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Consultation responses submitted in 2017


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)


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 20th 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 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


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