Airports National Policy Statement Contents

3Improvements to the Airports National Policy Statement

31.When considering a development consent order, the Secretary of State must take into consideration a variety of conditions, outlined in either the Planning Act 2008 or the relevant National Policy Statement. We want to ensure that, through these conditions, there are sufficient high-level mitigations and safeguards in place to ensure that the NWR scheme properly addresses its likely impacts. We also want to improve the draft NPS to lessen the risk of a prolonged or successful legal challenge at a later point in the planning process. This should also help to reduce the risk that the economic case is eroded over time.

32.Chapter 5 of the NPS covers a range of issues and while we do not intend to discount the importance of all those issues, we have focused predominantly on the conditions of approval associated with air quality, surface access, connectivity, costs and charges, noise, community impacts, resource and waste management. We have carefully considered how the NPS might be improved, including changes to clarify or update the supporting evidence and strengthen or add conditions on consent for any scheme.

Air quality

33.We have recently agreed a report with three other select committees on air quality.74 This is a pressing issue because of the 40,000 early deaths in the UK each year that can be attributed to poor air quality. The political debate around air quality has intensified since the Airports Commission’s recommendations were initially published. We looked at the treatment of air quality issues within the NPS to understand how airport expansion could be achieved without detriment to affected communities, compromising legal compliance, or exacerbating the air quality issues London already faces.


34.The latest figures from the air quality reanalysis show that there are 47,063 properties where annual mean NO2 concentrations are predicted to be higher with the NWR scheme, with 121,377 people affected.75 This figure does not incorporate scheme-level mitigations and a reasonable proportion of these people will experience worse air quality at relatively negligible levels. These figures also only apply to the “Principal Study Area”, which includes the proposed airport site and a 2km perimeter.

35.We received evidence to indicate the traffic impacts from an expanded Heathrow extend beyond this 2km radius.76 While airport related traffic might have a small absolute impact in terms of emissions,77 additional traffic on an already congested network can have a disproportionate impact in terms of creating additional congestion and additional pollution from non-airport related traffic. To only model population impacts within a 2km area seems to be an overly rigid view of the potential population impact of worse air quality. It should be noted the local population impact have not been updated since they were estimated by the Airports Commission in May 2015. They do not account for the latest uplift in demand forecasts and air traffic movements (ATMs) and surface access movements that occur under a NWR scheme and the consequent increase in pollution this would cause. It should also be noted that the population analysis is based on a static number of residents rather than an analysis that includes the population moving through the area.78 The transient population is exposed to significant health risks. Evidence received by our recent joint inquiry into air quality revealed that pollution can, in fact, be far worse inside a vehicle than on the street.79

36.To reflect the health and environmental impacts of air quality, the monetised costs of air quality are estimated within the appraisal. These were initially estimated by the Airports Commission at £958 million, with the damage cost from NOx emissions at £94.2 million. This assumed a damage cost of £875/tonne sourced from Defra guidance. The guidance was updated in September 2015 and the damage cost for NOx emissions relevant to the Heathrow expansion scheme is now £64,605/tonne (in 2015 prices). Adjusting for inflation, this damage cost is around 63 times higher than that used by the Airports Commission. Indicatively, the total damage costs from NOx emissions rises to £5.9 billion, taking the total damage costs to £6.8 billion (including PM10 costs); though for several technical reasons the increase may not be as considerable as that. Nevertheless, in the DfT’s updated October 2017 appraisal, the aggregate damage costs of air quality are 90 per cent lower at £30 million for NOx. It is difficult to see how this can be the case given that the local dispersion modelling has not been updated (or published), and there has been a substantial rise in unit damage costs for NOx. We received expert evidence that cast doubt on the approach taken by the DfT.80

37.Sections of the draft NPS dealing with air quality should be revised before a final NPS is tabled for approval by both Houses of Parliament. We recommend that the population impact estimates be updated to reflect the air quality impacts from the increased number of aircraft movements and surface access traffic that will result from a Northwest Runway scheme. We also recommend the air quality monetisation modelling and results be published to clarify the monetised costs of poor air quality.


38.Air quality is also a matter of legal compliance. The UK’s air quality obligations, which are set out in the 2008 ambient air quality Directive (2008/50/EC), are at high-risk of being breached between 2026 and 2029. Even then, this assumes that the Government air quality measures are implemented effectively. There is very little headroom in the compliance risk that would enable a deviation away from anything but a perfect implementation of the Government’s air quality strategy. The fact that the Government’s plan has been found to be “unlawful”81 on three occasions does not fill us with confidence that its current plan can be delivered effectively to ensure the NWR “capable of taking place within legal limits.”82 While we are encouraged by HAL’s commitment to improving air quality, as evidenced through its “triple-lock”, legal compliance is almost wholly dependent on measures introduced by Government at the national level.

