heathrow expansion consultation one - interim consultation ... · 20.1.1 in response to airport...

HEATHROW EXPANSION CONSULTATION ONE -

INTERIM FEEDBACK REPORT

VOLUME 3 OF 3

JANUARY 2019

HEATHROW EXPANSION CONSULTATION ONE -

INTERIM FEEDBACK REPORT

VOLUME 3 OF 3

JANUARY 2019

Heathrow Expansion Airspace and Future Operations Consultation

2 © Heathrow Airport Limited 2019 Heathrow Expansion Consultation One - Interim Consultation Feedback Report - Volume 3

CONTENTS

SURFACE ACCESS 5

Introduction 5

Prescribed Consultees 6 Local Authorities 6 Statutory Consultees 16 Other Prescribed Bodies 17

Local Communities 19 Members of the public 19 Businesses 21 Community Groups 25

Wider/other consultees 31

Issues Raised and Heathrow’s Responses 38

AIR QUALITY AND EMISSIONS 137

Introduction 137

Prescribed Consultees 137 Local Authorities 137 Statutory Consultees 142 Other Prescribed Bodies 143




CARBON AND CLIMATE CHANGE 195

Introduction 195

Prescribed Consultees 195 Local Authorities 195 Statutory Consultees 197 Other Prescribed Consultees 197




NATURAL ENVIRONMENT 220

Introduction 220



Prescribed Consultees 221 Local Authorities 221 Statutory Consultees 224 Other prescribed bodies 227

Local Communities 228 Members of the public 228 Businesses 230 Community groups 232

Wider/other Consultees 234


HISTORIC ENVIRONMENT 279

Introduction 279





AIRSPACE 321

Introduction 321





CONSULTATION 354

Introduction 354





Wider/Other Consultees 363


COSTS 392

Introduction 392





PLANNING 417

Introduction 417




Issues Raised and Heathrow’s Response 425

Overview of Ongoing Engagement and Next Steps 443

Introduction 443

Overview of ongoing engagement 443 Prescribed Consultees 443 Local Communities 444 Members of the public 445 Wider Consultees 447

Next steps 448



SURFACE ACCESS

Introduction

20.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback in

relation to the priorities and initiatives proposed for the development of the Surface

Access Strategy and the options for road user charging. A total of 1,139

consultees made comments about the priorities and initiatives proposed to be

used to develop Heathrow’s Surface Access Strategy and 1,606 consultees made

comments about road user charging.

20.1.2 Heathrow provided the following material that is directly related to the Surface

Access Strategy:

1. Airport Expansion Consultation Document; and

2. Our Approach to Developing a Surface Access Strategy.

20.1.3 Heathrow asked the following questions regarding the Surface Access Strategy at

Airport Expansion Consultation One:

1. Please tell us what you think about the priorities and initiatives we propose to

use to develop our surface access strategy.

2. Please tell us what you think about the options to use road-user charging to

reduce emissions and to manage vehicular access to the airport.

20.1.4 This chapter provides a summary of the relevant consultation feedback received

from prescribed consultees, local communities and wider/other consultees. The

issues raised by respondents have also been grouped in table form at the end of

this chapter, which includes Heathrow’s response to these issues. For the

purposes of the Airspace and Future Operations Consultation, we have prepared a

summary of our responses to those issues which are directly related to the

proposals being put forward in that consultation, and how in preparing those

proposals we have had regard to the relevant Airport Expansion Consultation One

feedback. For those issues raised in relation to any other aspects of the Heathrow

Airport Expansion Project (the Project), we have provided a summary of the way in

which we are seeking to consider the issues as part of preparing the detailed

proposals which will be presented as part of the Airport Expansion Consultation

planned for June 2019.



Prescribed Consultees

Local Authorities

General Comments

20.2.1 General comments from local authorities either focussed on the commitments and

priorities of the Surface Access Strategy and modal share targets or sought further

information.

20.2.2 The London Borough of Brent recommended that the priorities of the Surface

Access Strategy should be focussed on those areas where public transport is not

currently used to travel to/from the airport.

20.2.3 Elmbridge Borough Council requested greater clarity on the surface transport

infrastructure proposals for their Borough.

20.2.4 Essex County Council also sought additional information on the wider surface

access network and in particular bus, coach and rail proposals.

20.2.5 The London Borough of Hammersmith & Fulham commented that Heathrow needs

to include local communities in the development of the Surface Access Strategy.

They considered this should include impacts on those communities further away

from the airport.

20.2.6 Hampshire Services who responded on behalf of central and eastern Berkshire

authorities1 stated that the Surface Access Strategy should also take account of

the construction phase.

20.2.7 Hertfordshire County Council considered that a more comprehensive and realistic

picture of collective growth in the sub-region needs to be agreed, to enable an

assessment of the required mitigation measures and the agencies responsible for

delivery.

20.2.8 Runnymede Borough Council suggested that the National Infrastructure

Commission and Department for Transport (DfT) should develop a framework for

delivering the Surface Access Strategy, which considers the complex interfaces

between infrastructure schemes, runway construction, surface access works,

phasing of growth and funding.

20.2.9 South East England Councils highlighted that the productivity of the south east is

supported to ensure that economic growth prospects are not undermined by poor

services. They said that local authorities and Local Enterprise Partnerships (LEPs)

1 Bracknell Forest Council, Reading Borough Council, The Royal Borough of Windsor & Maidenhead and Wokingham Borough Council



have limited funds for transport investment and should not be expected to cover

the costs of improvements or mitigation measures required as a result of the

Project. All mitigation works, including upgrading local road and rail networks,

should be forward-funded by Heathrow, or by Heathrow securing government

funding.

20.2.10 Surrey County Council welcomed the ‘no more traffic’ commitment but said trips by

private car to/from car parks beyond the perimeter of the airport should be

included in the definition of ‘airport related traffic’.

20.2.11 They also expressed concern that there is no integrated strategy for those

travelling to and from the airport or any coherent view on how Heathrow sits within

the wider, national and regional transport network. The London Borough of Harrow

expressed a similar view commenting that the Surface Access Strategy should

consider cumulative impacts on the wider area.

20.2.12 The Royal Borough of Windsor and Maidenhead said the proposals should include

a clear strategic objective for the management of surface traffic associated with

the airport.

Modal share

20.2.13 Buckinghamshire and Essex County Councils, the London Borough of Ealing,

Runnymede and Spelthorne Borough Councils sought clarification on the ‘no more

traffic’ commitment and the areas, roads and traffic types it would include.

20.2.14 The London Boroughs of Ealing and Hounslow both expressed concern with the

proposed monitoring regime for mode shift involving the Heathrow Area Transport

Forum, suggesting that a viable, independent alternative solution is needed.

20.2.15 The London Borough of Hammersmith & Fulham, the London Borough of Harrow

and the Royal Borough of Kingston upon Thames questioned how the share of

passengers accessing the airport via sustainable transport would be achieved.

20.2.16 They also said there was a lack of evidence on whether the proposals would

successfully achieve their aims; they questioned the adequacy of the targets and

whether they were representative of the number of passengers expected to travel

to and from the airport. They also noted that there is no commitment to annual

reporting on performance against the modal shift targets.

20.2.17 Kent and Surrey County Councils expressed general support for the commitment

to mode share targets.

20.2.18 Slough Borough Council and Surrey Heath Borough Council recognised that the

targets could take pressure off the public highway, alleviate congestion on

surrounding road networks and bring about improvements to air quality.



20.2.19 The Royal Borough of Kingston upon Thames and Spelthorne Borough Council

also said that ongoing monitoring of progress towards modal shift targets will be

necessary. The Royal Borough of Kingston upon Thames suggested that there

should be enforcement action for non-compliance and considered that the modal

shift estimates were optimistic.

20.2.20 Runnymede Borough Council questioned why the mode share targets are so low.

20.2.21 Slough Borough Council commented that there needs to be clarity on how and

where the modal shift targets will be monitored, assessed and reported.

20.2.22 Spelthorne Borough Council stated that the Surface Access Strategy should

contain specific targets to maximise journeys to the airport by public transport,

cycling or walking.

20.2.23 The London Borough of Sutton stated that the Surface Access Strategy appears

too “road and car-focused” and that increasing rail and bus mode share is not

given enough priority.

20.2.24 Wokingham Borough Council requested clarification on the definition of public

transport, the monitoring arrangements and the consequences of failure to meet

targets.

Putting Heathrow at the heart of the rail network

General Comments

20.2.25 Elmbridge Borough Council stated that the growth of the airport should be

conditional upon substantial investment and the provision of major rail investment.

20.2.26 London Borough of Harrow stated that Heathrow should help deliver the West

London Orbital Rail Link and provide assurance of service frequency and reliability

improvements for the Piccadilly Line to Uxbridge.

20.2.27 Kent County Council welcomed the commitment to the Western and Southern Rail

Links but said Heathrow should lead these projects. They also suggested that

Heathrow should incentivise use of the Elizabeth Line with special ticketing as part

of the Surface Access Strategy.

20.2.28 The South East England Councils stated that rail transport should be given equal

priority with road, to resolve gaps in public transport. They also considered that the

Project should not be used to delay investment in surface access improvements to

the airport that are already developed and needed.

20.2.29 Spelthorne Borough Council stated that existing public transport improvements

deal with existing demand created by a two-runway airport, not to cater for the

Project. They said no commitment has been made by Heathrow to public transport

that will meet the needs of an expanded airport, particularly to the south. A similar

view was shared by the London Boroughs of Brent, Ealing and Hounslow.



Western Rail Link

20.2.30 The London Borough of Brent expressed concern that there are no alternatives

proposed for the Western Rail Link if it does not go ahead. They also suggested

that any extended hours on the Elizabeth Line need to be implemented in

conjunction with extended hours on public transport within London, to ensure that

people can complete their journeys.

20.2.31 Buckinghamshire County Council expressed a similar view commenting that early

planning and investment in the Western Rail Link and other rail projects will be

required well before the runway is completed, to avoid an increase in road traffic.

20.2.32 Reading Borough Council expressed concern about the lack of commitment to

ensuring delivery of the Western Rail Link in a timely manner. They considered

the construction of the Western Rail Link should be completed in advance of

construction for the Project, to mitigate disruption and enable significant modal

shift to take place.

20.2.33 Slough Borough Council expressed support for the Western Rail Link and

indicated that Heathrow should agree the contribution to provide certainty over its

delivery.

20.2.34 South Bucks District Council commented that the Western Rail Link and Elizabeth

Line will improve access and provide quicker journeys for residents close to

stations, such as Iver and Taplow.

20.2.35 Wokingham Borough Council considered that the Western Rail Link is the priority

infrastructure project and welcomed Heathrow’s commitment to contribute to the

scheme.

Southern Rail Link

20.2.36 Bracknell Forest Council expressed support for the Southern Rail Link.

20.2.37 Ealing Council commented that a Southern Rail Link is essential to help relieve the

Crossrail and Piccadilly lines, and raised concern about the number of competing

options being promoted. They suggested a need for an objective analysis of all the

options.

20.2.38 The London Borough of Hounslow expressed concern that no new rail connectivity

is proposed and considered it implausible that no more traffic on the road can be

delivered without improved rail access from the south. They also expressed

concern that the targets around the shift to public transport are not considered to

be reliant on the implementation of the Southern Rail Link.

20.2.39 The Royal Borough of Kingston upon Thames also expressed support for the

Southern Rail Link and recommended that an extended scheme is investigated

which involves tunnelling through to Wimbledon, rather than just to Kingston. They



identified that contributions towards the costs of major rail schemes will need to be

secured and without sufficient investment in the public transport network, negative

impacts will result on the road network over a wide area.

20.2.40 London Borough of Lambeth considered that a direct rail link between London

Waterloo and Heathrow with a stop at Vauxhall has the opportunity to reduce the

number of car journeys to the airport.

20.2.41 Runnymede Borough Council expressed concerns about ‘barrier downtime’ at

level crossings associated with the Southern Rail Link in the Borough and the

likely knock on effects on congestion and air quality.

20.2.42 Spelthorne Borough Council commented that the Southern Rail Link is needed to

deliver the ‘no more traffic on the road’ pledge and without it there will be more

traffic congestion. They considered Heathrow should support and commit to help

pay for the Southern Rail Link but said there is an opportunity for a ‘Super Public

Transport Levy Fund’ to support funding of major surface access schemes and

fund sustainable transport projects.

20.2.43 Surrey County Council stated that the Southern Rail Link is needed now to

address poor public transport links to the south of the airport, encourage modal

shift and reduce air pollution from congestion and emissions. They considered

that a scheme that enables connectivity between Surrey and Heathrow should be

a key element of the Surface Access Strategy and should be delivered before a

new runway is operational.

20.2.44 Waverley Borough Council expressed concern that there is no commitment from

Heathrow to fund the Southern Rail Link and that the proposals do not include a

direct link with Woking. They stated that a more direct southern access rail link

from Woking to the Airport would provide the greatest accessibility improvement

for residents and employees within this area of Surrey and Hampshire and would

provide a realistic alternative to the use of the private car.

Providing a public transport led scheme

20.2.45 Bracknell Forest Borough Council said their area is poorly served by sustainable

transport access to the airport. They considered that improvements to sustainable

transport modes need to be implemented before the Project is complete.

20.2.46 London Borough of Brent supported the focus on public transport but questioned

the commitment to its delivery. They welcomed the intention to align employment

and public transport but considered there is a lack of incentives to reduce car use.

20.2.47 Buckinghamshire County Council supported Heathrow’s aspirations to develop the

public transport network and identified potential for services to feed into

Buckinghamshire using key transport hubs. They stated that they are keen to

work with Heathrow to ensure that hub locations are appropriately located to

enable airport related employees to travel by public transport. The Council also



noted that the Elizabeth Line and the Western Rail Link would support new and

enhanced bus services to these rail stations from Buckinghamshire.

20.2.48 London Borough of Islington considered that flights should be timed to depart and

arrive at times when public transport is available and any increase in airport

capacity should be subject to the provision of additional public transport capacity.

20.2.49 Royal Borough of Kingston upon Thames said that access by road, rail and other

public transport to the airport needs to be high quality, efficient and reliable for

both passengers and workers and it must maximise the number of journeys to the

airport by sustainable forms of transport.

20.2.50 Reading Borough Council expressed support for the development of public

transport initiatives for both passengers and staff. They stated that for the targets

to be achieved, Heathrow will need to demonstrate support for a step change in

public transport provision to the airport.

Providing a resilient and reliable road network

20.2.51 Buckinghamshire County Council identified the following key areas on the highway

network requiring mitigation: Beaconsfield; Burnham; Iver (including the Five

Points Roundabout and to address the poor road traffic accident record); Iver

Heath (Willow Lane); and north/south connectivity via High Wycombe and to

Aylesbury.

20.2.52 Kent County Council stated it was unacceptable for the Project to have a

detrimental effect on the road network as it would not only impact airport users, but

also other users of the road network, including local communities and freight

companies/hauliers.

20.2.53 The London Borough of Lambeth commented that the motorway network around

Heathrow already suffers from congestion and high pollution levels. They said that

the Project should address this by providing measures to combat congestion and

pollution, and encourage sustainable means of travel.

20.2.54 Reigate and Banstead Borough Council raised concerns about the impact on

transport routes such as the M25 and the North Downs Line if appropriate

mitigation is not put in place. They also said Highways England had concerns

about the impact of future development on the M25 South West Quadrant and

southern stretches of the M25.

20.2.55 The South East England Councils considered that there is a need for a fully

integrated strategic transport network to ensure that non-airport ‘through’ traffic

has access to viable alternative routes as the Project would impact on the M25

and surrounding roads.

Strengthening the coach hub at Heathrow



20.2.56 The London Borough of Brent, Kent County Council and Surrey County Council

expressed support for strengthening the coach hub. The London Borough of Brent

also stated that a commitment should be made to improve links to areas with low

public transport use.

Investing in local transport solutions

20.2.57 London Borough of Brent said buses play a vital role for trips in the local area.

They welcomed the provision of new express and shuttle bus services

commenting that these will need to be frequent enough to attract people from their

cars. They also welcomed collaboration with Heathrow to develop strategic bus

routes and ‘demand responsive services’.

20.2.58 Buckinghamshire County Council requested bus and coach services towards

southern Buckinghamshire are reviewed for additional stops and route additions

within the final 10 kilometres to Heathrow. They also suggested Heathrow

identifies the need to provide on-demand services within southern

Buckinghamshire.

20.2.59 Ealing Council suggested that Heathrow investigate bus rapid transit to local areas

(Southall, Greenford, Northolt) aimed at employees living locally, as well as

demand responsive bus services.

20.2.60 The London Borough of Harrow stated that Heathrow should provide assurances

in relation to service reliability for the 140 bus service (capacity and frequency) or

introduce a new bus service/s to cope with the forecast increased demand.

20.2.61 The Royal Borough of Kingston upon Thames suggested an increase in the

frequency of the X26 express bus service on its route between the airport and

West Croydon.

20.2.62 Reading Borough Council stated the proposed expansion of bus routes ignores

those running outside the Greater London area to the Thames Valley. They

suggested the relocation/rebuilding of roads such as the A4 should include the

provision of dedicated bus lanes in each direction on the approach to the airport

campus. They also suggested that bus lanes should be in place for the

construction period and could provide support for bus services to serve shift

workers.

20.2.63 Slough Borough Council said Heathrow must help to fund/support mass rapid low

emission transport schemes to improve the links and journey time to the airport.

They also stated that these services must be located where demand is and that

the number of shuttles operating from hotels should be limited with mass rapid

transit facilities used to access the airport.

20.2.64 South Bucks District Council expressed a similar view, commenting that

consideration should be given to priority lanes for coaches and buses to speed up

journey times and ensure reliability. They suggested that if the Project generated



HGV traffic, in addition to that generated by other major infrastructure schemes in

the same area, Heathrow should make a significant contribution to the cost of the

Iver Relief Road. They also stated that the cumulative impact of these schemes

be addressed.

20.2.65 Spelthorne Borough Council also stated that Heathrow must commit to paying

capital and revenue costs for the introduction of regular and quick bus routes to

and from the areas to the west and south.

20.2.66 Surrey County Council queried whether ‘on-demand services’ which are a cross

between private taxi and public bus should be defined as public transport. They

also requested engagement with Heathrow on how bus services might be

enhanced and improving the local cycle network.

20.2.67 Wycombe District Council commented that consideration should be given to other

schemes to enable use of more sustainable transport modes such as the High

Wycombe rail connection to Old Oak Common, coach links to Handy Cross hub

and re-opening of the High Wycombe to Bourne End heavy rail line.

Making public transport easier for users

20.2.68 London Borough of Brent suggested that better advertising and information about

the free travel zone is required and a review of the pricing structure for public

transport to the airport is needed.

20.2.69 London Borough of Hounslow considered that more attention should be given to

inter-urban coach services rather than local buses. They expressed concern about

the frequency and timing of local services and a lack of detail on how Heathrow

will engage with the industry to improve frequencies to at least five an hour. They

suggested that Heathrow should be required to pay for enhanced service levels.

20.2.70 Kent County Council stated that making all public transport options easier for

users is essential to transfer mode share away from the private car. They

suggested that integrating ticketing for onward travel could create a seamless

journey for passengers.

20.2.71 Reading Borough Council considered that enabling passengers and employees to

obtain reasonably priced, flexible tickets incorporating free or discounted surface

access public transport tickets as part of an airline ticket package, would make

public transport more attractive.

20.2.72 Spelthorne Borough Council agreed that affordable and convenient transport

choices for employees and passengers are critical to achieving sustainable

surface access. They highlighted that Heathrow must consider the future

workforce and encourage a greater spread of employees with an equitable choice

of transport modes.

Enabling more efficient and responsible use of the road network



20.2.73 The London Borough of Brent said that further analysis should be undertaken

about how road user charging would reduce emissions and vehicle numbers, and

that any scheme needs to be simple with viable alternatives.

20.2.74 They also stated that all Heathrow related vehicles should be low or zero emission

and expressed support for measures to reduce the number of taxis and private

hire vehicles that travel to/from the airport empty, and that these should not be

defined as public transport.

20.2.75 Buckinghamshire County Council stated that Heathrow needs to make the case

that road user charging will not be used to increase income for the airport through

displacing traffic and parking. They suggested that if it is seen to be used to fund

public transport links to transport hubs with dedicated parking sites, then a

charging approach would have greater support. They also indicated that the

proposed environmental zones (uLEZ) need to be designed to ensure that any

impacts or benefits are effective and offset all potential emission source increases,

including from aircraft.

20.2.76 Buckinghamshire County Council also said that HGVs are a key issue for the Iver

community and welcomed Heathrow working with local communities and the

freight industry ahead of the Project.

20.2.77 Ealing Council and Hounslow welcomed the proposal for road user charging and

indicated their preference was for a graduated approach covering:

1. emission-based parking charges in Heathrow’s controlled car parks;

2. emission-based charges in third party and tenanted car parks;

3. workplace parking levy; and

4. emission-based drop off charges.

20.2.78 Ealing Council and the London Borough of Hounslow stated that if these were not

sufficient, a wider zone should be considered. However, both Councils expressed

concern that a wider charging zone may lead to displacement of traffic from the

airport highway network to the surrounding roads and streets, using them as a

through route or short cut. This would lead to increased pollution close to sensitive

receptors.

20.2.79 The Councils stated that more information is required to demonstrate the

effectiveness of the proposed measures to make taxis operations more efficient.

This should include innovative solutions such as the use of online trip-matching

systems, and rewards and penalties for efficient and inefficient operators such as;



introducing a charter for all private hire vehicles seeking to access the site which

encourages backfilling2, and incentivising operators to sign up to the charter

and/or a reward scheme.

20.2.80 The Councils also expressed concern over the feasibility and deliverability of

satellite consolidation sites3, the ability to incentivise and/or compel companies to

participate, and a lack of detail on mitigation if such plans are not successful.

20.2.81 Kent County Council supported the exploration of road user charging and

suggested it will be necessary to raise the emissions standards incrementally as

technology improves. They also highlighted that a drop off/pick up charge will need

to be carefully managed and a uLEZ for freight vehicles could see a reduction in

emissions.

20.2.82 Slough Borough Council stated that in order to meet the sustainable travel targets

by 2030 and 2040 that Heathrow and Slough will need to work together to provide

suitable alternatives that are not only affordable to the user but punctual and

reliable. If suitable alternatives are not provided they would not support road-user

charging. They also stated that they will need to work with Heathrow to create a

wider low emission zone (CAZ) that helps address the Air Quality Management

Area’s (AQMA’s) surrounding the expanded airport. They were concerned that an

approach involving a simple extension of the Transport for London (TfL) low

emission zone (LEZ) in to the Borough would not be acceptable as it could

potentially lead to more polluting vehicles to travel in the surrounding

Slough Borough.

20.2.83 Spelthorne Borough Council, whilst generally supportive of road user charging,

raised similar concerns and requested more detail on the options.

20.2.84 Surrey County Council commented that road user charging must be designed to

avoid unacceptable displacement impacts and be fully funded by Heathrow,

including associated mitigation measures, to ensure local communities are not

unfairly penalised.

20.2.85 The London Borough of Sutton noted that road user charging regimes may have

an impact on switching to more sustainable modes of transport.

20.2.86 Wokingham Borough Council considered that road user charging and drop off

charges for leisure travellers will form part of the decision on transport mode. They

2 Ensuring that taxi’s dropping off customers at the airport are used to fill demand for customers with onward journeys from the airport.

3 Freight transport consolidation or holding sites located outside of the airport perimeter to reduce the number of final mile journeys by

freight vehicles.



considered that it would be inevitable that there would be some form of road user

charging introduced at Heathrow as a means to encourage the use of public

transport and help improve air quality.

Building on our successful commuter programme

20.2.87 Ealing Council and the London Borough of Hounslow stated that Heathrow should

provide safe, high quality cycle infrastructure for employees living near the airport.

Slough Borough Council and South Bucks District Council also supported the

provision of cycle routes.

20.2.88 Ealing Council and the London Borough of Hounslow also said that employees

can often benefit from a monthly season bus ticket and suggested that this could

be addressed through an expansion of the free travel zone for buses. Slough

Borough Council also suggested an extension of the free travel zone.

20.2.89 London Borough of Harrow expressed concern over the target to reduce staff car

journeys to Heathrow by 25% by 2030. They considered that meeting such targets

will be key to no adverse impacts on traffic congestion and air quality from

additional vehicle journeys.

20.2.90 Wokingham Borough Council agreed that Heathrow should continue their

commuter programme to reduce car use.

Statutory Consultees

General Comments

20.2.91 Highways England supported the aims of the Surface Access Strategy so long as

it considers their Surface Access Priorities. They highlighted the need for robust

multi-modal traffic modelling, including future proofing requirements, before any

final decisions are made on terminal locations, car parking or road and junction

locations and capacities. They also suggested the Surface Access Strategy be

flexible to accommodate changing circumstances without losing sight of strategic

principles.

20.2.92 In addition, comments were received from statutory consultees on the efficient and

responsible use of the road network and the commuter programme.

Modal share

20.2.93 Highways England also supported the targets for public transport use and no

increase in airport related traffic but requested greater clarity on what airport

related traffic is, as the current proposed definition appears to be too narrow.

They also recommended that robust and enforceable processes are needed

to correct or mitigate any divergence from the expected reduction in airport

related traffic.



20.2.94 They also identified that the commitment to not increase airport related traffic will

redistribute traffic on some sections of the strategic road network for which

Heathrow will have to mitigate.

20.2.95 Natural England welcomed the ambition to expand airport capacity without any

increase in airport related traffic but stated that Heathrow must demonstrate that

this can and will be achieved with robust monitoring and that nitrogen-sensitive

designated sites will be avoided. They highlighted that the Habitats Regulations

require a high degree of certainty that any measures put in place to avoid or

mitigate impacts are deliverable.

20.2.96 They also suggested that a consistent measurement is used for colleague car trip

and passenger transport targets to ensure clarity relating to changes and targets

for surface access transport.


20.2.97 Highways England commented that the details of any proposed road charging

schemes should take into account the need to control any adverse impacts at the

charging boundary.


20.2.98 Highways England requested certainty on how Heathrow will achieve the

proposed targets for reducing staff car trips.

Other Prescribed Bodies

General Comments

20.2.99 Windlesham Parish Council expressed support for a wider surface traffic study and

road improvements but raised concerns about how Surrey Heath public transport

infrastructure will contribute to delivering the public transport passenger targets.

Windlesham Parish Council also suggested that a national approach to traffic was

required and commented that they would welcome the opportunity to discuss

transport to/from the airport across the M3 corridor.

20.2.100 The Heathrow Strategic Planning Group (HSPG) stated that recent commitments

by government for the Western and Southern Rail Links were a positive indication

that a suitable Surface Access Strategy can be developed.

Modal share

20.2.101 Iver Parish Council identified that there is no indication as to how the commitment

to not increase airport related traffic would be managed, monitored or enforced.

20.2.102 The HSPG said the consultation documentation does not provide any confidence

that the Project can be achieved with no increase in airport related traffic or that

progress to improve air quality in the surrounding area can be assured. They



considered that approval should only be granted for the Project if the target for no

more airport related traffic can be met, or if increases in capacity are linked to the

achievement of the targets and made a condition of approval.


20.2.103 The HSPG considered that the Western and Southern Rail Links are needed now,

prior to the Project.

20.2.104 Network Rail considered that surface rail must provide an increase in journeys of

200-300%, and schemes such as the Western and Southern Rail Links are critical

to achieving this. They highlighted that Heathrow needs to work with its Western

Rail Link project team to provide assurance on compatibility of design.

20.2.105 They identified that further work is needed with funders and stakeholders to

develop the business case for future funding of the Southern Rail Link and

requested that Heathrow support a collaborative approach to funding and

financing.

20.2.106 They also stated that Heathrow should support both the Elizabeth Line and other

services between London Paddington and the airport to optimise the available

capacity and make system wide decisions.


20.2.107 Chobham Parish Council supported the provision of a public transport led scheme

for an expanded airport.


20.2.108 Albury Parish Council raised concerns about an increase of freight and

passengers on the M25 and A3. They said that rail and public transport will not

absorb this excess traffic, as it would be dependent on existing overloaded road

and rail networks. They also expressed concerns about bottlenecks during the

rebuilding of the M25/A3 Wisley interchange and upgrading the Dennis

interchange (A25).


20.2.109 Bray Parish Council expressed concerns with road user charging. They also stated

that it is not within Heathrow’s remit to consolidate the freight loads of cargo

companies and applying road user charging to freight vehicles will increase prices

with no decrease in traffic and pollution.

20.2.110 The HSPG stated that road user charging may not be effective and that there is no

clear detail on how it will be monitored and by who. They recommended that

emission charging should be for direct users of the airport rather than all vehicles

and that joint monitoring and review of air quality across the area is vital to the

success of achieving a reduction in emissions. They also suggested that there



should be a combined logistics and freight strategy and an improvement on the

impact from freight.

20.2.111 Windlesham Parish Council expressed concern about the impact of the proposals

on local taxi companies and requested discussions with Heathrow regarding the

proposals for a preferential supplier system for taxi firms.


20.2.112 Windlesham Parish Council requested an opportunity to evaluate how transport for

airport workers can be incorporated into a wider public transport strategy across

the M3 corridor, incorporating passenger transport and airport access.

Local Communities

Members of the public

General Comments

20.3.1 Most responses from members of the public were general and provided negative

feedback about the Surface Access Strategy. These were often linked to negative

views about the extent of development or the Project.

20.3.2 These included general opposition to the Surface Access Strategy, that it was

insufficient, inadequate or would not be achievable due to inconsistencies between

the ambition of becoming traffic neutral and the proposals to expand. Comments

that the Surface Access Strategy would not resolve existing traffic congestion and

that there would be impacts on local people and local communities from both

traffic and unregulated parking in villages, specifically by taxis. Other members of

the public stated that a strategy was not required at all or raised concerns about

negative impacts on air pollution due to more traffic, longer journey times and

further congestion.

20.3.3 General positive comments were also received. Some said the Surface Access

Strategy would reduce the number of cars travelling to/from the airport; that local

cycle paths and accessibility would be improved and that it would address long

term requirements. Members of the public also considered that the Surface

Access Strategy would encourage more staff/workers to use public transport to get

to/from work at the airport.

20.3.4 Other respondents suggested that public transport should be subsidised, made

less expensive or free of charge, that public transport and rail access should be

improved and that road transport to/from the airport should be discouraged.

20.3.5 Queries were also received asking how the proposals would be funded, the cost

effectiveness of the Surface Access Strategy and the timescales for decision

making and its implementation.



20.3.6 In addition, comments were received from members of the public on putting

Heathrow at the heart of the rail network, providing a public transport led scheme,

providing a resilient and reliable road network, strengthening the coach hub and

enabling more efficient use of the road network.


20.3.7 Members of the public commented that the proposals would improve rail access

to/from the airport including from the south and west and that there would be

benefits from the Elizabeth Line.

20.3.8 However, some also considered that the proposed Surface Access Strategy would

not improve the rail network, that there were no commitments to funding the

necessary improvements and that the proposals would not work or make any

difference. A small number considered that Heathrow was already well served by

the rail network and that improvements were unnecessary.


20.3.9 Responses received from members of the public relating to public transport often

said the Surface Access Strategy would result in improvements to public transport

in general and that it would result in improved bus services, improved public

transport links, improved accessibility to and around the airport and that it would

ease traffic congestion.

20.3.10 Other comments suggested that public transport was not a practical option for

passengers with luggage that the transport infrastructure would not be able to

cope, that improvements in public transport would not make any difference, that

there would be negative consequences for traffic congestion and that public

transport is unreliable and not cost effective.


20.3.11 Of the members of the public that commented on the road network, the main

comments were that the area was already heavily congested and that

improvements would make the road network more efficient for users. Some

considered that improvements would also make access to the airport by road from

the south better.

20.3.12 However, most that commented on the road network expressed concern about the

negative impacts during construction and operation, the impacts of congestion and

that the roads will be unable to cope with the increased number of cars. Specific

comments were also received which expressed concern about the impacts on

traffic and congestion on local roads, the M25, the M4 and the M40.




20.3.13 A small number of members of the public expressed support for the improvement

of the coach hub.


20.3.14 Members of the public expressed support for the proposals for road user charging

as they considered it would encourage public transport use and reduce the

number of cars on the road. Others suggested that road user charging would

result in better access and convenience for passengers, would ease congestion

and result in a reduction in emissions, noise pollution and an improvement in air

quality. Some also suggested that it would encourage the use of low emission

cars.

20.3.15 Negative comments about the proposals for road user charging were also

received. They said that:

1. the focus should be on improving public transport or electric cars;

2. the proposal was motivated by increasing revenue for the airport rather than

reducing impacts or delivering road improvements; and

3. it will not reduce the number of cars on the road or that it will just move

congestion to other places and drive businesses away from the airport,

affecting competitiveness.

20.3.16 Others commented that motorists are already taxed too much and that the

proposals for road user charging were unfair for those working at the airport, and

would also result in increases in taxi fares.

20.3.17 Members of the public also suggested that the revenue from road user charging

should be spent on improved public transport and public transport infrastructure or

that public transport should be affordable, subsidised or free. Suggestions that

residents who live near the airport should be exempt from any road charges were

also received.

Businesses

General Comments

20.3.18 The Copas Partnership commented that surface access should be continually

improved without delay.

20.3.19 Business South said that they were content for the airport to find the right option

for configurations.

20.3.20 The Hampshire Chamber of Commerce said that ongoing investment in road and

rail transport infrastructure is essential for an expanded Heathrow and there

should be a commitment to enhanced connectivity and congestion reduction,

aligned with the new runway development.



20.3.21 Hatton Farm Estates Limited commented that the proposals for surface access

look sensible and are important for fast and affordable access to London.

20.3.22 Hatton Garden Trustees Limited and Pickering Properties considered that the

Surface Access Strategy proposals will help deliver a reduction in emissions and

limit fuel use, if applied correctly.

20.3.23 London (Heathrow) Airline Consultative Committee (LACC) and the Board of

Airline Representatives in the UK (BAR) supported the provision of varied,

affordable and reliable surface access options but expressed concern about the

affordability of the proposals. They stated that airlines and passengers should not

be responsible for subsidising national programmes or funding betterment of other

schemes and requested further engagement with the Airline Community in the

development of the Surface Access Strategy.

20.3.24 The Surrey Chambers of Commerce stated that the Surface Access Strategy is a

key part of the plans and the proposals seem well thought through.

20.3.25 Virgin Atlantic Airways Limited (Virgin) expressed concern that the Surface Access

Strategy is insufficiently developed and un-costed, with aspirational and

challenging objectives. They requested a detailed Surface Access Strategy,

including detailed modelling, evidence to support Heathrow’s ambitions, and an

assessment of the cost and risk to the entire scheme if the targets are not met.

Modal share

20.3.26 Greengauge 21 stated that a simple expansion of facilities will not achieve the

required increase in public transport mode share, zero growth of airport-related

vehicle traffic, local air quality limits and a reduction in the risk of unrestricted

vehicle access. They considered the benefits identified by the Airports

Commission and the draft ANPS for the national economy are at risk if the Project

is not accompanied by a clear strategic plan accompanied by new rail connections

and services.

20.3.27 LACC and BAR stated that Heathrow has not demonstrated how mode share and

employee car journey targets, as well as targets to limit freight movements, relate

to known air quality and/or congestion policy. They considered that the modal shift

targets should be reset to show that the airport is taking its ‘fair share’ of

congestion and will not increase road traffic. Also, that any schemes aimed at

reaching the targets must provide value for money and be in the interests of

passengers. They also suggested that Heathrow should analyse the needs of

specific groups of workers and passengers before defining the requirements.

20.3.28 Segro considered the mode shift targets ambitious and recommended that

Heathrow investigate the possibility of an extensive network of park and ride sites

to free up road capacity.



20.3.29 Virgin stated that there is insufficient modelling or supporting evidence to

demonstrate that the aim of no increase in road traffic is anything other than

ambition. They expressed concern that as new runway capacity will not be made

available if noise, traffic or emissions targets will be breached, the new runway

may never be fully utilised. They considered this would undermine the economic

case for the Project.


20.3.30 Airlines for America stated that current rail and road access to the airport is

outdated and must be enhanced to enable airlines to cater for passenger demand

when the third runway is operational.

20.3.31 Airport Industrial Property Unit Trust (AIPUT) stated that the Western Rail Link and

the Southern Rail Link must be considered if the Project is to be successful.

20.3.32 The Brett Group suggested that their land at Hithermoor should be considered for

a new rail station as part of the Southern Rail Link.

20.3.33 Greengauge 21 stated that although the draft ANPS says an interchange at Old

Oak Common will enable airport passengers to make a connecting journey to

access HS2, air passengers would be heavily dissuaded from using rail if an

interchange is required. They also suggested that the Western Rail Link could

provide national connectivity but will only connect the airport with the Great

Western Main Line if passengers are prepared to change during their journey.

20.3.34 They also highlighted that Heathrow should be relieved of any obligation to fund

enhanced rail access infrastructure and should instead contribute to new rail links

through expenditure that can be taken in to account by the CAA.

20.3.35 The Hampshire Chamber of Commerce considered the Western Rail Access and

Southern Rail Link to be of significant national interest, serving a range of

economic needs supporting the Project.

20.3.36 Jayflex Aggregates Limited suggested that a new passenger transfer hub adjacent

to Wraysbury station would enhance rail access, as rail passengers could be

transferred in automated pods along the embankment of the Wraysbury Reservoir

as far as M25 Jct. 14 and from there directly into the airport Terminals.

20.3.37 Segro stated that the key to Heathrow’s transport strategy is the delivery of new

strategic rail services, including the Western and Southern Rail Links

complemented with a network of high quality and reliable park and ride facilities for

passengers arriving by car. They considered that this will help ensure that local

roads around the airport are not overloaded with passenger traffic and will allow

essential goods, services and cargo to move efficiently and sustainably to and

from the airport. They also stated that the Western Rail Link is required now to

support the two-runway capacity.



20.3.38 The Thames Valley Chamber of Commerce said there is a clear business case for

the Western Rail Link based on a two or three runway airport. They suggested that

Heathrow actively participates in and leads the delivery of the Western Rail Link

before construction commences on the third runway.


20.3.39 Virgin welcomed the ambition to make the Project sustainable by providing high

quality reliable public transport links but said there is uncertainty as to who will

provide and pay for the different schemes and a lack of modelling to demonstrate

modal shift will take place.


20.3.40 AIPUT considered it necessary to increase the provision of public transport options

to serve the southern side of the airport by bus.

Making public transport easier for users

20.3.41 GlaxoSmithKline (GSK) highlighted that a significant proportion of trips to the

airport are by road, which results in road congestion impacts on local businesses.

They suggested a review of the fare structure of public transport should be

undertaken and that there should be better access at stations and better north /

south rail services.

20.3.42 Segro supported the provision of enhanced bus services but expressed concern

about the ability to deliver new bus priority measures on roads that under the

control of local authorities and TfL. They stated that, without the full support of

these organisations, it is unclear how the free travel zone could be expanded.


20.3.43 AIPUT raised concerns about road user charging and low emissions zone

charging around the airport as they considered it may distort how the market

operates and negate the attempts to minimise traffic generation. They suggested

that Heathrow should consult with commercial operators and land owners to

ensure that it does not reduce competitiveness or lead to more traffic in areas on

the edge of the zone.

20.3.44 Airlines for America stated that proposals to limit vehicles accessing the airport

should be rejected. They expressed particular concern about proposals to charge

airlines and their passengers for the cost of the infrastructure work associated with

the Project.

20.3.45 The Copas Partnership considered that the focus should be on low emission

vehicles and that road user charging is not the right principle.

20.3.46 Electron Bean Processes Limited considered road user charging inevitable and

logical.



20.3.47 The Fuel Trading Company generally supported road user charging but noted that

it works on the assumption that all the vehicles in and around the airport are

electric. They suggested that Heathrow consider using renewable diesel for bus

and coaches if a uLEZ is to be introduced.

20.3.48 GSK suggested that charging for passenger drop-off and collection should be

further reviewed as part of a wider strategy to increase the cost of road travel to

Heathrow compared with rail. They indicated that they would need to review the

impact of this on their business and the implications for staff and visitor travel if

road user charging and an airport uLEZ were to be considered.

20.3.49 Hatton Farm Estates Limited would be in favour of road user charging if electric

vehicle were exempt. This would encourage their use and not restrict vehicle

access for passengers.

20.3.50 LACC and BAR considered that Heathrow’s stated aim to ‘grow the airport without

increasing traffic’ does not appear to be realistic with respect to freight. They also

identified that any additional road user charges will directly impact the airport,

passengers and employees. They stated that alternative mechanisms and

schemes for promoting modal shift and meeting the targets of the ANPS should be

exhausted before additional charges to airport users are introduced.

20.3.51 Heathrow Southern Railway Limited supported the principle of vehicle charging to

encourage modal shift from road to rail. They considered this can only be justified,

and is only likely to be acceptable to airlines and passengers, if carried out in

conjunction with major improvements to public transport connections.

20.3.52 The Surrey Chambers of Commerce said that road user charging may be the only

way to encourage public transport use but only if public transport is readily

accessible.

20.3.53 Town Centre Securities PLC did not agree with the proposals for road user

charging as they believe it is not socially inclusive.

20.3.54 Virgin considered it unreasonable to pay a road user charge to access the airport

for private car or taxi on top of high airport charges and Air Passenger Duty.

20.3.55 WeMoved Limited suggested that the focus should be on autonomous vehicles

rather than road user charging.

Community Groups

General Comments

20.3.56 Aircraft Noise Three Villages and Englefield Green Action Group stated that a

Surface Access Strategy is not required if there is no third runway. Aircraft Noise

Three Villages also said that Heathrow should ensure there is no increase in road

traffic even as a two-runway operation.



20.3.57 The Colnbrook Community Partnership expressed support for the priorities of the

Surface Access Strategy and the key initiatives which seek to shift passengers

and workers from private car to public transport.

20.3.58 Dover House Estate Residents Association stated that the Surface Access

Strategy was poor.

20.3.59 Ealing Aircraft Noise Action Group considered the surface access proposals

unrealistic and highlighted uncertainty around the funding contributions and

delivery of the Piccadilly Line upgrades and the Western and Southern Rail Links.

They also considered that proposals to promote walking and cycling should only

relate to staff working on the airport periphery and not to passengers or to staff

needing to go into the central area.

20.3.60 Ealing Fields Residents Association said that even with upgrades, the Project will

result in overcrowding on the Piccadilly Line. They also considered that a premium

fare on the Elizabeth Line will push more passengers onto the Piccadilly Line.

20.3.61 Eastcote Conservation Panel and SCR Residents for a fair consideration of

Heathrow expansion expressed concern that changes to road layouts, more public

transport and train links will cause more disruption to communities.

20.3.62 Mortlake with East Sheen Society suggested that Heathrow should start

developing the Surface Access Strategy now and not in the future. They stated

that rail trips to Heathrow from SW London involve a detour which is time

consuming, resulting in most trips being made by car or taxi.

20.3.63 Residents Association HVG CA said the Surface Access Strategy is not accurate

in terms of the number of people affected or the effects on quality of life.

20.3.64 Richmond Heathrow Campaign considered the surface access options have not

been through a proper assessment to consider the environmental, operational,

economic and financial implications. They considered that there is a risk that

demand and the required capacity to meet it has been significantly

underestimated.

20.3.65 Slough and District Against Runway 3 considered the proposals for surface access

are unrealistic and unacceptable due to the scale of land and property that will

need to be compulsorily acquired, which will lead to blight in neighbouring

communities.

Modal share

20.3.66 Four Lanes Are More Than Enough (FLAME) stated that the commitments to

increase passenger numbers travelling by public transport and not increase airport

related traffic are not credible. They also raised concerns about the pressure that

will be placed on the M25 if the pledges are not honoured.



20.3.67 Local Conversation in Stanwell suggested that specific targets for maximising the

proportion of journeys made to the airport by public transport, cycling or walking

should be set and should apply to both the workforce and passengers.

20.3.68 Richmond Heathrow Campaign stated incentivising and supporting modal share

shift is insufficient and requires input from and cooperation with others. They

expressed concern that the government will end up paying Heathrow's surface

access costs and suggested that the surface access initiatives should be pursued

regardless of a third runway, so that rapid improvements to air quality are

delivered over and above those in the draft London Plan. They also highlighted the

release of runway capacity should be linked to surface access tests based on

predicted outcomes. The number of Heathrow related vehicles should be no more

than today and the tests must be based on targeted reductions in such traffic

compared to a ‘Do-minimum’ over future years.

20.3.69 Stanwell’s Green Lungs, Teddington Action Group and West London Friends of

the Earth suggested there must be no increase in road traffic and therefore no

need for new car parks or more road capacity.


20.3.70 The Camberley Society stated that there is a need for better transport links from

the west, south west and south including the proposed Southern Rail Link.

20.3.71 The Chertsey Society stated that they would oppose the Project unless a direct

link is provided to the South West Railway network. They stated that their

preferred option for this would be a light rail system from Chertsey in a tunnel.

They also expressed opposition to the Southern Rail Link which would require

heavy weight trains to cross over the M3, A30, River Thames and other local

roads.

20.3.72 The Colnbrook Community Partnership said that the Piccadilly Line is already

overcrowded and an expanded airport will put greater pressure on the public

transport system. They suggested that a link from the east would relieve much of

this overcrowding.

20.3.73 Egham Residents’ Association supported the principle of having direct rail access

to the airport from the south. They said their preferred option for this would be a

railway tunnel starting on the edge of Staines, emerging between Egham and

Virginia Water, and with a station within Runnymede Borough to provide a service

from Egham to the airport.

20.3.74 FLAME expressed support for the principle of a new direct rail link to the airport

from the south but raised concerns about the closure of level crossings because of

the effects on road traffic congestion. They also expressed concern about any

proposal to build a new railway line immediately alongside the M25 from Staines to



Chertsey, due to adverse effects on local people and the disruption to the M25 and

other roads during construction.

20.3.75 The Fulham Society considered a new rail link from Waterloo to the airport via

Clapham Junction, Putney and Staines should be a priority.

20.3.76 Heathrow Association for the Control of Aircraft Noise (HACAN) expressed

support for increased frequency and operating hours on the Elizabeth line,

contribution to the costs for a new Western Rail Link and a new direct rail link to

Heathrow from the south. However, they expressed concern that there is no clarity

on the cost and who will pay for new heavy rail infrastructure. Without this the

achievement of no increase in airport related traffic or the modal shifts will not be

possible.

20.3.77 Heathrow U3 Sustainability Group expressed support for the Southern Rail Link.

They considered the Piccadilly Line improvements will reduce car use and the

proposals to use a freight line from Hendon and Cricklewood for passenger trains

would be an improvement.

20.3.78 Local Conversation in Stanwell considered the ‘no more traffic on the road’ pledge

cannot be delivered without improving rail access from the south.

20.3.79 Mortlake with East Sheen Society expressed concern about the potential for a

Southern Rail Link to cause traffic congestion at the level crossings in the

Mortlake/East Sheen area. They suggested that all level crossings should be

replaced by tunnels or bridges or an alternative route found to Waterloo.

20.3.80 The Pavilion Association expressed support for a rapid rail T5 – Staines park and

ride.


20.3.81 The Chiltern Society welcomed the proposals to increase surface access to the

airport by alternatives to car transport.

20.3.82 The Colnbrook Community Partnership queried whether a realigned A4 with two

lanes will have sufficient capacity for good public transport. They suggested that

an effective and efficient public transport system needs to be augmented for both

workers and travellers to and from the airport.

20.3.83 Friends of the River Crane stated that Heathrow should develop walking and

cycling routes that will provide safe and attractive routes into the airport as well as

alternative green transport links between each of the population nodes.

20.3.84 Local Conversation in Stanwell stated that affordable and convenient transport

choices for staff and passengers are critical to achieving sustainable surface

access.



20.3.85 Richmond Heathrow Campaign said the planned increases in public transport

capacity are only sufficient to cater for growth in two runway demand.

20.3.86 Wentworth Residents Association expressed concern about the construction of car

parking and considered it contradicts the suggestion that most passengers/freight

will travel to/from the airport by public transport.


20.3.87 Eastcote Residents Association queried how route changes to the M25, A4, A312,

A30 and A3044 will ensure that there will be no increase in airport related traffic on

them.

20.3.88 The Hitcham and Taplow Society requested a ban on construction traffic on the A4

over Maidenhead Bridge as it is the only access from the west in the case of a

temporary closure of the M4.

20.3.89 Northumberland Walk Residents Association queried why road capacity needs to

be increased as Heathrow has stated that they will keep traffic volumes at current

levels.

20.3.90 Old Chiswick Protection Society expressed concern about the effect of increased

traffic on the M4 corridor in to and out of London, Hogarth roundabout and the

surrounding roads. They queried the plans for keeping traffic flowing with the

added pressure of extra transport to and from Heathrow.


20.3.91 Ashford and Staines Community Centre highlighted recent cutbacks in bus

services and the need for better transport links to and from the airport from the

Ashford area.

20.3.92 The Camberley Society stated that there is a need for better transport links to

Heathrow from the west, south west and south from Farnborough and Camberley.

20.3.93 The Chiltern Society suggested that sustainable transport options are required to

improve access to the airport from towns in the Chilterns.

20.3.94 The Colnbrook Community Partnership stated that a cycle network is essential to

encourage workers to cycle to and from work and in the vicinity of the airport. They

suggested that this must be considered in the road alignments and junction

layouts of both the local road network and motorway.

20.3.95 Elmbridge Friends of the Earth suggested that there should be trains from stations

in Elmbridge and a local bus to provide local people with sustainable access to the

airport.

20.3.96 Local Conversation in Stanwell expressed concerns that there is no commitment

to provide improved public transport to meet the needs of an expanded airport,



particularly to the south. They suggested that Heathrow considers where the future

workforce will be from and seek to encourage a greater spread of employees with

an equitable choice of transport modes.

20.3.97 Stanwell’s Green Lungs suggested bus connections to Terminal 5 via Stanwell

and Stanwell Moor should be restored and further consideration should be given to

a local tramway or light railway connection.


20.3.98 Aircraft Noise Three Villages, Stanwell’s Green Lungs, Teddington Action Group

and West London Friends of the Earth considered that consultation on road user

charging is the government's responsibility.

20.3.99 Camberley Society and the Cheyne Walk Trust did not favour road user charging.

20.3.100 The Colnbrook Community Partnership stated that road user charging is an

effective method to dis-incentivise vehicle use within certain areas but considered

that around the airport it will create disadvantages to local residents.

20.3.101 Dover House Estate Residents Association was supportive of road user charging.

Egham Residents Association also supported the principle of road user charging,

specifically on the basis of emissions.

20.3.102 Ealing Fields Residents Association considered that road user charging has a role

but that it would have no more effect than the already high parking charges.

Elmbridge Friends of the Earth shared a similar view commenting that that road

user charging will not necessarily reduce travel.

20.3.103 Englefield Green Action Group suggested residents within a 10-mile radius should

be exempt from road user charging. They also highlighted that the impact of an

increase in freight needs to be addressed, including HGV parking, road

congestion, infrastructure damage and the increase in air pollution from diesel

engine HGV vehicles.

20.3.104 HACAN stated that it is not clear whether a congestion charge scheme would be

required but said that Heathrow should have a scheme that is ready to be put in

place should it be required.

20.3.105 Harrow U3 Sustainability Group expressed support for road user charging if there

are adequate improvements in public transport. The Wentworth Residents

Association shared a similar view but indicated that the charging is not a fix for a

lack of public transport investment.

20.3.106 The Richmond Heathrow Campaign also stated that road-user charging and car

parking charges can be effective tools but must be accompanied by alternative

public transport. They considered that these measures should be pursued to

improve air quality regardless of a third runway.



20.3.107 Local Conversation in Stanwell expressed support for the principle of a uLEZ but

stated that cars should not be displaced into surrounding areas to park on local

roads. They also commented that a fund must be provided to support major

surface access schemes and sustainable transport projects in the wider area to

the benefit of local communities.

20.3.108 Residents Association HVG CA said the proposal for road user charging has not

been researched properly or accurately and it will not work.

20.3.109 SCR Residents for a fair consideration of Heathrow expansion stated that airport

employees will have the road user charging factored into rates of pay or contracts

and it will instead have the greatest effect on local residents who are not

compensated through employment.

20.3.110 Slough and District Against Runway 3 considered that a road user charge will

make no difference to air and noise pollution.

Wider/other consultees

General Comments

20.4.1 Association of British Travel Agents (ABTA) stated that surface access is crucial in

the choice of a passenger’s departure airport and recommended an increased

focus on improved surface access benefitting passengers and staff, as well as the

local population.

20.4.2 The Chartered Institute of Highways and Transportation (CIHT) expressed support

for the priorities and initiatives in the Surface Access Strategy but queried whether

they were all achievable.

20.4.3 Lambeth/Herne Hill Green Party stated that the initiatives identified are vital to

drive the development of the Surface Access Strategy and achieve the identified

priorities.

20.4.4 The London Parks and Gardens Trust welcomed all transport that minimises

environmental impacts.

20.4.5 The Kingston Environment Forum considered the plans inadequate, relying too

much on travellers using clean transport options.

20.4.6 The Liberal Democrats expressed concern at the lack of commitment from

Heathrow to fund new public transport infrastructure. They considered the Surface

Access Strategy to be dependent on projects to manage current demand that are

funded and controlled by other bodies.

20.4.7 The London Wildlife Trust expressed support for initiatives to provide more

sustainable travel alternatives but requested consideration of how the airport will fit

into the existing cycle and footpath network.



20.4.8 The Mayor of London stated that the Surface Access Strategy is almost wholly

dependent on pre-existing rail schemes such as the Elizabeth and Piccadilly Line

upgrades which were planned based on a two-runway Heathrow. He considered

that the Project would result in worsening congestion and delays on the roads and

increased crowding on the railways.

20.4.9 The National Trust expressed concern about the indirect impacts of increased

levels of traffic and parking, new transport infrastructure and new railway lines.

20.4.10 The Richmond Cycling Campaign indicated the Project should not lead to an

increase in climate-changing emissions, or any increase in motor vehicle volumes

(and resulting pollution and emissions).

20.4.11 The Royal Parks stated that transport links are important but expressed concern

about new transport infrastructure affecting the Longford River.

20.4.12 Transport for the South East expressed concern that there is not a coherent view

on how the airport sits within the wider transport network and indicated that a more

coherent and integrated strategy should be produced, with Heathrow taking the

lead.



Modal shift

20.4.13 CIHT considered the modal shift target will be difficult to achieve and expressed

concern that there is minimal explanation as to how the increase in public

transport usage would be achieved and funded.

20.4.14 Dominic Raab MP stressed the importance of Heathrow meeting its modal shift

and airport related traffic commitments, to ensure that the existing road network in

Elmbridge is not put under further strain from traffic generated by a third runway.

He suggested the Environment Agency or another body be mandated to monitor

the full environmental impact of the airport, including any additional congestion.

20.4.15 England’s Economic Heartland considered the pledge to have ‘no net increase’ in

airport related traffic and corresponding investment in surface access capacity can

enable the required improvements in air quality.

20.4.16 Enterprise M3 LEP considered that the lack of a detailed integrated Surface

Access Strategy for passengers, freight and workforce was a serious failing and

that without major infrastructure investment Heathrow will be unable to meet

modal split and sustainable transport targets. They also expressed concern that

without additional sustainable surface access the airport will not be able to

contribute fully to the economy or meet the demands of future air travel growth.

20.4.17 The Mayor of London stated that there are a lack of tangible commitments by

Heathrow to ensure no increase in airport related traffic. He queried what happens

if some of the measures do not come forward and suggested that if Heathrow’s

analysis has identified an alternative package of schemes this should be published

together with details of how these schemes will be delivered.

20.4.18 Transport for the South East also considered that meeting modal split and

sustainable transport targets without major infrastructure investment needs to be

properly evidenced, especially given recent evidence from the ANPS consultation

that passenger demand will grow faster than first expected.


20.4.19 ABTA welcomed the proposals for a Southern Rail Link and the introduction of

direct access to Heathrow by the Elizabeth line in 2018.

20.4.20 Bracknell Forest Economic and Skills Development Partnership highlighted the

importance of a Southern Rail Link to the future success of the airport and

recommended that it should form an integral part of the Project. They expressed

concern that without such a link residents and businesses would continue to suffer

from long and difficult public transport journeys to and from the airport, made

worse by the Project.

20.4.21 Crossrail to Ebbsfleet identified that Kent and much of South East London still lack

a direct, high-capacity connection to the airport and the Crossrail to Ebbsfleet



scheme is a vital part of reducing car journeys and in helping Heathrow to tackle

air quality impacts.

20.4.22 England’s Economic Heartland expressed support for Heathrow’s financial support

for the new Western Rail Link but considered that this should be provided as

matter of urgency in support of current airport operations. They also suggested

that strategic access could be provided to the airport by linking it to a single

interchange at Old Oak Common and requested that the High Wycombe to Old

Oak Common link is recognised as one of the key building blocks to enable

passengers and staff to sustainably access an expanded airport.

20.4.23 Enterprise M3 LEP expressed disappointment that the Western and Southern Rail

Links were not identified as essential schemes. They considered that the case for

these schemes has been more than clearly made for a two-runway airport.

Transport for the South East shared a similar view stating that the Western and

Southern Rail Links were identified by the Airports Commission as being justified

on the basis of a two-runway airport.

20.4.24 Heathrow Southern Railway Limited suggested TfL’s analysis concludes that both

the Western and Southern Rail Links are essential for the Project. They

considered the government’s call for ‘Market Led Proposals’ identifies the

Heathrow Southern Rail Link as a priority and Heathrow Southern Railway Limited

proposals would provide this.

20.4.25 Hounslow Green Party stated that the new rail schemes are not realistically costed

and Heathrow is neither willing nor able to fund them.

20.4.26 The Liberal Democrats stated that they would like to see firmer commitments from

Heathrow on plans to contribute to the cost of the Western Rail Link. They stated

that without a financial contribution to the costs of increasing the frequency of

trains on the Elizabeth Line or to the development of the Southern Rail Link, it is

difficult to see how the Surface Access Strategy would be fulfilled.

20.4.27 The London Cycling Campaign suggested Heathrow ensure that walking and

cycling are enabled and there should be no increase in road vehicles across the

area.

20.4.28 The Thames Valley Berkshire LEP identified that their priority for infrastructure

investment is the Western Rail Link scheme and that it is required for a two-

runway airport.

20.4.29 World Federalist Party said the priority should be improving the public transport

infrastructure.


20.4.30 CIHT expressed concern at the provision of ‘a resilient and reliable road network’

noting that many of the schemes are designed to deal with existing growth in



demand and not the extra journeys generated by an expanded airport. They

suggested an integrated approach between Heathrow, the DfT and Highways

England will be required to ensure a good level of service for road users.

20.4.31 Transport for the South East highlighted that the DfT-sponsored M25 South

West Quadrant study has identified several options for further consideration

and recommended that these need to be integrated far more closely into the

Project proposals.


20.4.32 England’s Economic Heartland supported the expansion of the coach and bus

hub, noting that there is an opportunity to introduce new services or increase

frequency either directly to the airport or to connect with direct train services via

East West Rail, the Elizabeth Line and mainline stations in and near the

Heartlands area.


20.4.33 London First welcomed the reference to demand responsive transport.

20.4.34 The Colne Valley Regional Park considered that walking and cycling needs to

become part of an integrated approach to reducing traffic and managing air

quality. They also considered cycling and walking routes need to serve people

accessing the Colne Valley Regional Park, create important links and build on the

strategic green infrastructure network.

20.4.35 Ealing Cycling Campaign said the new runway would present one of the largest

barriers to north-south cycling in London and suggested that Heathrow includes a

tunnel for cyclists under the runway. They suggested that there should be a more

central north-south cycle route through the airport, which could potentially be

combined with the proposed new southern access to the central terminal area.

Also, that there could be cycle routes around the perimeter and to the west and

south of the airport. They also highlighted that cycle hub areas will require large

amounts of cycle parking.

20.4.36 The London Cycling Campaign highlighted that much of the area surrounding the

airport is inhospitable to cycling and/or walking and that better walking and cycling

routes, connections and neighbourhoods should be provided. They identified that

corridors aligned with Bath Road, Staines Road east-west, High Street Harlington,

the A408, Parkway and A3063 north-south, Hayes, Yiewsley, Southall and

Hounslow as areas that should be prioritised.


20.4.37 The British Helicopter Association expressed opposition to road user charging,

considering it to be a stealth tax.



20.4.38 The Chartered Institute of Logistics and Transport supported the principle of road

pricing and suggested that a commitment to use the proceeds to provide transport

improvements could improve its acceptance.

