At the start of this year, Heathrow Airport Limited (HAL) issued two consultations, covering Airport Expansion and the Principles of Airspace Design.  These are part of the process that Heathrow must go through to gain approval for expansion and for airspace changes that are needed for it.  Additionally, the principles for airspace changes will apply even if a third runway is not built.

The Richmond Heathrow Campaign responded to both consultations in March and our responses can be found on our website.  Our response to the Principles of Airspace Design was particularly critical of the apparent lack of strategy and the vagueness of Heathrow’s proposals. Heathrow have since provided further information on their proposals, to which the Richmond Heathrow Campaign responded in July.

The threats to Richmond are

(i) The potential for flights to take off overhead

(ii) Less hours of respite from the noise of planes coming in to land

(iii) A higher proportion of heavy, noisier aircraft approaching the airport overhead

(iv) A potential increase in night noise

The opportunities include noise reductions arising from improved technology and changed flight operations.

Our response covered Heathrow’s Noise Objectives and Airspace Design Principles, and also recommended an overall decision framework.

Noise Objectives

Heathrow’s Airspace principles currently have three noise objectives:

(a) Limit and where possible reduce the number of people in the UK adversely affected by noise

(b) Share benefits from future noise improvements between the aviation industry and local communities

(c) Strike a fair balance between the negative aspects of noise and the positive economic impacts of flights

The Richmond Heathrow Campaign believes there should be the following two crucial updates to these objectives.

1. Amend Noise Objective (a) to incorporate WHO (World Health Organisation) guidelines, establishing their legal status, and a UK strategy and timetable for meeting them.  In particular, these guidelines recommend that a fixed interval of 8 hours is a minimal choice for night protection from the effects of noise.

2. Add a fourth Community Noise Objective: Where there is a reduction in overall noise the benefit should be applied to those already most affected and where there is an increase in overall noise the dis-benefit should be applied to those already least affected.

Airspace Design Principles

The Richmond Heathrow Campaign’s response also made 13 further recommendations on airspace design principles. These cover safety, flight dispersion, flight frequency, noise respite, flight path separation, flight path concentration and performance based navigation (PBN), less noisy aircraft fleet, ICAO* land use requirements, runway length and parallel operation, ICAO* flight operational requirements, London’s parks, night noise, and altitude based priorities.

* ICAO is the acronym for the United Nations International Civil Aviation Organisation.

Integrated Decision Framework

The Richmond Heathrow Campaign also recommended that there should be an integrated decision framework to bring together design principles and stakeholder interests in order to minimise noise impact the share the costs and benefits of noise mitigation both rationally and fairly.

We continue to play a leading part in the Heathrow Community Noise Forum (HCNF) to reduce the impact of aircraft noise on Heathrow, and to minimise or eliminate the impact of any changes to airspace design.

A more detailed summary of our response, the full response, and a presentation of the response to HCNF can be found here on our website.

The Richmond Heathrow Campaign has continued to work tirelessly on your behalf to oppose the proposals to build a Third Runway at Heathrow. Of necessity our work over the past few years has focussed on responding to Government consultations and lobbying those parts of government involved in the process. In 2018 alone so far, we have submitted seven responses to consultations amounting to over 150 pages of detailed research (link).

Much of our work has aimed to highlight the weakness of the economic and commercial cases for Heathrow. Is the runway financeable, or will we taxpayers be expected to pay up eventually? Is it justifiable, given that according to recent DfT estimates barely any of its activity would be for business passengers and much would cannibalise growth from other UK airports or be wasted in international transfers?  That these ideas are now entering mainstream discussion is at least partly due to our efforts.

On Monday night, the House of Commons voted in favour of Heathrow expansion.  This vote was not unexpected, and in many respects all it does is to initiate the stage where judicial reviews will be sought and popular action planned.  It’s also worth noting that although the Labour Party allowed a free vote, it is now officially opposed to expansion (link).  The SNP, which had originally stated they would vote in favour, abstained.  Time is against Heathrow expansion as more decision makers become aware of the poor case for it.  Our campaign continues.

Richmond Heathrow Campaign communiqué
following the House of Commons Vote on Monday 27 June 2018

It is disappointing that Parliament voted last night in favour of the Government’s National Policy Statement on Heathrow expansion. All the evidence shows a third runway at Heathrow to be a costly mistake, bringing no benefit for UK business connectivity, perpetuating an outdated model of “hub” airports rather than anticipating demand for point-to-point travel, and ignoring the effects on public health from noise and air pollution for the substantial numbers of people living under the flight paths and near roads leading to the airport.

There is a high chance the scheme will not be delivered as Heathrow and the Government face the reality of the financial costs, the impacts on international climate change obligations and the failure to show how legal requirements on air quality can be met

The Richmond Heathrow Campaign (RHC) will continue to work with Local Councils, the London Mayor and others to support the legal challenges which will start now. We base our objections to expansion at Heathrow on the clear evidence against the decision contained in the Government’s own documents which we have examined in great detail. This has been a flawed consultation, failing to look at the facts.

We will also be continuing to look at how Heathrow and the Government can be held to account for promises made to the local community on noise reduction. Heathrow has already formally applied to the Civil Aviation Authority to change the airspace to accommodate more flights. The decisions may take several years and we are actively engaged in the process, having already lodged an objection concerning Heathrow’s lack of proper engagement with local communities and the way flight path decisions are being made.

Whilst most commentators have been focussing on the decision to expand Heathrow, few have noted the significant impact that new flight paths currently being considered will have on thousands of Londoners, with or without Heathrow expansion. Some areas will be overflown for the first time, some will have increased noise and a few less. Decisions on the location of flight paths will be fraught. Communities exposed to arrivals on the southern runway will probably see the 8 hours of daily respite cut in half.

We will continue our fight for a night time ban on flights, no increase in flights in the “shoulder periods” (23.00-23.30 and 06.00-07.00), no loss of respite periods, no increase in noise for those already exposed to noise and a cap on the number of flights and passengers, adequate compensation/mitigation from Heathrow to communities affected by noise and no increase in noise and other pollutants affecting the Royal Botanic Gardens which could threaten its status as a World Heritage Site. We will also continue to campaign for noise limits to be placed on a legal footing, based on World Health Organisation standards so that the public has better protection from the effects of noise on health.

The next stage in the decision process (apart from a judicial review by local authorities and the flight path design) is for Heathrow to prepare a detailed business plan and submit it to the UK planning inspectorate. We expect to participate and strongly object during the course of the planning process over the next two years.

Notes

RHC represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green, and the Kew Society, which together have over 2000 members. The members of our amenity groups are adversely affected by noise from Heathrow Airport’s flight paths, poor air quality and road and rail congestion in west London. We acknowledge Heathrow’s contribution to the UK economy and seek constructive engagement in pursuit of a better Heathrow. We are an active participant in the Heathrow Community Noise Forum.

The RHC has a substantial body of evidence based reports on its website here: http://www.richmondheathrowcampaign.org