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Consultation 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