20.4.39 The CIHT also supported the principle of road user charging and suggested that

the London Congestion Charge is a useful model. They recommended that the

DfT and the local transport authority develop a scheme to minimise the impact of

the airport on surrounding communities, and which provides additional funds to the

local highway network including sustainable travel options for those working at the

airport.

20.4.40 The Colne Valley Regional Park suggested road-user charging be implemented in

a way that reduces traffic, poor air quality and noise impact on the Park and its

local communities. They expressed concern about the risk of introducing

excessive charges that lead to car drivers using surrounding villages as

alternatives for parking. The London Wildlife Trust expressed a similar view stating

that any road-user charging should be implemented in a way that reduces traffic,

poor air quality and noise impact on the natural environment.

20.4.41 World Federalist Party and Lambeth/Herne Hill Green Party supported road user

charging.

20.4.42 London First welcomed the option of restricting vehicle access through emissions

or access-based charging, suggesting that further analysis of congestion, charging

and other interventions should be undertaken.

20.4.43 The London Cycling Campaign supported road-user charging and/or other

methods to reduce private motor vehicle volumes. They suggested that these

approaches must be considered across the entire area to avoid either displacing

private car journeys to a few stops down the underground line or nearby hotels

etc.


20.4.44 The CIHT expressed support for Heathrow’s work on sustainable travel plans for

its staff and contractors, to reduce reliance on private motor vehicles.

20.4.45 London First welcomed the awareness of changing staff travel behaviour and

encouraged Heathrow to think creatively about how this might be achieved.

20.4.46 The London and Richmond Cycling Campaigns stated that more could be done to

ensure that a far higher proportion of those working at or near the airport can cycle

to work. The London Cycling Campaign recommended that Heathrow sets a clear

target for cycle journeys for staff that exceed TfL targets for London and develops

a plan to deliver the infrastructure necessary to meet any cycling targets in the

Surface Access Strategy.



20.4.47 The Richmond Cycling Campaign recommended that conditions for cycle access

to Heathrow will require an improvement to cycle superhighway standard and

secure cycle parking at all parts of the airport where employees are based.



Issues Raised and Heathrow’s Responses

The table below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other

consultees in relation to Surface Access. None of the feedback received in relation to Surface Access is directly related to the

proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019) but

instead relate to other aspects of the Project. The table therefore provides a summary of the way in which we are seeking to

consider the issues raised, and are provided for information only. No further feedback is being sought on the basis that a full

consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.

Table 20.1B

Issue Consultee4 Heathrow Response

PC MC WC

Public transport should be affordable, subsidised or free. ✓ The Airport Expansion Consultation One (January

2018) document, Our approach to developing a

surface access strategy explained the options

Heathrow was considering to make public transport

easier to use. This included measures to build on the

success of the Free Travel Zone, which provides free

travel by public transport around the Heathrow

Campus for passengers and colleagues.

Public transport should be subsidised, made less expensive or free

of charge.

✓

There should be a review of the fare structure of public transport

along with better access at stations and better north south rail

services.

✓

4 PC - Prescribed Consultees; MC – Members of the Community; WC – Wider Consultees




PC MC WC

Without the full support of Local Authorities and TFL, it is unclear

how the free travel zone could be expanded.

✓ At the Airport Expansion Consultation One (January

2018) Heathrow also expressed an intention to work

with local transport operators to make travel to and

from the airport on public transport as affordable as

possible. This could be through offers and promotions

on Heathrow’s services or negotiated discounts with

other operators.

With the significant upgrade in rail capacity and

frequency due to the introduction of the Elizabeth line

and Piccadilly line upgrade, there is an opportunity to

review the pricing structure of Heathrow Express fares

to ensure the service provides the optimal customer

experience and demand requirements. Making

efficient use of available rail capacity will be a key

driver in making public transport more accessible for

both passengers and colleagues.

The Airports National Policy Statement (ANPS) at

paragraph 5.7 identifies major rail improvements that

would support a new north west runway. In

considering the surface access infrastructure needed

to support the expansion plans, Heathrow must have

regard to paragraph 4.39 of the ANPS. This requires

Heathrow to demonstrate that its scheme is cost-

efficient and sustainable, and seeks to minimise costs

to airlines, passengers and freight owners over its

lifetime. Heathrow is supporting Network Rail’s

Development Consent Order (DCO) application for a

Western Rail Link to Heathrow and is supporting the

emerging plans for a Southern Rail Link. DfT is

exploring the potential for a Southern Rail Link to be

brought forward with private sector involvement.

There should be an extension of the free travel zone. ✓

Public transport is unreliable and not cost effective. ✓

Public transport and rail access should be improved. ✓

Public transport is not a practical option for passengers with

luggage.

✓

Concern expressed about the frequency and timing of local services

and a lack of detail on how Heathrow will engage with the industry

to improve frequencies to at least five an hour.

✓

Heathrow should be required to pay for enhanced service levels. ✓

Enabling passengers and employees to easily obtain economic,

flexible tickets and incorporating free or discounted surface access

public transport tickets as part of an airline ticket package would

make public transport more accessible and easier to use.

✓

Affordable and convenient transport choices for employees and

passengers are critical to achieving sustainable surface access.

✓

Making all public transport options easier for users is essential to

transfer mode share away from the private car.

✓

Integrating ticketing for onward travel could create a seamless ✓




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journey for passengers. Elizabeth Line services will begin operations to

Heathrow in 2019.

Heathrow is committed to meeting the targets for

increasing passenger mode share by public transport

and reducing the number of colleague car trips in the

ANPS. Heathrow will also continue to strive to meet its

pledge to have landside airport-related traffic no

greater than today.

Heathrow has been working with colleagues at the

airport to reduce the number of people driving single

occupied, private cars to work. Heathrow has invested

in a dedicated commuter team as well as local

transport to make it easier and more affordable for

people to use.

Outside the airport boundary, Heathrow is committed

to working with Highways England, Network Rail, TfL,

local authorities and transport operators to understand

and plan for the transport needs of the local

communities affected by the expansion.

At the Airport Expansion Consultation One (January

2018) the Our approach to developing a surface

access strategy document explained the measures

being considered to increase public transport use and

reduce the need to travel more generally. This

included consideration of an access charge /

emissions charge to access Heathrow and improved

taxi / PHV management. In addition, the Our

Emerging Plans document set out proposals that

would rationalise the existing four terminals, focused

on Terminal 5 and Terminal 2. This would focus

Better advertising and information about the free travel zone is

required and a review of the pricing structure for public transport to

the airport is needed.

✓

The focus on public transport is a good thing but is there a real

commitment to its delivery. The intention to align employment and

public transport is welcomed, but there is a lack of incentives to

reduce car use.

✓

Road, rail and other public transport access to the airport needs to

be high quality, efficient and reliable for both passengers and

workers and it must maximise the number of journeys to the airport

by sustainable forms of transport.

✓

Flights should be timed to depart and arrive at times when public

transport is available and any increases in capacity should be

subject to the provision of additional public transport capacity.

✓

Heathrow must help to fund/support mass rapid low emission

transport schemes to improve the links and journey time to the

airport.

✓




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activity and trips along the existing public transport

spine (with the addition of new Elizabeth Line

services) and improved bus and coach facilities at the

Terminals. Fewer larger terminals will also reduce the

need to travel around the airport, between terminals.

The draft Surface Access Strategy, supported by

technical information in the Preliminary Transport

Information Report (PTIR), will explain Heathrow’s

preferred options for the transport infrastructure

needed to support the expansion plans in the context

of increasing the use of public transport by

passengers and colleagues. This includes plans for a

new car park strategy and freight/logistics strategy.

This will be part of the documents published at the

Airport Expansion Consultation in June 2019.

Consideration should be given to other schemes to enable use of

more sustainable transport modes such as the High Wycombe rail

connection to Old Oak Common, coach links to Handy Cross hub

and re-opening of the High Wycombe to Bourne End heavy rail line.

✓ Heathrow supports improved public transport links

from areas that currently do not have direct links to the

airport. Improved bus / coach and rail options are

being investigated as part of the overall surface

access strategy, and links from High Wycombe and

Buckinghamshire more generally will be considered as

part of this. Bus and coach are key modes of travel for

Heathrow passengers and colleagues. Heathrow is

investigating the possibility of improving and extending

local bus services to the airport to capture demand

from wider areas and make travel by bus and coach

more attractive. The emerging Surface Access bus

and coach strategies are exploring how Heathrow can

promote the use of the buses or coaches by making

them a more attractive mode of transport through the

Heathrow’s aspirations are supported and should develop the

public transport network. There is also potential for services to feed

into Buckinghamshire using key transport hubs.

✓




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introduction of new express services, improvements to

the frequency and alignment of existing routes, and

extending operating hours. A draft Surface Access

Strategy will be consulted on at the Airport Expansion

Consultation (2019).

The Elizabeth Line will begin operating to Heathrow in

2019, offering the potential for connections to be

made from destinations in Buckinghamshire. In

addition, Heathrow is supporting Network Rail’s

proposal for a Western Rail Link to the airport from the

Great Western Mainline, which is the subject of a

separate DCO application. This may also provide

opportunities for connecting bus and coach services to

Reading and Maidenhead from Buckinghamshire.

Not certain if ‘on-demand services’ which are a cross between

private taxi and public bus should be defined as public transport.

✓ Heathrow is exploring the potential of Demand

Responsive Transport (DRT) services to fill gaps in

the public transport network early in the morning or

late at night, particularly to enable colleagues to travel

to and from the airport. Heathrow intends to trial DRT

services in the near future and roll them out to further

areas if the prove to be successful. Heathrow

acknowledges that as DRT technology evolves, it may

be necessary to adapt current definitions of what

constitutes public transport.

A commitment should be made to improve links to areas with low

public transport use.

✓ On the basis of the analysis carried out to date

Heathrow is confident that the broad range of surface

access measures suggested at the Airport Expansion

Consultation One (January 2018) provides an

effective means of meeting the surface access targets




PC MC WC

to increase the proportion of passengers travelling by

public transport and reduce the number of colleague

car trips. Further assessment and analysis is ongoing

by Heathrow to determine exactly which combinations

of measures are required by which date to deliver the

best surface access for the expanded airport.

Heathrow is working with Highways England, Network

Rail and TfL to co-ordinate the expansion plans with

their investment plans in the Heathrow area.

As part of an integrated surface access strategy, a

variety of measures are being considered to help meet

the surface access targets. Heathrow supports the

provision of improved public transport facilities to and

from the airport and is currently investigating a

number of options to improve access by rail,

underground and bus. For instance, Heathrow is

investigating the possibility of improving and extending

local bus services to the airport to capture demand

from wider areas. Heathrow is supporting Network

Rail’s DCO application for a Western Rail Link to

Heathrow and is supporting the emerging plans for a

Southern Rail Link to Heathrow. DfT is exploring the

potential for a Southern Rail Link to be brought

forward with private sector involvement. Elizabeth Line

services will begin operations to Heathrow in 2019,

which will provide a direct rail link to Heathrow from

the City and areas to the east for the first time.

The local area is poorly served by sustainable transport access to

the airport.

✓ The ANPS states at paragraph 3.36 that, “Heathrow

Airport already has good surface transport links to the

rest of the UK. It enjoys road links via the M25, M4,




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M40 and M3, and rail links via the London

Underground Piccadilly Line, Heathrow Connect, and

Heathrow Express. In the future, it will connect to

Crossrail, and link to HS2 at Old Oak Common. Plans

are being developed for improved rail access: the

proposed Western Rail Access could link the airport to

the Great Western Main Line, and Southern Rail

Access could join routes to the South Western

Railway network and London Waterloo Station. This

varied choice of road and rail connections makes

Heathrow Airport accessible to both passengers and

freight operators in much of the UK, and provides

significant resilience to any disruption.” Where there

are gaps in provision, the Surface Access Strategy -

informed by the technical assessment work in the

Transport Assessment - will set out practical

measures, including new and enhanced public

transport provision, that will seek to address them. A

draft Surface Access Strategy and a Preliminary

Transport Information Report (PTIR) will be consulted

on at the Airport Expansion Consultation in June

2019.

Improvements to sustainable transport modes need to be

implemented before the expansion is complete.

✓ On the basis of the analysis carried out to date,



Consultation One (January 2018) provide an effective

means of meeting the surface access targets and

pledges. Further assessment and analysis is ongoing


of measures are required, by which date, to deliver the





PC MC WC




Keen to work with Heathrow to ensure that hub locations are

appropriately located to enable airport related employees to travel

by public transport.

✓ Many Heathrow colleagues live in boroughs close to

the airport such as Hillingdon, Hounslow, Ealing,

Slough and Spelthorne. These are also the areas with

the highest proportion of people travelling to work by

public transport. Where there are good alternatives,

people are using public transport or other sustainable

modes such as car sharing to get to work. Heathrow

will work with TfL and other transport operators to

create the conditions that will encourage colleagues to

use public transport rather than drive to the airport, by

making it more attractive as an option.




in a dedicated commuter team, as well as local

transport, to make it easier and more affordable for

people to use. Heathrow will seek feedback on more

detailed plans as part of the draft Surface Access

Strategy which will be published as part of Airport

Expansion consultation in June 2019.

Rapid low emission transport schemes must be located where

demand is and the number of shuttles operating from hotels should

be limited with mass rapid transit facilities used to access the

airport.

✓ Heathrow will work with TfL and local authorities to

identify new and improved bus priority measures that

could be considered to improve the reliability and

experience of bus users to/from Heathrow. As

explained in the Our approach to developing a surface

access strategy document at the Airport Expansion




PC MC WC

Consultation One (January 2018), Heathrow is

considering the following bus priority measures for the

airport:

• Implementing an internal campus road network that enables easy access to terminals for buses

• Introducing bus-only corridors to Heathrow – exact locations to be determined; and

• Providing off-campus bus priority measures - re-allocate road space for buses (working with TfL/highway authorities) and coaches (working with Highways England) to improve journey times and reliability.

The Surface Access Strategy is also supported by an

Intelligent Mobility Strategy which considers the

potential for technological change in transport,

including the potential development of autonomous

vehicles, and explains how the benefits arising from

these changes can be captured. Heathrow will seek

feedback on more detailed plans as part of the draft

Surface Access Strategy which will be published as

part of Airport Expansion Consultation in June 2019.

Concerns expressed about the impact of the proposals on local taxi

companies. Discussions should take place with Heathrow regarding

the proposals for a preferential supplier system for taxi firms.

✓ The ANPS contains surface access targets around

public and colleague mode share which Heathrow will

need to meet. Heathrow’s strategy to meet these

requirements will necessarily include consideration of

taxis and private hire vehicles (PHV). Measures to reduce the number of taxis and private hire vehicles

that travel to/from the airport empty are supported. These vehicles

✓




PC MC WC

should not be defined as public transport. Heathrow is considering a range of measures to make

taxi operations more efficient, backfilling return

journeys and delivering higher vehicle occupancy.

These could include:

• priority taxi queueing for full arrivals - taxis arriving with a passenger are given a preferential lane for re-ranking which would reduce the amount of time spent waiting for their next fare;

• a taxi sharing scheme - many taxi passengers are heading to central London and other high density urban locations. Priority lanes within the forecourt for these customers that are willing to share a taxi could decrease vehicle traffic and reduce the waiting times and costs for passengers.

Local taxi companies will have the opportunity to

comment on Heathrow’s proposals to make taxi

operations more efficient as they emerge through the

pre-application consultation process.

The draft Surface Access Strategy will be published

as part of the Airport Expansion Consultation in June

2019 and will explain Heathrow’s preferred options for

managing taxis and PHVs at the airport. More efficient

management of taxis at the airport will reduce the

need for taxis to park and wait in streets around the

airport. Heathrow will also work with local authorities

to develop schemes to prevent taxis parking on local

residential roads, including support for the introduction

of Controlled Parking Zones (CPZs) and their

More information is required to demonstrate the effectiveness of the

proposed measures to make taxis more efficient. This should

include more innovative solutions including the use of online trip-

matching systems and reward and penalties for efficient and

inefficient operators such as introducing a charter for all private

hire vehicles seeking to access the site which encourages

backfilling or incentivising operators to sign up to the charter

and/or a reward scheme.

✓




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enforcement.

Concern expressed over the feasibility and deliverability of satellite

consolidation sites, the ability to incentivise and/or compel

companies to participate, and the lack of detail on mitigation if such

plans are not successful.


2018), Heathrow explained its proposals for a “Freight

Hub” in the Our Emerging Plans document. Chapter

10 included three options for a modal hub that sought

to offer opportunities to consolidate freight operations

in locations close to existing infrastructure, such as

main access routes to the airport and the existing rail

head at Colnbrook. In addition, four locations were

considered for a “Truck Park” in order to provide

appropriate facilities for long distance drivers and

improved management for HGVs, mitigating the

impact of freight traffic on the roads around Heathrow.

Through the masterplan, the modernisation of the

airport cargo facilities will help allow more cargo to be

processed on airport, reducing the need for goods to

be trucked to and from off airport warehouses.

Cargo and logistics facilities around the airport have

grown in an incremental and organic way which

means there are lots of facilities in different locations.

By working with the local authorities to more

proactively plan the land uses around the airport,

Heathrow can provide facilities in appropriate

locations, helping to reduce shuttling movements

through consolidation of loads and reducing impacts

on local communities.

Heathrow will be working with TfL and other




PC MC WC

authorities on re-timing journeys that are not time

critical to outside peak periods, monitoring of routing

for HGVs and other freight vehicles, as well as

ensuring there are appropriate measures in place for

those that do not comply.

In October 2017, Heathrow published a “Blueprint for

Sustainable Freight”. This included ten measures to

provide for more efficient management of freight

vehicles, in partnership with industry bodies and major

freight operators. The ten steps included:

• Using innovation through tools like a load

consolidation “Heathrow Cargo Cloud” app for

local forwarders and the trial of low emission

freight vehicles and geo-fencing technology to

reduce emissions on local roads;

• Investments in airfield charging points to

install an ultra-low emission zone for vehicles

on-airport;

• Modernising cargo infrastructure at the airport

to allow for more airside transhipments,

consolidation points away from airport local

roads and a new cargo village that reduces

unnecessary vehicle movements;

• Working with local authorities to address

congestion points with a Code of Conduct for

operators, and a joint strategic freight plan for

local roads.

Following ongoing technical assessment work and




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engagement, Heathrow will publish its preferred

options for a Freight Hub and measures to manage

freight trips around the airport in a draft Surface

Access Strategy and an Updated Scheme

Development Report at the Airport Expansion

Consultation in June 2019.

Heathrow’s stated aim to ‘grow the airport without increasing traffic’

does not appear to be realistic with respect to freight.

✓ Heathrow will continue to strive to meet its pledge to

have landside airport-related traffic no greater than

today, including freight traffic. Heathrow will help

operators clean up the vehicle fleets through a range

of different initiatives, including increasing efficiency,

optimising the fleet mix and modernisation of airport

cargo facilities. The approach and options being

considered in relation to freight were set out in the

Airport Expansion Consultation One (January 2018) in

the Our approach to developing a surface access

strategy. The preferred option for freight management

under expansion will be set out in the Airport

Expansion Consultation in June 2019. Heathrow

published a Blueprint for Sustainable Freight as part of

the Heathrow 2.0 Sustainability Strategy, which has

informed the emerging freight proposals for the

expansion plans.




be trucked to and from off airport warehouses. Cargo

and logistics facilities around the airport have grown in

an incremental and organic way which means there

are lots of facilities in different locations. By working

There should be a combined logistics and freight strategy and an

improvement on the impact from freight.

✓

It is not within Heathrow’s remit to consolidate the freight loads of

cargo companies and applying road user charging to freight

vehicles will increase prices with no decrease in traffic and

pollution.

✓

Heathrow working with local communities and freight industry

ahead of expansion is welcomed.

✓

The impact of an increase in freight needs to be addressed

including HGV parking, road congestion, infrastructure damage and

the increase in air pollution from diesel engine HGV vehicles.

✓

Heathrow’s stated aim to ‘grow the airport without increasing traffic’

does not appear to be realistic with respect to freight.

✓




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with the local authorities to more proactively plan the

land uses around the airport, Heathrow can provide

facilities in appropriate locations helping to reduce

shuttling movements through consolidation of loads

and reducing impacts on local communities.

Heathrow will work with TfL and other authorities on

re-timing journeys that are not time critical to outside

peak periods, monitor routings for HGVs and other

freight vehicles, and ensure that there are appropriate

measures in place for those that do not comply.

Concerns expressed about the construction of car parking and it

contradicts the suggestion that most passengers/freight will travel

to/from the airport by public transport.

✓ The total number of parking spaces available at

Heathrow is limited by an existing planning condition.

Heathrow’s current masterplan proposals would seek

to provide a similar number of car parking spaces as

permitted at the airport today, despite the increase in

passenger and staff numbers that would result due to

expansion. A sustainable level of passenger car

parking will continue to be provided as an alternative

to “kiss and fly” trips, which are an inefficient means of

accessing the airport. As part of the plans to reduce

colleague car trips, Heathrow will reduce the number

of parking spaces available for colleagues working at

the airport. However, Heathrow recognises the need

to be careful that this does not encourage more pick

up and drop off trips, whether by private car or taxi.

With expansion, a lot of the car parking along the

north side of Heathrow will be demolished. To ensure

Heathrow efficiently use all land available today and

There must be no increase in road traffic and therefore no need for

new car parks or more road capacity.

✓




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minimise the need to acquire land, it is likely that car

parking will re-provided by creating multi-storey car

parks.

Managing car parking is part of how Heathrow will

meet the surface access targets in the ANPS and how

Heathrow will manage air quality around the airport. In

addition to the re-provision of demolished car parking,

Heathrow’s thinking at Airport Expansion Consultation

One (January 2018) was to vacate some of the

existing surface level passenger and colleague car

parks and use a smaller number of multi-level car

parking sites, which are located near main access

routes and have dedicated access to the front door of

terminals. This will reduce traffic circulating around the

airport and improve way-finding. The consolidation of

passenger and colleague car parking also provides

the flexibility to change colleague and passenger car

parking allocations over time, in line with phasing and

meeting time-dependent NPS targets, as well dealing

with future vehicle types and technologies.

It is unacceptable for expansion to have a detrimental effect on the

road network as it would not only impact airport users but people

and freight using the network and local communities.






and pledges set out in the ANPS. Further assessment

and analysis is ongoing by Heathrow to determine

Concerns expressed about the negative impacts during

construction and operation, and due to the impacts of congestion,

the roads will be unable to cope with the increased number of cars.

✓




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Expansion would result in worsening congestion and delays on the

roads and increased crowding on the railways.

✓ exactly which combinations of measures are required,

by which date, to deliver the best surface access for

the expanded airport. Heathrow is working with

Highways England, Network Rail and TfL to co-

ordinate the expansion plans with their investment

plans in the Heathrow area.


2018), the Our approach to developing a surface







Emerging Plans document set out options that would

rationalise the existing 4 terminals, focused on

Terminal 5 and Terminal 2. This would focus activity

and trips along the existing public transport spine (with

the addition of new Elizabeth Line services) and

improved bus and coach facilities at the Terminals.


technical information in the PTIR, will explain

Heathrow’s preferred options for the transport

infrastructure needed to support the expansion plans,

in the context of increasing the use of public transport

by passengers and colleagues. This includes plans for

a new parking strategy and freight/logistics strategy.

Heathrow will be working with DfT, Highways England,

Network Rail, the local transport authorities and other

transport operators in developing the Surface Access

The plans for keeping traffic flowing with the added pressure of

extra transport to and from Heathrow are not clear.

✓

The motorway network around Heathrow already suffers from

congestion and high pollution levels. Expansion should address

this by providing measures to combat congestion and pollution and

encourage sustainable means of travel.

✓

The DfT and the local transport authority develop a scheme to

minimise effects of the airport on surrounding communities and

which provides additional funds to the local highway network and

includes sustainable travel options for those working at the airport.

✓

A significant proportion of trips to the airport are by road which has

resulting road congestion impacts on local businesses.

✓

The area is already heavily congested, and improvements would

make the road network more efficient for users.

✓




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Strategy for the Project. The PTIR will be an Airport

Expansion Consultation (June 2019) document and

will summarise and illustrate the outputs from the

transport modelling. It will identify locations where the

project will potentially have material impacts on the

operation of the transport networks that require further

detailed assessment. It will also set out, at a high-

level, the strategy for mitigating any impacts on the

surrounding transport networks that are considered

severe. A Transport Assessment will be submitted

with the DCO application and report on the results of

the further detailed assessment work and, for

locations where the impacts of the project are

determined to be severe, will set out in more detail the

proposed mitigation strategy.

A Code of Construction Practice will also form part of

the DCO application for expansion. It will set out how

construction traffic will be managed to minimise

environmental effects. Heathrow will consult on the

provisions contained in the draft Code of Construction

Practice at the Airport Expansion Consultation in June

2019.

Through effective planning, Heathrow aims to

minimise the amount of construction related traffic on

the roads. It will encourage suppliers and their

workforce to use the existing public transport

infrastructure and aim to move as much material as

possible in and out of the construction site using the

existing rail route in the north west of the proposed

Expansion site. This approach for construction

materials is closely associated with Heathrow’s plans




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for using remote logistics hubs across the UK, which

should both reduce construction material traffic and

the numbers of construction workers engaged directly

on the site.

There should be a ban on construction traffic on the A4 over

Maidenhead Bridge as it is the only access from the west in the

case of a temporary closure of the M4.

✓ Heathrow will employ a number of measures to

mitigate the impact of construction related traffic on

the local and strategic road network. These will

include:

• Maximise use of rail freight to reduce road deliveries.

• Construct a network of construction and haul roads for the site-related traffic to minimise the need of using public roads and so mitigate the risk of traffic backing-up onto the strategic road network.

• Implement a delivery management system to distribute the arrival of materials to site throughout the day to avoid peak hours.

• Create lorry parking facilities to hold vehicles off the public highways as and when required.

• Open the new sections of road infrastructure before the existing is closed.

• Maximise opportunities for off-site manufacture to reduce the need for on-site workforce and to consolidate material deliveries.

• Maximise the use of public transport and buses to reduce car trips during construction.

The A4 at the grade I listed Maidenhead Bridge is

maintained by The Royal Borough of Windsor and




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Maidenhead Borough Council, as the local highways

authority. Therefore, it has the relevant powers to

place weight restrictions on bridges and structures on

its road network and more generally protect heritage

assets in its area. Heathrow will work with the local

highways authorities around the airport to mitigate the

impact of the construction and operation of the

expanded airport, including the management of HGV

traffic where technical assessments and traffic

modelling show this to be necessary.

Concerns expressed about the effect of increased traffic on the M4

corridor in to and out of London, Hogarth roundabout and the

surrounding roads.

✓ Having taken account of feedback, Heathrow revised

early proposals in order to avoid changes to the

M25/M4 interchange.

Heathrow does not believe that the M4 and A4 (Great

West Road), including the Hogarth Roundabout in

Chiswick, need to be widened or altered as a result of

the Project. There are three key elements to the

emerging surface access strategy: making public

transport the preferred choice for more passengers;

making more efficient use of road transport; and

continuing to reduce the number of colleagues driving

to work. By the time Heathrow is expanded, and for

the first time, the airport will be part of an integrated

transport network served by at least 3 railway lines

and 5 motorways to North, South, East and West. This

will ensure the continuation of the trend that has seen

passenger numbers at Heathrow double since 1991,

but airport-related road traffic remain largely static.

Heathrow plans to almost double passenger journeys

made by public transport from 18 million (in 2013), to




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35 million by 2030.

The DfT confirmed that “The Government is looking at

M4 capacity as part of normal roads investment

planning. London’s population is growing and

congestion on the M4 is not just an airport issue – if

improvements benefit airport users then the airport is

expected to pay a share of the cost in line with

existing policy on the funding of surface access

schemes.” Heathrow recognises the existing

challenges on the road network in the Heathrow area,

with high traffic levels and local air quality issues.

Heathrow will work with the DfT and Highways

England as part of the planning process in order to

determine the most appropriate solution.

It Is not clear how route changes to the M25, A4, A312, A30 and

A3044 will ensure that there will be no increase in airport related

traffic on them.

✓ The proposed new runway location will result in the

loss of the Western Perimeter Road and parts of the

Northern Perimeter Road, and result in severance of

the A4 (Bath Rd) and A3044 (Stanwell Moor Rd).

These changes will require close working with a

number of interested highway authorities: Slough

Borough Council (A4), TfL (A4, A30 and A312),

London Borough of Hillingdon (A3044), as well as

Highways England as an interested party operating

nearby and parallel roads. To maintain traffic

connectivity in the area and reduce potential effects

on road users, the existing A3044 and A4 will be

maintained until the new replacement roads are

complete. Heathrow will also aim to reduce the effect

of construction traffic using these existing roads by

creating an internal construction road system as soon

Concern expressed about the impacts on traffic and congestion on

local roads, the M25, the M4 and the M40.

✓

Concerns expressed that changes to road layouts and more public

transport and train links will cause more disruption to communities.

✓

The commitment to not increase airport related traffic will

redistribute traffic on some sections of the strategic road network

for which Heathrow will have to mitigate.

✓




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as practical. More information about how Heathrow

will manage traffic flows during the construction stage

will be provided at the Airport Expansion Consultation

in 2019. In particular, the Updated Scheme

Development Report and draft Code of Construction

Practice will explain how the impacts of the

construction stage will be mitigated.

Detailed designs and programmes of work for the M25

diversion and works to the M4 spur are still being

developed, so it is not possible to be specific about

the duration of any works at this stage. As much as

possible of the construction works will be undertaken

alongside or near to the existing carriageway as it

continues to operate, to minimise disruption to road

users.

A wider surface traffic study and road improvements would be

supported.

✓ Heathrow is committed to meeting the targets for





greater than today.


technical information in the PTIR, published at Airport

Expansion Consultation in June 2019 will explain






The Surface Access Strategy would result in improvements to

public transport in general and in improved bus services, improved

public transport links, improved accessibility to and around the

airport and it would also ease traffic congestion.

✓




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The surface access strategy would not resolve existing traffic

congestion and there would be impacts on local people and local

communities from both traffic and unregulated parking in villages,

specifically by taxis.




Consultation One (January 2018) provide an effective

means of meeting the surface access targets and

pledges. Further assessment and analysis is ongoing


of measures are required, by which date, to deliver the





Heathrow will be part of an integrated transport

network with connections to the north, east, south and

west connecting all of the UK. This will ensure

Heathrow continues the trend that has seen

passenger numbers at the airport double since 1991,

but airport-related road traffic remain largely static.

Rail and public transport will not absorb this excess traffic, as it

would be dependent on existing overloaded road and rail networks

✓

Concerns expressed about bottlenecks during the rebuilding of the

M25 Wisley interchange and upgrading the Dennis interchange.

✓ Heathrow is working closely with Highways England to

develop the outline solution for the elements of their

network that are affected by the expansion of the

airport. This includes detailed consideration of the

construction methodology to be adopted, ensuring

minimum disruption to the users of the M25.

Heathrow’s aim is to have agreement with HE on the

main construction methodology before the Airport

Expansion Consultation (June 2019) takes place.

Heathrow is feeding into and working with Highways

Concerns expressed about an increase of freight and passengers

on the M25 and A3.

✓

Concerns expressed about the impact of future development on the

South West Quadrant and southern stretches of the M25.

✓

A national approach to traffic is required and opportunity for

councils to discuss transport to/from the airport across the M3

✓




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corridor would be welcomed. England on the M25 South West Quadrant Study.

There are currently a number of different proposals

that could connect the existing South Western railway

network to Heathrow via a new Southern Rail Link.

There is currently no railway connection between

Heathrow and the south so this link would fill a key

gap in the rail network. A feasibility study undertaken

by Network Rail showed that there is a strong

business case for the proposals and that there are

credible infrastructure solutions that should be

explored further. Heathrow’s analysis to date indicates

that the proposed surface access strategy is not

reliant on a Southern Rail Link to deliver the mode

share targets in the NPS. DfT is exploring the potential

for a Southern Rail Link to be brought forward with

private sector involvement and Heathrow is supportive

of this initiative.

Concerns expressed about the impact on transport routes such as

the M25 and the North Downs Line (Reading to Gatwick) if

appropriate mitigation is not put in place.

✓

There is no commitment to provide improved public transport to

meet the needs of an expanded airport, particularly to the south.

✓

There are a number of key areas on the highway network requiring

mitigation: Beaconsfield; Burnham; Iver including the Five Points

Roundabout and to address poor road traffic accident record, Iver

Heath (Willow Lane) and north-south connectivity via High

Wycombe and to Aylesbury.

✓ Heathrow’s proposals for the strategic and local road

networks will be focused on mitigating the impact of

the expansion project having regard to the ANPS

which states that the scheme should be, “cost-efficient

and sustainable, and seek to minimise costs to

airlines, passengers and freight owners over its

lifetime”. The scale and nature of the mitigation

proposed will be developed in that context and

informed by traffic modelling and analysis of the likely

significant impacts due to the construction and

operation of the expanded airport.




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Heathrow recognises the existing challenges on the

road network in the Heathrow area, with high traffic

levels and local air quality issues. There are three key

elements to the plans to enhance surface access to

the airport: making public transport the preferred

choice for more passengers; making more efficient

use of road transport; and continuing to reduce the

number of colleagues driving to work.

Transport links are important but expressed concern about new

transport infrastructure affecting the Longford River.

✓ The Project will extend the Airport's footprint into the

Colne Valley, in the path of existing alignments of

watercourses and areas of floodplain storage within

the valley. An extensive and detailed evaluation of

potential sites and environmental impacts is being

undertaken in order to identify the preferred location

and routes of the river diversions and flood storage

areas, taking into account the consultation responses.

For more information on our response on the effects

of the Project on rivers, please see Chapter 12.

The Environment Agency or another body be mandated to monitor

the full environmental impact of the airport, including any additional

congestion.

✓ Heathrow will be working with Natural England, the

Environment Agency and other stakeholders to deliver

appropriate solutions for the natural environment and

waterways.

Heathrow will seek to agree details about the

environmental monitoring regime with stakeholders,

including the Environment Agency. Monitoring

commitments will be secured in the draft DCO that will

be submitted with the application. The emerging




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proposals for monitoring will be set out in the Airport

Expansion Consultation (June 2019) documents,

including the Preliminary Environmental Information

Report (PEIR).

Campaign indicated expansion should not lead to an increase in

climate-changing emissions, or any increase in motor vehicle

volumes (and resulting pollution and emissions).

✓ The Our approach to air quality document published at

Airport Expansion Consultation One (January 2018)

explained the goals and targets identified in the

Heathrow 2.0 sustainability strategy. This stated

Heathrow’s goal to reduce emissions from airside

vehicles by working with partners and to meet a target

to reduce NOx emissions from airside vehicles by at

least 50% by 2020 and 70% by 2025 (from 2013

baseline).

The draft Surface Access Strategy will be an Airport

Expansion Consultation (June 2019) document which

will explain Heathrow’s preferred options for promoting

the use of cleaner vehicles accessing and servicing

the airport.

Concerns expressed about the indirect impacts of increased levels

of traffic and parking, new transport infrastructure and new railway

lines.

✓ An extensive and detailed evaluation of potential sites

has been undertaken in order to identify the preferred

location for transport infrastructure to serve the

expanded airport, taking into account the consultation

responses. Heathrow believes that the proposals

comprise the most sustainable balance between being

appropriately located, comprising an acceptable level

of land take, and minimising impacts upon the

environment and communities as far as possible.

Further information will be contained in the PEIR,

Trust welcomed all transport that minimises environmental impacts ✓

The proposals for surface access are unrealistic and unacceptable

due to the massive land grab which will lead to blight in

neighbouring communities.

✓




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The Surface Access Strategy is not accurate in terms of the number

of people affected or the effects on quality of life.

✓ which Heathrow will consult on as part of the Airport

Expansion Consultation in June 2019.

The surface access options have not been through a proper

assessment to consider the environmental, operational, economic

and financial implications.

✓

Concerns expressed about negative impacts on air pollution due to

more traffic, longer journey times and further congestion.

✓

The Habitats Regulations require a high degree of certainty that any

measures put in place to avoid or mitigate impacts are deliverable.

✓ The Secretary of State for Transport, as the

competent authority, will be required to undertake a

Habitats Regulations Assessment of the Project in the

context of European sites. In order to inform the

Secretary of State in making their decision, Heathrow

will provide the information required for an

assessment to take place. A HRA Screening Report

will be prepared by Heathrow and consulted on as

part of the information provided at the Airport


Heathrow is committed to achieving an overall net

gain in biodiversity and this will include consideration

of opportunities to conserve and enhance the Ramsar

and Special Protection Area (SPA) designations of the

surrounding borough’s reservoirs.

The Surface Access Strategy is dependent on projects to manage

current demand that are funded and controlled by other bodies.

✓ The ANPS sets out targets for Heathrow to increase

the public transport mode share of passengers and

reduce the number of colleague car trips to the airport.




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Heathrow will work with TfL, Network Rail and other

transport providers/ operators to ensure these targets

are met and in order to understand the target

completion dates of any third party or external

schemes included in existing rail, road or other

transport investment plans. Paragraph 5.12 of the

ANPS states that, “Heathrow must demonstrate that

Highways England, Network Rail and any relevant

highway and transport authorities and transport

providers have been consulted, and are content with

the deliverability of any new transport schemes or

other changes required to existing links to allow

expansion within the timescales required for the

preferred scheme as a whole, the requirements of the

ANPS and other statutory requirements.”

Heathrow has a strong track record of investing in

surface access improvements. Heathrow is committed

to funding all of the required road diversions alongside

a fair and reasonable contribution to new rail

infrastructure. Some surface access infrastructure will

be secured in the DCO itself, while funding and

support for schemes that are being delivered by third

parties can be secured through planning obligations, if

necessary.

This is consistent with the Government’s Aviation

Policy Framework that states "The general position for

existing airports is that developers should pay the

costs of upgrading or enhancing road, rail or other

transport networks or services where there is a need

to cope with additional passengers travelling to and

from expanded or growing airports. Where the




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scheme has a wider range of beneficiaries, the

Government will consider, along with other relevant

stakeholders, the need for additional public funding on

a case-by-case basis."

The provision of varied, affordable and reliable surface access

options is supported but concerns expressed about the affordability

of the proposals.

✓ The expansion of Heathrow will be privately funded

and no public funds will be required.

The ANPS para. 5.20 states “Where a surface

transport scheme is not solely required to deliver

airport capacity and has a wider range of

beneficiaries, the Government, along with relevant

stakeholders, will consider the need for a public

funding contribution alongside an appropriate

contribution from the airport on a case by case basis”.

Heathrow has a track record of investing in surface

access improvements at the airport and will fund all of

the road diversions required by expansion alongside a

fair and reasonable contribution to new rail

infrastructure, in accordance with the CAA policy on

surface access.

Heathrow continues to engage regularly with airlines

and stakeholders to develop its draft Surface Access

Strategy and the preferred masterplan.

Airlines and passengers should not be responsible for subsidising

national programmes or funding betterment of other schemes and

further engagement should be had with the Airline Community in

the development of the Surface Access Strategy.

✓

Airlines and passengers should not be responsible for subsidising

national programmes or funding betterment of other schemes and

requested further engagement with the Airline Community in the


✓

All pre-negotiated mitigation works, including upgrading local road

and rail networks, should be forward-funded by Heathrow, or

through Heathrow securing national Government funding.

✓ The Project will be privately funded and no public

funds will be required to deliver the airport

infrastructure. Heathrow has a strong track record of




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Contributions towards the costs of major rail schemes will need to

be secured as without sufficient investment in the public transport

network negative impacts will result on the road network over a

wide area.

✓ investing in surface access improvements. Heathrow

is committed to funding all of the required road

diversions alongside a fair and reasonable

contribution to new rail infrastructure.

Some surface access infrastructure will be secured in

the DCO itself, while funding and support for schemes

that are being delivered by third parties can be

secured through planning obligations.


Policy Framework that states "The general position for









a case-by-case basis."

Heathrow should support and commit to help pay for Southern Rail

but there is an opportunity for a ‘Super Public Transport Levy Fund’

to support funding of major surface access schemes and

sustainable transport projects.

✓

There are no commitments to funding the necessary improvements

and the proposals would not work or make any difference.

✓

Concern at the lack of commitment from Heathrow to fund new

public transport infrastructure.

✓

A fund must be provided to support major surface access schemes

and sustainable transport projects in the wider area to the benefit of

local communities.

✓

LEPs have limited funds for transport investment and should not be

expected to cover the costs of improvements or mitigation

measures required as a result of expansion

✓

Concerns expressed that the Government will end up paying

Heathrow's surface access costs and the surface access initiatives

should be pursued regardless of a third runway so that rapid

improvements to air quality are delivered over and above those in

the draft London Plan

✓




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The ambition to make the Project sustainable by providing high

quality reliable public transport links is welcomed, however, there is

uncertainty as to who will provide and pay for the different schemes

and a lack of modelling to demonstrate modal shift will take place.

✓

Heathrow should be relieved of any obligation to fund enhanced rail

access infrastructure and should instead contribute to new rail links

through expenditure that can be taken in to account by the CAA.

✓ The Project will be privately funded and no public

funds will be required to deliver the airport

infrastructure.

Heathrow is committed to funding all of the required

road diversions alongside a fair and reasonable

contribution to new rail infrastructure in accordance

with the CAA policy on surface access.

The Project should not be used to delay investment in surface

access improvements to the airport that are already developed and

needed.

✓ The expansion plans are being developed around

existing commitments such as the Elizabeth Line and

Piccadilly Line upgrade. Heathrow’s plan is to focus

development on the existing public transport spine

that runs between the CTA and Terminal 5 / Terminal

4.

The productivity of the South East is falling behind other areas and

local authorities.

✓ A new runway will double Heathrow’s cargo capacity

and create up to 40 new long-haul trading routes to

fast growing economies. This will create new

opportunities for businesses in the South East and

beyond, both large and small, to trade with the rest of

the world.

The package of transport improvements, that will form

an important element of the expansion plans, will

create new and enhanced public transport links to

South East England. The expansion plans also




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provide an opportunity to improve traffic conditions on

the strategic road network around the airport such as

the M25 and A4. All of these improvements will

contribute to improving the productivity of London and

the South East.

There is a lack of tangible commitments by Heathrow to ensure no

increase in airport related traffic.




Consultation One (January 2018) and the emerging

Airport Expansion Consultation (June 2019) provide

an effective means of meeting the surface access

targets and pledges. Further assessment and analysis

is ongoing by Heathrow to determine exactly which

combinations of measures are required, by which

date, to deliver the best surface access for the

expanded airport. Heathrow is working with Highways

England, Network Rail and TfL to co-ordinate the

expansion plans with their investment plans in the

Heathrow area.

If Heathrow’s analysis has identified an alternative package of

schemes this should be published together with details of how

these schemes will be delivered.

✓

The modal shift targets should be reset to reflect that the airport is

taking its ‘fair share’ of congestion and will not increase road traffic

but any schemes aimed at reaching the targets must provide value

for money and be in the interests of passengers.




ANPS. Heathrow will also continue to strive to meet

its pledge to have landside airport-related traffic no

greater than today.


Heathrow meeting its modal shift and airport related traffic

commitments is very important in order to ensure that the existing

road network in Elmbridge is not put under further strain from traffic

✓




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generated by a third runway. 2018), the Our approach to developing a surface













Terminals. Fewer larger terminals will also reduce the

need to travel around the airport, between terminals.

The draft Surface Access Strategy to be published at

Airport Expansion Consultation in June 2019,

supported by technical information in the PTIR, will

explain Heathrow’s preferred options for the transport



by passengers and colleagues. This will include plans

for a new parking strategy and freight/logistics

strategy.




Meeting modal split and sustainable transport targets without major

infrastructure investment needs to be properly evidenced,

especially given recent evidence from the NPS consultation that

passenger demand will grow faster than first expected.

✓

Transportation considered the modal shift target will be difficult to

achieve and expressed concern that there is minimal explanation as

to how the increase in public transport usage would be achieved

and funded.

✓

The lack of a detailed integrated Surface Access Strategy for

passengers, freight and workforce was a serious failing and that

without major infrastructure investment Heathrow will be unable to

meet modal split and sustainable transport targets.

✓

Specific targets for maximising the proportion of journeys made to

the airport by public transport, cycling or walking should be set and

should apply to both the workforce and passengers.

✓

Incentivising and supporting modal share shift is insufficient and

requires input from and cooperation with others.

✓

The commitments to increase passenger numbers travelling by

public transport and not increase airport related traffic are not

credible.

✓

For the targets to be achieved, Heathrow will need to demonstrate

support for a step change in public transport provision to the

✓




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airport.

The focus should be on improving public transport or electric cars,

the proposal was motivated by increasing revenue for the airport

rather than reducing impacts or delivering road improvements, it

will not reduce the number of cars on the road or it will just move

congestion to other places and drive businesses away from the

airport affecting competitiveness.

✓

There is insufficient modelling or supporting evidence to

demonstrate that the aim of no increase in road traffic is anything

other than ambition.

✓

Concerns expressed that without additional sustainable surface

access the airport will not be able to contribute fully to the economy

or meet the demands of future air travel growth.






and pledges. Further assessment and analysis is

ongoing by Heathrow to determine exactly which






Heathrow area.

The pledge has ‘no net increase’ in airport related traffic and

corresponding investment in surface access capacity can enable

the required improvements in air quality.







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Heathrow have not demonstrated how targets for mode share,

employee car journeys and freight movements relate to known Air

Quality and/or congestion policy

✓ Consultation One (January 2018) provides an









Heathrow area.

Given that non-airport-related road traffic is a

dominant source of emissions around Heathrow,

national and regional measures to improve air quality

will have an important role in addressing the wider

pollution issue across the UK that affects

concentrations in the area.

Since publication of the Airports Commission’s final

report, the Government has undertaken further work

on air quality to understand the implications of

updates to the tools published by Government to

calculate road vehicle emission rates. The

Government’s air quality re-analysis and the Appraisal

of Sustainability, published alongside the ANPS, are

clear in stating that the Project is capable of being

delivered in accordance with legal obligations for air

quality.

The ANPS recognises a range of potential mitigation

measures that Heathrow could put in place to help

meet legal air quality obligations and improve air

quality around the airport. Heathrow is already

Heathrow have not demonstrated how mode share and employee

car journey targets as well as targets to limit freight movements,

relate to known Air Quality and/or congestion policy.

✓




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delivering a number of these measures today. The

expansion of Heathrow provides the opportunity to

expand these initiatives and develop new ones, as

well as a chance to bring major change to the

surrounding road and public transport network. More

information about this will be set out at the Airport


Heathrow should analyse the needs of specific groups of workers

and passengers before defining the requirements.

✓ Heathrow has been working with colleagues at the





people to use, including funding the Heathrow Free

Travel Zone.

The PTIR will be published as part of the Airport

Expansion Consultation in June 2019 and will

summarise and illustrate the outputs from the

transport modelling and identify locations where the

project will potentially have material impacts on the

operation of the transport networks that require further

detailed assessment. It will also set out, at a high-

level, the strategy for mitigating any impacts on the

surrounding transport networks that are considered

severe.

Further technical assessment work and consideration

of the feedback from the statutory consultation,

including comments about the PTIR and the draft

Surface Access Strategy, will inform the preparation of

a Transport Assessment. This will be submitted with

the DCO application and will report on the results of




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Concerns expressed that there is not a coherent view on how the

airport sits within the wider transport network and a more coherent

and integrated strategy should be produced, with Heathrow taking

the lead.

✓ Heathrow will submit a Surface Access Strategy with

the DCO application for the Project, which will accord

with the ANPS. In so doing, the Strategy will set out

“improvements to Heathrow Airport’s transport links to

be able to support the increased numbers of people

and freight traffic which will need to access the

expanded airport.” (Paragraph 5.8).

The Airport Expansion Consultation One (January

2018) materials presented the options that were being

considered by Heathrow to improve public transport at

the airport. These were set out in the Our Emerging

Plans and Our approach to developing a surface

access strategy documents. For the forthcoming

Airport Expansion Consultation (June 2019) Heathrow

is setting out its preferred options for public transport

provision at the expanded airport based on feedback

from the Airport Expansion Consultation One (January

2018) and ongoing design and assessment work.

The draft Surface Access Strategy will be an Airport

Expansion Consultation (June 2019) document which

will explain Heathrow’s preferred options for the

provision of new and enhanced public transport to

serve the expanded airport.

The Surface Access Strategy is almost wholly dependent on pre-

existing rail schemes such as the Elizabeth and Piccadilly Line

upgrades which were planned based on a two-runway Heathrow.

✓

The priorities and initiatives in the Surface Access Strategy are

supported but it is not clear whether they were all achievable.

✓

The initiatives identified are vital to drive the development of the

Surface Access Strategy and achieve the identified priorities.

✓

The plans are inadequate, relying too much on travellers using

clean transport options.

✓

Surface access is crucial in the choice of a passenger’s departure

airport. There should be an increased focus on improved surface

access benefitting passengers and staff, as well as the local

population.

✓

Affordable and convenient transport choices for staff and

passengers are critical to achieving sustainable surface access.

✓




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An effective and efficient public transport system needs to be

augmented for both workers and travellers to and from the airport.

✓

The planned increases in public transport capacity are only

sufficient to cater for growth in two runway demand.




Consultation One (January 2018) and the Airport

Expansion Consultation (June 2019) provide an









Heathrow area.

The release of runway capacity should be linked to surface access

tests based on predicted outcomes, the number of Heathrow related

vehicles should be no more than today, and the tests must be based

on targeted reduction in such traffic compared to a ‘Do-minimum’

over future years.

✓ Heathrow must demonstrate that the targets set in

ANPS to increase the passenger mode share and

reduce the number of colleague car trips can be met

at each of the milestone dates referred to (2030 and

2040).

Reflecting the requirements set out in the ANPS and

Heathrow’s commitments towards delivering a

sustainable expansion, the surface access strategy

will contain specific and measurable targets that can

be monitored over time. Heathrow is currently in the

process of fully defining its targets and monitoring

process. In order to provide independence, there will

be a mechanism whereby the Heathrow Area

Robust and enforceable processes are needed to correct or mitigate

any divergence from the expected reduction in airport related traffic.

✓

Ongoing investment in road and rail transport infrastructure is

essential for an expanded Heathrow and there should be a

commitment to enhanced connectivity and congestion reduction

aligned with the new runway development.

✓




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A detailed Surface Access Strategy is requested, including detailed

modelling, evidence to support Heathrow’s ambitions and an

assessment of the cost and risk to the entire scheme if the targets

are not met.

✓ Transport Forum can oversee implementation of the

strategy and monitor progress. Heathrow will also

monitor the proposed timeframes for delivery of the

targets to ensure that the right measures are in place

sufficiently early as passenger numbers grow. More

details will be set out in the Airport Expansion


The delivery of Heathrow’s strategy will require it to

work with other agencies such as Transport for

London, Highways England, Network Rail and Local

Authorities. Heathrow has a strong history in working

with partners to deliver surface access improvements

that benefit both Heathrow and the surrounding area.

This offers a unique opportunity to plan the UK’s

infrastructure needs in an integrated way and will help

ensure the surface access plans for Heathrow are

embedded in key strategic long-term planning

processes and investment opportunities. For example:

• Highways England is currently delivering a programme of activity that was set out in its first Road Investment Strategy. There are a number of projects in the Heathrow area including M25 J10 improvements, M25 J10-16 and the M4 Smart Motorway between J3 and J12. Plans are currently being developed for the RIS2 (2021-2026) which will include outputs from the M25 Southwest quadrant study and other strategic studies.

• Network Rail is also preparing its plan for the next investment period (2019-24) known as Control Period 6 (CP6).

A simple expansion of facilities will not achieve the required

increase in public transport mode share, zero growth of airport-

related vehicle traffic, local air quality limits and a reduction in the

risk of unrestricted vehicle access.

✓

The Surface Access Strategy should contain specific targets to

maximise journeys to the airport by public transport, cycling or

walking.

✓

Approval should only be granted for expansion if the target for no

more airport related traffic can be met, or if increases in capacity

are linked to the achievement of the targets and made a condition of

approval.

✓

The growth of the airport should be conditional upon substantial

investment and the provision of major rail investment.

✓




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• The Mayor and Transport for London have set out their priorities for transport in London over the period to 2041.

There is an opportunity to develop a co-ordinated plan

for Heathrow surface access that brings together the

emerging plans for Heathrow with the programmes

developed by Highways England, Network Rail,

Transport for London, Local Authorities and others.

The range of schemes and initiatives presented at the


include some which are in the process of being

delivered already, and others where delivery will be

secured through the DCO for expansion. A more

detailed programme for delivery of surface access

improvements will be developed taking account of

comments from the public consultation exercises in

the Airport Expansion Consultation in June 2019.

There is a risk demand and required capacity has been significantly

underestimated




Consultation One (January 2018) and the Airport

Expansion Consultation (June 2019) provide an












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Heathrow area.

Heathrow should start developing the Surface Access Strategy now

and not in the future.


2018), Heathrow began the process of preparing a

Surface Access Strategy and presented initial

proposals and strategies in order to get early feedback

from consultees. These were set out in the Our

approach to developing a surface access strategy

consultation document. A draft Surface Access

Strategy will be presented at the Airport Expansion


A Surface Access Strategy is not required if there is no third

runway.

✓ The ANPS recognises that there is an urgent need for

new airport capacity in the South East (paras. 2.10-

18), that the Heathrow Northwest Runway scheme is

best placed to deliver this capacity and that overall it

would deliver the greatest net benefits to the UK

(para. 3.74).

Heathrow should ensure there is no increase in road traffic even as

a two-runway operation.

✓ Committed schemes that will come forward regardless

of the expansion plans include the Elizabeth Line,

which will begin operating to the airport in 2019, and

the Piccadilly Line upgrade that is planned for 2023.

The Western Rail Link to Heathrow is being promoted

by Network Rail to provide a direct rail connection

from the Great Western Mainline to the west of the

airport.

Together these committed projects will contribute

towards continuing the trend that has seen passenger

numbers at the airport double since 1991, but airport-




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related road traffic remain largely static.

The priorities of the Surface Access Strategy and the key initiatives

which seek to shift passengers and workers from private car to

public transport are supported.




ANPS. Heathrow has also pledged that there will be

no more landside airport-related traffic as a result of

expansion.





reduce travel demand more generally through smarter

airport design; for example, by consolidating some

activities around the airport such as parking and

freight operations.

The Airport Expansion Consultation in June 2019 will

seek views on the draft Surface Access Strategy. This

will be supported by technical information in the PTIR.

Together these will explain Heathrow’s preferred

options for the transport infrastructure needed to

support the expansion plans in the context of

increasing the use of public transport by passengers

and colleagues.

The Surface Access Strategy is a key part of the plans and the

proposals seem well thought through.

✓

The strategy would reduce the number of cars travelling to/from the

airport, improving local cycle paths and accessibility whilst also

addressing long term requirements.

✓

The provision of a public transport led scheme for an expanded

airport is supported.

✓

The proposals for surface access look sensible and are important

for fast and affordable access to London. The Surface Access

Strategy proposals will help deliver a reduction in emissions and

limit fuel use if applied correctly.

✓

The development of public transport initiatives for both passengers

and staff is supported.

✓

The aims of the Surface Access Strategy are supported, as long as

it considers their Surface Access Priorities.

✓

The proposals to increase surface access to the airport by

alternatives to car transport are welcomed.

✓




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The priority should be improving the public transport infrastructure. ✓

Concern expressed that there is no integrated strategy for those

travelling to and from the airport or any coherent view on how

Heathrow sits within the wider, national and regional transport

network.

✓ The Airport Expansion Consultation One (January





access strategy documents. For the Airport Expansion

Consultation in June 2019, Heathrow is setting out its

preferred options for public transport provision at the

expanded airport in a draft Surface Access Strategy.

This will take account of feedback from the Airport

Expansion Consultation One (January 2018), this

consultation, and ongoing design and assessment

work.

This iterative approach to consultation on NSIPs is

advocated in government guidance on the pre-

application process (DCLG March 2015). Paragraph

70 of the guidance states that, “…applicants might

wish to consider undertaking non-statutory early

consultation at a stage where options are still being

considered. This will be helpful in informing proposals

and assisting the applicant in establishing a preferred

option on which to undertake statutory consultation.”


as part of the Airport Expansion Consultation (June

2019) and will explain Heathrow’s preferred options

for the provision of new and enhanced public transport

The Surface Access Strategy was poor. ✓

Concerns expressed that the Surface Access Strategy is

insufficiently developed and un-costed, with aspirational and

challenging objectives.

✓

The Surface Access Strategy is insufficient, inadequate and would

not be achievable due to inconsistencies between the ambition of

becoming traffic neutral and the proposals to expand.

✓

The consultation documentation does not provide any confidence

that expansion can be achieved with no increase in airport related

traffic or progress to improve air quality in the surrounding area can

be assured.

✓




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to serve the expanded airport

On the basis of the analysis carried out to date,





and pledges referred to in the ANPS. Further

assessment and analysis is ongoing by Heathrow to

determine exactly which combinations of measures

are required, by which date, to deliver the best surface

access for the expanded airport. Heathrow is working

with Highways England, Network Rail and TfL to co-

ordinate the expansion plans with their investment

plans in the Heathrow area.

Proposals to limit vehicles accessing the airport should be rejected. ✓ The ANPS sets out targets for Heathrow to increase

the proportion of passengers travelling to the airport

by public transport and reduce the number of car trips

made by colleagues. Heathrow must prepare a DCO

application, including a Surface Access Strategy, that

demonstrates that these targets can be met in order

for the expansion plans to be consented. More

generally, Heathrow is committed to developing the

airport in a sustainable way as explained in the

Heathrow 2.0 document, Our plan for sustainable

growth published in 2017.

The modal shift targets should be reset to show that the airport is

taking its ‘fair share’ of congestion and will not increase road traffic

but any schemes aimed at reaching the targets must provide value

for money, being in the interests of passengers.



with the ANPS. In so doing, the Strategy will set out

“improvements to Heathrow Airport’s transport links to




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be able to support the increased numbers of people

and freight traffic which will need to access the

expanded airport.” (Paragraph 5.8).

The ANPS at paragraph 5.7 identifies major rail

improvements that would support a new north west

runway. In considering the surface access


Heathrow must have regard to paragraph 4.39 of the

ANPS. This requires Heathrow to demonstrate that its

scheme is cost-efficient and sustainable, and seeks to

minimise costs to airlines, passengers and freight

owners over its lifetime. Heathrow remains committed

to keeping airport charges close to 2016 levels.

The mode shift targets ambitious and recommended that Heathrow

investigate the possibility of an extensive network of park and ride

systems to free up road capacity.

✓ With expansion, a lot of the car parking along the

north side of Heathrow will be demolished. This is

likely to be replaced elsewhere at the airport. To

ensure Heathrow efficiently use all land available

today and minimise the need to acquire land, it is

likely that car parking will re-provided by creating

multi-storey car parks.

Managing car parking is part of how Heathrow will

meet the surface access targets in the ANPS and how

Heathrow will manage air quality around the airport. In

addition to the re-provision of demolished car parking,

Heathrow’s thinking at the Airport Expansion

Consultation One (January 2018) was to vacate some

of the existing surface level passenger and colleague

car parks and use a smaller number of multi-level car

parking sites which are located near main access

routes and have dedicated access to the front door of

The key to Heathrow’s transport strategy is the delivery of new

strategic rail services, including the Western and Southern Rail

Links complemented with a network of high quality and reliable park

and ride facilities for passengers arriving by car. This will help

ensure that local roads around the airport are not overloaded with

passenger traffic and will allow essential goods, services and cargo

to move efficiently and sustainably to and from the airport.

✓




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terminals. This will reduce traffic circulating around the

airport and improve way-finding. The consolidation of

passenger and colleague car parking also provides

the flexibility to change colleague and passenger car

parking allocations over time, in line with phasing and

meeting time-dependent ANPS targets, as well

dealing with future vehicle types and technologies.

Surface access should be continually improved without delay. ✓ Heathrow is committed to meeting the targets for





greater than today















Terminals.




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A draft Surface Access Strategy, supported by

technical information in a PTIR, will explain






This will be consulted on at the Airport Expansion


A strategy is not required at all. ✓ The ANPS sets out targets for Heathrow to increase

the proportion of passengers travelling to the airport

by public transport and reduce the number of car trips

made by colleagues. The ANPS requires Heathrow to

submit a Surface Access Strategy with the DCO

application that demonstrates that these targets can

be met in order for the expansion plans to be

consented. More generally, Heathrow is committed to

developing the airport in a sustainable way as

explained in the Heathrow 2.0 document, Our plan for

sustainable growth published in 2017.

There is no indication as to how the commitment to not increase

airport related traffic would be managed, monitored or enforced.

✓ Heathrow must demonstrate that the targets set in

ANPS to increase the passenger mode share and

reduce the number of colleague car trips can be met

at each of the milestone dates referred to (2030 and

2040).

