Seventh Special Report
The Environmental Audit Committee published its Seventh Report of Session 2016–17, The Airports Commission Report Follow-up: Carbon Emissions, Air Quality and Noise, [HC 840] on 23 February 2017. The Government’s response was received on 21 April 2017 and is appended to this report.
Appendix: Government response
Introduction
The Government welcomes the work that the Environmental Audit Committee (EAC) has done on the subject of airport capacity since the Airports Commission (AC) published its final report in July 2015.
In informing the House of Commons of the Government’s preference for the Heathrow Northwest Runway scheme the Secretary of State for Transport was very clear that “we must tackle air quality and noise, and meet our obligations on carbon both during and after construction”.
The draft Airports National Policy Statement (NPS), laid before Parliament and published for public consultation on 2 February 2017, sets out the requirements that an applicant for a Northwest Runway scheme at Heathrow Airport and associated infrastructure would need to meet in order to gain development consent. These include measures to limit the impacts of noise, air quality and carbon emissions.
The Transport Committee has been appointed by the Liaison Committee to scrutinise the draft NPS, and will publish its report by summer recess 2017. Once the public consultation has closed, the Government will consider all the responses received, along with the report from the Transport Committee. Only then would the Secretary of State lay a final NPS before Parliament, which may be voted on by the House of Commons, after which it could be designated by the Secretary of State.
Air Quality
1.The Government must publish such an assessment [of air quality impacts using the revised air quality plan] alongside the final National Policy Statement, it must work towards a scenario in which all road links affected by expansion have predicted concentrations below the limit value. Whilst the health impact assessment is a step in the right direction, the Government must carry out work to reduce the significant health impacts identified, before construction of the third runway begins. (Paragraph 32)
Response: The Government continues to update its evidence base on airport capacity as appropriate to ensure that any final NPS is based on the most up to date information.
The Government is determined to meet its air quality obligations and to do so in the shortest time possible. We will publish the final UK Air Quality Plan by 31 July. The draft NPS stipulates that final development consent will only be granted if the Secretary of State is satisfied that, with mitigation, the scheme would be compliant with legal air quality requirements.
As far as health impacts are concerned, the draft NPS makes very clear that “in order to be compliant with the Airports NPS, a further project level Health Impact Assessment is required. The application should include and propose health mitigation, which seeks to maximise the health benefits of the scheme and mitigate any negative health impacts”.1
2.We encourage the committee scrutinising the NPS to consider this report and its recommendations, and urge the Government to clarify its position [on post-Brexit air quality limits] in its response to this report. (Paragraph 33)
Response: The Government is aware of the desire for certainty around what exiting the EU means for our environmental policy and legislative framework. That is why the Prime Minister announced last year our plans for a Great Repeal Bill. The Bill will convert EU law into UK law as it stands at the moment before we leave the EU. On 30 March 2017 the Great Repeal Bill White Paper2 was published setting out the detail of our approach to the Bill and how the domestic legal system will work once we have left the EU.
The UK has a long commitment to improving the environment even before it joined the EU; for example the Clean Air Act was introduced in 1956. Our strong commitment to improving air quality will continue after the UK leaves the EU.
3.The Government should work with Defra on an air quality alert system for people who are especially vulnerable to the effects of short-term exposure to pollutants. (Paragraph 34)
Response: Through the Government-funded website UK-Air3, Defra already makes available a five-day forecast from the Met Office on predicted air pollution levels. This allows members of the public, particularly those who are most likely to be affected by such pollution, to take action. This information is also available on the Met Office website, alongside the weather forecast.
UK-Air also provides the most up-to-date information on local air pollution levels using data from the national network of air pollution monitors. Importantly, the website provides Public Health England’s advice on practical actions and steps people can take to minimise the impact of these events.
Defra issues daily tweets from the UK-Air Twitter account, which provide information about current air pollution levels and accompanying health advice. These include details of affected regions and links to regionalised maps. These are routinely retweeted by Public Health England and are followed by journalists who use the information to inform their reporting, as well as health charities and campaign groups who regularly retweet information to vulnerable populations.