39.While we are satisfied with the current conditions in the NPS with respect to legal compliance, the current interpretation supporting the NPS is that the NWR will be compliant but is deemed a “high-risk” of breaching, with very little headroom out to 2029. We recommend the Government adopts a more stringent interpretation of air quality compliance than what is currently applied by the Department for Transport to support the NPS. This should include an appropriate level of headroom to manage the inherent uncertainty of predicting future air quality compliance. The applicant for a Development Consent Order should be required to show, with a reasonable degree of confidence, that their scheme can comply.

40.The issue of legal compliance must be separated from the health impacts of air quality.83 A scheme may demonstrate legal compliance but may still result in outcomes that harm public health. There are no firm conditions of approval linked to the health impacts of worse air quality. There is a condition on noise approval in paragraph 5.67 of the NPS. We recommend that a condition be included in the NPS to the effect that development consent will only be granted if the Secretary of State is satisfied that the proposed scheme will: avoid significant adverse impacts on health and quality of life from air quality; mitigate and minimise adverse impacts on health and quality of life from air quality; and where possible, contribute to improvements to health and quality of life.

Surface access

41.Passengers, airport workers, airline staff, security personnel, freight operators and many others move on, off and around the airport everyday as an integral part of airport operations. Surface access issues are pivotal to the scheme’s business case and public health concerns arising from worse air quality. We looked at how surface access was addressed in the draft NPS because effective and efficient use of any new airport capacity will depend on good surface access. We were concerned about both the adequacy and cost of the surface access proposals; we were also keen to understand how well the draft NPS drew a distinction between the changes to surface access that were needed to support the airport now and those that would be needed by an expanded airport.


42.The surface access schemes required to support the NWR have not yet been finalised. Several schemes are committed to, including Crossrail, HS2 and the Piccadilly Line upgrades, and several others, including enhancements to the roads network, have been assumed and are based on the work done by the Airports Commission three years ago. These will manage the increase in London’s growing population and provide more surface access options for the current two runway world. But the eventual impact of a NWR on roads congestion and rail capacity is still highly uncertain. The Airports Commission concluded that with the assumed surface access schemes, some segments of the surface access network will struggle to cope with peak demand pressures.84 The DfT’s latest iteration of modelling, which shows that passenger growth will increase much faster than initially expected.85 Such growth would place further strain on the surface access networks supporting Heathrow. Results published in the DfT’s air quality reanalysis indicate that there will be as many as 17% more cars on the road by 2030 than was previously assumed by the Airports Commission.86 TfL modelling shows that even with the committed and assumed schemes, there will be a significant increase of 72,000 passengers using the highways daily, resulting in “congestion and delays for both airport and non-airport users.”87 There has been no comprehensive surface access assessment published by the DfT to understand what the congestion impact on the road and rail network would be with this increased demand.88

43.Schemes such as Southern and Western Rail Access are essential for a two-runway Heathrow, never mind a three-runway airport with an extra 50% capacity. We welcome the commitment to Western Rail Access provided by the Secretary of State when he provided oral evidence.89 We recommend a written commitment of policy support for Southern and Western Rail Access be made by the Government in the NPS, including clarity around funding and the timeline for delivery. We also recommend the Government clarify which schemes are needed to support current two-runway operations at Heathrow and which are needed to support an expanded Heathrow. As part of this, we recommend the Department for Transport’s updated surface access modelling be published so that the likely impact on road and rail congestion of a NWR scheme is known.

44.The DfT concedes that the eventual cost of surface access costs is uncertain;90 though £5 billion91 in surface access costs are incorporated in the appraisal. There was general agreement in the evidence we took that the proposed surface access schemes, which account for the £5 billion, will not be sufficient to cater for the step-change in passenger, airport staff and freight journeys to accompany expansion. In addition to the ambiguities around the total costs, there are uncertainties as to who is going to pay for these. The NPS is clear that HAL will pay for the full cost of M25, A4 and A3044 diversions and roadworks. However, it is vague about the contribution it expects from HAL towards the costs of Western Rail Access and Southern Rail Access, stating only that it would be “expected to make a contribution towards the cost.”92We recommend that the surface access costs in the appraisal, and which support the NPS, be updated and included in the final NPS to reflect the indicative costs of those additional schemes required to deliver on the target of no more road traffic. We are concerned about the absence of detail on proposed changes to the M25. We recommend that the Government work with Heathrow Airport Limited to clarify the proposals and bring greater certainty to the development plans. A key part of this must be the arrangements for diversion of traffic during any works.


