Select Committee on Transport Minutes of Evidence

Memorandum submitted by the London Borough of Hounslow


  1.1  The Select Committee extended an invitation to the London Borough of Hounslow (Hounslow Council") to give oral evidence as part of the inquiry into the Work of the Civil Aviation Authority. This memorandum is submitted to the Committee to supplement the oral evidence that Councillor Ruth Cadbury will give on behalf of Hounslow Council at the session on the afternoon of 1 February.

  1.2  Hounslow Council welcomes the opportunity to submit a summary of views on the work of the CAA. Hounslow Council recognises that there is increasing interest in aviation issues and, in particular, aviation related environmental impacts. In 2004, 239,000 people around Heathrow suffered from levels of noise in excess of 57 dB(A), leq,16[1] a level which the World Health Organisation describes as serious annoyance—daytime and evening".[2] Hounslow-specific figures are not available; suffice it to say that more Hounslow residents will suffer this level than any other borough.

  1.3  It is the view of Hounslow Council that the UK's specialist aviation regulator should have a clearer role and enhanced responsibility within the aviation environmental area including the ability to levy a charge allowing the mitigation of impacts. As a local authority representing over 200,000 residents, Hounslow Council submits this memorandum to stimulate a positive engagement with members of the Committee and hopes that a broad consensus can be developed on how to address and counter the effects of aviation related operations at Heathrow airport on the people and environment of West London.


  2.1  Hounslow Council recognises the contribution that aviation has made to the national and regional economy. With 11,500 borough residents directly employed at Heathrow airport and many others in associated employment, the value of Heathrow airport to the local economic environment is appreciated. Furthermore, Heathrow airport has been a catalyst to substantial inward investment in the Golden mile" and the locating of GlaxoSmithKline's European Headquarters in the borough. Hounslow Council therefore has an active working relationship with Heathrow airport and its operators, BAA.

  2.2  Hounslow Council has clearly defined policies, based on the principles of sustainable development and the polluter pays" principle, with respect to relations with Heathrow airport. In summary these are:

    —  That Hounslow Council requires mitigation to be provided to counter-balance the current impact of Heathrow airport operations.

    —  That Hounslow Council will oppose any further development that leads to an intensification of the aviation use of Heathrow Airport, for example through the introduction of mixed mode operation. 13[3]

    —  That Hounslow Council will oppose further developments of runways and terminals due to the negative economic, environmental and social effects on the local community.

    —  That without prejudice to the second and third bullets above, Hounslow Council will campaign for mitigation should any such development occur.

  2.3   In its report on the inquiry into Aviation in 2003, the Transport Select Committee stated that if aviation was to prosper, the public had to be confident that the Government and the industry were committed to minimising real" environmental impacts. The Committee also recommended that the funds from environmental fines should be used to benefit affected communities. It is the view of Hounslow Council that since the publication of this report, any progress on these matters has been extremely slow. Hounslow Council hopes the committee will consider this during its deliberations on the work and role of the CAA. Hounslow Council extends an invitation to the Committee to visit the borough of Hounslow so that Members can experience at first hand the problems our local community face on a daily basis.


  3.1  Hounslow Council understands that the Government directs the CAA to encourage measures to help reduce the environmental impact of aviation. The CAA also provides Government with expert technical advice on environmental matters. Furthermore the CAA has been a member of a high level Whitehall group looking at options for addressing aviation's environmental impacts. Hounslow Council would welcome greater clarity on how the CAA formulates its advice to Government on the environmental impact of aviation including, for example, whether it has a standing list of stakeholders with whom it has regular dialogue. If so, it will be important to establish greater clarity and openness on the nature and frequency of these discussions. If there is such a dialogue it is particularly important that they should involve the communities in the proximity of major airports such as Heathrow.

