The Airports Commission Report Follow-up: Carbon Emissions, Air Quality and Noise Contents


In November 2015 we published an interim report on the Airports Commission’s recommendation for airport expansion in the South East of England. In October last year the Government announced its support for a third runway at Heathrow Airport, in line with the Commission’s recommendation. The Government has since published a draft Airports National Policy Statement. This report is a follow-up to our first report.

We have seen little evidence so far of the “step change” in the Government’s approach to environmental mitigation which we called for in our interim report. To inform the National Policy Statement process, the Government needs to set out new modelling on air quality following the High Court’s latest ruling and a new approach to air quality post 2019; an emissions reduction strategy that will allow the UK’s carbon budgets to be met and effective noise mitigation measures enforced by an Independent Aviation Noise Authority. The Government must not allow our air quality standards to be watered down as a result of leaving the EU.

On air quality, the Government must produce a new air quality strategy, following the latest High Court judgement, to determine whether Heathrow Airport expansion can be delivered within legal air quality limits. It should set out how it will avoid an increase in the number of serious breaches of EU air quality limits. Surface access is widely considered the main contributor to airport related pollution. There is no agreement about the costs of required access improvements between the Government, Transport for London and local authorities. The Government must produce a fair assessment of the costs of expected transport improvements needed. We foresee legal and commercial risks if monitoring and responsibility for delivering measures such as Heathrow’s “no more cars on the road” pledge are not clearly set out. Such measures will only have credibility if they are legally enforceable.

In our report, ‘The Future of the Natural Environment after the EU Referendum’, we called on the Government to ensure that the UK has an equivalent or better level of environmental protection after we leave the EU. Our air quality standards, which derive from EU legislation, are no exception, and the Government should set out in response to this report, and during the National Policy Statement process, how it plans to maintain or improve upon current air quality standards.

There has been no clarity from the Government on carbon emissions. The Government’s headline cost-benefit analysis for Heathrow expansion is based on a hypothetical international framework to reduce emissions which would leave international aviation emissions 15% higher than the level assumed in the Fifth Carbon Budget (2028–2033).

The Government has said Heathrow “can” be delivered within emissions limits but it hasn’t decided or stated what these limits are. It is considering rejecting the Committee on Climate Change’s advice on the limits that should be adhered to and the level of passenger demand which is compatible with those limits. The Government’s revised aviation strategy must set out its approach to reducing emissions, the target it will work to and the measures it will take to close the policy gap between where we currently are and where we will need to be in each carbon budget period to 2050. If the Government does reject the Committee on Climate Change’s advice on aviation emissions it should set out clearly the resulting additional emissions reduction requirements on other sectors of the economy and the resulting costs to those sectors. These assumptions should be tested with industry and subjected to independent scrutiny by the Committee on Climate Change.

On noise, in order to minimise the impacts for local communities, the Government must follow the Airports Commission’s recommendations on providing predictable respite and the timing of a night flight ban. The Government’s noise targets should be more ambitious and be assessed against the projected impact of a two-runway airport as well as the position today. The need for an authoritative Independent Aviation Noise Authority remains clear.

20 February 2017