45.The NPS currently requires an applicant to take “all reasonable steps to mitigate [surface access] impacts.” It adds that “Where the proposed mitigation measures are insufficient to effectively offset or reduce the impact of expansion … on the transport network, the Secretary of State will impose requirements on the applicant to accept requirements and / or obligations to fund infrastructure or implement other measures to mitigate the adverse impacts.” Provided the applicant is willing to commit to transport planning obligations to satisfactorily mitigate transport impacts, “development consent should not be withheld on surface access grounds.”93

46.While we recognise the intention behind the current condition on surface access in the NPS, we conclude its drafting leaves too much scope for unintended surface access impacts from this scheme. We therefore recommend a condition be included in the NPS that ensures approval only be granted if the target for no more airport related traffic can be met, or that as a condition of approval, capacity be released at the airport, after construction, only when the target is met. This provides a real incentive on the applicant to find innovative ways to encourage modal shift. The condition we propose is not a complete solution. If passengers and airport staff are getting out of their cars and onto the public transport network, clearly it must have sufficient capacity to cope.

Connectivity for the regions

47.An expanded Heathrow needs to deliver not just for the South-East but for the rest of the UK. The anticipated growth in connections to Heathrow is a key reason why the NWR scheme has garnered considerable support from non-London regions.94 We wanted to understand the extent to which the NWR scheme was likely to deliver on these objectives and whether additional conditions in the NPS were needed to provide further guarantees around connections to Heathrow.


48.There are several uncertainties that may prevent the domestic connectivity benefits endorsed in the NPS from being realised. The Government has no real policy levers, outside of public service obligations, to allocate slots to domestic routes at Heathrow. Currently public service obligations cannot be applied at an individual airport level. The eventual domestic route offering at Heathrow will be determined by commercial considerations of the airlines that have the rights to the slots. The number of domestic routes at Heathrow has declined in recent years and it is difficult to see this trend being reversed if airport charges increase post-expansion.95

49.The non-London regions value the direct international connectivity from their own regions.96 While direct international connectivity from the regions will continue to grow in any eventuality, the DfT’s forecasts show that direct international connectivity from the regions97 would be lower with a NWR than without expansion.98 If the NWR scheme goes ahead, there would be 74,195 fewer direct international flights per year to and from airports in the non-London regions in 2030; this increases to 161,893 by 2050 (Figure 5). While the figures at the aggregate level are accepted, individual airports are concerned that the figures for their airport do not accord with their own projections and plans.99

Figure 5: Direct international connectivity, for non-London Airports, various expansion options, annual ATMs (000s)100


50.Given the uncertainty around the eventual domestic route offering at Heathrow, more needs to be done to reassure non-London regions that they will be offered this connectivity once a NWR scheme is delivered. The Secretary of State expressed his desire to “reserve up to about 15% of slots on the new runway for domestic connections” and that “this capacity has to be spread across the day; it cannot be loads of slots at 11 o’clock at night.”101 It is not clear how the Secretary of State intends to reserve slots for domestic connections. We recommend that the Government provide a clear definition in the NPS of what constitutes a domestic route and that the Government outlines more clearly, in paragraph 3.34, how it intends to secure 15% of new slots for domestic connections, including the policy levers it will use to achieve this target. This should also include an explanation as to how the Government intends to deliver these slots in the immediate period after the third runway opens and how it will guarantee these slots are made available at suitable times spread across the day. The Government should also outline how it will enforce Heathrow’s domestic connectivity commitments once a NWR scheme is in operation.

Costs, financeability and airport charges

51.The NWR business case works on the assumption that airlines would absorb any increase in airport charges and passenger demand for the airport would remain unchanged. The evidence suggests that these assumptions are unrealistic102 and the reality is that if airport charges increase significantly, as is assumed in the Airports Commission finance assessment, airline and passenger demand, and subsequent benefits, for the airport would be diluted.103


52.The NPS acknowledges that the Gatwick scheme “would be significantly cheaper” and require a significantly lower “level of debt and equity” than either of the schemes at Heathrow, with the Heathrow NWR the most expensive of the three schemes shortlisted by the Airports Commission.104 Beyond that, almost no mention is made in the NPS of the potential cost and investment risks associated with this scheme.

53.At this stage and in the absence of much of the scheme detail, exact costs for the NWR scheme are unknown. The DfT’s appraisal assumes costs of £17.6 billion.105 HAL has since taken steps to reduce this cost by £2.5 billion.106 Surface access costs have also been estimated at £5 billion,107 though not all this cost will be allocated to HAL. While a degree of optimism bias is already included in these estimates, there are still significant cost risks associated with this scheme, particularly with respect to the M25 reconfiguration.108 There is also considerable uncertainty as to what surface access schemes will be required to support the new runway, how much those schemes will cost and how those costs will be allocated between HAL and the public sector.109

54.We accept that cost accuracies will improve as the project matures, but fundamental aspects of scheme design and surface access remain undefined, creating a perception of a cost risk that is high. There is only one mention of cost in the NPS. This is not a fair reflection of the legitimate concerns of airlines and passengers, who are likely to absorb much of the risk, about the cost of expansion. Before votes in Parliament to approve a final NPS, we would like to see evidence to demonstrate that the Northwest Runway scheme is both affordable and deliverable and that steps are being taken to address the valid concerns we heard in evidence about the high cost of the scheme and the significant risk that costs will rise.