During episodes of high air pollution Defra alerts a network of health charities, providing full details of the nature of the episode, its geographical location and anticipated duration, along with links to further information including specific health advice relevant to the episode.
The Government will continue to ensure that members of the public have the information and advice they need to take appropriate action to minimise their exposure to high levels of pollution.
4.The Government must publish such an assessment [a comprehensive assessment of the infrastructure requirements of an expanded Heathrow] and consult on it before publishing a final National Policy Statement. (Paragraph 44)
Response: As part of the statutory planning process responsibility rests with the applicant to provide a detailed Transport Assessment as part of any development consent application and to set out its proposals to mitigate impacts on the surrounding transport network, whether through transport infrastructure or other transport measures.
In the draft NPS the Government has proposed the outcomes it wishes to see, including specific targets relating to public transport mode share and employee travel that the airport would be required to meet. It would be up to the applicant to demonstrate in detail how it would meet such outcomes. However, the work of the AC, and subsequent work, has illustrated a number of improvements to public transport which could support this. Some of these improvements, such as Crossrail, HS2 and improvements to the Great Western and Piccadilly Lines are happening regardless of airport expansion.
Other schemes, such as the planned Western Rail Link to Heathrow, are in development and could be in place before a new runway opens. This would provide a rail connection to the west of the airport. Other proposed schemes such as Southern Rail Access would provide direct access from the airport to the South West Trains network, with connections towards Waterloo and Clapham Junction, and potentially towards Woking and Basingstoke. Southern Rail Access is at an earlier stage of development and a range of options are being considered which would provide a range of benefits to both airport and non-airport users.
Details of any finalised proposals for the Northwest Runway scheme at Heathrow Airport and necessary changes to the transport system will rightly be considered as part of the statutory planning process.
5.There needs to be clarity over how this pledge [that there will be “no more cars on the road” as a result of expansion] will be delivered and monitored, the consequences if it is not met and the implications of that for local authorities’ responsibilities to deliver air quality compliance. (Paragraph 45)
Response: The Government has set out its expectation in the draft NPS that “Heathrow Airport should continue to strive to meet its public pledge to have landside airport-related traffic no greater than today.” The Government has also proposed specific targets on public transport mode share and employee travel. Heathrow Airport will need to set out, and provide evidence, as part of any development consent application as to exactly how it would achieve these. It is the Government’s expectation that, subject to the outcome of the NPS and planning processes, the mode share targets at paragraph 5.16 of the draft NPS would become binding upon the airport.
Lastly, we note that the EAC referred in its report to a Government target for 60% of all new cars to be Ultra Low Emissions Vehicles (ULEVs) by 2030. The EAC has since confirmed that this was an error as the Government currently has no such target. The Government is committed to almost all cars and vans being zero emission by 2050 and will publish an updated strategy on support for the transition to zero emission road transport by March 2018.
Carbon
6.The business case for Heathrow expansion must be assessed against a cost/benefit analysis which uses realistic carbon policy assumptions, in line with the Government’s aviation strategy, and takes account of the resulting impacts on other airports and other sectors of the economy. These must be the headline figures in future Government publications, including the final National Policy Statement. (Paragraph 59)
Response: The Government has reviewed the AC’s work and believes that the carbon scenarios and assumptions on carbon abatement measures used are realistic and that the analysis takes into account impacts on other airports4. None of the AC’s carbon scenarios involves placing additional pressure to reduce emissions on other sectors of the UK economy except as a consequence of carbon price.