Reflecting the requirements set out in the ANPS and

Heathrow’s commitments towards delivering a

sustainable expansion, the Surface Access Strategy

submitted with the DCO application will contain

The Surface Access Strategy should be flexible to accommodate

changing circumstances without losing sight of strategic principles.

✓

A consistent measurement should be used for colleague car trip

and passenger transport targets to ensure clarity relating to

changes and targets for surface access transport.

✓




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The ambition to expand airport capacity without any increase in

airport related traffic is welcomed but Heathrow must demonstrate

that this can and will be achieved with robust monitoring and

nitrogen-sensitive designated sites will be avoided.

✓ specific and measurable targets that can be monitored

over time.

Heathrow is currently in the process of fully defining its

targets and monitoring process. In order to provide

independence, there will be a mechanism whereby the

Heathrow Area Transport Forum can oversee

implementation of the strategy and monitor progress.

Heathrow will also monitor the proposed timeframes

for delivery of the targets to ensure that the right

measures are in place sufficiently early as passenger

numbers grow.

The draft Surface Access Strategy and other

consultation documents that will be consulted on at

the Airport Expansion Consultation in June 2019, such

as the PEIR, will contain more detail about how the

ANPS targets and Heathrow’s commitments will be

monitored, enforced and managed over time, so they

remain effective.

The ‘no more traffic’ commitment is welcomed. ✓ Heathrow will continue to strive to meet its pledge to


today. Heathrow is currently defining what vehicles

are considered to be ‘airport-related traffic’ and details

of this will be presented in the draft Surface Access

Strategy at the Airport Expansion Consultation in June

2019.

The targets for public transport use and no increase in airport

related traffic are supported but there is a need for greater clarity on

what airport related traffic is, as the current proposed definition

appears to be too narrow.

✓

Trips by private car to/from car parks beyond the perimeter of the

airport should be included in the definition of ‘airport related traffic’.

✓




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There is a need for robust multi modal traffic modelling, including

future proofing requirements, before any final decisions are made

on terminal locations, car parking or road and junction locations

and capacities.

✓ The draft Surface Access Strategy and the PTIR will

be published as part of the Airport Expansion

Consultation (June 2019) and together they will

explain what measures will need to be taken to deal

with the anticipated transport impacts of the

development. They will summarise and illustrate the

outputs from the transport modelling and identify

locations where the project will potentially have

material impacts on the operation of the transport

networks that require further detailed assessment.

They will also set out, at a high-level, the strategy for

mitigating any impacts on the surrounding transport

networks that are considered severe.

Further technical assessment work, including traffic

modelling, and consideration of the feedback from this

and future consultations will inform the preparation of

the masterplan and Transport Assessment.

Concern expressed over the target to reduce staff car journeys to

Heathrow by 25% by 2030. Meeting such targets will be key to no

adverse impacts on traffic congestion and air quality from

additional vehicle journeys.

✓ Many Heathrow colleagues live in boroughs close to




public transport. Where there are good alternatives,



wants fewer colleagues to drive to work by making

more sustainable modes more attractive and will be

putting in place measure to ensure the ANPS target to

reduce colleague car trips is met. In particular,

reducing the number of staff car parking spaces in a

managed way that ensures the operational needs of




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the airport continue to be met.






people to use.

Heathrow’s plans to reduce colleague car trips will be

set out in the draft Surface Access Strategy, produced

for the Airport Expansion Consultation in June 2019.

The National Infrastructure Commission and the Department for

Transport should develop a framework for delivering the Surface

Access Strategy which considers the complex interfaces between

infrastructure schemes, runway construction, surface access

works, phasing of growth and funding.

✓ The ANPS, informed by the Final Report of the

Airports Commission, sets out the national policy for

the expansion of Heathrow, including policy on the

development of a Surface Access Strategy and the

involvement of other infrastructure providers such as

Network Rail, Highways England, TfL and local

highways authorities.

Priorities of the Surface Access Strategy should be focussed on

those areas where public transport is not currently used to travel

to/from the airport.

✓ New and enhanced public transport infrastructure and

services are at the heart of the expansion plans. The

introduction of Elizabeth Line services in 2019 will

improve access to the airport from the City, East

London and the Thames Gateway. Heathrow is

supporting Network Rail’s proposed DCO for a

Western Rail Link that will provide direct access by rail

to the Airport for communities to the west on the Great

Western Mainline. Heathrow is also supporting the

plans for a Southern Rail Link from the South Western

Mainline rail network between Hampshire and

Waterloo. DfT is exploring the potential for a Southern




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Rail Link to be brought forward with private sector

involvement. Heathrow is working with TfL and local

authorities to identify new and improved bus priority

measures that could be considered to improve the

reliability and experience of bus users to/from

Heathrow.

The proposals for a Southern Rail Link and the introduction of

direct access to Heathrow by the Elizabeth line in 2018 are

welcomed.

✓ Support for the Southern Rail Link and the introduction

of direct services to Heathrow on the Elizabeth Line is

noted.

Kent and much of South East London still lack a direct, high-

capacity connection to the airport and the Crossrail to Ebbsfleet

scheme is a vital part of reducing car journeys and in helping

Heathrow to tackle air quality impacts.

✓ The Elizabeth Line will begin operating high capacity

frequent trains to Heathrow in 2019, providing direct

services to Stratford and connecting services using

the HS1 line, including commuter services to Kent.

The Department for Transport and Network Rail are

responsible for making investment decisions on the

national rail network. The ANPS at paragraph 5.7

identifies major rail improvements that would support

a new north west runway. In considering the surface

access infrastructure needed to support the expansion

plans, Heathrow must have regard to paragraph 4.39

of the ANPS. This requires Heathrow to demonstrate

that its scheme is cost-efficient and sustainable, and

seeks to minimise costs to airlines, passengers and

freight owners over its lifetime.

Strategic access could be provided to the airport by linking it to a

single interchange at Old Oak Common and the High Wycombe to

✓ Although Heathrow will not be directly served by HS2,

there will be an opportunity for passengers to




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Old Oak Common link is recognised as one of the key building

blocks to enable passengers and staff to sustainably access an

expanded airport.

interchange at the new station at Old Oak Common

via the Elizabeth Line, which will give significantly

reduced rail journey times between Heathrow,

Midlands and the major towns and cities of the North

of England and Scotland. Heathrow is working with

HS2 Ltd, Old Oak and Park Royal Development

Corporation, TfL and Network Rail to ensure the

design of the station at Old Oak Common meets the

needs of airport passengers.

The new rail schemes are not realistically costed and Heathrow is

neither willing nor able to fund them.

✓ The ANPS at paragraph 5.7 identifies major rail








owners over its lifetime. Heathrow is supporting

Network Rail’s DCO application for a Western Rail

Link to Heathrow and is also supporting emerging

plans for a Southern Rail Link, currently being

explored by the DfT to be brought forward with private

sector involvement. Elizabeth Line services will begin

operations to Heathrow in 2019. Heathrow remains

committed to keeping airport charges close to 2016

levels.

Support given for a rapid rail T5 – Staines park and ride. ✓ Park and Ride facilities have been considered in

developing the Surface Access Strategy, alongside

other ways of providing an appropriate amount of car




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parking linked to the airport.

However, Park and Ride is not currently the preferred

option within the emerging parking strategy. Heathrow

considers that the current preferred approach of using

parkways, with options to use people movers to link

directly to airport terminals, provides a better

passenger experience at a lower overall cost and

would not undermine efforts to encourage passengers

and colleagues to use existing and planned public

transport services.

The Piccadilly Line improvements will reduce car use and the

proposals to use a freight line from Hendon and Cricklewood for

passenger trains would be an improvement.



surface access strategy explained that TfL plans to

upgrade the Piccadilly line, with work commencing in

2023. The existing trains will be replaced with new

trains with more capacity and a modern fit-out. The

signaling system will be upgraded to allow a higher

frequency of trains and faster journey times. The

upgraded Piccadilly line will provide 50% more

capacity with up to 18 trains per hour in each direction

serving Heathrow.

A link from the east would relieve much of this overcrowding. ✓ The Elizabeth Line will begin operations to Heathrow

in 2019 and will provide a fast and frequent service

between Heathrow and destinations to the east such

as Shenfield, Canary Wharf and Liverpool Street

Station.

Support expressed for increased frequency and operating hours on

the Elizabeth line, contribution to the costs for a new Western Rail






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Link and a new direct rail link to Heathrow from the south but

concerns expressed that there is no clarity on the cost and who will

pay for new heavy rail infrastructure. Without this the achievement

of no increase in airport related traffic or the modal shifts will not be

possible.









Link to Heathrow and is also supporting the emerging

plans for a Southern Rail Link. DfT is exploring the

potential for a Southern Rail Link to be brought


services will begin operations to Heathrow in 2019.

Heathrow is clear that Government is responsible for

funding rail and road networks, regardless of

expansion.

It is important that any contribution provided by the

taxpayer is proportionate to the benefits that non-

airport users receive as a result of the new

infrastructure. Heathrow will pay for the proportion of

costs driven by expansion. For example, new rail

connections for the Great Western Mainline benefit

many travellers, and will reduce travel times,

congestion and pollution. This is a good business

case for public investment, regardless of expansion

for the airport. Nevertheless, an expanded Heathrow

is, as the Airports Commission’s analysis concluded,

“commercially viable and financeable” and with £187

billion in additional growth for the British economy, it

represents good value for money.

The Surface Access Strategy was unrealistic and highlighted

uncertainty around the funding contributions and delivery of the

Piccadilly Line upgrades and the Western and Southern Rail Links.

✓

Without a financial contribution to the costs of increasing the

frequency of trains on the Elizabeth Line or to the development of

the Southern Rail Link, it is difficult to see how the Surface Access

Strategy would be fulfilled.

✓




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Even with upgrades, airport expansion will result in overcrowding

on the Piccadilly Line.



surface access strategy explained that TfL plans to

upgrade the Piccadilly line, with work commencing in

2023. The existing trains will be replaced with new

trains with more capacity and a modern fit-out. The

signalling system will be upgraded to allow a higher

frequency of trains and faster journey times. The

upgraded Piccadilly line will provide 50% more

capacity with up to 18 trains per hour in each direction

serving Heathrow. The current and forecast patronage

of the Piccadilly Line will be assessed as part of the

emerging Surface Access Strategy, a draft of which

will be consulted on at the Airport Expansion


Heathrow will work with TfL, Network Rail and other

transport operators to ensure that the fare structures

for travelling to Heathrow on the various services are

consistent with the need to meet the surface access

targets in the ANPS.

That a premium fare on the Elizabeth Line will push more

passengers onto the Piccadilly Line.

✓

The Piccadilly Line is already overcrowded and an expanded airport

will put greater pressure on the public transport system

✓

Although the draft NPS says an interchange at Old Oak Common

will enable airport passengers to make a connecting journey to

access HS2, air passengers would be heavily dissuaded from using

rail if an interchange is required.

✓ HS2 is the subject of a separate consultation and

consenting process as a hybrid bill. The Airports

Commission assessed the case for a direct HS2 spur

to Heathrow and concluded that, “the scheme was

likely to attract only a small number of passengers,

carry a high capital cost and represent an inefficient

use of HS2 capacity.” (Airports Commission Final

Report page 159). A direct connection to HS2 at

Heathrow was therefore not recommended to form

part of the surface access package that would support




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airport expansion. The HS2 Heathrow spur was

consequently not included in the ANPS. Although

Heathrow is not directly served by HS2, there will be

an opportunity for passengers to interchange at the

new station at Old Oak Common via the Elizabeth

Line, which will give significantly reduced rail journey

times between Heathrow, Birmingham and the major

cities of the North of England and Scotland. Heathrow

is working with HS2 Ltd, Old Oak and Park Royal

Development Corporation, TfL and Network Rail to

ensure the design of the station at Old Oak Common

meets the needs of airport passengers.

Current rail and road access to the airport is outdated and must be

enhanced to enable airlines to cater for passenger demand when

the third runway is operational.

✓ The ANPS states at paragraph 3.36 that “Heathrow



M40 and M3, and rail links via the London











freight operators in much of the UK and provides

significant resilience to any disruption.”

The benefits identified by the Airports Commission and the draft

ANPS for the national economy are at risk if expansion is not






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accompanied by a clear strategic plan accompanied by new rail

connections and services.

with the Airports National Policy Statement. The

Strategy will set out “improvements to Heathrow

Airport’s transport links to be able to support the

increased numbers of people and freight traffic which

will need to access the expanded airport.” (Paragraph

5.8). At the Airport Expansion Consultation One

(January 2018), Heathrow consulted on the early

options and strategies that will form the basis of the

Surface Access Strategy in the, Our approach to

developing a surface access strategy document. A

draft Surface Access Strategy will set out Heathrow’s

preferred options for surface access and will be

consulted on during the Airport Expansion


Heathrow is already well served by the rail network and

improvements were unnecessary.

✓ Heathrow is committed to ensuring that the needs of

an expanded airport can be met. A Surface Access

Strategy will be submitted with the DCO application,

which will demonstrate how the targets to increase the

proportion of passengers travelling by public transport

and reduce colleague car trips will be met. The

Strategy will include measures for new and enhanced

rail services to Heathrow.

The proposed Surface Access Strategy would not improve the rail

network.












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Link to Heathrow and is also supporting the emerging

plans for a Southern Rail Link. The DfT is exploring

the potential for a Southern Rail Link to be brought


services will begin operations to Heathrow in 2019.

These schemes individually and collectively have the

potential to significantly improve rail services to the

airport in terms of the quality and frequency of

services, and accessibility for areas not currently

served by direct rail links to Heathrow.

The Western and Southern Rail Links were not identified as

essential schemes.











Link to Heathrow and is also supporting emerging

plans for a Southern Rail Link, which is being explored

by the DfT with private sector involvement.

The case for these schemes has been more than clearly made for a

two-runway airport

✓

Western and Southern Rail Links were identified by the Airports

Commission as being justified on the basis of a two-runway airport.

✓

Both the Western and Southern Rail Links are essential for airport

expansion.

✓

The Western Rail Access and Southern Rail Link is of significant

national interest, serving a range of economic needs supporting

expansion.

✓

Surface rail must provide an increase in journeys of 200-300%, and

schemes such as the Western and Southern Rail Links are critical to

✓




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achieving this.

The Western and Southern Rail Links are needed now, prior to

expansion.

✓

The Western Rail Link and the Southern Rail Link must be

considered if Heathrow's expansion is to be successful.

✓

Recent commitments by the Government for the Western and

Southern Rail Links were a positive indication that a suitable

Surface Access Strategy can be developed.

✓

The Western Rail Link and the Southern Rail Link must be

considered if Heathrow's expansion is to be successful.

✓

The commitment to the Western and Southern Rail Links is

welcomed, however, it should be Heathrow should lead these

projects.

✓

Heathrow’s financial support for the new Western Rail Link is

welcomed but this should be provided as matter of urgency in

support of current airport operations.

✓ Network Rail is promoting a new rail connection

between Heathrow Terminal 5 and the Great Western

Main Line close to Langley station. A new 7km section

of railway would be constructed in a tunnel and would

allow direct rail services from Heathrow to places such

as Reading (in 26 minutes) and Slough (in 7 minutes).

This new Western Rail Link would provide direct rail

links to key passenger and colleague catchments in

the Thames Valley, taking traffic off the M4.

The proposed rail link is currently being developed by

Network Rail and a statutory public consultation was

The priority for infrastructure investment is the Western Rail Link

scheme and that it is required for a two-runway airport.

✓

There should be firmer commitments from Heathrow on plans to

contribute to the cost of the Western Rail Link.

✓

The Western Rail Link is required now to support the two-runway ✓




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capacity. held in 2018, in advance of a DCO application being

submitted. This would be separate from Heathrow’s

DCO application for the expansion of the airport. If

granted consent, the new rail link could become

operational by 2025. The funding and development of

the rail link is currently linked to the DCO application

stage for that project– with additional funding required

for construction as part of Network Rail’s Control

Period 6 (2019-2024) to deliver the project. Heathrow

is working with Network Rail in support of the Project.

There is a clear business case for the Western Rail Link based on a

two or three runway airport.

✓

Heathrow needs to work with its Western Rail Link project team to

provide assurance on compatibility of design.

✓

Heathrow should support both the Elizabeth Line and other services

between London Paddington and the airport to optimise the

available capacity and make system wide decisions.

✓

Heathrow should incentivise use of the Elizabeth Line with a special

ticketing as part of the Surface Access Strategy.

✓

Any extended hours on the Elizabeth Line need to be implemented

in conjunction with extended hours on public transport within

London, to ensure that people can complete their journeys.

✓

Heathrow actively participates in and leads the delivery of the

Western Rail Link before construction commences on the third

runway.

✓

The Western Rail Link could provide national connectivity but will

only connect the airport with the Great Western Main Line if

passengers are prepared to change during their journey.

✓

Support expressed for the Western Rail Link and recommendations

that Heathrow should agree the contribution to provide certainty

over its delivery.

✓




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Early planning and investment in the Western Rail Link and other

rail projects will be required well before the runway is completed to

avoid an increase in road traffic.

✓

The Western Rail Link and Elizabeth Line will improve access and

provide quicker journeys for residents close to stations such as Iver

and Taplow.

✓

The Western Rail Link is the number one infrastructure project and

welcomed Heathrow’s commitment to contribute to the scheme.

✓

Concern expressed that there are no alternatives proposed for the

Western Rail Link if it does not go ahead.

✓

Heathrow should help deliver the West London Orbital Rail Link and

provide assurance of service frequency and reliability

improvements for the Piccadilly Line to Uxbridge.

✓ The Mayor’s Transport Strategy includes an early

proposal for a West London Orbital rail line connecting

Hounslow with Cricklewood and Hendon. TfL is

responsible for taking forward these proposals.

Heathrow is committed to working with TfL to support

proposals that will contribute to the assessed transport

needs and demands arising from the expanded

airport.

Rail transport should be given equal priority with road to resolve

gaps in public transport.


2018) document Our approach to developing a

surface access strategy set out Heathrow’s surface

access priorities in Chapter 4 of the document. It

explained that the proposed priorities were:

• Making public transport the preferred choice for more passengers;

• Offering sustainable and affordable




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alternatives for colleagues, and

• Facilitating more efficient and responsible use of the road network.

Key initiatives set out in Chapter 5 are to put

Heathrow at the heart of the rail network, create a

public transport focused airport, and make public

transport easier to use. These initiatives will see rail

play a vital role in ensuring that Heathrow meets the

surface access targets set out in the ANPS.

Rail trips to Heathrow from SW London involve a detour which is

time consuming result in most trips are being made by car or taxi.

✓ There are currently a number of different proposals



These proposals form part of a wider network

improvement being considered by Network Rail. There

is currently no railway connection between Heathrow

and the south so this link would fill a key gap in the rail

network. A feasibility study undertaken by Network

Rail showed that there is a strong business case for

the proposals and that there are credible infrastructure

solutions that should be explored further. Heathrow’s

analysis to date indicates that the proposed Surface

Access Strategy is not reliant on a Southern Rail Link

to deliver the mode share targets in the ANPS.

However, Heathrow is supportive of proposals for a

Southern Rail Link, which are now being explored in

greater detail by the DfT with private sector

involvement.

Heathrow will set out its draft Surface Access Strategy

at the Airport Expansion Consultation in June 2019,

which includes a range of schemes and considers that

The preferred option for this would be a light rail system from

Chertsey in a tunnel.

✓

Concerns expressed about any proposal to build a new railway line

immediately alongside the M25 from Staines to Chertsey, due to

adverse effects on local people and the disruption to the M25 and

other roads during construction.

✓

Concerns expressed that without such a link residents and

businesses would continue to suffer from long and difficult public

transport journeys to and from the airport, made worse by

expansion.

✓

Concern expressed that the targets around the shift to public

transport are not considered to be reliant on the Southern Rail.

✓

They said no commitment has been made by Heathrow to public

transport that will meet the needs of an expanded airport,

✓




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particularly to the south. they should be delivered whether or not the airport

expands. Heathrow has also ensured that the

emerging Surface Access Strategy has resilience so

that it is not reliant on the delivery of any one scheme.

It is important that any contribution provided by

Heathrow is proportionate to the benefits that airport

users receive as a result of the new infrastructure. For

example, new rail connections for the Great Western

Main line benefit many travellers, and will reduce

travel times, congestion and pollution. This is a good

business case for public investment, regardless of the

expansion of the airport.

Nevertheless, an expanded Heathrow is, as the

Airports Commission’s analysis concluded,

“commercially viable and financeable” and with £187

billion in additional growth for the British economy,

represents value for money in the UK.

The Southern Rail Link is essential to the future success of the

airport and it should form an integral part of the airport’s expansion.

✓

The preferred option would be a railway tunnel starting on the edge

of Staines, emerging between Egham and Virginia Water and with a

station within Runnymede Borough to provide a service from

Egham to the airport.

✓

The principle of having direct rail access to the airport from the

south is supported.

✓

The ‘no more traffic on the road’ pledge cannot be delivered without

improving rail access from the south.

✓

The Government’s Call for ‘Market Led Proposals’ identifies the

Heathrow Southern Rail Link as a priority and their proposals would

provide this.

✓

Opposition expressed to the Southern Rail Link which would

require heavy weight trains to cross over the M3, A30, River Thames

and other local roads.

✓

All level crossings should be replaced by tunnels or bridges or an

alternative route found to Waterloo.

✓

The principle of a new direct rail link to the airport from the south is

supported but concerns expressed about any closing of crossings

because of the effects on road traffic congestion.

✓




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A new rail link from Waterloo to the airport via Clapham Junction,

Putney and Staines should be a priority.

✓

Support expressed for the rail link to southern lines ✓

There is a need for better transport links from the west, south west

and south including the proposed southern rail link

✓

Expansion would not be supported unless a direct link is provided

to the south west railway network.

✓

Further work is needed with funders and stakeholders to develop

the business case for future funding of the Southern Rail Link and

Heathrow should support a collaborative approach to funding and

financing.

✓

A direct rail link between London Waterloo and Heathrow with a

stop at Vauxhall has the opportunity to reduce the number of car

journeys to the airport.

✓

A more direct southern access link from Woking to the Airport

would provide the greatest accessibility improvement for residents

and employees within this area of Surrey and Hampshire and would

provide a realistic alternative to the use of the private car.

✓

There is no commitment from Heathrow to fund the new southern

rail access or proposals do not include a direct link with Woking.

✓

A scheme that enables connectivity between Surrey and Heathrow

should be a key element of the Surface Access Strategy and should

✓




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be delivered before a new runway is operational.

Concern Expressed about the lack of commitment to ensuring

delivery of the Western Rail Link in a timely manner. The

construction of the Western Rail Link should be completed in

advance of construction for airport expansion, to mitigate

disruption and enable significant modal shift to take place.

✓

Concerns expressed about ‘barrier downtime’ at level crossings

associated with the Southern Rail Link in the Borough and the likely

knock on effects on congestion and air quality.

✓

The Southern Rail Link is needed now to address poor public

transport links to the south of the airport, encourage modal shift

and reduce air pollution from congestion and emissions.

✓

Southern Rail Link is essential to help relieve the Crossrail and the

Piccadilly line. There are also issues about the number of

competing options being promoted. There is a need for an objective

analysis of all the options.

✓

Concern expressed that no new rail connectivity has been proposed

and it is implausible that no more traffic on the road can be

delivered without improved rail access from the south.

✓

The Southern Rail Link is needed to deliver the ‘no more traffic on

the road’ pledge, without it there will be more traffic congestion.

✓

Support expressed for the Southern Rail Link. ✓




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Support expressed for the Southern Rail Link. An extended scheme

recommended to be investigated involving tunnelling through to

Wimbledon, rather than just to Kingston.

✓

Concerns expressed at the provision of ‘a resilient and reliable road

network’ noting that many of the schemes are designed to deal with

existing growth in demand and not the extra journeys generated by

an expanded airport.

✓ Heathrow is in regular dialogue with Highways

England to ensure the final M25 design is the best

possible solution for the Strategic Road Network,

Highways England and Heathrow. The M25 is an

important artery into the airport, so for resilience

purposes, Heathrow will be required to ensure it

remains open and operational during construction and

operation. Also, all final road designs will be in

accordance with design standards and regulatory

requirements. Ongoing collaboration with Highways

England is important to ensure this is achieved.

A robust traffic model is being developed, which will

determine the locations of the most severe traffic flow

levels and thus the type of road required to ensure

access is easily achievable for all.

There should be an integrated approach between Heathrow, DfT and

Highways England which will be required to ensure a good level of

service for road users.

✓ The delivery of Heathrow’s strategy will require it to

work with other agencies such as Transport for

London, Highways England, Network Rail and Local

Authorities. Heathrow has a strong history in working

with partners to deliver surface access improvements

that benefit both Heathrow and the surrounding area.

There is an opportunity to develop a coordinated plan

for Heathrow surface access that brings together the

The DfT-sponsored M25 South West Quadrant study has brought

forward several options for further consideration, these need to be

integrated far more closely into the expansion proposals.

✓




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emerging plans for Heathrow with the programmes

developed by Highways England. For example,

Highways England is currently delivering a

programme of activity that was set out in its first Road

Investment Strategy. There are a number of projects

in the Heathrow area including M25 J10

improvements, M25 J10-16 and the M4 Smart

Motorway between J3 and J12. Plans are currently

being developed for the RIS2 (2021-2026) which will

include outputs from the M25 Southwest Quadrant

Study and other strategic studies.

The range of schemes and initiatives presented at the


include some which are in the process of being

delivered already, and others where delivery will be

secured through the DCO for expansion. A more

detailed programme for delivery of surface access

improvements will be developed taking account of

comments from the public consultation exercises and

further engagement with Highways England.

It is not clear whether a realigned A4 with two lanes will have

sufficient capacity for good public transport.

✓ A robust traffic model is being created, so that any

new road designs for the A4 will bring positive

outcomes for the surrounding communities. The


was an opportunity for Heathrow to exhibit all options

that will provide suitable links, once the Western

Perimeter Road is removed and the existing

alignments of the A4 and A3044 are diverted.

Heathrow will continue to engage with local

stakeholders, including TfL and other transport




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providers to ensure a suitable solution is arrived at for

the masterplan.


technical information in the PTIR will summarise and

illustrate the outputs from the transport modelling and

will be consulted on during the Airport Expansion

Consultation in June 2019. These will explain


infrastructure needed to support the expansion plans


by passengers and colleagues as required by the

ANPS.

There is a need for a fully integrated strategic transport network to

ensure that non-airport ‘through’ traffic has access to viable

alternative routes as the expansion proposals would impact on the

M25 and surrounding roads.

✓ Heathrow is building a sophisticated suite of transport

models which will be utilised to predict the flow of

traffic on the M25 mainline and around the various

junction links. Heathrow is working closely with

Highways England to ensure that the outline solution

for the M25 presented at the Airport Expansion

Consultation (June 2019) will have their agreement,

which will include meeting their views on capacity

requirements. Heathrow has already agreed to

provide collector distributor roads which will improve

traffic flow on the mainline. Key to mitigating the

potential increases of traffic on the M25 is the delivery

of the Surface Access Strategy, which includes

measures to get significant numbers of passengers

and colleagues out of their cars and onto public

transport. A draft Surface Access Strategy will set out

Heathrow’s preferred options for the provision of

infrastructure to meet the needs of the expanded

Concerns expressed about the pressure that will be placed on the

M25 if the pledges are not honoured.

✓




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airport and will be consulted on at the Airport


Road transport to/from the airport should be discouraged. ✓ The Airport Expansion Consultation in June 2019 will

include a draft Surface Access Strategy and

supporting technical information in a PTIR. These will


infrastructure needed to support the Project in the

context of increasing the use of public transport,

walking and cycling by passengers and colleagues,

and our preferred plans for a new parking strategy and

freight/logistics strategy.

The draft Surface Access Strategy will make clear our

commitment to meeting the targets for increasing

passenger mode share by public transport and

reducing the number of colleague car trips, as

required by the ANPS.

The expansion of the coach and bus hub, is supported. There is an

opportunity to introduce new services or increase frequency either

directly to the airport or to connect with direct train services via

East West Rail, the Elizabeth Line and mainline stations in and near

the Heartlands area.

✓ Heathrow plays an important role as a local transport

hub. As a focus for local bus services it is a key

interchange and provides access to the London

Underground and local rail services. As rail and coach

access improves at Heathrow, this role will only

increase. There is an opportunity to ensure that local

communities benefit from this improved access by

making sure there are local services that connect

communities to on airport stations. Heathrow will also

Bus connections to Terminal 5 via Stanwell and Stanwell Moor

should be restored and further consideration should be given to a

local tramway or light railway connection.

✓




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Provision of enhanced bus services is supported, however, there

are concerns about the ability to deliver new bus priority measures

on roads that under the control of local authorities and TfL.

✓ seek to deliver solutions that work towards achieving

local transport priorities that align with our own

strategy, encouraging more sustainable travel in the

local area by all users.

Heathrow will work with TfL and local authorities to

identify new and improved bus priority measures that

could be considered to improve the reliability and

experience of bus users to/from Heathrow. In the


document, Our approach to developing a surface

access strategy Heathrow explained that it was

considering the following bus priority measures:

• Implementing an internal campus road network that enables easy access to terminals for buses

• Introducing bus-only corridors to Heathrow – exact locations to be determined; and

• Providing off-campus bus priority measures (re-allocate road space for buses (working with TfL/highway authorities) and coaches (working with Highways England) to improve journey times and reliability.

Approximately one third of colleagues (around 10 m

trips per year) and around one million passengers per

year use local buses to travel to and from Heathrow.

The development of bus priority measures into the

airport, on corridors where there are larger

concentrations of colleagues and passengers, could

help achieve a bigger shift towards bus use.

It necessary to increase the provision of public transport options to

serve the southern side of the airport by bus.

✓

The improvement of the coach hub supported. ✓

More attention should be given to inter-urban coach services rather

than local buses.

✓

There should be engagement with Heathrow on how bus services

might be enhanced and improving the local cycle network.

✓

Heathrow must commit to paying capital and revenue costs for the

introduction of regular and quick bus routes to and from the areas

to the west and south.

✓

Bus lanes should be in place for the construction period and could

provide support for bus services to serve shift workers.

✓

Consideration should be given to priority lanes for coaches and

buses to speed up journey times and ensure reliability.

✓

Buses play a vital role for trips in the local area. ✓

The provision of new express and shuttle bus services is welcomed,

these will need to be frequent enough to attract people from their

cars.

✓




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Collaboration would be welcomed with Heathrow to develop

strategic bus routes and ‘demand responsive services’.

✓ The current central bus station will be upgraded into a

new public transport interchange over the life of the

expansion programme. This will have more capacity

for buses and be better integrated with Terminal 2 and

with easier access to London Underground, Rail

stations and walking and cycling routes. In addition to

improving the coach station, Heathrow will work with

the coach industry to encourage new and innovative

routes and operators to improve services for

passengers and increase the travel options on offer.

Areas for growth include the South Coast, with urban

areas like Worthing and Eastbourne, the M40 corridor

including High Wycombe as well as North West

London. Other growing cities in the North would also

benefit from direct coach services.

Heathrow’s preferred options for new and enhanced

bus and coach facilities at the airport will be explained

in the draft Surface Access Strategy, which will be

consulted on as part of the Airport Expansion


Heathrow should investigate bus rapid transit to local areas

(Southall, Greenford and Northolt) aimed at employees living

locally, as well as demand responsive bus services.

✓

Heathrow should provide assurance of service reliability

improvements for the 140 bus service (capacity and frequency) or

introduce a new bus service/s to cope with the forecast increased

demand.

✓

The proposed expansion of bus routes ignores those running

outside the Greater London area to the Thames Valley.

✓

Roads such as the A4 should be rebuilt/relocated to include the

provision of dedicated bus lanes in each direction on the approach

to the airport campus.

✓

There should be a bus and coach services towards southern

Buckinghamshire and a review for additional stops and route

additions within the final 10 kilometres to Heathrow.

✓

There is support for strengthening the coach hub. ✓

The Elizabeth Line and the Western Rail Link would support new

and enhanced bus services to these rail stations from

Buckinghamshire.

✓




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Walking and cycling corridors aligned with Bath Road, Staines Road

east-west, High Street Harlington, the A408, Parkway and A3063

north-south, Hayes, Yiewsley, Southall and Hounslow should be

prioritised.

✓ The Our approach to developing a surface access

strategy consultation document at the Airport

Expansion Consultation One (January 2018) stated

that the provision of better and more sustainable

commuting options (public transport, cycling and

walking) was one of the key priorities for the emerging

surface access strategy. It set out a number of

measures and options about how cycling provision

could be improved including expanding the Heathrow

Cycle Hub scheme, new cycle hub facilities, and

ensuring that fast and frequent connections are

available from the cycle hubs to relevant employment

locations around the airport. It would be possible to

build similar hubs at key entrances to the south and

east of the airport, making cycling more convenient for

many more of our colleagues.

Heathrow is developing and refining plans for cycle

and walking provision taking into account feedback


2018) and technical assessment. A draft Surface

Access Strategy, including an Active Travel Strategy,

will be consulted on at the Airport Expansion

Consultation in June 2019, and will explain

Heathrow’s preferred options for improving cycle and

walking provision.

There should be trains from stations in Elmbridge and a local bus to

provide local people with sustainable access to the airport.

✓ As set out in the Airport Expansion Consultation One

(January 2018) document Our approach to developing

a surface access strategy a priority of the surface

access strategy for Heathrow is improving public

transport so that it becomes the preferred mode of Due to recent cutbacks in bus services, there is a need for better

transport links to and from the airport from the Ashford area.

✓




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There is a need for better transport links to Heathrow from the west,

south west and south from Farnborough and Camberley.

✓ travel for more passengers.

Heathrow supports improved public transport links


airport. Improved bus / coach and rail options are

being investigated as part of the overall surface

access strategy. Elmbridge, Ashford, Farnborough

and Camberley may also benefit from proposals being

considered for a Southern Rail Link that could connect

the existing South Western Railway network to

Heathrow. These proposals form part of a wider

network improvement being considered by the DfT

with private sector involvement.

The preferred options for surface access at the

expanded airport will be set out in the draft surface

access strategy published at the Airport Expansion

Consultation in June 2019, based on feedback from

the Airport Expansion Consultation One (January


Sustainable transport options are required to improve access to the

airport from towns in the Chilterns.



a surface access strategy a priority of the surface

access strategy for Heathrow is improving public

transport so that it becomes the preferred mode of

travel for more passengers.

Heathrow supports improved public transport links


airport. Heathrow acknowledges that the Chilterns

region currently has no direct rail access. Improved

bus / coach and rail options are being investigated as




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part of the overall surface access strategy.

The preferred options for surface access at the

expanded airport will be set out in the draft surface

access strategy published at the Airport Expansion

Consultation in June 2019, based on feedback from



Concern expressed about the potential for a Southern Rail Link to

cause traffic congestion at the level crossings in the Mortlake/East

Sheen area.

✓ The operation of level crossings does not fall under

the remit or responsibility of Heathrow; it is the

responsibility of Network Rail as the rail transport

operator. Furthermore, the Southern Rail Link is a

scheme being explored outside of the Project by the

DfT with private sector involvement and as such, the

impact of the Southern Rail Link on traffic congestion

at level crossings is not a specific consideration for the

Project.

However, Heathrow is working and consulting with

transport operators in developing the surface access

strategy for expansion and is supportive of the

principle of a Southern Rail Link.

A new passenger transfer hub adjacent to Wraysbury station would

enhance rail access, as rail passengers could be transferred in

automated pods along the embankment of the Wraysbury Reservoir

as far as M25 Jct. 14 and from there directly into the airport

Terminals.

✓ The proposal suggested does not currently form part

of the options being considered by Heathrow as part

of its Surface Access Strategy.

As set out in the Airport Expansion Consultation One


a surface access strategy, new technologies (referred

to in the document as “Intelligent Mobility”) have been

taken into account in developing the surface access




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strategy. Heathrow also recognises in this document

the role that new technologies, including automated

vehicles and on-demand services, could have on the

nature of transport and access to the airport.

The land at Hithermoor should be considered for a new rail station

as part of the Southern Rail Link.

✓ There are currently a number of different proposals



These proposals form part of a wider network

improvement being explored by the DfT. There is

currently no railway connection between Heathrow

and the south so this link would fill a key gap in the rail

network. A feasibility study undertaken by Network

Rail showed that there is a strong business case for

the proposals and that there are credible infrastructure

solutions that should be explored further. Heathrow’s

analysis to date indicates that the proposed surface

access strategy is not reliant on a Southern Rail Link

to deliver the mode share targets in the ANPS and

commitment to no increase in Heathrow-related traffic.

Heathrow will work with the DfT to explore options for

a Southern Rail Link. Heathrow has set out its

preferred surface access strategy, which includes a

range of schemes and considers that they should be

delivered whether or not the airport expands.

However, Heathrow has ensured that the emerging

surface access strategy has resilience so that it is not

reliant on the delivery of any one scheme.

Concerns expressed about how Surrey Heath public transport

infrastructure will contribute to delivering the public transport

✓ The ANPS sets down targets for Heathrow to increase

the public transport mode share of passengers and




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passenger targets. reduce the number of colleague car trips to the airport.

Heathrow will work with local authorities, TfL, Network

Rail and other transport providers / operators to

ensure these targets are met and in order to

understand the target completion dates of any third

party or external schemes included in existing rail,

road or other transport investment plans.

Paragraph 5.12 of the ANPS states that, “Heathrow

must demonstrate that Highways England, Network

Rail and any relevant highway and transport

authorities and transport providers have been

consulted, and are content with the deliverability of

any new transport schemes or other changes required

to existing links to allow expansion within the

timescales required for the preferred scheme as a

whole, the requirements of the ANPS and other

statutory requirements.”

Some surface access infrastructure will be secured in

the DCO itself, while funding and support for schemes

that are being delivered by third parties can be

secured through planning obligations if necessary.


Policy Framework that states “The general position for











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a case-by-case basis.”

HGVs are a key issue for the Iver community. ✓ In relation to freight, Heathrow plans to limit freight

vehicles to similar levels to today and help operators

clean up the vehicle fleets through a range of different

initiatives, including increasing efficiency, optimising

the fleet mix and modernisation of airport cargo

facilities. The approach and options being considered

in relation to freight were set out in the Airport

Expansion Consultation One (January 2018) in the

Our approach to developing a surface access strategy

consultation document. The preferred option for freight

management will be set out in the Airport Expansion





be trucked to and from off airport warehouses. Cargo

and logistics facilities around the airport have grown in

an incremental and organic way which means there

are lots of facilities in different locations. By working

with the local authorities to more proactively plan the

land uses around the airport Heathrow can provide

facilities in appropriate locations helping to reduce

shuttling movements through consolidation of loads

and reducing impacts on local communities, including

Iver.

Heathrow will be working with TfL and other

authorities on re-timing journeys that are not time

critical to outside peak periods, monitoring of routing




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for HGVs and other freight vehicles, as well as

ensuring there are appropriate measures in place for

those that do not comply.

Heathrow is continuing to assess any likely significant

effects associated with construction traffic on local

communities. For further information see Chapter 16.

There should be an increase in the frequency of the X26 express

bus service on its route between the airport and West Croydon.

✓ Heathrow recognises the importance of the airport as

a transport hub and the role of local bus services in

connecting communities to the airport, which will only

be more important as rail, coach and Underground

services to Heathrow are improved under expansion.

As such, Heathrow will work with local authorities, TfL

and transport operators to identify measures for new

and improved services, including bus priority

measures to improve the reliability and experience of

bus users travelling to and from Heathrow.

The emerging Surface Access bus and coach

strategies seek to promote use of the bus or coach by

making them a more attractive mode of transport

through the introduction of new express services,

improvements to the frequency and alignment of

existing routes, and extending operating hours.

Heathrow’s preferred options will be set out in the

draft Surface Access Strategy that will be consulted

on at the Airport Expansion Consultation in June

2019.

If the airport expansion proposals generate HGV traffic in addition

to that generated by other major infrastructure schemes in the same

area, Heathrow should make a significant contribution to the cost of

✓ Heathrow will continue to strive to meet its pledge to


today, including freight traffic. The PTIR will be




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the Iver Relief Road in order to address the cumulative impact of

these schemes.

published as part of the Airport Expansion

Consultation (June 2019) and explains what measures

will need to be taken to deal with the anticipated

transport impacts of the development. It summarises

and illustrates the outputs from the traffic modelling. It

will also set out, at a high-level, the strategy for

mitigating any impacts on the surrounding transport

networks that are considered severe.

Further technical assessment work and consideration

of the feedback from the statutory consultation,

including comments about the PTIR and the draft

Surface Access Strategy, will inform the preparation of

a Transport Assessment. This will be submitted with

the DCO application and will report on the results of





Heathrow should identify the need to provide on-demand services

within southern Buckinghamshire




to in the document as ‘Intelligent Mobility’) have been


strategy. Heathrow also recognises in this document

the role that new technologies, including automated

vehicles and on-demand services, could have on the

nature of transport and access to the airport.

For the Airport Expansion Consultation in June 2019,

Heathrow is setting out its preferred options for

surface access at the expanded airport based on




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feedback from the Airport Expansion Consultation

One (January 2018) and ongoing design and

assessment work.

Cycling and walking routes should serve people accessing the

Colne Valley Regional Park, creating important links and building on

the strategic green infrastructure network.

✓ The Our approach to developing a surface access








could be improved including expanding the Heathrow

Cycle Hub scheme, new cycle hub facilities, and

ensuring that fast and frequent connections are

available from the cycle hubs to relevant employment

locations around the airport. It would be possible to

build similar hubs at key entrances to the south and

east of the airport, making cycling more convenient for

many more of our colleagues.




2018) and technical assessment. A draft Surface

Access Strategy will be consulted on at the Airport

Expansion Consultation in June 2019, and will explain

Heathrow’s preferred options for improving cycle and

walking provision.




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The reference to demand responsive transport is welcomed. ✓ As set out in the Airport Expansion Consultation One





strategy.






assessment work.

Concerns expressed that as new runway capacity will not be made

available if noise, traffic or emissions targets will be breached, the

new runway may never be fully utilised. This would undermine the

economic case for expansion.

✓ The ANPS paragraph 5.31 states that the Government

is satisfied that, with a suitable package of policy and

mitigation measures, including the Government’s

modified air quality plan, the Heathrow Northwest

Runway scheme would be capable of being delivered

without impacting the UK’s compliance with air quality

limit values. This also aligns with the conclusion of the

Airport’s Commission and Heathrow’s own work.

The ANPS also includes requirements on noise and

traffic which Heathrow must demonstrate it can meet

as part of its DCO. As part of our Airport Expansion

Consultation in June 2019, we will be publishing more

information on how we will monitor environmental

performance for an expanded airport.

All Heathrow related vehicles should be low or zero emissions. ✓ One option for road user charging being considered,

and which was set out at the Airport Expansion

Consultation One (January 2018) in the Our approach




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to developing a surface access strategy consultation

document, is a charge based on vehicle emissions or

the creation of a low emissions zone. Furthermore, it

explained that Heathrow is investigating options to

ensure that new vehicle technology can be supported

at the airport through appropriate electric vehicle

charging or fuel infrastructure at the airport. This is

already happening with the introduction of a hydrogen

filling station at the airport and Heathrow’s investment

of almost £4million on electric vehicle charging

infrastructure since 2014.






assessment work.

Heathrow should include local communities in the development of

the Surface Access Strategy.

✓ Heathrow has engaged with neighbouring

communities to understand their surface access

requirements to and from the airport, which the draft

Surface Access Strategy will look to support. The

ANPS (paragraph 5.9) also requires that the surface

access strategy is developed in conjunction with the

Airport Transport Forum of key stakeholders including

representatives of local communities. Heathrow

consulted on the emerging surface access strategy at


2018) where the options were presented in the Our

approach to developing a surface access strategy

consultation document. A draft Surface Access




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Strategy will explain and seek feedback on

Heathrow’s preferred options, which will be consulted

on in the Airport Expansion Consultation in June 2019,

in advance of the submission of the application for a

DCO.

Heathrow should include communities that are further away in the


✓ Heathrow consulted on the emerging surface access

strategy at the Airport Expansion Consultation One

(January 2018) where the options were presented in


strategy consultation document. A draft Surface

Access Strategy will explain and seek feedback on

Heathrow’s preferred options, which will be consulted

on in the Airport Expansion Consultation in June 2019,

in advance of the submission of the application for a

DCO. The ANPS (paragraph 5.9) also requires that

the surface access strategy is developed in

conjunction with the Airport Transport Forum of key

stakeholders including representatives of local

communities affected by the expansion plans. Anyone

who is interested in the expansion plans, regardless of

where they live, can put forward their views about the

surface access strategy and the expansion plans.

Publicity about the Airport Expansion Consultation in

June 2019 will be published in local and national

newspapers and journals in accordance with the

Statement of Community Consultation and the

requirements of the Planning Act 2008.

There should be existing public transport improvements to deal

with existing demand under a two-runway airport, not to cater for

✓ The ANPS states at paragraph 3.36 that “Heathrow






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expansion. M40 and M3, and rail links via the London











freight operators in much of the UK, and provides

significant resilience to any disruption.”

Committed schemes that will come forward regardless

of the expansion plans include the Elizabeth Line, that

will begin operating to the airport in 2019, and the

Piccadilly Line upgrade that is planned for 2023. The

Western Rail Link is being promoted by Network Rail

to provide a direct rail connection to Heathrow from

the Great Western Mainline to the west of the airport.

Together these committed projects will contribute

towards continuing the trend that has seen passenger

numbers at the airport double since 1991, but airport-

related road traffic remain largely static.

Road user charging supported. ✓ Support for the principle of road user charging is

noted. Heathrow considers the ability to impose road

user charges where necessary is an important Support for the principle of road pricing and a commitment to use ✓




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the proceeds to provide transport improvements could improve its

acceptance.

component of an integrated surface access strategy

that responds to the targets on air quality, public

transport use and congestion set out in the ANPS. It is

an approach supported by ANPS (paragraph 5.39)

and the recommendations of the Airports Commission.

Options for road user charging were set out at the



strategy consultation document. These included:

• Emissions based surcharge

• Drop off charge

• Terminal low emission zone

• Airport low emissions zone

• Airport access charge

A preferred option is being developed taking into

account consultation feedback and ongoing technical

assessment on the anticipated transport impacts of

expansion. The preferred option will be set out in the


The principle of road user charging is supported, London’s is a

useful model.

✓

Campaign supported road-user charging and/or other methods to

reduce private motor vehicle volumes.

✓

Support expressed for road user charging. ✓

Support expressed for the principle of road user charging,

specifically on the basis of emissions.

✓

Welcome the option of restricting vehicle access through emissions

or access-based charging, suggesting that further analysis of

congestion, charging and other interventions.

✓

The proposals for road user charging supported as it would

encourage public transport use and reduce the number of cars on

the road.

✓

Road user charging would result in better access and convenience

for passengers, would ease congestion and result in a reduction in

emissions and noise pollution and an improvement in air quality.

✓

The Surface Access Strategy would encourage the use of low

emission cars.

✓

Road user charging is both inevitable and logical. ✓




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Road user charging and drop off charges for leisure travellers

should form part of the decision on transport mode.

✓

Charging for passenger drop-off and collection should be further

reviewed as part of a wider strategy to increase the cost of road

travel to Heathrow compared with rail.

✓

It is not clear whether a congestion charge scheme would be

required but Heathrow should have a scheme that is ready to be put

in place should it be required.

✓

Road user charging is supported if electric vehicle were exempt.

This would encourage their use and not restrict vehicle access for

passengers.

✓

The exploration of road user charging and is supported, it will be

necessary to raise the emissions standards incrementally as

technology improves.

✓

Support expressed for road user charging if there are adequate

improvements in public transport.

✓ Heathrow considers that the ability to impose road

user charges where necessary is an important

component of an effective surface access strategy

that responds to the targets on air quality, public

transport use and congestion set out in the ANPS.

Alongside a charging strategy, Heathrow is developing

a wide range of improvements to public transport

provision and accessibility within its surface access

strategy, including rail, coach and local bus, as well as

cycling and walking and colleague travel initiatives.

This aims to create an integrated strategy to meet the

The principle of vehicle charging to encourage modal shift from

road to rail is supported. This can only be justified and is only likely

to be acceptable to airlines and passengers if carried out in

conjunction with major improvements to public transport

connections.

✓

Road user charging may be the only way to encourage use of public ✓




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transport but only if public transport is readily accessible. targets within the ANPS and make public transport the

preferred choice of more passengers and colleagues.

Consideration is being given to the most appropriate

allocation of any potential funding stream generated

by road user charging. Options for road user charging

and the surface access strategy in general were set

out at the Airport Expansion Consultation One

(January 2018) in the Our approach to developing a

surface access strategy consultation document. A

preferred option is being developed taking into



expansion. The preferred option will be set out in the


The Road-User Charging is not a fix for a lack of public transport

investment.

✓

Road-user charging and car parking charges can be effective tools

but must be accompanied by alternative public transport. They

considered that these measures should be pursued to improve air

quality regardless of a third runway.

✓

If suitable alternatives are not provided, road-user charging cannot

be supported.

✓

The revenue from road user charging should be spent on improved

public transport and public transport infrastructure.

✓

Heathrow needs to make the case that road user charging will not

be used to increase income for the airport through displacing traffic

and parking.

✓

If it is seen to be used to fund public transport links to transport

hubs with dedicated parking sites, then a charging approach would

have greater support.

✓

A road user charge will make no difference to air and noise

pollution.

✓ Objection to the principle of road user charging is

noted.

The ANPS, paragraph 5.39, states that an emissions-

based access charge is a potential mitigation measure Opposition shown to road user charging, considering it to be a ✓




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stealth tax. that may be put forward by the applicant in order to

meet the passenger mode share and colleague car

trip targets in the ANPS. This is consistent with the

Airports Commission recommendation that the

introduction of a congestion or access charge for road

vehicles should be considered.

Heathrow considers the ability to impose road user

charges where necessary is an important component

of an integrated surface access strategy that responds

to the ANPS surface access targets. A price incentive

that favours public transport is important to obtain the

required behavioural change from airport users and

enable maximum effectiveness and use of

investments in public transport. It is intended to be

implemented as a component of an integrated surface

access strategy alongside a wide range of

improvements to public transport provision and

accessibility.

Heathrow remains committed to keeping airport

charges close to 2016 levels.

Did not favour road user charging. ✓

Road user charging has a role, however, it would have no more

effect than the already high parking charges.

✓

Road user charging will not necessarily reduce travel. ✓

It is unreasonable to pay a road user charge to access the airport

for private car or taxi on top of high airport charges and Air

Passenger Duty.

✓

Concern expressed about proposals to charge airlines and their

passengers for the cost of the access work associated with

expansion.

✓

Concerns expressed about road user charging. ✓

Motorists are already taxed too much and the proposals for road

user charging are unfair for those that work at the airport and would

also result in increases in taxi fares.

✓

Any additional road user charges will directly impact the airport,

passengers and employees.

✓

Alternative mechanisms and schemes for promoting modal shift

and meeting the targets of the ANPS should be exhausted before

✓




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any form of additional charges to airport users is introduced.

Any alternative mechanisms and oncoming schemes for promoting

modal shift to meet the targets of the ANPS should be exhausted

before any form of additional charges to airport users are

introduced.

✓

Further analysis of congestion, charging and other interventions

should be undertaken.






access strategy. For the Airport Expansion

Consultation in June 2019, Heathrow is setting out its

preferred options for public transport provision at the

expanded airport based on feedback from the Airport

Expansion Consultation One (January 2018) and

ongoing design and assessment work.

Furthermore, a Transport Assessment will be

submitted with the DCO application and will report on

the results of the further detailed assessment work

and, for locations where the impacts of the project are


proposed mitigation strategy. An Environmental

Statement will assess the scheme in terms of its likely

impacts on the environment and identify mitigation

measures to minimise impacts.

Further analysis should be undertaken as to how road user

charging would reduce emissions and vehicle numbers.

✓

Road user charging may not be effective and there is no clear detail

on how it will be monitored and by who.

✓

The impact of this strategy on business and the implications for

staff and visitor travel if road user charging and an airport uLEZ

were to be considered needs to be understood.

✓

Concerns expressed about road user charging and low emissions

zone charging around the airport as it is considered that it may

distort how the market operates and negate the attempts to

minimise traffic generation.

✓

Road user charging is generally noted but it should be noted that it

only works on the assumption that all the vehicles in and around

the airport are electric.

✓




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The proposed uLEZ zones need to be designed to ensure that any

impacts or benefits are effective and offset all potential emission

source increases including from aircraft.

✓

The proposal for road user charging has not been researched

properly or accurately and it will not work.

✓

The focus should be on low emission vehicles and that road user

charging is not the right principle.

✓ One option for road user charging being considered,

and which was set out at the Airport Expansion

Consultation One (January 2018) in the Our approach

to developing a surface access strategy consultation

document, is a charge based on vehicle emissions or

the creation of a low emissions zone. Furthermore, it

explained that Heathrow is investigating options to

ensure that new vehicle technology can be supported

at the airport through appropriate electric vehicle

charging or fuel infrastructure at the airport. This is

already happening with the introduction of a hydrogen

filling station at the airport and Heathrow’s investment

of almost £4million on electric vehicle charging

infrastructure since 2014.






assessment work.

The focus should be on autonomous vehicles rather than road user

charging.







PC MC WC



strategy.


Heathrow will set out its preferred options for surface

access at the expanded airport based on feedback



Heathrow should consider using renewable diesel for bus and

coaches if a uLEZ is to be introduced.


2018) document Our approach to developing a

surface access strategy explained that Heathrow is

investigating options to ensure that new vehicle

technology can be supported at the airport through

appropriate electric vehicle charging or fuel

infrastructure at the airport. This is already happening

with the introduction of a hydrogen filling station at the

airport and Heathrow’s investment of almost £4million

on electric vehicle charging infrastructure since 2014.


as part of the Airport Expansion Consultation (June

2019) and will explain Heathrow’s preferred options

for promoting the use of cleaner vehicles servicing the

airport, including providing electric charging

infrastructure at the airport.

Consultation on road user charging is the Government's

responsibility.

✓ The proposals for user charging would involve

Heathrow being granted powers in the DCO to impose

charges for vehicles using the airport roads. It is

therefore Heathrow's responsibility to carry out

consultation on those proposals. Heathrow is




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therefore consulting on road user charging relating to

the Project. Options for road user charging at the

airport related to expansion were consulted on at the


the document Our approach to developing a surface

access strategy. Further consultation is being

undertaken prior to submission of the DCO application

in accordance with best practice and statutory

requirements, as more detailed proposals are

developed and preferred options identified.

The proposals for road user charging are not socially inclusive. ✓ Heathrow considers the ability to impose road user


of a surface access strategy that responds to the

targets on air quality, public transport use and

congestion set out in the ANPS. It is an approach

supported by ANPS (paragraph 5.39) and the

recommendations of the Airports Commission. A price

incentive that favours public transport is important to

obtain the required behavioural change from airport

users and enable maximum effectiveness and use of

investments in public transport. Any charging strategy

will be implemented in a manner that is sensitive to

the needs of airline colleagues and passengers and

would include appropriate exemptions.

Emission charging should be for direct users of the airport rather

than all vehicles. Joint monitoring and review of air quality across

the area is vital to the success of achieving a reduction in

emissions.

✓ The principle of vehicle charging is considered a

necessary component of an integrated strategy that

responds to the ANPS targets. A price incentive

towards alternative modes of transport is important to

obtain the required behavioural change from airport





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investments in public transport.

As set out in the Airport Expansion Consultation One

document Our approach to developing a surface

access strategy, any charging strategy will be

implemented in a manner that is sensitive to the

needs of airline staff and passengers and would

include appropriate exemptions. Heathrow has stated

that the surface access strategy for expansion will

contain specific and measurable targets that can be

monitored over time.

Concerns expressed about road user charging and low emissions

zone charging around the airport as it is considered that it may

distort how the market operates and negate the attempts to

minimise traffic generation.

✓ A low emissions zone was just one option within the

wider consideration of road user charging that was set

out at the Airport Expansion Consultation One


surface access strategy consultation document. A

preferred option is being developed taking into



expansion. The preferred option will be set out in a

draft Surface Access Strategy at the Airport

Expansion Consultation in June 2019. This will take

account of feedback received during ongoing

consultation and engagement activities, including with

the public, local authorities, landowners, TfL and

numerous other stakeholders.

Heathrow should consult with commercial operators and land

owners to ensure that it does not reduce competitiveness or lead to

more traffic in the areas on the edge of the zone.

✓

Heathrow should work with councils to create a wider low emission

zone (CAZ) that helps address the AQMA’s surrounding the

expanded airport rather than an extension of the TfL LEZ causing

more polluting vehicles to travel in the surrounding Slough

Borough.

✓

A drop off/pick up charge will need to be carefully managed and a

uLEZ for freight vehicles could see a reduction in emissions.

✓ A low emissions zone and a drop off/pick up charge

are two options within wider consideration of road user

charging set out at the Airport Expansion Consultation

One (January 2018) in the Our approach to




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developing a surface access strategy consultation

document. A preferred option is being developed

taking into account consultation feedback and ongoing

technical assessment on the anticipated transport

impacts of expansion. The preferred option will be set

out in the Airport Expansion Consultation in June

2019. Options specifically in relation to freight are also

being considered and developed alongside a charging

strategy.

Any road user charging scheme needs to be simple with viable

alternatives.


user charges where necessary is an important

component of a surface access strategy that responds

to the targets on air quality, public transport use and

congestion set out in the ANPS. Alongside a charging

strategy, Heathrow is developing a wide range of

improvements to public transport provision and

accessibility within its surface access strategy,

including rail, coach and local bus, as well as cycling

and walking and colleague travel initiatives. This aims

to create an integrated strategy to meet the targets

within the ANPS and make public transport the

preferred choice of more passengers and colleagues.

Concern expressed about the risk of introducing excessive charges

that lead to car drivers using surrounding villages as alternatives

for parking.


user charging, where necessary, is an important

component of a surface access strategy that responds

to the targets on air quality, public transport use and

congestion set out in the ANPS. A price incentive

towards alternative modes of transport is important to Road user charging is an effective method to dis-incentivise vehicle

use within certain areas but around the airport it will create

✓




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disadvantages to local residents. obtain the required behavioural change from airport


investments in public transport. Any charging strategy

will be implemented in a manner that is sensitive to

the needs of airline colleagues and passengers and

would include appropriate exemptions.

As set out at the Airport Expansion Consultation One


surface access strategy consultation document,

Heathrow will work with local authorities to develop

schemes to prevent airport-related parking on local

residential roads, such as the introduction of

Controlled Parking Zones (CPZs) and their

enforcement.

The options for road user charging were consulted on

at the Airport Expansion Consultation One (January

2018). Further information and the preferred approach

to a charging strategy will be set out and consulted

upon in the draft Surface Access Strategy during the


Furthermore, a Transport Assessment will be

submitted with the DCO application and will report on

the results of the further detailed assessment work

and, for locations where the impacts of the project are



The principle of a uLEZ is supported but cars should not be

displaced into surrounding areas to park on local roads.

✓

Residents who live near the airport should be exempt from any road

charges were also received.

✓

The details of any proposed road charging schemes should take

into account the need to control any adverse impacts at the

charging boundary.

✓

Road user charging must be designed to avoid unacceptable

displacement impacts and be fully funded by Heathrow, including

associated mitigation measures, to ensure local communities are

not unfairly penalised.

✓

These approaches must be considered across the entire area to

avoid either displacing private car journeys to a few stops down the

underground line or nearby hotels etc.

✓

Airport employees will have the road user charging factored into

rates of pay or contracts and it will instead have the greatest effect

on local residents who are not compensated through employment.

✓




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Any road-user charging should be implemented in a way that

reduces traffic, poor air quality and noise impact on the natural

environment.

✓ Heathrow considers the ability to impose road user


of a surface access strategy that responds to the

targets on air quality, public transport use and

congestion set out in the ANPS. It is an approach

supported by ANPS (paragraph 5.39). The options for

road user charging were consulted on at the Airport

Expansion Consultation One (January 2018) and

included consideration of charging related to vehicle

emissions, drop-off, general access or the creation of

low emissions zones. The aim of a charging strategy

would be to prevent increases in traffic, encourage

public transport use and help address air quality

concerns.

Further information and the preferred approach to a

charging strategy will be set out and consulted upon in

the draft Surface Access Strategy during the Airport


Road-user charging be implemented in a way that reduces traffic,

poor air quality and noise impact on the Park and its local

communities.

✓

Heathrow’s work on sustainable travel plans for its staff and

contractors to reduce reliance on private motor vehicles is

supported.

✓ The Airport Expansion Consultation in June 2019 will

include a draft Surface Access Strategy and

supporting technical information in the PTIR. This will


infrastructure needed to support the Project in the

context of increasing the use of public transport,

walking and cycling by passengers and colleagues,

and Heathrow’s preferred plans for a new parking

Heathrow should continue their commuter programme to reduce car

use.