55.Heathrow Airport Limited will need to raise the finance to pay for its scheme. The Airports Commission assumed that HAL would take a corporately financed cash flow approach and that it would raise the money through a combination of debt and equity.110 It estimated that HAL would require additional debt financing between £22.1 and £27.0 billion; and additional equity between £5.5 and £7.0 billion (both in nominal terms);111 this does not cover any contribution to surface access costs.112 Andrew Haines, Chief Executive of the Civil Aviation Authority (CAA), told us it would be “probably the largest privately financed infrastructure project anywhere ever in the world.”113

56.The Airports Commission identified several risks that may prevent HAL from raising the debt and equity required, one being the level of charges it would be able to levy on airports users. The investors surveyed by the Airports Commission believed this risk was manageable, but this was on a presumption that airport charges increase to a potential peak charge of £31 per passenger, with some degree of pre-funding allowed.114 The other major risk was how investment of this scale would be treated by the CAA when determining the costs of capital. This effectively determines the rate of return for any prospective investor. The Airports Commission found that investor interest was there but depended on a stable regulatory structure being in place to enable such returns.115

57.Heathrow’s airport charges are already the highest in the world.116 Both HAL and the Secretary of State expressed a desire to keep airport charges close to current levels in real terms;117 neither was willing to make it a firm condition for planning approval in the NPS. The Secretary of State said it was an issue to be dealt with by the CAA.118 CAA Chief Executive Andrew Haines indicated that “it is plausible to build the infrastructure that is currently proposed and keep costs flat”, despite it being “a bit counter-intuitive” to the historic trends in infrastructure spend and airport charges.119 He said this was down to the historic low levels of cost of capital, which “is a very significant factor in terms of the overall cost. That alone can change the cost per passenger by several pounds.”120 He cautioned that investor interest would be affected if guarantees on charges were included in the NPS.121

58.If the NWR scheme is going to deliver the strategic benefits set out in this NPS, airport charges will need to remain broadly in line with current charges. If airport charges increase significantly, it will either make using Heathrow unaffordable for some passengers; or for those that continue to use the airport, the passenger benefits–which make up over 90% of the economic benefits–will be eroded.122 A significant rise in airport charges could limit the degree of airline competition at an expanded airport. It may also have a detrimental impact on the competitiveness of Heathrow relative to other major European hubs.123 Willie Walsh, Chief Executive of the International Airlines Group, believed that with significantly higher charges, Heathrow would “become a white elephant.”124 Clearly a 50% increase in airport charges, as was assumed by the Airports Commission, is an unacceptable outcome and would be detrimental to the business case for this scheme.


59.It may not be in the interests of passengers to recommend a firm limit on the increase in airport charges at this point of the approvals process.125 Yet anything more than a marginal increase in airport charges is clearly undesirable. We recommend a condition be included in the NPS that airport charges be held flat in real terms but with scope for a marginal increase provided the balance of benefits is in favour of the consumer, as assessed by the Civil Aviation Authority. We recommend that the Government consider whether the CAA has the powers necessary to regulate effectively future airport charges at Heathrow.

60.The financing requirements for this scheme are considerable. While the Airports Commission considered these risks to be manageable, it assumed a 50% increase in airport charges, as well as some degree of pre-funding. This is clearly incompatible with delivery the passenger benefits endorsed as part of the business case. With a condition on charges in the NPS, HAL would be incentivised to make an early judgement as to whether it believes its scheme is financeable. Nevertheless, we recommend that, at an appropriate early stage of the DCO planning process, the Government’s preferred scheme be tested by the Civil Aviation Authority to ensure it is both affordable and financeable. Such as test should offer an opportunity to halt the planning process if it is evident that the proposed scheme has no realistic prospect of being built.


61.The impact of noise from airport expansion is a key concern for affected communities and high exposure to noise causes annoyance, can disturb sleep, and can affect people’s health.126 We wanted to ensure that the noise impacts, outlined in the evidence supporting the NPS, are a fair reflection of what’s likely to occur in practice with a NWR scheme. Noise mitigation must also be a priority and safeguards need to be in place to protected communities from unintended consequences of expansion.


