CONSULTATION QUESTIONS AND RESPONSES
- Do you agree or disagree with the
proposal that a third runway at
Heathrow, if built, should be supported
by associated passenger terminal
facilities? What are your reasons? Are
there any significant considerations you
believe need to be taken into account?
If so, what are they?
Response:
Disagree.
The principle of the entire proposed development, including the associated passenger terminal, is wrong. It is unsustainable to site a major new runway, its terminal and associated infrastructure within Greater London.
It is not disputed that the environmental impacts associated with the proposed development are very severe particularly in terms of community destruction, noise and air safety risks for hundreds of thousands of residents of London. The impacts associated only with the proposed terminal are also severe. They involve a significant increase in dwellings demolished from around 260 (for the runway itself) to over 700. This requires the total demolition of the community of Sipson and the loss of extensive areas of Green Belt countryside which is highly valued within Greater London.
The SERAS consultation in the lead up to the 2003 Aviation White Paper considered the third runway in comparison with alternative runway options in the South East of England. Given the scale of the changes now proposed including the lengthened runway, the terminal, and extended airfield and ancillary development, a new assessment is required. This would need to compare the radically changed property demolitions and community impacts against those at other locations. The reassessment should also take into account the relevant findings of the ANASE study and accordingly give greater weight to the severe noise impacts of the third runway.
- Do you agree or disagree with the
Government’s view on the continuing
validity of the environmental conditions?
What are your reasons? Are there any
significant considerations you believe
need to be taken into account? If so,
what are they?
Response:
Disagree.
Hillingdon strongly disagrees with the Government’s view on the continuing validity of the noise condition requiring no increase in the size of the 57 dB LAeq, 16h noise contour applying in year 2002. We consider the noise contour limit is neither appropriate nor adequate as a noise control.
The ANASE study recently confirmed that people’s sensitivity to aircraft noise has increased significantly since this was last investigated in the ANIS study 22 years ago. This finding is not disputed. On this basis, there needs to be a reassessment of air noise policy and of the Heathrow expansion noise condition set in the Aviation White Paper. Such a reassessment would inevitably set a more stringent noise condition for any expansion at Heathrow. Also, a new assessment of Heathrow expansion in comparison with other runways in the South East should be undertaken. Given that aircraft noise is a primary issue and that more residents are affected by aircraft noise at Heathrow than other potential runway sites (by a factor of at least 10), it is probable that Heathrow would not be judged the most sustainable option.
Even if a noise contour limit were considered appropriate, we consider it perverse to continue using the contour area from 2002 when the most recent available contour for 2006 has a smaller area. A significant reduction in contour area occurred between 2002 and 2006, largely due to the retirement of Concorde in 2003. This demonstrates that choice of the contour size in year 2002 is artificial and arbitrary.
Hillingdon considers it illogical to use a noise contour from year 2002 to determine expansion issues affecting noise levels over the next 25 years and beyond. The consequence of this is that the government would be denying people the benefits of the large reductions in noise levels which would be delivered by less noisy aircraft if there were no expansion of capacity.
The noise contour limit is not sensitive to a number of important noise issues. It does not cover noise in the night, and does not reflect the benefits of runway alternation. It ignores the noise protection provided by the Cranford agreement. It ignores airport ground noise and road traffic noise. Also, a noise limit in the form of an average mode LAeq,16h noise contour conceals large local noise impacts, such as large increases in aircraft noise in Hillingdon borough with a third runway. Furthermore, the noise contour totally ignores noise impact in areas outside the 57 dB LAeq,16h noise contour. The ANASE study suggests that there is significant community annoyance at lower noise levels, and this is consistent with reports of complaints about aircraft noise from areas outside the 57 dB noise contour.
For the above reasons, the Government is requested to review and revise its aircraft noise policy as matter of urgency.
Hillingdon believe that the DfT is moving the goal posts and not adhering to their own strict environmental test of meeting the EU emission limit levels for air pollution applicable from 2010. This is contrary to all their assertions. The consultation assumes that the UK Government has both applied for, and been granted, a derogation with regards to a 5 year extension to the EU limit. This would grant an extension to the compliance date from 2010 to 2015. Hillingdon believe it is premature to assume this derogation will a) occur and b) be granted. This issue is still at negotiation stage in Europe and the proposal presented suggests that the derogation will only be granted in special circumstances.