✓

Heathrow should consider where the future workforce will be from

and seek to encourage a greater spread of employees with an

✓




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equitable choice of transport modes. strategy and freight/logistics strategy.

The draft Surface Access Strategy will make clear

Heathrow’s commitment to meeting the targets for


and reducing the number of colleague car trips as

required by the ANPS.

Many Heathrow colleagues live in boroughs close to




public transport. Where there are good alternatives



wants fewer colleagues to drive to work by making

more sustainable modes more attractive.






people to use.

As part of its surface access strategy for expansion,

Heathrow is committed to working with Highways

England, Network Rail, TfL, local authorities and

transport operators to understand and plan for the

transport needs of the local communities affected by

the expansion and further improve colleague access

to sustainable travel as well as changing travel

behaviour.

The strategy allows more staff/workers to use public transport to

get to/from work at the airport.

✓

The awareness of changing staff travel behaviour is welcomed and

Heathrow should think creatively about how this might be achieved.

✓

An opportunity to evaluate how transport for airport workers can be

incorporated into a wider public transport strategy across the M3

corridor, incorporating passenger transport and airport access

would be welcomed.

✓

Employees can often benefit from a monthly season bus ticket and

this could be addressed through an expansion of the free travel

zone for buses.

✓

Heathrow must consider the future workforce and encourage a

greater spread of employees with an equitable choice of transport

modes.

✓

There is a need for certainty on how Heathrow will achieve the

proposed targets for reducing staff car trips.

✓




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A draft Surface Access Strategy will be consulted on

at the Airport Expansion Consultation in June 2019

and will explain Heathrow’s preferred options for

encouraging sustainable travel by colleagues.

The provision of cycle routes is supported. ✓ The Our approach to developing a surface access








could be improved including:

• expanding the Heathrow Cycle Hub scheme which already has over 2,300 members and offers discounted cycles and equipment, free labour on maintenance and training to all airport employees.

• new cycle hub facilities could provide a single point of entry to and from Heathrow and a holistic service to users, including shower and changing facilities.

• ensure that fast and frequent connections are available from the cycle hubs to relevant employment locations around the airport. It would be possible to build similar hubs at key entrances to the south and east of the airport, making cycling more convenient for many

More could be done to ensure that a far higher proportion of those

working at or near the airport can cycle to work.

✓

Cycle hub areas will require large amounts of cycle parking. ✓

Heathrow should provide safe, high quality cycle infrastructure for

employees living near the airport.

✓

Walking and cycling needs to become part of an integrated

approach to reducing traffic and managing air quality.

✓

A clear target for cycle journeys for staff that exceeds TfL targets

for London and develops a plan to deliver the infrastructure

necessary to meet that target.

✓

Heathrow should ensure that walking and cycling are enabled and

there should be no increase in road vehicles across the area.

✓

The new runway would present one of the largest barriers to north-

south cycling in London. Heathrow should include a tunnel for

cyclists under the runway.

✓




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Suggested that there should be a more central north-south cycle

route through the airport which could potentially be combined with

the proposed new southern access to the central terminal area.

✓ more of our colleagues.




2018) and ongoing technical assessment work. A draft

Surface Access Strategy will be consulted on at the

Airport Expansion Consultation in June 2019 and will

explain Heathrow’s preferred options for improving

cycle and walking provision.

Much of the area surrounding the airport is inhospitable to cycling

and/or walking. Better walking and cycling routes, connections and

neighbourhoods should be provided.

✓

There could be cycle routes around the perimeter and to the west

and south of the airport.

✓

The proposals to promote walking and cycling should only relate to

staff working on the airport periphery and not to passengers or to

staff needing to go into the central area.

✓

Initiatives to provide more sustainable travel alternatives are

supported but consideration should be given to how the airport will

fit into the existing cycle and footpath network.

✓

A cycle network is essential to encourage workers to cycle to and

from work and in the vicinity of the airport. They suggested that this

must be considered in the road alignments and junction layouts of

both the local road network and motorway.

✓

Heathrow should develop walking and cycling routes that will

provide safe and attractive routes into the airport as well as

alternative green transport links between each of the population

nodes.

✓

Conditions for cycle access to Heathrow will require an

improvement to cycle superhighway standard and secure cycle

✓




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parking at all parts of the airport where employees are based.



AIR QUALITY AND EMISSIONS

Introduction


relation to the measures proposed to manage emissions from the design,

construction and operation of the Heathrow Expansion Project (the Project). A

total of 1,226 consultees made comments relating to this topic.

21.1.2 Heathrow provided the following material that is directly related to the measures

proposed to manage emissions:


2. Our Approach to Air Quality.

21.1.3 Heathrow asked the following questions in relation to the measures proposed to

manage emissions at Airport Expansion Consultation One:

1. Please tell us what you think about the measures proposed to manage

emissions. Are there any other measures that we should consider?









feedback. For those issues raised in relation to any other aspects of the Project,

we have provided a summary of the way in which we are seeking to consider the

issues as part of preparing the detailed proposals which will be presented as part

of the Airport Expansion Consultation planned for June 2019.


Local Authorities

General Comments

21.2.1 Bracknell Forest Council expressed concerns that expansion will increase

disturbance and pollution for its residents, particularly those in the northern

parishes of the borough. They requested further information on the proposals to

eliminate these effects, maintain air quality and minimise emissions.



21.2.2 The London Boroughs of Hillingdon, Richmond upon Thames and Wandsworth

and the Royal Borough of Windsor and Maidenhead stated their opposition to the

Project due to unlawful air pollution. They suggested that the government’s air

quality plan does not include expansion at Heathrow and considered that there is

no evidence to suggest an expanded Heathrow can be achieved and operated

without causing additional unlawful air pollution. They suggested the best

approach is to not expand Heathrow and address the current adverse impacts.

21.2.3 The London Borough of Islington expressed opposition to expansion and raised

concerns that any increase in air travel will have a detrimental impact on air quality

and increase greenhouse gas emissions.

21.2.4 Kent County Council welcomed Heathrow‘s commitment to develop new

technologies that could improve the environment in which they operate. They

suggested that Heathrow contribute funding for such technological improvements

and facilitate the development of new technologies to do this.

21.2.5 The London Borough of Lambeth expressed concern about the potential impact on

air quality in the immediate and Greater London area. They stated that an

expanded Heathrow will undermine London’s ability to meet legal air quality limits

and said that the Heathrow area has breached air pollution limits every year for the

past decade due to its location between the M25 and M4 motorways, planes and

traffic.

21.2.6 Wycombe District Council expressed concern about the impacts of pollution on

their residents due to the Project. They commented that Heathrow must make a

commitment to deliver projects that enable passengers, workers, commuters and

freight to move to more sustainable and accessible modes of travel and contribute

towards the achievement of mode share targets.

Surface access related emissions and management

21.2.7 The London Borough of Brent considered that more could be done to

control/influence how the airport is accessed and reduce the need for passenger

and staff car use. Elmbridge Borough Council also referred to surface access

issues in respect of air quality and noted that better traffic management and

vehicle improvements will also improve air quality around the airport, whilst

highlighting that tackling air quality is not the sole responsibility of Heathrow.

21.2.8 The London Borough of Hounslow contested Heathrow’s statement that airport

related traffic accounts for only 16% of the total volume of traffic on the

surrounding road network. They expressed concern about the deliverability of

Heathrow’s pledge to deliver expansion with no more vehicles on the road without

any new significant public transport infrastructure being proposed. They also

commented that dust emissions will need to be assessed as part of a cumulative

impact assessment.



21.2.9 The Royal Borough of Kingston on Thames said that air quality modelling

contributions towards the costs of major schemes and investment in the public

transport network will be required. They identified that even with these approaches

the latest government air quality assessments show that the Project will make the

London Zone non-compliant in 2026/28. They considered that the only way to

address this would be the implementation of a Clean Air Zone and/or Zero

Emissions Zone. A similar view was shared by Ealing Council who stated that

there needs to be an Ultra-Low Emission Zone (ULEZ) and that consideration

should be given to alternative fuel infrastructure especially for freight transport, so

that ultra-low emission vehicle technologies can be introduced.

21.2.10 The Royal Borough of Kingston on Thames also stated that the implementation of

Air Quality Action Plans, surface access improvements and encouraging

sustainable forms of transport would be of benefit and suggested that Heathrow

work with stakeholders to increase understanding of key matters such as how it

affects the health and quality of life of local communities.

21.2.11 Reading Borough Council emphasised that the delivery of the rail and bus links for

surface access will be the most effective way of reducing emissions and improving

air quality. They also requested further detail on how the emissions from the extra

planes will be addressed.

21.2.12 Slough Borough Council expressed concern that displaced airport and non-airport

traffic will give rise to air pollution hot spots, suggested that the scope of air quality

assessments will need to be agreed with Heathrow Strategic Planning Group

(HSPG) and requested that Brands Hill Air Quality Management Area be included

with the airports air quality model and study area.

21.2.13 Spelthorne Borough Council requested mitigation measures to improve air quality

in pollution hotspots beyond the immediate area of the scheme. They raised

concerns that expansion will result in significant redistribution of traffic around the

airport and additional traffic flows across the north of Spelthorne where

improvements and mitigation will also be required.

21.2.14 They suggested that the definition of Heathrow related traffic must include traffic

on all roads, as vehicle movements on the airport controlled landside roads could

have significant highways, air quality and noise impacts. The Perimeter Roads

also carry a high proportion of traffic circulating around the airport between

terminals, car parks and other ancillary airport facilities and must be included in

both the baseline and future assessment of vehicle movements.

21.2.15 Surrey Heath Borough Council welcomed Heathrow's aim to incentivise more

efficient operation of aircraft on the ground and upgrade the airline fleet but

requested that their highway network is given full consideration in Heathrow's

future approach to air quality. This includes an AQMA in place on the M3 between



J3 and 4 and the A331 in the west of Surrey Heath, where exceedances of the

annual mean NO2 limit value have been identified.

21.2.16 The Royal Borough of Windsor and Maidenhead expressed concern that

expansion would increase traffic in the Air Quality Management Areas (AQMAs)

within the borough and that no strategic objective for the management of surface

transport had been produced. They considered that Heathrow has not

demonstrated how it can effectively deliver its proposed scheme, including its

2030 public transport modal share target, without adversely affecting air quality.

21.2.17 They also requested that:

1. the A4 is declared as a clean air zone (CAZ) and aligned with the airports low

emission zone (LEZ);

2. airport related freight routes that use the strategic road network (motorway),

are CAZ compliant;

3. electric vehicle infrastructure is implemented within and outside the airport to

encourage the adoption of low emission vehicles; and

4. Heathrow work with the Council to enable all taxis to be ultra-low emission

vehicles (ULEV) by 2025.

Air quality assessment and monitoring

21.2.18 Buckinghamshire County Council stated that local air quality and the potential

effects of pollution upon public health remain a significant concern to communities

around Heathrow. They welcomed Heathrow’s commitment to complete a detailed

air quality assessment and commented that increases in passengers, freight and

staff are likely to push air quality over legal limits in communities in the southern

part of the county.

21.2.19 They stated that the area of monitoring must include locations in and around the

Ivers which will be subject to cumulative increases in traffic and locations and has

high numbers of vulnerable users i.e. schools and where the public access leisure

and recreation facilities.

21.2.20 They also stated that it is not clear what the current health impacts are, and no

information is provided on the health impacts and mitigation measures, a view also

expressed by Elmbridge Borough Council. They requested the health impact and

air quality assessment methodologies and reports are provided at the earliest

opportunity.

21.2.21 The London Borough of Hammersmith and Fulham expressed concern that

increases in emissions of pollutants during the construction or operational phases

of the scheme could result in the worsening of local air quality. They also

highlighted that air quality assessments show that an expanded Heathrow would

contribute to exceedances of the Nitrogen Dioxide air quality limits.



21.2.22 The London Borough of Hounslow expressed disappointment at Heathrow’s

reluctance to fund on-site air quality monitoring and requesting continuous

monitoring to establish an accurate baseline at specific sites. They also shared

concern that Heathrow appears content to use the Pollution Climate Mapping

(PCM) model, which is known to under-predict real air pollution level by a

wide margin.

21.2.23 Runnymede Borough Council commented that to grant development consent, the

Secretary of State will need to be satisfied that the scheme would be compliant

with legal requirements on air quality impacts in the wider area. They requested

confirmation of how the wider area is defined before they could confirm

acceptance of Heathrow’s approach. They also highlighted that Heathrow’s

assessment must include the cumulative impact on existing exceedances and

likelihood of new/additional exceedances of the air quality objective limits.

21.2.24 They expressed concern about the impacts on air quality and the health of

communities during the construction and operation of the expanded airport

including the M25 and suggested that compliance with the National Air Quality

Objectives and rigorous monitoring of performance against agreed measures at

regular intervals are essential. To achieve this, they considered that air pollutants

should be monitored and assessed on the surrounding local and strategic road

network and not just within the red line boundary.

21.2.25 Slough Borough Council expressed support for the ‘Triple Lock Guarantee’.

21.2.26 South Bucks District Council expressed concern about the impact on the proposed

AQMA in the Iver and Burnham Beeches Special Area of Conservation. They

suggested that extending the ULEZ to the area around the airport, including

preferably the M25 Motorway, will assist in improving air quality for residents.

21.2.27 Spelthorne Borough Council welcomed the use of independent Air Quality experts

and requested clarity on how the group will function, the level of transparency and

how outputs from the assessment will be shared with stakeholders.

21.2.28 They also made the following comments as summarised below.

1. The air quality assessment must model all main roads across the wider area

and local roads in the immediate vicinity of the scheme and must take account

of air quality monitoring data from the local authority networks across the

Heathrow area.

2. The highways and air quality assessments must consider the cumulative

impacts of expansion with existing consented major schemes, likely schemes

from the Local Plans and all displaced uses.

3. The effect of airborne aircraft emissions on local pollutant concentrations

should be demonstrated by mapping airport-related contributions to annual



mean concentrations of pollutants, with a plan showing just the airborne aircraft

emissions contribution.

4. Targets or measures should be proposed to minimise air quality impacts

arising from the construction workforce.

21.2.29 Surrey County Council commented that Heathrow should commit to support

progressive reductions in air pollutants in areas that do not meet Air Quality

Objective thresholds. They further assert that the ‘Triple Lock Guarantee5’ must be

honoured.

Legislation and policy

21.2.30 The London Borough of Hammersmith and Fulham requested detailed information

on pollution sources at Heathrow and the mitigation measures detailed in the draft

Airports National Policy Statement (draft ANPS) as this information was not in the

consultation document.

21.2.31 They also commented that the ‘Triple Lock Guarantee’ on air quality made by

Heathrow is not consistent with the draft ANPS and cannot be regarded as long-

term commitments.

21.2.32 The London Borough of Harrow referred to the aspirations and targets set out by

the Mayor of London in the draft New London Plan and requested further detail on

how emissions would be mitigated and how Heathrow would contribute to the Air

Quality Positive policy.



21.2.33 Highways England commented that adverse change to noise and air quality from

any changes to the strategic road network must be fully considered and mitigated,

including in relation to compliance with the European air quality limit values and/or

in local authority designated Air Quality Management Areas (AQMAs).


21.2.34 Natural England stated that the consultation documents did not include an

assessment of potential air quality impacts on European sites and advised that a

detailed assessment should be completed prior to submission of the Development

Consent Order (DCO) application.

5 Triple lock Guarantee as detailed on page 58 of the Airport Expansion Consultation Document



Other Prescribed Bodies

General Comments

21.2.35 Bray Parish Council suggested the measures proposed to manage emissions

would only increase prices.


21.2.36 Albury Parish Council suggested that the roads surrounding Heathrow cannot

cope with the existing volume of traffic contributing to poor air quality. They

considered that new rail links must be built before the new runway to ensure

impacts on the existing road system are minimised.

21.2.37 Horton Parish Council expressed concern that additional construction traffic

movements would add to the existing issues with air quality caused by traffic

congestion and commercial vehicles using the roads through the village. They

commented that existing air quality measures have not worked, and that further

erosion of land and green space will worsen air pollution in the area.


21.2.38 Iver Parish Council stated that it was not possible to form a view on many of the

proposals without more information on the impact on air quality. They stated that

no baseline measurements had been undertaken in the area following existing air

quality breaches and noted that an AQMA has been declared within the Parish.

21.2.39 The Heathrow Strategic Planning Group noted that air quality demands a joint

approach by Heathrow and Local Authorities, including monitoring and

compliance. They welcomed Heathrow’s ambition to be a ‘flagship’ of sustainability

and suggested that the ‘Triple Lock Guarantee’ should be honoured by Heathrow

and intertwined into the DCO requirements. They also said that joint monitoring

and review processes are vital to the success of achieving a reduction in

emissions and Heathrow should provide funding for this.


21.2.40 Windlesham Parish Council recognised Heathrow’s commitment to improving air

pollution by adopting an incentive policy which will encourage airlines to upgrade

their fleet. They expressed disappointment that Heathrow considers surface traffic

to be the major cause of pollution and are concerned that measures to manage

emissions do not extend beyond a 2km radius of the airport.

Local Communities


General Comments



21.3.1 Members of the public who commented on air quality and emissions made a range

of comments that comprised general statements of support for the approach along

with criticisms about the effects of the existing and proposed airport expansion and

the approach to managing effects. The main criticism received was that the

proposed measures were inadequate, insufficient or ineffective with concerns

about the lack of practical measures being applied to reduce the airport related

traffic movements for staff and service vehicles as well as airport users. Others

commented that the measures were unrealistic, lacked credibility and were

unsuitable with some respondents suggesting that emissions management will not

keep pace with longer term expansion.

21.3.2 Respondents highlighted that managing air quality is of the utmost importance and

that greener vehicles, such as electric cars, will have a positive effect in the future,

whilst others recommended a review of the achievements made by other cities

which prevent aircraft flying over communities. Other respondents indicated that

there wasn’t enough information or detail about proposed measures for them to

provide comment or feedback at this stage.

21.3.3 Positive comments were received from the public about the approach to managing

air quality and emissions and Heathrow’s ‘Triple Lock Guarantee’. These were

often general statements of support for the approach and were not qualified with

further information or detail. Comments were also received which expressed

support for the approach to managing air quality impacts and emissions subject to

certain conditions being met.

21.3.4 Consultation feedback highlighted the effects of extra vehicle traffic on the local

road network and congestion on air quality. The additional vehicular movements

associated with construction activities was also a concern. Respondents

suggested that measures to manage emissions would have negative

consequences on traffic congestion, business and the economy.

21.3.5 Concerns were also raised about the lack of detail and information on air quality

matters, the impact on people’s quality of life, health and well-being, the impacts of

air pollution, the effect on the environment and that the proposals fail to consider

pollution produced by aircraft and the danger of breaching EU limits.

21.3.6 Suggestions for plans to deal with air quality emissions were received, these

comprised:

1. reducing the number of flights in order to manage air pollution from aircraft

taking off and that aircraft should fly higher;

2. The proposals are based on old technology and should include measures that

ensure all airport related vehicles including cargo and maintenance are electric

and the banning of more polluting planes;



3. Real-time public display of air quality data against targets with the

encouragement of less polluting commercial vehicles with a rebate system;

4. restricting or banning high polluting vehicles with cleaner less polluting vehicles

paying less for parking and road charges and having better access to the

Terminals;

5. using/incentivising cleaner aircraft and the incentivisation of low carbon flights;

and

6. enforcing a ban on aircraft of a certain age.

Businesses

General Comments

21.3.7 Annie’s Nest Nursery cited noise, pollution and the overall human cost of extra air

pollution in the area as the reasons they opposed the scheme.

21.3.8 Hatton Garden Trustees Limited and Pickering Properties Limited acknowledged

the requirement for Heathrow to provide a resilient and reliable road network in

order for it to deliver a reduction in emissions and limit fuel use.

21.3.9 Hatton Farm Estates Limited suggested that Heathrow should encourage the use

of electric vehicles by providing incentives.


21.3.10 The Arora Group expressed concern about the air quality impacts of construction

as well as other scheme elements such as a realigned M25 and suggested that

legal challenges will emerge following the adoption of the Airports National Policy

Statement, which are likely to address air quality.

Air quality and carbon assessment and monitoring

21.3.11 The Airport Industrial Property Unit Trust (AIPUT) commented that Heathrow

should publish the results of their air quality assessments as well as the embodied

carbon and emissions impact.

21.3.12 The Arora Group said that it was unclear how the assessments for evaluation and

discontinuation of options had taken in to consideration issues such as air quality,

public transport considerations and the influence of other scheme elements. They

commented that discounting the Family C Runway options (as detailed in the

Scheme Development Report) based on air quality impacts does not appear to sit

properly within the unworkable evaluation prescribed to it.

21.3.13 The Emerson Group on behalf of Orbit Developments (Southern) Limited stated

that the approach set out in the consultation documentation is inadequate and

lacks information on mitigation measures. They also suggested that if Heathrow is



in breach of air quality requirements it weakens the case for the use of compulsory

purchase powers.

21.3.14 The Fuel Trading Company suggested that the measures proposed to combat the

issue of emissions were very vague. They suggested that mandating all

contractors to use renewable diesel would improve both the air quality and

greenhouse gas emissions/carbon intensity when building the runway.

21.3.15 Segro asked for confirmation as to whether the ‘Triple Lock Guarantee’ includes

freight and cargo traffic or is limited to light duty vehicles. They considered that

any air quality measures taken around the airport that may apply to freight or other

air related businesses in the future must be consistent with the ULEZ in London

and the government’s Clean Air Strategy to avoid fragmentation of vehicle

standards. They also expressed a desire to participate in the Sustainable Freight

Group.

21.3.16 The Thames Valley Chambers of Commerce asked that mitigation be introduced

as early as possible, before the runway is completed.

21.3.17 The London (Heathrow) Airline Consultative Committee and the Board of Airline

Representatives UK commented that the airline community has an important role

and any air quality and emissions measures must be developed in full consultation

and agreement with them. Non-airport related emissions should be distinguished

clearly from airport-related emissions and the focus for Heathrow and the airline

community should be on collective working to address the latter.

21.3.18 They indicated that the Airline Community will support cost-effective and

operationally viable initiatives to help reduce emissions including supporting a

broad choice of sustainable transport modes for passengers, cargo and

employees. They agreed with the conclusion that NOx emissions are a

consequence of urban development and non-airport traffic but suggested that

punitive emission charges should not be introduced unless affordable and

sustainable alternative means to access the airport are implemented.

Community Groups

General Comments

21.3.19 The Camberley Society highlighted the need to look at the existing Heathrow

Airport first, in respect of air quality issues, and queried whether Heathrow is

looking at best practice examples from around the world.

21.3.20 Colnbrook Community Association considered the plans to reduce emissions are

inadequate and fail on all grounds according to the recent report produced by the

New Economics Foundation which uses DfT modelling.



21.3.21 Slough and District Against Runway 3 commented that Heathrow cannot meet

World Health Organisation air and noise pollution limits today and has no credible

or acceptable plan to do so.

21.3.22 West Windsor Residents Association stated they have no confidence in

Heathrow’s claims that air pollution can be adequately addressed. They suggested

it has been promised many times previously and air pollution remains at an

unacceptable and in places dangerous level.


21.3.23 The Camberley Society suggested that better transport links are required to

reduce traffic emissions.

21.3.24 The Colnbrook Community Partnership suggested consideration be given to how

unauthorised car park and caravan sites for construction workers will be managed

as these could lead to adverse air quality impacts on residential areas.

21.3.25 The Fulham Society commented that air quality problems extend to areas further

from Heathrow airport. Limiting car parking spaces and the provision of a new rail

link from Waterloo are therefore important measures.

21.3.26 The Heathrow Association for the Control of Aircraft Noise expressed concern

that the amount of traffic on the roads will have a knock-on effect on the ability

to control air quality levels. They considered improvements to air quality will

largely depend on government action to tackle vehicle emissions and investment

in rail schemes.

21.3.27 Local Conversation in Stanwell commented that Heathrow’s commitment to not

increase the amount of airport-related vehicle traffic on the road and increase the

numbers of people using public transport would not be enough to improve air

quality in Stanwell and Stanwell Moor.

21.3.28 Northumberland Walk Residents Association commented that current traffic

volumes, especially HGVs, already have a significant and negative impact on their

community from noise, air pollution and poor road safety.

21.3.29 St Albans Quieter Skies commented that in the long term, increased flights from

Heathrow will lead to a lot more traffic on the M25 (and M4) increasing congestion

and air pollution near Heathrow and up to and near St Albans.

21.3.30 Wentworth Residents’ Association said that building more car parks, hotels and

other sites around the airport contradicted Heathrow’s intention of dealing properly

with air quality issues.


21.3.31 Aircraft Noise Three Villages stated that Heathrow already breaches legal air

pollution limits and does not have a tenable plan to meet legal air pollution limits



even without a third runway. They considered that Heathrow are misleading

consultees by suggesting that ground based sources are the main contributor to

harmful emissions when planes emit large amounts of NOx and have vastly higher

emissions than suggested.

21.3.32 The Colnbrook Community Partnership expressed support for the ‘Triple Lock

Guarantee’, the establishment of an independent regulator and the use of

construction logistic hubs to reduce emissions.

21.3.33 They raised concerns about air quality impacts on Elbow Meadow properties due

to the proximity of the potential Area 2 taxiways and queried whether air quality

had been considered when selecting the options for the A3044, the M25, or Option

6C for the A4 (as detailed on pages 23, 27 and 28 of the Airport Expansion

Consultation Document).

21.3.34 Ealing Fields Residents Association commented that the Project will mean more

emissions on top of the existing situation.

21.3.35 Egham Residents’ Association suggested the ‘Triple Lock Guarantee’ is a work of

fiction and that any binding commitments can be undone by blaming the increases

on the M25 or the M4. They also raised concerns about Britain exiting the EU for

air quality regulations. A similar view was shared by Harrow U3A Sustainability

group who commented that “Brexit” may affect regulations.

21.3.36 The Residents association HVG CA highlighted the need for an accurate

measurement of air quality and emissions and compliance with EU standards.

21.3.37 The Richmond Heathrow Campaign stated that air pollution is damaging to health

and quality of life for over 100,000 people. They suggested that the release of

runway capacity should be linked to air quality tests based on predicted outcomes

and not be based on value limit compliance but also a reduction in pollution.

21.3.38 Stanwell’s Green Lungs and Teddington Action Group commented that

Heathrow’s commitment to deliver expansion while meeting all relevant legal air

quality obligations is profoundly misleading and no evidence has been given for

the assertion.


21.3.39 Eastcote Conservation Panel commented that one of the most contentious areas

in the plans for the Project was air quality. They stated that no evidence had been

provided to show that there will be measures in place to ensure that illegal levels

of pollution are reduced and that air quality regulations will be met and maintained.

21.3.40 Eastcote Residents’ Association said they find it hard to see how air quality will be

able to be kept within legal requirements with a new third runway. They stated that

if levels cannot be managed to fulfil this requirement the area will be left with an

unused runway and redundant supporting infrastructure.



21.3.41 SCR Residents for a fair consideration of Heathrow Expansion commented that

they assume Heathrow will comply with current legislation regarding air quality and

emissions thresholds.


General Comments

21.4.1 The Chiltern Society asked whether Heathrow would be interested in exploring

environmental offsetting in the Chilterns, possibly in the form of improved habitat

management. They considered that this could provide some habitat enhancement

in a nationally important landscape to compensate for any habitat or species loss

that may arise through the works to expand the airport.

21.4.2 West London Friends of The Earth considered Heathrow’s claim that expansion

can be delivered while meeting all relevant legal air quality obligations to be

misleading. The Local Authorities’ Aircraft Noise Council expressed a similar view

commenting that the Project will directly and indirectly cause unlawful levels of air

pollution which damages health.

21.4.3 The Herts and Middlesex Wildlife Trust commented that the proposals send the

wrong message both nationally and internationally as we should be striving to

reduce our carbon emissions.

21.4.4 Kingston Environment Forum suggested that the plans are inadequate and rely too

much on people using clean transport options with massive behaviour and

technological changes that are unlikely to happen soon enough.

21.4.5 The Mayor of London stated that effects on climate change must be minimised

and that Heathrow must contribute to the ambition for London to be a zero-carbon

city by 2050.


21.4.6 The Colne Valley Regional Park stated that Heathrow already contributes

significantly to air pollution in the area and post-expansion effects will be more

keenly felt, especially by those using the Colne Valley Regional Park. They

requested an evidence-based approach to looking at how noise and air quality,

including aerial pollutants, will be managed and suggested that opportunities to

extend the ULEZ to keep the effects of freight traffic under control should be

implemented.

21.4.7 Crossrail to Ebbsfleet commented that they are a vital part of reducing the

current volumes of traffic between Kent and Heathrow and the subsequent effects

on air pollution.

21.4.8 London Cycling Campaign stated that the Project must not lead to an increase in

climate-changing emissions or any increase in motor vehicle volumes (and



resulting pollution and emissions). They considered that enabling people to use

modes other than the private motor vehicle is vital.

21.4.9 Dominic Raab MP expressed concern that the increase in road traffic caused by a

growth in the number of passengers travelling to and from the airport risks a

negative impact on local air pollution. He also suggested that the Environment

Agency or another body should be mandated to monitor the full environmental

impact of the airport, not just from extra flights but from additional congestion.

21.4.10 Elmbridge Friends of the Earth expressed opposition to the Project and raised

concerns about a lack of clarity on how there will be no increase in road usage and

why there is no consideration of inflight emissions from aircraft.

21.4.11 The Liberal Democrats expressed concerns around air quality and commented

that they would like to see firmer commitments from Heathrow on its plans to

contribute to the cost of the Western Rail Link and the Heathrow Southern Railway

to achieve modal change.

21.4.12 The London Wildlife Trust stated that Heathrow must address the risk of

increasingly poor air quality but considered that discouraging individuals from

travelling by car is an inadequate response to address this. They stated that

Heathrow already contributes significantly to air pollution in the area and that

impact will be even greater post-expansion. They proposed that an evidence-

based approach to the management of air quality during construction be

undertaken and that opportunities to extend the Mayor of London’s ULEZ should

be investigated.

21.4.13 The Royal Parks expressed support for measures that improve air quality in and

around the airport but raised concern about the likely increase in pollution from

increased air and vehicle traffic on the main trunk roads. They also expressed

concern about the implications this could have on sensitive and protected

grassland habitats, specifically Richmond Park, Bushy Park Site of Special

Scientific Interest, Kensington Gardens, Primrose Hill, Regents Park and

Greenwich Park.


21.4.14 The Chartered Institute of Logistics and Transport raised concerns over who would

be held to account if air quality limits are breached. They proposed that a limit on

passenger numbers be applied until any breaches related to the airport cease.

21.4.15 The Church of England Diocese of London, Oxford and Southwark expressed a

similar view raising concerns with the commitments not to release capacity unless

compliance on air quality is assured. They indicated that Heathrow has been

working to address the air quality impacts for more than 15 years but the problem

remains. They highlighted that there is a much stronger focus on reducing

Nitrogen Dioxide, than on particulates.



21.4.16 Dominic Raab MP stated that there should be legally binding limits on air quality

and compliance should be independently monitored. He commented that a

concern of his constituents is that the Project should not lead to any deterioration

of air quality as a result of the additional flights or additional vehicles that may use

the roads. He also said the Civil Aviation Authority had provided assurances that

an increase in flights would have no direct impact on air quality in Elmbridge.

21.4.17 England’s Economic Heartland expressed support for the ‘Triple Lock Guarantee’

which they consider will ensure that new capacity at an expanded Heathrow will

only be released in compliance with air quality requirements.

21.4.18 Friends of the River Crane commented that air quality is similar to noise in respect

of its widespread impact on public open spaces and the relatively limited means

available to mitigate it. They suggested that green infrastructure has capacity to

absorb poor air quality and that the impact of air quality upon the value and

diversity of the open spaces within the Heathrow envelope should be addressed

as part of the overall project alongside the impact of air quality on people using

open spaces.

21.4.19 Lambeth/Herne Hill Green Party referred Heathrow to the London Assembly's

consultation on changes to the ULEZ. They identified that there are environmental

organisations with expertise to reduce or mitigate the potential local air quality

effects that may arise due to the Project.

21.4.20 London First commented that Heathrow should think holistically about how it can

unilaterally and bilaterally reduce emissions from all sources, tackling the greatest

sources of emissions first.

21.4.21 London Parks and Garden’s Trust welcomed the 'Triple Lock Guarantee’ but urged

greater consideration to be given to horticulture as a means of carbon

sequestration and other air pollutant capture.




Tables 21.1A and 21.1B present a summary of the main issues raised by prescribed consultees, local communities and

wider/other consultees in relation to Air Quality and Emissions.

Table 21.1A presents a summary of Heathrow’s responses to those issues which are directly related to the proposals on which

we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019), and how in preparing

those proposals we have had regard to the relevant Airport Expansion Consultation One feedback.

Table 21.1B provides a summary of the way in which we are seeking to consider the issues raised in relation to any other

aspects of the Project not included in the Airspace and Future Operations Consultation. These interim responses are provided

for information only, and so no further feedback is being sought on the basis that a full consultation feedback report will be

published as part of the Airport Expansion Consultation in June 2019.

Table 21.1A


PC MC WC

A review should take place of the

achievements made by other cities which

prevent aircraft flying over communities.

✓ Heathrow are working with a range of specialists in airspace and airport

design who are aware of projects and practices undertaken elsewhere.

The Airspace and Future Operations Consultation (January 2019) presents geographical areas within which flight paths could be positioned. The consultation seeks feedback on what local factors should be taken into




account when developing new flightpaths within these geographical defined areas known as design envelopes.

Table 21.1B


PC MC WC

The best approach is to not expand Heathrow

and address the current adverse impacts of

the airport on air quality.

✓ The Government has designated the Airports National Policy Statement (ANPS), which sets out the need for additional airport capacity in the south-east of England and confirms that the Government believes that this need is best met by a north-west runway at Heathrow Airport. The ANPS sets out specific requirements that Heathrow as the applicant for a new north-west runway will need to meet to gain development consent. “The Secretary of State will use the Airports NPS as the primary basis for making decisions on any development consent application for a new Northwest Runway at Heathrow Airport, which is the Government’s preferred scheme” (paragraph 1.15). The ANPS is informed by an Appraisal of Sustainability, which describes the analysis of reasonable alternatives to the preferred scheme. The Appraisal of Sustainability informs the development of the ANPS by assessing the potential economic, social and environmental impacts of options to increase airport capacity. The ANPS states at paragraph 1.29 that “the overall conclusions of the Appraisal of Sustainability show that (provided any scheme remains within the parameters and boundaries in this policy), whilst

The number of flights should be reduced in

order to manage air pollution.

✓





PC MC WC

there will be inevitable harm caused by a new Northwest Runway at Heathrow Airport in relation to some topics, the need for such a scheme, the obligation to mitigate such harm as far as possible, and the benefits that such a scheme will deliver, outweigh such harm. However, this is subject to the assessment of the effects of the preferred scheme, identification of suitable mitigation, and measures to secure and deliver the relevant mitigation.”

One of the most contentious areas in the

plans for expansion is air quality.

✓ Heathrow recognise that the potential air quality effects of the Heathrow

Expansion Project (the Project) are a concern to communities around

Heathrow and other interested stakeholders. We are committed to any

potential significant adverse air quality effects of the Project and will publish

the initial assessment findings within the Preliminary Environmental

Information Report (PEIR), as part of the Airport Expansion Consultation in

June 2019.

Heathrow should be looking at best practice

examples from around the world.

✓

Heathrow are working with a range of specialists in airspace and airport

design who are aware of projects and practices undertaken elsewhere.

To reduce emissions aircraft should fly

higher.

✓ The modernisation of UK airspace, which is being developed in parallel to

plans for the Project, provides opportunities for changing the ways in which

aircraft currently fly. Additionally, as newer technologies become available,

operating practices are also likely to change. As such, our environmental

assessments will consider the impacts of measures such as steeper descent

approaches and departures, which would result in aircraft flying higher for

longer as well as changes in aircraft flight paths.




PC MC WC

There is no attempt to bring NOx emissions at

altitude within scope.

✓ Heathrow submitted an Environmental Impact Assessment (EIA) Scoping

Report to the Planning Inspectorate (PINS) on 21st May 2018. We

subsequently received a Scoping Opinion from PINS, on behalf of the

Secretary of State, on 2nd July 2018. The Scoping Opinion sets out PINS

opinion on the scope, level of detail and information to be provided in the

Environmental Statement (ES). The Infrastructure Planning (EIA) Regulations

2017 (the EIA Regulations) require Heathrow to submit an ES which is in

based on the most recent scoping opinion adopted.

Air quality effects are assessed at a local level, based on potential changes in

pollutant concentrations at locations where people might be exposed, for

example at residential properties. It is for this reason that the air quality

assessment will not assess pollutant emissions from aircraft above the

landing and take-off cycle (3000ft). Due to the dispersion of these emissions

at height, they have a negligible effect on pollutant concentrations at ground

level. This approach is based on the International Civil Aviation Organization

(ICAO) air quality guidance.

Concerns why there is no consideration of

inflight emissions from aircraft.

✓ Heathrow submitted an EIA Scoping Report to the Planning Inspectorate

(PINS) on 21st May 2018. We subsequently received a Scoping Opinion from

PINS, on behalf of the Secretary of State, on 2nd July 2018. The Scoping

Opinion sets out PINS opinion on the scope, level of detail and information to

be provided in the ES. The EIA Regulations require Heathrow to submit an

ES which is in based on the most recent scoping opinion adopted.

Air quality effects are assessed at a local level, based on potential changes in

pollutant concentrations at locations where people might be exposed, for

example at residential properties. It is for this reason that the air quality

assessment will not assess pollutant emissions from aircraft above the

landing and take-off cycle (3000ft). Due to the dispersion of these emissions

at height, they have a negligible effect on pollutant concentrations at ground




PC MC WC

Concerns about the impacts of air pollution,

the effect on the environment and that the

proposals fail to consider pollution produced

by aircraft and the danger of breaching EU

limits.

✓ level. This approach is based on the ICAO air quality guidance.

Concern expressed that increased traffic and

aircraft movements will worsen air quality.

This is damaging to the health, quality of life

and wellbeing for people across the local area

and Greater London.

✓ ✓ Heathrow recognise that the potential impacts of the Project on local air

quality and how these could potentially affect public health is a concern to

local communities. Heathrow will undertake both a detailed air quality

assessment and an assessment of impacts on human health as a result of

the Project. These will be presented as part of the ES. A standalone Health

Impact Assessment report will also be appended to the ES submitted with the

Development Consent Order (DCO) application. This will include mitigation

proposals where potential significant effects are identified. Chapter 12 of the

EIA Scoping Report sets out the approach to the assessment of impacts on

human health.

Expansion will directly and indirectly cause

unlawful levels of air pollution which

damages health.

✓

Heathrow must work with stakeholders to

increase understanding of key matters such

as how it affects the health and quality of life

of local communities.

✓

Heathrow already contributes significantly to

air pollution in the area and the expansion will

exacerbate this. This will particularly affect

those using the Colne Valley Regional Park.

✓ Recreational routes, spaces and facilities within the Colne Valley Regional

Park are being considered as part of the recreation and amenity impact

assessment which will form part of the community chapter of the ES, to be

submitted with the DCO application. It will identify recreation and amenity

effects resulting from the construction and operation of the Project.

Information on the mitigation strategies to address any likely significant

effects will also be identified.




PC MC WC

Concern about the implications impacts on

air quality and increased emissions could

have on sensitive and protected grassland

habitats, specifically Richmond Park, Bushy

Park SSSI, Kensington Gardens, Primrose

Hill, Regents Park and Greenwich Park.

✓ The impacts of potential changes in air quality on biodiversity designations

(including European site designations and Sites of Special Scientific Interest

(SSSIs)) will be assessed in detail as part of the EIA. Early findings and initial

information on any proposed mitigation measures will be reported in the PEIR

to be published as part of the Airport Expansion Consultation in June 2019.

The consultation documents did not include

an assessment of potential air quality impacts

on European sites, a detailed assessment

should be completed prior to submission of

the DCO application.

✓

Concerns about air quality impacts on Elbow

Meadow properties due to the proximity of the

Area 2 taxiways.

✓ The likely air quality effects on receptors in Elbow Meadow and other

communities will be assessed during the EIA, with initial findings reported in

the PEIR to be published as part of the Airport Expansion Consultation in

June 2019.

The positioning of aircraft taxiways and other elements of infrastructure will

seek to reduce air quality impacts by facilitating efficient aircraft movements

on the ground and maximising separation between emission sources and

receptors as far as reasonably practicable. A detailed evaluation considering

a range of criterion (as detailed in the Scheme Development Report) is being

undertaken to identify the preferred location and options for new taxiways,

taking into account the consultation responses. The findings of this

evaluation will be presented in the Updated Scheme Development Report

that will be published to accompany the Airport Expansion Consultation in

June 2019.




PC MC WC

The release of runway capacity should be

linked to air quality tests. This should be

based on a reduction in pollution and not on

value limit compliance.

✓ The ANPS sets out the tests that Heathrow must meet in order to be granted

a DCO for the Project. This includes a requirement to demonstrate that the

Project would be compliant with legal obligations that provide for the

protection of human health and the environment.

Heathrow has also made a commitment that in addition to continuing to play

its part in improving air quality and ensuring further measures are ready to be

introduced if required to reduce traffic. Extra capacity at an expanded

Heathrow will only be released when it is clear that the airport’s contribution

will not delay compliance with EU air quality obligations.

Concerns about the lack of detail and

information.

✓ The information provided in Airport Expansion Consultation One reflected the

fact that the Project was at an early design stage. Further information

regarding air quality and emissions, including early findings from our EIA

work assessing potential effects upon local communities and developing

proposed mitigation measures, will be provided within the PEIR. This will be


It was not possible to form a view on many of

the proposals without more information on

the impact on air quality.

✓

Lack of information of in the consultation

documents regarding pollutions sources,

health impacts and mitigation measures

including those detailed in the draft ANPS.

✓




PC MC WC

Discounting the Family C Runway options

based on air quality impacts does not appear

to sit properly within the unworkable

evaluation prescribed to it.

✓ The Scheme Development Report published at Airport Expansion

Consultation One presented the findings of the evaluation process to date.

The Family C options were considered likely to result in adverse ground

noise, air quality and amenity impacts at a larger number of properties than

the alternatives, given proximity of the runway end to Harlington. The Family

C options would also result in additional property loss and community

displacement in Sipson when compared to Family A and as a result were

discounted.

Concern that the proposed measures lack

credibility and are unrealistic, inadequate or

insufficient.

✓

The information provided in Airport Expansion Consultation One reflected the

fact that the Project was at an early design stage. We remain confident in the

ability of our proposals to deliver sustainable growth and demonstrate that

construction and operation of the Project will not affect the UK’s ability to

comply with legal obligations. Further information regarding the potential

effects of emissions associated with the Project, including early findings from

the EIA, will be contained within the PEIR which will be published as part of


Heathrow has not demonstrated how it can

effectively deliver its proposed scheme,

including its 2030 public transport modal

share target, without adversely affecting air

quality.

✓ The air quality assessments previously undertaken by the Airports

Commission, Heathrow and Government have consistently demonstrated that

the Project can be delivered in compliance with legal air quality obligations

and without causing exceedances of the National Air Quality Objectives.

The ANPS puts in place a planning framework for a new runway in the South




PC MC WC

No evidence had been provided to show that

there will be measures in place to ensure that

illegal levels of pollution are reduced and that

air quality regulations will be met and

maintained.

✓ of England. In doing so, it defines requirements for Heathrow’s environmental

assessment. In the context of air quality, this includes demonstrating that

construction and operation of the Northwest Runway will not affect the UK’s

ability to comply with legal obligations that provide for the protection of human

health and the environment.

The ES submitted alongside the DCO will report the likely significant effects

of the Project. This will include consideration of EU Limit Values and Local Air

Quality Objectives for NO2 and particulates. Heathrow will therefore provide

further evidence that the Project can be delivered in compliance with legal air

quality obligations. In advance of the ES being submitted, the initial findings

from our assessments will be provided within the PEIR, which forms part of


Concerns about confidence levels in

Heathrow’s claims that air pollution can be

adequately addressed.

✓

Concern that if expansion goes ahead there

will be a huge increase in emissions from

aircraft and vehicle movements.

✓ ✓

The expansion of Heathrow should not lead to

any deterioration of air quality as a result of

the extra flights or the extra vehicles that may

use the roads.

✓

The Secretary of State will need to be

satisfied that the scheme would be compliant

with legal requirements on air quality impacts

in the wider area.

✓

Opposition to an expanded Heathrow as

increases in passengers, freight and staff is

likely to make air quality over legal limits in

the local area, Greater London and the south-

east.

✓




PC MC WC

Concern that air quality assessments show

that an expanded Heathrow would contribute

to breaching Nitrogen Dioxide air quality

limits.

✓

Heathrow’s commitment to deliver expansion

while meeting all relevant legal air quality

obligations is profoundly misleading and no

evidence has been given for the assertion.

✓ ✓ ✓

Heathrow will have to comply with current

legislation regarding air quality and

emissions thresholds.

✓

The latest government air quality

assessments show that expansion will make

the London Zone non-compliant in 2026/28.

✓

Heathrow already contributes significantly to

air pollution in the area and that impact will

be even greater post-expansion.

✓ We have been working to address emissions from Heathrow for more than 15

years and we, alongside our partners, have a strong track-record of reducing

emissions from airport operations. For example, our 2013 Emissions

Inventory showed that the implementation of the Air Quality Action Plan led to

a 430 tonne (16%) reduction in total emissions of NOX from ground-based

sources since the last full inventory for the period 2008/9. This action has

contributed to concentrations of NO2 at Heathrow falling by over 20% in the

past 20 years.

We have carried out continuous air quality monitoring at locations on and

around Heathrow since 1993, in addition to the monitoring conducted by the

local authorities. This network of monitoring illustrates that within 2km of

Heathrow has been working to address the air

quality impacts for more than 15 years but the

problem remains.

✓ ✓

It has been promised many times previously

and air pollution remains at an unacceptable

and in places dangerous level.

✓




PC MC WC

Heathrow already breaches legal air pollution

limits and does not have a tenable plan to

meet legal air pollution limits even without a

third runway.

✓ Heathrow, only two air quality monitoring sites have historically recorded

annual mean NO2 concentrations exceeding the Air Quality Objectives (AQO)

– these are located next to the M4 motorway. Real time air quality monitoring

data and details of monitoring sites are available from Heathrow Airwatch

(http://www.heathrowairwatch.org.uk/latest).

We will continue to work in partnership with local authorities and Government

to play our part in improving local air quality.

Concern that more flights will mean more

emissions, air quality levels are already poor

and breach EU limits.

✓

Heathrow should focus on low emissions. ✓ We agree that Heathrow should focus on low emissions and are developing

measures that will encourage the uptake of low emission technologies, be

that in relation to aircraft operations and ground support equipment on the

airfield, or trips made to and from the airport by passengers and colleagues.

Further details of these measures will be provided in the PEIR, which forms

part of the Airport Expansion Consultation in June 2019.




PC MC WC

Heathrow are misleading consultees by

suggesting that ground based sources are

the main contributor to harmful emissions

when planes emit large amounts of NOx and

have vastly higher emissions than suggested.

✓ Our dispersion modelling studies enable us to specifically assess the impact

of aircraft emissions and other sources on pollutant concentrations at relevant

locations (i.e. those where people might be exposed). Our work, and other

work from around the world, shows that although aircraft are a significant

source of total NOX emissions at Heathrow, because emissions from aircraft

in flight are elevated, the effect at ground-level is limited. Road traffic-related

NOx emissions are the most important source in terms of local air quality. It is

customary for studies on air quality around airports to include the whole

aircraft landing and take-off (LTO) cycle, including operations on the ground

and in the air up to 3,000 feet (~1,000 metres (m)) above ground level.

However, it is generally understood that emissions from aircraft become

negligible, in terms of their effect on ground-level air quality, once aircraft are

more than approximately 100-200m above the ground on departure, and

when greater than approximately 50-100m on arrival. Aircraft are much

higher than this when they are on the flight path, therefore, the effect of

emissions from these aircraft in the sky on ground level pollutant

concentrations at receptors beyond the airport boundary is negligible.

Concerns that if levels cannot be managed to

stay within legal requirements the area will be

left with an unused runway and redundant

supporting infrastructure.

✓ We stand by our ‘triple lock’ commitment and specifically the guarantee that

new capacity at an expanded airport will only be released when it is clear that

the airport’s direct contribution to air quality will not delay or cause non-

compliance with the UK’s legal air quality obligations. It has repeatedly been

demonstrated through previous assessment undertaken by the Airports

Commission, Heathrow and Government that the Project can be delivered

without delaying compliance. We will provide further evidence through the

EIA process, the initial findings of which will be reported in the PEIR which

forms part of the Airport Expansion Consultation in June 2019.




PC MC WC

Concern that building more car parks, hotels

and other sites around the airport

contradicted Heathrow’s intention of dealing

properly with air quality issues.

✓ An expanded Heathrow will need to be supported by appropriate Airport

Related Development (ARD), which includes hotel development where

demand is generated by the growth in passenger numbers and the

displacement of existing hotels to facilitate construction of the Project.

Proposals for ARD and airport supporting facilities such as car parks are not

considered to conflict with Heathrow’s goal of improving local air quality. The

Project provides an opportunity to consolidate existing facilities, which over

time have grown organically around Heathrow, and facilitate more holistic and

efficient land use. This includes, for example, locating hotel facilities near

public transport links, or consolidating car parking capacity close to the

motorway network to reduce traffic movements otherwise circulating on the

local road network. Potential air quality impacts have been considered

throughout the design development process and will continue to inform our

choices as we finalise a preferred masterplan. This will be published in June

2019 during our Airport Expansion Consultation.

Hopes for a much stronger focus on reducing

NO2, than on particulates.

✓ Heathrow’s focus is on managing all relevant emissions associated with the

airport and the Project, where they have potential to result in adverse

environmental effects, including NO2, particulates and carbon. Emissions of

these pollutants and associated effects will be assessed as part of the EIA,

the initial findings of which will be reported within the PEIR as part of the





PC MC WC

The expansion of Heathrow Airport must not

lead to an increase in climate-changing

emissions or any increase in motor vehicle

volumes (and resulting pollution and

emissions).

✓ The ANPS sets out the planning framework for a new runway in the South of

England. In doing so, it defines requirements for Heathrow’s environmental

assessment. In the context of carbon, this includes demonstrating that the

increase in carbon emissions resulting from the project would not have a

material impact on the ability of Government to meet its carbon reduction

targets, including carbon budgets.

The ANPS does not require Heathrow to demonstrate that there will be no

increase in motor vehicle volumes due to the Project. It does however require

that the DCO application include details of how Heathrow will increase the

proportion of journeys made to the airport by public transport, cycling and

walking to achieve a public transport mode share of at least 50% by 2030 and

at least 55% by 2040 for passengers. The application will also detail how a

25% and 50% reduction in all colleague car trips will be achieved by 2030

and 2040 respectively.

Heathrow will also continue to strive to meet its pledge to have landside

airport-related traffic no greater than today.

Heathrow should commit to support

progressive reductions in air pollutants in

areas that do not meet Air Quality Objective

thresholds.

✓ We have carried out continuous air quality monitoring at locations on and

around Heathrow since 1993, in addition to the monitoring conducted by the

local authorities. This network of monitoring illustrates that within 2km of

Heathrow, only two air quality monitoring sites have historically recorded

annual mean NO2 concentrations exceeding the AQO – these are located




PC MC WC

Heathrow’s proposals should not increase

emissions from the current levels, suggesting

that tapered reduction targets should be set.

✓ next to the M4 motorway. Real time air quality monitoring data and details of

monitoring sites are available from Heathrow Airwatch

(http://www.heathrowairwatch.org.uk/latest).

As older vehicles with higher emissions are replaced by newer ones that

meet progressively tighter EU emission standards, air quality is predicted to

improve, such that those locations within London and the south east which

currently exceed the EU Limit Value/AQO are projected to be compliant by

the mid to late 2020s8. To accelerate this process, Heathrow is exploring the

potential for strategically managed access charges, low emission zones, and

parking charges at Heathrow to further encourage the use of low emissions

vehicles, reduce unnecessary highway travel, and generate revenue to invest

in public transport.

Despite the application of appropriate mitigation measures, the Project could

potentially result in increases in pollutant concentrations in distinct locations,

due to, for example, redistribution of traffic or amendments to the road

network. Heathrow is committed to managing the potential air quality impacts

of the Project and playing our part in meeting the Government’s national

AQOs and achieving compliance with European air quality limits. The initial

findings of the EIA, including air quality projections and proposed mitigation

measures, will be reported within the PEIR which forms part of the Airport


8 Air quality plan for nitrogen dioxide (NO2) in UK (2017), Department for Environment, Food and Rural Affairs and Department for Transport




PC MC WC

Details required on how Heathrow would

contribute to the Air Quality Positive policy.

✓ Policy SI1 of the Draft New London Plan states that “the development of

large-scale redevelopment areas, such as Opportunity Areas and those

subject to an EIA should propose methods of achieving an Air Quality

Positive approach through the new development”. In line with this draft policy

and its existing commitments, Heathrow will implement measures to actively

reduce air pollution, which may include provision of low or zero-emission

heating and energy, improvements to public transport, walking and cycling

infrastructure, and designing out features that prevent effective dispersion of

pollutants.

Concerns with the commitments not to

release capacity unless compliance on air

quality is assured.

✓ As required by the ANPS, Heathrow must demonstrate (via the ES), that with

mitigation, the scheme would be compliant with legal obligations that provide

for the protection of human health and the environment.

Heathrow should think holistically about how

it can unilaterally and bilaterally reduce

emissions from all sources, tackling the

greatest sources of emissions first.

✓ Heathrow agree that a holistic approach is appropriate when developing

measures to manage the potential emissions associated with the airport, and

that these measures will require both direct action by Heathrow and

partnership with the relevant stakeholders. Further details on the measures

proposed to manage the effects of the Project will be contained within the

PEIR, which forms part of the Airport Expansion Consultation in June 2019.




PC MC WC

Requested the health impacts and air quality

assessment methodologies and reports are

provided at the earliest opportunity.

✓ Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018,

which described the proposed assessment methodologies for all aspects to

be considered during the EIA, including health and air quality. We

subsequently received a Scoping Opinion from PINS, on behalf of the

Secretary of State, on 2nd July 2018. The Scoping Opinion sets out PINS

opinion on the scope, level of detail and information to be provided in the ES.

Further information on the assessment methodologies will also be published

within the PEIR which forms part of the Airport Expansion Consultation in

June 2019.

The ‘Triple Lock’ guarantee is a work of

fiction, any binding commitments can be

undone by blaming the increases on the M25

or the M4.

✓ We remain confident in the ability of our proposals to expand Heathrow to

deliver sustainable growth and with respect to air quality, we stand by our

‘triple lock’ guarantee. The three elements of the triple lock are:

1. meeting our existing commitment to improving air quality by not increasing the amount of landside airport-related vehicle traffic (including freight and cargo traffic) on the road by supporting improved surface access and by encouraging and incentivising the use of new technology and cleaner vehicles;

2. ensuring further measures are ready to be introduced if required to reduce traffic: Heathrow has identified a number of options available to improve air quality that can be implemented if needed as part of our expansion plans to reduce road journeys (e.g. the introduction of a road user charge or emission-based access charge); and;

3. binding our commitment by guaranteeing that new capacity at an expanded airport will only be released when it is clear that the airport’s direct contribution to air quality will not delay or cause non-

The ‘triple lock guarantee’ must be honoured

by Heathrow and intertwined into the DCO

requirements.

✓ ✓

Confirmation as to whether the ‘Triple Lock’

guarantee includes freight and cargo traffic or

is limited to light duty vehicles is needed.

✓




PC MC WC

The triple lock guarantee on air quality made

by Heathrow is not consistent with the draft

ANPS and cannot be regarded as a long-term

commitment.

✓ compliance with the UK’s legal air quality obligations.

This commitment is consistent with the ANPS, which requires Heathrow to

demonstrate that construction and operation of the Project will not affect the

UK’s ability to comply with legal obligations that provide for the protection of

human health and the environment.

Concerns over who would be held to account

if air quality limits are breached.

✓ The EIA Regulations require decision-makers of DCO applications (i.e. in the

case of transport DCOs, the Secretary of State for Transport) to consider

whether it is appropriate to impose monitoring measures of any likely

significant adverse effects identified through the EIA process. This includes

consideration of potential remedial action.

This provides additional assurance that consideration of the effects of

expansion and appropriate mitigation will continue into the construction and

operational phases of the project, informed by an appropriate monitoring

regime.

We also continue to think that there is the potential for an independent

regulator to provide scrutiny and further confidence in our air quality plans.

We are ready to work with government should they move to create such a

role.

Concern about how plans will be impacted by

Britain exiting the EU for air quality

regulations.

✓ The Government has confirmed that it intends to uphold its obligations under

international environmental treaties. Regarding air quality regulations, the

Government has stated that the Ambient Air Quality Directive (including its

limit values and target values) was transposed into law in England through

the Air Quality Standards Regulation 2010, and that it has no plans to change

the limit values and target values in the regulations.




PC MC WC

Legal challenges will emerge following the

adoption of the NPS which are likely to

address air quality.

✓ Noted.

If Heathrow is in breach of air quality

requirements it weakens the case for the use

of compulsory purchase powers.

✓ The assessments previously undertaken by the Airports Commission,

Heathrow and Government have consistently demonstrated that the Project

can be delivered in compliance with legal air quality obligations and without

causing exceedances of the National Air Quality Objectives. Assessment of

compliance with EU limit values will be a key component of the assessment.

We remain confident in the ability of our proposals to expand Heathrow to

deliver sustainable growth and with respect to air quality, we stand by our

‘triple lock’ guarantee to deliver the Project in accordance with the UK’s legal

air quality obligations.

Concerns that the government’s Air Quality

Plan does not account for the expansion of

Heathrow.

✓ The Government referenced Heathrow’s plan for sustainable growth within

the Greater London Urban Area (UK001) zone plan published in support of

the Air Quality Plan for Nitrogen Dioxide (the AQ Plan). Based on the

Pollution Climate Mapping projections supporting the AQ Plan, the

Government also updated previous air quality assessments completed by the

Airports Commission. This work concluded that based on a conservative

assessment, with the implementation of actions as set out in the AQ Plan, the

Project would not impact on modelled compliance with limit values in any

potential opening year.

The focus for Heathrow and the Airline

Community should be on collectively working

towards addressing airport-related emissions.

✓ ✓ We have been working to address emissions from the airport for more than

15 years and we, alongside our partners, have a strong track-record of

reducing emissions from airport operations. We will continue to work in




PC MC WC

The airline community has an important role

and any air quality and emissions measures

must be developed in full consultation and

agreement with them.

✓ partnership with the aviation community to manage emissions associated

with the airport operation and the aviation industry. Further details of the

measures proposed to manage the emissions resulting from the Project will

be provided within the Preliminary Environmental Information Report,

published in June 2019 as part of our Airport Expansion Consultation.

The Airline Community will support cost-

effective and operationally viable initiatives to

help reduce emissions including supporting a

broad choice of sustainable transport modes

for passengers, cargo and employees.

✓

Concern about Air quality impacts of

construction as well as other scheme

elements such as a realigned M25.

✓

Heathrow will employ best practice management and delivery systems to

manage the effects of construction. Detailed measures will be developed to

avoid, reduce and mitigate the likely impacts of construction on communities

and the environment as the DCO application becomes more developed. As

part of the EIA process, a draft Code of Construction Practice will be

prepared, which will outline how construction activities will be managed. This

document will set out the requirements for mitigation and the monitoring of

potential environmental impacts throughout the construction period. Heathrow

will be consulting on the draft Code of Construction Practice as part of the

PEIR which will be published as part of the Airport Expansion Consultation in

June 2019.

Concern about the impacts on air quality and

the health of communities during the

construction of the expanded airport.

✓

Consideration should be given to how

unauthorised car park and caravan sites for

construction workers will be managed as

these could lead to adverse air quality

impacts on residential areas.

✓

Concern about the additional vehicular

movements associated with construction

activities.

✓




PC MC WC

Electric engines to aircraft which could be a

compulsory source of power when landing

should be introduced.

✓ Although Heathrow supports developments and innovations in this area, this

comment refers more directly to aircraft manufacturers and airlines.

Heathrow engages with airlines and other stakeholders to operate in an

environmentally efficient way and will continue to support solutions to improve

ways of working and operating whilst maintaining safety and efficiency.

Existing air quality measures have not

worked and that further erosion of land and

green space will worsen air pollution in the

area.

