Suggested Response Material for Heathrow Third Runway Consultation

West London Friends of the Earth


Air pollution


Air pollution is a massive public health issue, with an estimated 40,000 people in the UK dying every year and 9,500 in London. The courts have found twice, following cases brought by Client Earth, that the government has no tenable plan for bringing air pollution within legal limits.  The judgments were reached without any assumption that Heathrow would be expanded and thereby increase air pollution levels (above the two runway scenario), hence making the government’s stance on air pollution seem even less tenable.


With a third runway, the emissions from Heathrow will be much greater than with two runways.  As passengers and aircraft movements will be about 50% higher with 3 runways than with two, the emissions will be proportionately greater and concentrations of pollutants will be increased.  The revised NPS states that the proposal for a northwest runway at Heathrow has a ‘high risk’ of exceeding legal limits for air quality.




The revised NPS does not fully take into account the impact aircraft will have on people and communities that are newly overflown. The population exposure at high noise levels is 42% higher in 2030 in the new forecasts.


The lack of information around detailed flight paths associated with a third runway at Heathrow is a significant flaw that undermines the credibility of the NPS.


The revised NPS now demonstrates that there is a lowering of the threshold at which significant community annoyance begins to occur.  Nearly 400,000 more people will fall within the noise contour considered to mark the onset of significant community annoyance in 2030.


There is insufficient information in the revised NPS on the length of respite periods that communities will experience should a third runway become operational.  It appears that where there is currently respite for half the time this will typically be reduced to a third.  It should also be noted that one person’s respite is another person’s extra noise (because respite is only possible at one location by having a flight path over another location instead).


Surface Access

There has been a major disagreement about the schemes needed to handle the extra passengers, with the Airports Commission (AC) estimating about £5 billion and Transport for London estimating about £15bn.  DfT lowered the AC estimate to between £1.4 bn and £3.4 bn (after Minister Chris Grayling intervened).  The revised NPS has not included any further analysis of the potential costs to resolve these discrepancies.

Heathrow has offered to fund just £1 bn of the surface access improvements.  This means a large public subsidy will be needed for the remainder.


While a few public transport and road schemes are proposed, the majority of road usage and public transport resulting from a third runway will be on unenhanced roads and public transport.  There will therefore be additional congestion, noise and general harm.  These impacts should have been quantified and included in the estimate of net economic benefit.


Climate Change


The revised NPS includes a significant reduction in CO2 emissions per passenger compared to AC’s estimate, yet does not provide evidence to explain why the current predictions are valid and the previous ones were incorrect.


The increased emissions of CO2 from Heathrow expansion mean that, in order to achieve the 80% cut required by the climate change act, other sectors would have to cut their emissions even more.  The Committee on Climate Change (CCC) concluded that it would be just about possible for aviation to emit 37.5 million tonnes of CO2 pa within the 2050 target.  However, they noted that other sectors would have to cut their emissions by about 85% instead of 80%. This is a very hard ask and there would be a considerable cost to this even deeper cut.  The costs, which are clearly attributable to aviation, have not been included in the NPS.


The revised NPS and Appraisal of Sustainability make it clear that the Government has no

intention of pursuing a ‘carbon capped’ scenario but rather will allow expansion on a carbon

traded basis. It assumes that all the extra emissions will be ‘offset’ by a global trading system to ensure that emissions in other sectors will be reduced by whatever the increase is from aviation. This is a wild and unjustified assumption because a comprehensive worldwide trading scheme is not even on the horizon and because there is extensive evidence that ‘carbon offsets’ are nowhere near 100% effective in capping emissions.


The NPS only considers CO2. However, aircraft emit NOx (nitrogen oxides) and water vapour which are both powerful greenhouse gases when emitted at altitude. (They do not have a significant effect near ground level.)  These impacts have been qualitatively and quantitatively ignored in the climate and economic assessments.




The work of the Airports Commission (AC) showed that if a new runway was not built at Heathrow, the great majority of growth in UK demand would simply be met at other airports, SE and further afield, where is plenty of spare capacity.  Put another way, a new runway at Heathrow stultifies growth at other airports.  The new DfT forecasts conclude the same thing.

The new forecast show that traffic outside London would be reduced by 5.4 million passengers per annum (mppa) at 2030 and 17.3 mppa at 2050.  This is a reduction of 4.3 and 8.5% respectively in total traffic.  The reduction of growth (from 2016 to 2030 or 2050) is a massive 24.4% at 2030 and 42.2% at 2050

Great play is made by the government of the importance of more routes and hence greater “connectivity”.  However the government’s own analysis show there would be less routes with a new runway than without (Table 3.3 of the Updated Appraisal Report).  Only by ignoring shorthaul or ignoring routes where frequency is less than one a day can an increase in routes be claimed.

