Transport CommitteeWritten evidence from the London Borough of Hounslow (AS 101)

1. Executive Summary

Hounslow represents approximately 256,000 residents and 10,000 businesses operating within the boundaries of this densely populated, socially vibrant and economically dynamic part of west London.

1.1 Aviation policy has a massive impact upon the economic well-being and the quality of life of our community. London Heathrow Airport is an important source of employment and wealth generation for us, both directly and through its use of the local supply chain—over 11,000 Hounslow residents (around 10% of our working population) are employed at the airport.

1.2 Yet through its very size, Heathrow also causes distortion of our local economy, generates serious congestion on our road and rail networks, and produces massive environmental and health impacts in the form of noise and air pollution.

1.3 Thousands of our residents as well as many of our schools and businesses are intensively overflown by commercial aircraft, some of which are a very short distance from the airport’s perimeter fence. Our Borough experiences flights overhead every 90 seconds, and has to endure an average of 16 night flights before 0600, sometimes even more. These night flights have been proven to have a serious affect on the health and well-being of local people as shown by the HYENA study.1

1.4 For the avoidance of doubt, Hounslow Council has absolutely no desire to see the closure of Heathrow or a significant reduction in its volume of air traffic because of the associated economic and employment benefits that it brings to our community.

1.5 Hounslow believes that the only responsible way forward is to manage aviation demand by considering and assessing the costs, including social and environmental costs, of meeting the predicted demand, and then determining if the benefits of meeting demand outweigh those costs. It is only then that a reasoned decision should be made on whether demand should be met in full, met in part or not met at all.

1.6 As a starting point to demand management, Hounslow holds the following as of the highest importance:

Retention of Heathrow’s 480,000 Air Transport Movements (ATM) annual cap;

Retention of runway alternation—no Mixed Mode operations;

No return of the third runway proposal;

Movement towards a complete night flights ban;

Better and more generous mitigation schemes for the effects of Heathrow on residents, businesses and communities; and

Progress towards the incorporation into compacts, regulation and ultimately law of the mitigation of these limits and practices.

2. How to make best use of existing capacity

We would caution the Committee against believing the line promoted by the aviation industry that significant airport expansion is necessary. The previous Secretary of State for Transport and the previous Aviation Minister called for proper evidence for the need of additional airport capacity, if indeed such a need exists at all. They were critical when in office of the lack of substantial evidence provided by the industry.

2.1 A 2011 report by WWF and Airport Watch2 demonstrated that London has greater connectivity to the key centres of business than any other European city, despite having fewer transfer passengers than the four other major European hubs. This study concluded that there is no evidence that an increase in transfer passengers is critical in maintaining Heathrow’s outstanding connections with the world’s business centres. Therefore the key question is not lack of capacity at Europe’s airports but how that capacity is used.

2.2 The argument is consistently made that we must expand in order to maintain connectivity that is essential to businesses. Yet only 30% of passengers at Heathrow are travelling for business purposes. We believe that the value of each flight from Heathrow should be maximised for the benefit of UK Plc. and that this could be achieved through more intelligent routing of aircraft, making best use of airport capacity throughout the country.

2.3 We agree that Heathrow offers a premium product and therefore argue that a premium price should be paid by airlines wishing to fly in and out of it. The CAA has historically kept landing charges at Heathrow low to avoid BAA abusing their monopoly position in the South East, however this monopoly no longer exists. We assert that a deregulation of the landing charges would help to create a truly free market competition for slots at Heathrow and would help other airports to compete effectively for traffic and passengers.

2.4 We believe that Heathrow is an example of market failure in the aviation sector. This is because the rational allocation of the available air transport movement capacity should incentivise the use of the largest possible aircraft, carrying the maximum possible number of passengers, too and from the UK’s principal international hub airport. Instead, capacity is wasted on small short-haul aircraft, general aviation and executive jets that should be displaced to other London airports. Capacity is also wasted on multiple airlines serving the same destinations, often with aircraft that are less than full—a problem especially prevalent on trans-Atlantic routes.

2.5 Evidence suggests that airlines operating in a completely free market will tend to use new capacity to operate yet more flights on existing profitable routes rather than open up new ones. Taking Virgin Atlantic as an example, despite the industry mantra that it is necessary to have more flights to China when newly obtained slots are assigned, Virgin choose to fly to San Francisco, Vancouver and Manchester3

2.6 The key to the rational use of existing capacity is the development of a more transparent secondary market for slots at Heathrow. If airlines really want to be able to operate large aircraft to new destinations, they should be able to purchase the slots from airlines currently running small aircraft to minor cities or half-empty aircraft on over-served routes. The smaller and less busy aircraft could then find new slots at less busy London airports if there is a need for them to operate at all. Existing slot holder should sell these slots at a realistic price.

