HM Treasury Consultation on Aviation Tax Reform
The Richmond Heathrow Campaign responds
The Richmond Heathrow Campaign calls for aviation to be taxed at the same level as other sectors of the economy, and for carbon quotas at individual UK airports.
You can read a two-page summary of our response, plus the full response we submitted to the Treasury, at this link, or by clicking on the image on the right.
2021 Night Flights Consultation Stage 1A
The Richmond Heathrow Campaign (RHC) responds
The Richmond Heathrow Campaign calls for a total ban on Heathrow air traffic
Normally around sixteen large passenger aircraft land at Heathrow in the early hours of the morning between 4:30am and 6:00am. For the past year this number has reduced to just three or four. The improvement to life in Richmond and Kew has been substantial: far less disturbance to the last hours of sleep. Not since the Icelandic volcano ash air closures in 2010 have early mornings here been so peaceful.
There is no reason why arrivals need to be scheduled so early. All are from airports that also have flights landing at Heathrow later in the morning. Other major airports from the same parts of the world do not have night time arrivals into London. Night flights do not enhance Heathrow connectivity: night flight international transfer passengers are not essential to the viability of onward flights. Night flights add no clear economic value. There would be no economic cost to the UK if all night flights were re-timed to the day and in this are included unscheduled late running flights after 11pm and unscheduled early arrivals before 7am. That night flights persist reflects of a mixture of convenience for the airlines and organisational inertia.
The Department for Transport consults on night flying restrictions every five years. This time the consultation process has two purposes: the first to seek views on the next shortened regime 2022-2024, and the second to present proposals and ask for detailed suggestions on night flight policy after 2024. The first part closed on 3 March 2021 and our response is summarised here with the full document available by clicking here or on the image.
The second part of this year’s consultation closes on 31 May 2021 and will be followed by a further consultation in 2022. Our first response also includes much of the material for this longer-term policy consultation.
In our response, we made the case that the current reduced number of flights each night should not be increased, and that a total ban on Heathrow air traffic between 11:00pm and 7:00am (except for dispensed flights) should be introduced in stages and completed by October 2024.
In the meantime starting with the regime in 2022, all unscheduled flights between 11pm and 7am, other than the few dispensations, should be banned and scheduled flights using the more noisy types of aircraft should also be banned.
In the wider context of aircraft noise policy, day and night, RHC proposed:
Our response covers these key proposals, and includes the detailed technical information that supports them. It also sets out several other important recommendations that are needed to make them happen.
The campaign to end the misery of night flights over Richmond and Kew has been long, but there are solid grounds for optimism. For example, the 2015 Airports Commission recommended a ban on all scheduled night flights between 11:30 pm and 6:30am, all be it in exchange for airport expansion. And overall, growing awareness of the overall environmental impact of aviation is driving more complete analyses of the wider costs and impact of flying.
Our proposal for banning all night flights from 11:00 pm to 7:00 pm is therefore becoming increasingly achievable, and we shall continue to pursue it.
Heathrow’s expansion is lawful says the Supreme Court
... but it is still a Pipe Dream
Wednesday 16th December 2020
The Supreme Court today upheld Heathrow’s appeal and concluded that the Transport Secretary was entitled in 2018 to ignore the UK’s climate change commitments under the 2015 Paris Agreement on Climate Change and that the decision to progress Heathrow’s expansion to the planning stage is lawful.
There were always major gaps in the arguments for Heathrow’s third runway and the world has changed so much since 2018, not least because of Covid-19. Climate change is the greatest risk to aviation growth and last week the Climate Change Committee’s 6th Carbon Budget emphasised no net increase in UK airport capacity and that an increase at one airport means a reduction elsewhere - in other words levelling down the regions. Bio-fuels and carbon removal from the atmosphere are only partial solutions and demand will have to be constrained to achieve aviation’s net zero carbon.
If Heathrow still wants a 3rd runway it will have to restart the already delayed planning process with diminishing chance of success. The pandemic has highlighted Heathrow’s lack of financial resilience and the improbability of raising finance for a very expensive expansion in the face of growth constrained by climate risk. Heathrow should not waste billions of pounds on ill-judged expansion. Shareholders are unlikely to want to dilute a steady cash flow with the poor return from risky expansion without tax payer support.
