Consultation responses submitted in 2018
Date |
Organisation |
Title of Consultation/Presentation |
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7 Dec 2018 |
HoC Climate Change Committee |
Building a Zero Carbon Economy - Call for Evidence |
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9 Nov 2018 |
HAL |
Independent Parallel Approaches (IPA) Heathrow Consultation |
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14 Aug 2018 |
DEFRA |
Clean Air Strategy Consultation |
Economic regulation of capacity expansion at Heathrow: policy update and consultation CAP 1658Consultation from the CAA. This follows on from the June and December consultations that the RHC responded to - 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 Due 29th June 2018 |
RHC ResponseReiterates 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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Heathrow Airport ExpansionThis 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 Due 28th March 2018 |
RHC Response1. 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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Consultation on economic regulation of capacity expansion at Heathrow: policy update and consultation, December 2017 (CAP 1610)Consultation from the CAA. 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 Due 2nd March 2018 |
RHC ResponseWe 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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Mayor of London: London PlanConsultation 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 Due 2nd March 2018 |
RHC ResponseThe 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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Proposed changes to the TfL Ultra Low Emission Zone and Low Emission ZoneConsultation from TfL. The consultation can be found Due 28th February 2018 |
RHC ResponseWe 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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