2.7 The Government should also take a market-oriented look at international treaty obligations, which continue to protect the historic rights of flag carriers on international routes. These treaty obligations could lead to distortions in the market. We support the principle of expanding the UK’s open skies policy initiatives and believe they will help to correct this potential market failure.

2.8 Hounslow desires to use the economic engine of Heathrow to enhance the skills and, therefore, the earnings potential of its local population. As it is Hounslow people who bear the brunt of the environmental impact of Heathrow, we believe it is Hounslow people who should enjoy the best employment opportunities there.

2.9 We assert that Hounslow misses out on greater economic benefits because the vast majority of airline passengers merely pass through Heathrow on their way to or from central London. We believe that the advent of Crossrail will bring Heathrow much closer to central London in terms of journey time, enabling visitors to London to consider using hotels and other facilities in west London during their stays. We wish to work with adjoining Boroughs and the Greater London Authority to maximise the benefits of this new connectivity for Hounslow.

3. Surface access

Congestion on our local road and rail networks generated by the presence of Heathrow is a significant issue. It gives rise to poor air quality, affects community health and limits the ability of our local economy to diversify. High air pollution levels could ultimately attract a fine from the European Union, which may have to be partly met by local authorities such as ours.

3.1 We welcome the benefits Crossrail will bring, which may include an associated reduction in surface congestion, but recognise that it provides a modal shift of only 1% away from road transport.

3.2 For Heathrow to achieve its full potential in terms of passenger numbers, substantial investment in surface access improvements will be necessary. We support the present Government’s initiative on improving rail access to Heathrow from the west and in proceeding with Crossrail but we greatly regret the decision of the Mayor of London to delay all planned improvements to the London Underground Piccadilly Line. We call for an urgent joint effort by the Government and the Mayor to expand the capacity and reduce journey times on this vital artery with new trains and signalling systems.

3.3 To further the sustainable access to Heathrow we are part of a group promoting a revised rail scheme known as Airtrack Lite. This would facilitate heavy rail access from the south of the airport. Unlike the previous scheme this does not have the associated difficulty of extended level crossing down times. We believe this scheme has the potential to provide a step change improvement in the way passengers and workers access Heathrow, thus helping to reduce congestion, reduce carbon emissions and improve air quality.

3.4 We are generally supportive of the first phase of HS2 to Birmingham in particular the proposed sub-regional hub at Old Oak Common. We would like to see this realised as a key sub-regional interchange complete with wider orbital rail links—including integration with the Hounslow loop line. However we are not yet convinced that HS2 will ease demand for new capacity at Heathrow. The supporters of HS2 rightly argue that improved city centre to city centre journey times by rail within Great Britain will reduce the demand for short haul flights. We are concerned, however, that the proposed spur line from HS2 to Heathrow will increase the connectivity of the airport for international travellers beginning and ending their journeys from cities in the UK other than London, thereby undermining the growth plans of airports such as Birmingham, Leeds-Bradford and Manchester whilst stoking demand at Heathrow.

3.5 We believe that the development of a domestic high-speed rail network may contribute towards reducing pressure for the further expansion of Heathrow, and have separately responded to the UK Government’s consultation on this. However, we are concerned that the Government has failed to research this point and reserve our right to object to the HS2 Bill on these grounds.

3.6 Surface access strategies should address modal shift for passengers and workers, especially shift workers who need access to the airport for 24 hours per day. Heathrow needs to be a public transport hub, which should include:

Frequent 24-hour bus services;

Heathrow Express being included within the TfL fare structure, making it a mass transit service rather than a premium product;

The Piccadilly Line upgrade to be brought forward; and

Implementation of a charge for “Kiss and Fly”4 with revenues hypothecated to local public transport improvements.

The aforementioned rail access from the south of Heathrow.

3.7 Equally, surface access to Heathrow needs to address the air quality issue from a strategic perspective. Although the Heathrow Area Transport Forum could be considered by some to be a useful initiative, its air quality sub-group was ineffective. The airport/aviation component of the air pollution concentrations within the Heathrow area needs to be defined and agreed by stakeholders once and for all before more meaningful discussions on resolving this issue must take place.