  3.2  The CAA document; Aviation Industry—Roles and Responsibilities states that the airport operators remain responsible for the environmental impact of their operations and are expected to strike a balance" between the needs of operators and the needs of a local community that may be affected. [4]Hounslow Council certainly agrees on the need for balance, but shares the view and experience of those living in proximity to Heathrow that currently there is a grave imbalance between what the aviation industry wants (and gets) and what local communities need (and want). Successive expansion at Heathrow has not been accompanied with mitigation to Hounslow's satisfaction. For example in relation to noise and the Terminal 5 inquiry, the local authorities submitted a detailed mitigation package and the associated justification. [5]The Inspector saw fit to impose a movement limit for aircraft (a condition that looks very shaky in the current climate) but did not see it as appropriate to impose our other conditions on items such as departure noise fines, noise insulation etc. So, with respect to this matter Hounslow believes that the balance has not been struck. Hounslow would be interested in the CAA opinion on its expectations about balance.

  3.3  The CAA website states that the authority has adopted the Government definition of sustainability, that has the aim of ensuring a better quality of life for everyone now and for the future, and the authority's Economic Regulation Group provides advice to Government on sustainable policies for aviation. Furthermore the CAA Aviation Environmental Co-ordination Group has set the authority's environmental policy objective as: In support of the Government's objectives for sustainable development, and the principle that aviation should fully meet its environmental costs and obligations, the CAA seeks to encourage civil aviation to mitigate the detrimental impact of the industry on the environment, without compromising safety standards." [6]Hounslow Council would certainly agree with the broad thrust of the CCA aim, but would be interested in the actions the CAA undertakes to encourage civil aviation on mitigation, particularly efforts made to mitigate detrimental impacts and the criteria used to monitor improvements.

  3.4  The aim of the review of London airport price controls undertaken by the CAA, has the stated aim of striking a balance between the interests of airport users, airport operations and investment. Hounslow Council understands that at the same time as the CAA is making preparations for the next review, it may also undertake a detailed scrutiny of BAA's projected costs and revenues. Hounslow Council fully agrees with the broad thrust of the CAA's claim but it is far from clear what actions the CAA takes to encourage the civil aviation industry to mitigate the detrimental impacts of the industry. Much greater clarity and openness is necessary here if the local communities around airports are to have confidence in the CAA's stated aims. In particular, the CAA should be required to set, and publish mitigation criteria and targets, and for these to be reviewed at regular intervals. The CAA should also have powers to impose sanctions against airlines and airports which fail to meet these mitigation targets. If the CAA requires additional statutory powers in the area of mitigation and the environment generally, then these should be sought at the earliest opportunity.


  4.1  The main environmental, health and social impacts affecting residents in the borough of Hounslow relate to noise and air quality, surface access, land impacts and transport pressures. All of these aspects of community blight" share a common characteristic in that they are issues for which Hounslow Council has long sought fair and adequate mitigation measures.

  4.2  Hounslow Council acknowledges that there is a national air capacity problem that specifically affects the south-east of England, and recognises the national importance of solving the problem. However both the Council and the community of Hounslow believe that Heathrow has reached the limit of sustainable development and that expansion, be that in the form of a third runway, additional terminals or greater runway utilisation, is not feasible. This view has been arrived at because the environmental effects of Heathrow aviation operations have a detrimental impact on the health and quality of life for residents.


  4.3  The Aviation White Paper suggested that the Government would bear down on noise especially at night. But at the same time it suggests that an increase in the number of night movements may be increased. [7]It should be noted that WHO recommend a noise level for a bedroom of 30dB(A).

  4.4  The Government has stated that it recognises that noise from aircraft operations at night is widely regarded as the least acceptable aspect of aircraft operations. In addition the local community are very appreciative of the operating measures such as runway alternation that give some relief from the noise.

  4.5  On 4 June 2005, the respected medical journal; The Lancet stated categorically that children's educational development was being affected by exposure to aircraft noise. The findings of the Lancet study reflect those of similar studies undertaken in the UK and elsewhere in recent years. The teachers and pupils in schools throughout Hounslow can testify that noise is a serious problem in their classrooms and play areas.

  4.6  As an Authority for Children, Hounslow Council has vigorously pursued the introduction of adequate noise insulation and ventilation schemes for many local schools where school children are affected by aviation noise. Hounslow Council acknowledges there are current BAA insulation schemes on offer to local schools, but remains pessimistic about the level of funding and is disappointed about the lack of any associated ventilation. We are continuing to work on the costs of insulating the schools to the appropriate standard and the current estimate is circa £100 million. In some instances aircraft noise disturbance is so serious that it is believed that some of our schools may have to be rebuilt.

