AEF response to the Airports Commission consultation: gaping holes conceal potential environmental disaster
‘Gaping holes‘ still remain in the analysis on a new South East runway. That is the overall message we set out in our response to the Airports Commission’s final consultation. However, even before this work is completed, it is clear from what has been presented by the Airports Commission that expanding Heathrow or Gatwick could be an environmental disaster.
We are calling on the Airports Commission to publish any outstanding analysis for public scrutiny before it submits its final report to the next Government and to clarify how the appraisals it has carried out of expanding Heathrow or Gatwick will inform its final recommendations.
Our conclusions from the analysis presented so far by the Airports Commission
Economic impacts are highly uncertain
The direct economic impacts calculated by the Commission, which include monetised costs, range from substantially positive to marginally positive for Gatwick and even negative for the two Heathrow options – a very different picture from the figures the Commission has sometimes quoted relating to large but speculative indirect economic benefits.
None of the scheme proposals would be compatible with the Climate Change Act
Emissions forecasts for each scheme proposal overshoot the aviation carbon target unless new policies, which are left unspecified, are introduced to cut emissions.
Each would worsen air quality and threaten breaching legal limits
For all shortlisted options, expansion would have an adverse to significantly adverse impact on air quality. However, the Airports Commission is yet to carry out detailed local air quality modelling, making it impossible to understand whether or not expansion would breach legal limits and how effective mitigation measures would be. The Commission should undertake this modelling as soon as possible, and the assumptions it makes in its modelling should be open for public scrutiny.
None would reduce noise to levels safe for human health
The Airports Commission should model future noise exposure at the levels which pose risks to health according to guidance by the World Health Organisation. The Commission should also make clear the population that would be newly exposed to noise by each scheme and provide reasoning for the assumptions used of future fleet mix and flight paths, and details of the sensitivity of the results to these assumptions.
Each would negatively affect tranquility and character of places around the airports
Despite concluding that tranquility would be negatively impacted for all three options, Jacobs, the consultancy which carried out the place assessment, says it has made no effort to quantify the associated impacts on people and landscape. The Commission should address this gap in time for its final report.
Noise is the key issue for quality of life
The analysis carried out by PWC focuses on aircraft noise as an issue, saying it is negatively associated with all subjective wellbeing measures. However, the Airports Commission’s summary of this work reports only the finding that quality of life impacts from airports are currently broadly neutral at a local level. This glosses over the potential extent of disturbance that could be brought by a new runway, given the increasing number of people whose lives are seriously affected by aircraft noise.
Significant gaps remain in the Airports Commission’s analysis of environmental, social and economic impacts
Our guidance document and consultation response both set out in detail the work that we believe is essential to complete before any decision on runway capacity is taken. This includes incorporating the costs of reducing emissions in economic analysis, present public safety zones following expansion, and undertaking health impact assessments.
Additional information is also provided in our response guidance, available here.
Our press release is available here.