✓

As part of Airport Expansion Consultation One (January 2018) Heathrow

presented Our Design Approach to the Natural Environment, which included

an approach to multifunctional green infrastructure to achieve as much

environmental and community benefit as possible. The PEIR that Heathrow

will consult on as part of the Airport Expansion Consultation in June 2019,

includes further details in regard to mitigation proposals. This includes

landscaping and air quality measures.

Timely adoption of sustainable aircraft and

higher landing fees for aircrafts with higher

emissions are critical.

✓

Through variable landing charges, Heathrow charges the highest prices to

the noisiest and highest emitting aircrafts in order to encourage use of the

greenest aircrafts at the airport. Heathrow will continue this approach and is

exploring how this policy may evolve in the future to manage the emissions

directly associated with aviation.

Through its Committee on Aviation Environmental Protection (CAEP), the

International Civil Aviation Organization (ICAO) sets new emission standards

for aircraft engines – including for NOx. Engine models which were certified

on or after 1 January 2014 must meet CAEP8, the latest standard for NOx.

The proportion of flights made by newer, cleaner CAEP8 aircraft at Heathrow

increased from 20.8% in 2016 to 27.2% at the end of Q2 2018. The trend is

expected to continue as airlines proceed in replacing their older, higher

emission aircraft and Heathrow’s NOx emission landing charges and

Use and/or incentivise cleaner aircraft,

incentivise low carbon flights and banning

older, more polluting planes.

✓

Aircraft emissions should be reduced and

there should be penalties for older or more

polluting aircraft.

✓




PC MC WC

Suggestions that the fee airlines pay to

operate at the airport should not remain close

to current levels but should reflect the cost in

harm to the environment.

✓ engagement encourages the use of best-in-class aircraft.

Concern that Heathrow will not be able to

influence existing behaviours and as a result

expansion will simply lead to more of the

current impacts.

✓ Heathrow has a good record when it comes to managing emissions. For

example, through the implementation of an Air Quality Action Plan, we cut

total NOx emissions from ground-based sources by 16% between 2008 -

2013. This has contributed to observed concentrations of NO2 at the airport

falling by over 20% in the last 20 years. Over this same period, Heathrow’s

passenger numbers have risen by almost 80% but airport related road traffic

has remained broadly static. This demonstrates that significant growth in

passenger numbers is possible whilst managing vehicle trips to and from the

airport.

The plans are inadequate and rely too much

on people using clean transport options with

massive behaviour and technological

changes that are unlikely to happen soon

enough.

✓

Plans to reduce emissions are inadequate

and fail on all grounds according to the

recent report produced by the New

Economics Foundation which uses DfT

modelling.

✓

Mitigation should be introduced as early as

possible, before the runway is completed.

✓ As part of the design development and EIA processes, Heathrow is

developing a suite of mitigation measures designed to manage the potential

effects of the Project during both construction and operation. A number of

measures may be implemented in advance of the runway being completed.

As part of the Airport Expansion Consultation in June 2019, Heathrow will

publish the initial findings of the EIA (including a description of proposed

mitigation measures) within the PEIR.




PC MC WC

Suggested the measures proposed to manage

emissions would only increase prices.

✓ The Project is being carefully prepared to balance design priorities, including

reducing potential emissions, and also achieve a scheme of optimal viability.

There is an overarching emphasis upon affordability to ensure that the airport

is expanded with passenger charges staying as close as possible to 2016

levels.

Concern that the measures would negatively

impact on businesses and the economy.

✓

Details should be provided on how increased

emissions will be effectively mitigated.

✓

The information provided in Airport Expansion Consultation One (January

2018) reflected the fact that the Project was at an early design stage. We will

provide further detail on mitigation measures aimed at managing emissions

and effects on air quality within the PEIR, published part of our Airport

Expansion Consultation in June 2019. The purpose of the Airport Expansion

Consultation One was to provide an early opportunity to provide feedback on

options and components to inform the preferred masterplan that will be

presented as part of the Airport Expansion Consultation in June 2019.

The measures proposed to combat the issue

of emissions were very vague

✓

The approach set out in the consultation

documentation is inadequate and lacks

information on mitigation measures.

✓




PC MC WC

Concern that the emissions management

measures proposed will only offset or

mitigate in the short term.

✓ Heathrow have considered potential emissions into the longer term. For

example, Heathrow are developing measures to ensure that the carbon

associated with the construction and operation of the airport itself is managed

appropriately, working towards its goal of operating zero carbon airport

infrastructure by 2050. The Air Quality and Carbon and other greenhouse

gases chapters of the PEIR, to be published as part of the Airport Expansion

Consultation in June 2019 will provide further details on the approach to

mitigating emissions.

Concerned that measures to manage

emissions do not extend beyond a 2km radius

of the airport.

✓ The assessment will consider air quality beyond the immediate area around

Heathrow. The spatial extent of the detailed study area will be based on

where potential changes in pollutant concentrations could result in significant

environmental effects, through for example changes in traffic flows on the

public highway. This will be determined in accordance with the EIA Scoping

Opinion published by the Planning Inspectorate on the 2nd July 2018,

through use of appropriate screening criteria.

The measures proposed within our Surface Access Strategy will be effective

beyond the immediate area surrounding Heathrow. They are expressly

designed to manage the number of potential vehicle trips to and from the

airport, which originate within a wide catchment area.

Mitigation measures to improve air quality in

pollution hotspots beyond the immediate area

of the scheme should be implemented.

✓✓




PC MC WC

Invites should be offered to participate in the

Sustainable Freight Group.

✓ In October 2017 Heathrow published its Blueprint for Sustainable Freight.

Part of the commitments set out in this initiative was to establish a

partnership with leading cargo and freight companies, the Freight Transport

Association and the British International Freight Association (BIFA). The

Group meets twice a year to exchange experience and best practice, support

the development of initiatives to reduce emissions from freight activity at the

airport and feed into local and national freight policy development. It also

supports the roll out of freight accreditation schemes with emissions reduction

targets, trials low and zero emission vehicle technologies and identifies

measures to consolidate freight movements to and from the airport.

Heathrow’s assessment must include the

cumulative impact on existing exceedances

and likelihood of new/additional exceedances

of the air quality objective limits.

✓ The potential cumulative effects of the Project and other committed

developments will be considered as part of the EIA process, the initial

findings of which will be published within the PEIR as part of the Airport


The highways and air quality assessments

must consider the cumulative impacts of

expansion with existing consented major

schemes, likely schemes from the Local

Plans and all displaced uses (whether in the

DCO application or not).

✓




PC MC WC

The effect of airborne aircraft emissions on

local pollutant concentrations should be

demonstrated by mapping airport-related

contributions to annual mean concentrations

of pollutants, with a plan showing just the

airborne aircraft emissions contribution.

✓ The air quality dispersion model used to assess the potential significant

environmental effects of the Project will include aircraft within the Landing

and Take-off Cycle (LTO), up to approximately 3000ft. Therefore, the

predicted effects of the Project on local annual mean pollutant concentrations

will include consideration of the influence of airborne aircraft. This is

consistent with the Scoping Report submitted to the Planning Inspectorate

and subsequent Scoping Opinion provided by PINS on 2nd July 2018.

Heathrow's reluctance to fund on-site air

quality monitoring is disappointing. Accurate

and continuous monitoring is necessary to

establish a baseline at specific sites and

ensure compliance with EU standards.

✓ Heathrow has carried out continuous monitoring at locations on and around

the airport since 1993, in addition to the monitoring conducted by the local

authorities. This data can be accessed via the Heathrow Airwatch website,

funded by a joint working partnership consisting of Heathrow Airport Limited,

London Boroughs of Hillingdon and Hounslow, Slough and Spelthorne

Borough Councils and British Airways.

Targets or measures be proposed to minimise

air quality impacts arising from the

construction workforce.

✓ A draft Code of Construction Practice will be produced, setting out a series of

control measures and standards to be implemented throughout the

construction of the Project. This document will ensure effective planning,

management and control of construction activities, to mitigate potential

impacts upon people and the environment. It will include reference to

Construction Workforce Travel Plan (CWTP) to support and encourage use of

sustainable, active modes of travel and reduce impacts of workforce travel

upon transport networks and air quality. A draft of the Code of Construction

Practice will be published as part of the PEIR in June 2019.




PC MC WC

The area of air quality monitoring must

include locations in and around the Ivers,

which will be subject to cumulative increases

of traffic in locations that have high numbers

of vulnerable users (e.g. schools and

recreational facilities).

✓ It is acknowledged that an Air Quality Management Area (AQMA) has

recently been declared for the Parish of The Ivers and this will be considered

within the EIA. Air quality monitoring is currently undertaken by the local

authority, whose responsibility it is monitor pollutant concentrations under the

Local Air Quality Management (LAQM) regime. This monitoring will be used

to inform the baseline assessments undertaken as part of the EIA.

Additionally, the EIA Regulations require decision-makers (i.e. in the case of

transport DCOs, the Secretary of State for Transport) to consider whether it is

appropriate to impose monitoring measures of any significant adverse effects

of the Project, as identified through the EIA process. This includes

consideration of potential remedial action. This provides additional assurance

that consideration of the effects of expansion and appropriate mitigation will

continue into the construction and operational phases of the Project.

Welcome the use of independent Air Quality

experts and requested clarity on how the

group will function, the level of transparency

and how outputs from the assessment will be

shared with stakeholders.

✓ Heathrow is working with a range of air quality experts, including advisory

groups which are providing additional scrutiny of the approach to air quality

assessment and development of appropriate mitigation measures. Outputs

will be reflected in the EIA process and the PEIR published as part of the


It is unclear how the assessments for

evaluation and discontinuation of options had

taken in to consideration issues such as air

quality, public transport considerations and

the influence of other scheme elements.

✓ The scheme development process that Heathrow has applied is explained

within the Scheme Development Report. The document explains how

Heathrow has applied a range of criteria to evaluate the respective

performance of different design options. This includes criteria which triggers

consideration of the relative risk of adverse air quality impacts as a result of

the Project, for example this may differ based on proximity of receptors to

emission sources or based on the likely traffic and transport effects of a

particular design option.




PC MC WC

Joint monitoring and review processes are

vital to the success of achieving a reduction

in emissions and Heathrow should provide

funding for this.

✓ Heathrow is committed to working alongside key stakeholders (such as the

Heathrow Strategic Planning Group, HSPG) and local authority partners to

achieve air quality and emissions objectives. The Heathrow Air Quality

Working Group (a partnership between ourselves, our neighbouring local

authorities – London Borough of Hillingdon, London Borough of Hounslow,

Slough Borough Council and Spelthorne Borough Council, the GLA, TfL and

the Environment Agency) works collaboratively to monitor, share and publish

data from 22 air quality monitoring stations within approximately 20

kilometres (km) of Heathrow. The data collected by us, our surrounding local

authorities and Defra is publicly available and can be found on the Heathrow

Airwatch website.

The air quality assessment must take account

of air quality monitoring data from the local

authority networks across the Heathrow area

not just Heathrow’s continuous monitoring

stations.

✓

Air quality demands a joint approach by

Heathrow and Local Authorities, including

monitoring and compliance.

✓

The scope of air quality assessments will

need to be agreed with HSPG.

✓ Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018. PINS

consulted on the Scoping Report, taking into account responses received

from consultation bodies (including HSPG) before providing a Scoping

Opinion, on behalf of the Secretary of State, on 2nd July 2018. The Scoping

Opinion sets out PINS opinion on the scope, level of detail and information to

be provided in the Project ES. The EIA Regulations require Heathrow to

submit an ES which is in based on the most recent scoping opinion adopted.

No baseline measurements had been

undertaken in the area following existing air

quality breaches.

✓ The PEIR, which will be published in June 2019 as part of the Airport

Expansion Consultation, will set out baseline (current) air quality within the

study area, as will the final ES to be submitted with the DCO application for




PC MC WC

Heathrow should publish the results of their

air quality assessments as well as the

embodied carbon and emissions impact.

✓ the Project. The assessment will draw on the extensive network of automatic

and non-automatic monitoring sites around Heathrow. Much of this data can

be accessed via the Heathrow Airwatch website, funded by a joint working

partnership consisting of Heathrow Airport Limited, London Boroughs of

Hillingdon and Hounslow, Slough and Spelthorne Borough Councils and

British Airways.

Real-time public display of air quality data

against targets with the encouragement of

less polluting commercial vehicles with a

rebate system.

✓

Air pollutants should be monitored and

assessed on the surrounding local and

strategic road network.

✓ The spatial extent of the detailed study area for the air quality assessment will

be based on where potential changes in traffic flows could result in changes

in pollutant concentrations, be that on the Strategic Road Network (SRN) or

local roads. This will be determined in accordance with the EIA Scoping

Opinion published by the Planning Inspectorate in July 2018, through use of

appropriate screening criteria. The air quality assessment in the

environmental statement must model all main

roads across the wider area and local roads

in the immediate vicinity of the scheme.

✓

Discouraging individuals from travelling by

car is an inadequate response to air quality

concerns.

✓ Discouraging individuals from travelling by car is just one of Heathrow’s

priorities. Our Surface Access Strategy will set out a suite of measures

expressly designed to manage the effects associated with traffic, including

making public transport more accessible and putting Heathrow at the heart of

an improved rail network. Beyond managing the number of vehicles travelling

to and from the airport, we are also developing measures to encourage use

of low emission vehicles (both on the public road network and on the airfield),

uptake of the latest in aircraft technology and adoption of increasingly

sustainable operating practices.




PC MC WC

Agreement with the conclusion that NOx

emissions are a consequence of urban

development and non-airport traffic but

suggested that punitive emission charges

should not be introduced unless affordable

and sustainable alternative means to access

the airport are implemented.

✓ ✓ As older vehicles with higher emissions are replaced by newer ones that

meet progressively tighter EU emission standards, air quality is predicted to

improve. To accelerate this process, Heathrow is exploring the potential for

strategically managed access charges, low emission zones, and parking

charges at Heathrow to further encourage the use of low emissions vehicles,

reduce unnecessary highway travel, and generate revenue to invest in public

transport.

A draft Charging Strategy will be published as part of the Surface Access

Strategy at the Airport Expansion Consultation in June 2019. High polluting vehicles should be restricted

whilst cleaner, less polluting vehicles should

be incentivised e.g. by paying less for parking

and road charges and being given better

access to the Terminals.

✓

Concern that measures to manage emissions

would have negative consequences on traffic

congestion.

✓ The main source of pollution outside of the airport boundary is traffic. As

such, the effective management of potential air quality effects associated with

the expansion of Heathrow is inherently linked to the effective management

of potential traffic and transport impacts, including congestion. Given that the

low speeds and stop start driving behaviour associated with congestion result

in greater emissions than driving at a more constant speed, measures to

manage congestion and measures to manage emissions are typically

considered complementary.




PC MC WC

Proposals are based on old technology and

should include measures that ensure all

airport related vehicles are electric

✓

In accordance with the ANPS, our mitigation proposals for reducing impacts

on air quality will include encouraging use of zero- or low-emission hybrid or

electric vehicles (ultra-low emission vehicles), and providing adequate

charging infrastructure across the airport.

We are already putting in place measures to increase the number of low

emission vehicles operating at Heathrow. This includes replacing all

Heathrow operated cars and small vans with electric vehicles by 2020 and

implementing standards for airside vehicles in line with the London Ultra Low

Emission Zone.

EV infrastructure should be implemented

within and outside the airport to encourage

the adoption of low emission vehicles.

Concern that managing air quality is of the

utmost importance and that greener vehicles,

such as electric cars, will have a positive

effect in the future.




PC MC WC

Consideration should be given for alternative

fuel infrastructure especially for freight

transport.

✓ In designing the appropriate infrastructure at an expanded airport, Heathrow

are considering future trends in vehicle technology and fuel use. This

includes, for example, understanding the potential demand for electric vehicle

charging infrastructure in the future and ensuring adequate capacity is

provided for both passengers and those operating at the airport.

Heathrow should work with the Council to

enable all taxis to be ULEV by 2025.

✓ We remain open to working with partners to maximise opportunities for

appropriate mitigation and welcome further discussions through existing

engagement channels, such as the HSPG.

New rail links must be built before the new

runway to ensure impacts on the existing

road system are minimised.

✓ There are several large committed rail infrastructure projects that are likely to

have an effect on how passengers get to Heathrow in the future. These

include the Elizabeth Line, Piccadilly Line upgrade and HS2 at Old Oak

Common.

The draft Surface Access Strategy, that will be published as part of the

Airport Expansion Consultation in June 2019 will explain how Heathrow are

working with Network Rail to support their application for a western rail link

and the DfTs proposals for a southern rail link. In designing the expanded

Heathrow care is being taken to plan for the interface between these

proposed rail links and the terminals.




PC MC WC

Concern about the deliverability of

Heathrow’s pledge to deliver expansion with

no more vehicles on the road without any new

significant public transport infrastructure

being proposed.

✓ ✓ The ANPS states at paragraph 3.36 that “Heathrow Airport already has good

surface transport links to the rest of the UK. It enjoys road links via the M25,

M4, M40 and M3, and rail links via the London Underground Piccadilly Line,

Heathrow Connect, and Heathrow Express. In the future, it will connect to

Crossrail, and link to HS2 at Old Oak Common. Plans are being developed

for improved rail access: the proposed Western Rail Access could link the

airport to the Great Western Main Line, and Southern Rail Access could join

routes to the South-Western Railway network and London Waterloo Station.

This varied choice of road and rail connections makes Heathrow Airport

accessible to both passengers and freight operators in much of the UK, and

provides significant resilience to any disruption.”

Heathrow will publish a draft Surface Access Strategy at the Airport

Expansion Consultation in June 2019, which will set out measures we

propose to put in place to continue to strive to meet our pledge of ensuring

the expanded airport landside airport-related traffic is no greater than today.

It will also set out measures to achieve the NPS requirements of a public

transport mode share of at least 50% by 2030, and at least 55% by 2040, for

passengers for the expanded airport.

The delivery of the rail and bus links for

surface access will be the most effective way

of reducing emissions and improving air

quality.

✓

Heathrow agree that increasing the use of public transport is key to improving

air quality. Part of our approach to meeting our existing commitment to

improving air quality is by continuing to strive to meet our commitment of not

increasing the amount of landside airport-related vehicle traffic on the road

compared to today; by supporting improved surface access that would

increase the number of people (both passengers and employees) using

public transport; and by encouraging and incentivising the use of new

technology and cleaner vehicles.




PC MC WC

Heathrow’s commitment to not increase the

amount of airport-related vehicle traffic on the

road and increase the numbers of people

using public transport would not be enough

to improve air quality in Stanwell and

Stanwell Moor.

✓ Heathrow will publish a draft Surface Access Strategy at the Airport

Expansion Consultation in June 2019, which will set out measures to deliver

our commitment of ensuring the expanded airport landside airport-related

traffic is no greater than today. It will also set out measures to achieve a

public transport mode share of at least 50% by 2030, and at least 55% by

2040, for passengers for the expanded airport. The strategy will play a key

role in managing the potential air quality effects of the Project, assessed as

part of the EIA. The initial findings of the EIA will be reported in the PEIR to

be published as part of the Airport Expansion Consultation in June 2019. This

will include predicted effects in Stanwell and Stanwell Moor and further

details of proposed mitigation measures.

More could be done to control/influence how

the airport is accessed. Heathrow must make

a commitment to deliver projects that enable

passengers, workers, commuters and freight

to move to more sustainable and accessible

modes of travel and contribute towards the

achievement of mode share targets.

✓ ✓ Heathrow are developing a surface access strategy to meet targets set out in

the ANPS on public transport mode share (at least 50% of surface access

passengers arriving or departing from Heathrow by public transport in 2030

and at least 55% of surface access passengers arriving or departing from

Heathrow by public transport in 2040), colleague car use reduction (25%

reduction of all colleague car trips by 2030 compared with 2013 levels and

50% reduction of all colleague car trips by 2040 compared with 2013 levels).




PC MC WC

The implementation of surface access

improvements to encourage sustainable

forms of transport is needed.

✓

We will also continue to strive to meet our commitment of not increasing

landside in airport-related traffic compared to today.

The Surface Access Strategy will include initiatives that improve the physical

infrastructure and the level of service provided to passengers, colleagues and

residents and initiatives that make public transport easier to use and change

travel behaviour more widely. A draft Surface Access Strategy will be


Concern that the Heathrow Express is too

expensive and holds back Heathrow’s

aspirations for modal change.

✓ At Airport Expansion Consultation One (January 2018) Heathrow expressed

an intention to work with local transport operators to make travel to and from

the airport on public transport as affordable as possible. This could be

through offers and promotions on Heathrow’s services or negotiated

discounts with other operators. Heathrow has already led a number of

innovative pricing offers on Heathrow Express such as advanced fares for as

little as £5.50, children travelling for free and the recent £15 summer price

promotions.

With the significant upgrade in rail capacity and frequency due to the

introduction of the Elizabeth line and Piccadilly line upgrade, there is an

opportunity to review the pricing structure of Heathrow Express fares to

ensure the service provides the optimal customer experience and demand

requirements. Making efficient use of available rail capacity will be a key

driver in making public transport more accessible for both passengers and

colleagues.




PC MC WC

Air quality problems extend to areas further

from the airport. Limiting car parking spaces

and the provision of a new rail link from

Waterloo are therefore important measures.

✓ It is recognised that a large number of monitoring sites across London

currently record pollutant concentrations in excess of the relevant EU Limit

Values and Air Quality Objectives. It is important to note that non-airport

related road traffic is the dominant contributor to ground-level pollutant

concentrations outside of the airfield and that international, national and

regional actions will play an important role in reducing pollutant

concentrations across the UK in the forthcoming years.

We will continue our work in partnership with the companies operating at

Heathrow, local authorities and Government, and we remain fully committed

to playing our part in meeting the Government’s national Air Quality

Objectives (AQOs) and achieving compliance with European air quality limits.

Our Surface Access Strategy will set out how we intent to do so, and include

initiatives that improve the physical infrastructure and the level of service

provided to passengers, colleagues and residents and initiatives that make

public transport easier to use and change travel behaviour more widely. A

draft Surface Access Strategy will be published as part of the Airport





PC MC WC

Enabling people to use modes other than the

private motor vehicle is vital such as

improved cycle access.

✓ Our approach to developing a surface access strategy which was published

at Airport Expansion Consultation One (January 2018) stated that the

provision of better and more sustainable travel options (public transport,

cycling and walking) was one of its the key priorities. It set out a number of

measures and options about how cycling provision could be improved

including:

• Expanding the Heathrow Cycle Hub scheme which already has over

2,300 members and offers discounted cycles and equipment, free

labour on maintenance and training to all airport employees.

• New cycle hub facilities could provide a single point of entry to and

from Heathrow and a holistic service to users, including shower and

changing facilities.

• Ensuring that fast and frequent connections are available from the

cycle hubs to relevant employment locations around the airport. It

would be possible to build similar hubs at key entrances to the south

and east of the airport, making cycling more convenient for many

more of our colleagues.

• Heathrow is also currently re-purposing an existing tunnel to provide

direct bicycle access to the Central Terminal Area from the north

boundary of the airport.

This approach has been progressed in the Surface Access Strategy and a

draft will be published at the Airport Expansion Consultation in June 2019.




PC MC WC

Improvements to air quality will largely

depend on government action such as

investment in rail schemes.

✓ Heathrow acknowledged within the Airport Expansion Consultation One

materials that international, national and regional actions will play an

important role in reducing pollutant concentrations across the UK in the

forthcoming years. We are however committed to playing our part and

managing the influence of Heathrow on local air quality. As required by the

ANPS, we must demonstrate through the DCO and supporting ES that the

Project would be compliant with legal air quality obligations that provide for

the protection of human health and the environment.

In the long term, increased flights from

Heathrow will lead to more traffic on the M25

(and M4) increasing congestion and air

pollution near Heathrow and up to and near St

Albans.

✓ Heathrow recognises the existing challenges on the road network in the

Heathrow area with high traffic levels and local air quality issues.

Heathrow are developing a Surface Access Strategy that will set out

measures to meet the requirements of the ANPS. These requirements

include: increase the proportion of journeys made to the airport by public

transport, cycling and walking to achieve a public transport mode share of at

least 50% by 2030, and at least 55% by 2040 for passengers; from a 2013

baseline level, achieve a 25% reduction of all colleague car trips by 2030,

and a reduction of 50% by 2040.

We will also continue to strive to meet our public pledge to ensure that

landside airport related traffic is no greater than today.

In doing so, we are developing measures which are expressly designed to

manage on site traffic movements from passengers, such as improving on-

Concern that displaced airport and non-

airport traffic will give rise to air pollution hot

spots.

✓

Concerns that expansion will result in

significant redistribution of traffic around the

airport and additional traffic flows.

✓




PC MC WC

Concern that expansion would increase traffic

in the Air Quality Management Areas

(AQMA’s) within the borough and that no

strategic objective for the management of

surface transport had been produced.

✓ site transport facilities to encourage the use of public transport. Meeting these

requirements is important to our approach to reducing air quality impacts. The

draft Surface Access Strategy will be published in at the Airport Expansion


The increase in road traffic caused by a

growth in the number of passengers

travelling to and from the airport risks a

negative impact on local air pollution.

✓

The roads surrounding Heathrow cannot cope

with the existing volume of traffic

contributing to poor air quality.

✓

Concern that the amount of traffic on the

roads will have a knock-on effect on the

ability to control air quality levels.

✓

There is a requirement for Heathrow to

provide a resilient and reliable road network

in order for it to deliver a reduction in

emissions and limit fuel use.

✓




PC MC WC

Adverse change to noise and air quality from

any changes to the strategic road network

must be fully considered and mitigated,

including ensuring compliance with the

European air quality limit values and/or in

local authority designated Air Quality

Management Areas.

✓

Concern about the lack of measures to

reduce airport related traffic movements for

staff, service vehicles and airport users.

✓

Additional construction traffic movements

would add to the existing issues with air

quality caused by traffic congestion and

commercial vehicles using the roads through

the village.

✓ Air quality will be monitored as part of the wider pre-construction/construction

monitoring programme, which will include appropriate locations based on

potential impacts. The full programme for monitoring has not yet been

planned, but monitors will be installed in advance of the construction

programme.

Concern whether air quality had been

considered when selecting the options for the

A3044, the M25, or Option 6C for the A4.

✓ The Scheme Development Report published at Airport Expansion

Consultation One explains the evaluation process for the selection of

proposed options for the Project. Evaluation criteria includes seven discipline

areas which includes sustainability. Air quality is a criterion within the

sustainability discipline against which all masterplan options are considered.

The preferred masterplan will be presented at the Airport Expansion

Consultation in June 2019 along with the Updated Scheme Development

Report that will set out the findings of the evaluation process.




PC MC WC

Current traffic volumes, especially HGVs,

already have a significant and negative

impact on their community from noise, air

pollution and poor road safety.

✓ As part of the Project Heathrow will aim to limit freight vehicles to similar

levels to today and help operators clean up the vehicle fleets through a range

of different initiatives, including: increasing efficiency; optimising the fleet mix

and using new technology to increase load factors to help more goods to be

delivered in the same number of vehicles. Cargo and logistics facilities

around the airport have grown in an incremental and organic way which

means there are lots of facilities in different locations. By working with the

local authorities to more proactively plan the land uses around the airport

Heathrow can provide facilities in appropriate locations helping to reduce

shuttling movements through consolidation of loads and reducing impacts on

local communities. Working with Transport for London and other authorities

on re-timing journeys that are not time critical to outside peak periods,

monitoring of routing for HGVs and other freight vehicles, as well as ensuring

there are appropriate measures in place for those that do not comply.

The Perimeter Roads also carry a high

proportion of traffic circulating around the

airport between terminals, car parks and

other ancillary airport facilities and must be

included in both the baseline and future

assessment of vehicle movements.

✓ The Airport is surrounded and accessed by an inner ring road, formed by the

northern, eastern, southern and western perimeter roads and an outer ring of

the A4, A312, A30 and A3044.

The Project would result in the loss of the Western Perimeter Road and parts

of the Northern Perimeter Road. It would also result in severance of the A4

(Bath Rd) and A3044 (Stanwell Moor Rd). These roads will form part of the

baseline and transport and traffic impact assessment. This will include

considering how the impact of physical changes to the road network and or

changes in traffic flow associated with the Project will affect delay on these

roads. Early findings of the traffic and transport assessment will be published

in the PEIR at the Airport Expansion Consultation in June 2019.




PC MC WC

The definition of Heathrow related traffic must

include traffic on all roads.

✓ Heathrow will continue to strive to meet its pledge to have landside airport-

related traffic no greater than today. Heathrow is currently defining what

vehicles are considered to be ‘airport-related traffic’ and details of this will be

presented in the draft Surface Access Strategy at the Airport Expansion


Brands Hill Air Quality Management Area

should be included with the airports air

quality model and study area.

✓ The spatial extent of the detailed study area will include the Brands Hill

AQMA.

Concern about the impact on the proposed

Air Quality Management Area in the Iver and

Burnham Beeches Special Area of

Conservation.

✓ The assessment will consider air quality beyond the immediate area around

Heathrow. The spatial extent of the detailed study area will be based on

where potential changes traffic flow as a result of the Project could result in

changes in pollutant concentrations, to the extent that these could result in

significant environmental effects. This will be determined in accordance with

the EIA Scoping Opinion published by the Planning Inspectorate on the 2nd

July 2018, through use of appropriate screening criteria.

The initial findings of the assessment will be reported in the PEIR to be

published as part of the Airport Expansion Consultation in June 2019. The highway network should be given full

consideration in Heathrow's future approach

to air quality. This includes an Air Quality

Management Area in place on the M3 between

Junction 3 and Junction 4 and the A331 in the

west of Surrey Heath, where exceedances of

the annual mean NO2 limit value have been

identified.

✓




PC MC WC

Extend the ULEZ to the area around the

airport, including preferably the M25

Motorway. This will assist in improving air

quality for residents.

✓ ✓ Heathrow is exploring the potential for strategically-managed access charges,

low emission zones, and parking charges at the airport to encourage the use

of low emissions vehicles and reduce unnecessary trips. In doing so,

Heathrow is engaging with the Mayor and Transport for London to co-

ordinate proposals for an emission based charge with plans for the emerging

London Ultra Low Emissions Zone. These proposals will be outlined at the

Airport Expansion Consultation in June 2019. The only way to address air quality issues

would be the implementation of a Clean Air

Zone and/or Zero Emissions Zone.

✓

The A4 should be declared as a CAZ and

aligned with the airports LEZ.

✓

Air quality measures taken around the airport

that may apply to freight or other air related

businesses in the future must be consistent

with the ULEZ in London and the

Government’s Clean Air Strategy to avoid

fragmentation of vehicle standards.

✓

Airport related freight routes that use the

strategic road network (motorway) should be

CAZ compliant.

✓



CARBON AND CLIMATE CHANGE

Introduction


relation to the measures proposed to limit carbon emissions from the design,

construction and operation of the Heathrow Expansion Project (the Project). A

total of 878 consultees made comments relating to this topic.

22.1.2 Heathrow provided the following material that is directly related to the measures

proposed to limit carbon emissions:


2. Our Approach to Carbon and Climate Change.

22.1.3 Heathrow asked the following question in relation to the approach to limiting

carbon emissions at Airport Expansion Consultation One:

1. Do you have any comments on our approach to limiting carbon emissions from

the design, construction and operation of an expanded Heathrow?














Local Authorities

22.2.1 The London Borough of Brent supported Heathrow’s efforts to date to reduce the

carbon footprint of terminal buildings and incentivising airlines to use greener

aircraft. However, they considered that more could be done to reduce the carbon

emissions generated by travel to and from the airport.



22.2.2 Elmbridge Borough Council said Heathrow’s dependence on technological

progress, including the evolution of aircraft fleet, gave optimistic carbon

projections.

22.2.3 The London Borough of Hammersmith and Fulham stated that a carbon neutral

third runway was aspirational and requested formal commitments from Heathrow.

They recommended that Heathrow quantify the carbon emission impacts before

and after mitigation to show its value, otherwise there is no way to assess if

measures are achieving the low/zero carbon or carbon neutral targets.

22.2.4 They requested more information on whether Heathrow’s carbon neutral

commitments apply across all the demand scenarios that were used for modelling

by the Airports Commission and the Department for Transport (DfT).

22.2.5 Hampshire Services, on behalf of the Central and Eastern Berkshire Authorities,

supported the proposals for low carbon construction and materials, particularly the

minimisation of materials wherever possible.

22.2.6 The London Borough of Hounslow commented that carbon emissions associated

with aircraft will increase with the additional proposed flights and will be significant

unless timely measures are implemented. They considered the adoption of fuel-

efficient aircraft and sustainable biofuel critical to achieve the carbon reduction

targets set by Heathrow and UK/EU Legislation.

22.2.7 They asked for more detail on the approaches that will be used to limit carbon

emissions and concrete commitments which demonstrate how Heathrow will

incentivise and monitor progress with targets and penalties. They suggested that

timely adoption of sustainable aircraft and higher landing fees for aircrafts with

higher emissions are critical for the sustainable expansion of Heathrow.

22.2.8 They also highlighted that:

1. details should be provided on how increased emissions will be effectively

mitigated;

2. carbon offsetting should be the last resort once all the mitigation has been

implemented;

3. failure to reduce carbon emissions immediately will result in ever-increasing

costs and public safety risk associated with the impacts of climate change;

4. effective baseline, monitoring and periodic targets are set to ensure carbon

reduction is apparent; and

5. loss of green space should be minimised as it is critically important for carbon

storage, temperature regulation and flood mitigation.

22.2.9 The London Borough of Islington considered that the expansion of any airport

cannot be justified unless the volume of greenhouse gas emissions that would



result from expansion, including emissions from additional flights, is consistent

with the government’s overall climate change targets.

22.2.10 Kent County Council stated that carbon impacts should be assessed at all stages

of the project lifecycle and consideration should be given to the waste hierarchy

during operations, specifically energy generation. They highlighted that all

practicable measures should be taken to ensure carbon emissions are minimised

at all stages of construction and operation and that measures to increase public

transport use are vital to maintaining and reducing the airport’s carbon emissions.

22.2.11 The Council also supported the use of carbon offsetting but said that this should

be meaningful. They cited the example of providing finance to support energy

efficient housing stock in the local area.

22.2.12 Reading Borough Council supported the proposals to reduce carbon emissions

and reduce the airport’s effect on climate change. They highlighted the need to

make surface access by sustainable transport as attractive and easy as possible

to reduce car use and the influence on climate change.

22.2.13 Spelthorne Borough Council stated that the approach to carbon and climate

change was highly encouraging but said that the aspiration and related objectives

appeared high-level and lacking in specific details. They recognised Heathrow’s

investment into electric vehicle infrastructure and that it would also assist with

wider air quality benefits through faster and greater uptake of electric vehicles by

the residents and businesses in the local communities to help offset increased

surface access emissions.

22.2.14 Surrey County Council supported the overarching aspiration to make growth from

the new runway carbon neutral and the objective to operate a zero-carbon airport

but requested more details on how these would be achieved, measured and

monitored. Further information was also requested on where materials for

construction would be sourced and waste would be disposed. They considered

this should be documented in a materials and disposals brief for the scheme.

22.2.15 Wokingham Borough Council supported the strategy for reducing carbon

emissions outlined in the consultation document.


22.2.16 No comments were received from statutory consultees about lowering carbon

emissions.

Other Prescribed Consultees

22.2.17 Albury Parish Council expressed concern that no details were provided on how

airlines will be incentivised to deliver low carbon flights or how it will be policed.



22.2.18 Bray Parish Council commented that on still days the smell of aviation fuel is

apparent and increased traffic will only make pollution worse. They perceive that

the country is not achieving the reduced carbon emissions required and fail to see

how carbon reduction policies can be achieved.

Local Communities


22.3.1 Positive and negative comments on the approach to managing carbon emissions

were received. The most comment positive comment was that the measures

appeared suitable and fair. Positive comments were also received that stated that

the approach was comprehensive, that limiting emissions was necessary and that

investment into renewable energy sources, the use of low emission and/or electric

vehicles and that the proposals would address long term needs or requirements.

22.3.2 Responses were also received which expressed support for the approach subject

to certain conditions being met, these comprised that:

1. there must be an extension of the proposed ULEZ further beyond the boundary

of the airport;

2. alternative energy should be introduced on site; and

3. aircraft emissions should be reduced and there should be penalties for older or

more polluting aircraft.

22.3.3 Negative comments relating to carbon emissions often expressed general

concerns about the effects of emissions from aircraft or commented that the

approach to managing carbon emissions was inadequate or insufficient. Other

negative comments and criticisms comprised:

1. the approach is unrealistic or unachievable;

2. the approach lacks credibility given the current air pollution;

3. carbon emissions would not be reduced;

4. Heathrow will not be able to influence existing behaviours and that expansion

will simply lead to more of the current impacts, overall levels of pollution will not

be reduced.

5. concern that the emissions management measures proposed can only hope to

offset or mitigate in the short term.

6. the methods proposed to reduce carbon emissions should be implemented

ASAP and not be delayed.

7. concern that more flights will mean more emissions, air quality levels are

already poor and breach EU limits; and



8. concern with the impact of emissions on local communities from traffic and

planes.

22.3.4 Members of the public also raised points about the need for low carbon design,

that it was important and that it would also improve the resilience of the airport.

However, others believed that low carbon design would not make a difference or

that it would be insufficient.

22.3.5 Suggestions were also received that Heathrow should invest in new technology,

use of solar panels or wind turbines within the design or that the priority should be

for an energy efficient design, be carbon neutral or that the buildings should be

zero carbon utilising recycled materials or reuse for construction where possible.

22.3.6 With regard to low carbon operations suggestions were received that cleaner/low

emission aircraft and cleaner/low emission ground vehicles should be used and,

that older aircraft should be banned from using Heathrow Airport.

22.3.7 Suggestions were also received that the process should be expedited, that

emissions were unavoidable, and that the theory of climate change and its impacts

were a myth.

Businesses

22.3.8 The Airport Industrial Property Unit Trust (AIPUT) requested that Heathrow publish

the results of its air quality assessments as well as the embodied carbon and

emissions impact.

22.3.9 The Copas Partnership suggested that Heathrow should focus on low emissions.

22.3.10 The Emerson Group on behalf of Orbit Developments (Southern) Limited stated

that it is not clear how Heathrow can remain within the Committee on Climate

Change's recommended assumptions in respect of carbon emissions, especially

when combined with emissions from other UK airports. They considered that

inadequate information was provided on this.

22.3.11 The Fuel Trading Company recommended that renewable diesel should be used

in both the operation and the construction of any part of the airport to limit carbon

emissions.

22.3.12 Suez UK indicated that as a recycling, resource management renewable energy

company, they had numerous comments to make on this matter but requested a

discussion with the Project team, separate to the consultation.

Community Groups

22.3.13 Aircraft Noise Three Villages considered that Heathrow is relying entirely on

reductions in carbon emissions from other sources such as regional airports. They

also expressed concern that there is no acknowledgement of the facts laid out by



the Committee on Climate Change. The Richmond Heathrow Campaign

expressed a similar view and suggested that restrictions on other sectors of the

UK economy and growth at other UK airports was likely to be required to address

carbon emissions.

22.3.14 The Colnbrook Community Partnership expressed support for the approach set

out within the consultation documents to limit carbon emissions.

22.3.15 The Chertsey Society stated that if the Project goes ahead there will be a huge

increase in carbon dioxide emissions from planes and vehicle movements. They

suggested that airlines should set aside money to plant trees to absorb the carbon

dioxide as an offsetting scheme.

22.3.16 Ealing Fields Residents Association considered Heathrow’s proposals satisfactory

but expressed concern that air travel is a disproportionate contributor to climate

change.

22.3.17 Englefield Green Action Group commented that Heathrow’s proposals should not

increase emissions from the current levels, suggesting that tapered reduction

targets should be set. They also expressed opposition to the use of carbon

offsetting.

22.3.18 Harrow U3A Sustainability Group expressed concerns over the use of the term

'carbon emissions' and suggested that carbon dioxide, particulate carbon or

methane should be considered.

22.3.19 Local Conversation in Stanwell recognised Heathrow’s investment into electric

vehicle infrastructure and considered it will help staff, taxis and private hire

vehicles in making the transition to electric vehicles. They also considered that

greater uptake of electric vehicles by the residents and businesses in the local

communities will help to offset increased surface access emissions.

22.3.20 Richmond Environmental Information Centre asked for the introduction of electric

engines to aircraft which could be a compulsory source of power when landing.


22.4.1 The Royal Society for the Protection of Birds expressed opposition to any airport

expansion until the Committee on Climate Change’s recommendation that

government produce a plan to limit UK aviation emissions is set in motion. They

considered that airport expansion within current policy structures will damage the

UK’s ability to keep emissions within carbon budgets and that expanding Heathrow

will lead to increased aviation emissions.

22.4.2 The Colne Valley Regional Park supported measures that encourage low carbon

design, construction and operation of the airport and requested further details on

Heathrow’s approach.



22.4.3 The Campaign to Protect Rural England stated that the vast majority of carbon

(dioxide) emissions will be from the extra aircraft and there are no proposals that

would appreciably offset this increase. They also commented that there was no

mention of the impact of the Project on the UK’s obligations in the Climate Act and

no recognition of the significant greenhouse-causing emissions at altitude from the

extra aircraft.

22.4.4 The Church of England – Diocese of London, Oxford and Southwark expressed

concern that the approach to tackling climate change is incoherent, incomplete,

inadequate and deeply unconvincing. They said there is no attempt to bring

Nitrogen Oxide emissions at altitude within scope or to improve on the

International Civil Aviation Organisation’s (ICAO) offsetting scheme.

22.4.5 Hounslow Green Party commented that the Project defies logic on air pollution and

climate change grounds. National targets on carbon reduction should be tougher

and Heathrow should not be allowed to expand unless the other emitters reduce

activity beyond what is viable.

22.4.6 Lambeth/Herne Hill Green Party requested carbon emission reduction goals are

taken seriously and that measures to reduce carbon emissions before considering

off-setting are implemented. They also suggested that the fee airlines pay to

operate at the airport should not remain close to current levels but should reflect

the cost in harm to the environment.

22.4.7 The London Parks and Garden Trust highlighted concerns that there are

insufficient details to comment on the approach to limiting carbon emissions at

present and urged as much use of green infrastructure as possible.

22.4.8 The London Wildlife Trust expressed support for measures that encourage low

carbon design, construction and operation and requested further details on

Heathrow’s approach.

22.4.9 The Royal Parks expressed support for the move to reduce carbon emissions.

They suggested that mitigation should be included that allows biodiversity to

develop and tolerate changes in climate.

22.4.10 The World Federalist Party commented that the approach to carbon and climate

change was short-sighted or disingenuous.





consultees in relation to Carbon and Climate Change. None of the feedback received in relation to Carbon and Climate

Change are directly related to the proposals on which we are seeking feedback as part of the Airspace and Future Operations

Consultation (January 2019) but instead relate to other aspects of the Project. The table therefore provides a summary of the

way in which we are seeking to consider the issues raised, and are provided for information only. No further feedback is being

sought on the basis that a full consultation feedback report will be published as part of the Airport Expansion Consultation in

June 2019.

Table 22.1B


PC MC WC

Concerns that emissions management

will not keep pace with longer term

expansion.

✓ The Environmental Impact Assessment (EIA) will assess the likely significant effects

of the Heathrow Expansion Project (the Project) based on a range of variables.

These include reasonable worst-case projections of the growth in aircraft

movements facilitated by the Project, but also other factors which will affect

emissions in the future. These factors include developments in aircraft and vehicle





PC MC WC

Heathrow’s dependence on technological

progress, including the evolution of

aircraft fleet, gave optimistic carbon

projections.

✓ technology and subsequent evolution of the fleets, modernisation of airspace and

the uptake of sustainable aviation fuels. In accordance with the EIA Scoping Opinion

provided by the Planning Inspectorate (PINS), conservative assumptions relating to

these variables will be applied during the assessment. However, Heathrow is

developing a number of measures which aim to accelerate the uptake of increasingly

sustainable technologies, practices and fuels, across both the airfield and for those

passengers and colleagues travelling to and from the airport via the transport

network.

Further information relating to emissions projections and proposed mitigation

measures will be published within the Preliminary Environmental Information Report

(PEIR), as part of the Airport Expansion Consultation in June 2019.

Carbon emissions associated with

aircraft will increase with the additional

proposed flights and will be significant

unless timely measures are implemented.

✓ It is recognised that in the short term, the growth in air traffic movements associated

with the Project will result in an increase in absolute carbon emissions. However, in

accordance with the Airports National Policy Statement (ANPS), Heathrow must

demonstrate that expansion will not result in an increase in carbon emissions that

would have a material impact on the ability of Government to meet its carbon

reduction targets, including carbon budgets. Through the adoption of appropriate

measures which seek to accelerate the uptake of new aircraft technology and

encourage the use of sustainable operating practices and aviation fuels, we are

confident in meeting this test.

Concern that carbon emissions would

not be reduced

✓

Concern that air travel is a

disproportionate contributor to climate

change.

✓ Heathrow recognise that aviation has a central role to play in helping to meet the

global challenge of limiting climate change. As required by the ANPS, we will need

to demonstrate that the Project will not result in an increase in emissions so

significant that it would have a material impact on the ability of Government to meet

its carbon reduction targets, including carbon budgets. Looking beyond this

requirement, our long-term aspiration is for growth from our new runway to be

carbon neutral.




PC MC WC

Failure to reduce carbon emissions

immediately will result in ever-increasing

costs and public safety risk associated

with the impacts of climate change.

✓ Climate change is widely accepted as one of the greatest global risks facing our

planet and the challenge facing all of us is to find a way to cut our emissions whilst

continuing to develop socially and economically. The aviation industry has to play its

part and Heathrow’s aim is to take a lead globally in decoupling growth in aviation

from growth in carbon emissions.

The EIA will consider the likely significant impacts of carbon emissions associated

with the construction and operation of the Project and identify appropriate mitigation

measures to manage these emissions. We are also assessing the effects of

potential future changes in climate on the Project itself and on surrounding

receptors. This includes, for example, how the potential effects of the Project on

biodiversity receptors could be exacerbated by projected changes in temperature.

The initial findings of our Carbon and other greenhouse gases and Climate Change

assessments will be published within the PEIR, as part of the Airport Expansion


Concerns over the use of the term

'carbon emissions' and suggested that

carbon dioxide, particulate carbon or

methane should be considered.

✓ The scope and methodology of our Carbon and other greenhouse gases

assessment is described within the EIA Scoping Report submitted to PINS on 21st

May 2018, and the subsequent Scoping Opinion provided by PINS (on behalf of the

Secretary of State) on 2nd July 2018.

Emissions resulting from the Project will be reported in terms of carbon dioxide

equivalent (CO2e) for all main greenhouse gases (carbon dioxide, methane etc.),

with the exception of aircraft emissions. Heathrow has adopted the advice of the




PC MC WC

Committee on Climate Change10 to consider only CO2 emissions from air transport.

This advice has also been adopted by the DfT11 and has informed its policy on

aviation and climate change.

Heathrow should be looking at best

practice examples from around the world.

✓ Heathrow are working with a range of specialists in airspace and airport design who

are aware of projects and practices undertaken elsewhere.

10 Committee on Climate Change, Scope of carbon budgets – Statutory advice on inclusion of international aviation and shipping, April 2012, and

Committee on Climate Change, Meeting the UK aviation target – options for reducing emissions to 2050, December 2009

11 Department for Transport, UK Aviation Forecasts, 2017




PC MC WC

No recognition of the significant

greenhouse-causing emissions at altitude

from the extra aircraft (NOx and H2O).

✓

✓

Heathrow submitted an EIA Scoping Report to PINS on 21st May 2018. We

subsequently received a Scoping Opinion from PINS, on behalf of the Secretary of

State, on 2nd July 2018. The Scoping Opinion sets out PINS opinion on the scope,

level of detail and information to be provided in the ES. The EIA Regulations require

Heathrow to submit an ES which is in based on the most recent scoping opinion

adopted.

As set out in the Scoping Report and subsequent Scoping Opinion, the EIA will

assess CO2 emissions from aircraft, both in the landing and take-off cycle and above

3000ft (cruise). The approach which will be applied by Heathrow is consistent with

the advice of the Committee on Climate Change, which has also been adopted by

the DfT and has informed its policy on aviation and climate change.

The approach which will be adopted during the air quality assessment differs to that

for carbon due to the different nature of the effects and receptors. Specifically, the

impact of carbon emissions is generally assessed at a global level, given the

influence of aircraft CO2 emissions in the atmosphere on climate change. Air quality

effects however are assessed at a local level, based on potential changes in

pollutant concentrations (NO2 and particulate (PM)) at locations where people might

be exposed, for example at residential properties. It is for this reason that the air

quality assessment will not assess pollutant emissions from aircraft above the

landing and take-off cycle (3000ft). Due to the dispersion of these emissions at

height, they have a negligible effect on pollutant concentrations at ground level. This

approach is based on the International Civil Aviation Organization (ICAO) air quality

guidance.




PC MC WC

Concerns about the lack of detail and

information.

✓

The information provided in Airport Expansion Consultation One reflected the fact

that the Project was at an early design stage. Further information regarding the

potential effects of carbon emissions associated with the Project, including early

findings from the EIA, will be contained within the PEIR which will be published as


We remain confident in the ability of our proposals to deliver sustainable growth and

demonstrate that the Project will not result in an increase in emissions that would

have a material impact on the ability of Government to meet its carbon reduction

targets.

Concern that the approach to tackling

climate change is incoherent, incomplete,

inadequate and deeply unconvincing.

✓ The information provided in Airport Expansion Consultation One reflected the fact

that the Project was at an early design stage. Further information regarding the

potential effects of carbon emissions associated with the Project, including early

findings from the EIA, will be contained within the PEIR which will be published as


We remain confident in the ability of our proposals to deliver sustainable growth and

demonstrate that the Project will not result in an increase in emissions that would

have a material impact on the ability of Government to meet its carbon reduction

targets.

Concern that the proposed measures

lack credibility and are unrealistic,

inadequate or insufficient.

✓

Concern that low carbon design would

not make a difference and be insufficient.

✓ Heathrow is in the process of developing a baseline for the carbon emissions

associated with construction (known as embodied carbon) and put in place

measures to reduce these carbon emissions (See Our Approach to Carbon and

Climate Change). Heathrow is in the process of establishing a set of principles for

design and construction to address the carbon impact of expansion.




PC MC WC

The vast majority of carbon (dioxide)

emissions will be from the extra aircraft

and there are no proposals that would

appreciably offset this increase.

✓ Heathrow acknowledges that the primary source of carbon emissions associated

with the airport is aircraft, with operations and energy use and travel to and from the

airport other contributing sources. As required by the ANPS, we will demonstrate via

the ES that the Project will not result in an increase in emissions so significant that it

would have a material impact on the ability of Government to meet its carbon

reduction targets, including carbon budgets.

Looking beyond this requirement, our aspiration is to make growth from our new

runway carbon neutral. This would mean that growth in emissions from additional

flights after expansion would be offset through carbon credits – resulting in no net

growth in emissions. Following a historic agreement in 2016 at the International Civil

Aviation Organisation (ICAO), the UN body for international aviation, the industry is

working with governments to implement CORSIA, the world’s first sector wide

market-based measure for offsetting the growth in international aviation emissions

after 2020. In December 2018, Heathrow published its plan for carbon neutral

growth, and in 2019 will work with the aviation industry, advocacy groups and

climate change experts to seek further inputs.

We want to play a lead role in developing the next generation of high quality, cost

effective carbon offsetting in the UK. For example, we recently funded a project to

restore 70 hectares of peatland in the north-west of the UK, in partnership with the

Lancashire Wildlife Trust. This pilot scheme will stop this peatland emitting carbon,

and over time sequester it, and deliver other benefits, like more biodiversity value

and a lower risk of flooding downstream. It will help us offset a portion of emissions

from Heathrow’s own infrastructure to achieve our goal of carbon neutral

infrastructure by 2020.

A carbon neutral third runway was

aspirational, formal commitments from

Heathrow would be appreciated.

✓ It remains Heathrow’s aspiration to make growth from the new runway carbon

neutral. In December 2018, Heathrow published its plan for carbon neutral growth,

and in 2019 will work with the aviation industry, advocacy groups and climate

change experts to seek further inputs.




PC MC WC

Heathrow is relying entirely on

reductions in carbon emissions from

other sources such as regional airports.

✓ Heathrow dispute the statement that we are relying entirely on reductions in carbon

emissions from other sources, such as regional airports. As required by the ANPS,

we will demonstrate through the DCO application and supporting ES that the

increase in carbon emissions resulting from the Project would not have a material

impact on the ability of Government to meet its carbon reduction targets, including

carbon budgets. The initial findings of the EIA process will be reported in the PEIR

as part of the Airport Expansion Consultation in June 2019.

The expansion of Heathrow Airport must

not lead to an increase in climate-

changing emissions or any increase in

motor vehicle volumes (and resulting

pollution and emissions).

✓ The ANPS sets out the planning framework for a new runway in the South of

England. In doing so, it defines requirements for Heathrow’s environmental

assessment. In the context of carbon, this includes demonstrating that the increase

in carbon emissions resulting from the project would not have a material impact on

the ability of Government to meet its carbon reduction targets, including carbon

budgets.

The ANPS does not require Heathrow to demonstrate that there will be no increase

in motor vehicle volumes due to the Project. It does however require that the

application for development consent to include details of how Heathrow will increase

the proportion of journeys made to the airport by public transport, cycling and

walking to achieve a public transport mode share of at least 50% by 2030 and at

least 55% by 2040 for passengers. The application will also detail how a 25% and

50% reduction in all colleague car trips will be achieved by 2030 and 2040

respectively.

Heathrow should think holistically about

how it can unilaterally and bilaterally

reduce emissions from all sources,

tackling the greatest sources of

emissions first.

✓ Heathrow agree that a holistic approach is appropriate when developing measures

to manage the potential emissions associated with the airport, and that these

measures will require both direct action by Heathrow and partnership with the

relevant stakeholders. Further details on the measures proposed to manage the

effects of the Project will be contained within the PEIR, which forms part of the





PC MC WC

Project should use technologies that

could improve environment, e.g. use an

energy efficient/carbon neutral design,

solar panels or wind turbines and

utilising recycled materials in

construction.

✓ ✓ Heathrow objective is to develop an expanded airport that minimises carbon in its

operation and construction. This means carbon is a key criterion that informs our

thinking and the design of the Project ensuring, for example, that land is

safeguarded for renewable energy technology and flexibility is built into our designs

to enable new technologies to be adopted in the future.

Our goal is to be a zero-carbon airport by 2050 – generating no carbon from the

energy used to run Heathrow. In the near term, we’re maximising renewable energy

generation onsite and already purchase 100% renewable electricity. Alternative energy should be introduced

on site.

✓

Concern regarding expansion of any

airport in relation to the government's

climate change targets (e.g. Climate Act).

✓ ✓ Paragraphs 5.82 and 5.83 of the ANPS set out the policy requirement of ensuring

that the Project would not have a material impact on the ability of Government to

meet its carbon reduction targets, including carbon budgets. Evidence of

appropriate mitigation measures in both design and construction will be presented

as part of the DCO application, along with emission projections for construction

activity, transport to and from the airport, operations (e.g. fuel and energy use) and

aircraft movements. The Secretary of State will consider the effectiveness of

Heathrow’s proposed mitigation measures to ensure that the project's carbon

footprint is not unnecessarily high. The Secretary of State’s view of the adequacy of

the mitigation measures will be a crucial factor in the decision-making process.

The initial findings of the EIA, including carbon and greenhouse gas projections and

proposed mitigation measures, will be reported within the PEIR which forms part of


Concern that airport expansion within

current policy structures will damage the

UK’s ability to keep emissions within

carbon budgets.

✓ The Climate Change Act 2008 set out a 2050 carbon reduction target (80%

reduction versus 1990) for the UK and requires the Committee on Climate Change

(CCC) to put forward for government approval 5 year carbon budgets consistent with

this target. The Act also requires the CCC to monitor and report progress to




PC MC WC

Concern that the country is not achieving

the reduced carbon emissions required

and fail to see how these policies can be

achieved.

✓ Government including providing advice on any remedial actions required. Latest

advice from the CCC indicates that the UK has reduced its greenhouse gas

emissions by 43% compared to 1990 levels and is on the way to a target of at least

80% reduction by 2050 albeit that there is a need for Government to consider further

policies to ensure progress is improved in order to meet the fourth and fifth carbon

budgets. Notwithstanding wider carbon reduction targets that apply at a national

level the ANPS has considered the CCC’s advice on international aviation emissions

and concluded that its policy support for the north west runway option is consistent

with the UK’s climate change obligations.

The proposals send the wrong message

both nationally and internationally.

✓

It is not clear how Heathrow can remain

within the Committee on Climate

Change's recommended assumptions in

respect of carbon emissions, especially

when combined with emissions from

other UK airports. Inadequate information

was provided on this.

✓ The ANPS has considered the advice of the CCC and is supported by in-depth

technical assessment to demonstrate that domestic and international UK aviation

emissions can be consistent with the CCC’s advice with the additional capacity

provided through the north west runway option. This assessment has considered not

only carbon emissions from the north west runway option but also forecast carbon

emissions for all UK airports.

Government has committed to publishing its Aviation Strategy in 2019 setting out its

position on international aviation emissions and UK climate change policy. Opposition to any airport expansion until

the Committee on Climate Change’s

recommendation that government

produce a plan to limit UK aviation

emissions is set in motion.

✓

Concern that there is no

acknowledgement of the facts laid out by

the Committee on Climate Change.

✓




PC MC WC

Mitigation should be included that allows

biodiversity to develop and tolerate

changes in climate.

✓ Heathrow has committed to achieving an overall net gain in biodiversity and this will

include the creation of new and enhanced habitats and management arrangements

(EIA Scoping Report May 2018).

The EIA process will also include consideration of the effects of potential future

changes in climate on the Project itself and on surrounding receptors. This includes,

for example, how the potential effects of airport expansion on biodiversity receptors

could be exacerbated by projected changes in temperature, which will inform

appropriate mitigation measures.

Early findings of the biodiversity and climate change assessments will be reported in

the PEIR to be published as part of the Airport Expansion Consultation in June 2019.

More information should be supplied on

whether Heathrow’s carbon neutral

commitments apply across all of the

Airport Commission/DfT demand

scenarios.

✓ As required by the ANPS, Heathrow will need to demonstrate that the Project will not

result in an increase in emissions so significant that it would have a material impact

on the ability of Government to meet its carbon reduction targets, including carbon

budgets.

Looking beyond this requirement, our long-term aspiration is for growth from the

Project to be carbon neutral. This would mean that growth in emissions from

additional flights after expansion would be offset through carbon credits – resulting in

no net growth in emissions. This aspiration is applicable to actual aircraft

movements rather than Airport Commission of DfT demand scenarios. In December

2018, Heathrow published its plan for carbon neutral growth, and in 2019 will work

with the aviation industry, advocacy groups and climate change experts to seek

further inputs.




PC MC WC

All practicable measures should be taken

to ensure carbon emissions are

minimised at all stages of construction.

✓ Heathrow will employ best practice management and delivery systems to manage

the effects of construction. Detailed measures will be developed to avoid or reduce

the likely impacts of construction on communities and the environment as the Project

develops. As part of the EIA process, a Code of Construction Practice will be

prepared, which will outline how construction activities will be managed. This

document will set out the requirements for mitigation and the monitoring of potential

environmental impacts throughout the construction period. Heathrow will be

consulting on the draft Code of Construction Practice as part of the PEIR which will

be published as part of the Airport Expansion Consultation in June 2019.

Further information requested on where

materials for construction would be

sourced and waste would be disposed.

✓ Heathrow are in the process of developing a baseline for the carbon emissions

associated with construction (known as embodied carbon) and will put in place

measures to reduce these carbon emissions. (This was set out in Our Approach to

Carbon and Climate Change at Airport Expansion Consultation One). We are also in

the process of establishing a set of principles for design and construction to address

the carbon impact of expansion. These currently include using carbon as a key

criterion for determining material choice and minimising the need for virgin materials

and sourcing materials and products locally to where they are used. The Logistics

hubs and use of off-site construction should help to reduce the carbon footprint of

the Project.

Loss of green space should be minimised

as it is critically important for carbon

storage, temperature regulation and flood

mitigation.

✓

As part of Airport Expansion Consultation One (January 2018) Heathrow presented

Our Design Approach to the Natural Environment, which included an approach to

multifunctional green infrastructure to achieve as much environmental and

community benefit as possible. The PEIR that Heathrow will consult on as part of the

Airport Expansion Consultation in June 2019, includes further details in regard to

mitigation proposals.




PC MC WC

There are insufficient details to comment

on at present and urged as much use of

green infrastructure as possible.

✓

No details were provided on how airlines

will be incentivised to deliver low carbon

flights or how it will be policed.

