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Heathrow opens Public Consultation on proposed third runway

25th January, 2018

Why are they consulting?

Before it can proceed with construction, Heathrow needs to submit an application to the Planning Inspectorate for a Development Consent Order (DCO). This can only happen once Parliament has approved the National Policy Statement which is currently expected to be voted on by MPs in the second quarter of this year. If it is approved, and it remains a big if, it is likely that Heathrow will submit its DCO application in early 2020. Heathrow’s public consultation lasts for 10 weeks and seeks to inform that final application by asking the public and stakeholders for their views on options and possible mitigation, including:

  • Three options for the new northwest runway, with length varying from 3,200 to 3,500 metres;
  • Potential locations to expand terminal infrastructure: east of Terminal 2, west of Terminal 5, or a new satellite terminal next to the new runway;
  • Proposed alignment of the M25: repositioning it approximately 150 metres to the west, lowering it by seven metres in a tunnel, and raising the runway height so it passes over the M25.

The airport is also asking for the public to review its plans to manage the effects of expansion on local communities and the environment.

On noise

Heathrow’s goal: to expand its airport while affecting fewer people with noise compared to the number currently affected

What does it propose?

NOISE ENVELOPE (‘A package of measures used to reduce noise’): to form a Noise Envelope Design Group (NEDG), made up of community members, stakeholders and noise experts) to define and implement a noise envelope.

RESPITE: to provide predictable respite from noise through the design of flightpaths (addressed in Airspace Principles Consultation).


  • ‘Inner Zone’: to provide full acoustic insulation for residential properties within the 60dB LAeq noise contour of an expanded airport;
  • Outer Zone’: contribution of up to £3000 for noise insulation of residential properties within 57dB LAeq or 55dB Lden noise contours of the expanded airport;
  • Community buildings: noise insulation and ventilation for community buildings within the 60 LAeq noise contour.

NIGHT FLIGHTS: six and a half hour night flight ban between the hours of 11pm and 7am. Heathrow expresses a preference for between 11pm and 5.30am.

On air quality

Heathrow’s goal: to play its part in improving local air quality and managing emissions from airport-related sources

What does it propose?

TRIPLE LOCK GUARANTEE to (1) meet its existing commitment to target no increase in the amount of airport-related vehicles and by supporting improved surface access (2) ensure further measures are ready to be introduced, if required, to reduce road journeys and encourage more sustainable forms of travel (3) guarantee new capacity will only be released when it is clear the airport’s contribution will not delay the UK’s compliance with EU air quality limits.

PRELIMINARY ENVIRONMENTAL INFORMATION provided at Consultation 2 which will begin the process of fully assessing environmental effects, including air quality, and will also include initial information on necessary mitigation.

LOW EMISSIONS DESIGN: positioning of realigned roads, layout of airfield and provision of flight facilities to reduce potential for emissions from traffic and aircraft to affect local air quality.

MANAGING AIR QUALITY DURING CONSTRUCTION through use of low emission construction vehicles, use of logistics hubs to combine deliveries and reduce number of individual vehicle trips, moving bulk materials by rail rather than road, and managing and coordinating traffic and workforce travel.

MANAGING AIR QUALITY DURING OPERATION through incentivising use of cleaner aircraft, more efficient operation of aircraft on the ground, and emissions-based charge for vehicles accessing the airport to encourage use of cleanest vehicles, sustainable and public transport modes.

On climate change

Heathrow’s goal: to ensure growth from the new runway, including flights, is carbon neutral.

What does it propose?

LOW CARBON DESIGN: to reduce potential taxiing distances and allow aircraft to taxi using only one engine, installing electric vehicle charging points and promoting and better integrating the airport with low carbon public transport.

LOW CARBON CONSTRUCTION AND MATERIALS: measures will be put in place to manage carbon emissions associated with construction, including minimising resources and use of off-site fabrication, construction and logistics hubs.

LOW CARBON OPERATIONS: Heathrow’s target is to operate a zero-carbon airport infrastructure (buildings and other fixed assets) by 2050.

To meet this target, the airport proposes to:

  • Use modern energy efficiency measures in new infrastructure;
  • Improve energy efficiency of existing buildings, assets, and other infrastructure;
  • Maximise use of renewable energy from on-site or local sources;
  • Purchase renewable energy from off-site sources;
  • Invest in low emissions vehicles and implement procedures to reduce aircraft taxiing; and
  • Develop an approach to offsetting carbon.

There is also proposed mitigation on the natural and historic environment.

AEF’s view

Heathrow’s consultation largely reiterates previous commitments, while many of the proposed mitigation measures have yet to be defined or elaborated upon.

On noise, the proposed ban is six and a half hours, with flights occurring before 6am. This falls short of the eight-hour sleep target recommended by the WHO and allows flights during the most sensitive period in terms of sleep disturbance. Meanwhile, the noise envelope, respite plans, and flight path locations remain unclear.

On air quality, the consultation includes a binding commitment that new capacity at an expanded airport will only be released when it is clear that the airport’s contribution will not delay the UK’s compliance with EU air quality limits. However, it uses the Airport Commission’s misleading framing of the objective (i.e. not delaying compliance as opposed to not worsening an existing breach, allowing Heathrow to be in breach as long as other areas of London are also above legal levels). Mitigation measures will not be proposed until the second consultation and the airport only commits to playing a part in improving air quality, reinforcing AEF’s view that the Government needs to demonstrate whether and how expansion at the airport can be compliant.

Finally, on climate, the airport’s goal remains an aspiration, which relies largely on ICAO’s offsetting measure to meet its carbon neutral runway ambition. This does not address the bigger challenge of whether the Government can develop an effective climate plan to show how expansion, when combined with forecast emissions from other UK airports, can remain within the Committee on Climate Change’s recommended planning assumption of 37.5Mt CO2 by 2050.

At the same time, Heathrow has also published a consultation on the principles to apply to future airspace design with a third runway. This includes asking respondents whether they have a preference for concentrating flight paths over the fewest number of people or dispersing them over a wider area, if reducing noise should be a higher priority than reducing emissions, as well as asking for feedback on how to treat newly overflown communities, open spaces and rural areas.

Should the NPS be approved by Parliament in the summer, Heathrow plans to issue a second consultation early next year revealing the areas that could be impacted by new or revised flightpaths following the application of the design principles on which it is currently consulting.

Both consultations remain open until 11.55pm on 28 March 2018. Responses can be made here.