62.Expansion at Heathrow will lead to a rise of around 700 flights per day compared to a no expansion scenario. The NWR scheme is estimated to cause significant annoyance127 for 653,900 people in 2030, as well as 263 noise sensitive buildings.128 This is 92,700 more people than would be impacted without expansion. The NWR scheme will also result in an increase of around 20,000 people impacted by noise levels that are acknowledged by the government to contribute to premature deaths.129

63.These figures are taken from the DfT’s Appraisal of Sustainability that only shows the overall populations affected by noise and the net change in noise exposure at three different thresholds.130 The DfT’s approach nets out the ‘winners’ and ‘losers’ from noise changes. Yet community acceptability is often shaped much more by the ‘losers’ who have a much lower tolerance to equivalent levels of noise to people who’ve been exposed over long periods.131 The presentation of the modelling work using ‘net figures’ presents a slightly skewed picture and does not reflect the political realities of how noise changes will be received by communities. On this basis, a more revealing metric—which is not presented in the appraisal work supporting the NPS—is the gross number of people who will be newly exposed to significant levels of noise annoyance.132 The evidence suggests that over 300,000 people could be newly affected by significant noise annoyance from an expanded Heathrow (Figure 6).133

Figure 6: Number of people newly affected by significant noise annoyance (>54dB), by expansion option, 2030134

64.The noise analysis in support of the NPS is reliant on averaging methods and at thresholds inconsistent with the Government’s own guidance.135 Noise thresholds used by the DfT in the draft NPS are not in-line with its own guidance that accepts the onset of annoyance at 51 dBLAeq. The analysis supporting the NPS does not show the number of people affected at this level, using only the higher threshold of 54 dBLAeq.136 As shown in Figure 7, if the threshold of annoyance was extended down to the 51dB level, an extra 539,327 people would be captured in the annoyance footprint; taking the total number of people in the noise annoyance footprint to over 1.15 million.

Figure 7: Local noise population impacts, at different thresholds of noise, NWR option137

65.It is impossible to know what the exact noise outcomes of a NWR will be without actual flight-paths; there are several uncertainties as to the scale of the noise impacts for people living in and around Heathrow. The impacts shown above are likely to be toward the lower end of the range of possible noise impacts from a NWR scheme. Among other factors, this is primarily because the noise impacts have been modelled using a single flight-path scenario; this does not reflect what is likely to happen in the real world. The noise results also rely on much more optimistic assumptions around the fleet mix that will be operating in and out of Heathrow in the future.138

66.The evidence in the NPS shows that a Northwest Runway (NWR) scheme could have a seriously damaging effect on communities living under and adjacent to flight-paths. Until actual flights paths are known the actual noise distributions resulting from the NWR scheme cannot be known. We believe that the approach taken by the Department for Transport has resulted in an analysis that tends towards the lower end of the range of possible noise impacts. It is right that Parliament and the public have a fair view of the range of possible noise impacts from a NWR scheme. We recommend the noise modelling be updated to reflect a range of possible flight-path scenarios. The results from this modelling should also be presented using a range of metrics and across the full range of thresholds recommended in the latest guidance. We believe it would be helpful if the Department for Transport published the evidence base supporting their assumptions about future fleet mix.


67.The NPS recognises the Environmental Impact Assessment Regulation which requires a scheme proponent to undertake a noise assessment ahead DCO of approval. The baseline of noise for the purposes of the DCO assessment, as defined in the NPS, is the 2013 baseline for the 54 decibel LAeq, 16h noise contour assessed by the Airports Commission. We believe that the 2013 baseline assessed by the Airports Commission may not reflect a true baseline of noise without expansion. One metric of noise, at one threshold, does not constitute a sound basis to assess noise. We recommend that a condition be included in the NPS to ensure noise impacts be measured, during the DCO process, against an updated baseline that incorporates the Government’s latest guidance and assumptions. We recommend that the NPS also specify the noise metrics and thresholds upon which noise will be assessed. These must be consistent with the Government’s updated guidance.

68.At present, the NPS “expects the applicant to make particular efforts to avoid significant adverse noise impacts and mitigate other adverse noise impacts as a result of the NWR scheme and Heathrow Airport as a whole.” Adding that:

The Secretary of State will consider whether the mitigation measures put forward by the applicant following consultation are acceptable. The noise mitigation measures should ensure the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission.139

69.While we agree, in principle, with these conditions, the drafting means that there is too much ambiguity as to what “significant adverse noise impacts” might mean in practice. Without more scheme detail, it is impossible to know what the precise noise impacts of a future scheme will be. It is possible to make a judgement as to what constitutes “significant adverse impacts”. We recommend that the Government defines in the NPS what constitutes “significant adverse impacts” and define an acceptable noise limit that reflects a maximum acceptable number of people newly exposed to noise due to the scheme. With a population noise limit on expansion, there is a safety net for communities going into this process. By setting high-level targets, the incentive is there for the airport to develop its own package of mitigations that will either meet those targets, or seek to minimise noise below those targets.