Hillingdon contest that the environmental condition that should be adhered to is the EU limit set for annual mean nitrogen dioxide in 2010 and not 2015. The Government has not put any specific plans in place to alleviate residents who will be exposed to levels above the limit in 2010 in areas around the airport even without any airport expansion. It is irresponsible, and could be deemed unlawful, to promote a substantial increase in emissions in an area where the current environmental limit cannot be met even in current conditions. It should be noted that the consultation document clearly states there will still be exceedences in 2015.
- Do you agree or disagree with the
Government’s view on adding a third
runway and being able to meet air
quality limits without further measures?
What are your reasons? Are there any
significant considerations you believe
need to be taken into account? If so,
what are they?
Response:
Disagree.
Scientific evidence has been provided by Hillingdon to show that the Government cannot be confident on this issue. This evidence has demonstrated that although the consultation document advises that there would be no exceedences with a 3rd runway, the margin of error behind these results is very narrow and therefore any confidence is misplaced. Evidence is supplied with the Hillingdon response to show that the air quality model is under-predicting, the assumed downward trend in air quality concentrations over-optimistic and the assumptions and uncertainties used in the modelling have been untested with regard to sensitivity. Examples have been given to show how a small change in an assumption can cause large numbers of properties to fall into areas of non-compliance. The lack of sensitivity testing is in direct contrast to the approach recommended by the Air Quality Technical Panels Report, fails the Government’s own Using Sound Science Responsibly by use of the precautionary approach and is wholly unacceptable given the potential impacts of this scheme.
In addition the key influential inputs on air quality, namely future aircraft fleet and road traffic assumptions, have been provided by the airport operator and Government. Both have failed to provide appropriate evidence that these inputs have been independently verified. Without this assurance Hillingdon is not confident in the forecast air quality outcome. It should be noted that Hillingdon were denied access to these crucial inputs.
No control mechanism is discussed. Without this the Government cannot be confident of future air quality. As the margin of error with regards compliance/non-compliance is so small clear controls should have been identified to allow consultees confidence in the EU limit being maintained. As assumptions have been made on technologies not yet built or in operation then the emphasis is on the Government to prove how this will work in the future.
A third runway must be ruled out on air quality grounds.
- Do you agree or disagree with the
Government’s view that adding a third
runway is achievable within the noise
contour limit of 127 sq km, at the
indicated levels of air traffic? What are
your reasons? Are there any significant
considerations you believe need to be
taken into account? If so, what are they?
Response:
Disagree.
Hillingdon disagrees with the Government’s view that adding a third runway can be achieved within the noise contour limit.
The noise predictions underlying the Government’s view are contained in ERCD report 0705. Predicting noise contours with a third runway in 2020 and 2030 is a complex process relying on a large number of assumptions relating to types of aircraft operating, numbers of movements of each aircraft type, noise emission levels from each type of aircraft, and aircraft flight paths. There will inevitably be errors in these assumptions when made so far into the future. For example, a large proportion of the aircraft types assumed to form part of the fleet mix in 2020 and 2030 are not yet in service, or even in production. It is therefore considered that the replacement programmes for existing aircraft and the level of reduction of noise emissions of future aircraft types are overly optimistic.
We note that the predicted contour areas in 2020 and 2030 are only 0.3 sq km and 14.1 sq km less than the noise condition contour area of 127 sq km. There is evidently no margin for error despite the inherent uncertainties in making the noise predictions. Hillingdon therefore has no confidence that the contour limit will be met. This concern is supported by the information on historical trends in aircraft noise source reduction in the ERCD report. This suggests that the main technological reductions in aircraft source noise levels have already been achieved, and that further technological improvements will only deliver small source noise reductions. For these reasons, Hillingdon is very sceptical that the noise contour limit can be met.
The other considerations we believe should be taken into account relate to the validity and adequacy of the noise contour limit. We have explained these concerns in our answer to question 2. Even if the noise contour limit were met, a third runway would have very serious adverse noise impacts in Hillingdon and other areas newly overflown by aircraft arriving at, and departing from, a third runway. Noise impacts would be worst in Hillingdon because this is where the third runway would be situated. Since the third runway would operate in mixed mode, there would be no noise respite periods (such as can be provided by runway alternation) with either departures or arrivals. Noise from night flights would increase with a third runway, since the ERCD report acknowledges that the third runway would provide an opportunity to increase night flights. Also, according to a supporting NATS report, there would be triple arrival streams in the period 0600 to 0645 hrs. As well as increased air noise, Hillingdon would be adversely affected by new ground noise and road traffic noise sources.
