger demand in the South East. The Airports Commission therefore have two options for addressing surplus demand that do not involve the development of additional runways at Heathrow or anywhere else in South East England.

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RHC response 8


Davies: Discussion Paper 05:
Aviation Noise

The call for suggestions is in Discussion Paper 05: Aviation Noise.

Due 6th September 2013

Summary of RHC response

1. Existing aircraft noise associated with Heathrow significantly breaches World Health Organisation (WHO) guideline limits. Targets and a timetable should be set to bring aircraft noise within these guidelines.

2. Noise contours and population numbers effected are based on averages: we see this as deficient. We suggest some new metrics to reduce the averaging effect and facilitate assessment of impact and respite.

3. Night Noise. The next 5 Year Night Flight Regime should commit to a phased extension of a no flight period resulting over time in a total ban on night flights between 11pm and 7am.

4. A doubling of passengers by 2050 will require noise per passenger to be halved just to avoid an increase in noise let alone an advance towards WHO guideline limits. We recommend fewer flights with higher loads and larger aircraft.

In April 2013 we also responded to the consultation on Night Flights. Further information and our response are on our consultations page.

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RHC response 9


Airports Commission:
Appraisal Framework Consultation

Appraisal Framework Consultation Web Page

Airports Commission Consultation Document
Due 28th February 2014
Noise is covered in Chapter 5, pages 55-63.

Summary of RHC response

We recommend the Appraisal Framework should be based on a reduction in noise that satisfies both current NPF objectives and the WHO Standards, whichever is the lower.

We recommend that the Appraisal Framework provide for the sharing of the noise benefits of quieter aircraft between the aviation industry and the community.

We oppose the Commission’s recommendation of Early Morning Smoothing.

We recommend that the Appraisal Framework should include an objective to comply with EU limits on air quality.

We question whether the UK Aviation’s projected carbon emissions of 25% of the national quota in 2050 are sustainable without a significant negative impact on the rest of the UK’s economy.

We recommend that there should be a gradual replacement of international transfers at Heathrow with local demand. London is the hub, not Heathrow.

We suggest the meaning of the term “do-minimum” is not sufficiently clear in the Draft Appraisal Framework. The lack of well-defined “do-minimum” options may compromise the evaluation process.

We question the financial viability of any new runway requiring large state subsidies to keep down ticket prices and increase the rate of return for private investors.

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RHC response 10


Davies: Discussion Paper 06:
Use of the UK’s existing airport capacity

The call for evidence is in Discussion Paper 06: Utilisation of the UK’s Existing Airport Capacity.

Due 25th July 2014

Summary of RHC response

1. Our analysis indicates that by 2050, passenger demand in the regions will have shifted from the post-recession 3:2 split in favour of the South East to an even 1:1 split between the South East and the other regions.

2. Increased runway capacity in the South East would be contrary to shifting the balance of the UK’s economic growth to the regions.

3. We have already submitted evidence that increasing the proportion of Heathrow transfer passengers reduces the number of destinations served. Reducing this proportion could make it possible for 35 million more passengers per year to fly to and from London.

4. Meanwhile, the proportion of domestic transfers at Heathrow has decreased as regional airports offer direct long-haul services.

5. The value of international transfers to the UK economy is overstated.

6. We refer to reports by the RSPB and WWF that point out that even with just one additional runway in the South East, it may not be possible to meet UK carbon emissions targets.

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RHC response 11


Davies: Discussion Paper 07:
Delivery of new runway capacity

The call for evidence is in Discussion Paper 07: Delivery of new runway capacity.

Due 15th August 2014

Summary of RHC response

We believe that two specific aspects of the National Planning Policy Framework issued by the Department of Communities and Local Government (March 2012) should be prioritised by the Commission:

a. “Encouragement should be given to solutions which support reduction in greenhouse emissions and reduce congestion” (para. 30),
b. “Planning policies and decisions should aim to:
i. Avoid noise from giving rise to significant adverse impacts on health and quality of life...”

Since many past promises made by the aviation industry and politicians on the subject of Heathrow have been broken, we urge legally binding permissions and enforcement of environmental and other conditions with proportionate penalties.

The Government should formulate plans to meet statutory obligations - for example, on compliance with EU air pollution and WHO noise targets - that currently it is failing to meet. It must do this before any decision is made on airport expansion.

Improvements to other unacceptable outcomes need to be implemented by the state, and before a decision on expansion is taken – for example surface access congestion.

If any decision on a third runway at Heathrow fails to rule out a fourth runway in the strongest legal terms then it is essential the full consequences of a fourth runway be included as part of the third runway proposal and appraisal.

Those communities newly affected by noise should have the right to redress through civil action and/or through their council’s environmental provision and not have the rights on this matter waived as they have been by successive aviation Acts since 1922 when aviation was on a wholly different scale to the present.

The detailed parameters where legally binding commitments from airports and airlines are needed should be identified and formal commitments should be part of any recommendation by the Airports Commission.

Kew Gardens is a World Heritage Site and the Government has signed up to various concordats regarding such sites: we expect these to be complied with.

We do not believe the consequences for other airports in the South East and the regions and non-aviation sectors of the economy have been examined sufficiently for the Commission to conclude that the climate change statutory requirement will be met without undue harm. We believe this examination needs to be completed before any recommendation is made by the Commission.

We cannot see how the Treasury can justify additional multi-billion pound public funding of aviation, especially for new runways where 85% of the capacity on such routes will be used by UK resident leisure travellers who are likely to be the better off and who generate a sizable balance of payments deficit when travelling overseas.

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RHC response 12