70.The NPS requires the scheme proponent to put forward plans for a noise envelope. We support this approach and agree that the specific design of this envelope should occur in consultation with local communities and relevant stakeholders. It is important that any noise envelope is subject to periodic review to ensure they remain relevant. The NPS still needs to outline how these noise envelopes will be monitored and enforced. We recognise the role the noise commission will have in assessing noise but it does not appear to have sufficient powers to enforce such an envelope as yet; nor is it currently the CAA’s role to do so.140 We recommend that the Government set out in the final NPS how it intends to regulate any noise envelope and what options for recourse will be available against the airport and/or airlines for breaching such an envelope. Without an enforcement mechanism and the associated incentives, a noise envelope will be nothing more than an ambition.

71.The NPS says that a scheme proponent “should put forward plans for a runway alternation scheme that provides communities affected with predictable periods of respite.” It adds that “the timings, duration and scheduling should be defined in consultation with communities and relevant stakeholders.” It also says that “predictability should be afforded to the extent that this is within the applicant’s control.”141 It should be noted that communities around Heathrow currently have a respite period where planes are not overhead of half the flying day, resulting from a switch in runway. The NPS acknowledges that this will reduce to one third of the day with a NWR; HAL dispute this claim.142 The NPS also states that respite only appears to be necessary, provided “it is within the applicant’s control”. It is not clear what this means. We recommend the Government define a minimum acceptable level of noise respite in the NPS. We appreciate that precise arrangements will be determined once a full consultation has taken place with communities and once flight-paths have been designed; but this provides some reassurance for communities that any application will need to demonstrate how it meets clear standards as it goes through the DCO process. It should then be up to the scheme proponent to design its runway and accompanying flight-paths in such a way that guarantees these minimum levels of acceptable respite.

72.The Government expects a ban on scheduled night flights for a period of six and a half hours, between the hours of 11pm and 7am, to be implemented. The NPS states that “the rules around its operation, including the exact timings of such a ban, should be defined in consultation with local communities and relevant stakeholders.”143 We heard from airlines and commuter groups that there are more flexible ways of dealing with respite than a blanket ban.144 In principle, we endorse a night-flight ban and believe improved and predictable night-respite is long-overdue for nearby communities. However, we believe that the Government’s proposal for a blanket ban of six and a half hours pre-empts the DCO process and the community consultation within that. We recommend that affected communities are provided with a minimum average period of 7 hours of respite a night. The exact timing of this respite should be determined through joint working between the airport, airlines and communities. Evidence received suggest such a scheme would be achievable.145 A future night flight ban should not prohibit unpreventable overruns, in the event, for example, of weather delays. But we recommend a mechanism be established that provides stringent oversight of any night-flight regime to ensure that airlines and the airport are monitored and an effective enforcement regime is in place to incentivise much tighter control of overruns into the night-flight respite period where they are preventable.

Community impacts, compensation and support

73.A NWR scheme will impact communities who will be forced to vacate their homes that will be demolished to make way for the runway. The NWR scheme is expected to result in the loss of 783 residential properties and several community facilities.146 This figure only includes properties within the direct boundaries of the expanded airport. Around 5,500 more lie within the Wider Property Offer Zone boundary (Figure 8) and those residents may have to move out of the area because of new and significantly adverse living conditions.147

Figure 8: Compulsory Purchase and Wider Property Offer Zones148

74.The NWR scheme will also affect the livelihoods of those residents left behind and living adjacent to the airport; the fabric of their communities will change irreversibly. For example, the additional traffic and increased journey times will lead to issues of severance, loss of sense of place, breakdown in community cohesion, and a reduction in the quality of amenity within the community.149 The Health Impact Analysis supporting the NPS shows that a NWR scheme have major adverse health effects on resident, including on selected “children and young people” and “people with living in areas with poor health status”. It also found that is likely that a NWR will “further increase inequalities between a number of vulnerable groups and the general population” and that “a large number of those most affected by the expansion schemes are unlikely to benefit from the opportunities provided.”150 It will also affect the lives of residents living under future flight paths who will either experience worse noise or be newly affected by noise that weren’t affected previously.