✓

Through variable landing charges, Heathrow charges the highest prices to the

noisiest and highest emitting aircrafts in order to encourage use of the greenest

aircrafts at the airport. Heathrow will continue this approach and is exploring how

this policy may evolve in the future to manage carbon emissions directly associated

with aviation. Further information on the measures proposed to manage carbon

emissions will be included in the PEIR, published as part of the Airport Expansion

Consultation in June 2019. Use and/or incentivise cleaner aircraft,

incentivise low carbon flights and

banning older, more polluting planes.

✓

Suggestions that the fee airlines pay to

operate at the airport should not remain

close to current levels but should reflect

the cost in harm to the environment.

✓

Heathrow should quantify the carbon

emission impacts before and after

mitigation to show its value.

✓ As required by the ANPS, within the ES published alongside the DCO application,

Heathrow will quantify the greenhouse gas impacts of the Project before and after

mitigation, to show the impacts of the proposed mitigation.




PC MC WC

More detail on the approaches that will be

used to limit carbon emissions and

concrete commitments which

demonstrate how Heathrow will

incentivise and monitor progress with

targets and penalties are requested.

✓

The information provided in Airport Expansion Consultation One (January 2018)

reflected the fact that the Project was at an early design stage. We will provide

further detail on mitigation measures aimed at managing carbon dioxide emissions

within the PEIR, published part of our Airport Expansion Consultation in June 2019.

The purpose of the Airport Expansion Consultation One was to provide an early

opportunity to provide feedback on options and components to inform the preferred

masterplan that will be presented as part of the Airport Expansion Consultation in

June 2019.

Concern that the emissions management

measures proposed will only offset or

mitigate in the short term.

✓

Heathrow have considered carbon emissions into the longer term. For example,

Heathrow are developing measures to ensure that the carbon associated with the

construction and operation of the airport itself is managed appropriately, working

towards its goal of operating zero carbon airport infrastructure by 2050. The Air

Quality and Carbon chapters of the PEIR, to be published as part of the Airport

Expansion Consultation in June 2019 will provide further details on the approach to

managing emissions.

Curiosity whether Heathrow would be

interested in exploring environmental

offsetting in the Chilterns, possibly in the

form of improved habitat management

✓ As required by the ANPS, Heathrow will need to demonstrate that the Project will not

result in an increase in emissions so significant that it would have a material impact

on the ability of Government to meet its carbon reduction targets, including carbon

budgets. In this context, we are developing measures to manage gross CO2

emissions, such as encouraging use of the latest (lower emitting) aircraft, uptake of

sustainable fuels and adoption of increasingly sustainable operating practices.

Looking beyond the ANPS requirement, our aspiration is to make growth from the

Project carbon neutral. This would mean that growth in emissions from additional

flights after expansion would be offset through carbon credits – resulting in no net

growth in emissions. Following a historic agreement in 2016 at ICAO, the UN body

Airlines should set aside money to plant

trees to absorb the Co2 as an offsetting

scheme.

✓

Carbon offsetting should be meaningful. ✓




PC MC WC

Carbon offsetting should be the last

resort once all the mitigation has been

implemented.

✓ for international aviation, the industry is working with governments to implement

CORSIA, the world’s first sector wide market-based measure for offsetting the

growth in international aviation emissions after 2020. In December 2018, Heathrow

published its plan for carbon neutral growth, and in 2019 will work with the aviation

industry, advocacy groups and climate change experts to seek further inputs.

We want to play a lead role in developing the next generation of high quality, cost

effective carbon offsetting in the UK. For example, we recently funded a project to

restore 70 hectares of peatland in the north-west of the UK, in partnership with the

Lancashire Wildlife Trust. This pilot scheme will stop this peatland emitting carbon,

and over time sequester it, and deliver other benefits, like more biodiversity value

and a lower risk of flooding downstream. It will help us offset a portion of emissions

from Heathrow’s own infrastructure to achieve our goal of carbon neutral

infrastructure by 2020.

Opposition to the use of carbon

offsetting.

✓

Carbon emission reduction goals should

be taken seriously and that measures to

reduce carbon emissions before

considering off-setting are implemented.

✓

Renewable diesel should be used in both

the operation and the construction of any

part of the airport to limit carbon

emissions.

✓ Heathrow are already putting in place measures to increase the number of low

emission vehicles operating at the airport. This includes replacing all Heathrow cars

and small vans with electric vehicles by 2020 and implementing standards for airside

vehicles in line with the London Ultra Low Emission Zone. We will also adopt

appropriate emission standards during construction of the Project through the Code

of Construction Practice, a draft of which will be published as part of the PEIR in

June 2019.




PC MC WC

Consideration should be given to the

waste hierarchy during operations,

specifically energy generation.

✓ Heathrow are committed to delivering a resource efficient, zero waste airport, as set

out in goal 10.3 of the Heathrow 2.0 sustainability strategy. This will include following

the waste hierarchy (reduce, re-use, recycle) in our approach to waste management

in the design, construction and operation of the Project. Heathrow is also actively

considering options to maximise the generation of renewable energy on-site (with

technologies that are compatible with airport operation) in preparing its masterplan.

Additional details of the carbon and air quality impacts of the project during both

construction operation will be provided in the Carbon and other greenhouse gasses

chapter in the PEIR, to be published as part of the Airport Expansion Consultation in

June 2019.

Effective baseline, monitoring and

periodic targets are important ensure

carbon reduction.

✓ Heathrow is in the process of developing a baseline for the carbon emissions

associated with construction activity, operations (e.g. fuel and energy use), travel to

and from the airport and aircraft movements. This is a critical aspect of the EIA

process and existing and future baseline data will be reported in the PEIR, to be

published in June 2019 as part of the Airport Expansion Consultation. The PEIR will

also include emission projections in the 3-runway scenario, based upon Heathrow’s

proposed mitigation measures.

Heathrow should publish the results of

their air quality assessments as well as

the embodied carbon and emissions

impact.

✓ The PEIR, which will be published in June 2019 as part of the Airport Expansion

Consultation, will report the initial findings of our air quality and carbon and other

greenhouse gases assessments. The PEIR will be followed by the ES, published in

support of the DCO application.

Proposals are based on old technology

and should include measures that ensure

all airport related vehicles are electric.

✓

In accordance with the ANPS, our mitigation proposals for managing potential

emissions associated with the Project will include encouraging use of zero- or low-

emission hybrid or electric vehicles (ultra-low emission vehicles) and providing




PC MC WC

EV infrastructure should be implemented

within and outside the airport to

encourage the adoption of low emission

vehicles.

✓

adequate charging infrastructure across the airport.

We are already putting in place measures to increase the number of low emission

vehicles operating at Heathrow. This includes replacing all Heathrow operated cars

and small vans with electric vehicles by 2020 and implementing standards for airside

vehicles in line with the London Ultra Low Emission Zone.

Limiting emissions and investment into

renewable energy sources is necessary.

✓ ✓ Heathrow’s objective is to develop an expanded airport that minimises carbon in its

operation and construction. This means carbon is a key criterion that informs our

thinking and the design of the Project ensuring, for example, that land is

safeguarded for renewable energy technology and flexibility is built into our designs

to enable new technologies to be adopted in the future.

In the near term, we’re maximising renewable energy generation onsite and already

purchase 100% renewable electricity.

Consideration should be given for

alternative fuel infrastructure especially

for freight transport.

✓

In designing the appropriate infrastructure at an expanded airport, Heathrow are

considering future trends in vehicle technology and fuel use. This includes, for

example, understanding the potential demand for electric vehicle charging

infrastructure in the future and ensuring adequate capacity is provided for both

passengers and those operating at the airport.




PC MC WC

Measures to increase public transport

use are vital to maintaining and reducing

the airport’s carbon emissions.

✓

Heathrow are developing a surface access strategy to meet targets set out in the

ANPS on public transport mode share (at least 50% of surface access passengers

arriving or departing from Heathrow by public transport in 2030 and at least 55% of

surface access passengers arriving or departing from Heathrow by public transport

in 2040), colleague car use reduction (25% reduction of all colleague car trips by

2030 compared with 2013 levels and 50% reduction of all colleague car trips by

2040 compared with 2013 levels) and the commitment that landside airport related-

traffic is no greater than today.



residents and initiatives that make public transport easier to use and change travel

behaviour more widely. A draft Surface Access Strategy will be published as part of


There is a need to make surface access

by sustainable transport as attractive and

easy as possible to reduce car use and

the influence on climate change.

✓ Heathrow are developing a surface access strategy to meet targets set out in the

ANPS on public transport mode share (at least 50% of surface access passengers

arriving or departing from Heathrow by public transport in 2030

and at least 55% of surface access passengers arriving or departing from Heathrow

by public transport in 2040), colleague car use reduction (25% reduction of all

colleague car trips by 2030 compared with 2013 levels and 50% reduction of all

colleague car trips by 2040 compared with 2013 levels) and the commitment that

landside airport related-traffic is no greater than today.



residents and initiatives that make public transport easier to use and change travel

behaviour more widely. A draft Surface Access Strategy will be published as part of




NATURAL ENVIRONMENT

Introduction

23.1.1 In response to Airport Expansion Consultation One Heathrow sought feedback in

relation to its proposed approach to managing the effects of the Heathrow

Expansion Project (the Project) on the natural environment. A total of 1,125

consultees made comments relating to this topic.

23.1.2 Heathrow provided the following material that is directly related to managing the

effects of the Project on the natural environment:

1. Airport Expansion Consultation Document;

2. Our Emerging Plans; and

3. Our Design Approach to the Natural Environment.

23.1.3 Heathrow asked the following questions regarding the natural environment at


1. Please tell us what you think about our approach to natural

environment issues.

2. Are there any opportunities that the expansion of Heathrow could provide to

enhance the natural environment?















23.1.5


Local Authorities

General comments

23.2.1 Local authorities provided general comments on the proposed approach to the

natural environment and potential enhancement opportunities. The majority of

those that responded considered that the natural environment should be protected

and enhanced. The importance of continued engagement and collaboration with

stakeholders including Natural England and the Environment Agency was also

highlighted.

23.2.2 Ealing Council considered that the approach was generally acceptable. They

supported the need for biodiversity offsetting and suggested that further

enhancements could be achieved through the improvement of local parks and

footpaths, to provide high quality walking and cycling routes for local communities.

23.2.3 Hampshire Services who responded on behalf of Central and Eastern Berkshire

Authorities indicated that high quality mitigation around Heathrow Airport for the

benefit of local communities and wildlife was required and should be implemented.

23.2.4 The London Borough of Islington commented that the social, economic and

environmental impacts of the proposed Heathrow airport growth and growth in air

travel should be examined. They stated that all proposals to expand London

airports and increase air travel should be subjected to a Strategic Environmental

Assessment.

23.2.5 The London Borough of Lambeth expressed concern that there were no costed

mitigation plans to address the environmental impacts of the Project.

23.2.6 Runnymede Borough Council considered that the environmental impacts must be

considered beyond the immediate area of development.

23.2.7 Slough Borough Council also supported the general approach to the natural

environment. They indicated that the overall strategy must retain the integrity and

connectivity of the Colne Valley Park as far as is possible and provide off-site

compensation and mitigation for any permanently used land. They also outlined

that Colnbrook and Poyle villages should be protected within a ‘Green Envelope’12.

12 A network of green spaces protected from development



23.2.8 The South East England Councils requested a stronger package of environmental

protection measures and requested that Heathrow work with councils in the South

East region.

23.2.9 Spelthorne Borough Council welcomed the consideration of integrated and

connected green infrastructure but expressed concern that this approach should

not result in a reduction in the amount of green infrastructure created or the

focussing of benefits into a very small area.

23.2.10 The London Borough of Sutton commented that it is not clear how the Project

could be anything other than detrimental to the natural environment.

Ecology

23.2.11 Mitigating the effects on ecology and biodiversity was cited by local authorities.

Where this was the case they indicated that the proposed approach to mitigating

the effects was generally acceptable and provided detailed comments or outlined

concerns about specific aspects of the proposals.

23.2.12 Buckinghamshire County Council supported the focus on the Biodiversity Strategy

2020 and the use of net gain, natural capital13 and green infrastructure concepts.

They also welcomed the design of connectivity within the proposals which they

recognised are often not included within major infrastructure projects.

23.2.13 They commented that the use of green infrastructure as the primary basis for

measuring success regarding the environment has potential disadvantages due to

the conflicting objectives. They indicated that the design of multifunctional space

needs careful consideration to avoid these conflicts.

23.2.14 They went on to highlight that the environmental mitigation and enhancements

proposed need to be evidence based, address legislative requirements and

provide general enhancements for wildlife. They also indicated that ecological

surveys and assessments must incorporate all impacted areas including an

adequate buffer.

23.2.15 The London Borough of Ealing supported the need for biodiversity offsetting where

loss or harm to habitats from the Project is unavoidable.

23.2.16 The London Borough of Hammersmith and Fulham commented that the negative

effect of the scheme on biodiversity was not acknowledged in the consultation

information. They expressed concern that the mitigation hierarchy was not being

used and indicated that a much more comprehensive approach is required.

13 the world's stocks of natural assets which include geology, soil, air, water and all living things.



23.2.17 The London Borough of Hounslow commented that biodiversity offsetting

approaches should not only consider the quantity and quality of the habitats but

also the significance of biodiversity linkages. They highlighted that the potential

indirect impacts and species specific recolonisation potential should also be

considered.

23.2.18 They highlighted that the development is likely to impact habitat used by

designated bat species and suggested that there are various sites east of the

airport that should be considered for bat habitat offsetting.

23.2.19 The Council sought clarity on how the loss of river habitat will be calculated and

offset, how the proposals will be enforced, what baseline will be used and how

progress will be monitored.

23.2.20 Runnymede Borough Council raised similar points about the scope of the

ecological assessments and indicated that wider impacts on nearby designated

sites must be considered e.g. the Thames Basin Heaths Special Protection Area.

23.2.21 Spelthorne Borough Council commented that there was little information specific to

local sites and wildlife which meant an assessment of impacts could not be

undertaken. They indicated that these, together with details of the protected

species for each of the sites, must be made available in future consultations.

23.2.22 They also made the following comments.

1. The diversion of Colne Valley Way through Staines Moor could lead to other

issues such as litter or disturbance to wildlife.

2. Staines Moor contains the oldest known colony of yellow meadow ants in the

whole country and would be affected by any work on the northern end of the

site. As a result, any development in this location would be strongly resisted.

3. Reduction of Bonehead woodland (an area of woodland to the east of Staines

Moor SSSI) would probably lead to the loss of the deer and would reduce the

habitat available to many species of bird.

4. Any work on the Staines Moor floodplain would disturb wildlife and could also

alter the amount of water on the floodplain. This could lead to a change in the

historical composition of habitats and a knock-on reduction in biodiversity.

5. The whole of Staines Moor should be designated as a proposed protected

species site and should not be included within the potential development area.

23.2.23 Surrey County Council expressed concerns about whether compensatory habitats

can be achieved if Compulsory Purchase Order (CPO) powers cannot be used.

They commented that there needs to be further detail on how any habitat

compensation land will be managed and highlighted that wildlife corridors should

be at least 100m wide.



23.2.24 The Royal Borough of Windsor and Maidenhead highlighted the importance of the

Colne Valley to the Borough and surrounding areas. They questioned how

mitigation would be maintained in the longer term if not part of the Development

Consent Order (DCO) application.

Landscape

23.2.25 The London Borough of Hounslow commented that greening measures would be

likely to bring economic, health and tourism benefits. They also suggested that

mitigation measures to maintain or improve facilities could be part of the ‘quality of

life’ fund proposed by the council to mitigate the effects of the Project on local

communities and could include:

1. tree planting;

2. improvement of nearby green areas;

3. public transport to green areas;

4. free or low cost indoor play places;

5. high intensity play places (e.g. climbing wall) at low cost; and

6. enhanced school green spaces that are accessible after school and on

weekends.

23.2.26 Spelthorne Borough Council commented that Heathrow’s ‘Our Design Approach to

the Natural Environment’ only included a very brief section on landscape and

visual amenity and requested considerably more detail.

Watercourses/Flood risk

23.2.27 Runnymede Borough Council commented that any proposals need to be

considered in a holistic manner, with links to other strategic interventions in the

surrounding area also being considered, for example the River Thames Scheme.

23.2.28 South Bucks District Council commented that new ponds and lakes could benefit

and compensate the local area if done well and queried whether these would be

included in the DCO.

23.2.29 The Royal Borough of Windsor and Maidenhead considered that there was

insufficient information presented to allow an assessment of impacts on

watercourses. They expressed concern that local authorities have not been

consulted on potential sites for flood storage and that the proposals may impact

existing flood alleviation schemes.


General comments



23.2.30 Natural England and the Environment Agency both welcomed the principles

outlined in Heathrow’s ‘Our Design Approach to the Natural Environment’

document, presented at Airport Expansion Consultation One. They both

emphasised the need for detailed assessments to be undertaken and provided

comments on the proposed approach.

Ecology

23.2.31 Natural England welcomed measures to ensure net gain for biodiversity and

encouraged Heathrow to make a firm commitment. They highlighted that the

biodiversity metric designed by Defra has been used for a number of major

developments and recommended that industry good practice published by CIEEM,

IEMA and CIRIA should be used when designing the approach.

23.2.32 They highlighted a comprehensive suite of biodiversity surveys will be required to

establish current populations of protected species within and around the

development area and the likely impact of the proposals upon them. These will

also inform biodiversity offsetting or net gain calculations.

23.2.33 Natural England indicated that a large number of lakes to the north west of

Heathrow Airport are likely to function as supporting habitat for the South West

London Water Bodies Special Protection Area (SPA). Some of these sites are

likely to be impacted by construction which will need consideration as part of the

Habitats Regulation Assessment (HRA).

23.2.34 The importance of the network of locally protected sites for biodiversity and local

communities was also highlighted and they requested that Heathrow examine

opportunities for enhancing the connectivity of these sites for the benefit of people

and wildlife.

23.2.35 Natural England also highlighted that management and maintenance of green

infrastructure should be integrated into the Project design. This could include

green features, such as green walls, green roofs and green bridges, which would

improve the resilience of the development whilst also protecting the building fabric

from sunlight and temperature fluctuations, reducing costs, reducing noise,

providing visual features of interest, capturing air pollutants and dust and providing

wildlife habitat.

23.2.36 The Environment Agency commented that biodiversity offsetting and environment

net-gain principals should be followed. They considered that rivers should be

defined as having high distinctiveness and condition assessments should use a

wide suite of techniques to measure the biological quality.

23.2.37 They also highlighted that connectivity should be maintained and enhanced for

terrestrial mammals and that unhindered fish migration will help to prevent

ecological impacts outside of the footprint of the Project.

Landscape



23.2.38 Natural England welcomed the provision of high quality, connected, integrated and

multifunctional green infrastructure and supported the aim of connecting local

people to the natural environment. They highlighted that good quality design will

be required to ensure effective north/south movement within the Colne Valley

Regional Park.

23.2.39 They welcomed the inclusion of landscape design as part of the integrated green

infrastructure aim and indicated that it could deliver additional benefits for

landscape and visual amenity. However, they commented that no details of the

approach to Landscape Visual Impact Assessment were provided and as a result

could not comment.

23.2.40 They also highlighted that the Project may disrupt recreational walking routes and

suggested that Heathrow take account of local authority open space strategies or

rights of way improvement plans to identify possible enhancements.


23.2.41 Natural England commented that water discharged from Heathrow Airport must be

effectively treated and pollutants removed. They highlighted the success of

Mayfield Farm reedbeds (which were installed to treat run-off from Heathrow’s

Southern Catchment) and encouraged the use of similar systems. However, they

suggested that consideration should be given to the integration of drainage and

pollution controls with the green infrastructure masterplan.

23.2.42 They expressed concern that the increase in non-permeable material across the

development site will alter the effects on ground water, aquifer recharge and

connections with river channels. They recommended that existing flows within the

nearby water courses are maintained alongside the use of Sustainable Drainage

System (SuDS).

23.2.43 The Environment Agency expressed concerns that need for long-term monitoring

had not been mentioned.

23.2.44 They indicated that naturalised flow regimes within the modified river channels and

improved connectivity through all channels will be required. They considered that

the issue of connectivity could not be delivered solely through the Colne Brook

diversion option.

23.2.45 They recommended that dimensions of local River channels should be used to

define the physical characteristics of the modified ones. They supported the use of

infiltration SuDS but indicated that a large part of the area of the Project contains

licensed and historic landfills or land which may be affected by contamination. As

a result, infiltration SuDS may not always be an appropriate option.

23.2.46 The Environment Agency also highlighted that the water table is at a very shallow

depth and susceptible to contamination. They specified that if any infiltration SuDS

are proposed for areas where there is a potential for an accidental spill of



contaminants, such as car parks, then appropriate pollution prevention measures

must be in place.

Other prescribed bodies

General comments

23.2.47 Windlesham Parish Council welcomed the proposed approach to the natural

environment but sought clarification whether Heathrow will maintain the

environment surrounding Project area. The Parish Council also drew attention to

the opportunity to create cycle routes which will encourage visitors and increase

cycling.

23.2.48 Bray Parish Council commented that the aims and intentions towards the natural

environment are commendable but unachievable as existing habitats will be

disturbed and destroyed. They also indicated that the effects of light pollution need

to be considered and requested further consultation.

23.2.49 The Heathrow Strategic Planning Group (HSPG) commented that a health impact

assessment should be central to all environmental considerations and highlighted

that those responsible for local resources should be consulted to design lasting

managed solutions.

Ecology

23.2.50 The HSPG commented that sites designated for nature conservation must be

protected and enhanced. Local wildlife sites and undesignated habitats must be

conserved and enhanced with ongoing monitoring, maintenance and

management. They considered that where loss or harm is unavoidable,

biodiversity off-setting should be provided locally.

23.2.51 They also highlighted that the Green and Blue infrastructure strategy should drive

the design process and be intertwined into all proposals.

23.2.52 Iver Parish Council commented that the Colne Valley Regional Park will be

fundamentally changed by the Project. As a result, they considered that any Green

and Blue Infrastructure Plan should extend to The Ivers.



Landscape

23.2.53 Albury Parish Council were critical of the focus on the immediate vicinity of

Heathrow and suggested that the natural environment of the Surrey Hills AONB

should be equally respected.

23.2.54 Iver Parish Council commented that landscape mitigation should enhance the local

environment for wildlife and ecology as well as for residents, employees and

visitors. It should also improve site connectivity by land and water wherever

possible. They requested further information on the proposals and expressed

support in principle for the protection and enhancement of green belt land.


23.2.55 The HSPG indicated that Colne Brook should be retained as an open channel with

the other watercourses remaining as open channels as much as possible. They

commented that the Rivers, water bodies and storage are interconnected systems

and need to be considered together. They also requested further information on

surface water run-off and any exceptional release of polluted waters.

23.2.56 Thames Water commented that the best available technology with respect to

water efficiency should be used within all new supporting facilities and terminal

buildings. They also encouraged rain and greywater harvesting and recycling to

meet non-potable water needs. They highlighted that SuDS need to be considered

in the design of drainage for all large areas of hard standing (including car parks).

23.2.57 Iver Parish Council highlighted that strategic corridors are provided in Iver by the

Rivers Colne, Colne Brook, Alderbourne and Horton Brook and their drains and

tributaries. These waterways extend through the Colne Valley and must be

protected and enhanced to counter the effect of culverting and diverting flows

downstream.

23.2.58 They also expressed concern that each proposal is considered as a separate

scheme without an overall view on the impact to surface water, drainage and

flooding.

Local Communities


General

23.3.1 The majority of members of the public that made comments in relation to the

natural environment expressed negative views.

23.3.2 The concerns raised were wide ranging and covered the effects on wildlife habitats

and species, the Green Belt and green open spaces, watercourses, recreational

areas, the landscape and the environment in general.



23.3.3 Respondents stated that the enhancement of the natural environment would be

impossible given the impacts of the existing airport and the expansion proposals.

Reservations were also expressed about whether the mitigation measures would

ever be delivered.

23.3.4 Respondents expressed support for the preservation and enhancement of the

natural environment. They stated that protecting and mitigating effects on the

natural environment was necessary and fair, that there could be benefits for

habitats and wildlife, that effects on environmentally sensitive and valued sites

should be minimised as far as possible and that sites for development should

avoid important landscapes and designated green belt.

23.3.5 Those that expressed support for the proposals also indicated that more could be

done to protect the natural environment. These were often accompanied by

requests for further detailed information.

Ecology

23.3.6 Comments received either considered that the Heathrow’s approach to the natural

environment would be beneficial for wildlife and people or raised concerns about

wildlife sites or species that would be impacted. The latter included concerns

about the effects on the Colne Valley Regional Park, Crown Meadow, the Thames

Basin SPA, the River Crane, ancient woodland and number of species of wildlife.

23.3.7 Suggestions were also received about the following factors that should be

considered further:

1. more trees should be planted;

2. greater consideration should be given to the impact on wildlife and habitats;

3. new/additional green spaces should be created;

4. any negative impacts should be mitigated as much as possible;

5. experts and environmental groups should be consulted;

6. green spaces should be maintained and managed for the long term;

7. locations proposed for supporting facilities should be turned in to green spaces

and parks after being used for construction;

8. flood storage areas and habitats that may attract birds should be away from the

airport;

9. wildlife parks and a wildlife centre should be created; and

10. contributions should be made to improving a country park along the

River Colne.

Landscape



23.3.8 Comments on the landscape either highlighted the benefits of the proposals to the

natural environment and local communities or raised concerns that the proposals

failed to consider local people, would result in a loss of green space/recreational

facilities or were generally insufficient.

23.3.9 The following suggestions were also received about factors that should be

considered further:

1. more trees should be planted;

2. consideration should be given to using trees/landscaping and the soil/waste

material as embankments to act as noise barriers;

3. new/additional green spaces should be created;

4. any negative impacts should be mitigated as much as possible;

5. more consideration should be given to the landscape such as creating

parks/parkland landscapes around the airport;

6. new recreational spaces for people should be created;

7. more could be done to improve public walking and cycling access to the natural

environment;

8. dedicated/segregated cycle paths and footpaths should be created;

9. natural/sustainable design measures should be incorporated;

10. attractive landscaping and design would reduce the landscape and visual

impacts of the Project;

11. consideration needs to be given to impacts on the countryside and

enhancement of amenity as part of the approach to the natural environment;

12. green corridors / buffer zones between the airport and neighbouring residential

areas including Stanwell and Stanwell Moor should be retained and enhanced;

13. consideration should be given to creating a botanic garden landscape; and

14. impacts on green/open spaces and the countryside should be minimised.

Watercourses/Flood Risk

23.3.10 Those members of the public that commented on watercourses/flood risk either

expressed concerns about an increased risk of flooding or suggested that

disruption to waterways should be minimised, flood prevention targets should be

promoted or that SuDS should be used.

Businesses

General



23.3.11 The London Airline Consultative Committee and the Board of Airline

Representatives noted that whilst they were supportive of using the Project as an

opportunity to enhance the natural environment, it should not add delay to the

construction phase, increase risks, costs and complexity to airport users. They

also commented that such proposals should be funded though other mechanisms

that do not pass on costs to airport users.

23.3.12 The Copas Partnership noted the importance of ‘green lungs’ but highlighted that

airports are not a natural environment.

23.3.13 The Arora Group commented that there was insufficient supporting information to

allow further comment and understand the approach taken to date. They identified

that Heathrow had failed to take account of the environmental characteristics of its

alternative development proposals.

23.3.14 The Surrey Chamber of Commerce highlighted that it considered Heathrow had

adopted a responsible approach to the natural environment. They suggested that

an educational centre would provide further enhancement for the natural

environment.

23.3.15 The Hampshire Chamber of Commerce noted that Heathrow is located between

areas of importance for tourism, leisure and heritage. They considered that the

appropriate development of Heathrow Airport could enhance these sectors.

23.3.16 The Thames Valley Chamber of Commerce commented that the Project provides

an opportunity for Heathrow to deliver a step change in the quality of natural and

historic environment in and around the airport. They considered that creating a

positive long-lasting legacy should be a core component of the development.

Ecology

23.3.17 Jayflex Construction Limited commented that in order to maximise environmental

enhancements and biodiversity offsetting proposed on land at Horton Brook

Quarry, the land must be protected from development. It commented that areas of

parkland and open space previously created in the vicinity of the airport suffer from

underuse and neglect, often because of concerns over lack of safe parking,

security and isolation.

23.3.18 They suggested that one possible solution would be to protect the new parkland

area by developing a small area of light industrial units in Horton Brook Quarry

along the Horton Road. This would maintain a continual presence in the area and

create a buffer zone to defend against fly tipping and illegal occupation.

23.3.19 The Thames Valley Chamber of Commerce highlighted that the protection,

enhancement and re-introduction of indigenous species and habitats would be a

long-lasting legacy.

Landscape



23.3.20 GlaxoSmithKline commented that the proposed cycle route around the airport

could be attractive for its employees provided it is built to a high standard. To

achieve this, they considered that the cycle route needs to be integrated into a

landscape zone and not just placed immediately next to the perimeter road or

airport fence.


23.3.21 The Airport Industrial Property Unit Trust assumed that all proposals concerning

rivers/watercourses will not detrimentally affect any of the assets within their

property portfolio.

Community groups

23.3.22 Many of the community groups who provided feedback to Airport Expansion

Consultation One expressed opposition to the Project but did not necessarily

include specific feedback on the natural environment.

23.3.23 Those that did often raised concerns about the effect of the Project on the natural

environment and the lack of detail or made specific suggestions about aspects of

the environment or factors that should be considered further.

General

23.3.24 Slough and District Against Runway 3, Residents Association HVG, Englefield

Green Action Group, Aircraft Noise Three Villages, St Albans Quieter Skies,

Eastcote Residents Association, Stanwell’s Green Lungs and Colnbrook

Community Association all indicated that the Project will harm the environment

and that this harm will not be offset by the measures proposed.

23.3.25 Wentworth Residents’ Association supported efforts to offset impacts on the

environment but considered that effects cannot be adequately offset.

23.3.26 The Camberley Society highlighted the importance of protecting biodiversity and

wildlife and challenged Heathrow to be one of the 'greenest' airport developments.

23.3.27 Harrow U3A Sustainability Group welcomed measures to maintain continuity of

green space along northern boundary and along the Colne. They considered these

measures essential to prevent discharges into the Colne along the western edge

of airport.

23.3.28 The Richmond Environmental Information Centre considered the plans to be

inadequate and lacking detail.

Ecology

23.3.29 Local Conversation in Stanwell commented that wildlife corridors are visible and

lead into surrounding areas of biodiversity. They considered that the diversion of

Colne Valley Way through Staines Moor could be positive but could lead to other

issues such as litter or disturbance to wildlife.



23.3.30 They also made the following comments.

1. Staines Moor contains the oldest known colony of yellow meadow ants in the

whole country and would be affected by any work on the northern end of the

site. As a result, any development in this location would be strongly resisted.

2. Bonehead woodland provides a home for many bird species and a small

population of deer. Reduction of this small area of woodland would probably

lead to the loss of the deer and would reduce the habitat available to many

species of bird.

3. Any work on the Staines Moor floodplain would disturb wildlife and could also

alter the amount of water on the floodplain. This could lead to a change in the

historical composition of habitats and a knock-on reduction in biodiversity.

4. The whole of Staines Moor should be designated as a proposed protected

species site and should not be included within the potential development area.

23.3.31 Colnbrook Community Partnership commented that the wildlife corridor through

Crown Meadow is very narrow and would need to be further reduced if river

diversion Option C1F and/or A3044 replacement were to go through Crown

Meadow. They also highlighted that burying the National Grid overhead cables

through Crown Meadow would severely affect the biodiversity value of the site

unless the site were restored and a net gain in biodiversity achieved. The

Partnership also expressed opposition to the diversion of the Colne Valley Way to

the west, commenting that it should follow the alignment of the potential primary

cycle route which appears to be along the Colne Brook.

Landscape

23.3.32 Local Conversation in Stanwell commented that there was only a very brief section

on landscape and visual amenity in the consultation documents and that more

detail is required.

23.3.33 They highlighted that the proposed cycle route appears to connect well to the

surrounding area but that further investment is needed around Stanwell/Stanwell

Moor to connect the current off airport routes with the routes within the airport

boundary. They also commented that the cycle route along the Southern

Perimeter Road should be extended to link up with routes to Terminal 4 and

Bedfont.


23.3.34 Colnbrook Community Partnership highlighted that along the river courses in

Slough (the Horton Brook and the Colne Brook) there are numerous fallen trees in

the water which impede flow, particularly during flood events. They suggested that

the removal of the fallen trees would enhance the natural environment and help to

reduce flood risk and this should be undertaken as part of overall measures to

improve the habitat along the watercourses.



23.3.35 Eastcote Residents Association commented that the loss of wildlife habitat and

putting rivers underground is unacceptable. They considered that the effects of the

Project on the Colne Valley Regional Park should not be allowed to happen.

Wider/other Consultees

23.4.1 The majority of those that responded indicated support for aspects of the approach

and made specific suggestions about factors or sites that should be considered

further. The importance of engagement with relevant stakeholders in the further

development of the proposals was also highlighted.

General

23.4.2 The Kingston Environment Forum and the World Federalist Party considered the

plans to be inadequate and lacking detail.

23.4.3 The Buckinghamshire and Milton Keynes Natural Environment Partnership

indicated that all aspects of the environment and the benefits it provides to people,

wildlife and the economy should be taken into account in options development and

any future stages of the Project.

23.4.4 They requested that Heathrow commit to a long-term measurable net gain in

biodiversity and make use of a recognised biodiversity accounting metric. They

also highlighted the importance of:

1. early and strategic planning of green and blue infrastructure;

2. minimising the impact on protected areas and land take within wildlife and

recreation areas;

3. employing best practice to integrate biodiversity and green infrastructure into

the design of the development;

4. working closely with environmental stakeholders; and

5. ensuring any works and compensation integrates with existing priorities,

habitats, environmental functions and benefits.

23.4.5 Friends of the River Crane highlighted the need for an overall masterplan for open

spaces covering the whole of the area covered by the consultation exercise. They

cited impacts on the local area, opportunities for improvements and benefits to

local communities and challenges to the preservation of the green belt and

Metropolitan Open Land as reasons for this need. They also commented that the

scope of this masterplan should be developed with key stakeholders.

23.4.6 The Colne Valley Regional Park commented that the Heathrow’s Design Approach

to the Natural Environment document, published at Airport Expansion Consultation

One, is too vague to provide detailed comment.



23.4.7 The National Trust highlighted the requirements of relevant national, regional and

local planning policy and the need to address the potential impact on the Colne

Valley Regional Park. They expressed concerns that the Project will be likely to

result in significant environmental effects and indicated that they wished to be

consulted on the DCO application and Environmental Impact Assessment

documentation in due course.

23.4.8 The London Parks and Gardens Trust welcomed the inclusion of more

opportunities for the public to visit the proposed landscaped areas. They

suggested that participation in events such as Open Garden Squares Weekend

would go some way to allowing the public a greater understanding of the natural

landscape around the airport.

23.4.9 The London Wildlife Trust and Surrey Wildlife Trust both welcomed Heathrow’s

design approach and commitments to create a positive legacy of better, well

connected green infrastructure and maintain current populations of animals and

plants.

23.4.10 The Royal Parks expressed concern about the effects on grasslands in Richmond

Park, Bushy Park Kensington Gardens, Primrose Hill, Regents Park and

Greenwich Park. They considered that it should be part of the project to improve

the natural habitat surrounding the airport and that green areas should link

together to provide wildlife corridors.

23.4.11 Lambeth/Herne Hill Green Party commented that the approach to the natural

environment needs to be led by Biodiversity Officers and environmental advisers.

23.4.12 The Church of England Diocese of London, Oxford and Southwark welcomed

individual mitigation measures but challenged the idea that the Project provides a

unique opportunity to deliver high quality mitigation. They considered that it would

be better to avoid the harm altogether.

Ecology

23.4.13 London Wildlife Trust noted that many of the proposals were too vague to allow

anything other than generic comments. They commented an overall gain in

biodiversity should be a legally-binding commitment and that they were happy to

work with Heathrow to identify potential sites and strategies to ensure they can be

managed and maintained.

23.4.14 They welcomed the consideration of the All London Green Grid but indicated that

this should also take account of the habitat restoration and creation targets in the

Mayor’s London Environment Strategy, Biodiversity Action Plan targets, the

Wildlife Trusts’ Living Landscapes, and the Crane and Colne catchment plans.

They also highlighted the Colne Valley as an area of significant focus as it is one

of the most affected landscapes by the Project. They suggested that further

information on implications of the proposed flood storage areas/lakes/rivers on bird

strikes should be made available.



23.4.15 The Hertfordshire and Middlesex Wildlife Trust stated that the proposal must

achieve a measurable net gain to biodiversity. They considered that the ecological

impact of the plans must be fully understood and informed by ecological survey.

23.4.16 They considered that development should not be permitted until all ecological

measures necessary to achieve net gain have been fully secured. They

recommended the establishment of an ecological steering group to review surveys

and guide ecological mitigation, compensation and enhancement.

23.4.17 The Surrey Wildlife Trust also considered that there should be a net gain for

biodiversity and suggested that a commitment to this should be made. They

sought clarity on the purpose of the Potential Protected Species Area and queried

whether this relates to the existing location of protected species or is a designated

refuge for translocated species.

23.4.18 They welcomed the intention to use a natural capital and Ecosystem Services

approach to measure the overarching impacts of the Project on the natural

environment and recommended that Heathrow consider the use of the Surrey

Nature Partnership Natural Capital Investment Plan.

23.4.19 Friends of the River Crane commented that the risk of bird strike results in controls

being put on the habitats around an airport runway. They indicated that these

approaches already impact upon the diversity and management of wildlife habitat

within the river corridors around the airport (including within the Crane corridor)

and assumed that it would be necessary to increase these areas. They highlighted

that such restrictions have a negative impact upon the existing or potential wildlife

management opportunities over a wider surrounding area and this should be

evaluated during the ongoing assessment process.

23.4.20 The Colne Valley Regional Park commented that Heathrow must ensure a net

gain for biodiversity. They indicated that they would be happy to work with

Heathrow to identify potential sites and strategies to ensure they can be managed

and maintained. They also indicated that compensation for the permanent loss of

Colne Valley Regional Park land in the south should be provided by expanding the

Park boundaries.

23.4.21 They also highlighted the need for a Green and Blue Infrastructure Plan and a

number of opportunities for mitigation within the Park. They indicated that the key

elements of the Green and Blue Infrastructure Plan must be included in the DCO

application to ensure they can be delivered, managed and maintained.

23.4.22 The Surrey Bat Group also indicated that a net gain to biodiversity should be

ensured. They indicated that they would like to see surveys (and impact

assessment results) as soon as they become available.

23.4.23 The Buckinghamshire and Milton Keynes Natural Environment Partnership

highlighted the value of green infrastructure and indicated that it must be

considered and planned for. They commented that Heathrow needs to go beyond



its current commitments and commit to a net biodiversity gain. They also urged

the use of a recognised biodiversity accounting metric, based on the one produced

by Defra.

23.4.24 They indicated that biodiversity offsets should be located locally to maximise the

creation of ecological networks and should consider priority habitats and species,

priority areas for biodiversity and wildlife investment, local wildlife sites and

opportunities to extend, enhance, create and connect habitats and green

infrastructure for wildlife and people.

Landscape

23.4.25 The London Parks and Gardens Trust considered that insufficient account has

been taken of the loss of amenity value for many of the surrounding parkland and

nature rich areas as a result of the increased air traffic. They considered that an

endowment fund, grant scheme or additional flight levy should be set up for

London's public Parks to support their maintenance and enhancement.

23.4.26 The Colne Valley Regional Park commented that open green spaces need to

include walking routes and cycling paths which link with the wider Colne Valley

Park, other green spaces and walking/cycling corridors surrounding the airport.

They indicated that provision of recreational areas should also consider areas

further away which less affected by the airport

23.4.27 They also commented that Heathrow should extend the Colne Valley Trail further

south and explore enhancement of existing sections of the Colne Valley Trail.


23.4.28 Friends of the River Crane commented that there must be no negative impacts

upon water quality in the River Crane and that the risks of pollution minimised

through appropriate planning, design and operational controls.

23.4.29 The Colne Valley Regional Park commented that the proposed flood storage areas

will need to form part of the Green and Blue Infrastructure Plan. They highlighted

that opportunities for constructed wetlands that deliver open green spaces should

be explored and that a fully integrated SuDS, drainage and storm management

strategy is required.

23.4.30 The London Wildlife Trust indicated that the proposed flood storage areas need to

form part of the green infrastructure plan. The suggested that opportunities for

newly created wetlands should be explored that meet water quality standards and

flood requirements whilst also delivering open green spaces.



23.4.31 The Wildlife Trust also suggested that a fully integrated SuDS, drainage and storm

management strategy within the airport is required and that is should consider

opportunities for integrated green roofs, living walls, and swales14.

23.4.32 Surrey Wildlife Trust challenged the claim that the proposals would protect rivers

and their associated vegetation corridors when over one kilometre of the diverted

rivers would flow beneath the new runway, essentially below ground.

14 Swales are shallow, broad and vegetated channels designed to store and/or convey runoff and remove pollutants





consultees in relation to Natural Environment. None of the feedback received in relation to Natural Environment are directly

related to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation

(January 2019) but instead relate to other aspects of the Project. The table therefore provides a summary of the way in which

we are seeking to consider the issues raised, and are provided for information only. No further feedback is being sought on the

basis that a full consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.

Table 23.1B


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The natural environment should be protected and

enhanced.

✓ The Heathrow Expansion Project (the Project) is being developed in

accordance with the designated Airports National Policy Statement

(ANPS) which identifies the need for the Project to meet additional

airport capacity in the South East of England during the short, medium

and long term. Habitat creation and enhancement proposals will be

designed to ensure that the biodiversity interest of designated sites in

this area will be maintained and where possible, enhanced.

As part of the development of the Project, proposals for landscaping,

It would be better to avoid the harm from the

Heathrow Expansion Project altogether.

✓

Note the importance of ‘green lungs’ but highlighted

that airports are not a natural environment.

✓





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The Project provides an opportunity for Heathrow to

deliver a step change in the quality of the natural

environment in and around the airport.

✓ mitigation and compensation works (‘green infrastructure’) are being

developed that will form a network of connected green spaces and

water environments in the vicinity of the Airport. This network will help

provide biodiversity habitats, with Heathrow working to achieve a net

gain in biodiversity.

Heathrow are undertaking an Environmental Impact Assessment (EIA).

This assessment has informed the design of the Project, through an

ongoing evaluation process. Early findings of this process will be

reported in the Preliminary Environmental Information Report (PEIR)

and the Updated Scheme Development Report to be published at the


The delivery of the expanded airport will impact on the existing natural

environment. As part of the process the Project will carry out an

assessment of habitats and species. However, it also presents an

unprecedented opportunity to deliver high quality mitigation for green

infrastructure in the local area. The preferred masterplan which will be

published as part of the Airport Expansion Consultation in June 2019

will include areas which could be landscaped, planted, restored or

enhanced in order to mitigate and off-set the effects of the Project as

far as possible.

Concerns about wildlife sites or species that would

be impacted.

✓

Happy to work with Heathrow to identify potential

sites and strategies to ensure they can be managed

and maintained.

✓ Heathrow are considering a range of options for ecological mitigation,

compensation and enhancement and are engaging stakeholders in the

process. A detailed collaborative and multidisciplinary approach to the

evaluation and selection of options is being undertaken. This includes

engagement with a range of stakeholders including the Heathrow

Strategic Planning Group (HSPG) and Natural England as part of the

EIA as well as consideration of the feedback received in relation to

Airport Expansion Consultation One. Heathrow will present its

preferred option and the early findings of its assessments in the PEIR

that will be published as part of the Airport Expansion Consultation in

Requested that Heathrow work with councils in the

South East.

✓

Recommend the establishment of an ecological

steering group to review surveys and guide

✓




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ecological mitigation, compensation and

enhancement.

June 2019.

Would like to see surveys (and impact assessment

results) as soon as they become available.

✓ Heathrow are considering a range of options and are engaging

stakeholders in the process. A detailed collaborative and

multidisciplinary approach to the evaluation and selection of options is

being undertaken. Heathrow have shared the early findings of the

biodiversity surveys with stakeholders and will present the early

findings of this assessment, information on surveys that have been

undertaken and their findings in the PEIR which will be published as


Participation in events such as Open Garden

Squares Weekend would go some way to allowing

the public a greater understanding of the natural

landscape around the airport.

✓ The government has established the need for the Project within the

ANPS. The ANPS expresses the need for the applicant to ensure the

functionality and connectivity of the green infrastructure is maintained

and to mitigate any adverse impacts where possible.

Heathrow today is actively involved in number of external events and is

open to exploring new events.

Heathrow has a number of existing relationships with local educational

facilities and opportunities to promote further learning about the natural

environment will be with them. The Project also presents an opportunity

to deliver high quality mitigation for communities through green

infrastructure in the local area, taking the consultation responses

received into account and facilities, such as educational or visitor

centres to aid understanding of the natural and historic environment.

Heathrow are considering a range of options and are engaging

stakeholders in the process. A detailed collaborative and

multidisciplinary approach to the evaluation and selection of options is

being undertaken.

Heathrow will present its preferred masterplan and the early findings of

An educational centre would provide further

enhancement for the natural environment.




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this assessment in the Updated Scheme Development Report.

Information on surveys that have been undertaken and their findings

will also be published in PEIR. Both of these documents will form part

of the Airport Expansion Consultation in June 2019.

Concerns that need for long-term monitoring had not

been mentioned.

✓ A draft Biodiversity Off-setting Plan will form part of the Airport

Expansion Consultation in June 2019. The ANPS states that in terms

of off-setting and biodiversity mitigation that areas that will provide the

most ecological and ecosystem service benefits should be focussed

on.

It will include long term management prescriptions, a monitoring

protocol and a method to determine suitable remediation should any be

required.

Welcome the intention to use a Natural Capital and

Ecosystem Services approach to measure the

overarching impacts of the Project on the natural

environment and recommended that Heathrow

consider the use of the Surrey Nature Partnership

Natural Capital Investment Plan.

✓ Heathrow will use the natural capital concept in its approach to

expressing the value of nature to society and the effects of the Project

on the local natural environment. The use of monetary values is not

intended to put a price tag on nature, but to demonstrate one of many

services that the local natural environment provides to communities.

The approach will also include quantitative assessments of natural

capital and ecosystem services to allow for other ways of assisting

decision making on the Project.

During 2018 Heathrow has been developing the Natural Capital

approach and methodology with Natural England based upon the

Natural England draft ecometric. In order to agree our natural capital

approach with Natural England we looked at various industry examples

to help inform that strategy but the approach we are adopting is not that

of the Surrey Nature Partnership Natural Capital Investment Plan.

Supported the focus on the biodiversity strategy

2020 and the use of net gain, Natural Capital and

green infrastructure concepts.

✓

Whilst supportive of using expansion as an ✓ ✓ The delivery of the Project will impact some areas of the existing




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opportunity to enhance the natural environment, it

should not add delay to the construction phase,

increase risks, costs and complexity to airport users.

natural environment and However, Heathrow are considering

opportunities to deliver high quality mitigation for green infrastructure,

biodiversity (wildlife and plants), the landscape and the water

environment (rivers, ponds and streams) for the benefit of both local

communities and wildlife in the local area as part of the Project is a key

aspect of the ANPS. However, any enhancements that are required (in

order to deliver specific mitigation and legal compliance) within or

adjacent to the areas within which construction or operational activity

will be necessary will be designed in-conjunction with the delivery

teams to ensure delays and increased cost can be managed

effectively.

Heathrow also aim to ensure that the expanded airport will operate with

passenger charges staying as close to 2016 levels as possible.

As part of the development of its proposals Heathrow is considering

areas which could be landscaped, planted, restored or enhanced in

order to mitigate and offset the effects of the Project. Further details on

the proposals for landscaping and the enhancement of the natural

environment will be reported in the PEIR which will be published as


It is not clear how expansion could be anything other

than detrimental to the natural environment.

✓ The delivery of the Project will impact the existing natural environment.

However, Heathrow are considering opportunities to deliver high quality

mitigation for green infrastructure, biodiversity (wildlife and plants), the

landscape and the water environment (rivers, ponds and streams), for

the benefit of both local communities and wildlife in the local area. In

accordance with paragraph 5.127 of the ANPS, the Secretary of State

will need to assess whether very special circumstances justify potential

changes to the Green Belt. Heathrow will need to demonstrate that

such circumstances exist for the Project.

The enhancement of the natural environment would

be impossible given the impacts of the existing

airport and the expansion proposals.

✓

Support for the preservation and enhancement of the

natural environment.

✓




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More could be done to protect the natural

environment.

✓ Heathrow are undertaking an EIA, which includes an assessment of

impacts on the natural environment and Green Belt. This assessment

is informing the design of the Project, through an ongoing evaluation

process. Early findings of this process will be reported in the PEIR and

the Updated Scheme Development Report to be published at the


Concerns about the effects on wildlife habitats and

species, the Green Belt and green open spaces,

watercourses, recreational areas, the landscape and

the environment in general.

✓

The Approach to Natural Environment is too vague to

provide detailed comment.

✓ The information provided in Airport Expansion Consultation One

reflected the fact that the Project was at an early design stage. Further

information regarding statutorily and non-statutorily designated sites,

including early findings from our EIA work regarding potential effects

upon them, will be provided will be contained within the PEIR which

forms part of the Airport Expansion Consultation in June 2019.

Paragraph 5.89 of the ANPS expects that the ES submitted with the

Development Consent Order (DCO) sets out clearly the likely

significant impacts on local, national and nationally designated sites

and factors that are of principal importance for the conservation of

biodiversity.

Heathrow’s plans for the natural environment were

inadequate or lacking detail.

✓

Opposition to the expansion of Heathrow and as a

result a number did not make comments on the

natural environment.

✓

Concerns about the effect of expansion on the

natural environment and the lack of detail

✓

Many of the proposals were too vague to allow

anything other than generic comments.

✓

Insufficient supporting information to allow further

comment and understand the approach taken to

date.

✓

Requests for further detailed information. ✓ Consultation documents provided at Airport Expansion Consultation




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Welcomed the consideration of the All London Green

Grid but indicated that this should also take account

of the habitat restoration and creation targets in the

Mayor’s London Environment Strategy, Biodiversity

Action Plan targets, the Wildlife Trusts’ Living

Landscapes, and the Crane and Colne catchment

plans.

✓ One provided information early in the design and assessment process,

focused on design components and options. Heathrow recognised the

need for strategic ecological corridors and biodiversity rich habitats,

including ones to enable connectivity between the Colne and Crane

Valleys. Opportunities for the provision of such corridors and habitats

are being explored and designed to reflect local context and to support

and enhance the flora and fauna characteristic of the area in

developing the Project.

Heathrow are undertaking an EIA, which includes an assessment of

effects on biodiversity. This assessment has informed the design of the

Project, through an ongoing evaluation process. Early findings of this

process will be reported in the PEIR to be published at the Airport


Employing best practice to integrate biodiversity and

green infrastructure into the design of the

development.

✓

Good quality design will be required to ensure

effective north/south movement within the Colne

Valley Regional Park.

✓

All proposals to expand London airports and

increase air travel should be subjected to a Strategic

Environmental Assessment.

✓ As required by the Planning Act 2008, the Government has produced

an Appraisal of Sustainability in relation to the ANPS. The Appraisal of

Sustainability describes the analysis of the reasonable alternatives to

the Project and has informed the development of the ANPS by

assessing the potential environmental, economic and social impacts of

options to increase airport capacity. The Appraisal of Sustainability also

incorporates a Strategic Environmental Assessment, which assesses

12 environmental topics. It describes the analysis of reasonable

alternatives to the preferred scheme. The Appraisal of Sustainability

informs the development of the ANPS by assessing the potential

economic, social and environmental impacts of options to increase

airport capacity.

The ANPS states at paragraph 1.29 that “the overall conclusions of the

Appraisal of Sustainability show that (provided any scheme remains

within the parameters and boundaries in this policy), whilst there will be




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inevitable harm caused by a new Northwest Runway at Heathrow

Airport in relation to some topics, the need for such a scheme, the

obligation to mitigate such hard as far as possible, and the benefits that

such as scheme will deliver, outweigh such harm. However, this is

subject to the assessment of the effects of the preferred scheme,

identification of suitable mitigation, and measures to secure and deliver

the relevant mitigation.” The independent Airports Commission

explored potential alternatives to additional runway capacity, which

included: redistribution methods, for example changing the rate of air

passenger duty; investment in high speed rail and improved surface

access options; and new technologies. The Airports Commission found

that none of these options delivered a sufficient increase in capacity,

and that many required investment far in excess of the cost of runway

expansion. The Airports Commission did note that the need to make

best use of existing infrastructure would remain. (Airports Commission

Final Report, paragraph 16.1 and 16.40). The ‘Environmental

Assessment of Plans and Programmes Regulations 2004’ which

implement the requirements of the European Directive 2001/42/EC (the

‘Strategic Environmental Assessment Directive’) set out the

requirements for an assessment of the effects of certain plans and

programmes on the environment.

The Project will be subject to a DCO application and supported by an

ES in accordance with Infrastructure Planning EIA Regulations 2017.

The Project does not constitute a ‘plan’ or ‘programme’ as is defined by

the Environmental Assessment of Plans and Programmes Regulations

2004.

A comprehensive suite of biodiversity surveys will

be required to establish current populations of

✓ As part of the EIA Heathrow is undertaking a range of ecological

surveys and assessments. The survey work and assessments being




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protected species within and around the

development area and the likely impact of the

proposals upon them.

undertaken are compliant with the CIEEM Guidelines for Ecological

Impact Assessment.

A series of method statements describing the field survey programme

will be included in the PEIR to be published as part of the Airport

Expansion Consultation in June 2019. The methodologies are based

on relevant guidance and have been formally agreed with Natural

England. Further information regarding statutorily and non-statutorily

designated sites, including potential effects upon them, will be provided

within future consultation information and the ES.

The negative effect of the scheme on biodiversity

was not acknowledged in the consultation

information.

✓

The biodiversity metric designed by Defra has been

used for a number of major developments and

recommended that industry good practice published

by CIEEM, IEMA and CIRIA should be used when

designing the approach.

✓

Ecological surveys and assessments must

incorporate all impacted areas including an adequate

buffer.

✓

The ecological impact of the plans must be fully

understood and informed by ecological survey.

✓

Urge the use of a recognised biodiversity accounting

metric, based on the one produced by Defra.


effects on biodiversity. Paragraph 5.96 of the ANPS confirms that the

DCO must make provision for the long term management of

biodiversity measures. The ANPS also expects that full advantage of

and maximised opportunities to conserve biodiversity and geological

conservation interests have been taken. The approach being taken

forward for biodiversity accounting by the Project has been agreed with

Natural England and other stakeholders. It seeks to deliver high value

biodiversity habitats by ensuring that losses are accounted for through

the provision of offsets that have a biodiversity value that is the same,

Request that Heathrow commit to a long-term

measurable net gain in biodiversity and make use of

a recognised biodiversity accounting metric.

✓

An overall gain in biodiversity should be a legally-

binding commitment

✓




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Heathrow must ensure a net gain for biodiversity. ✓ or greater than the area lost. Flexibility in the approach to the delivery

of net gain will be maintained to consider projects identified by local

stakeholders on their merits. This approach is consistent with Defra’s

guidance which encourages replacement of high value habitats with

similar habitat types and avoids issues associated with the acquisition

of sites (including use of compulsory purchase powers).

The approach to biodiversity accounting and proposals for

compensation land will be provided as part of the DCO application.

The PEIR to be published as part of the Airport Expansion Consultation

in June 2019, will provide more information on these matters.

Development should not be permitted until all

ecological measures necessary to achieve net gain

have been fully secured.

✓

The importance of protecting biodiversity and

wildlife and challenged Heathrow to be one of the

'greenest' airport developments.

✓

A net gain to biodiversity should be ensured. ✓

The aims and intentions towards the natural

environment are commendable but unachievable as

existing habitats will be disturbed and destroyed.

✓

There should be a net gain for biodiversity and

suggested that a commitment to this should be

made.

✓

Heathrow needs to go beyond its current

commitments and commit to a net biodiversity gain.

✓

Concerns about whether compensatory habitats can

be achieved if CPO powers cannot be used.

✓

Ensuring any works and compensation integrates

with existing priorities, habitats, environmental

functions and benefits

✓




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There needs to be further detail on how any habitat

compensation land will be managed and highlighted

that wildlife corridors should be at least 100m wide.

✓

New ponds and lakes could benefit and compensate

the local area if done well and queried whether these

would be included in the DCO.

✓

Burying the National Grid overhead cables through

Crown Meadow would severely affect the biodiversity

value of the site unless the site were restored and a

net gain in biodiversity achieved.

✓ Crown Meadow and Horton Brook Quarry provide an opportunity for

enhancing the biodiversity. These sites, amongst others, are being

considered during the design process for green infrastructure.

As part of the development of the Project, Heathrow will continue to

work with stakeholders such as National Grid and land owners to

ensure that property affected by associated developments will be

considered appropriately and mitigation measures, such as green

infrastructure to offset the effects of the proposals, can be employed if

necessary. Crown Meadow is a valuable local public open space and

the project is not looking to locate development on it. Crown Meadow

does provide an opportunity for enhancing biodiversity and this is being

actively considered during the design process for green infrastructure.

In order to maximise environmental enhancements

and biodiversity offsetting proposed on land at

Horton Brook Quarry the land must be protected

from development.

✓

The wildlife corridor through Crown Meadow is very

narrow and would need to be further reduced if river

diversion Option C1F and/or A3044 replacement were

to go through Crown Meadow.

✓

The approach to the natural environment needs to be

led by Biodiversity Officers and environmental

advisers.

✓ Heathrow’s approach to the natural environment is being designed by

environmental specialists. Ongoing engagement with stakeholders,

such as Natural England and the Environment Agency, on matters

related to the natural environment is required to ensure that the

approaches and measures being proposed, as part of the EIA process,

are suitable and effective across a wide range of subject matters.

The proposed approach to the natural environment will be set out in the

PEIR which will be published as part of the Airport Expansion




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Support for the need for biodiversity offsetting and

suggested that further enhancements could be

achieved through the improvement of local parks

and footpaths, to provide high quality walking and

cycling routes for local communities.

✓ The delivery of the Project will impact the existing natural environment.

However, Heathrow are considering opportunities to deliver biodiversity

offsetting areas (for wildlife, habitats and linkages between habitats)

and high-quality mitigation (including re-colonisation) for biodiversity

(wildlife and plants), the landscape and the water environment (rivers,

ponds and streams), for the benefit of both local communities and

wildlife in the local area.

Biodiversity offsetting calculations will be undertaken to demonstrate

the delivery of net gain by the Project. The mechanism to achieve this

has been agreed with Natural England and the Environment Agency.

Heathrow are considering a range of options and are engaging

stakeholders within the Colne Valley Regional Park and

Buckinghamshire in the process. The EIA that Heathrow are

undertaking, in accordance with best practice guidance, policy and

legislation, includes an assessment of direct and indirect impacts on

the environment and communities. The initial findings relating to

specific impacts and mitigation for the resources identified will be

reported in the PEIR to be published as part of the Airport Expansion


Biodiversity offsets should be located locally to

maximise the creation of ecological networks and

should consider priority habitats and species,

priority areas for biodiversity and wildlife investment,

local wildlife sites and opportunities to extend,

enhance, create and connect habitats and green

infrastructure for wildlife and people.

✓

Supported efforts to offset impacts on the

environment but considered that effects cannot be

adequately offset.

✓

Welcome the provision of high quality, connected,

integrated and multifunctional green infrastructure

and supported the aim of connecting local people to

the natural environment.

✓

Supported the need for biodiversity offsetting where

loss or harm to habitats from expansion is

unavoidable.

✓




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Expansion will harm the environment and that this

harm will not be offset by the measures proposed.

✓

Biodiversity offsetting approaches should not only

consider the quantity and quality of the habitats but

also the significance of biodiversity linkages.

✓

Biodiversity offsetting and environment net-gain

principles should be followed.

✓

Where loss or harm is unavoidable, biodiversity off-

setting should be provided locally.

✓

The potential indirect impacts and species specific

re-colonisation potential should also be considered.

✓

The development is likely to impact habitat used by

designated bat species and suggested that there are

various sites to east of the airport that should be

considered for bat habitat offsetting.

✓

Clarity is required on how the loss of river habitat

will be calculated and offset, how the proposals will

be enforced, what baseline will be used and how

progress will be monitored.

✓

The need for detailed assessments to be undertaken

and provided a number of comments on the

proposed approach.

✓




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The project should include measures to improve the

natural habitat surrounding the airport and create

wildlife habitat linked together to form wildlife

corridors.

