Heathrow Airport Third Runway Submission to the Environmental Audit Committee

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1 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 1

2 The Airports Commission Report: Carbon emissions, air quality and noise inquiry Contents The Airports Commission Report: Carbon emissions, air quality and noise inquiry... 1 Executive summary... 3 Carbon emissions... 3 Air quality... 4 Noise Introduction The EAC inquiry Our response to the inquiry The role of the Airports Commission The Airports Commission s recommendations The Government s commitments and policies Overarching policies... 8 National Planning Policy Framework (NPPF) (March 2012)... 8 Aviation Policy Framework (APF) (March 2013) Carbon emissions Air quality Noise Question 1: Are the indicative policies and proposed mitigations set out in the Airports Commission's recommended option realistic and achievable? Carbon emissions Committee on Climate Change Sustainable Aviation Department of Energy and Climate Change Carbon pricing Negotiation and implementation of trading mechanisms Air quality Compliance with Air Quality Standards and EU limit values Mitigation measures Noise Better than today Noise insulation and compensation schemes Heathrow Airport Limited 2015 HAL Submission to the EAC Page 1

3 Predictable and reliable respite Collaborating and working together Noise envelope Aviation noise levy Night flight ban Question 2: What the implications of adopting or not adopting those policies and mitigations are for wider Government policy? Carbon emissions Air quality Noise Question 3: Do realistic and achievable alternatives to those policies and mitigations exist, should the Government adopt the recommended option? Carbon emissions Air quality Noise To minimise and where possible reduce noise impacts Respite and airspace design options Noise envelope Insulation and compensation Community Engagement Board and Independent Aviation Noise Authority Ban on all scheduled night flights in the period 23:30 to 06: Aviation noise levy Question 4: What steps should the Government take in these areas to reach its decision in a way that is consistent with its commitments on sustainable development? Carbon emissions Air quality Noise Summary Heathrow Airport Limited 2015 HAL Submission to the EAC Page 2

4 This written submission is being made by Heathrow Airport Limited. As the promoter of the scheme selected by the Airports Commission, we are pleased to support the inquiry being taken forward by the Environmental Audit Committee. Executive summary E.S.1 On 1 st July 2015, the Airports Commission unequivocally concluded that a third runway should be built at Heathrow to the north west of the existing airport. A formal announcement from Government in response to the Commission s recommendation is expected in the autumn of E.S.2 In contrast to the proposal for expansion at Heathrow that was rejected in 2010, we have gone back to the drawing board, designed a completely new approach and put forward a number of new measures designed to minimise and mitigate the impact of the proposed runway. This new approach to Heathrow expansion features a full-length runway further to the west than the existing two. This design will maximise the level of noise respite that can be provided to local communities and limit its noise impacts. The surface access strategy for the airport will also ensure that there are no more airport-related vehicles on the road than there are today, which will help us to play our part in ensuring that air quality limits are not exceeded. E.S.3 Combined with measures to further enhance the way that the airport engages with its nearby communities and to establish an unprecedented long-term funding stream to address local impacts, this is a radically improved plan and one which is fundamentally different from any previous attempt to expand at Heathrow Airport. It generates significant benefits for the UK as a whole and is fair and deliverable, balancing the needs of the airport s users with the concerns of those living nearby. Heathrow is an industry leader in sustainability, managing noise and emissions, and we were recently named the ACI Europe 2015 Eco-innovator, from amongst all European airports. 1 E.S.4 The Commission s final recommendation follows three years of extensive consultation, evidence gathering and analysis. It recognises the unique role that Heathrow plays as Britain s only hub airport. The Commission finds that Heathrow expansion is the only solution which can help British businesses compete for global growth, and support a truly national recovery built on exports, skills and investment. E.S.5 The headline benefits of Heathrow expansion are: Up to 211bn economic benefits and 180,000 new jobs; Creation of up to 40 new long-haul connections to emerging growth markets; Double the freight capacity; Links to 16 regional airports, up from 7 today; Increased competition and choice for passengers; At least 200,000 fewer people affected by significant noise. The Commission thoroughly reviewed our proposals, tested them and found them to be credible. Carbon emissions E.S.6 We welcome the Commission s confirmation that a third runway at Heathrow is compatible with the UK government s target of 37.5MtCO2 emissions from aviation by This aligns with the opinion of the independent Committee on Climate Change which has confirmed a 60% growth in passengers is consistent with meeting the UK s climate change targets. E.S.7 The Commission also pointed out the benefit of Heathrow s location in terms of low emissions: 1 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 3

5 Heathrow s location and its much greater public-transport connectivity (both locally and to the country as a whole) makes it the most efficient location in terms of carbon emissions due to surface access. 2 We look forward to supporting the aviation industry and Government to achieve the required emissions reductions as we develop our expansion plan. Air quality E.S.8 We are pleased that the recommendation from the Airports Commission builds upon their detailed analysis of local air quality and clearly confirms that our North West Runway (NWR) scheme can be delivered within statutory air quality limits. We are confident that we can deliver emissions reductions that surpass the conservative calculations prepared by the Commission which will enable us to clearly forecast air quality levels which will not delay the timeline for UK compliance with the Air Quality Directive. It is significant that by far the greatest contribution to local air pollution in the Heathrow area arises from non-airport related road traffic. Coordinated and meaningful action is needed from Government and City Hall within the framework of an integrated transport strategy to get cleaner vehicles on to major roads and motorways across London and the South East and give more people an alternative to cars. We look forward to working closely together with national and regional government, industry and business to help accelerate the timeline for the UK s compliance as much as possible. Noise E.S.9 We welcome the Commission s finding that an expanded Heathrow can be better than today. This outcome was also identified by us in our own technical assessment 3. The Commission s findings confirm that a bigger Heathrow would not inflict noise nuisance on more people than the airport does today 4 which complies fully with the Government s overall noise policy objective. E.S.10 The Commission set out a number of conditions in relation to noise in recommending Heathrow: Predictable and reliable respite; Clear noise performance targets (noise envelope) agreed with local stakeholders; Scheduled ban on all night flights night flight 23:30-06:00; A National Independent Aviation Noise Authority (IANA); Community Engagement Board (CEB) to be established but not to replace HACC or existing forums and a remit to give more equal representation to communities; and Establish a UK Noise Levy to add funds on top of our 1bn commitments proportionate to impact. E.S.11 We recognise the intent behind these conditions. Some, such as reliable respite, represent proposals we have advocated ourselves. Others, such as an Independent Noise Authority, are proposals that we have previously supported in principle, though they are the responsibility of Government to deliver and require further discussion and consultation. Others, such as a ban on night flights, represent a significant change from the way the airport operates today, which brings community benefits but significant economic costs too. We continue to study the detail of the Commission s conditions in consultation with our stakeholders and we comment on them individually in the subsequent sections. We are confident that a package of measures can be agreed that meets the needs of Government policy, local communities, the airport, airlines and those who benefit from Heathrow Airport for employment, business and travel. E.S.12 If the Government decides that Heathrow should have a third runway we will do all we can to ensure that an application for planning consent is submitted in time to enable a positive decision within the current Parliament (i.e. by May 2020). If a positive decision is made, it is currently unknown whether the Government s preferred consenting route would be through a National Policy Statement and Development Consent Order (DCO) or 2 Airports Commission Final Report, Executive Summary, p4 3 Heathrow Airport Limited, Heathrow s North-West Runway Air and Ground Noise Assessment, June Airports Commission Final Report, Foreword, July 2015 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 4

6 through a Hybrid Bill which is considered by a government-appointed select committee before final approval by Parliament through primary legislation. Our preferred consenting mechanism is a DCO and therefore in this document we refer throughout to the DCO process when referring to future actions and safeguards, but the same safeguards could be in place if the Hybrid Bill route were adopted. Moreover where we have referred below to the expected content of an NPS, similar policy commitments could just as easily accompany the promotion of a Hybrid Bill even though not in a document formally termed an NPS. E.S.13 In this report we look at the indicative policies and mitigations that are part of the Airports Commission s recommendation for a third runway at Heathrow. Expansion at Heathrow will give the airport the ability to act as a catalyst for environmental innovation and to fast track research and development. Heathrow already hosts the world s largest single site employee car share scheme, has the UK s only free airport public transport travel zone, the busiest bus and coach station in the UK and has the UK s first publicly accessible hydrogen refuelling site. E.S.14 The Airports Commission was established with cross-party support for its membership and terms of reference. It has gathered expert advice and spent 30 months and 20m to unanimously and unambiguously conclude that a third runway can be built at Heathrow while reducing the airport's noise impacts, meeting carbon targets and complying with air quality limits. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 5

7 1. Introduction This document has been prepared as part of Heathrow Airport Limited s (Heathrow s) September 2015 submission to the Environmental Audit Committee (EAC) The EAC is conducting an inquiry into the implications for Government commitments on carbon emissions, air quality and noise should the Airports Commission's (AC s) recommendation of a third runway at Heathrow Airport be adopted Here we look at the indicative policies and mitigations that are part of the Airports Commission s recommendation for a third runway at Heathrow and we explain why we consider that they are realistic, achievable and entirely consistent with the Government s own policies and commitments The EAC inquiry While the Airports Commission s recommendation was made taking full account of the need to ensure compliance with Government policy and meeting Government commitments, critics of airport expansion have, nonetheless, raised concerns about whether the proposed mitigation that formed part of that decision is realistic and deliverable. The EAC is, therefore, examining the Airports Commission s assessment of these issues in order to inform the debate about the future of aviation in the South East The Terms of Reference of the EAC inquiry have posed four questions: 1. Whether the indicative policies and proposed mitigations set out in the Airports Commission's recommended option are realistic and achievable. 2. What the implications of adopting or not adopting those policies and mitigations are for wider Government policy. 3. Whether realistic and achievable alternatives to those policies and mitigations exist, should the Government adopt the recommended option. 4. What steps the Government should take in these areas to reach its decision in a way that is consistent with its commitments on sustainable development Our response to the inquiry We are pleased to have the opportunity to provide our views on these matters In this document we present Heathrow s response on the topics of carbon, air quality and noise to the questions posed by the EAC. We start in Section 2 by describing our understanding of the Government s policy and commitments in more detail. Sections 3-6 respond to each of the questions in turn. We explain why we consider that expansion at Heathrow Airport is indeed possible while meeting the UK s binding commitments on air pollution and climate change and its policies for sustainable development In this section we look at the role of the Airports Commission and the indicative policies and mitigations that are part of the Airports Commission s recommendation for a third runway at Heathrow The role of the Airports Commission In September 2012, the Government announced the creation of an independent Airports Commission, which was tasked with making recommendations to the Government for maintaining the UK s status as an international hub for aviation. At the end of 2013, in its interim report, the Airports Commission recommended that at least one new runway was needed in the South East of England before 2030, at either Heathrow or Gatwick. Three options (two at Heathrow and one at Gatwick), were invited and then presented to the Airports Commission for more detailed consideration. On 1 st July 2015, the Airports Commission unanimously concluded Heathrow Airport Limited 2015 HAL Submission to the EAC Page 6