75.We acknowledge that for many residents no amount of compensation will be sufficient to replace the homes they might lose, the communities they will be separated from or the very significant changes in lifestyle or livelihood they may experience because of expansion at Heathrow. Compensation is a fundamental component of the package of measures that accompany the NWR scheme. As outlined in the NPS, the scheme proponent “will have to provide an appropriate community compensation package, relevant to planning. This will include financial compensation to residents who will see their homes compulsorily acquired, as well as ongoing financial compensation to the local community.”151 HAL has publicly committed to a community compensation package comprising offers totalling up to £2.6 billion, including an offer to pay 125% of market value, plus taxes and reasonable moving costs, for all owner-occupied homes within the compulsory acquisition zone. It has also committed to paying contributions for acoustic insulation based on a property’s location within the noise contours of an expanded airport. The draft NPS also identifies a community compensation fund of £750 million (a sum of £50 million per annum over a 15-year period) to be distributed to local communities. With respect to the compensation schemes:

The Government expects to see arrangements being made for the community compensation schemes which Heathrow Airport has publicly stated would be provided, and for a community compensation fund.152

76.We support the proposed compensation measures put forward by Heathrow Airport Limited and are encouraged by their willingness to engage with communities. However, we believe it is too early in the process to specify exact sums for compensation when the detail of the scheme and its subsequent impacts remain unclear. The NPS should set the framework and principles upon which compensation will be offered, with the finer details determined during the planning process. With respect to the compensation package identified in the NPS, we recommend that: the threshold for £3,000 in compensation for acoustic insulation for residential properties be revised to reflect the significant noise annoyance thresholds in the latest Government guidance; the £3,000 committed for noise insulation be independently tested during the DCO process to ensure that this is a sufficient sum of money to mitigate properly the increased noise nuisance cause by the scheme; and the 125% offered to compensate residents whose homes are compulsorily acquired be independently tested during the DCO process to ensure it is appropriate and sufficient to cover the repurchase of an equivalent standard of housing at a suitable location. We recommend that the NPS clearly outline that there is no fixed limit on the amount of compensation offered to affected communities provided it meets the criteria set within the designated NPS. We also recommend that the £50m a year figure is increased by RPI each year so that the real terms value of this remains the same for each year of the 15 years.

77.Other measures are required to support communities that must vacate their homes. For example, there will be vulnerable residents, such as the elderly, the unemployed or those with young families, who will need support above and beyond the financial compensation offered to set up their new lives. Supporting measures are also required for those that continue to live in areas adjacent to NWR to ensure those communities can prosper, or at the very least, cope with the changes induced by an expanded Heathrow. The NPS has a condition of approval that the scheme proponent engages constructively with the community engagement board throughout the planning process which is something we fully support.153 But more needs to be done once the planning process is complete to engage with and support affected communities. We recommend that a condition approval be included in the NPS which requires the scheme proponent to develop a strategy outlining how it intends on supporting local communities during and in the extended periods after the planning process is finished. This should be developed in consultation with the communities affected as well as the relevant local authorities.

Replacement of existing facilities

78.The NPS acknowledges that an expanded Heathrow will require the removal of existing facilities in and around the airport, notably two Immigration Removal Centres (IRCs) and the Lakeside Energy from Waste plant. With respect to the IRCs, the NPS has a condition stating that “the Secretary of State considers that replacement facilities in substitution for the affected IRCs should be provided prior to any works which may significantly interfere with the service and facilities provided by the existing IRCs.”154 This effectively provides for their removal and replacement by HAL as part of the DCO process. However, with respect to the Lakeside plant, the NPS only states that:

The applicant should make reasonable endeavours to ensure that sufficient provision is made to address the reduction in waste treatment capacity caused by the loss of the Lakeside Energy from Waste plant.155

79.While it acknowledges that the plant is a consideration in the process, there is no firm obligation on HAL, as a condition of approval, to remove and replace the plant. The replacement and removal of this plant was considered by the Airports Commission to be one of the main delivery risks, alongside the reconfiguration of the M25, and as such concluded that:

Its replacement is not considered an optional component of the scheme. The planning and construction of an Energy from Waste Plant is a substantial exercise in its own right, whose timescales are not substantially shorter than the delivery of new runway infrastructure. The process of planning a provision of an alternative facility would, therefore, need to begin soon after a decision to proceed with airport expansion.156

80.We see no reasons why the Lakeside plant–which is a critical piece of infrastructure for the region and underpins the successful delivery of this scheme–should not be given equivalent treatment in the NPS as the IRCs. We recommend a condition of approval be specified in an updated NPS that provides the Lakeside Energy from Waste plant with equivalent recognition as the Immigration Removal Centres and that the replacement of its facilities be accounted for in the DCO process.

74 Fourth Report of the Environment, Food and Rural Affairs Committee, Fourth Report of the Environmental Audit Committee, Third Report of the Health and Social Care Committee, and Second Report of the Transport Committee of Session 2017–19, Improving air quality, HC 433

76 Heathrow Strategic Planning Group, March 2017 (NPS0075); Q259

77 WSP, 2017 Plan update to air quality re-analysis, Report No 62103867–041-03, October 2017

78 Q494, Qq497–98

79 Fourth Report of the Environment, Food and Rural Affairs Committee, Fourth Report of the Environmental Audit Committee, Third Report of the Health and Social Care Committee, and Second Report of the Transport Committee of Session 2017–19, Improving air quality, HC 433

80 See Annex F for full discussion.

82 Department for Transport, Revised Draft Airports National Policy Statement, p 19

84 Airports Commission, Final Report, July 2015, p 160

85 While it is universally accepted by witnesses that this is an implausible eventuality, that is the planning assumption being used by the DfT and for consistency the rest of the NPS should be judged against that benchmark.