Heathrow should give up its impossible ambition and focus on making Heathrow a better airport and re-enforcing London as the best served city in the world with its five airports.
Better surface access, more passengers per flight and replacement of international-to-international transfer passengers with UK passengers would be a good start. Reducing carbon, air pollution and noise, including no night flights, are crucial. It would be of great benefit to the UK generally for the recovery and subsequent expansion of air traffic to be shared across UK airports, instead of concentrated at Heathrow, thereby levelling up regional jobs and economies and better serving demand and world-wide access.
More than two million people, including Richmond and Kew residents, are exposed to Heathrow’s aircraft noise and attendant health risk but worse still they have experienced the threat of expansion for over a decade. Heathrow and the government should abandon a further decade of expansion and flight path uncertainty and focus on reducing existing noise misery. Residents now know how much better life can be without aircraft noise.
One certainty is the opposition to Heathrow’s expansion from community groups, NGOs and local councils is stronger today than ever with the environment playing a much bigger part in society’s goals. Richmond Heathrow Campaign will continue to ensure that Heathrow’s expansion remains a pipe dream.
Richmond Heathrow Campaign represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green, and the Kew Society, which together have over 2000 members.
Or at least not on the basis of the Government’s Davies Commission’s
on which the decision to go ahead was based.
Its summary recommended a third runway at Heathrow.
But here’s what’s inside the report itself:
1. A 3rd Runway would just move flights into the South-East from the rest of the UK.
A 3rd Runway would add 41 million passengers per year in the over-heated South-East but take away 58 million from airports outside the South-East.
So where’s the benefit? And how is this compatible with the Northern Powerhouse?
2. A 3rd Runway would shrink the UK aviation sector and reduce UK connectivity.
The number of UK passengers per year would decrease by 4%. For the UK as a whole, the numbers of long-haul, short-haul, and domestic destinations would stay the same or reduce.
How is this “... maintaining the UK’s status as an international hub for aviation”?
3. International transfers would take up most new capacity, delivering negligible value.
Over 50% of the new capacity would be used for an extra 22 million International to International transfers, delivering little benefit to the UK as these passengers don’t step outside the airport.
How does this add value to the UK?
4. The investment offers no compelling return.
The proposed investment of £17 billion would result in a net present value over 60 years
of £1.4 billion. That’s well within the margin of error.
And the benefit may even be negative once full allowance
for noise, air pollution
and the £20 billion that TfL estimate for new transport links is included.
What kind of value is this?
Air pollution: Exhaust pollution from traffic travelling to and from Heathrow is already killing people. Existing airport operations already result in a breach of legal air pollution limits. It seems unlikely that a third runway could be operated while remaining within the law.
Noise: Heathrow noise levels already breach World Health Organisation guidelines and affect far more people than any other airport in Europe. A third runway would expose several hundred thousand more to aircraft noise for the first time.
Carbon: Heathrow’s growth would be constrained by limits on carbon emissions: there simply won’t be enough headroom or affordable carbon credits for a third runway to operate.
Surface access: Transport for London (TfL) has stated that up to £20 billion will be needed to provide surface transportation for a third runway. The alternative would be more crowded trains, more road congestion, and even more dangerous air pollution.
Public subsidy: The Government would need to commit to commit tens of billions of pounds of grants and loan guarantees to cover airport expansion and the supporting surface transport infrastructure.
Competition: It would entrench Heathrow’s dominance of UK intercontinental flights and put at risk the quality of service that air travellers experience.
Opposition to a 3rd Runway at Heathrow is overwhelming
Over 70% of people in Richmond and Hounslow are against a 3rd runway at Heathrow.
Even British Airways is against a 3rd runway at Heathrow.
It’s mainly the
foreign owners of Heathrow
who want a 3rd runway.
The Richmond Heathrow Campaign’s view is that expected future passenger demand can be met by substantially reducing transfers at Heathrow – most of which neither increase the number of destinations served nor benefit the wider economy – and with predicted higher occupancy and larger aircraft. No additional runways need be built.
In particular, we are opposed to any expansion at Heathrow. This would increase noise misery for many in West London and blight new areas of the city. Instead, Heathrow’s operations should be managed to meet existing national and international public health and noise guidelines. This includes the abolition of all night flights.