8 that a third runway should be built at Heathrow to the north west of the existing airport. A formal announcement from Government in response to the Airports Commission s recommendation is expected in Autumn The Airports Commission, chaired by Sir Howard Davies was tasked with producing: An Interim Report - published in December 2013, setting out the nature, scale and timing of steps needed to maintain the UK s global hub status alongside recommendations for making better use of the UK s existing runway capacity over the next five years; and A Final Report - by the summer of 2015 setting out recommendations on how to meet any need for additional airport capacity in the longer term The approach followed by the Airports Commission was integrated as well as open, transparent and collaborative It was integrated in considering a range of economic, social and environmental factors, those that affect how much and what sort of airport capacity is needed in the UK. It was open through engaging extensively with a broad range of interested parties through formal consultations at various stages, public evidence sessions, a programme of meetings and visits and a series of discussion papers on key topics. The final report was published along with a full set of supporting technical appendices. This openness to challenge and the transparent approach taken can give the EAC, and the Government, confidence that the recommendations in the Airports Commission s Final Report are robust and deliverable The Airports Commission s recommendations In the Airports Commission Final Report (ACFR) 5 on airport capacity, the Airports Commission unequivocally recommended the building of a third runway to the northwest of Heathrow Airport, subject to a series of policies and mitigations to reduce the impact of a third runway on the local environment and communities The Airports Commission s report also included a series of specific conditions covering (in relation the issues of interest to the EAC) noise and air quality (pp10-11 ACFR) We continue to study the detail of the Commission s conditions in consultation with our stakeholders. We are confident that a package of measures can be agreed that meets the needs of Government policy, local communities, the airport, airlines and those who benefit from Heathrow Airport for employment, business and travel In respect of carbon emissions, the Airports Commission assessed the runway options alongside the Committee on Climate Change s (CCC s) planning assumption that aviation should not exceed 2005 levels of carbon dioxide (CO2) by The Airports Commission drew up an indicative set of policies that would allow the CCC s assumption to be met, including a carbon price of 334 per tonne by 2050 in the carbon-capped scenario (assuming no international system for internationally trading emissions). 5 Airports Commission: Final Report (ACFR), July 2015, ISBN: Heathrow Airport Limited 2015 HAL Submission to the EAC Page 7

9 2. The Government s commitments and policies 2.1. Overarching policies An Inquiry into the implications of the Airports Commission s recommendation for the Government s commitments on carbon emissions, air quality and noise must necessarily start with an understanding of those commitments and policies. This section therefore briefly sets out those policies. Compliance against the policies is then addressed in Section 3 of our submission. National Planning Policy Framework (NPPF) (March 2012) Government planning policy on sustainability and other issues is set out in the National Planning Policy Framework (NPPF) 6. The NPPF provides an up-to-date framework within which the Government expects planning decisions to be taken and explains at paragraph 6 that the purpose of the planning system is to contribute to the achievement of sustainable development The NPPF reminds us of the UN General Assembly (resolution 42/187) definition of sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs The UK Sustainable Development Strategy Securing the Future set out five guiding principles of sustainable development: living within the planet s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly The NPPF advises that there are three dimensions to sustainable development: economic, social and environmental and that these are closely related. The NPPF explains how these principles should be applied in planning policy and decision making. It sets out a presumption in favour of sustainable development which is seen as a golden thread running through both plan-making and decision-taking. Paragraph 14 of the NPPF explains that: for plan-making policies should seek to meet development needs; and for decision-taking, there is a presumption that planning permission should be granted In both cases this is to be the case unless the adverse effects of doing so would significantly and demonstrably outweigh the benefits. In other words, Government policy is that a positive approach should be taken to decision-making with the presumption that identified needs should be met and that planning decision makers have a role in helping to facilitate development. The NPPF makes clear that economic growth is necessary for a sustainable future The NPPF lists core planning principles which underpin plan-making and decision making and include principles relating to the three dimensions of sustainable development. These include that planning decisions should: proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth; support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy); 6 National Planning Policy Framework (NPPF), March 2012, Department for Communities and Local Government, ISBN: NPPF, p2 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 8

10 contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework To give effect to this approach, paragraph 19 of the NPPF makes clear that: The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system Paragraph 20 confirms that, to help to achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21 st century, while paragraph 21 emphasises that planning policies should seek to recognise and address barriers to investment. This would include, for instance, adopting policies and supporting measures to mitigate impacts so that development can be enabled to proceed, rather than seeking to prevent economic development We examine the detailed NPPF policies with respect to carbon, air quality and noise below. Aviation Policy Framework (APF) (March 2013) The Aviation Policy Framework (APF) 8 then applies the Government s overall policy approach set out in the NPPF to sustainable development of the aviation industry. The APF is a high level strategy setting out the Government s overall objectives for aviation and the policies it will use to achieve those objectives Paragraph 5 of the APF states the primacy of long-term economic growth: The Government s primary objective is to achieve long-term economic growth. The aviation sector is a major contributor to the economy and we support its growth within a framework which maintains a balance between the benefits of aviation and its costs, particularly its contribution to climate change and noise. It is equally important that the aviation industry has confidence that the framework is sufficiently stable to underpin long-term planning and investment in aircraft and infrastructure Paragraph 9 reminds us of the importance of air connectivity and states: One of our main objectives is to ensure that the UK s air links continue to make it one of the best connected countries in the world. This includes increasing our links to emerging markets so that the UK can compete successfully for economic opportunities. This should be done in a balanced way, consistent with the high-level policies set out in this document and acknowledging Government s commitment to economic growth Within this overall context, the NPPF and APF set out specific policies in relation to the areas currently being considered by the EAC, in order to ensure that the Government s approach to sustainable development will be applied consistently with its commitments to environmental protection Carbon emissions The achievement of a low carbon future including mitigation and adaptation to climate change is a central theme of the NPPF and a principal driver of the presumption in favour of sustainable development. Paragraph 18 of the NPPF states that the Government is committed to securing economic growth in order to create jobs and prosperity, building on the country s inherent strengths, and meeting the twin challenges of global competition and of a low carbon future. Growth can enable the prosperity and investment necessary to meet the 8 Aviation Policy Framework (APF), Presented to Parliament by the Secretary of State for Transport by Command of Her Majesty, March 2013, Cm 8584, ISBN: APF, Executive Summary, paragraph 1 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 9

11 Government s objectives. The policy is clear, i.e. that the Government s overall objectives for a sustainable future would not be met by inhibiting growth The APF explains the Government s objective of ensuring that the aviation sector makes a significant and costeffective contribution towards reducing global emissions 10. Paragraph 2.15 of the APF explains that in the absence of a legally binding global agreement to tackle aviation emissions, the Government s strategy is to continue to strongly support activity at a European level. The two principal components of this are the EU Emissions Trading System (EU ETS) and improving EU airspace design through the Single European Sky (SES) programme The APF states that the Government believes that the EU ETS is a cost effective means of achieving a specified level of emissions 11. The EU ETS applies an emissions cap (see further details below) whereby net emissions from flights arriving into and departing from the European Economic Area (EEA) airports cannot increase above the level of the cap. Airlines can either reduce their own emissions over time, or purchase allowances or credits from other sectors where options for reducing CO2 are easier and cheaper to deliver 12. In this way aviation growth can be used to fund carbon reductions in other industries Paragraph 2.25 of the APF explains the UK s strong support for the SES programme which it states has already delivered and is expected to deliver further significant benefits in reduced CO2 emissions and mitigation of local environmental impacts The Government s legally binding carbon target is set out in the Climate Change Act which commits the UK to reducing its net greenhouse gas emissions by at least 80% below 1990 levels by Emissions from international aviation currently do not form part of the target. Under the Act, a decision on the inclusion of international aviation and shipping was expected by the end of The APF confirms the new date for this decision as June 2016, to allow international agreements relating to the EU ETS to be resolved The CCC, which was established by the Climate Change Act 2008, has identified a planning assumption for aviation emissions which is consistent with the UK s overall targets that emissions from UK aviation in 2050 should not exceed 37.5 Mt (the level seen in 2005). 15 The Airports Commission report also notes that the CCC considers that this is a realistic but ambitious goal. The expansion of the UK s hub capacity was tested by the Airports Commission in the light of a full understanding of this policy approach Air quality The European Directive on Air Quality and Cleaner Air for Europe (Directive 2008/50/EC, referred to as the Air Quality Directive) sets out limit values for outdoor, ambient concentrations of nitrogen dioxide (NO2) and other pollutants which are implemented in the UK through the Air Quality Standards Regulations The NPPF states that planning policies should sustain compliance with and contribute towards EU limit values The APF states that the Government policy on air quality is to seek improved international standards to reduce emissions from aircraft and vehicles and to work with airports and local authorities as appropriate to improve air quality 18 and notes that the Government is committed to achieving full compliance with European air quality standards APF, paragraph APF, paragraph APF, paragraph HM Government (2008) Climate Change Act 2008, 14 APF, paragraph ACFR, paragraph STATUTORY INSTRUMENTS, 2010 No. 1001, ENVIRONMENTAL PROTECTION, Air Quality Standards Regulations 2010, 17 NPPF, paragraph APF, paragraph Aviation Policy Framework, paragraph 3.47 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 10