AC showed that a new runway at Heathrow would reduce substantially (as compared with no new runway) the number of foreign destinations served by other airports, ie a loss of connectivity.  A similar analysis (or presentation of results) has not been carried out a part of this re-consultation but there is no reason to suppose that the same pattern would not emerge, especially as the total destinations from the UK does not increase (see previous paragraph).

Growth at Heathrow at the expense of airports in the regions will concentrate even more economic activity and population in the SE and further unbalance the UK economy.

The AC analysis showed that of the traffic lost, the great majority would be interchange traffic.  This is traffic where foreigners jet into Heathrow and then jet out.  Because they are not staying in Britain, they bring no economic benefit; but they dump extra noise and pollution over the populace near Heathrow.  The government tries to justify Heathrow expansion by defining an objective as ‘maintaining Heathrow’s hub status’.  But no proper economic justification is given of that objective.

The new forecasts show the same.  Of the forecast 29.1 mppa extra traffic at 2030, 18.3 is international-to-international transfers (I-I) ie 63%.  At 2050 15.8 out of 25.8 mppa is I-I ie 61%.

The need for long-haul flights by UK business people to markets such as China is constantly cited by supporters of Heathrow expansion (and now argued as being even more important post Brexit).  But the reality is that such flights represent a tiny proportion of total flights – less than 2% (Table 60 of the revised forecasts).  There is more than enough airport capacity to serve all conceivable needs of business people for the foreseeable future.  There is no evidence that british businessmen (and women) would not fly to China simply because there was not a flight from Heathrow but instead from or via another airport.

The great majority of flights are leisure and great majority of those are taken by affluent people including ‘frequent fliers’.  The main beneficiaries of a new Heathrow runway (apart from Heathrow itself) are the affluent.  The downsides – congestion, noise, air pollution, loss of homes – are felt by primarily by the less affluent who live near the airport.  A new runway is therefore, in terms of equality, highly regressive.

The forecasts of demand on which the entire AC and DfT analyses are based assume that aviation will continue to enjoy tax free fuel indefinitely.  A tax on fuel at the same rate as petrol would raise about £10 billion pa at current rates.  Because air travel is quite ‘price elastic’ demand would be considerably less if there were a tax on fuel.  The reduction in traffic due to a fuel tax is very likely greater than the modest increase in traffic due to a new runway.  The “need” for a new runway is therefore, in a sense, predicated on a tax dodge.  We do not believe that a new runway should be built, with all the devastation it will cause, on the basis of a large and continuing tax dodge.

Economic impacts

Throughout the entire policy process for a new runway, the government and industry lobbyists have claimed there would be huge economic benefits from Heathrow expansion.  This has continued in the current consultation - despite the fact that the extensive analysis and quantified analysis show otherwise.

To assess whether a big, complex project such as a new runway is worthwhile, it is necessary to look at the stream of costs and benefits over many years and then balance all these costs and benefits.  The recognised method is to calculate a ‘Net Present Value’ or NPV.  The great advantage of NPVs is that they take account of all costs and benefits into the future for everyone, not just financial costs and benefits for some of the parties.  For this reason NPVs are the standard measure for large infrastructure projects where the overall cost/benefit to society needs to be assessed.

The key figure for NPV, shown in Table 9.2 (page 44) of ‘Updated appraisal report airport capacity in the south east’, for the Heathrow northwest runway (HNW) is -£2.2 to +£3.3 billion (bn).  This is a downgrading from the already very low net economic benefit derived by the AC and subsequently updated by DfT.   Now it is conceded that the net economic benefit could well be negative.  Even if the benefit is at the top of the range, it is negligible in comparison with the UK economy.  £3bn is a cumulated benefit over 60 years, to be compared with the UK’s economy which is worth about £2 trillion pounds every year.  

The conclusion is profound. By the government’s own admission, there is no demonstrable net economic benefit for a new runway at Heathrow. All the other figures of economic benefit in Table 9.2 and elsewhere in the consultation are misleading (or potentially so) because they all exclude some or all of the costs.

Scope of NPS

The new consultation documents suggest that if a new runway becomes operational in 2026 it would be full by 2028.  This means that, if a third runway at Heathrow were approved there would immediately be a perceived need for a 4th runway.  Given the time from beginning (formulation of policy) to end (operational) of the new runway process, we could be sure the lobbying for a 4th runway would start as soon as the 3rd runway was approved in order that a 4th runway would be available when capacity runs out – namely 2028.

There is no reason to suppose that the underlying policy – “predict and provide” - and the arguments – connectivity, trade, economic benefits – would not be applied all over again.  An NPS and an aviation policy which considers just a 3rd runway and ignores the 4th runway, which could follow just two years later on the basis of demand, is fundamentally flawed.  It misleads the public about all the impacts of expansion by considering only the first part of an expansion programme and for this reason it may be legally unsound.  It is most certainly morally unsound.