3.8 The Borough is also compromised when it comes to air quality, with the area regularly breaching EU limit value for nitrogen dioxide of 40 microgrammes per cubic metre expressed as an annual average. We would argue that it is all well and good having a roadmap to dealing with air quality, yet is the implementation of this strategy that is key. Indeed the London Assembly Environment Committee report, Plane Speaking, highlighted that poor air quality leads to 4,000 deaths a year in London and made a series of recommendations that could improve the lives of the community close to Heathrow, including better use of public transport.

4. Improved noise mitigation scheme for local communities

In relation to Heathrow, aircraft noise is Hounslow’s top priority. Our Borough hosts an environment that is probably the noisiest in the UK, indeed Hounslow is currently the fourth noisiest borough in London even before aircraft noise is taken into account. Suburbs of our Borough such as Cranford are situated less than 500 metres from Heathrow’s perimeter fence but the extent of overflying across the whole of the Borough is considerable.

4.1 Government should not allow expansion to go ahead on the basis that technological improvements within the industry will solve all the concerns around noise and air quality. Whilst new aircraft may well be less noisy and less polluting this is offset by the dramatic increase in the number of flights over the last 30 years or so. It is vital that mitigation measures are put in place protect communities and schoolchildren in particular.

4.2 Our stance on this is based on the fact that noise directly affects our residents’ health including the often-overlooked areas of mental health. We feel that this position is justified by current and emerging health related research. There is an increasing body of evidence that night noise has direct consequences for public health. Research from Warwick Medical School published 8 February 2011 in the European Heart Journal shows that prolonged sleep deprivation and disrupted sleep patterns can have long-term, serious health implications which are: increasing risk of heart disease/stroke; high blood pressure and cholesterol; diabetes and obesity.

4.3 Annoyance

In policy terms, Hounslow would like the UK to be consistent with the EU standard of 55Lden in regard to the noise and argue that as this is also the metric used in Heathrow’s Noise Action Plan; it should be the qualification point for noise mitigation and compensation. We believe that airport operators should be referring to the European Environment Agency’s “Good Practice Guide” when developing and the implementing any noise related schemes including those within the Heathrow Noise Action Plan and actions related to mitigation.

4.4 Mitigating Aircraft Noise

The Council’s starting point in relation to the mitigation of aircraft noise is that future developments should not make the current, unacceptable situation worse. This means that we are fundamentally against any increases in runway capacity, which includes a third or a fourth runway. We are also against the introduction of operating practices that worsen the noise environment such as mixed mode. A predictable period of respite is the single most effective noise mitigation measure available. We are equally committed to the preservation of the existing runway alternation pattern and segregated mode operation.

4.5 Mixed Mode

Hounslow is extremely concerned about the “Operational Freedoms” trials at Heathrow, which we fear are a device to introduce Mixed Mode operation by stealth. Notwithstanding this exercise it is Hounslow’s view that improved resilience should be achieved by a reduction in the numbers of aircraft scheduled at Heathrow.

4.6 The present ATM cap was established by the Terminal 5 planning inquiry with the principle aim of protecting the community from aircraft noise. We will strenuously resist any proposal for this to be lifted through either more intensive use of the existing runways via the introduction of Mixed Mode operations or the creation of additional runways. This stance is taken due to the unacceptable environmental and public health impact of such schemes on Hounslow.

4.7 Framework for A Mitigation Scheme for Aircraft Noise

The community surrounding Heathrow has had to live with a noise mitigation scheme that is much less generous than other comparable airports. The Council recognises that BAA has proposed a new scheme but believes the revised boundary is not wide enough to fully redress, mitigate and compensate the effects of aircraft noise upon the local community.

4.8 As stated above, a new noise mitigation scheme should encompass the 55Lden contour and should provide the following:

Maintenance of the annual movement limit;

Establishment of a new contour cap that provides a real incentive for aircraft and airports to improve their noise performance and comply with Government policy;

Introduction of area limits on the higher contour bands for example > 65Lden;

Greater differentials between the landing charges for highest and lowest noise emitting aircraft;

Noise insulation and appropriate ventilation for windows/roofs out to 55Lden;

Noise attenuation, for example the installation of material that reduce sound reverberation in school classrooms;

Examination of new aircraft operating practices designed to reduce community noise;

A revision of the fine system for departing aircraft in terms of noise limits and the levels of the fines;

A review of the operating practices such as continuous decent approach and aircraft arrivals so establish if a fining regime for non-compliance is appropriate;

Greater consideration for the mitigation of ground noise and road noise associated with the travel to and from Heathrow; and

A compensation scheme for local authorities who are obliged to build schools and other public buildings to higher specifications because of aircraft noise.

