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

Conclusions and recommendations

Air Quality

1.The UK has already breached legal NO2 limits in London for 2017. The High Court has ordered the Government to produce a new plan to tackle air pollution by July 2017, the conclusions of both of the Government’s air quality re-analysis studies are based on the previous, over-optimistic plan. The effectiveness of the Government’s new air quality plan will be integral to determining whether Heathrow expansion can be delivered within legal limits. We are concerned that the timing of the draft NPS consultation means the Government will be unable to carry out a comprehensive re-analysis of the air quality impacts, using the new air quality plan, before the consultation process is complete. (Paragraph 32)

2.The Government must publish such an assessment 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)

3.Since the Government intends to withdraw the UK from the EU before April 2019, there is no certainty about what our legally binding air quality limits will be after 2019. We are disappointed that these limits are not clearly laid out in the Draft National Policy Statement. (Paragraph 33)

4.We encourage the committee scrutinising the NPS to consider this report and its recommendations, and urge the Government to clarify its position in its response to this report. (Paragraph 33)

5.We are concerned about the Government’s apparent reliance on low emission technology to solve the problem of air quality. We do not consider encouraging people to buy ULEVs an adequate response to the significant health impacts of air pollution and we have no confidence that the Government will meet its 60% target. (Paragraph 34)

6.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)

7.The Government has not yet published a comprehensive assessment of the infrastructure requirements of an expanded Heathrow, including an outline of costs, responsibilities and accountability. (Paragraph 44)

8.The Government must publish such an assessment and consult on it before publishing a final National Policy Statement. (Paragraph 44)

9.We reiterate that we foresee legal and commercial risks down the line if clear responsibilities and accountability for meeting air quality targets are not set out at the beginning of the process. For example, Heathrow have said there will be “no more cars on the road” as a result of expansion. (Paragraph 45)

10.There needs to be clarity over how this pledge 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)

Carbon Emissions

11.The headline cost and benefits figures in the Government’s announcement on Heathrow and the draft National Policy Statement assumed a black hole in the 2050 carbon budget that other sectors, such as energy or industry, would have to fill. It also assumed continued participation in the European Emissions Trading Scheme up to 2030, it is imperative that the UK remains within the EUTS or any future European emissions trading scheme. The Government has told us it intends to base its policy on another scenario which incorporates assumptions about the level of passenger demand compatible with managing emissions which are more optimistic than the Committee on Climate Change’s advice. (Paragraph 59)

12.The business case for Heathrow expansions 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)

13.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)

14.The signing of the ICAO agreement is a necessary first step to reducing emissions from international aviation, but it is not sufficient in itself. (Paragraph 61)

15.The Government should reconfirm its intention to participate in this scheme 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)

16.Our interim report noted a significant policy gap between the modelling done by the Airports Commission and meeting the Committee on Climate Change’s advice on aviation emissions. The Committee on Climate Change has repeatedly urged the Government to draw up an emissions reduction strategy for aviation. The ICAO agreement means the Government no longer has any excuse not to do so. In the absence of concrete policy proposals from Government, we cannot assess whether the additional emissions from additional flights to and from Heathrow can be properly mitigated. Expanding Heathrow without drawing up such a strategy would, therefore, be putting the cart before the horse. (Paragraph 62)

17.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)


18.We are concerned that the Government’s National Policy Statement has provided no further clarity on how predictable respite will be achieved or on the specific timings of a night flight ban. (Paragraph 72)

19.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)

20.The stated goal of “fewer people [...] affected by noise from Heathrow by 2030 than are today” shows a lack of ambition. Without Heathrow expansion, local communities would have seen a decrease in aircraft noise as new technology and airspace management techniques were developed. A number of scenarios in the Airports Commission’s technical report showed that an expanded Heathrow in 2030 could be quieter than a two runway airport at the same time. The Government and Heathrow have argued three runways will allow the airport to manage its airspace more efficiently. The NPS does not clearly lay out the nature of the legally binding noise targets and it only compares an expanded airport in 2030 with noise levels today, it does not compare noise levels in 2030 with a two-runway airport at the same time. (Paragraph 86)

21.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)

22.The Government has argued that, with more effective use of airspace and new technology and operational techniques, noise levels will fall. There is a trade-off between carbon emissions reduction and noise reduction. (Paragraph 87)

23.The Government should work with the sector and public to set its priorities. 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)

24.The importance of the Government’s proposed Independent Aviation Noise Authority is demonstrated by the lack of ambitious noise targets and the necessity for a body to enforce the mitigation and compensation measures proposed by the Government and Heathrow. We are concerned that the Government has downgraded the proposed Independent Aviation Noise Authority to an Independent Commission on Civil Aviation Noise. The proposed structure and role of this body would prevent it from having an authoritative role, and may raise questions about whether it is truly independent and credible. (Paragraph 105)

25.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)

26.We are concerned with the inconsistency of the metrics used to measure noise attitudes. The Government has recognised that the level of significant annoyance has reduced and the number effected increased, yet it bases its conclusions on the out of date 57 dB LAeq 16hr contour. (Paragraph 106)

27.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)

28.We continue to support the Airports Commission in its recommendation of a Community Engagement Board, but emphasise that this body must have real influence and act as a bridge between the airport and communities during the NPS process. We question whether Heathrow’s 20 year timetable for rolling out noise insulation is reasonable. We believe that communities affected by noise in 2026 should not have to wait 20 years for insulation. (Paragraph 107)

20 February 2017