✓

Welcomed measures to ensure net gain for

biodiversity and encouraged Heathrow to make a

firm commitment.

✓

It should be part of the project to improve the natural

habitat surrounding the airport and that green areas

should link together to provide wildlife corridors.

✓

High quality mitigation around the airport for the

benefit of local communities and wildlife was

required and should be implemented.

✓ The government has established the need for the Project within the

ANPS. The Project presents an opportunity to deliver high quality

mitigation through green infrastructure in the local area, taking the

consultation responses into account. In accordance with the ANPS,

the Secretary of State will need to be satisfied that the proposed

landscaping measures are appropriate and deliverable when

determining the DCO application.

A detailed collaborative and multidisciplinary approach to the

evaluation and selection of options is being undertaken. This has

included engagement with a range of stakeholders as part of the EIA

as well as taking into account the consultation responses received in

relation to Airport Expansion Consultation One. Heathrow will present

its preferred option and the early findings of this assessment in the

Updated Scheme Development Report. Information on surveys

undertaken and their findings will be published in the PEIR. Both

documents will be published as part of the Airport Expansion

Challenged the idea that expansion provides a

unique opportunity to deliver high quality mitigation.

✓




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Concern that there were no costed mitigation plans

to address the environmental impacts of expansion.

✓ In accordance with the ANPS the mitigation hierarchy is being used

within the design process to ensure that negative impacts on

biodiversity are limited as far as possible. Potential effects on SSSIs

will be assessed in detail within the EIA.

Consultation documents provided at Airport Expansion Consultation

One provided information early in the design and assessment process,

focused on design components and options in relation to a number of

aspects of the development still under consideration, this included the

approach to mitigation and environmental protection measures.

Heathrow are undertaking an EIA of the Project, and early findings will

be reported in the PEIR to be published as part of the Airport

Expansion Consultation in June 2019. That process will enable

Heathrow to provide the initial information on the detail, quantity and

cost of mitigation and protection measures.

The proposed approach to mitigating the effects was

generally acceptable.

✓

Concern that the mitigation hierarchy is not being

used and indicated that a much more comprehensive

approach is required.

✓

Requested a stronger package of environmental

protection measures.

✓

Concerns that expansion will be likely to result in

significant environmental effects.

✓

Questioned how mitigation would be maintained in

the longer term if not part of the DCO application.

✓ The maintenance of habitats created for the Project will be over the

long term, as specified within the Defra guidance on biodiversity

offsetting. The definition of "long term" is a topic of discussion with

Natural England and will continue to be as the green infrastructure

design progresses. This discussion will continue as individual land

owners and organisations where habitat creation and management will

be proposed will have their own views on the definition of long term.

The Masterplan Scheme Development Manual include a wide range of

considerations in the evaluation criteria used for appraising different

options and masterplan components, including sustainability and

impacts on communities. The ANPS requires at paragraph 4.31 “a

good design should meet the principal objectives of the scheme by

Reservations about whether the mitigation measures

would ever be delivered.

✓

Local wildlife sites and undesignated habitats must

be conserved and enhanced with ongoing

monitoring, maintenance and management.

✓

Clarification whether Heathrow will maintain the

environment surrounding the expansion area.

✓




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eliminating or substantially mitigating the adverse impacts of the

development, for example by improving operational conditions. It

should also mitigate any existing adverse impacts wherever possible,

for example in relation to safety or the environment”.

The DCO application will comply with this. In addition, an ES will form

part of the DCO application to explain how Heathrow will identify and

mitigate any likely significant environmental effects during construction

and operation of the airport. Early findings of this process will be

reported in the PEIR to be published at the Airport Expansion


Mitigation measures to maintain or improve facilities

could be part of the ‘quality of life’ fund to include

• tree planting;

• improvement of nearby green areas;

• public transport to green areas;

• free or low cost indoor play places;

• high intensity play places (e.g. climbing wall) at low cost; and

• enhanced school green spaces that are accessible after school and on weekends.

✓ Any natural environment proposals for mitigation will be funded by a

contribution payable under a legally binding planning agreement.

The Our Design Approach to the Natural Environment document

presented at Airport Expansion Consultation One set out Heathrow’s

plans in relation to the natural environment. Currently, no areas have

been designated for any specific use. However, Heathrow are

identifying areas that could form part of a high quality, multi-functional

green infrastructure network with good connections to the places where

people live and work. Heathrow are aiming to provide a richly varied

landscape that will benefit both people and wildlife, providing diverse

uses, accessible to all.

Further information will be contained within the PEIR, identifying the

plans for the future provision of green space around the airport which

will form part of the Airport Expansion Consultation in June 2019.

Landscape mitigation should enhance the local

environment for wildlife and ecology as well as for

residents, employees and visitors.

✓

The mitigation and enhancements proposed need to

be evidence based, address legislative requirements

and provide general enhancements for wildlife.

✓




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Factors that should be considered further relating to

landscape:

• more trees should be planted;

• consideration should be given to using

trees/landscaping and the soil/waste material as

embankments to act as noise barriers;

• new/additional green spaces should be created;

• any negative impacts should be mitigated as

much as possible;

• more consideration should be given to the

landscape such as creating parks/parkland

landscapes around the airport;

• new recreational spaces for people should be

created;

• more could be done to improve public walking

and cycling access to the natural environment;

• dedicated/segregated cycle paths and footpaths

should be created;

• natural/sustainable design measures should be

incorporated;

• attractive landscaping and design would reduce

the landscape and visual impacts of expansion;

• consideration needs to be given to impacts on

the countryside and enhancement of amenity as

part of the approach to the natural environment;

• green corridors / buffer zones between the

airport and neighbouring residential areas

including Stanwell and Stanwell Moor should be

retained and enhanced;

• consideration should be given to creating a

✓




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botanic garden landscape; and

• impacts on green/open spaces and the

countryside should be minimised.

The risk of bird strike results in controls being put on

the habitats around an airport runway. These

approaches already impact upon the diversity and

management of wildlife habitat within the river

corridors around the airport (including within the

Crane corridor) and assumed that it would be

necessary to increase these areas. Such restrictions

have a negative impact upon the existing or potential

wildlife management opportunities over a wider

surrounding area and this should be evaluated

during the ongoing assessment process.

✓ Proposals for mitigation and enhancement will be designed to minimise

the risk of bird-strike. Areas away from an operational airport provide

opportunities to promote biodiversity in locations where the risk of bird-

strike is reduced.

Management of wildlife strike risk will focus on creating habitats that

will not attract the species (e.g. Canada goose) considered to be a risk.

Where there are areas that need greater levels of management (e.g.

use of netting) the design will focus on ensuring that the exclusion of

risk species does not prevent usage by other species (e.g. bats).

Further information will be contained within the PEIR, identifying the

plans for the future provision habitats and wildlife management areas

around the airport which Heathrow are consulting on as part of the

Airport Expansion Consultation in June 2019. That further information on implications of the

proposed flood storage areas/lakes/rivers on bird

strikes should be made available.

✓

Request for further information on the proposals for

each of the sites and expressed support in principle

for the protection and enhancement of green belt

land.

✓ The Project will require areas of Green Belt land. Where possible

Heathrow will seek to minimise the amount of Green Belt which is

required.

As set out at paragraph 5.127 of the ANPS, the Secretary of State, as

the decision maker on the DCO application, will need to assess

whether there are very special circumstances to justify development on

areas of Green Belt land.

Impacts on the local area, opportunities for

improvements and benefits to local communities and

challenges to the preservation of the Green Belt and

Metropolitan Open Land are all reasons for an overall

masterplan.

✓




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Protecting and mitigating effects on the natural

environment was necessary and fair, that there could

be benefits for habitats and wildlife, that effects on

particular sites and locations should be minimised

as far as possible and that sites for development

should avoid important landscapes and Green Belt.

✓

Wider impacts on nearby designated sites must be

considered e.g. the Thames Basin Heaths Special

Protection Area.

✓ As part of the development of the Project Heathrow is seeking to

minimise the requirement for additional land take, including that within

wildlife and recreation areas wherever practicable.

The ANPS requires an ES to be submitted as part of the application

which describes any likely impact on protected areas, species, and

habitats that are considered of principal importance for the

conservation of biodiversity. Habitat creation and enhancement

proposals will be designed to ensure that the biodiversity interest of

designated sites in this area will be maintained and where appropriate

enhanced.

Proposals for landscaping, mitigation and compensation works (‘green

infrastructure’) are being developed that will form a network of

connected green spaces and water environments in the vicinity of the

airport. This network will help provide biodiversity habitats, with

Heathrow aiming to achieve a net gain in biodiversity.

Sustainability considerations are sub-divided into environmental topic

areas, with the consideration of potential biodiversity impacts being

guided by the following criteria: 1) Impacts on protected sites for nature

conservation (e.g. Special Protection Area (SPA), Sites of Special

Scientific Interest (SSSI), Site of Importance for Nature Conservation

(SINC)) 2) Impacts on designated Ancient Woodland 3) Impacts on

Sites designated for nature conservation must be

protected and enhanced.

✓

Minimising the impact on protected areas and land

take within wildlife and recreation areas.

✓




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priority habitats and species.

A Habitats Regulations Appraisal Screening Report will be published at

the Airport Expansion Consultation in June 2019. It will consider the

potential for significant effects on the Thames Basin Heaths SPA.

Clarity on the purpose of the Potential Protected

Species Area and queried whether this relates to the

existing location of protected species or is a

designated refuge for translocated species.

✓ For some legally protected species, there will be a need to translocate

populations from land located within the area that will be affected by

the Project. For example, habitat creation works can apply to land

where there is a need for major earthmoving work to create flood

storage areas. The sites to which translocated animals would be

relocated could be located in habitat creation areas where major

earthmoving work is not required. Where necessary, habitat creation

and management works will be undertaken in advance of translocation

in order to ensure that the chosen locations are sufficiently mature to

be effective as receptor sites.


impacts on protected species. This assessment is being used to inform

the design of the Project, through an ongoing evaluation process. Early

findings of this process will be reported in the PEIR to be published at


Details of the protected species for each of the sites

must be made available in future consultations.

✓

The network of locally protected sites for biodiversity

and local communities was also highlighted and they

requested that Heathrow examine opportunities for

enhancing the connectivity of these sites for the

benefit of people and wildlife.

✓

Protect the new parkland area by developing a small

area of light industrial units in Horton Brook Quarry

along the Horton Road.

✓ It is unclear how the development of light industrial units within Jayflex

Quarry would result in the protection of new parkland. However, any

parkland design will be developed on the basis that function and form

are not compromised by neighbouring land uses.

The delivery of the Project will impact the existing natural environment.

However, it also presents an unprecedented opportunity to deliver high

quality mitigation for green infrastructure in the local area.

Through the development of carefully considered and integrated

Concern about the effects on grasslands in

Richmond Park, Bushy Park, Kensington Gardens,

Primrose Hill, Regents Park and Greenwich Park.

✓

Insufficient account has been taken of the loss of ✓




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amenity value for many of the surrounding parkland

and nature rich areas as a result of the increased air

traffic.

natural and built environment proposals, the expanded Airport seeks to

provide positive contributions to the local landscape and views, where

opportunities arise. The draft masterplan will propose areas which

could be landscaped, planted, restored or enhanced in order to mitigate

and off-set the effects of the Project, including those upon habitats, as

far as possible. Heathrow are undertaking an EIA, which includes an

assessment of impacts on public open space. This assessment is

informing the design of the Project, through an ongoing evaluation

process.

The Open Space Assessment carried out to support the DCO will

identify the scale and location of the public open space affected by the

Project. The ANPS requires the preferred scheme to be carried out to

high environmental standards and, where possible, includes measures

to enhance other aspects of the environment. As part of the landscape

mitigation strategy the re-provision of public open space affected by the

Project including parks will be required. The locations of new public

open space will be detailed during the Airport Expansion Consultation

in June 2019 following consultations with the LPAs. Early findings of

this process will be reported in the PEIR to be published at the Airport


The need for an overall Masterplan for open spaces

covering the whole of the area covered by the

consultation exercise.

✓

The scope of this Masterplan should be developed

with key stakeholders

✓

Critical of the focus on the immediate vicinity of

Heathrow and suggested that the natural

environment of the Surrey Hills AONB should be

equally respected.

✓ The Project would not physically affect the Surrey Hills AONB and any

tranquility effects would relate to airspace change rather than ground-

based infrastructure or development proposals.

The DCO application for the Project cannot pre-determine flight paths

(which are subject to a separate consenting process), however an aim

of airspace change is to minimise impacts on the Area of Outstanding

Natural Beauty (AONB). More information on AONBs will be provided

within the Landscape and Visual Impact Assessment (LVIA) Chapter of

PEIR during the Airport Expansion Consultation in June 2019.




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A health impact assessment should be central to all

environmental considerations and highlighted that

those responsible for local resources should be

consulted to design lasting managed solutions.

✓ To meet the statutory and policy requirements, Heathrow are preparing

a health impact assessment (HIA) which will identify, assess and

manage any health impacts caused by the DCO Project. The HIA will

also take account of Chapter 12 of the EIA Scoping Report which sets

out the approach to the assessment on human health (including

children’s health). Section 12.4 of the EIA Scoping Report explains how

the study area used for the purposes of the assessment is to be

determined.

Drawing on the analysis in the HIA, the Environmental Statement will

report on the likely significant health effects and the measures taken by

the DCO Project to enhance positive health effects and reduce

negative health effects. The HIA will be reported as an appendix to the

health chapter of the Environmental Statement.

Heathrow will continue to work with a number of stakeholders such as

Natural England, the Environment Agency, and London Wildlife Trust to

look into good practice as well as the latest techniques and technology

in which to implement within our proposals for the natural environment.

Details of these engagements will be provided within the Consultation

Report submitted as part of the DCO application.

✓

There was insufficient information presented to allow

an assessment of impacts on watercourses.

✓ As part of Airport Expansion Consultation One numerous options for

the diversion of rivers were presented in the Airport Expansion

Consultation Document and Our Emerging Plans.

As part of the further refinement of the proposals and the EIA detailed Concerns about an increased risk of flooding ✓




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Disruption to waterways should be minimised, flood

prevention targets should be promoted or that SuDS

should be used.

✓ consideration is being given to the risk to flooding and the potential to

increase the risk of flooding. This will be presented in the flood risk

assessment that will accompany Heathrow’s DCO application.


impacts on watercourses. This assessment has informed the design of

the Project, through an ongoing evaluation process. A detailed

evaluation considering a range of criterion is also being undertaken to

identify the preferred location and routes for river diversions, taking into

account consultation responses.

Early findings of this process will be reported in the PEIR and the

Updated Scheme Development Report to be published at the Airport


Along the river courses in Slough (the Horton Brook

and the Colne Brook) there are numerous fallen trees

in the water which impede flow, particularly during

flood events.

✓

The removal of the fallen trees would enhance the

natural environment and help to reduce flood risk

and this should be undertaken as part of overall

measures to improve the habitat along the

watercourses.

✓

Rivers should be defined as having high

distinctiveness and condition assessments should

use a wide suite of techniques to measure the

biological quality.

✓

Water discharged from the airport must be effectively

treated and pollutants removed.

✓ Heathrow recognise that the use of infiltration-based Sustainable

Drainage Systems (SuDS) will be constrained by the risk of pollution to

shallow groundwater. Pollution prevention measures will be applied so

that water discharged from the airport will be effectively treated and

pollutants removed. The draft Code of Construction Practice (CoCP) for

the Project will influence the approach to water discharges that may

occur during construction. The draft CoCP will be developed in

conjunction with stakeholders, such as the Environment Agency and

will form part of the DCO application.

Recommended that existing flows within the nearby

water courses are maintained and the use of

Sustainable Drainage Systems.

✓

A large number of lakes to the north west of the ✓ Heathrow is preparing a Habitats Regulations Assessment (HRA)




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airport are likely to function as supporting habitat for

the South West London Water Bodies SPA. Some of

these sites are likely to be impacted by construction

which will need consideration as part of the HRA.

Screening Report. The purpose of the Screening Report is to identify

the likely impacts of the Project, either alone or in combination with

other projects, upon European sites and to determine (in consultation

with statutory consultees) whether these impacts are likely to be

significant or uncertain – in either case Appropriate Assessment will be

required. The HRA Screening Report will be published as part of the

Airport Expansion Consultation in June 2019. The HRA will include

consideration of likely significant effects on supporting habitats.

Concern that the increase in non-permeable material

across the development site will alter the effects on

ground water, aquifer recharge and connections with

river channels.

✓ Heathrow are committed to protecting the quality of the water

environment. Heathrow are considering a range of options and are

engaging stakeholders in the process. Heathrow will present its

preferred option at the Airport Expansion Consultation in June 2019.

The objectives of the Water Framework Directive (WFD), which are

reiterated in the ANPS, are being taken into account.

The proposed masterplan will be designed to protect and enhance the

biodiversity associated with the water environment as far as possible.

More information will be provided the PEIR to be published as part of


There must be no negative impacts upon water

quality in the river and that the risks of pollution

minimised through appropriate planning, design and

operational controls.

✓

Naturalised flow regimes within the modified river

channels and improved connectivity through all

channels will be required.

✓ The Project will extend the airport's footprint into the Colne Valley, in

the path of existing alignments of watercourses and areas of floodplain

storage.

It is proposed that the Duke of Northumberland’s River and the

Longford River are combined in one channel underneath the runway,

before being returned to their current channels and flow conditions

downstream of the expanded airfield.

An extensive and detailed evaluation of potential sites has been

undertaken in order to identify the preferred location and routes of the

Colne Brook should be retained as an open channel

other watercourses remaining as open channels as

much as possible.

✓

The issue of connectivity could not be delivered

solely through the Colne Brook diversion option.

✓




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Strategic corridors are provided in Iver by the Rivers

Colne, Colne Brook, Alderbourne and Horton Brook

and their drains and tributaries. These waterways

extend through the Colne Valley and must be

protected and enhanced to counter the effect of

culverting and diverting flows downstream.

✓ river diversions and flood storage areas, taking into account the

consultation responses. Heathrow believe that the proposals provide

the most sustainable balance between being appropriately located,

requiring an acceptable level of land take, and minimising impacts upon

the environment and communities as far as possible. More information

will be provided within the PEIR to be published as part of the Airport


Opposition to the diversion of the Colne Valley Way

to the west, commenting that it should follow the

alignment of the potential primary cycle route which

appears to be along the Colne Brook.

✓

Rivers, water bodies and storage are interconnected

systems and need to be considered together.

✓

Opportunities for newly created wetlands should be

explored that meet water quality standards and flood

requirements whilst also delivering open green

spaces.

✓ Heathrow are committed to aiming to achieve an overall net gain in

biodiversity and this will include the creation of new and enhanced

habitats (including wetlands and marshlands.

Heathrow are committed to protecting the quality of the water

environment and working with the Environment Agency and other third

parties to deliver appropriate solutions.

The masterplan is being designed to accord with the environmental

objectives of the WFD, which are reiterated in the ANPS. In this regard,

one of the emerging scheme’s overall aims is to prevent the

deterioration in status of water bodies, and not to jeopardise the future

achievement of good status for any affected water bodies. The

proposed masterplan is also being designed to protect and enhance

the biodiversity associated with the water environment as far as

possible.

More information will be provided within the PEIR to be published as




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Welcome measures to maintain continuity of green

space along northern boundary and along the Colne.

They considered these measures essential to

prevent discharges into the Colne along the western

edge of airport.

✓ A green infrastructure strategy is being developed as part of the

Project. It will be focused on improving the area for biodiversity and

people including creating a network of green spaces around the airport.

Discussions are underway with local landowners on a range of land

uses of which green infrastructure is given a high priority.

Open green spaces need to include walking routes

and cycling paths which link with the wider Colne

Valley Park, other green spaces and walking/cycling

corridors surrounding the airport.

✓ Heathrow have been developing a full active travel strategy which

includes cycling. The proposed cycle network will be included in the

documents published as part of the Airport Expansion Consultation in

June 2019.

The delivery of the Project will impact the existing natural environment.

However, Heathrow are considering opportunities to deliver high quality

mitigation for green infrastructure, and for biodiversity (wildlife and

plants), the landscape and the water environment (rivers, ponds and

streams) – for the benefit of both local communities and wildlife in the

local area.

Effects on ecological sites and habitats will be considered as part of the

EIA and mitigation will be proposed where significant effects are

identified. More information will be provided within the PEIR to be


Heathrow should extend the Colne Valley Trail

further south (section 3) and explore enhancement of

existing sections of the Colne Valley Trail.

✓

Colne Valley Regional Park will be fundamentally

changed by Heathrow expansion. As a result, they

considered that any Green and Blue Infrastructure

Plan should extend to The Ivers.

✓

The effects of expansion on the Colne Valley

Regional Park should not be allowed to happen.

✓

The need to address the potential impact on the

Colne Valley Regional Park.

✓




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Compensation for the permanent loss of Colne

Valley Regional Park land in the south should be

provided by expanding the Park boundaries.

✓

Concerns about the effects on the Colne Valley

Regional Park, Crown Meadow, the Thames Basin

SPA, the River Crane, ancient woodland and number

of species of wildlife.

✓

The overall strategy must retain the integrity and

connectivity of the Colne Valley Park as far as is

possible and provide off-site compensation and

mitigation for any permanently used land.

✓

Colnbrook and Poyle villages should be protected

within a ‘Green Envelope’.

✓ Slough Borough Council, through the ongoing HSPG engagement have

stressed the importance of the ‘green envelope principle around Poyle

and Colnbrook and the Project is looking to maintain and enhance that

principle where practicable. Heathrow will continue to work with HSPG

to seek to identify an effective solution.

Heathrow is located between a number of areas of

importance for tourism, leisure and heritage. They

considered that the appropriate development of the

airport could enhance these sectors.

✓ Heathrow recognises that in accordance with the ANPS the Secretary

of State should refuse consent unless it can be demonstrated that

substantial harm or loss of significance of heritage assets is necessary

in order to deliver substantial public benefits that outweigh the loss

(ANPS 5.204). Heathrow must therefore take steps to minimise the

extent of harm to heritage assets alongside demonstrating the public

benefits (including any heritage benefits) from the proposals. One of

the key principles of Heathrow’s approach to the historic environment is

opportunity. As part of this, an exploration of initial options to unlock the




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potential for sustainable uses of heritage assets and for creating

circumstances to help others to manage heritage assets that might

otherwise be at risk; as well as creating new amenity that increase

people’s ability to enjoy the wider historic environment

The proposed cycle route appears to connect well to

the surrounding area but that further investment is

needed around Stanwell/Stanwell Moor to connect

the current off airport routes with the routes within

the airport boundary.

✓ Almost 20,000 airport personnel currently live within 5km of the airport

boundary – a comfortable cycling distance for many people. The

Project represent an opportunity to improve connections to the airport

from existing cycle routes and improve the quality of the environment

and infrastructure for cyclists in the future with improved or new routes.

The cycle route along the Southern Perimeter Road

should be extended to link up with routes to Terminal

4 and Bedfont.

✓

The proposed cycle route around the airport could

be attractive for its employees provided it is built to a

high standard. The cycle route needs to be

integrated into a landscape zone and not just placed

immediately next to the perimeter road or airport

fence.

✓

The development may disrupt recreational walking

routes and suggested that Heathrow work alongside

Local Authority open space strategies or rights of

way improvement plans to identify possible

enhancements.


stakeholders in the process. Heathrow are working with stakeholders to

ensure that it is understood what the precise amount of green space

that will be lost or created as part of this application will be. Heathrow’s

aim is that the new landscapes to be created by the Project are at least




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Provision of recreational areas should also consider

areas further away which less affected by the airport

✓ as good in terms of quantity, quality and connectivity as those they

replace. Heathrow’s vision is to create new landscapes that will deliver

a range of environmental, social and economic benefits to local

communities and beyond.

The expansion of Heathrow will affect the existing natural environment

but it also represents a unique opportunity to deliver high quality

mitigation around the airport for biodiversity (wildlife and plants), the

landscape and the water environment (rivers, ponds and streams) for

the benefit of both local communities and wildlife. Heathrow will

continue to work with stakeholders, including local authorities, to

identify opportunities and improvements as part of the development

proposals. More information will be provided within the PEIR to be


Concerns that the proposals failed to consider local

people, would result in a loss of green

space/recreational facilities or were generally

insufficient.

✓

Welcome the consideration of integrated and

connected green infrastructure but expressed

concern that this approach should not result in a

reduction in the amount of green infrastructure

created or the focussing of benefits into a very small

area.

✓ One of the four principles of Heathrow’s Green Infrastructure approach

is to improve connectivity around the airport by creating new cycle

paths and footpaths to improve public access to the natural

environment for health and wellbeing. Heathrow is considering the

implementation of dedicated/segregated cycle paths and footpaths

(e.g. providing connections to the London Loop path by improving

existing cycle paths and footpaths). In addition, baseline study work will

assess the existing network to identify areas for improvement (e.g.

resurfacing and maintaining the cycle/footpaths) and linking with off-

airport routes (e.g. around Stanwell/Stanwell Moor, Colne Valley Way).

These routes will aim to provide safe cycle pathways for colleagues.






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The water table is at a very shallow depth and

susceptible to contamination.

✓ Heathrow are undertaking EIA, which includes an assessment of

impacts on the water table. The risks associated with having shallow

river terrace gravels will be assessed as part of the EIA.





Concern that local authorities have not been

consulted on potential sites for flood storage and

that the proposals may impact existing flood

alleviation schemes.


stakeholders in the process, including Lead Local Flood Authorities

through the HSPG and the Environment Agency, to ensure that

locations identified are appropriate and that the proposals do not affect

existing flood alleviation schemes.

The proposed flood storage areas will need to form

part of the Green and Blue Infrastructure Plan.

✓ The Project presents an opportunity to deliver high quality mitigation for

green and blue infrastructure in the local area. Heathrow are

considering a range of options on this. The Project will propose areas

which could be landscaped, planted, restored or enhanced in order to

mitigate and off-set the effects of the Project. Heathrow are

undertaking an EIA of the Project, including an extensive and detailed

evaluation of potential sites, to identify the preferred location and routes

of the river diversions and flood storage areas, taking into account the

consultation responses received from the Airport Expansion

Consultation One.

A landscape vision that includes a green and blue infrastructure

strategy that focuses on providing multifunctional space that is

beneficial to both wildlife and people is also being developed. This

strategy includes habitat connectivity, biodiversity mitigation,

biodiversity offsetting, re-provision of public open space, active

transport, historic setting and improvement of existing green belt.

Green infrastructure must be considered and

planned for.

✓

Need for a Green and Blue Infrastructure Plan and a

number of opportunities for mitigation within the

Park.

✓

Welcome Heathrow’s design approach and

commitments to create a positive legacy of better,

well connected green infrastructure and maintain

current populations of animals and plants.

✓

The key elements of the Green and Blue ✓




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Infrastructure Plan must be included in the DCO

application to ensure they can be delivered,

managed and maintained.



Early and strategic planning of green and blue

infrastructure.

✓

Creating a positive long-lasting legacy should be a

core component of the development.

✓

Areas of parkland and open space previously created

in the vicinity of the airport suffer from underuse and

neglect, often because of concerns over lack of safe

parking, security and isolation.

✓

Protection, enhancement and re-introduction of

indigenous species and habitats would be a long-

lasting legacy.

✓

Improve site connectivity by land and water wherever

possible.

✓

Greening measures would likely bring economic,

health and tourism benefits.

✓

The proposed flood storage areas need to form part

of the green infrastructure plan.

✓

Management and maintenance of green

infrastructure should be integrated into project

✓




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design.

This could include green features, such as green

walls, green roofs and green bridges, which would

improve the resilience of the development whilst also

protecting the building fabric from sunlight and

temperature fluctuations, reducing costs, reducing

noise, providing visual features of interest, capturing

air pollutants and dust and providing wildlife habitat.

✓

Challenged the claim that the proposals would

protect rivers and their associated vegetation

corridors when over one kilometre of the diverted

Rivers would flow beneath the new runway,

essentially below ground.

✓

Green and Blue infrastructure strategy should drive

the design process and be intertwined into all

proposals.

✓

Welcomed the inclusion of landscape design as part

of the integrated green infrastructure aim and

indicated that it could deliver additional benefits for

landscape and visual amenity.

✓

The use of green infrastructure as the primary basis

for measuring success regarding the environment

has a number of potential disadvantages due to the

conflicting objectives.

✓




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Any proposals need to be considered in a holistic

manner, with links to other strategic interventions in

the surrounding area also being considered, for

example the River Thames Scheme.

✓ However, it also presents an opportunity to deliver high quality

mitigation for green infrastructure in the local area. Heathrow are

considering a range of options, including areas which could be

landscaped, planted, restored or enhanced in order to mitigate and off-

set the effects of the Project, including those upon habitats. Further

information will be contained within the PEIR to be published as part of


Consideration should be given to the integration of

drainage and pollution controls with the green

infrastructure masterplan.

✓ Heathrow are committed to protecting the quality of the water

environment. Plans for expansion consider a range of options which

will be presented to our stakeholders, including the Environment

Agency, for their consideration. Stakeholders will help Heathrow to

deliver appropriate solutions in accordance with the environmental

objectives of the WFD. In this regard, Heathrow aims to prevent the

deterioration in status of water bodies and not adversely affect the

future achievement of good status by any affected water bodies. In

accordance with the WFD, Heathrow are considering options to protect

and enhance the biodiversity associated with the water environment.



Heathrow had failed to take account of the

environmental characteristics of its alternative

development proposals.

✓ The ANPS sets out specific requirements that Heathrow will need to

meet to gain development consent for the Project. Heathrow are

undertaking an EIA of the Project, which will take account of the

proposals. As part of the requirements for an EIA, a scoping report was

presented to the planning inspectorate setting out the extent of the

study area beyond the immediate environment. Early findings in line

with these requirements will be reported in the PEIR to be published as

part of the Airport Expansion Consultation in June 2019. As part of the

decision making process, the Secretary of State will have to be

Environmental impacts must be considered beyond

the immediate area of development.

✓

The social, economic and environmental impacts of ✓




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airport growth and growth in air travel should be

examined.

satisfied that the economic, social and environmental benefits of the

Project outweigh the environmental impacts and are within local and

global levels.

The design of multifunctional space needs careful

consideration to avoid conflicts.

✓ The Project provides an opportunity to create linked spaces for both

people and wildlife (known as multi-functional spaces) which reflect the

characteristics of the local area. As distance from the airport increases,

so a greater range of habitat types may be possible as potential

conflicts reduce. Heathrow are considering a range of options.

Heathrow will present its preferred option/s at the Airport Expansion

Consultation in June 2019. This information will be presented in the

PEIR to be published as part of the Airport Expansion Consultation in

June 2019.

There was little information specific to local sites and

wildlife which meant an assessment of impacts could

not be undertaken.

✓ Heathrow are undertaking an EIA of the Project. The EIA is being

undertaken in accordance with best practice guidance, policy and

legislation. It includes an assessment of effects on the environment

and communities. Early findings will be reported in the PEIR, including

mitigation measures to avoid and reduce impacts on the environment

and communities, to be published as part of the Airport Expansion


Connectivity should be maintained and enhanced for

terrestrial mammals and that unhindered fish

migration will help to prevent ecological impacts

outside of the footprint of the project.

✓ The Project represents an opportunity to deliver high quality mitigation

around the airport for biodiversity (wildlife and plants), the landscape

and the water environment (rivers, ponds and streams) for the benefit

of both local communities and wildlife. Mitigation on a catchment scale

should ensure that habitat connectivity can be maintained between the

upper Colne catchment and the River Thames, including connections

to the Crane catchment. factors that should be considered further related to

ecology:

✓




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• more trees should be planted;

• greater consideration should be given to the

impact on wildlife and habitats;

• new/additional green spaces should be created;

• any negative impacts should be mitigated as

much as possible;

• experts and environmental groups should be

consulted;

• green spaces should be maintained and

managed for the long term;

• locations proposed for supporting facilities

should be turned in to green spaces and parks

after being used for construction;

• flood storage areas and habitats that may attract

birds should be away from the airport;

• wildlife parks and a wildlife centre should be

created; and

• contributions should be made to improving a

country park along the River Colne.

Heathrow is considering a range of options. The new landscapes

created by the Project will aim to be at least as good in terms of

quantity, quality and connectivity as those they replace. Heathrow’s

landscape vision is to create new landscapes that will deliver a range of

environmental, social and economic benefits to local communities and

beyond. Heathrow is undertaking an Environmental Impact

Assessment of the Project, and early findings will be reported in the

PEIR which will be published as part of the Airport Expansion


The diversion of Colne Valley Way through Staines

Moor could be positive but could lead to other issues

such as litter or disturbance to wildlife.

✓ Heathrow is not planning any development on the Staines Moor Site of

Special Scientific Interest (SSSI), to the east of the M25. Heathrow are

however undertaking an EIA, which includes an assessment of impacts

on this SSSI. This assessment informs the design of the Project,

through an ongoing evaluation process. Early findings of this process

will be reported in the PEIR and the Updated Scheme Development

Report to be published at the Airport Expansion Consultation in June

2019. Opportunities for mitigation and enhancement measures will

continue to be assessed in light of the Staines Moor status as a SSSI

Highlighted the importance of the Colne Valley to the

Borough and surrounding areas.

✓

Staines Moor contains the oldest known colony of

yellow meadow ants in the whole country and would

✓




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be affected by any work on the northern end of the

site. As a result, any development in this location

would be strongly resisted.

as the Project progresses.

Any work on the Staines Moor floodplain would

disturb wildlife and could also alter the amount of

water on the floodplain. This could lead to a change

in the historical composition of habitats at Staines

Moor and a knock-on reduction in biodiversity.

✓

The whole of Staines Moor should be designated as

a proposed protected species site and should not be

included within the potential development area.

✓

The diversion of Colne Valley Way through Staines

Moor could be positive but could lead to other issues

such as litter or disturbance to wildlife.

✓

Bonehead woodland provides a home for many bird

species and a small population of deer. Reduction of

this small area of woodland would probably lead to

the loss of the deer and would reduce the habitat

available to many species of bird.

✓ ✓ Bonehead Woodland lies within the Staines Moor SSSI. There are no

plans for any works within the area of this woodland.

Heathrow are undertaking an EIA. Survey data is being collected

across the area for both breeding and wintering birds, and mammals.








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All aspects of the environment and the benefits it

provides to people, wildlife and the economy should

be taken into account in options development and

any future stages of Heathrow expansion.

✓ A wide range of considerations are being applied within the evaluation

criteria used for appraising different options and masterplan

components which will form part of the decision making process,

including cost, buildability, land use, environment, including biodiversity

and impact on existing operations. All metrics and sub-criteria will have

no formal weighting applied. However, in considering the overall

balance of considerations, material issues will be highlighted, including

any ‘show stoppers’ which are considered to prejudice the deliverability

of the scheme as well as elements causing excessive environmental

impacts. This approach will ensure that effects on biodiversity are

weighed in the balance at all stages of masterplan scheme

development and will feed into the DCO application. As the scheme is

developed, further information will become available and this

information will be presented within PEIR to be published as part of the


The loss of wildlife habitat and putting rivers

underground is unacceptable.

✓ Numerous options for the diversion of rivers were presented in Airport

Expansion Consultation One.

A detailed evaluation considering a range of criterion (as detailed in the

Scheme Development Report) is being undertaken to identify the

preferred location and routes for river diversions, taking into account

the consultation responses. The findings of this assessment will be

presented in the Updated Scheme Development Report that will be


No details of the approach to Landscape Visual

Impact Assessment were provided.

✓ Airport Expansion Consultation One set out a range of options and

approaches under consideration by Heathrow in the formation of its

masterplan.

The landscape in the airport vicinity encompasses a diverse range of

land uses, including areas that are degraded or in decline.

There was only a very brief section on landscape and

visual amenity in the consultation documents and

✓ ✓




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that more detail is required. Through the development of carefully considered and integrated

natural and built environment proposals, the Project seeks to provide

positive contributions to the local landscape and views, where

opportunities arise.

A LVIA considering a range of criterion will be undertaken to consider

the landscape character and visual amenity context of the proposals, to

minimise adverse landscape and visual consequences of the Project

and, where possible, to provide enhancement.

Further information will be contained within the PEIR to be published as


Dimensions of local River channels should be used

to define the physical characteristics of the modified

ones.

✓ The design of any modified river channels will seek to maintain

naturalised flow regimes to support a range of natural fluvial

geomorphological processes. The design will also take into account

the requirements of the water environment to allow it to function as

naturally as possible.

Supported the use of infiltration SuDS but indicated

that a large part of the area of the proposed airport

extension contains licensed and historic landfills or

land which may be affected by contamination. As a

result, infiltration SuDS may not always be an

appropriate option.

✓ Heathrow recognise that the use of infiltration-based SuDS will be

constrained by the risk of pollution to shallow groundwater.

Heathrow operate an existing SuDS system which will be expanded to

incorporate the new runway and associated airside infrastructure.

If any infiltration SuDS are proposed for areas where

there is a potential for an accidental spill of

contaminants, such as car parks, then appropriate

pollution prevention measures must be in place.

✓

Requested further information on surface water run- ✓ Heathrow recognise that the use of infiltration-based SuDS will be




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off and any exceptional release of polluted waters. constrained by the risk of pollution to shallow groundwater.

Heathrow operate an existing SuDS system which will be expanded to

incorporate the new runway and associated airside infrastructure.

Roads and other development outside the airport boundary will be

served by dedicated SuDS, in compliance with Policy 5.13 of the

London Plan. These systems will capture and attenuate surface water

before releasing it sustainably back into the environment in accordance

with the London Plan SuDS Hierarchy.

Heathrow will consider using green roofs as part of a wider offering but

the Project will have to adhere to strict Civil Aviation Authority (CAA)

guidelines on green roofs as proposing green roofs next to an airport

will attract gulls, a significant risk to aircraft.

Green infrastructure design and water efficiency is a key part of the

design in terms of the landscape and views/visual amenity and water

reuse as it provides the opportunity to integrate natural environment

components so that the Project fits into and enhances its surroundings,

wherever possible.

Concern that each proposal is considered as a

separate scheme without an overall view on the

impact to surface water, drainage and flooding.

✓

SuDS need to be considered in the design of

drainage for all large areas of hard standing

(including car parks).

✓

A fully integrated SuDS, drainage and storm

management strategy within the airport is required

and that it should consider opportunities for

integrated green roofs, living walls, and swales.

✓

Opportunities for constructed wetlands that deliver

open green spaces should be explored and that a

fully integrated SuDS, drainage and storm

management strategy is required.

✓

The best available technology with respect to water

efficiency should be used within all new supporting

facilities and terminal buildings.

✓

Rain and greywater harvesting and recycling should

be used to meet non-potable water needs.

✓

The effects of light pollution need to be considered

and requested further consultation.


impacts of light pollution. Heathrow will seek to minimise the impacts

of light pollution on the surrounding area. This assessment has

informed the design of the Project, through an ongoing evaluation




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process. Early findings of this process will be reported in the PEIR to

be published as part of the Airport Expansion Consultation in June

2019.

Proposals should be funded though other

mechanisms that do not pass on costs to airport

users.

✓ ✓ The programme for ecological measures, funding and delivery

mechanisms will be set out as part of the DCO application. The PEIR

to be published as part of the Airport Expansion Consultation in June

2019 will provide additional information.

An endowment fund, grant scheme or additional

flight levy should be set up for London's public

Parks to support their maintenance and

enhancement.

✓

Working closely with environmental stakeholders. ✓ Heathrow are considering a range of options and are engaging

stakeholders in the process. Early findings will be reported in the PEIR

to be published as part of the Airport Expansion Consultation in June

2019. Information received from stakeholders, including consultation

responses, will inform the approaches that are put forward for

consideration.



HISTORIC ENVIRONMENT

Introduction


relation to its proposed approach to managing the effects of the Heathrow

Expansion Project (the Project) on the historic environment. A total of 908


24.1.2 Heathrow provided the following material that is directly related to the approach to

managing the effects of the Project on the historic environment:



3. Our Approach to Historic Environment.

24.1.3 Heathrow asked the following questions regarding the historic environment at


1. Please tell us what you think about our approach to historic

environment issues.














Local Authorities

General comments on approach to managing effects on the historic environment

24.2.1 Buckinghamshire County Council also considered the approach to be largely

appropriate. However, they expressed concern that Heathrow’s Our Approach to

the Historic Environment document was focused on the built-environment and that

potentially significant buried archaeological remains could be missed. They



highlighted that field evaluation should take place at an early a stage to inform

preferred design options and that geophysical surveys should be ‘ground truthed’

through trail trenching as geophysical surveys can have variable results within the

area.

24.2.2 They requested that joint meetings are held with Historic England to share findings

and progress historic environment assessment in the areas of the county

potentially affected by the proposals.

24.2.3 Ealing Council considered the approach to be acceptable and noted that the

proposed method for the characterisation study appears to follow the relevant

guidance. However, they highlighted that the study area should not exclude areas

that are located beyond the immediate area of the Project, such as the Southall

area, and that the assessment should also consider the impact of airspace

design/future flight plans on these areas.

24.2.4 The London Borough of Hounslow expressed support for the three-pronged

approach of understanding, protection and opportunity and confirmed that the

approach to the historic environment identifies appropriate heritage assets in each

area. They welcomed that input has been sought from Historic England and that

Heathrow’s Our Approach to the Historic Environment document refers to their

guidance at various points.

24.2.5 They suggested that the study area could include Heston Village, Cranford and

Bedfont Green Conservation Areas. They expressed concern that there was no

detailed approach for archaeological baseline data and indicated that the

approach to assessing significance should consider potential impacts on cultural,

social and townscape changes.

24.2.6 Kent County Council considered that the scheme should make a positive

contribution to the historic environment both in its immediate area and further

afield where new flight paths may alter the way heritage assets can be enjoyed.

24.2.7 The London Borough of Sutton considered that the approach to the historic

environment was too narrowly focussed and ignored potential significant impacts

on nearby heritage assets as well as environmentally important sites such as

Royal Botanic Gardens at Kew, the Royal Parks and Windsor Castle.

Comments on specific heritage assets

24.2.8 Ealing Council highlighted that it is seeking a £150million package of measures to

maximise the economic benefits of the Project and mitigate the environmental

impacts of a third runway. They considered that the following sites should be

covered by this fund:

1. Part of Southall’s oldest building, the Grade II* Manor House to provide a café

and additional space for training; and



2. The historic St John’s Church and Gardens and the Kings Centre - to provide a

community and cultural hub.

24.2.9 Slough Borough Council welcomed the identification of Colnbrook as a potential

historic enhancement area. It stated that it would like to see enhancements to the

Colnbrook Conservation Area and the urban realm and that appropriate parts of

the Colnbrook and Poyle green envelope should be managed and enhanced in a

way which would reflect the historic importance of the area.



24.2.10 Historic England highlighted that based upon available information, a new north

west runway is likely to mean the loss of 21 designated heritage assets and effects

on the setting of 220 designated heritage assets.

24.2.11 They welcomed the research-led approach to the consideration of historic

environment issues and highlighted that this approach should result in a strategy

that understands the context and significance of all heritage assets affected and a

design and mitigation response that is appropriately informed by the baseline.

They also highlighted that there should be a presumption that scheduled

monuments and associated remains of equivalent significance should be protected

and preserved in-situ.

24.2.12 They highlighted the importance of the natural and historic environment working

together on green infrastructure and indicated that the proposed Cultural

Interpretation Framework should raise public awareness of the results of previous

archaeological interventions, and the history of the area generally.

24.2.13 They highlighted that any diversions of rivers around the airport will have an

impact on hydrology which could lead to locally waterlogged deposits experiencing

periods of drying which would be detrimental to preservation of archaeological

remains. They suggested that appropriate testing and modelling of the water

environment before, during and after diversions could be required and that Lidar

data (as well as geophysical survey) may be of use in locating potential former

paleochannels.

24.2.14 They asked for innovative and successful mitigation measures to address noise

impacts on the historic environment. They also requested further detail on the

potential for heritage assets currently in viable uses to become at risk as a result

of the Project citing the Great Barn, St Mary’s Church and the Five Bells public

house in Harmondsworth as examples of this.


24.2.15 Historic England suggested that Lanz farmhouse and the King William IV public

house (both on Harmondsworth Lane and listed Grade II) will be subject to



significant effects should the westernmost runway option be taken forward and

should be considered as part of the assessment.

24.2.16 They also highlighted that in addition to two scheduled monuments the Mayfield

Farm site is also covered by the East Bedfont Archaeological Priority Area and is

adjacent to the Bedfont Green Conservation Area. They highlighted that the site

will contain considerable archaeological potential and any proposed development

will require appropriate investigation to ensure that it will not cause harm to their

significance.



24.2.17 The Heathrow Strategic Planning Group suggested heritage assets affected by the

Project should be enhanced. They requested further development of the heritage

mitigation scheme to achieve wider objectives around traffic management,

environmental, social economic compensatory and mitigation actions and

highlighted that this will be particularly relevant to the ‘green envelope’ concept at

the Colnbrook Village Conservation Area.

24.2.18 Windlesham Parish Council expressed concern that the Project would result in the

likely loss of Longford Conservation Area and part of the Harmondsworth

Conservation Area. They deferred on this to Historic England as the experts in this

field but indicated that wherever possible historically significant buildings and

areas should be retained.

24.2.19 Horton Parish Council stated that the village of Horton contains several listed and

historic buildings. It asked that the village be designated a conservation area to

protect heritage buildings and residents from disruption from passing vehicle

traffic.

24.2.20 Bray Parish Council questioned how the Project can be acceptable when it results

in the loss of a number of listed buildings and other heritage assets.


24.2.21 No comments on specific sites/assets were received from other prescribed

consultees.

Local Communities



24.3.1 More than half of the members of the public that made comments about the

historic environment expressed concerns about the impacts of the Project on the



local area or perceived that the measures proposed to mitigate effects on the

historic environment were unsuitable, would not make a difference or lacked

credibility.

24.3.2 The concerns raised were wide ranging and comprised the loss of irreplaceable

heritage assets including listed buildings, the impact of noise and air pollution on

the historic environment and the impact on local towns and villages. The impact of

flight paths and increased flights on heritage assets and local tourism related to

the historic environment was also highlighted.

24.3.3 Concerns were also raised about the cost of the effects on the historic

environment. Members of the public who raised this issue considered that the cost

of preserving and/or relocating the heritage assets should be borne by Heathrow

and not taxpayers and that these costs may be significant.

24.3.4 Members of the public also expressed general support for the proposed approach

to the historic environment as they considered it irreplaceable. Comments were

also received that the preservation of heritage assets is important but should not

jeopardise operational safety or hinder expansion.

24.3.5 As well as raising general concerns or expressing support for the proposed

approach, the following suggestions were provided about factors that should be

considered further:

1. all heritage assets must be protected and not removed;

2. flightpaths should be designed to avoid overflying heritage assets;

3. Kew and the Royal Parks should be made a no-flight zone;

4. there should be an ongoing levy to support heritage assets across London;

5. a more proactive approach should be adopted to enable the adequate

recording of affected sites;

6. as many listed buildings as possible should be kept, even if it means

relocation;

7. priority should be placed upon listed buildings that have a social function and

contribute to community health;

8. there should be communication with/involvement of residents;

9. any archaeology found should remain publicly accessible;

10. items recovered from investigations should be preserved in a local museum

e.g. the Museum of Middlesex’, ‘Colne Valley Visitor and Learning Centre or a

Heathrow Heritage Museum;

11. there should be contributions, sponsorship and support for local museums and

galleries;



12. Heathrow should consult with experts to ensure the best approach to the

preservation of the historic environment;

13. if archaeology is found to be present within the site it would be best to leave it

undisturbed and not be compelled to ‘save/rescue’;

14. land take should be minimised to preserve as much archaeology as possible;

15. the historic environment and natural environment issues should be considered

together; and

16. Heathrow should establish a new conservation area into which affected

heritage assets could be moved.

Comments on heritage assets

24.3.6 Members of the public expressed general concerns about the effects of the Project

on the following specific properties or locations:

1. Colnbrook, Harmondsworth, Longford and Sipson conservation areas;

2. heritage assets along the River Thames;

3. Osterley House;

4. Cliveden House and Gardens;

5. Hampton Court Palace;

6. the historic centre of Windsor;

7. heritage assets in Richmond Park;

8. the Air Force Memorial at Runnymede;

9. heritage buildings in Bedford Park;

10. Chiswick House;

11. St Mary's Church;

12. Windsor Castle;

13. heritage assets at Kew Gardens;

14. Harmondsworth Great Barn

15. Holloway College and Holloway Sanatorium;

16. Taplow Court (Saxon burial site);

17. Bushy Park; and

18. Windsor Great Park

24.3.7 In addition to these general concerns respondents expressed support for the

consideration given to the potential impacts on Harmondsworth Great Barn and St



Mary's Church and indicated that detailed proposals need to be provided for the

preservation or relocation of these heritage assets.

24.3.8 Suggestions were also received that Sipson Church, Sun House, Five Bells Inn,

Grange House, Crown Inn, Gorge and Barnes Wallis Memorial should be

considered for relocation and that the best historic buildings in the Longford

Conservation Area should be relocated to the north.

Businesses

General comments on approach managing effect on the historic environment

24.3.9 Of the businesses that commented on Heathrow’s approach to the historic

environment, Hampshire Chamber of Commerce highlighted that the consideration

of heritage sites is vital. They considered that the appropriate development of the

airport would enhance the use of these assets and boost the adjacent tourism,

leisure and heritage sectors.

24.3.10 The Copas Partnership recognised the importance of the historic environment but

considered that its importance was overplayed, and that effects could not be

avoided.


24.3.11 No comments on specific heritage assets were received from businesses.

Community groups




include specific feedback on the historic environment.

24.3.13 Aircraft Noise Three Villages, Colnbrook Community Association, Teddington

Action Group, Slough and District Against Runway 3, Dover House Residents

Association, Residents Association HVG CA and the all made comments opposing

the approach and the impacts on historic assets.

24.3.14 Colnbrook Community Partnership did not consider that the impact on Colnbrook

Conservation Area and the listed buildings within it had been taken into account.

They queried why the designation of Colnbrook as a Potential Historic

Enhancement Area was not referred to in the Approach to the Historic

Environment document or other consultation information. They also suggested that

enhancements should be made to the Colnbrook Conservation Area and that

Heathrow should contribute financially to local projects which would preserve the

historic past.



24.3.15 Local Conversation in Stanwell commented that the historic buildings to the north

of Stanwell or Stanwell Moor could be deconstructed and rebuilt in a new location

near the airport and used as a teaching/learning opportunity.

24.3.16 Stanwell’s Green Lungs commented that it did not support an approach that would

result in heritage sites and features being destroyed or adversely impacted.

24.3.17 Ealing Fields Residents Association commented that historic environment issues

should be continually addressed irrespective of the proposed Heathrow expansion.

24.3.18 The Wentworth Residents Association highlighted that the impact on the

environment will be negative. They supported efforts to offset effects but

considered that this could not be adequately achieved.


24.3.19 The Sant Nirankari Mission requested exemption from inclusion within the

Heathrow Expansion proposals due to the spiritual and architectural heritage of

their land and buildings which cannot be transferred to another site.

24.3.20 Harrow U3A Sustainability Group suggested that Harmondsworth Great Barn is on

a timber frame and should be relocated, possibly to the Chalfont Open Air

Museum. They also commented that St Mary's Church will lose its congregation

and will come to resemble the village of Lowfield Heath.

24.3.21 The Old Chiswick Protection Society expressed concern about the effects of

increased traffic through Chiswick Hogarth roundabout on the Old Chiswick

Conservation Area.

24.3.22 The Richmond Heathrow Campaign considered that full weight should be given to

protecting and improving the World Heritage Site at Kew which is significantly

impacted by noise.

24.3.23 The Pavilion Association Stanwell and Stanwell Moor suggested that the area

around the Great Barn should be expanded to a Heathrow Heritage Site.



24.4.1 The World Federalist Party considered that Heathrow’s plans for the historic

environment were inadequate and lacking in detail. West London Friends of the

Earth were also critical and indicated that they did not support an approach which

would destroy or adversely impact heritage sites.

24.4.2 The London Wildlife Trust supported the consideration of the historic environment

and highlighted that areas of countryside character that support remnant features

of an agricultural landscape should be considered for protection and/or

enhancement in any proposals.



24.4.3 London Parks and Gardens considered that the loss of heritage assets such as

the Longford Conservation Area would be irreplaceable. They suggested the

establishment of a levy or other mechanism to fund and sustain heritage assets (in

particular parks and historic gardens across London which are not supported

through statutory funding) would bring huge benefits across London and provide a

unique way of offsetting any damage done.

24.4.4 The Royal Parks highlighted that the Project should contribute to the conservation

of the historic environment wherever possible.

24.4.5 The Richmond Cycling Campaign considered that the measures set out in

Heathrow’s Our Approach to the Historic Environment document should be definite

commitments rather than aspirations.

24.4.6 The National Trust expressed concern that the Project will have a direct impact on

its properties but welcomed Heathrow’s intent to minimise negative effects and

ensure everyone is treated fairly. They indicated that they have previously

opposed expansion primarily on the grounds of the noise impacts and that these

concerns need to be addressed before this position could change.

24.4.7 The Society of Antiquaries considered that the study area for the historic

environment assessment should be expanded (particularly to the west and the

north) to include all potentially affected areas, so that the total impact of the project

on heritage assets and undesignated archaeological deposits is understood. They

suggested that the airport perimeter in the vicinity of Harmondsworth should be

designed to deflect aircraft noise and mitigate visual impact on its setting.

24.4.8 They expressed concern about the potential loss and relocation of the Great Barn

and considered that if the barn cannot be retained as a monument because of

noise levels the northern half of Harmondsworth Conservation Area, also has

no future.

24.4.9 They highlighted that a comprehensive archaeological mitigation programme will

be required to address impacts on archaeological remains within the Colne Valley

floodplain and cited the example of Kingsmead Quarry which produced in-situ

archaeological remains from the Late Glacial and Mesolithic periods (10,000-4000

BC), the Neolithic, Bronze and Iron Ages and the Romano-British, Saxon and

medieval periods. They also highlighted that the Colne alluvial deposits have

greater potential for the exceptional preservation of archaeological waterlogged

organic remains and expressed concern that to the scale and importance of such

deposits had not been considered.

24.4.10 They commented that due to the limitations of non-intrusive survey techniques,

trial trenching and other intrusive survey techniques should be given greater

importance and that a clear rationale for any intrusive surveys should be

developed, rather than relying on a percentage-based approach to sampling.

They suggested that the results of all work and mitigation for the Project should be



integrated with the Geographical Information System, that a deposit model should

be created and that detailed topographic survey data for areas required for the

new expanded Heathrow should be undertaken.

24.4.11 The Milestone Society expressed concern about the destruction of the Old Bath

Road in Longford. They considered that as the road does not form part of the

runway it would be possible to retain it and site any required ancillary buildings or

features elsewhere or build them in such a way to allow retention of the route.

24.4.12 They requested that if the route is removed heritage assets should first be

carefully recovered, preserved, re-installed and exhibited elsewhere at Heathrow’s

expense. They suggested that an appropriate museum for such a display might

include the Chiltern Museum which holds and displays a number of historic

highways assets removed from the line of the M25.

24.4.13 They also expressed concern that the Project would result in the loss of other

historic milestones along Bath Road between Harlington and Longford and the

cannon marking the northern end of General Roy's Base. They highlighted that

these assets should be protected as part of scheme design and during

construction.

24.4.14 The Colne Valley Regional Park considered that where heritage assets are directly

affected, they should be moved to another location locally. Any archaeological

findings should also be displayed locally at venues such as visitor centres,

museums, community buildings and public houses.

24.4.15 They highlighted the importance of retaining and enhancing the setting of historic

villages such as Colnbrook and Harmondsworth and suggested that community

development projects should be implemented to maintain and build community

and ‘village life’.

24.4.16 They also suggested that Heathrow should provide simple interpretation boards to

keep the public fully informed during construction. These could include artists

impressions of the pre-historic landscape of the Colne Valley, photos/artwork of

the C20th landscape, a viewing hole to the construction site or and artists

impression of restored green infrastructure or airport development at the site.

24.4.17 The Church of England Diocese of London, Oxford and Southwark considered that

the approach to the historic environment was ‘broadly sound’ but indicated that it

would be preferable for these impacts not to be necessary in the first place.

24.4.18 They considered that the Church of St Mary and the Great Barn at Harmondsworth

must be retained and that any options that do not meet this criterion should be

discontinued. They also considered that the assessment of significance should

include spiritual significance and that other churches, graveyards and cemeteries

in the study area should not be overlooked.



24.4.19 Lambeth/Herne Hill Green Party suggested that Heathrow should consult with

Historic England about the approach to the historic environment.

Comments on specific sites

24.4.20 The National Trust made a number of detailed comments about properties they

considered likely to be affected by the Project that are summarised as follows.

1. Osterley currently enjoys respite from arriving aircraft when the runways are

alternated. Any attempts to end alternation at Heathrow would have a

significant impact on the way that visitors experience their visit and noise

disturbance.

2. Runnymede and Ankerwyck currently experience overflying of aircraft on

departures from the southern runway when on westerly operations. The end of

alternation would offer no respite to those enjoying this open space and would

impact on the quality of visitors’ lives. The new runway also has the potential

to dominate views from Coopers Hill at Runnymede.

3. Ham House and Gardens experiences both arrivals and departures from both

runways and the burden of being located under these flightpaths should not be

underestimated.

4. Petersham Meadows are an iconic view and have been immortalised by the

landscape painter JMW Turner. Aircraft noise is detrimental to the enjoyment of

this space.

24.4.21 They also commented that sites potentially affected by the Project and changes to

flight paths include Cliveden, Claremont Garden, Morden Hall Park, Basildon Park,

Carlyle’s House, 575 Wandsworth Drive, 2 Willow Road and Fenton House.

24.4.22 Friends of the River Crane expressed concern about the potential loss of heritage

features along river channels. They indicated that surveys for structures, heritage

or archaeological features should be undertaken by Heathrow’s consultants. They

highlighted the example of a historic brick bridge across the Upper Duke’s River

near to Harmondsworth that could be at risk due to the scheme.

24.4.23 The Royal Parks highlighted that the Kings Bridge over the river in Longford

should be retained and repositioned in a publicly accessible area.





wider/other consultees in relation to Historic Environment.








Table 24.1A


PC MC WC

Concerns about the impact of flight paths and

increased flights on heritage assets and local

tourism related to the historic environment.

✓ The Airspace Design Principles do not include a generic design

principle for Expansion on avoiding historical assets. This is because

the scope of this airspace change means that it has potential effects

over a large geographic area, within which there will be a wide range of

noise sensitive buildings/areas to consider.

(Full details of our fixed airspace design principles for Expansion can be

Flightpaths should be designed to avoid overflying

heritage assets.

✓





PC MC WC

Kew and the royal parks should be made a no-flight

zone.

✓ found at: https://www.caa.co.uk/Commercial-

industry/Airspace/Airspace-change/Decisions-from-2018/London-

Heathrow-airspace-departure-and-arrival-procedures/)

However, we are still at a relatively early stage of our airspace design

process which started from a ‘blank sheet’. We have now identified the

‘design envelopes’, which show the geographical areas which are

potentially overflown. This consultation asks for feedback on local

factors relating to these areas to which we will have regard in designing

the flight paths. Local factors can include historical assets. See further

Heathrow’s Airspace design envelopes for expansion and Making

Better Use of Our Existing Runways.

Further information of the likely effects of the Project on the historic

environment will be presented in the Preliminary Environmental

Information Report (PEIR) as part of the Airport Expansion Consultation

in June 2019.

https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decisions-from-2018/London-Heathrow-airspace-departure-and-arrival-procedures/






PC MC WC

Osterley currently enjoys respite from arriving

aircraft when the runways are alternated. Any

attempts to end alternation at Heathrow would have

a significant impact on the way that visitors

experience their visit and noise disturbance.

✓ Alternation

Heathrow recognises that a new third runway provides an opportunity to

consider how the runways will operate in the future, and that this will

require a change to how runway alternation operates today.

The Airspace and Future Operations Consultation in January 2019

provides information on our emerging proposals for the provision of

respite through alternation.

For more information, please see the Airspace and Future Operations:

Consultation Document and the Runway Operations – Respite Through

Alternation Documents.

Overflight generally

The Airspace Design Principles do not include a generic design





(Full details of our fixed airspace design principles for Expansion can be

found at: https://www.caa.co.uk/Commercial-








the flight paths. Local factors can include sensitive placed and

historical assets. See further Heathrow’s Airspace design envelopes







PC MC WC

for expansion and Making Better Use of Our Existing Runways.

We will treat this comment as response on local factors.

Further information of the likely effects of the Project (including on the

historic environment) will be presented in the Preliminary Environmental


in June 2019.