7.The Government claims that Heathrow expansion can be delivered within “the UK’s climate change obligations”. The Government has not set out what it means by “obligations”, let alone how it will meet them. It has not decided whether to accept the Committee on Climate Change’s recommendation on limiting emissions from international aviation. It has not decided whether to follow the CCC’s advice on offsetting. The Airports Commission told us the appropriate body to make recommendations on managing aviation emissions is the CCC. It would not be a credible position for the Government to claim that it can deliver Heathrow expansion within emissions limits whilst rejecting independent advice as to what those limits should be and how they should be met. (Paragraph 60)
Response: We have been very clear, including in correspondence with the EAC, that we have not ruled out any of the AC’s carbon policy scenarios. In January 2017, we wrote to the Chair of the EAC, stating:
“[t]he Government has not taken a view on whether to accept the CCC’s planning assumption. The Government remains open to considering all feasible measures to ensure that the aviation sector contributes fairly to UK emissions reductions.”
The upcoming aviation strategy will consider measures to tackle the carbon impacts of aviation.
8.The Government should reconfirm its intention to participate in this scheme [ICAO agreement] from 2021, which is after the date when the Government intends to have formally completed leaving the EU, urge other major emitters, including the United States, to live up to their commitments to participate from the earliest possible date, and work towards strengthening the agreement during its review periods. (Paragraph 61)
Response: The Government agrees with this recommendation. We have stated our intention to participate in the scheme from 2021 and we continue to encourage our international partners to do the same. The UK is strongly in favour of further increasing the ambition of the scheme as it progresses and will work with other States in ICAO to try and achieve this during the review periods.
9.The Government’s aviation strategy should be integrated with the cross-Government emissions reduction plan. It should set out costed policies to either meet the Committee on Climate Change’s planning assumption or to make up the shortfall from other sectors. This decision will have to take account of the limited progress towards decarbonisation outside the energy sector and the likely additional climate change impact of some non-CO2 emissions. Where the Government makes assumptions that are more optimistic than the Committee on Climate Change’s advice it should subject those assumptions to independent scrutiny from industry and the CCC and, if necessary, revise its plans accordingly. This strategy should be available well before the end of the scrutiny period for the draft National Policy Statement and consultation on it should be completed before the National Policy Statement is finalised. (Paragraph 63)
Response: The Government partially agrees with this recommendation. We are working closely across Government on both our plan to reduce emissions through the 2020s and an aviation strategy to replace the Aviation Policy Framework.
The issue of aviation and climate change is much broader than the development of an airport. Aviation is inherently an international industry and climate change is an international challenge. As agreed at the time of the Kyoto Agreement, it is only right that aviation emissions are tackled via concerted international action. It is also right that we take action domestically to reduce the carbon intensity of air travel. The AC considered both international and UK sectoral frameworks for tackling aviation emissions and concluded that any of its three shortlisted schemes for increased airport capacity could be delivered consistently with the UK’s obligations. The Government agrees with the AC’s conclusion and will continue to consider both international and domestic policy measures to tackle the climate change impacts of aviation.
The Government will set out its strategic approach to aviation in a series of consultation papers over the next two years including a paper on the environmental impacts of aviation. This will be an ambitious programme of work and will take some time. We will be consulting widely, both with the industry and with consumers throughout 2017 and 2018 – leading to publication of an Aviation Strategy White Paper in 2018.
The Department has also begun a programme of work to update our evidence on what measures could be used to reduce UK aviation emissions and what the associated costs would be to the UK and society more widely. This is due to be published in summer 2017 and will feed into the Department’s aviation strategy.
Noise
10.The Government must carry out further work on respite which should form part of the NPS process, alongside plans for a live timetable of respite to be published beginning when the new runway is operational. We welcome the Government’s commitment to a 6.5 hour night flight ban. However as the Government’s case for expansion has relied heavily on the Airports Commission’s work; it would appear inconsistent to reject its key recommendation on the precise timing of a night flight ban. The Government must consider this recommendation alongside consideration of the health aspects caused to residents, in line with the requirements of EU Directive 598/2014. (Paragraph 72)
Response: The Government disagrees with this recommendation. It will be for the airport to submit plans for a respite scheme, arrived at in consultation with local communities and other interested parties, as part of its development consent application. Details such as timings, duration and scheduling will need to be defined through consultation with local communities and other relevant stakeholders.