4.9 Mitigation Scheme Administration

Hounslow would like to engage with BAA on a constructive debate about its noise insulation and mitigation scheme. It has been over a year since Hounslow responded to BAA’s consultation on this scheme and the Borough is still waiting to receive even an informal response from BAA.

4.10 The support given to the community-led body that is responsible for making necessary decisions involved in administering the schools and community buildings scheme is variable at best. It is frustrating that after BAA agreed to provide £25million for this body it has only managed to spend £4.6million in seven years of existence. The Council feels that a lot more could be achieved in providing mitigation, particularly to schools, if more project, staff and administrative resources were supplied by BAA.

4.11 Fines Fund

Aircraft departing Heathrow airport are fined if the noise they create is above a certain level. This scheme was designed to penalise poor flying practices. Historically the fines money has been used for mitigation for example noise insulation or more general environmental improvement projects such as tree planting. Hounslow believes that this scheme is no longer effective as noise level at which a fine is incurred is too low. The fiscal penalty does not reflect the level of community disturbance, as such it should be reviewed, with a view towards making the fines and penalties more stringent.

4.12 Noise and Schools

The RANCH (2005)5 study recognised that schools exposed to high levels of aircraft noise are not healthy educational environments. Aircraft noise also impairs cognitive development in children, specifically reading comprehension. We believe that no child in Hounslow and beyond should suffer any educational deficit because of the fact that they are educated in a school that is affected by aircraft noise. It is vital that noise criteria, as defined by the appropriate British Standard or Building Bulletin standard, can be met. Therefore appropriate insulation must be provided for any premises where education is undertaken.

4.13 Aircraft Noise Mitigation and the Abolition of the Cranford Agreement

The Cranford Agreement prevented aircraft departing from the northern runway to the east over London. As a result of its abolition 15,000 plus households will suffer a 1dB or greater increase in noise disturbance. Residents have bought their homes on the basis that the Cranford Agreement was operating. We believe that a 1dB increase is significant and mitigation/compensation should be available. This would be comparable to mitigation measures available by statute when roads are constructed. We are also concerned about increases in ground noise levels resulting from aircraft taxiing off the eastern end of the southern runway, as this is a new operating practice.

4.14 Night Noise

Night noise from aircraft is the biggest cause of community disturbance and annoyance from the airport. As such it is the Council’s position that a night curfew should be instigated between the hours of 11pm to 7 am, emergencies excepted.

4.15 However, as an interim measure increasing the differential between the largest and smallest landing fees and placing the money into a community fund could achieve massive improvements. During the sensitive times of the day (06:00–07:00 and 22:00–23:00) an additional charge could be added (base plus x £ to all but the quietest types (Quota Count (QC) 0.25). QC 0.25 and below, that fly with at least 90% loading, might be rewarded with a base minus x£ fee.

4.16 For direct examples of the current insulation and mitigation scheme on offer at Heathrow please see the Bureau Veritas report.6 This report, commissioned by the London Borough of Hounslow looks at major international airports in the UK, Europe and world wide and compares the relative merits of each mitigation and insulation scheme. Interestingly it demonstrates that BAA offers far more generous insulation schemes to communities near to the other airports they operate in the UK.

4.17 The Need for Further Research

Aviation policy has for too long been driven in the UK by the aviation industry. Hounslow, therefore, believes that truly independent research is needed to underpin sensible decision-making for the future. Much of this is beyond the scope of hard-pressed local authorities such as ours to resource. Such research needs to include:

A Health Impact Assessment of the presence and activity of Heathrow Airport fully examining the impact on and the provision of services for the community;

A revised UK noise annoyance study or consideration and adoption of more up to date international research;

An assessment of the effect of the use of landing charges as an environmental lever; and

Further research into the effects of aviation emissions on climate change.

25 October 2012

1 Hypertension and Exposure to Noise near Airports (HYENA): Study Design and Noise Exposure Assessment

2 International Air Connectivity for Business, August 2011, WWF & Airport Watch

3 Information obtained from

4 “Kiss and fly” is where passengers are given lifts in private cars by friends or relatives to or from the airport


6 Comparison of airport noise insulation grant scheme, Bureau Veritas, June 2011

Prepared 31st May 2013