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Rule out expansion options on air quality grounds: our response to the Airports Commission

29th May, 2015

In our response to the Airports Commission’s air quality consultation, we argue that the evidence produced by the Commission suggests all expansion options should be ruled out on air quality grounds.

The Commission’s consultation contained the results of dispersal modelling, the Defra PCM Model, and revised figures for costs and total emissions.

We go into detail about how we reached our conclusions and the concerns we have about the assessment in our full response.

To summarise, we argue:

  • Air pollution would increase for tens of thousands of people around Heathrow or Gatwick (and for over one hundred thousand people in one Heathrow scenario) leading to associated health impacts. The Commission’s new assessment significantly revised up the costs it associated with air pollution to a total of over £1 billion for Heathrow expansion. These costs would be borne by the communities around the airports.
  • All options would worsen air quality, which is contrary to sustainable development as outlined in the European Ambient Air Quality Directive and the UK’s national planning policy.
  • Unmitigated Heathrow expansion would worsen air quality in an area that is already above the EU legal limit, contrary to the Supreme Court ruling that air quality needs to be reduced urgently to achieve EU legal limits ‘as soon as possible’. It also fails the Airports Commission’s air quality objective.
  • It is not clear how effective the proposed mitigation options could be, particularly Heathrow’s plan to build a new runway without adding any cars to the road. The consultation document comments that “it is not clear whether that (the surface access plan) is deliverable.
  • Gatwick expansion would pose a “high” risk of breaching the legal limit on air quality and the area would have the highest pollution in the South East air quality zone.

We conclude that as long as doubt exists about whether expansion is compatible with legal and health based limits, all expansion proposals should be ruled out.

Other respondents to the Commission’s consultation, including those concerned about Heathrow and Gatwick expansion have outlined that the Commission’s modelling is likely to underestimate background emissions through not taking into account underlying population growth and the additional number of journeys being made if all of the jobs associated with expansion materialised.

Download: Aviation Environment Federation Consultation Response to the Airports Commission

Image Credit: Bev Norton via Flickr