The Government’s expected ban on scheduled night flights of six-and-a-half hours each night at an expanded Heathrow is the same length of time as the ban recommended by the AC and an hour and a half more than the current arrangement. Although at this stage the Government is setting out its expectation of a ban of six-and-a-half hours, international legislation requires consultation before any ban is introduced. The outcome of this process, during which local communities and other interested parties will all get to have their say, will determine the exact details, including the timings of any ban. We are not going to pre-empt the outcome of this process.
Health impacts of exposure to aircraft noise from an expanded airport were assessed by the AC and included in the Appraisal of Sustainability (AoS). The change in noise will have to be further assessed by the applicant for development consent. Proposed changes to UK airspace policy would also require impacts on health and quality of life as a result of noise to be assessed to inform any future decisions on flight paths for a new runway.
11.The Government should publish a comparison between projected three- and two-runway noise levels in 2030 as well as with noise levels now. The Government and Heathrow should work towards a goal of less noise than a two runway Heathrow would create in 2030. (Paragraph 86)
Response: This data was produced by the AC and published alongside its Final Report5. The draft NPS requires the applicant to put forward plans for binding noise performance targets which should be tailored to local priorities and therefore defined in consultation with local communities. We would not want to pre-empt the outcome of this consultation.
12.The Government should work with the sector and public to set its priorities [between carbon emissions reduction and noise reduction]. If the Government plans to rely on future technical improvement to reduce noise impacts, then it must provide the aviation industry with support by setting a clear strategic direction for the industry and guarantee policy certainty for investment. (Paragraph 87)
Response: The Government accepts that there can be trade-offs for aircraft and engine manufacturers between improved fuel consumption and noise reduction, but to make their products commercially viable they have to deliver both. The Government’s existing airspace policy makes clear that noise reduction is the priority at lower levels (below 4,000 feet) and that both noise and carbon should be balanced between 4,000–7,000 feet, with noise no longer a priority above 7,000 feet. Reduced fuel consumption and the introduction of low-carbon fuels will both help to deliver lower carbon emissions from aviation. The Government intends to consider these strategic issues in more detail as part of its work to develop a new aviation strategy.
13.The Government must create an Independent Aviation Noise Authority with an independent chair, the ability to enforce its policy recommendations and the remit to monitor and enforce Heathrow’s commitments to provide respite, including the live timetable; its compliance with night flight scheduling; and the schedule and investment timetable for rolling out the promised noise insulation. (Paragraph 105)
Response: The Government has carefully considered the AC’s recommendation to establish an independent aviation noise authority and has agreed to set up a new Independent Commission on Civil Aviation Noise. The Government is consulting on the functions and governance of this body in the consultation on airspace policy.
14.The Government must ensure that the NPS process is informed by the most up-to-date noise metrics, in light of the Attitudes to Noise Survey we expect the Government to consider 54 dB LAeq 16hr as the onset of significant annoyance. (Paragraph 106)
Response: The Government agrees with this recommendation. The AC assessed noise down to 54dB LAeq and this was also included in the AoS, which accompanies the consultation on the draft NPS. The Government is now consulting on proposals to update how noise is considered, as part of its airspace policy consultation, which reflect findings6 that the same percentage of people are now annoyed at 54 dB LAeq 16hr as were previously annoyed at 57dB LAeq. As a result, we have proposed a lowest observed adverse effect level (LOAEL) above which impacts on health and quality of life should be assessed for the purposes of airspace changes. Our proposed LOAELs are 51 dB LAeq for daytime noise and 45 dB Lnight for night time noise. We have also proposed several other metrics to inform decisions and explain noise impacts on communities, including those which reflect the frequency of aircraft that an individual will be exposed to.
1 Draft NPS, paragraph 1.33
4 Airports Commission Strategic Fit: Forecasts, Chapter 6
26 April 2017