12 2.3.4 Paragraph 9.55 of the ACFR confirms that responsibility for meeting the EU limit values lies with the UK Government and paragraph 9.57 confirms that the UK is currently meeting European air quality standards for nearly all pollutants with the exception of NO2 limits alongside roads in cities and towns. It then explains that, following the Supreme Court ruling on the ClientEarth case, the UK Government is required to submit a revised action plan to the European Commission by the end of 2015, detailing how and by when it will meet the standards for NO Paragraph 3.55 of the APF is helpful in reminding us that proposals for a new runway at Heathrow, or any other nationally significant infrastructure for aviation, would be taken forward through an Airports National Policy Statement (NPS). Such an NPS would take a similar approach to existing NPSs and necessarily be consistent (and require compliance) with the Government s stated policies on sustainability and environmental protection The use of an NPS to provide the principal policy tests for new aviation capacity would in itself ensure that any future decision was consistent with national policy. Section 104 of the Planning Act 2008 requires decisions on Development Consent Order applications to be consistent with an NPS An examination of other NPSs provides us with a useful indication of how Government policy on air quality is likely to be applied through an Airports NPS. For instance, the Overarching NPS on Energy (EN-1, July 2011) states at paragraph : In all cases the [IPC] must take account of any relevant statutory air quality limits. Where a project is likely to lead to a breach of such limits the developers should work with the relevant authorities to secure appropriate mitigation measures to allow the proposal to proceed. In the event that a project will lead to non-compliance with a statutory limit the [IPC] should refuse consent The National Networks NPS (December 2014) contains a similar policy requirement at paragraph 5.13: The Secretary of State should refuse consent where, after taking into account mitigation, the air quality impacts of the scheme will: Result in a zone/agglomeration which is currently reported as being compliant with the Air Quality Directive becoming non-compliant; or Affect the ability of a non-compliant area to achieve compliance within the most recent timescales reported to the European Commission at the time of the decision The Supreme Court case brought by ClientEarth confirmed the obligation on the UK to meet EU limit values for particular pollutants by January The UK Government had previously submitted air quality plans to demonstrate that the exceedence periods for the 16 zones where EU limit values could not be expected to be met by 1 January 2015 would be kept as short as possible. The Supreme Court ruled that the plans were not sufficient, placing the UK in breach of the Directive and ordered that the Government must submit new air quality plans to the European Commission by no later than 31 December Defra is expected to open the consultation on its new plans during September 2015, and we look forward to engaging in that consultation and playing our part in bringing forward compliance. Parliament can take confidence from the fact that it has been so recently made clear that the Government is obliged to act to achieve compliance. The Government will pass on obligations for air quality compliance through its NPSs, with aviation and other infrastructure applications being tested against very clear requirements, consistent with the UK s international and domestic obligations The air quality analysis completed by the Airports Commission is consistent with our own analysis that compliance can be achieved with an additional runway at Heathrow. Even if that were not the case, it is clearly intended that the next stage of policy (the Aviation NPS) can and will set the necessary tests to ensure that the construction and operation of a new runway is not allowed to generate a breach of air quality standards. 20 ACFR, paragraph 9.58 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 11

13 2.4. Noise The Government s overall noise policy vision is set out in the Noise Policy Statement for England (NPSE) 21 and it is to: Promote good health and a good quality of life through the effective management of noise within the context of Government policy on sustainable development The NPSE has three policy aims which are, like its vision, set in the context of sustainable development. These are: avoid significant adverse impacts on health and quality of life; mitigate and minimise adverse impacts on health and quality of life; and where possible, contribute to the improvement of health and quality of life Defra s Guidance for Airport Operators reinforces the fundamental importance of the NPSE: overall policy on noise is set out in the Noise Policy Statement for England (NPSE). It promotes good health and a good quality of life (wellbeing) through the effective management of noise in the context of sustainable development This NPSE objective is set out in the Government s APF, which the Government states is the current key document within the aviation industry. This is also reflected in the NPPF that reiterates the aims of the NPSE as material when advising on the considerations and judgements in plan-making and decision-taking 23. The National Planning Practice Guidance for Noise (NPPG) 24 states that: the management of the noise associated with particular development types is considered in.. aircraft noise Aviation Policy Framework The NPPG makes it clear that noise should not be considered in isolation, separately from the economic, social and other environmental dimensions of proposed development. 26 The APF states its noise policy objective is: consistent with the Government s Noise Policy, as set out in the Noise Policy Statement for England (NPSE) which aims to avoid significant adverse impacts on health and quality of life It is therefore clear that with respect to aviation noise, Government policy is set out within the APF. There the Government has set two policy objectives for aviation noise. These are: to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise; 28 to encourage the aviation industry and local stakeholders to strengthen and streamline the way in which they work together The APF also confirms the Government s commitment to the International Civil Aviation Organization (ICAO) Assembly balanced approach principle to aircraft noise management. The balanced approach through international agreements and European Directives is implemented in the UK under The Aerodromes (Noise Restrictions) (Rules and Procedures) Regulations These regulations reflect the adoption of the balanced 21 Noise Policy Statement for England (NPSE, March 2010) 22 Guidance for Airport Operators to produce noise action plans under the terms of the Environmental Noise (England) Regulations 2006 (as amended), Defra, July NPPF, 2011, Paragraph Planning Practice Guidance Noise (NPPG), Paragraph: 010 Reference ID: NPPG, paragraph 010 ID: NPPG, paragraph 003 ID APF, paragraph APF, paragraph APF, paragraph 20 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 12

14 approach in achieving the noise objectives which are implicit in Government policy. These consist of identifying the noise problem at an airport and then assessing the cost effectiveness of various measures to limit noise, with operating or capacity restrictions only applied after a full consideration of the benefits to be gained from other elements of the balanced approach. 30 The Airports Commission s work and recommendations were prepared in full knowledge and application of the balanced approach principles The APF clarifies that the Government will continue to treat the 57dB LAeq 16hr contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance 31 and then sets clear and specific requirements for noise mitigation. It recommends that airports use alternative measures which better reflect how noise is experienced in different locations. It states that these should be developed in consultation with airport consultative committees and local communities and could be used to help provide a better understanding of noise impacts and to inform noise mitigation schemes Our proposals for noise insulation in association with a third runway, coupled with our continuing commitment to reduce noise at source, already exceed the stated requirements of the APF. Our proposals would guarantee compliance with national aviation noise policy and the Committee can be confident that the obligation to do so will be reinforced by the Aviation NPS and closely examined through any DCO examination, with appropriate binding commitments put in place The APF confirms that the Government wishes to pursue the concept of noise envelopes. Again this approach is directly consistent with the APF which encourages the use of noise envelopes as a means of giving certainty to communities about the levels of noise that can be expected around airports, whilst providing operators with clarity about how they can use their airports The Airports Commission s work which informed their recommendation tested the expansion of the UK s hub capacity in the light of a full understanding of this policy approach Government has a range of policies and attendant commitments to address the environmental impacts of infrastructure developments. Those policies and commitments were fully taken into account by the Airports Commission The policy landscape will continue to evolve as an Aviation NPS is prepared, so that the NPS can ensure that any new airport capacity is delivered and operated in a manner consistent with the most up to date understanding of Government policy. The robustness of the Airports Commission s approach and the detail of our own analysis create confidence that the new proposal for expanding Heathrow put forward to, and selected by, the Airports Commission will be able to respond to these requirements. The nature of the DCO consenting process will then ensure that this is the case. 30 APF, paragraph APF, paragraph APF, paragraph 3.29 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 13

15 3. Question 1: Are the indicative policies and proposed mitigations set out in the Airports Commission's recommended option realistic and achievable? 3.1. Carbon emissions The Environmental Audit Committee can be confident that the indicative policies and proposed mitigations set out in the Airports Commission s recommended option in relation to carbon emissions are realistic and achievable The Airports Commission integrated the CCC s planning assumption (37.5 MtCO2 emitted by aviation cruise and LTO by 2050) into its approach to forecasting aviation demand. 33 It developed two sets of forecasts, one of which assumes that carbon-trading will enable emissions reductions where they are most desirable or efficient across global or regional economies and one with a national carbon-cap of 37.5MtCO2 in place for UK aviation emissions in A new runway at Heathrow was found to be consistent with either carbon-traded or 35, 36 carbon-capped scenarios The carbon-capped scenario presents a worst-case where international emissions trading does not take place in any form and so sets a physical limit on demand growth. The carbon-traded scenarios are also conservative in that they do not rely on effective operation of the EU ETS nor a global trading scheme, although some form of international offsetting is implied. If such a trading scheme were in place, trading could further reduce the net emissions from aviation To test robustness of its analysis of carbon-capped and carbon-traded forecasts of future aviation demand, the Airports Commission created five scenarios for how the aviation sector and broader global economy might develop. In support, the Airports Commission identified and analysed abatement measures that could be used unilaterally in both carbon-traded and carbon-capped scenarios, 37 including as the main measures, new biofuels and operational efficiency improvements. The Airports Commission was commended by its academic peer review panel for the uncommon reasonableness of its assumptions on operational efficiency. (Economy: Carbon Policy Sensitivity Test, Airports Commission, July 2015; A Note from Expert Advisors, Prof. Peter Mackie and Mr Brian Pearce, on key issues considering the Airports Commission Economic Case, May 2015) Organisations independent of the Airports Commission have previously published studies showing that the target of 37.5MtCO2 by 2050 is realistic and achievable and outlining how it can be achieved, as explained below. Committee on Climate Change The CCC is an independent, statutory body established under the Climate Change Act 2008 to advise the UK Government and Devolved Administrations on emissions targets and periodically reports to Parliament on progress made in reducing greenhouse gas emissions and preparing for climate change. In the context of a previous Government supporting a third runway at Heathrow, the CCC was asked to advise on options for reducing CO2 emissions from UK aviation to meet the 2050 target. The CCC report, Meeting the UK aviation target options for reducing emissions to , was published in It described the combination of 33 ACFR, paragraph ACFR, paragraph ACFR, paragraph Airports Commission, Business Case and Sustainability Assessment Heathrow Airport Northwest Runway, July 2015, paragraph ACFR, paragraph Meeting the UK aviation target options for reducing emissions to 2050, Committee on Climate Change, December 2009, Heathrow Airport Limited 2015 HAL Submission to the EAC Page 14