86 WSP, 2017 Plan Update to Air Quality Re-Analysis, October 2017, Appendix B

88 See Annex G for full discussion

89 Q551

90 Department for Transport, Updated Appraisal Report, October 2017, p 31–32

91 In real terms

92 Department for Transport, Revised Draft Airports National Policy Statement, October 2017, p 25

93 Department for Transport Revised Draft Airports National Policy Statement, p 48

94 Qq122–23, Q131

95 See Annex A for full discussion.

96 Q72

97 That is, a direct connection from a non-London UK destination to an overseas destination.

98 Airports Commission, Strategic Fit: Forecasts, July 2015; Q70

99 Q126

100 Department for Transport, Aviation Forecasts, October 2017

101 Q478

103 Q155, Q595, See Annex C for full discussion

104 Department for Transport, Revised Draft Airports National Policy Statement, p 27; See Annex C for full discussion

105 In real terms and at 2014 prices.

107 In real terms and at 2014 prices.

108 Q382, Q581, Q588; For more information, see: Highways England, Strategic Road Network Proposal – Validation of Costs and Delivery Assumptions, October 2016

109 See Annex G for full discussion.

110 Airports Commission, Business Case and Sustainability Assessment, July 2015

111 This includes a profile of scheme capex, coupled with the airport’s core capex, asset replacement, opex RAB depreciation and non-aero revenues

112 Heathrow has expressed its desire to reduce costs by £2.5 billion, this would come off the financing costs. But it has also acknowledged that it has set aside £2 billion for surface access contributions. These will broadly balance out in these figures. There are also uncertainties as to how much Heathrow will eventually have to pay out in noise insulation compensation, this is linked to the flight-paths and the subsequent noise footprint, which at this stage is unknown

113 Q634

114 Airports Commission, Business Case and Sustainability Assessment, July 2015, p 113

115 Airports Commission, Business Case and Sustainability Assessment, July 2015, p 113

116 Leigh Fisher, Review of Airport Charges, 2016

117 Heathrow Airport Ltd (NPS0055); Q522

118 There are wider issues to the effectiveness of the regulatory framework and the CAA in managing Heathrow’s costs post-expansion but this is beyond the scope of this inquiry.

119 Q635

120 Q638

121 Q645

123 See Annex C for full discussion.

124 Q595

125 Q649

126 Department for Transport Revised Draft Airports National Policy Statement, p 51

127 At the 54 dB LAeq,16hr which measures noise for a certain period of time during the day and averages that out by day over several months.

128 Schools, hospitals and religious places of worship are considered noise-sensitive buildings for the DfT appraisal; Department for Transport, Appraisal of Sustainability, Appendix A, A-4 Noise

129 At the 63-decibel contour level

130 >54 dB, >63dB, >69dB Daytime Average Noise.

131 Q306

132 This is an estimate of the number of people who without a runway scheme experienced noise of less than 54dB but with expansion will experience noise greater than 54dB.

133 This is an estimate based on the latest noise modelling by the CAA of the number of people who without a runway scheme experienced noise of less than 54dB but with expansion will experience noise greater than 54dB

134 CAA monetisation workbooks

137 CAA monetisation workbooks

138 See Annex H for full discussion

139 Department for Transport, Revised Draft Airports National Policy Statement, p 54

140 Q647

141 Department for Transport, Revised Draft Airports National Policy Statement, p 54

142 Q418

143 Department for Transport, Revised Draft Airports National Policy Statement, p 54

144 See Annex H for full discussion.

145 Q311, Q630

146 Jacobs, Place Assessment, Prepared for the Airports Commission, November 2014

147 Heathrow Airport Limited, Compensation Schemes, accessed 23 February2017

148 Heathrow Airport Limited, Heathrow Airport expansion consultation document, January 2018, p.49

149 Department for Transport, Appraisal of Sustainability: Appendix A–1 Community, October 2017

150 Department for Transport, Health Impact Analysis, October 2017, p 4

151 Department for Transport, Revised Draft Airports National Policy Statement, p 83

152 Department for Transport, Revised Draft Airports National Policy Statement, p 83

153 Department for Transport, Revised Draft Airports National Policy Statement, p 84

154 Department for Transport, Revised Draft Airports National Policy Statement, p 66

155 Department for Transport, Revised Draft Airports National Policy Statement, p 67

156 Airports Commission, 16. Delivery: Risk Assessment and Mitigation, November 2014, p 21

Published: 23 March 2018