We believe the proposal for a third runway contradicts the Government’s noise policy “to take all practicable steps to prevent any deterioration in the noise climate at Heathrow, and to continue to do everything practicable to improve it over time” (Aviation White Paper, 2003). With a third runway, Hillingdon and many other areas would experience a serious deterioration in nose climate. Also, with the addition of a third runway, the noise climate would not improve over time. The expected reductions in future aircraft source noise levels should not be used to create “headroom” for a third runway. Addition of a third runway would also lead to a breach of the 480,000 ATM limit which the Terminal 5 Inspector considered essential to protect the noise climate.
It is Hillingdon’s case that current noise impacts from Heathrow are unacceptable. The addition of a third runway would seriously worsen the noise impact in Hillingdon and many other areas, resulting in seriously harm to the quality of life of a large number of people.
A third runway must be ruled out on noise grounds.
- &
- Do you agree or disagree with the
Government’s view that mixed mode
operations could be introduced
within the noise limits set out in the
White Paper? What are your reasons?
Are there any significant considerations
you believe need to be taken into
account? If so, what are they?
To what extent would you support the
introduction of mixed mode operations:
a) throughout the day?
b) limited to specific hours (if so,
would you support mixed mode
between 0600 and 1200 hours?
Some other period? (please
specify)
c) within the current planning
cap (i.e. with no extra capacity
overall)?
If you support additional movements,
in what periods of the day do you think
they should be provided?
What are your reasons for these
answers? Are there any significant
considerations you believe need to be
taken into account? If so, what are they?
Please provide evidence where you can
(e.g. environmental impacts, business
benefits).
Response:
Disagree.
Hillingdon disagree with the Government’s view that full mixed mode operations could be introduced within the noise contour limit.
The noise contour predictions for mixed mode operations contained in the consultation document relate to full mixed mode with 540,000 ATMs in years 2015 and 2030. Our answer to question 4 above explains our doubts about the reliability of noise contour predictions projected so far into the future. Our main concern is that the replacement programme for existing aircraft and the level of source noise reduction for future aircraft types are overly optimistic. We also note that the predicted noise contour area for 2015 with full mixed mode is 125.5 sq km, which is only 1.5 sq km within the contour limit area of 127 sq km.
For these reasons, Hillingdon is sceptical that the noise contour limit can be met with full mixed mode operation at 540,000 ATMs. We do, however, accept that mixed mode operation with no increase in aircraft movements may meet the noise contour limit. This is because changing from existing segregated mode operation with alteration on westerlies, to mixed mode operation (without a movements increase), would have relatively minor effects on overall contour area.
The other considerations we believe should be taken into account relate to the validity and adequacy of the noise contour limit. We have explained these concerns in our answer to question 2. Even if the noise contour limit were met, mixed mode operation would have serious adverse noise impacts.
With mixed mode operation, the current half-day noise respite periods provided by runway alternation would be lost. This represents a serious deterioration in the noise climate affecting large populated areas. With mixed mode operation, the Cranford agreement would be ended, and there would be easterly departures from the north runway. We have explained the serious noise impact of such departures in our answer below to question 9. We are strongly of the opinion that noise impacts in Longford and Cranford Cross would be so severe that easterly departures from the north runway must never be permitted. It follows that we consider mixed mode operation involving such departures should also be not be permitted. With mixed mode operation, compliance with Continuous Descent Approach would be greatly reduced, and aircraft approaching the southern runway would be held at a lower altitude.
Hillingdon believe the proposal for mixed mode operations contradict the Government’s noise policy (stated above in our answer to question 4). Thus, introducing mixed mode operation would constitute both a deterioration in noise climate, and would not improve noise climate over time. Full mixed mode operation at 540,000 ATMs would also breach the 480,000 ATMs limit which the Terminal 5 Inspector considered essential to protect the noise climate.
The noise impact with mixed mode throughout the day would constitute a worse noise impact than if limited to specific hours. Similarly, mixed mode operation exceeding the 480,000 ATM limit would have a worse noise impact than mixed mode operation within the ATM limit. Nevertheless, we are totally opposed to the introduction of mixed mode operation, whether it be (a) throughout the day, (b) limited to specific hours, or (c) within the current planning cap. Our main reason is the unacceptable noise impact with easterly departures from the north runway.
- Do you agree or disagree with the
Government’s view that full mixed mode
operations could be introduced by 2015