16 technology, operational practices and low carbon fuels that would be required, concluding that a 60% growth in demand for aviation could be accommodated and the target would still be met The CCC has been consulted by the Airports Commission during its work and has agreed with the Airports Commission s analysis of carbon emissions. 39,40 The Airports Commission s recommendations are therefore consistent with the Government s policies and its plan to meet its commitment under the Climate Change Act. Sustainable Aviation Sustainable Aviation, the coalition of airlines, aircraft manufacturers, airports and air traffic services provider NATS, which develops practical and policy solutions for cleaner, quieter, smarter flying, published a detailed 2050 CO2 Road-Map in and, in 2014, a Sustainable Fuels UK Road-Map The Sustainable Aviation CO2 emissions road-map shows how, with the aid of technology, improvements in operational efficiency and increased take up of low-carbon alternative fuels, the level of UK air traffic can more than double without increasing the direct emissions from those flights. It also confirms the industry s support for internationally agreed carbon trading to cut net CO2 emissions to 50% of 2005 levels in line with IATA s global industry goal. Any additional activity would be made possible by additional carbon trading Heathrow supports the need for global market based measures such as an emission trading scheme. We consider that the climate change effects of aircraft emissions can be further reduced by emissions trading, and that this process provides economically-efficient and environmentally-effective contributions to carbon abatement. By linking aviation with carbon abatement in other sectors, not only does aviation benefit from lower abatement costs, but the carbon market is stimulated to drive further abatement The CO2 Road-Map figure showing forecast of carbon emissions from UK aviation up to 2050 is reproduced here in Figure The Sustainable Fuels UK Road-Map identifies the potential for a 24% reduction in CO2 emissions from aviation by It identifies and forecasts the potential volumes of sustainable aviation fuel to 2050, both for the UK and globally. It forecasts that by 2030 there could be operational sustainable fuel plants globally, with up to 12 plants in the UK. Government support will be vital to achieve this full potential and Sustainable Aviation looks to build on the successful work promoting innovation that Government has already undertaken with industry, in order to develop a shared vision that focuses on investing in the commercialisation of high value sustainable aviation fuels. It recommends the establishment of a public-private initiative to help realise these opportunities, similar to the USA s Commercial Aviation Alternative Fuel Initiative (CAAFI) CCC, July 2013, Letter to the Aviation Commission, 40 CCC, February 2015, Letter, Response to Airports Commission consultation on increasing the UK s long-term aviation capacity, 41 Sustainable Aviation (2012) CO2 Road-Map, March 2012, pdf Figure 13 for carbon reduction factors. 42 Sustainable Aviation (December 2014) Sustainable Fuels UK Road-Map 43 Commercial Aviation Alternative Fuel Initiative (CAAFI) Heathrow Airport Limited 2015 HAL Submission to the EAC Page 15

17 Figure 3.1: The Sustainable Aviation road-map for CO 2 (Figure 7.1 from the Sustainable Aviation CO2 Road-Map ) Department of Energy and Climate Change Carbon pricing The Airports Commission drew up an indicative set of policies in the carbon-capped scenario that would allow the CCC s assumption (37.5 MtCO2 by 2050) to be met based on a carbon price of 334/tCO2 by This carbon price reflects a baseline do nothing (no airport expansion) scenario where emissions are kept to 37.5 MtCO2. It is also used as the reference price in all carbon-capped expansion scenarios. As such, it is noted as a conservative assumption by the academic reviewers as it is at least possible that a lower price would be sufficient to keep demand (and hence emissions) below the target in the baseline and in other scenarios 45. The cost of 334/tCO2 is in almost identical to DECC s upper bound for the cost of carbon in ,47 and so falls within a realistic range according to current Government thinking Our research shows that passengers value international connectivity and will be prepared to pay their carbon costs to allow them to travel. The Airports Commission s analysis confirms that demand is still strong at a high carbon price ( 334/tCO2). Through global market based measures such as a trading scheme, a growing aviation industry can play its part by promoting emissions cuts in other sectors where they can be delivered much more cost-effectively. Ultimately, and assuming policy makers take steps to internalise carbon costs across the economy through their inclusion in ticket prices, consumers will decide how to allocate their spending to maximise the utility of each tonne of carbon purchased The underlying demand for air travel and relatively low elasticity to prices observed within the aviation sector (Aviation Demand forecasting, Airports Commission, February 2013) makes the Airports Commission s assumption of high carbon prices realistic for long term planning and underpins a conservative approach to their assessment more generally. 44 Airports Commission, July 2015, Economy: Carbon Policy Sensitivity Test, paragraph Due to the Airports Commission s assumption of a constant elasticity demand form at all price levels (as opposed to a functional form where elasticities increase as prices increase). A Note from Expert Advisors, Prof. Peter Mackie and Mr Brian Pearce, on key issues considering the Airports Commission Economic Case May DECC, _2014_DECC_HMT_Supplementary_Appraisal_Guidance.pdf 47 DECC, Copy of _Supporting_Tables_for_DECC-HMT_Supplementary_Appraisal_Guidance.xlsx Heathrow Airport Limited 2015 HAL Submission to the EAC Page 16

18 Negotiation and implementation of trading mechanisms Carbon limits amount to restrictions on capacity. In this context, the UK is an international leader in the use of methods of allocating scarce resources to achieve economic efficiency through market incentives. As well as piloting mechanisms used in the European Emissions Trading System (EU-ETS), the UK has implemented mechanisms for other resources: allocating network capacity between mobile phone operators; providing operators with choice in the methods of disposing of waste electrical and electronic equipment; and allowing owners of large combustion plants to trade SO2, NOx and dust allowances under the National Emissions Reduction Program With this experience, the assumption that the UK can effectively negotiate allocation of international emissions as well as implement schemes for domestic allocation is seen as a realistic component of the proposed policies Air quality As in the case of carbon above, the Environmental Audit Committee can be confident that the indicative policies and proposed mitigations set out in the Airports Commission s recommended option in relation to air quality are realistic and achievable The main pollutant of concern is nitrogen dioxide (NO2.) This is produced by all combustion processes, including those that take place within aircraft engines, road vehicle engines, central heating boilers and many other sources. This is why high levels are found near busy roads and motorways, in heavily built-up areas, and on airports. The area around Heathrow has the airport, but also the M4 and M25 motorways, many other busy roads, the Great Western Mainline railway (non-electrified), and many residential, commercial and industrial properties Government policy recognises the air quality contribution made by airport surface access within the APF (paragraph 3.51): Road traffic remains the main problem with regard to NOx in the UK. Airports are large generators of surface transport journeys and as such share a responsibility to minimise the air quality impact of these operations. The Government expects them to take this responsibility seriously and to work with the Government, its agencies and local authorities to improve air quality The concentration of NO2 at a given location depends on the sources near to it. In general concentrations fall off quickly within a few hundred metres from a source (as shown in Figure 3.2 below). For example, the contribution from a motorway halves within about m of the hard shoulder. Similarly, the concentration from Heathrow Airport halves within a few hundred metres of the airport boundary. The height of a source is also important (which is why industrial sources have tall chimneys): the contribution from aircraft taking off or landing is insignificant for ground level concentrations once they are more than about 100 m above the ground. 48 Compliance with Air Quality Standards and EU limit values Heathrow expansion is possible while meeting legal limits on air quality. We would not promote a scheme that would not be capable of being legally compliant. The Airports Commission has shown that, even with conservative assumptions (what it calls a plausible worst case scenario ). The Heathrow Northwest Runway scheme can perform well within limits, saying: Even with additional runway capacity in place, none of the air quality receptors around Heathrow which would have implications for human health, such as at schools or residential buildings, are forecast to exceed air quality limits in (Executive Summary, p. 27) Indeed, the Airports Commission s modelling shows that compared to the business-as-usual case, the Heathrow Northwest scheme will result in just 14 extra properties in the at risk band where concentrations of NO2 are over 32 µg m 3 which provides a 20% margin of headroom below the legal limit of 40 µg m 3. This is despite the 48 Department for Transport (2006) Project for the Sustainable Development of Heathrow. Report of the Airport Air Quality Technical Panels. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 17

19 Airports Commission assuming no specific mitigation measures and making a number of other highly conservative assumptions Our own forecasting, reported in our submission to the Airports Commission 49, was designed to provide a realistic estimate of the air quality with a third runway and used best-practice modelling techniques consistent with the recommendations of the Project for the Sustainable Development of Heathrow (PSDH) and ICAO s Airport Air Quality Manual. It differs from the Airports Commission s assessment in a number of respects, principally by including more precise detail of airport operations. For example, our assessment takes account of the fact that aircraft rarely use full thrust when taking off (aircraft engines are overpowered for normal take-offs, since they must have enough reserve power to be able to complete the manoeuvre safely if an engine fails); this reduces emissions from take-off by around 10 20% compared to the Airports Commission s assumption of full thrust This means that we estimate concentrations with a third runway to be a little lower than the Airports Commission. For example, the highest forecast annual mean NO2 concentration at a health-based receptor in 2030 is 34.7 µg m 3 in the Airports Commission s assessment, and 31.6 µg m 3 in ours. Overall, however, these two independent expert analyses agree in their conclusions that it is clear that the Heathrow Northwest scheme will not result in exceedences of the legally-binding Air Quality Standards Our modelling shows that concentrations around the airport boundary are similar in both 2R (two runway) and 3R (three runway) cases. This is to be expected since, although the total aircraft emissions are greater in the 3R case, they are spread over a larger area and necessarily the level of activity per runway, taxiway or stand is no higher than it is now, since the airport is already at full capacity. Because concentrations drop off substantially over a distance of several hundred metres from the source, and as the airport is several kilometres across, the effect at the boundary is that concentrations are independent of airport size. The table below gives modelled NO2 concentrations at the continuous monitoring stations around the airport in both 2R and 3R cases, and shows that NO2 concentrations are no more than 3 µg m 3 higher with the third runway than the 2R business-as-usual case. Table 3.1 Comparison of modelled NO 2 concentrations at automatic monitoring locations in 2R and 3R cases Annual mean NO 2 concentration (µg m 3 ) 2R R 2030 Difference Heathrow LHR Heathrow Oaks Road Heathrow Green Gates 25.1 *36.0 * Slough Colnbrook Hillingdon Harmondsworth 24.1 *30.2 * London Hillingdon Hillingdon Sipson London Harlington Hillingdon 3 Oxford Ave Hillingdon Hayes Hounslow 2 Cranford Hounslow Hatton Cross * In the 3R case, these locations will be within the new airport boundary Turning to compliance with EU limit values, Defra assesses compliance with the EU Air Quality Directive for reporting to the European Commission by dividing the country into a number of Zones and Agglomerations, of which Heathrow lies in the Greater London Agglomeration. To be compliant with the Directive, the whole of the Agglomeration must be below the limit. 49 Heathrow Airport Limited, Heathrow s North-West Runway: Air Quality Assessment. June 2014 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 18