Air quality and transport

  4.7  West London already has some of the poorest air quality in the UK and even the 2003 Air Transport consultation had made clear that a third runway at Heathrow would lead to an additional 21,000 people being exposed to nitrogen dioxide levels which exceeded EU limits. Mitigation measures to address this will require major effort and significant resources. The Air Transport White Paper, paragraph 3.31 states that achieving EU air-quality limits will require a combination of measures" including local authorities, transport bodies and airports limiting road traffic emissions associated with passengers and employees and using increased public transport.

  4.8  As one of the local authorities that borders Heathrow, poor air quality is a significant issue. No suggestion is provided as to who will pay for the said improvements, bearing in mind that the large-scale infrastructure costs required are beyond the scope of local authorities. In the borough of Hounslow, local road and public transport networks are already operating at over-capacity. Capital investment is required to improve public transport links. Construction traffic and the transportation of new passengers and staff using Terminal Five will severely exacerbate the problem. The CAA has a role to advise Government on aviation related infrastructure and should be in discussions with Ministers about adequately developing and financing the local transport infrastructure.

  4.9  Hounslow Council believes that the shift of the UK aviation industry and its supporters toward adopting some of the language of the environmental lobby demonstrates that the detrimental environmental impact case remains a potent argument. To an extent the DfT has recognised and acknowledged that that are many serious issues to be addressed in the Heathrow area. The DfT has laid out clear, specific and largely environmental conditions that had to be met before construction of any third runway could begin. Chapter 3 of the Air Transport White Paper describes the environmental impacts of airports and aviation in some detail. It also places a duty upon airport operators to undertake noise insulation for noise sensitive buildings and to help with moving costs for the worst affected households. Figures 1 and 2 Annex 1 exemplify the levels of noise and air pollution experienced by Hounslow's community.


  5.1  The mitigating measures are often provided as a condition of development within the planning process. There are two problems with this:

    —  Firstly Hounslow is not the planning authority for the airport and therefore its ability to negotiate mitigation on matters such as for example a change in the routing of a taxiway is greatly limited.

    —  Secondly Heathrow's growth is incremental. In 1994 there were 424,600 air transport movements increasing to 460,000 in 2004. There is no formal mechanism for obtaining mitigation for this past growth.

  5.2 Subscribing to the polluter pays principle", Hounslow has made numerous direct approaches to BAA on a variety of mitigation issues only to be told that the airlines will not allow for such payments to be made. BAA has suggested that Hounslow enters into a Compact" similar to the one negotiated between Gatwick and the surrounding local authorities. Such agreements are predicated on airport expansion. The Council has not ruled out this course of action but this avenue is not open to the authority with respect to the current situation. It is for this reason that it is the Councils believes that the CAA should have the ability to levy an environmental charge at Heathrow and use this to rectify the problems outlined above.


  6.1  This paper has attempted to demonstrate the effect Heathrow has on Hounslow's community. There are many benefits of living and working near such a huge provider of jobs; however the environmental factors that accompany this are also immense. To this end, Hounslow believes that the balance between the airport and the community needs to be changed so that the community can take advantage of the economic prosperity whilst enjoying an improved environment.

  Hounslow believes that:

    —  Enough is Enough" and that further development at Heathrow airport is not sustainable.

    —  There should be a stronger and clearer mitigation regime.

    —  The CAA should have a specific environmental remit within its terms of reference.

23 January 2006

Annex 1

Noise Exposure contours for Heathrow - 2004

Air Quality Exceedance Areas - CERC for the London Borough of Hounslow.

1   CAA Report 0501 Noise Exposure Contours For Heathrow-2004. Back

2   WHO Guidelines for Community Noise, Berglund, Lindvall and Schwela. Back

3   The introduction of mixed mode operation at Heathrow means that both runways would be used for departures and arrivals at the same time. This is opposed to the current situation whereby one runway is used for arrivals and the other for departures, and runway alternation takes place on westerly operation. Back

4   Aviation Industry-Roles and Responsibilities Back

5   T5 Inquiry documents LAH 5117R and LAH 5124. Back

6   CAA Sustainable Development And Aviation Environmental Policy Environmental%20Pol Back

7   Night noise consultation. Back

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