The NPS for Heathrow expansion: a brief tour
One of the many aviation documents published by Government on 2nd February was the Draft National Policy Statement (NPS) for Airports, which represents the next step in the delivery of a new runway at Heathrow. The statement sets out:
- the need for additional airport capacity in the south-east of England
- why government believes that need is best met by a north-west runway at Heathrow Airport
- the specific requirements that the application for a new north-west runway will need to meet to gain development consent, including; pollution, climate change, habitats, health, good design, cost
The public has until 25th May to respond to a consultation on the draft document and its various associated papers. An official period of parliamentary scrutiny runs from now until the summer recess (21st July) after which comment will be invited from the Transport Committee (a parliamentary committee that has historically been strongly supportive of expansion). A final NPS will then be prepared and put to Parliament for a vote. On the assumption that the vote is in favour, the NPS will be ‘designated’ and there will then be a six week period in which judicial reviews (such as the case being prepared by four London councils together with Greenpeace) can be brought. If it survived legal challenge, Heathrow Airport would then be invited to submit an application for a Development Consent Order from the Planning Inspectorate, with the NPS being the primary policy document that the Inspectorate would need to implement.
What, then, are the ‘specific requirements’ on the environment that the Government says would need to be met in order for Heathrow to gain consent? We consider 3 key areas below.
What the NPS says about air quality
Air quality impacts have in the past represented a significant legal obstacle to Heathrow expansion and they seem set to do so again. A DfT spokesperson, quoted recently in the press, said “The Government believes that the Heathrow Northwest Runway scheme can be delivered without impacting on the UK’s compliance with air quality limit values”. The last time a third runway was on the table, the issue was about whether the Government had fudged the figures on air pollution to try to make the runway fit. But this time around, any belief that everything will be OK isn’t even supported by the Government’s own evidence.
Any confusion is, perhaps, unsurprising. The ground is, after all, constantly shifting when it comes to air quality, with Government plans to comply with legal limits repeatedly being ruled by the courts to be inadequate. The Airports Commission’s analysis found that roads near Heathrow would be well over legal limits when the airport opened and that expansion would make this worse. But in 2015 the Government published a new air quality plan, as demanded by the Supreme Court, indicating that London would be compliant with limit values by 2025. Under this new plan, the Government’s consultants argued, the opening of a third runway after or between 2025 and 2030 would not impact on compliance. Job done?
Well no. Following revelations that some diesel vehicles were emitting six times more NOx than the test limit, Europe published updated ‘emissions factors’ to account for likely emissions in real world conditions. Using these new figures, the Government’s consultants have found, even if all currently envisaged policy measures were implemented, NO2 emissions will in fact still be in breach of the legal limit in 2025, with Heathrow expansion likely to worsen that exceedance.
Over-optimistic modelling assumptions were one reason why the 2015 air quality plan has, meanwhile, again been thrown out by the courts. The Government has until July to try to figure out plausible measures to get air pollution under control. Pausing the Heathrow expansion project would seem a pretty obvious first step.
What about the longer term future? The current analysis indicates that by 2030 emissions should have fallen to within legal limits. And there it ends; there is no NO2 modelling beyond that date. But the runway is not forecast to be at capacity in terms of aircraft movements until 2040, and passenger numbers are expected to continue growing even beyond that. The air pollution impacts of this growth haven’t been considered.
What the NPS says about noise
The Government makes a big deal about its various proposed measures for noise mitigation. But aside from the fact that none will bring noise levels down to anywhere near the level recommended by the World Health Organisation, many are problematic and misleading.
Key measures include:
- A six and a half hour night flight ban for scheduled flights.
For those communities who have been suffering from night noise for decades and who have campaigned relentlessly for a night flight ban this will feel like a step forward. But 6 and a half hours is a long way short of the 8 recommended by WHO, and a proposed curfew for ‘scheduled’ flights doesn’t prevent late-running flights from being pushed into the night period, or from being scheduled in the late evening and early morning, times when some people find their sleep is most likely to be disrupted.
- The introduction of a “legally binding” noise envelope
While this may sound powerful, the detail of how it will work is left for Heathrow itself to work out, with the danger being that the airport only commits to noise limits that are easy to achieve. Defining limits in a way that actually benefits local communities, while adding 260,000 more aircraft to the local skies, will be a challenge. While the 57 Leq noise ‘footprint’ of the airport has, for example, been reducing over time as a result of the introduction of quieter aircraft, there is no evidence that there has been a commensurate fall in noise annoyance. In fact annoyance from aircraft noise at a national level has been increasing.
- The provision of predictable periods of respite from noise.
Providing more reliable respite periods had been cited by the Airports Commission, without much explanation, as a possible benefit to communities from expansion. But the Government specifies that predictability should be afforded only “to the extent that this is within the applicant’s control”, and noise respite will in fact be less on average with an expanded airport than is the case today.
And climate change?
“Heathrow Airport will need to take ambitious measures to limit carbon emissions from its scheme”, the Government says, such as using locally sourced materials during runway construction and using low-emission vehicles on-site. Unfortunately, as noted by the Appraisal of Sustainability, while carbon emissions from the airport arise both from ground-based sources and aircraft, the aircraft emissions make up over 97% of the total associated with the new runway over the 60 year appraisal period.
The Government is, as ever, imposing no conditions whatsoever on emissions from aircraft and plans to delay writing its policy on aviation’s climate change impacts until it has the NPS all sewn up. Can’t let those CO2 emissions get in the way of a good runway.
What about other impacts of expansion?
The Government continues to claim that a new runway is justified in terms of its economic benefits, despite the fact that the Airports Commission’s original claim of £211 billion, a figure still quoted by Heathrow, was later cut to £147 billion, and the Government has slashed this to £61 (over a sixty year period) in the NPS papers. Other relevant impacts of expansion identified in the sustainability appraisal include: community, quality of life, biodiversity, soil, water, resources, historic environment and landscape. The likely impacts, allowing for planned mitigation measures, are colour-coded in Table 6-1 (p65). Judge for yourself.