20 For London compliance is driven by conditions in central London, and Defra is currently forecasting that at Marylebone Road for example, concentrations will still be 48.6 µg m 3 in 2030, well above the limit, meaning the Greater London Agglomeration will not be compliant unless action is taken, regardless of Heathrow expansion Under the Airports Commission s modelling, the NO2 concentration at Bath Road near Heathrow in 2030 will be 0.1 µg m 3 higher than at Marylebone Road. Therefore, the Airports Commission argues that some additional mitigation beyond that assumed in its modelling (which was effectively none) will be necessary to ensure that air quality around Heathrow, by keeping concentrations below those in central London, does not delay compliance. In fact, our more realistic modelling shows that, taking into account measures which are already standard practice today, concentrations will be substantially lower without any additional mitigation being required. However, Heathrow is committed to ensuring that air quality around the airport is as good as practicable, so the mitigation measures proposed by the Airports Commission are discussed in detail below to show that the level of additional mitigation the Airports Commission proposes is readily achievable Improvements to air quality at Marylebone Road (and elsewhere in central London) will come from a mixture of nationwide actions (e.g. improvements to emissions from road vehicles) and from locally targeted actions (e.g. a Ultra-Low Emission Zone). The former of these will benefit air quality around Heathrow as well. The latter will be matched by actions targeted at Heathrow, some of which are already being implemented and others of which are under consideration. Heathrow s actions will be sufficient to at least match those in central London to ensure that compliance with the limit values is not delayed We therefore agree with the Airports Commission s independent analysis that it is realistic and achievable that expansion at Heathrow will not delay compliance with EU limits The Airports Commission made an important broader point about the nature of the air quality issue (ACFR paragraphs & ) that: Tackling air quality is not, however, only the responsibility of the airport operator. Heathrow is situated close to the M25, M4 and other major roads and the majority of emissions in the area are caused by road traffic unrelated to the airport... The air quality issue around Heathrow is a manageable part of a wider problem, the underlying causes of which will need to be addressed by the Government This observation is supported by the fact that pollutant concentrations at the worst locations in the region of Heathrow (over 2km north of the airport) are predominantly due to non-airport traffic. For example, at the Hillingdon monitoring station north of the M4 motorway, less than 3% of NOx concentrations in 2013 came from the airfield, and just 13% came from airport-related traffic, compared with 42% from non-airport road traffic and another 42% from other non-airport (background) sources (see Figure 3.2). Clearly concentrations here are largely outside our control and uninfluenced by the airport. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 19

21 Figure 3.2 Contributions to NO x concentrations at locations around Heathrow Hillingdon: 2km north of airport, north of M4 Hayes: over 2 km north of airport, north of M4 LHR2: On airfield, next to runway Oxford Avenue: 50m northeast of airport near A As noted in Section 2.3 above, Defra is expected to open the consultation on its new plans during September. This will be a key step in promoting national compliance. We will engage in that consultation to play our part in helping to achieve compliance as soon as possible. It can be expected, however, that the effect of the Government s actions must necessarily be a greater reduction in background concentrations than was assumed in the Airports Commission s analysis. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 20

22 Mitigation measures The Airports Commission s assessment incorporates many of the mitigation measures that we proposed as part of the Heathrow NWR scheme. In addition it suggests a number of possible mitigation measures which it did not include in its main assessment. These measures are feasible and achievable and many of these are already being implemented or are included in our plans for expansion. The measures suggested by the Airports Commission 50 are discussed below Achieving better public transport mode share - Our strategy is designed to meet the objective of increasing public transport mode share and not increasing absolute traffic generated by airport passengers and employees. The strategy is focussed on public transport and through committed projects, we will see rail access to the north, east, south and west of the Airport transformed. In 2019, Crossrail will provide direct access to the heart of London, connecting Heathrow to the city, west end and Canary Wharf. Western Rail access will provide direct access to key catchments in the Thames Valley and improve access to the south west and south Wales. Southern Rail Access will fill a current gap in connectivity to the south providing faster journeys to south London, Surrey and the south coast, providing choice and resilience for passengers. Through a connection to Heathrow via Old Oak Common, HS2 will help to substantially cut journey times to key cities across the Midlands and the North. We will also work with operators to upgrade the bus and coach station, already the busiest in the country, and develop a new and improved network of routes. This will help to improve local connectivity through more frequent bus services and more early morning services to allow more airport workers to get to the airport as early as 4am by sustainable modes. Of the 32 local bus routes currently serving Heathrow, there are already 13 that have early morning or 24-hour services. The Airports Commission s analysis agrees with our own assessment that public transport will rise to 53% by With demand management the Airports Commission believe this could rise to over 60% We will also deliver a reduction in airport employees driving to work. We will reduce staff car parking spaces; continuing to support the world s largest single site car-sharing scheme. Our Heathrow Commuter team will continue to deliver discounted travel for airport workers through our airport travelcard scheme. Our programme of sustainable travel initiatives has seen the proportion of airports workers driving to work fall from almost 80% in 1991 to just above 50% in The Airports Commission analysis currently assumes an increase in car trips by airport employees to Based on the public transport improvements and our track record in this area, there are further reductions to be made above and beyond those assumed by the Airports Commission work. In addition to our plans for public transport, we will work to deliver more efficient use of cars. This includes schemes to reduce the proportion of empty return journeys by private hire vehicles and increase the number of vehicles with passengers travelling both to and from the airport. In line with the AC recommendation we also continue to investigate a congestion charge should this be necessary. What this means is that in 2030, annual NOx emissions from airport-related road traffic would be around 85 tonnes, compared to around 220 tonnes annually today NOx emissions charging for airlines. We already have a NOx emissions charge which forms part of the fees airlines pay for using the airport. This scheme, which was introduced in 2004, has helped to ensure that airlines use the cleanest aircraft at Heathrow, and contributed to reductions in NOx emissions from aircraft in recent years. We keep the level of the charge under regular review in association with airlines. The emissions charge forms part of the overall fee paid by airlines which is regulated by the CAA, and so is cost-neutral overall (that is, Heathrow does not make any additional profit by increasing the NOx charge). Significant strides forward in the reduction of NOx emissions from aircraft engines have been made over the last 30 years and there are still gains to be made with the introduction of new combustion technology. Over the period 2009 to 2013, NOx emissions from aircraft ground movements at Heathrow reduced by 7% Providing incentives for airlines to shut down an engine during taxiing. This is an area of active investigation with our partners in airlines and aircraft manufacturers, although there are a number of technical difficulties with reduced-engine taxiing, especially on taxi-out. We are examining ways to implement systems to allow us monitor the usage of reduced-engine taxiing. 50 Jacobs, Module 6: Air Quality Local Assessment: Detailed Emissions Inventory and Dispersion Modelling, Section Table 5.1 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 21

23 Supporting ongoing technological developments and innovation, including industry research into the use of alternative fuels for aircraft. As the Airports Commission notes, the use of alternative fuels is an area of active research within the aviation industry, driven primarily by carbon emissions. It is not yet clear what the effect on NOx emissions will be, but current evidence suggests it is likely to be small (neither positive nor negative). The need to keep NOx emissions down is widely recognised in the aviation industry and, for example, ICAO s Committee on Aviation Environmental Protection manages a process to drive down emissions from newly-certified engines Implementation of an Ultra-Low Emissions Zone (ULEZ). The Airports Commission has analysed the possible effect of two options for a ULEZ around Heathrow. The less strict option would reduce NO2 concentrations by 0.2 µg m 3 and the more strict option would reduce concentrations by 0.8 µg m In addition to the mitigation measures proposed by the Airports Commission, we have a wide range of additional measures that we are planning, or have already begun to implement. Current measures are described in our blueprint for reducing emissions 52, the latest in a series of air quality action plans implemented over the last 15 years. The Blueprint was examined as part of the recent planning inquiry into the ending of the Cranford Agreement, at which we offered a binding planning obligation to give confidence that it will be applied and committed funding to help facilitate the early improvement of emissions from the bus fleets serving some of the most sensitive areas We have a track record of achieving growth while driving down emissions. Over the period 2008 to 2014, aircraft NOx emissions per passenger fell by 8.6%. Monitoring results for NO2 at the seven monitors closest to the airfield, all of them within about 300 m of the airport boundary, demonstrate that concentrations have fallen over the last eight years at every monitoring location. In particular, the LHR2 monitor is located within the airfield secure area just 170 m from the northern runway (an area without public access) in order to measure the contribution from aircraft specifically, and demonstrates that concentrations from aircraft have fallen by over 10% in the last eight years In summary, it is possible to implement realistic mitigation measures to achieve our commitment to expand within air quality limits, and the measures we have in place and are planning to introduce will ensure it happens. Heathrow has a proven track record of delivering air quality improvements that will ensure that expansion is consistent with the Government s legally binding commitments on air quality. As explained above, policy in the Aviation NPS, and the DCO process itself, will also ensure that expansion cannot be consented if it would lead to non-compliance with EU air quality limits. 52 Heathrow Airport Limited. Heathrow s blueprint for reducing emissions, May 2015, Heathrow Airport Limited 2015 HAL Submission to the EAC Page 22

24 3.3. Noise Many of the policies and mitigations that the Airports Commission has put forward have also been proposed by Heathrow and are the result of extensive consultations with our local communities and industry stakeholders. As such, they are both realistic and credible. As noted in the Executive Summary, we continue to study the detail of the Commission s specific conditions in relation to noise in consultation with our stakeholders and we comment on some of them below. We are confident that a package of measures can be agreed that meets the needs of Government policy, local communities, the airport, airlines and those who benefit from Heathrow Airport for employment, business and travel In July 2013, the Airports Commission published and consulted on its discussion paper on aviation noise. The paper was clear that the Airports Commission s work would be carried out in the context of the Government s then recent APF which installs a number of policy objectives and themes. Both Heathrow s and the Airports Commission s indicative policies and mitigations expand on these themes At a high level, the APF sets the Government s policy objectives on aviation noise as: to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise; to encourage the aviation industry and local stakeholders to strengthen and streamline the way in which they work together Commenting on the Government s policy, the Airports Commission also cited the following statements from the APF which expand upon the balance between the impact of noise on communities and the benefits that growth in aviation brings: [to] strike a fair balance between the negative impacts of noise and the positive impacts of flights; and as a general principle, any benefits from future aircraft noise performance should be shared between the aviation industry and local communities The Airports Commission was correct to take this approach. The Airports Commission acknowledged that in certain areas, including noise assessment, compensation schemes and the concept of noise envelopes, the APF highlighted that a greater consensus was required. The Airports Commission correctly identified that its work was an opportunity to develop the policy themes contained within the APF. We agreed with this position and consider this approach to be appropriate in developing realistic and achievable policies and mitigations The Airports Commission s consultation on noise sought to reconsider how noise was managed and invited views on this in the context of the Government s existing policy framework. This resulted in extensive research and a thorough consultation to identify how aircraft noise will be reduced in the short and medium-term through technological advances and management practices. It also considered the social and community aspects of aircraft noise management, identifying situations in the past which have led to mistrust and how these situations can be avoided in the future by changing the way aircraft noise is managed in the UK Heathrow has developed its noise management strategy (which was in turn endorsed by the Airports Commission) in a way which is consistent with, and in many cases exceeds, the Government policy requirements For example, the Airports Commission s overall noise objective to minimise and where possible reduce noise impacts 54 that underpins its sustainability assessment and appraisal framework is consistent with the Government s overall policy objective on aviation noise as defined within the APF. The Airports Commission acknowledges that expansion at Heathrow can result in fewer people exposed to aircraft noise than today 55. This is fully consistent with the objectives of the Airports Commission s objective on noise and the Government s policy. 53 Airports Commission Discussion Paper 5 aviation noise, July 2013, paragraph Airports Commission Appraisal Framework, April 2014, Section 5 55 Airports Commission Business Case and Sustainability Assessment Heathrow Airport Northwest Runway, paragraph 6.16, Figure 11.6 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 23

25 3.3.9 A number of the mitigation and compensation measures that are proposed as conditions of expansion by the Airports Commission are consistent with Heathrow s own proposed measures and industry best practice. These measures are the result of extensive consultations, collaborations and research with industry stakeholders and communities since 2010 as summarised in Figure 3.3 below. For example, we have worked extensively in improving how we collaborate with our communities and stakeholders in addressing noise. We have sought to improve how we communicate with communities and have voluntarily established programmes such as Fly Quiet. We have continued to work with our industry stakeholders to further reduce noise at source as highlighted in our Noise Blueprint. Our proposals reflect what we have learned and what we know can be achieved. Figure 3.3 Our consultations, collaborations and research with industry stakeholders and communities since 2010 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 24

26 Better than today The Airports Commission has acknowledged that an expanded Heathrow can be better than today. This outcome was also identified by Heathrow in our own technical assessment 56. The Airports Commission s findings confirm that a bigger Heathrow would not inflict noise nuisance on more people than the airport does today 57 which complies fully with the Government s overall noise policy objective The Airports Commission s analysis shows that across all metrics, the noise impact of an expanded Heathrow will reduce compared to today, as shown in Figure 3.4. In the case of night noise, expansion provides an opportunity to significantly reduce the number of people exposed. Government policy is clear within the APF that noise from aircraft at night is therefore widely regarded as the least acceptable aspect of aircraft operations 58. The opportunity that expansion provides to significantly reduce and further mitigate night-time noise exposure is important. Figure 3.4 The Airports Commission comparison of the current scenario with expansion scenarios for a range of noise metrics (ACFR, Figure ES.4) Our proposals have a number of significant features that are designed to reduce noise, which are both realistic and achievable. These features take into account research, collaboration and consultations, to help shape our approach. Our proposal is designed to grow Heathrow with less noise and to build on our track record of reducing noise. Since the 1970s we have reduced our noise footprint by around 90%. We have highlighted some of our achievement in noise management in the diagram below such as: being the first European hub airport to have a Fly Quiet programme; the first to introduce differential noise landing charges; and changing the way we collaborate and work together without communities and noise stakeholders by setting up the Heathrow Noise Forum. These achievements and the work of the aviation industry have all contributed towards significantly reducing noise at Heathrow. 56 Heathrow Airport Limited, Heathrow s North-West Runway Air and Ground Noise Assessment, June ACFR, Foreword 58 APF, paragraph 3.34 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 25

27 Notwithstanding our achievements, we continue to work hard to further reduce our noise impacts. We have published our Blueprint for noise reduction 59 which sets out a range of measures we will take to address noise from our existing operations These include measures such as steeper approaches, which we recently started to trial. We have worked with our airlines to encourage quieter aircraft. We are likely to be the first international hub airport to achieve a voluntary phase-out of Chapter 3 aircraft, the noisiest permitted to operate We continue to make significant progress in improving the noise performance of our fleet working collaboratively with our airline customers. For example, the number of Boeing aircraft movements, one of the noisiest aircraft to operate at Heathrow, has reduced by 41% since We will also work with airlines and the aviation industry to implement measures that reduce and manage noise through, for example, landing gear deployment and aircraft retrofitting As part of our proposals, we have set out a range of measures and incentives that would allow Heathrow to expand without exposing more people to noise than it does today. We have summarised our approach in Figure 3.5 below which is documented in full in our technical submission to the Airports Commission. The Airports Commission has indicated that many of the technical measures and incentives to encourage quieter aircraft could form part of a noise envelope. We agree with this approach. Figure 3.5 Our measures and incentives for tackling noise We are confident given our track record and our approach that a policy of allowing expansion without exposing more people to noise than today is realistic and achievable. 59 Heathrow Airport Limited, Heathrow s Blueprint for noise reduction, June 2015 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 26

28 Noise insulation and compensation schemes The Airports Commission s proposed policy, that at least 1bn is to be spent on noise insulation and compensation, is based on Heathrow s own proposals which are fully costed and have been the subject of consultation 60. The Airports Commission s recommendation is that Heathrow should be held to this commitment, which we would expect to honour (subject, as we have always said, to an appropriate regulatory regime to support private investment in the third runway scheme as a whole) Our proposals entail a world-class noise insulation scheme covering 160,000 households providing 100% costs for noise insulation for those closest to the airport and up to 3,000 in contribution towards noise insulation for properties further away Our proposals far exceed current Government policy and noise insulation and compensation conditions that were set by Government in 2010 as a condition of expansion as part of previous expansion proposals For example, current Government policy indicates that residential dwellings should be provided with noise insulation where noise levels are at least 63 db LAeq, 16hr and they experience an increase of 3dB or more. Policy relating to the previous, 2010, third-runway scheme required an extension of Heathrow s then existing financial assistance noise insulation schemes for those exposed to at least 57 db LAeq, 16hr where a 3 db increase in exposure occurred as a result of the third runway. Our proposed schemes provides, as a minimum, financial assistance of 3,000 towards noise insulation for those exposed to 55 db Lden, which is approximately 53 db LAeq, 16hr and the full costs of noise insulation to those exposed to 60 db LAeq, 16hr during any mode of operation. Figure 3.6 provides an overview of our noise insulation and compensation proposals. Figure 3.6 Overview of our noise insulation and compensation proposals Our insulation scheme proposals would benefit not just those who would become affected by expansion but would also benefit those who already experience aircraft noise from our existing operation but may not be 60 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 27

29 eligible for compensation under our existing schemes. This is only fair so that the benefits of expansion can be shared with all our communities and not just those who become affected. These proposals are recognised by John Stewart of HACAN as being more generous than anything we have seen before. They reflect Heathrow s commitment to tackle aircraft noise Our proposal to provide 25% above market value compensation and to cover legal fees and stamp study costs associated with moving is a significant improvement compared with other major infrastructure projects which typically offer market value or up to 15% above market value. For example, similar compensation offered under schemes for HS2 is 10% above market value We are committed to consulting and further exploring how our insulation scheme can be world-class. Predictable and reliable respite The policy of providing predictable periods of respite has been in place at Heathrow since the 1970s. This policy is in place through what is known as runway alternation which is currently in operation during westerly operations. This involves aircraft arriving on runway and departing from the other. At 3pm each day, the arrival and departure runways alternate providing those who live under the departure and arrival routes with a half a day without overflight and respite from aircraft noise. Our community consultation has highlighted the value of respite 61. In the APF, the Government is supportive of predictable respite. The Airports Commission is clear that predictable and reliable respite is an important policy 62 and that Heathrow s respite proposals were a differentiator between it and the other shortlisted options 63. Our proposals can be designed to ensure that 94% of people affected by aircraft noise receive respite 50% of the time. 61 Taking Britain Further Volume 1, Heathrow Airport Part 2.2 Page ACFR, paragraph ACFR, paragraphs 13.83, 9.30 and 9.28 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 28

30 Figure 3.7 Schematic of runway alternation and the corresponding noise relief Our proposals already include provision for predictable and reliable respite which we know to be important to our communities This reflects our research and consultations that showed more people were in favour of respite by a ratio of 3:1 64 than concentrating aircraft along routes In developing our proposals, we have tabled indicative route designs and operating procedures which will require further work and, importantly, extensive public consultation and engagement. Throughout our scheme development we have been focused on engaging and listening to input from local community stakeholders. A clear message from the consultation has been to develop the concept of predictable periods of respite. The Airports Commission has recognised this All of our route designs are based around four different operating modes. Mixed mode (DL) is only operated on the northern and southern runways and not on the central runway. How these modes are used, when they occur and for how long would be the subject of future consultation. The use of these modes focuses on providing respite for those communities closest to the airport and is similar in concept to the current alternation pattern operated for westerly arrival operations. Building on our work with HACAN and industry partners we have taken that concept further to consider how we could alternate the arrival and departure routes to provide respite for communities further afield, by what can be called route alternation Our submission sets out three airspace design options. All three include runway alternation as a minimum (Table 3.2) and one also seeks to maximise respite using an alternating route structure, for example by having two routes for each runway mode. Table 3.2 The four modes of runway operation for each of the three airspace designs 64 Taking Britain Further Volume 2, Heathrow Airport, paragraph 7.1.9, May 2014 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 29

31 The timing, duration and scheduling of the alternation pattern would also be subject to public consultation but for the purposes of modelling the noise impacts both ourselves and the Airports Commission have assumed that all route and runway alternation patterns have been used in equal measure With advances in aircraft navigation technology, respite can become more defined and more predictable in line with the Airports Commission s indicative policies. Performance-Based Navigation (PBN) will allow us to fly routes more accurately to achieve route alternation. We have been working with our communities to understand how best to implement PBN and our Community Noise Forum is involved in this process In summary, we fully support the policy of providing predictable and reliable periods of respite but acknowledge that further work is required to understand its benefits and how it should be delivered and communicated. This will require further work and consultation which Heathrow is committed to as a global leader in this area. The principle of providing respite from aircraft noise to communities located around Heathrow is already a policy backed by Government, which we consider to remain both achievable and realistic with an expanded Heathrow. Collaborating and working together The APF is clear that it expects the aviation industry to work together and collaborate with local communities. The Government s objective is to encourage the aviation industry and local stakeholders to strengthen and streamline the way in which they work together We share this objective and regularly hold community forums such as the Heathrow Area Consultation Committee (HACC), and the Local Focus Forum. We recently established the Heathrow Community Noise Forum (HCNF) which is made up of representatives of 12 local authorities, NATS, British Airways, DfT, CAA and Heathrow. The forum was set up in response to local concerns regarding future changes in airspace as a result of the Government s Future Airspace Strategy and aims to build trust, seek input and collaborate on airspace issues The Airports Commission proposes building on these forums through: A new Community Engagement Board, that would be established under an independent Chair, with influence over spending on compensation and community support throughout the airport s operations; and The establishment of an Independent Aviation Noise Authority (IANA) with statutory rights to be consulted and a formal role in monitoring and quality assuring all processes and functions that have an impact on aircraft noise, including those of Government and the CAA We are in principle supportive of these new bodies, versions of which have been successful for other national hub airports in other countries including the Netherlands (Schiphol) and Germany (Frankfurt) 66, though we also acknowledge that further work is needed by Government to define and consult on the detail of how both such bodies would work in practice The Airports Commission s final report provides case studies of where these policies have been implemented, demonstrating that the challenges facing Heathrow are not unique and have been experienced and managed elsewhere Our own research has shown that where bodies such as these have been implemented, this has helped to engender trust between the aviation industry and local communities. It has streamlined decisions and encouraged both the aviation industry and local communities to work together. This is why we have reviewed our engagement forums in recent years and have established a Heathrow Noise Forum and a Community Noise Forum The case studies provided by the Airports Commission should provide the EAC with reassurance that these policies are realistic, achievable and effective. 65 APF, paragraph ACFR, paragraph Heathrow Airport Limited 2015 HAL Submission to the EAC Page 30

32 Noise envelope The Airports Commission has recommended that a clear noise envelope be agreed and that Heathrow must be legally bound to stay within the limits defined by it The concept of a noise envelope is part of Government policy as set out within the APF. The Government has made clear in the APF that it believes that a noise envelope would provide certainty to local communities about levels of noise which can be expected in the future and how developers can use their airports 68. The APF states clearly that in the case of any new national hub airport capacity, the Government is likely to develop an NPS that would determine the principles of a noise envelope and that would have regard to: The Government s overall noise policy; Within the limits set by the envelope, the benefits of future technological improvements should be shared between the airport and its local communities to achieve a balance between growth and noise reduction; and The objective of incentivising airlines to introduce the quietest suitable aircraft as quickly as is reasonably practicable The basic concept of a noise envelope is not unfamiliar to Heathrow. We are already subject to a number of legally binding commitments that restrict and cap the amount of noise from our operations. These include: A limit on the area enclosed within the 57 db LAeq, 16hr contour of 145 km 2 to be achieved by 1 January 2016 as set as part of the Terminal 5 planning consent; and Restrictions on the number and noise emission of aircraft operating during the night, as set by Department of Transport In both examples above, we comply with these restrictions and have exceeded them. For example, at present Heathrow s 57 db LAeq, 16hr noise contour is approximately 108 km 2 which is around 25% below our legal obligation We agree with the Airports Commission that setting a noise envelope can help incentivise improved noise performance while giving communities reassurance on future noise impacts. The Airports Commission has indicated that there are a number of ways in which noise can be measured and in which an envelope can be set. We agree and believe that there is a need for constructive dialogue with local communities and industry partners to establish an effective noise envelope We look forward to ongoing dialogue with local communities and with the Government to define an appropriate noise envelope for Heathrow. Aviation noise levy The Airports Commission recommends that a new aviation noise charge or levy be introduced in order to provide long-term funding to compensate local communities 69. We note that the indicative policy of an aviation noise levy is not unique to Heathrow expansion and the Commission has indicated that this would apply to all UK major airports 70. We note that such levies are in place at others airport and believe that the idea is worthy of further study. We also note that, in Air Passenger Duty (APD), the UK already has the highest aviation tax in the world. There is a strong case for eliminating that tax on UK passengers and business, but an alternative would be to use some of the funds raised annually by APD from Heathrow passengers to support mitigation and compensation measures. 67 ACFR, Executive Summary, A Balanced Approach to Expansion Bullet 2 68 APF, paragraph ACFR, paragraph ACFR, Table 16.1 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 31

33 It is also worth noting that The principle of an aviation noise levy has been in place at a number of airports in the form of differential landing charges tied to aircraft noise emissions. We already operate differential landing charges that aim to incentivise airlines to use quieter aircraft. Heathrow was the first UK airport to introduce such charges relating to noise and we attribute some of the progress we have made with our airline customers in reducing the noise of our fleet to these. The general principle of an aviation noise levy is therefore not new and we already use financial incentives to attract quieter aircraft. Night flight ban The Airports Commission has recommended banning all scheduled night flights in the period 23:30 06:00 and points out that this is only possible with expansion At present, current Government restrictions permit aircraft operations within these times subject to a limit on numbers of movements and noise emissions. These restrictions aim to balance the economic benefits that these flights bring against the health and social consequences of the noise they produce In our submission we proposed not to increase operations at night, and to reduce noise at night through the use of quieter aircraft, steeper approaches, and runway alternation We recognise that night flights are a sensitive issue. We currently go beyond Government-imposed restrictions, working with airlines and the aviation industry to introduce voluntary measures such as preventing flights scheduled to land between 0430 and 0600hrs landing before 0430hrs. Furthermore, we do not schedule any departures between 2300 and 0600hrs despite the current Government restrictions providing us with the scope to do so We also recognise that the small number of early morning arrivals each day are significant for arrivals from fast-growing economies in south-east Asia in particular, and create significant benefits for the UK economy We continue to study the detail of the Commission s conditions in consultation with our stakeholders. We are confident that a package of measures can be agreed, including in relation to night flights, that meets the needs of Government, local communities, airlines and those who benefit from Heathrow Airport for employment, business and travel. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 32

34 4. Question 2: What the implications of adopting or not adopting those policies and mitigations are for wider Government policy? We have demonstrated in the above sections in broad terms that the overall thrust of the Commission s proposed approach to carbon, noise and air quality is realistic and achievable (albeit we have noted that in relation to some of the specific conditions proposed we are still in the process of studying the conditions, though we are confident that a package can be agreed that reflects the concerns of all of our stakeholders). Importantly, the Commissions proposed approach is also consistent with, and in some cases exceed, Government policy requirements in the NPPF, APF, NPPG and NPSE. We would expect to see them replicated in an Aviation NPS The Commission s proposed approach is also consistent wider Government policy on sustainable development and the Government commitment to ensure that the planning system does everything it can to support sustainable economic growth The Airports Commission carried out a robust and evidenced process which considered a wide range of economic, social and environmental factors and concluded that the proposal for a new NWR at Heathrow Airport in combination with a package of measures to address its environmental and community impacts presents the strongest case (Executive Summary, ACFR) On this basis, the presumption in favour of sustainable development at the heart of Government planning policy in the NPPF should be applied to give effect to Government policy. As we discuss below, should the Government support the recommended option, any proposal for a third runway at Heathrow would be subject to rigorous and detailed examination through the DCO consenting process, which will consider whether the adverse impacts outweigh the benefits of the proposal. Any detailed proposal for the Heathrow NWR would, therefore, need to demonstrate that its specific impacts were acceptable and compliant with Government policy, and such a requirement can be expected to be reinforced by an Aviation NPS Against this background, we consider whether there are implications for such an approach for wider Government policy. 4.1 Carbon emissions The Climate Change Act 2008 set the commitment of the UK to reduce its net Green House Gas (GHG) emissions by 80% below 1990 levels by 2050 and requires the Government to establish 5-year carbon budgets. Due to the nature of carbon emissions, the Government s policy necessarily spans the whole economy and is formulated to take account of the overall impact of the introduction of abatement techniques across industrial, commercial and domestic sectors. It is an underlying principle of policy development in the UK that carbon emissions are controlled in the most cost-effective manner and that sectors are not penalised when trade-offs can be made between them for mutual benefit Achievement of the UK s GHG commitment in 2050 has been formulated in the context of the need to address total carbon emissions recognising the constraints and potential in different sectors and the interactions between them. Although not currently included in the carbon budgets, international aviation and international shipping emissions are recognised as an item for note. The indicative policies for them are presented by the Airports Commission with a picture that is as integrated as can be achieved at the current time. Abatement incentives in the aviation industry both will and should depend on the outcomes of incentives in other sectors. Equally, benefits from the negotiation of a favourable design of international trading system for aviation emissions have the potential to help other sectors in their implementation of cost-effective abatement strategies The UK s wider planning, aviation and climate change policies with and without airport expansion are to achieve net emissions of CO2 from international aviation that will not exceed 37.5Mt by The Airports Commission has identified a possible "hybrid method for achieving this based on a carbon price that falls within the range Heathrow Airport Limited 2015 HAL Submission to the EAC Page 33

35 proposed by DECC and the introduction of additional abatement techniques. 71 The implications of the carbon price within the DECC range will already be included in Government policy and no additional impacts are expected as a result of the Airports Commission s reliance on the same forecasts. The additional abatement measures are either unique to aviation (operational efficiency) or closely related to it (aviation biofuels) and so are unlikely to be applicable to other. As such, there are no untoward consequences from abatement measures for wider Government policy and there may be favourable effects on supply chains in the UK. 4.2 Air quality In its work, the Airports Commission took full account of relevant Government policy on air quality, including: The European Directive on Air Quality and Cleaner Air for Europe; The Air Quality Standards Regulations 2010; The UK Air Quality Strategy; Local Air Quality Management Plans; The 2001 National Emissions Ceiling Directive; The Gothenburg Protocol; The National Planning Policy Framework; and The National Networks National Policy Statement The Airports Commission s primary objective with regard to air quality was to ensure that legal requirements are met. These relate primarily to complying with the EU Directive limit values, and then the Air Quality Standards Regulations. The Airports Commission was able to satisfy itself that the former requirement can be met with some realistic mitigation measures, and the latter requirement can be met comfortably even without mitigation. As discussed in our response to the previous question, our own independent assessment draws the same conclusions. 4.3 Noise As outlined in our response in Section 3.1 to Question 1, we consider the Airports Commission s indicative policies and mitigations to be fully compliant and consistent with the Government s overall aviation noise policy The Government has set two policy objectives for aviation noise within the APF. These are: to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise; to encourage the aviation industry and local stakeholders to strengthen and streamline the way in which they work together Heathrow s approach in developing our proposals has had these objectives in mind We have developed our plans so that Heathrow can grow without resulting in more adverse noise impacts than it does today We have consulted with our communities and the aviation industry to understand what is important and what can be achieved The Airports Commission has also undertaken similar consultations in undertaking its own assessment and making its recommendations. In both instances however, wider Government policy has been considered As well as setting out its overarching policy objectives, the APF also provides Government policy and thinking with respect to a range of other aviation noise management and mitigation measures, namely: Noise envelopes; 71 Airports Commission, July 2015, Economy: Carbon Policy Sensitivity Test, paragraph 1.14 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 34

36 Airspace design and use, including respite; Information and communication of aviation noise; Night noise; and Noise insulation and compensation The Airports Commission has stated that it undertook its work on noise in the context of the Government s policies as set out in the APF. In its July 2013 fifth discussion paper, aviation noise, the Airports Commission stated that it will: And that carry out its work in the context of the Government s recent Aviation Policy Framework (APF), which sets out the Government s high level objectives on aircraft noise. 72 Recognising that there is still no firm consensus on how to approach issues around aircraft noise, the APF also identified certain areas, including noise assessment, compensation schemes, and the concept of noise envelopes, where the Government wishes to see further work undertaken. The timing of the Airports Commission s work on noise assessments therefore presents an opportunity to contribute to the further work envisaged by the Government, as well as to wider debates on the measurement, assessment, and abatement of aircraft noise. For example, while the Airports Commission s assessment of options to increase UK airport capacity will need to incorporate the approach to noise mapping outlined by the APF, it could also provide opportunities to test additional approaches that might better reflect how aircraft noise is experienced Throughout its work, the Airports Commission has sought to consult and research matters relating to noise. It has welcomed the views of stakeholders and communities in developing its approaches and judgements and has sought to contribute to the further work envisaged by the Government within the policy itself The Airports Commission s indicative policies and mitigations are extensions and developments of the Government s existing aviation and noise policy as set out in the APF. These policies and mitigations are, therefore, consistent with existing Government policies and commitments. 72 Airports Commission Discussion Paper 05 Aviation Noise, July 2013, paragraph Airports Commission Discussion Paper 05 Aviation Noise, July 2013, paragraphs 1.4 and 1.5 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 35

37 5. Question 3: Do realistic and achievable alternatives to those policies and mitigations exist, should the Government adopt the recommended option? 5.1. Carbon emissions Without the indicative policy recommended by the Airports Commission, the target of 37.5 MtCO2 is unlikely to be met by 2050, the consequence of which is that greater reductions would be required form other sectors to enable the UK as a whole to meet the commitment made in the Climate Change Act The driver of a carbon price, through trading or a carbon cap, is necessary to drive the timely delivery of abatement technologies and mechanisms Accompanying their recommendation for a new runway in the South East the Airports Commission stated that even a fully utilised new runway is compatible with continued progress towards reducing carbon emissions, and that putting it elsewhere in the country than the South East would produce a far less efficient outcome in carbon terms (p4, Executive Summary, ACFR) Heathrow s location and its much greater public-transport connectivity (both locally and to the country as a whole) makes it the most efficient location in terms of carbon emissions due to surface access Heathrow is within easy reach of people in London and surrounding regions and is positioned just 12 miles from the demand centroid (Denham in South Buckinghamshire) for air passengers nationally. Over 12 million people live within a one-hour journey time, including 6.7 million within one hour by public transport. Heathrow is already served by an outstanding choice of well-established public transport connections radiating in every direction and lies at a focus of the strategic highway network. Heathrow already hosts the UK s busiest bus station. The addition of Crossrail, Western Rail access and Southern Rail access will bolster this still further Our public transport-led strategy will bring almost 2 million more people within a one-hour public transport journey of the airport. We will also continue to reduce the number of staff driving to work, through the continued work of our Heathrow Commuter Team and significant reductions in staff car parking. These objectives can be targeted because Heathrow is in the right location As well as the surface accessibility, the greater immediate population density makes Heathrow far more sustainable than alternatives as an employment location, whilst its greater sub-regional population (of people and workplaces) makes it a far more sustainable location from which to serve demand. Heathrow s location at the heart of the London and Thames Valley urban network means that it is much more able to sustainably serve and to stimulate further business development Air quality Heathrow s aim is to grow while reducing its contribution to air quality around the airport, helping to keep monitoring sites within legal limits and improving air quality further. Both Heathrow s and the Airports Commission s assessments independently show that this is possible and that an expanded Heathrow would result in fewer people being exposed to poor air quality than today, and would not delay compliance with EU limit values at health receptor locations This is possible as a result of mitigation measures, some of which are already in hand and more of which are already incorporated into our scheme proposal. Our proposals include much of what the Airports Commission has recommended, and more. In our view, our proposals represent and incorporate realistic and achievable policies and mitigations that are supported by the Airports Commission. While alternative policies and mitigation exist, Heathrow s and the Airports Commission s research and evidence points to these being less favourable or effective. Heathrow Airport Limited 2015 HAL Submission to the EAC Page 36

38 5.2.3 In general it is not possible to be prescriptive about other specific mitigation measures that should be followed. The reason for this is that contributions from airfield sources drop off quickly with distance from the airport boundary, and are only significant within a few hundred metres of the airport fence, where there is limited public exposure. It is therefore essential that any measures implemented are taken in collaboration between the airport and other interested parties including local authorities, Highways England and central Government, and after careful evaluation. We have many years of experience of air quality action plans to call on in assessing the effectiveness of different emissions reduction measures In addition, the general situation with air quality is changing quickly. Aircraft engines are becoming cleaner and the fleet mix is evolving. New controls on road vehicle emissions are being introduced. Controls on other sources will reduce background concentrations. It is therefore important that mitigation measures are updated from time to time to reflect changing circumstances Heathrow s current Blueprint for Reducing Emissions, its Surface Access Strategy, and its proposals for the third runway, all take these factors into account and are designed to be effective at controlling and improving air quality. Therefore, these form the most realistic and achievable policies and measures Noise Both Heathrow s and the Airports Commission s assessment confirm that an expanded Heathrow would result in fewer people being exposed to noise than today. Our proposals include much of the mitigation that the Airports Commission has recommended, and more in some cases. For example, we can attract a quieter fleet mix earlier than the date estimated by the Airports Commission. Our proposals therefore represent and incorporate realistic and achievable policies and mitigations that are supported by the Airports Commission. The Airports Commission s overall approach to noise is be fully consistent with wider Government policy While alternative policy principles may exist, both Heathrow s and the Airports Commission s research and evidence points to these being less favourable. For example, Heathrow and the Airports Commission agree that respite is important and fundamental to expansion. The alternative to respite is to concentrate aircraft along as few routes as possible. While the Government indicates that concentration and respite are both options when considering how airspace is used, the APF states that decisions regarding respite or concentration should follow engagement with local communities. Heathrow s own public consultation showed that people favour respite in ratio of 3:1 74. However, acknowledging the Government s policy we have prepared three indicative airspace route options that allow varying degrees of respite to be delivered to communities all in the context of the Government s overall aviation noise policy. In the text below we consider for some of the key noise measures whether alternative policies exist. To minimise and where possible reduce noise impacts As highlighted in Section 4.2, the Airports Commission s indicative policy to minimise and where possible reduce noise impacts is entirely consistent with wider Government policy on aviation noise. This policy is vital to the sustainability of any expansion proposal. The Airports Commission has demonstrated that Heathrow can expand without exposing more people to noise than it does today Both the Airports Commission and the Government s wider policy acknowledges that airports will inevitably result in people being affected by noise and therefore it is imperative that where these impacts occur, they are reduced where possible. Heathrow s proposals are fully costed and mitigated based on what is realistic and achievable. For example, our 700m noise insulation and 300m compensation packages have been fully cost. 74 Taking Britain Further Volume 1, Heathrow Airport Part 2.2 Page 111 Heathrow Airport Limited 2015 HAL Submission to the EAC Page 37

39 Respite and airspace design options We have proposed three indicative airspace design options all prepared within the context of the Government s overall noise policy objective as highlighted below. In addition to these designs, we have proposed indicative operating procedures that provide respite, as discussed in our response to Question 2, in Section Throughout the development of our proposals we have focused on engaging with and listening to input from local community stakeholders. A clear message has been to develop the concept of developing predictable periods of respite. The Airports Commission has identified this. As such, our three indicative airspace options can all be operated to provide respite to communities to differing extents Our indicative airspace designs and operating procedures are by no means fixed. We acknowledge that further work and extensive public consultation and engagement will be required to further refine our proposal. However, options regarding how both the Government s and Airports Commission s policies on respite are delivered exist and are there to be explored. A formal process of Airspace Change will be necessary to give effect to the chosen outcome, led by the CAA and informed by Government policy. Figure 5.1 Diagram of alternative airspace design delivering different noise respite outcomes Both Heathrow and the Airports Commission have assessed these options and have come to consistent conclusions that across all metrics, Heathrow can produce lower overall levels of noise than today. As outlined above, each of our indicative airspace options provides respite and the Airports Commission s analysis indicates that our maximise respite airspace option has some real advantages over the alternatives In summary, Heathrow provides a number of options and alternatives for the delivery of respite all deliverable within the context of Government policy. Noise envelope As outlined above, we agree with the Airports Commission that setting a noise envelope can help incentivise improved noise performance while giving communities reassurance on future noise impacts. The Airports Commission has indicated that there are a number of ways in which noise can be measured and in which an Heathrow Airport Limited 2015 HAL Submission to the EAC Page 38

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