PC MC WC

Ham House and Gardens currently experiences both

arrivals and departures from both runways and the

burden of being located under these flightpaths

should not be underestimated.






(Full details of our fixed airspace design principles for Expansion can

be found at: https://www.caa.co.uk/Commercial-















in June 2019.







PC MC WC

Petersham Meadows are an iconic view and have

been immortalised by the landscape painter JMW

Turner. Aircraft noise is detrimental to the enjoyment

of this space.






(Full details of our fixed airspace design principles for Expansion can

be found at: https://www.caa.co.uk/Commercial-















in June 2019.







PC MC WC

Runnymede and Ankerwyck currently experience

overflying of aircraft on departures from the

southern runway when on westerly operations. The

end of alternation would offer no respite to those

enjoying this open space and would impact on the

quality of visitors’ lives.

✓ Alternation

Heathrow recognises that a new third runway provides an opportunity to

consider how the runways will operate in the future, and that this will

require a change to how runway alternation operates today. We are

committed to delivering respite through alternation as part of the

Project.

The Airspace and Future Operations Consultation in January 2019

provides information on our emerging proposals for the provision of

respite through alternation.

For more information, please see the Airspace and Future Operations:

Consultation Document and the Runway Operations – Respite Through

Alternation Documents.

Further information of the likely effects of the Project will be presented

in the Preliminary Environmental Information Report (PEIR) as part of




Table 24.1B

Issue Consultee Heathrow Response

PC MC WC

The approach to the historic environment is

acceptable, noting that the proposed method for the

characterisation study appears to follow the relevant

guidance.

✓ Comments duly noted.

Support for the three-pronged approach of

understanding, protection and opportunity and

confirmed that the approach to the historic

environment identifies appropriate heritage assets in

each area.

✓

General support for the proposed approach to the

historic environment.

✓

Welcomed the research-led approach to the

consideration of historic environment issues and

highlighted that this approach should result in a

strategy that understands the context and

significance of all heritage assets affected and a

design and mitigation response that is appropriately

informed by the baseline.

✓

The natural and historic environment are important

elements to green infrastructure.

✓




PC MC WC

In addition to two scheduled monuments the Mayfield

Farm site is also covered by the East Bedfont

Archaeological Priority Area and is adjacent to the

Bedfont Green Conservation Area.

✓

The approach to the historic environment was

‘broadly sound’ but it would be preferable for these

impacts not to be necessary in the first place.

✓

The consideration of heritage sites is vital.

✓

Why was the designation of Colnbrook as a Potential

Historic Enhancement Area not referred to in the

approach to historic environment or consultation

information?

✓ The information leaflet for Poyle, Colnbrook and Brands Hill provided at

the Airport Expansion Consultation One identified Colnbrook as a

potential historic enhancement area.

Further details on proposed potential enhancements and mitigation to

the historic environment will be provided in the Preliminary

Environmental Information Report (PEIR) that will be published at the

Airport Expansion Consultation in June 2019. The document Our

Approach to the Historic Environment published at the Airport

Expansion Consultation One provided a high-level overview of

Heathrow’s early considerations regarding its approach to the historic

environment to seek feedback early in the design process of the

Project.




PC MC WC

The study area should not exclude areas which lie

beyond the immediate area of the proposed

expansion, such as the Southall area, and the

assessment should also consider the impact of

airspace design/future flight plans on these areas.

✓ Heathrow are undertaking an Environmental Impact Assessment (EIA)

of the Project, and early findings will be reported in the Preliminary

Environmental Information Report (PEIR) to be published as part of the

Airport Expansion Consultation in June 2019. This will include an

assessment of likely effects of the Project on heritage assets.

Heathrow proposes that the study area for the purposes of the EIA will

comprise a core study area and a wider study area. The core study area

is to be based on an area extending a one-kilometre beyond the

proposed development area for the Project.

A wider study area will be defined to identify heritage assets which lie

beyond the core study area but which may be impacted by operational

effects relating to noise and the setting of heritage assets, known as the

zone of theoretical visibility. The wider study area will be identified in

accordance with Scoping Opinion published by the Planning

Inspectorate in July 2018. Section 4.7 of the Scoping Opinion states the

following regarding the study area for the historic environment

assessment “the potential for significant effects from airport operations

on settings of heritage assets beyond the ‘core’ study area and within

the within the zone of theoretical visibility should be considered in the

ES”.

The study area could include Heston Village,

Cranford and Bedfont Green Conservation Areas.

✓

The study area for the historic environment

assessment should be expanded (particularly to the

west and the north) to include all potentially affected

areas, so that the total impact of the Project on

heritage assets and undesignated archaeological

deposits is understood.

✓




PC MC WC

Concern that the Approach to the Historic

Environment document was built-environment

orientated and that potentially significant buried

archaeological remains could be missed.

✓ Heathrow recognise the importance of archaeological remains as

heritage assets and in accordance within planning policy aim to avoid

damage to the most significant archaeological sites. (Airports National

Policy Statement (ANPS) 5.212)) The ANPS also notes that “where a

site on which development is proposed includes or has the potential to

include heritage assets with archaeological interest, the applicant

should include an appropriate desk-based assessment and, where

necessary, a field evaluation. The applicant should ensure that the

extent of the impact of the proposed development on the significance of

any heritage asset affected can be adequately understood from the

application and supporting documents.” Heathrow will accord with this

approach as set out in the ANPS.

Heathrow are undertaking research to predict the nature and extent of

surviving archaeological remains across the site. Where the potential

presence of significant archaeological sites remains, there are several

mitigation strategies that can be agreed before construction to facilitate

development while minimising potential disturbance. This approach will

be set out in the PEIR to be published as part of the Airport Expansion


Further archaeological field evaluation or other investigation will be

undertaken in accordance with the overarching written scheme of

investigation (to be produced in agreement with Historic England, the

Heathrow Strategic Planning Group (HSPG) and the Greater London

Archaeology Advisory Service (GLAAS).

Individual archaeological field investigations are to be agreed as

detailed site specific written schemes of investigation, prepared in

collaboration with construction contractors and subject to stakeholder

consultation and approval.




PC MC WC

Field evaluation should take place at an early stage

to inform preferred design options and geophysical

surveys should be ‘ground trothed’.

✓ In accordance with Historic England advice and guidance, the historic

environment baseline surveys Heathrow are undertaking include

archaeological field evaluation (see paragraph 11.9.8 of the EIA

Scoping Report)). The baseline data and the assessment of likely

impacts on heritage assets will inform the design of the Project.

The Mayfield Farm site will contain considerable

archaeological potential and any proposed

development will require appropriate investigation to

ensure that it will not cause harm to their

significance.

✓

A comprehensive archaeological mitigation

programme will be required to address impacts on

archaeological remains within the Colne Valley

floodplain

✓

The Colne alluvial deposits have greater potential for

the exceptional preservation of archaeological

waterlogged organic remains, concern that to the

scale and importance of such deposits had not been

considered.

✓

Due to the limitations of non-intrusive survey

techniques, trial trenching and other intrusive survey

techniques should be given greater importance and

that a clear rationale for any intrusive surveys should

be developed, rather than relying on a percentage-

based approach to sampling.

✓




PC MC WC

Request that joint meetings are held with Historic

England to share findings and progress the historic

environment assessment in the areas of the county

potentially affected by the proposals.

✓ Heathrow have a programme of ongoing engagement with Historic

England including joint meetings with the HSPG. These discussions

have been ongoing since late 2017. These ongoing meetings with

Historic England are informing the approach being taken for the EIA

relating to the historic environment

Heathrow also has an ongoing programme of engagement with

communities and residents covering a variety of issues including the

historic environment.

There should be communication with/involvement of

residents.

✓

Heathrow should consult with experts to ensure the

best approach to the preservation of the historic

environment.

✓

Heathrow should consult with English Heritage about

the approach to the historic environment.

✓

Concern that there was no detailed approach for

archaeological baseline data.

✓ Since the Airport Expansion Consultation One Heathrow have published

details of our approach to the collection of historic environment baseline

data sources in chapter 11 of the EIA Scoping Report. The Secretary of

State provided their scoping opinion in June 2018 and we will be

developing the baseline data in accordance with our report and their

comments. The details will form part of the PEIR to the published as





PC MC WC

The approach to assessing significance should

consider potential impacts on cultural, social and

townscape changes.

✓ In urban areas landscape may be termed townscape, which includes

buildings and urban open space. The methodology for assessing the

likely impacts of the proposed development, including the impacts of

noise, on landscape and townscape amenity is set out in the EIA

Scoping Report. Specifically, it is covered in the Chapter 13 dealing

with landscape and visual amenity. The assessment of these impacts

will be presented in the PEIR in the Airport Expansion Consultation in

June 2019.

The masterplan will be carefully designed to avoid or minimise adverse

landscape and visual consequences of development and, where

possible, provide enhancement. Impacts on landscape and townscape

amenity will also be considered as part of the airspace design proposals

and the airspace change process as, well as the DCO application. The

impacts of aircraft noise on open spaces and tranquility will be one of

several factors that will be considered as part of the development of the

airspace design and the siting of flightpaths.

Concerns about the impacts of expansion on the

local area.

✓

Concerns regarding the impact on local people,

towns and villages and the effects on tourism.

✓




PC MC WC

The following sites should be covered by a fund:

• The Grade II* Manor House - to provide a café and additional space for training; and

• The historic St John’s Church and Gardens and the Kings Centre - to provide a community and cultural hub.

✓ Heathrow is undertaking an assessment of likely impacts on heritage

assets as part of the EIA for the Project, including identification of

potential mitigation measures. For assessment of effects on the historic

environment, a two-part study area is being determined in accordance

with the proposals set out in Heathrow’s Scoping Report and as

commented on by the Secretary of State in the Scoping Opinion

received in June 2018. Preliminary findings will be presented in the

PEIR as part of the Airport Expansion Consultation in June 2019. This

will include early information on our proposed mitigation measures for

the historic environment.

As set out in Heathrow’s EIA Scoping Report (2018), additional

mitigation measures will be identified on a case by case basis

depending on the significance of the heritage asset and the likely

environmental effect and may include: provision of enhanced access

and interpretation to heritage assets to mitigate potential loss of historic

interest; and localised enhancement measures within areas of historical

and architectural interest to mitigate against visible change in setting

causing loss of historical and architectural interest.

Heathrow are also proposing a Community Compensation Fund, details

of which will be consulted on as part of the Airport Expansion


A new north-west runway is likely to mean the loss of

21 designated heritage assets and effects on the

setting of 220 designated heritage assets.

✓ Heathrow has currently identified 17 listed buildings within the boundary

of the land being considered for the Project. The Longford and

Harmondsworth Conservation Areas are also within the boundary. In




PC MC WC

[GROUP D] Concern that the project would result in

the likely loss of Longford Conservation Area and

part of the Harmondsworth Conservation Area. The

loss of these assets would be irreplaceable.

✓ ✓ certain circumstances, it may be possible to consider relocation and

reconstruction, but in other cases, the proposals will result in permanent

loss of the heritage asset.

The ANPS (paragraph 5.200) confirms that the Secretary of State will

give great weight to the conservation of heritage assets. The ANPS

further states (5.203) that harmful impacts to the significance of a

heritage asset will need to be weighed against the public benefit of the

Project, recognising that and that the greater the harm to the

significance of the heritage asset, the greater the justification that will

needed for any loss.

In developing the preferred masterplan for the Project, where demolition

or loss of a heritage asset is unavoidable, Heathrow will need to put

forward justification for such loss. In addition, Heathrow will accord with

the ANPS (paragraphs 5.209 to 5.212) regarding carrying out relevant

recording and the depositing of those records with the relevant Historic

Environmental Record and repository.

Heathrow is continuing to develop the preferred masterplan which

includes understanding the potential effects on heritage assets.

Early findings of the EIA for the Project will be reported in the PEIR to


2019. This will include an assessment of likely effects of the Project on

heritage assets. The PEIR will also consider mitigation measures, and

this could include scope for relocation or for retention of specific

architectural elements which can then be placed within a relevant

museum repository.

There should be a presumption that scheduled

monuments and associated remains of equivalent

significance should be protected and preserved in-

situ.

✓

Historic environment is irreplaceable and should

therefore be a priority and the preservation of

heritage assets is important but should not

jeopardise operational safety or hinder expansion.

✓

As many listed buildings as possible should be kept,

even if it means relocation.

✓

Recognised the importance of the historic

environment but considered that its importance was

overplayed, and that effect could not be avoided.

✓

Historic environment would be impacted or

destroyed by expansion.

✓

It is noted that the impact on Colnbrook

Conservation Area and the listed properties within it

will be taken into account.

✓




PC MC WC

Do not support an approach that would result in

heritage sites and features being destroyed or

adversely impacted.

✓

The impact on the environment will be hugely

negative.

✓

Supported efforts to offset effects but considered

that this could not be adequately achieved.

✓

Concern about the effects of increased traffic

through Chiswick Hogarth roundabout on the Old

Chiswick Conservation Area.

✓

Heathrow’s plans for the historic environment were

inadequate or lacking detail.

✓

Do not support an approach which would destroyed

or adversely impact heritage sites.

✓

Concerns about the loss of irreplaceable historic

assets and listed buildings.

✓

How can the development be acceptable when it

results in the loss of listed buildings and other

heritage assets?

✓




PC MC WC

Concern about the potential loss of heritage features

along river channels.

✓

Concern that expansion would result in the loss of

other historic milestones along Bath Road between

Harlington and Longford and the cannon marking the

northern end of General Roy's Base. These assets

should be protected as part of scheme design and

during construction.

✓

Concern about the potential loss and relocation of

the Great Barn.

✓

The historic buildings to the north of Stanwell or

Stanwell Moor could be deconstructed and rebuilt in

a new location near the airport and used as a

teaching/learning opportunity.


impacts on the historic environment and will conclude with mitigation

measures to avoid and reduce adverse impacts. Early findings and

mitigation proposals will be set out in the PEIR to be published for

consultation in the Airport Expansion Consultation in 2019.

Our approach to mitigation for heritage assets includes a consideration

of the translocation of heritage assets to retain elements of architectural

and historic interest. It also includes the provision of enhanced access

and interpretation to heritage assets to mitigate potential loss of historic

interest.

The proposed Cultural Interpretation Framework

should raise public awareness of the results of

previous archaeological interventions, and the

history of the area generally.

✓ Heathrow will consider its approach to heritage interpretation as part of

wider measures to be proposed in reference to the preferred masterplan

and this will be presented at Airport Expansion Consultation in June

2019.




PC MC WC

Any diversions of rivers around the airport will have

an impact on hydrology which could lead to locally

waterlogged deposits experiencing periods of drying

which would be detrimental to preservation of

archaeological remains.

✓ Heathrow are undertaking research to predict the nature and extent of

surviving archaeological remains across the site. Early findings of the

EIA for the Project will be reported in the PEIR to be published as part

of the Airport Expansion Consultation in June 2019. This will include an

assessment of likely effects of the Project on heritage assets.

Appropriate testing and modelling of the water

environment before, during and after diversions

could be required and that Lidar data (as well as

geophysical survey) may be of use in locating

potential former paleo channels.

✓

Further detail on the potential for heritage assets

currently in viable uses to become at risk as a result

of airport expansion citing the Great Barn, St Mary’s

Church and the Five Bells public house in

Harmondsworth as examples of this.

✓ Potential impacts of the Project on the Great Barn, St Mary’s Church,

Lanz Farmhouse, the King William IV Public House and Five Bells

public house in Harmondsworth are being assessed as part of the EIA

for the Project. Early findings will be reported in the PEIR to be


This will include both an assessment of likely effects of the Project on

heritage assets and potential impacts in regard to community resources

and businesses (reported in the Community and Socio-Economic

chapters of the PEIR).

Lanz farmhouse and the King William IV public house

(both on Harmondsworth Lane and listed Grade II)

will be subject to significant effects should the

westernmost runway option be taken forward and

should be considered as part of the assessment.

✓

Historic assets affected by expansion should be

enhanced.

✓ Heathrow recognises that loss of conservation areas and listed

buildings is only permitted in exceptional or wholly exceptional

circumstances. The ANPS guides Heathrow to make decisions that

avoid and minimise harm, and this applies to all aspects of the project,

including temporary as well and permanent development effects that All heritage assets must be protected and not

removed.




PC MC WC

Wherever possible historically significant buildings

and areas should be retained.

✓ might harm the fabric of heritage assets or the setting of heritage

assets.

One of the key principles of Heathrow’s approach to the historic

environment is opportunity. As part of this, an exploration of initial

options to unlock the potential for sustainable uses of heritage assets

and for creating circumstances to help others to manage heritage

assets that might otherwise be at risk; as well as creating new amenity

that increase people’s ability to enjoy the wider historic environment.

Heathrow’s understanding of the heritage assets and their significance

will inform design proposals for the Project and in doing so address the

ANPS policy.

Specifically, Heathrow will seek to reduce loss of or substantial harm to

the Longford conservation area and part of Harmondsworth

conservation area and associated heritage assets, including both

designated and non-designated heritage buildings. This is underpinned

by the evaluation process for the ongoing design of the Project, which

includes a consideration of heritage as part of the assessment criteria

that influence the progression of the design. The outcomes of this

evaluation, including how criteria have informed the decision-making

process in considering design options will be reported in the Updated

Scheme Development Report in June 2019.

Heathrow is restricted to minimal land take essential to expand national

airport capacity in accordance with the ANPS.




heritage assets.

Would like to see enhancements to the conservation

area and the urban realm and that appropriate parts

of the Colnbrook and Poyle. Green envelope should

be managed and enhanced in a way which would

reflect the historic importance of the area.

✓

Enhancements should be made to the conservation

area and that Heathrow should contribute financially

to local projects which would preserve the historic

past.

✓

The appropriate development of the airport would

enhance the use of these assets and boost the

adjacent tourism, leisure and heritage sectors.

✓

Areas of countryside character that support remnant

features of an agricultural landscape should be

considered for protection and/or enhancement in any

proposals.

✓

The scheme should make a positive contribution to

the historic environment both in its immediate area

and further afield where new flight paths may alter

the way historical assets can be enjoyed.

✓

The project should make a contribution to retain the

historic environment wherever possible.

✓




PC MC WC

Heathrow should establish a new conservation area

into which affected heritage assets could be moved.

✓ The designation of new conservation areas (or amendments to existing

conservation areas) is a matter for the relevant local authority in

accordance with the provisions of the Planning (Listed Buildings and

Conservation Areas) Act 1990.

Heathrow will assess the effects of the Project on heritage assets and

early findings of the EIA for the Project will be reported in the PEIR to


2019.

The village of Horton should be designated a

conservation area to protect heritage buildings and

residents from disruption from passing vehicle

traffic.

✓

Requested further development of the heritage

mitigation scheme to achieve wider objectives

around traffic management, environmental, social

economic compensatory and mitigation actions and

highlighted that this will be particularly relevant to

the ‘green envelope’ concept at the Colnbrook Village

Conservation Area.

✓ The heritage mitigation scheme will be further developed to achieve

wider objectives around traffic management, environmental, social

economic compensatory and mitigation actions. This information will be

provided in the PEIR to be published in June 2019.

Concern that the measures proposed to mitigate

effects on the historic environment were unsuitable,

would not make a difference or lacked credibility.

✓ At Airport Expansion Consultation One high level information was

provided on Our approach to the Historic Environment, which reflected

the early stage of the design process, environmental assessment and




PC MC WC

The measures set out in the approach to historic

environment should be definite commitments rather

than just aspirations.

✓ mitigation proposals relating to the Project.

Heathrow is continuing to develop the preferred masterplan which

includes understanding the potential effects on heritage assets.




heritage assets. The PEIR will also consider mitigation measures and

will reflect continued engagement with Historic England (and other

stakeholders).

Concerns about the impact of noise and air pollution

on the historic environment.

✓ Heathrow will assess the effects of the Project on the Historic

Environment and this will include the effects of noise on the setting of

heritage assets. Early findings of the EIA for the Project will be reported

in the PEIR to be published as part of the Airport Expansion


Concerns about the cost of the effects on the historic

environment.

✓ As part of the EIA for the Project Heathrow will be carrying out an

assessment of the likely effects on the historic environment, and this will

include consideration of relevant measures to address any identified

effects.



2019, and this will include consideration of mitigation.

The cost of preserving and/or relocating the heritage

assets should be borne by Heathrow and not

taxpayers.

✓

There should be an ongoing levy to support historic

assets across London.

✓




PC MC WC

There should be contributions, sponsorship and

support for local museums and galleries.

✓

Establishment of a levy or other mechanism to fund

and sustain heritage assets (in particular parks and

historic gardens across London which are not

supported through statutory funding) would bring

huge benefits across London and provide a unique

way of offsetting any damage done.

✓

A more proactive approach should be adopted to

enable the adequate recording of affected sites.

✓

Any archaeology found should remain publicly

accessible.

✓

Items recovered from investigations should be

preserved in a local museum e.g. the Museum of

Middlesex’, ‘Colne Valley Visitor and Learning Centre

or a Heathrow Heritage Museum.

✓

If the Old Bath Road in Longford is removed heritage

assets should first be carefully recovered, preserved,

re-installed and exhibited elsewhere at Heathrow’s

expense. An appropriate museum for such a display

might include the Chiltern Museum which holds and

displays several historic highways assets removed

from the line of the M25.

✓




PC MC WC

Priority should be placed upon listed buildings that

have a social function and contribute to community

health.

✓ The Historic Environment assessment methodology recognises the

requirement for designated heritage assets to be assessed on a case

by case basis, in accordance with legislation. This approach is adopted

for Listed Buildings, Registered Historic Parks and Gardens, and

Scheduled Monuments.

Heathrow will present findings of its initial assessment of impacts on the

historic environment in the PEIR as part of the Airport Expansion


If archaeology is found to be present within the site it

would be best to leave it undisturbed and not be

compelled to ‘save/rescue’.

✓ Heathrow are undertaking research to predict the nature and extent of

surviving archaeological remains across the site. Early findings of the

EIA for the Project will be reported in the PEIR to be published as part

of the Airport Expansion Consultation in June 2019, and this will include

the approach to confirming baseline data. Land take should be minimised to preserve as much

archaeology as possible.

✓

The historic environment and natural environment

issues should be considered together.

✓ Heathrow is continuing to engage with Historic England and other

stakeholders, and this includes regular meetings with the HSPG under

forums relating to both green infrastructure and the historic

environment.




PC MC WC

Concerns about the effects of expansion on specific

properties or locations, these included:

• Colnbrook, Harmondsworth, Longford and Sipson conservation areas;

• heritage assets along the River Thames;

• Osterley House;

• Cliveden House and Gardens;

• Hampton Court Palace;

• the historic centre of Windsor;

• heritage assets in Richmond Park;

• the Air Force Memorial at Runnymede;

• buildings in Bedford Park;

• Chiswick House;

• St Mary's Church;

• Windsor Castle;

• heritage assets at Kew Gardens;

• Harmondsworth Great Barn;

• Holloway Collage and Holloway Sanatorium;

• Taplow Court (Saxon burial site);

• Bushy Park; and

• Windsor Great Park.

✓ The ANPS gives great weight to heritage conservation (paragraph

5.200). Harmful impacts will be weighed against the public benefit of

Heathrow’s proposals, recognising that the greater the harm to the


needed for any loss (paragraph 5.203).

Heathrow acknowledges and appreciates the feedback received

regarding specific heritage assets. We will assess the likely effects of

the Project on all heritage assets which fall within the study areas

confirmed for the purposes of the EIA, and early findings will be

presented in the PEIR as part of Airport Expansion Consultation in June

2019. This will include relevant mitigation measures being considered.

Chapter 11, Section 11.9 of Heathrow’s EIA Scoping Report (2018) sets

out our approach to preparing the baseline and identification of heritage

assets for the assessment of impacts on the historic environment.

Heathrow recognises that it may be possible to relocate and reconstruct

heritage assets where they would otherwise be lost or significantly

affected by development, but such actions can only ever be considered

on a case-by-case basis.

Full weight should be given to protecting and

improving the World Heritage Site at Kew which is

significantly impacted by noise.

✓

Why the designation of Colnbrook as a Potential

Historic Enhancement Area was not referred to in the

approach to historic environment or consultation

information.

✓




PC MC WC

The Sant Nirankari Mission should be exempt from

inclusion within the expansion plans due to their

spiritual and architectural heritage which cannot be

transferred to another site.

✓

Concern that the expansion of Heathrow will have a

direct impact on National Trust properties

✓

The airport perimeter in the vicinity of

Harmondsworth should be designed to deflect

aircraft noise and mitigate visual impact on its

setting.

✓

Concern about the destruction of the Old Bath Road

in Longford. As the route does not form part of the

runway it would be possible to retain it and site any

required ancillary buildings or features elsewhere or

build them in such a way to allow retention of the

route.

✓




PC MC WC

The Kings Bridge over the river in Longford should

be retained and repositioned in a publicly accessible

area.

✓

Sipson Church, Sun House, Five Bells Inn, Grange

House, Crown Inn, Gorge and Barnes Wallis

Memorial should be considered for relocation and

that the best historic buildings in the Longford

Conservation Area should be relocated to the north.

✓

Sites potentially affected by expansion and changes

to flight paths include Cliveden, Claremont Garden,

Morden Hall Park, Basildon Park, Carlyle’s House,

575 Wandsworth Drive, 2 Willow Road and Fenton

House.

✓

A historic brick bridge across the Upper Duke’s River

near to Harmondsworth could be at risk due to the

Project.

✓




PC MC WC

Harmondsworth Great Barn is on a timber frame and

should be relocated, possibly to the Chalfont Open

Air Museum.

✓ Heathrow’s proposals to the Airports Commission, developed following

consultation with local communities, suggested options for the

preservation of both the Grade I listed Harmondsworth Great Barn and

the Grade II* listed St Mary’s Church in the present locations. Retaining

these significant heritage assets in in situ remains our preferred

approach, although one of our key concerns is to avoid exposing them

to increased risk. Heathrow will continue to consult with residents and

other stakeholders about options for the future setting and use of these

buildings and the ways in which we can mitigate the effects of the

development.

The effects of the Project on both the Great Barn and St Mary’s Church

will be assessed and early findings presented in the PEIR as part of the


The area around the Great Barn should be expanded

to a Heathrow Heritage Site.

✓

If the Great Barn cannot be retained as a monument

because of noise levels the northern half of

Harmondsworth Conservation Area, also has no

future.

✓

Church of St Mary and the Great Barn at

Harmondsworth must be retained and that any

options that do not meet these criteria should be

discontinued.

✓

St Mary's Church will lose its congregation and will

come to resemble Lowfield Heath.

✓




PC MC WC

Concerns about the effects on the green belt,

heritage assets, biodiversity, increased levels of

traffic and parking, new transport infrastructure such

as road repositioning and widening, new railway

lines and additional airport support facilities.

✓ The ANPS gives great weight to heritage conservation (para 5.200).

Harmful impacts will be weighed against the public benefit of

Heathrow’s proposals, recognising that the greater the harm to the


needed for any loss (para 5.203).

Heathrow are undertaking an EIA of the Project, and early findings will

be reported in the PEIR to be published as part of the Airport Expansion

Consultation in June 2019. This will include an assessment of likely

effects of the Project on heritage assets. It will also include chapters

reporting findings of our assessed impact on biodiversity, traffic and

transport and landscape.

Suggestion that the results of all work and mitigation

for the third runway project should be integrated with

the Geographical Information System (GIS).

✓ All fieldwork arising from trial work and mitigation for the third runway

project will be integrated with the GIS system.

A deposit model should be created and that detailed

topographic survey data for areas required for the

new expanded Heathrow should be undertaken.

✓ Heathrow is collating all available aerial photography, and LIDAR data

which will inform the topographic survey assessment, including mapping

areas already destroyed.

Any archaeological findings should also be displayed

locally at venues such as visitor centres, museums,

community buildings and public houses.

✓ In the ES, Heathrow will set out the proposed methodology for

developing and implementing an archaeological research framework

from the early stages of the Project through to completion. Early

proposals on this framework will be set out in the PEIR, to be published

in June 2019.




PC MC WC

The importance of retaining and enhancing the

setting of historic villages such as Colnbrook and

Harmondsworth and suggested that community

development projects should be implemented to

maintain and build community and ‘village life’.

✓ As part of considering mitigation measures associated with the effects

of the Project on historic environment, Heathrow will be exploring a

strategy for enhancing the setting of historic villages. The strategy is

also considering how heritage assets can be used for community

development projects in the local villages to maintain the assets and

help build community life

Heathrow continues to run Community Engagement workshops which

include discussions on heritage assets and their role within local

communities, and this will inform the development of the preferred

masterplan to be presented at the Airport Expansion Consultation in

June 2019.

Heathrow should provide simple interpretation

boards to keep the public fully informed during

construction. These could include artist’s

impressions of the pre-historic landscape of the

Colne Valley, photos/artwork of the C20th landscape,

a viewing hole to the construction site or and artists

impression of restored green infrastructure or airport

development at the site.

✓ Heathrow’s will be developing its wider interpretation strategy, which will

include heritage interpretation, and early details of this will form part of

the materials presented with the preferred masterplan at Airport


The assessment of significance should include

spiritual significance and that other churches,

graveyards and cemeteries in the study area should

not be overlooked.

✓ Heathrow are undertaking an assessment of impacts on heritage assets

as part of the EIA. Churches cemeteries, and graveyards are included

in this assessment. Early findings will be published for consultation in

June 2019 in the PEIR.

The new runway also has the potential to dominate

views from Coopers Hill at Runnymede.

✓ Heathrow will be including Coopers Hill in our landscape and visual

impact assessment, and preliminary findings will be presented in the

PEIR as part of the Airport Expansion Consultation in June 2019.




PC MC WC

Surveys for structures, heritage or archaeological

features should be undertaken by Heathrow’s

consultants.

✓ Heathrow have appointed a range of environmental specialists to

undertake environmental surveys and assessment work.



AIRSPACE

Introduction

25.1.1 In response to Airport Expansion Consultation One, most consultees that made

comments about airspace did so directly in response to the Airspace Consultation

which had a separate feedback form. These are separately reported in the

Airspace Principles Analysis of Findings Report. Consultees did however make

general comments in relation to flight paths and airspace in their responses to the

Airport Expansion Consultation One. A total of 134 consultees made comments

relating to this topic.

25.1.2 Heathrow provided the following material that is directly related to airspace:


2. Our Emerging Plans;

3. Airspace Principles Consultation Document;

4. Airspace Change Information Paper; and

5. Heathrow Operations Handbook.















Local Authorities

25.2.1 The most common response from local authorities was that flight paths had not

been shown and so it was not possible to understand who would be affected and

to what extent. The London Borough of Brent, Ealing Council, Elmbridge Borough



Council, Spelthorne Borough Council, Surrey County Council, and the Royal

Borough of Windsor and Maidenhead all made this comment.

25.2.2 Buckinghamshire County Council commented that new flight paths could have a

significant adverse impact on the quality of life and health of its residents, service

users and workers. They considered that minimising the need to affect new

populations and businesses should be the first principle in the redesign

of airspace.

25.2.3 They also expressed concern about impacts on the communities of Dorney and

Taplow who would be directly under the east – west flight path, and the Colne

Valley Regional Park which they considered would be significantly adversely

impacted if the majority of new flight paths are routed away from urban areas.

25.2.4 The Royal Borough of Kingston upon Thames expressed concern that flight paths

will be focussed on areas that do not already have significant air quality issues and

will therefore be over areas with existing low background noise levels. They asked

for further information on the assessment principles and the capping of airport size

and flight numbers. They also queried the implications for aircraft stacking if the

airport operates at full capacity.

25.2.5 Kent County Council emphasised the importance of working with local

communities and those affected by overflight to reduce the impacts of noise from

the Project. They also considered that new flight paths may alter the way heritage

assets can be enjoyed.

25.2.6 Runnymede Borough Council stated that there should be a wider dispersal of flight

paths in order to distribute noise more fairly. They considered that although this

would affect more people it would provide greater respite to those that would

otherwise be under a concentrated flight path.

25.2.7 Spelthorne Borough Council suggested that planes should gain as much altitude

as possible as quickly as possible and that the current stacking arrangements

should be removed. They also commented that residents should benefit from

quieter aircraft/airport technology and systems.

25.2.8 Surrey County Council expressed concern that if the new runway cannot

accommodate the largest planes it would increase usage of the other runways with

the likelihood of more overflight of its communities.


25.2.9 Highways England queried whether the environmental statement for the airspace

change process will be the same as for the DCO application. They commented

that if the two are different they will need to be consulted on whether the

determination of flight paths could alter decisions about highway networks.




25.2.10 Albury Parish Council expressed concern about planes taking off to the west and

then turning east on route to Europe and eastern destinations. They considered

that the increased number of aircraft using these routes would further impact on

the Surrey Hills AONB and its tranquillity.

25.2.11 Bray Parish Council also said that little or no information about flight paths had

been provided.

25.2.12 The Civil Aviation Authority (CAA) stated that there must be no unacceptable

safety, economic or airspace consequences arising from the proposals that would

prevent them from providing the relevant regulatory approvals. They stated that

this will require Heathrow to engage with the CAA on its proposals with sufficiently

detailed and mature information so that they can provide meaningful advice and

commentary and ultimately be satisfied that the ‘no impediments’ threshold has

been met.

25.2.13 The Heathrow Strategic Planning Group highlighted that a key issue was how

predictable, reliable runway and flight path alternation could be provided to allow

respite to local communities throughout the day, night and shoulder periods.

Local Communities


25.3.1 Members of the public commented that flight paths should be over less populated

areas and should consider noise. Linked to this were suggestions that urban

areas should be avoided, that flights should not be routed over London and that

where flights do go over urban areas the flight paths should be wider to share

noise more equally.

25.3.2 Suggestions were also received that flight paths should be moved to locations

where dilution or dispersion would be easier, circling/stacking should be reduced

and flight paths should be tied to specific noise and air quality limits.

Businesses

25.3.3 Greengauge 21 requested an analysis of the costs and environmental benefits of

extending the Southern Runway to the west to provide quieter landings for planes

from the east and decrease the number of residents within the 65-decibel contour.

25.3.4 Heathrow Hub commented that the scheme is dependent on an unprecedented

scale of airspace change and if this cannot be delivered the scheme would not be

able to operate at the capacity and/or with the respite that has been assumed.

They also expressed concern that there is no consideration how airspace change



would affect other London and south east airports or the flight paths necessary to

deliver runway alternation and respite.

25.3.5 The London Airline Consultative Committee and the Board of Airline

Representatives UK stated that the UK’s airspace is in urgent need of

modernisation and this is necessary to support the Project. Clear policy direction

from the government is urgently required to ensure that the international

commitments of the UK via ICAO’s Balanced Approach to noise, carbon and air

quality needs can be met.

25.3.6 They also expressed concern that until an airspace design is agreed it will not be

possible to define, consult on and agree the noise envelope.

25.3.7 PPL/IR Europe commented that the needs of other airspace users need be

considered. They specifically highlighted the following three groups who use

airspace near to Heathrow:

1. Light aircraft flying instrument flight rules through the London Terminal Control

Area;

2. Light aircraft flying visual flight rules to airports in the Heathrow vicinity; and

3. Light aircraft flying visual flight rules outside the control zone.

25.3.8 They stated that flight paths that are as direct as possible and allow aircraft to

climb and descend as quickly as possible have the potential to minimise controlled

airspace. They also stated that any expansion of the Heathrow control zone to

accommodate new flight paths must consider the impact on potential chokepoints

in the visual flight rule corridors outside the control zone.

25.3.9 Virgin Atlantic Airways Limited considered that if airspace is not upgraded

passenger delays will increase as traffic levels increase. They cited analysis

conducted by NATS on behalf of the Department for Transport (DfT) which

predicts that by 2030 air traffic delays will increase to 5.6 million minutes and

commented that if delays reach this level, more than 1 in 3 flights from all UK

airports will depart over half an hour late. They stated that such delays would have

significant environmental consequences and would reduce the resilience of the air

transport network.

Community groups



include specific feedback on flight paths and airspace

25.3.11 Aircraft Noise Three Villages, Ealing Fields Residents Association, Eastcote

Conservation Panel and the Local Authorities Aircraft Noise Council commented

that the lack of detail on the position of flight paths made it difficult to understand



how communities would be impacted and respond to the consultation. The Local

Authorities Aircraft Noise Council also commented that people need to know if

they are likely to be overflown and how often.

25.3.12 St Albans Quieter Skies stated that Heathrow affects all communities on or near its

departure flight paths including those between 6,000 and 11,000 feet, as up to this

altitude aircraft are climbing steadily and often sustaining high levels of noisy climb

thrust. They also noted that Heathrow flights at this altitude overlap with those

from Luton and force departures from Luton to fly at lower levels causing a

persistent noise nuisance.

25.3.13 They expressed concern about the impact of the proposed increase in aircraft

numbers on Hertfordshire, the current very high levels of vectoring off Heathrow

departure routes (BUZAD and BPK) directly over St Albans and the likely

significantly increase in noise over certain parts of London and the Home Counties

caused by the Project.

25.3.14 They also stated that the burden of aircraft noise should be shared out equally and

fairly among the UK population and suggested that as London’s airspace is

already one of the busiest in the world the expansion of air traffic should instead

be in less busy areas of UK airspace.

25.3.15 Teddington Action Group commented that the masterplan should not be

developed until environmental conditions including the restriction of air pollution

and noise as well as flight paths, are finalised.

25.3.16 Cheyne Walk Trust stated that flights over central and SE/SW London are a major

hazard in this age of non-state terrorism.

25.3.17 Local Conversation in Stanwell welcomed the added respite that would be

provided through runway alternation. However, they commented that the use of

the existing runways to create an additional 25,000 flights per annum would likely

result in a reduction of respite which would have an adverse impact on residents’

quality of life. They also commented that since the scrapping of The Cranford

Agreement there has been no change to the operating procedures at the airport

during easterly operations.

25.3.18 Wentworth Residents Association stated their preference for airport expansion at

Gatwick and highlighted the concerns and mistrust of Heathrow by local

communities following flight path changes in 2015.

25.3.19 The Fulham Society stated that the concentration of flights in a densely populated

area is unfair and unnecessary. They considered that regardless of the Project,

new measures that reduce the number of flights arriving over West London are

required as this is the only way to reduce noise.

25.3.20 West Windsor Residents Association stated that their residents will be situated

between the flight paths of two runways. They expressed concern that aircraft



operating on the new runway would be flying at significantly lower altitude than

those on the current northern runway and as there would be significantly more

aircraft movements this will make relief periods almost non-existent.

25.3.21 Spring Grove Residents Association expressed concern about noise from

overflying aircraft and highlighted that a third runway would create a new approach

path over Osterley and ruin the peace of Osterley Park.


25.4.1 Aviation Safety Investigations commented that no indication had been provided

about how the go-around flight paths will be integrated with the proposed

departure routes.

25.4.2 London Biggin Hill Airport recognised that there are options for changing the

routes of arriving and departing flights and opportunities to reduce noise by raising

their height. They recommended that Heathrow should seek to reduce the noise

on existing routes rather than creating new noise impacted areas.

25.4.3 Dominic Rabb MP stated that the Project provides an opportunity to shift away

from the current policy of concentrated flight paths towards a policy of dispersal

over a wider geographical area. He considered that this would provide relief to

local residents most severely impacted by noise and asked Heathrow to take this

opportunity to improve local residents’ quality of life.

25.4.4 The Mayor of London considered it unacceptable that the indicative flight paths

that would form the basis of the DCO may bear no relation to the actual future

flight paths used. He suggested that to meaningfully address public concerns the

process should be accelerated and actual flight path options used.

25.4.5 The London Parks and Gardens Trust urged a re-think on flying over parkland and

in particular, designated historic spaces. They also considered that as well as

compensating householders Heathrow should compensate local authorities for

loss of amenity value of parkland by setting up a fund for public parks.

25.4.6 The Campaign to Protect Rural England stated that more sophisticated flight

programming may result in future improvements but would depend on better

coordination and reliability of take-off and landings so that “stacking” is less

necessary.

25.4.7 The National Trust requested further details on the geographic areas for potential

flight path options, the likely environmental effects such as noise, air quality and

health and Heathrow’s plans for mitigation.

25.4.8 The Hounslow Green Party expressed opposition to the Project stating that it

includes destruction of communities and introduction of blight to new areas. They



also expressed concern that no clear indication of new flight paths had been

provided.

25.4.9 The Lambeth/Herne Hill Green Party stated that the use of multiple rotated flight

paths and sharing routes over a wider area would give communities a break from

noise each day. They also considered that new technology to modernise airspace

may provide respite for local communities.




Table 25.1A below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other

consultees in relation to Airspace. The table presents a summary of Heathrow’s responses to the issues on the basis that they

relate to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation

(January 2019), and how in preparing those proposals we have had regard to the relevant Airport Expansion Consultation One

feedback.

Table 25.1A

Issue Consultee17

PC MC WC Heathrow Response

Flight paths had not been shown and so it was not possible to

understand who would be affected and to what extent.

✓ We recognise that some people want to see detailed

flight path options before engaging in our design

process. We also recognise that some people want

to be involved from the outset, so that they have a

chance to influence the development of the options

whilst we still have a blank sheet. We have therefore

developed a 3-phase consultation strategy designed

to involve people at key stages as soon as design

The lack of detail on the position of flight paths made it difficult to

understand how communities would be impacted and respond to the

consultation.

✓

Little or no information about flight paths had been provided. ✓

17 Prescribed Consultees (PC), Members of the local community (MC) and Wider Consultee Groups (WC)



Issue Consultee17


No indication had been provided about how the go-around flight paths

will be integrated with the proposed departure routes.

✓ detail becomes available.

Airspace Principles Consultation One (January –

March 2018) was on airspace design principles, for

those wanting to influence from the outset. The

process for the development of the airspace design

principles, which have now been fixed, is set out in

Heathrow's Airspace Design Principles for

Expansion.

The Airspace and Future Operations Consultation,

which is currently taking place, is seeking feedback

on local factors that should be taken into account in

defining the flight paths within the design envelopes.

For more information, please see Heathrow’s

Airspace design envelopes for expansion, Making

better use of our existing runways, and

Understanding our design envelopes.

In our Airport Expansion Consultation we will present

preliminary environmental information which will

include an assessment of the effects of overflight

based on indicative flightpaths, in accordance with

the Airports NPS.

Then, our final consultation will seek feedback on

detailed route options and impacts arising from the

specific flight paths. This consultation is scheduled to

take place in 2022.

This 3-phase approach to consultation gives

stakeholders a number of opportunities to influence

the airspace change process, to include with

Further details requested on the geographic areas for potential flight

path options, the likely environmental effects such as noise, air quality

and health and Heathrow’s plans for mitigation.

✓

No clear indication of new flight paths had been provided. ✓

People need to know if they are likely to be overflown and how often. ✓



Issue Consultee17


reference to flight path design whilst allowing us to

present information as it becomes sufficiently certain.

New flight paths could have a significant adverse impact on the quality

of life and health of its residents, service users and workers.

✓ We are currently exploring plans to use the existing

runways more to create up to 25,000 ATMs per year.

This would be in advance of the completion of the

third runway and could only happen if consent for

expansion is granted. This would be an initial first

phase out of the additional ATMs per year that

expansion will permit.

This proposal will be the subject of a full assessment

as part of the development consent order application

(and airspace change process), to include in respect

of health and quality of life. At this stage the effects

are yet to be determined as we are still in the

formative phase of the design process.

It should be noted that the Airports National Policy

Statement (Airports NPS)18 requires that Heathrow’s

proposals must meet the following aims for the

effective management and control of noise, within the

context of Government policy on sustainable

development:

The use of the existing runways to create an additional 25,000 flights

per annum would likely result in a reduction of respite which would

have an adverse impact on residents’ quality of life.

✓

This would provide relief to residents most severely impacted by noise

and asked Heathrow to take this opportunity to improve local residents’

quality of life.

✓

18 https://www.gov.uk/government/publications/airports-national-policy-statement

https://www.gov.uk/government/publications/airports-national-policy-statement



Issue Consultee17


• Avoid significant adverse impacts on health and

quality of life from noise;

• Mitigate and minimise adverse impacts on health

and quality of life from noise; and

• Where possible, contribute to improvements to

health and quality of life.

In terms of our approach thus far, a Noise Expert

Review Group has been established to

independently peer review Heathrow’s approach to

aircraft noise assessment to ensure it is robust, and

Heathrow has set out its proposed methodology for

scoping and assessing aircraft noise for Expansion in

the Scoping Report submitted to the Planning

Inspectorate.19 On the basis of the information

provided in that report, the Planning Inspectorate

adopted its Scoping Opinion on 29 June 2018. This

sets out the Planning Inspectorate's opinion as to the

scope and level of detail of the information to be

provided in Heathrow's environmental statement, as

part of the development consent order application.20

19 https://infrastructure.planninginspectorate.gov.uk/projects/london/expansion-of-heathrow-airport-third-runway/?ipcsection=overview

20 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020003/TR020003-000451-HTHR%20-%20Scoping%20Opinion.pdf



Issue Consultee17


Minimising the need to affect new populations and businesses should

be the first principle in the redesign of airspace.

✓ These issues all relate to Heathrow's airspace design

principles and their prioritisation.

Heathrow's airspace design principles for Expansion

were submitted to the CAA on 31 August 2018 and

were approved on 28 September 2018. This forms

part of the CAA's CAP1616 process for establishing

design principles for airspace. The airspace design

principles are now fixed and will be used to evaluate

our airspace design options.

As part of the process for securing this approval from

the CAA, Heathrow received a number of responses,

in addition to those listed here, from the Airspace

Principles Consultation One. All of the issues raised

in those responses were considered by Heathrow

and were addressed in our submission to the CAA in

August last year.

Each of the comments listed here pertain to issues

which Heathrow has already considered and

addressed in the submission to the CAA on airspace

design principles. For a summary of this work see

Heathrow’s airspace design principles for Expansion.

For more information, please see:

https://www.caa.co.uk/Commercial-

industry/Airspace/Airspace-change/Decisions-from-

2018/London-Heathrow-airspace-departure-and-

Heathrow should seek to reduce the noise on existing routes rather

than creating new noise impacted areas.

✓

The needs of other airspace users need be considered, specifically,

light aircraft flying instrument flight rules through the London Terminal

Control Area, light aircraft flying visual flight rules to airports in the

Heathrow vicinity and Light aircraft flying visual flight rules outside the

control zone.

Any expansion of the Heathrow control zone to accommodate new

flight paths must consider the impact on potential chokepoints in the

visual flight rule corridors outside the control zone.



Issue Consultee17


Flight paths that are as direct as possible and allow aircraft to climb

and descend as quickly as possible have the potential to minimise

controlled airspace.

arrival-procedures/.

If airspace is not upgraded passenger delays will increase as traffic

levels increase.

Analysis conducted by NATS on behalf of the DfT which predicts that

by 2030 air traffic delays will increase to 5.6 million minutes and

commented that if delays reach this level, more than 1 in 3 flights from

all UK airports will depart over half an hour late.

New technology to modernise airspace may provide respite for local

communities.

✓

It includes destruction of communities and introduction of blight to new

areas.

✓



Issue Consultee17


Welcomed the added respite that would be provided through runway

alternation.

✓

There are options for changing the routes of arriving and departing

flights and opportunities to reduce noise by raising their height.

✓

Planes should gain as much altitude as possible as quickly as possible

The use of multiple rotated flight paths and sharing routes over a wider

area would give communities a break from noise each day.

✓

There should be a wider dispersal of flight paths in order to distribute

noise more fairly. Although this would affect more people it would

provide greater respite to those that would otherwise be under a

concentrated flight path.

✓

The scheme is dependent on an unprecedented scale of airspace

change and if this cannot be delivered the scheme would not be able to

operate at the capacity and/or with the respite that has been assumed.

✓ Major changes to flight paths and the tools used by

air traffic controllers are taking place across the UK

as the Government implements its Airspace



Issue Consultee17


Concern raised that there is no consideration how airspace change

would affect other London and South- East airports or the flight paths

necessary to deliver runway alternation and respite.

✓ Modernisation Strategy. This is being led by the CAA

and is overseen by the Department for Transport.

The Airspace Modernisation Strategy will require all

the UK's main airports to modernise their airspace.

For more information on airspace modernisation,

please see What is airspace modernisation?

We plan to carry out the process to modernise our

airspace at the same time as we expand the airport.

We are coordinating our airspace change design

process with both NATS and all relevant

neighbouring airports. This will help to ensure that

both Expansion and airspace modernisation can be

delivered at Heathrow. In addition, this will ensure

that our proposals and the operations of our

neighbouring airports can function in tandem.

This Airspace and Future Operations Consultation

provides an opportunity to give feedback on a

number of areas, to include the delivery of respite to

local communities using our runway and airspace

alternation pattern.

The UK’s airspace is in urgent need of modernisation and this is

necessary to support expansion.

✓

Heathrow flights at this altitude overlap with those from Luton and

force departures from Luton to fly at lower levels causing a persistent

noise nuisance.

✓



Issue Consultee17


The burden of aircraft noise should be shared out equally and fairly

among the UK population and suggested that as London’s airspace is

already one of the busiest in the world the expansion of air traffic

should instead be in less busy areas of UK airspace.

✓ The Government has designated the Airports NPS,

which sets out the need for additional airport capacity

in the south-east of England and confirms that the

Government believes that this need is best met by a

north-west runway at Heathrow.

Preference raised for airport expansion at Gatwick.

✓

As explained in the above response, the Airports

NPS confirms that the Government believes that the

need for additional airport capacity in the south-east

of England is best met by a north-west runway at

Heathrow.

Residents will be situated between the flight paths of two runways. ✓ This consultation provides an opportunity to inform

us of any local factors (e.g. any particularly noise

sensitive locations) which should be taken into

account when we reach the stage of designing the

flight paths within the design envelopes.

For more information, please see Heathrow’s

Airspace and Future Operations Consultation

Document and, in particular, Heathrow’s airspace

design principles for Expansion which sets out the

principles as to how we will determine flight paths.

Impacts would likely continue as a result of increased air traffic but

requested that noise levels be reduced.

✓ Future noise levels will be managed according to our

‘noise envelope’.

A noise envelope is a framework for the control of the

effects of noise. It provides certainty to communities

about how noise will be managed to comply with



Issue Consultee17


Government policy, balancing growth and noise

reduction, for the long term.

This would include a set of aims and principles,

performance targets, evaluation criteria (and

method), the mitigation measures to be applied as

considered necessary and a review period. This will

be developed in consultation and engagement with

stakeholders and local communities.

For more information, see Developing our approach

to noise management.

Heathrow affects all communities on or near its departure flight paths

including those between 6,000 and 11,000 feet, as up to this altitude

aircraft are climbing steadily and often sustaining high levels of noisy

climb thrust.

✓ We are responsible for the design of routes up to

7,000ft for arrivals into and departures out of

Heathrow.

Higher level airspace (i.e. above 7,000ft) is being re-

designed by NATS, with input from Heathrow,

neighbouring airports and other stakeholders. The

Government's Air Navigation Policy (2017) states

that changes at or above 7,000 feet will usually not

have a noticeable impact and for that reason

consultation is unlikely to be necessary.

For the latest details of our proposed changes below

7,000ft see Heathrow’s Airspace and Future

Operations Consultation Document and Making

Better Use of Our Existing Runways.

For NATS changes above 7,000ft, please see:




Issue Consultee17



2018/London-Airspace-Management-Programme-

Phase-2---ATS-Network/

Importance of working with local communities highlighted as well as

with those affected by overflight to reduce the impacts of noise from

expansion.

✓ Our consultations are open to all communities,

whether they are currently overflown or not.

Furthermore, our engagement on airspace design

principles has involved speaking to focus groups

including those from areas not currently overflown.

For full details of our airspace design principles

submission to the CAA for Expansion, including

details of all consultation and engagement activities

undertaken as part of that submission, please see:




arrival-procedures/

Concern raised about the impact of the proposed increase in aircraft

numbers on Hertfordshire, the current very high levels of vectoring off

Heathrow departure routes (BUZAD and BPK) directly over St Albans

and the likely significantly increase in noise over certain parts of

London and the Home Counties caused by expansion.

✓ These responses raise concern over a potential

increase in overflight of specific areas.

As explained above, we have developed a 3-phase

consultation strategy. This Airspace and Future

Operations Consultation asks stakeholders for local

information now in order that we are able to take

them into account when defining the flight paths

within the design envelopes. Local information could

include suggestions for noise sensitive areas or

Concern raised about impacts on the communities of Dorney and

Taplow who would be directly under the east – west flight path, and the

✓







Issue Consultee17


Colne Valley Regional Park which was considered to potentially be

significantly adversely impacted if the majority of new flight paths are

routed away from urban areas.

buildings that stakeholders believe should get special

consideration (which may include those mentioned).

Following this consultation we will consider all

suggestions on a case-by-case basis.

This response also raises a concern that the flight

paths will be routed away from populations. This

relates to the work that we have already undertaken

in respect of the airspace design principles for

Expansion. Similar comments were received during

the Airspace Principles Consultation One in January

2018 and, as explained previously in this table, those

comments were addressed in our submission on the

principles to the CAA.

Our work on airspace design principles for Expansion

has been approved by the CAA – full details of the

airspace design principles, as approved on 28

September 2018, can be found at:




arrival-procedures/

For a summary of Heathrow's airspace design

principles for Expansion, please see Heathrow's

Airspace Design Principles for Expansion.

Concern about noise from overflying aircraft and highlighted that a

third runway would create a new approach path over Osterley and ruin

the peace of Osterley Park.

✓

Regardless of expansion, new measures that reduce the number of

flights arriving over West London are required as this is the only way to

reduce noise.

✓







Issue Consultee17




Issue Consultee17


The increased number of aircraft using these routes would further

impact on the Surrey Hills AONB and its tranquility.

✓ Our airspace design principles were approved by the

CAA on 28 September 2018. Of the approved

principles, one of the more strategic principles (rather

than a 'core' requirement of airspace design) that

Heathrow is intending on delivering on is 6(f) i.e.

limiting, where possible reducing, local noise effects

from flights by prioritising routing flight paths over

parks and open spaces (rather than over residential

areas), but avoiding overflight of Areas of

Outstanding Natural Beauty (AONB).

Heathrow does intend on delivering this, but it should

be noted that inevitably some trade-offs will have to

be made when making decisions.

Although not providing a simple formula to develop

airspace design, the principles are a valuable first

step in the CAA's airspace design process. We will

refer to them whenever we make design decisions.

This will ensure transparency so that all our

stakeholders can see how the principles have been

taken into account in our emerging designs.

Please see: Heathrow's Airspace Design Principles

for Expansion for more information.

Since the scrapping of The Cranford Agreement there has been no

change to the operating procedures at the airport during easterly

✓ Although the Government confirmed the Cranford

Agreement should be removed in 2010 following

public consultation, we need to make changes to the



Issue Consultee17


operations. taxiways in order to implement full alternation on

easterly operations.

To do so, in 2013 we submitted a planning

application to the London Borough of Hillingdon. This

was rejected so we appealed, and this was

eventually overturned by the Government in 2017.

However, we then assessed whether the taxiway

works approved in our original application would fit

with the airfield design for an expanded Heathrow

and this demonstrated the need to reposition the

taxiway works. Moving the location of the taxiway

works will change the noise impacts from departing

aircraft. Taken together, this will require a new

planning application to account for these changes.

We are therefore pursuing this work through our

DCO application.

Concern raised about planes taking off to the west and then turning

east on route to Europe and eastern destinations.

✓ For safety reasons, aircraft generally take off and

land into the wind. In the UK, the prevailing winds are

mostly south-westerly (from the south west). As a

result, the majority of aircraft (approximately 70% a

year) make their final approach to Heathrow towards

the west.

As part of our ongoing work in re-designing the

arrival and departure routes for Expansion, we have

been assessing various concepts which are intended

to be the starting point for the detailed design phase

of the airspace. As an example, one of those

concepts on departures is to provide opportunities to



Issue Consultee17


'wrap-around' the departure runway as the aircraft

climbs. This would help minimise fuel burn/CO2 and

also provide opportunities to maximise operational

efficiency.

Further information is provided in Heathrow’s

Airspace and Future Operations Consultation

Document and a technical description potential wrap

around routes are in Our approach to redesigning our

airspace network for an expanded Heathrow.

A key issue is how predictable, reliable runway and flight path

alternation could be provided to allow respite to local communities

throughout the day, night and shoulder periods.

✓ We are seeking feedback in this consultation on

respite through runway and airspace alternation,

amongst a number of other areas.

Please see Heathrow’s Airspace and Future

Operations Consultation Document and Runway

Operations – Respite through Alternation.

Concern raised that if the new runway cannot accommodate the largest

planes it would increase usage of the other runways with the likelihood

of more overflight of its communities.

✓ The Airports NPS requires that the proposed new

runway is a minimum length of 3,500m. A new

runway of at least 3,500m in length would enable the

largest commercial aircraft to take-off and land. For

more information see Chapter 7 of this Consultation

One Interim Feedback Report.

New flight paths may alter the way historical assets can be enjoyed.

✓ Further information on the effects of expansion on

the historical environment will be set out as part of

the Airport Expansion Consultation in June.

Our airspace design principles for Expansion do not



Issue Consultee17


include a generic principle on avoiding historical

assets. This is because the scope of this airspace

change means that it has potential effects over a

large geographic area, within which there will be a

wide range of noise sensitive buildings/areas to

consider.

(Full details of our fixed airspace design principles

for Expansion can be found at:




arrival-procedures/)

However, we are still at a relatively early stage of our

airspace design process which started from a ‘blank

sheet’. We have now identified the ‘design

envelopes’, which show the geographical areas

which are potentially overflown. This consultation

asks for feedback on local factors relating to these

areas to which we will have regard in designing the

flight paths. Local factors can include historical

assets. See further Heathrow’s Airspace design

envelopes for expansion and Making Better Use of

Our Existing Runways.

A re-think on flying over parkland and, in particular, designated historic

spaces is urged.

✓

✓ This issue relates to the work that Heathrow has

already undertaken in respect of airspace design

principles for Expansion. Similar comments were

received during the Airspace Principles Consultation

One in January 2018 and, as explained previously in







Issue Consultee17


this table, those comments were addressed in our

submission to the CAA.

Principle 6(h) of the approved and now fixed airspace

design principles states that Heathrow should limit,

and where possible reduce, local noise effects from

flights by prioritising routing flight paths over parks

and open spaces rather than residential areas (but

avoiding overflight of AONB). It should be noted that

rather than being a 'core' requirement of airspace

design, this is one of the more strategic principles

that Heathrow intends to deliver on. Inevitably some

trade-offs will always have to be made.

Our work on airspace design principles for Expansion

has been approved by the CAA – full details of the

airspace design principles, as approved on 28

September 2018, can be found at:




arrival-procedures/

For a summary of Heathrow's airspace design

principles for Expansion, please see Heathrow's

Airspace Design Principles for Expansion.

Concern expressed that flight paths will be focussed on areas that do

not already have significant air quality issues and will therefore be over

areas with existing low background noise levels.

✓ The Government’s Air Navigation Guidance 2017 states “Due to the effects of mixing and dispersion, emissions from aircraft above 1,000 feet are unlikely to have a significant impact on local air quality. “







Issue Consultee17


Air quality is therefore unlikely to influence the design

of the airspace beyond the immediate vicinity of the

airport.

Further information requested on the assessment principles and the

capping of airport size and flight numbers.

✓ We propose to put legally binding obligations in place to ensure the growth of the airport is only allowed to take place within the boundaries of the environmental criteria set out in the Airports NPS. For more information, please see Heathrow's Airspace and Future Operations Consultation Document. We will set out detailed proposals for how future growth will be managed as part of our Airport Expansion Consultation planned for June 2019. We will be seeking feedback on these proposals and we want local communities to have their say on our plans.

Questioning the implications for aircraft stacking if the airport operates

at full capacity.

✓ The plan to modernise the UK’s airspace involves

using technology to remove the need for stacking in

normal circumstances, even when the airport

reaches full capacity.

Heathrow stacks operate from 7,000ft upwards and

are therefore part of the NATS airspace change to

modernise airspace above 7,000ft. For information

on NATS changes above 7,000ft, please see



2018/London-Airspace-Management-Programme-

Circling/stacking should be reduced and flight paths should be tied to

specific noise and air quality limits.

✓

More sophisticated flight programming may result in future

improvements but would depend on better coordination and reliability

of take-off and landings so that “stacking” is less necessary.

✓

Planes should gain as much altitude as possible as quickly as possible

and the current stacking arrangements should be removed.

✓

https://www.caa.co.uk/Commercial-industry/Airspace/Airspace-change/Decisions-from-2018/London-Airspace-Management-Programme-Phase-2---ATS-Network/





Issue Consultee17


Circling/stacking should be reduced and flight paths should be tied to

specific noise and air quality limits.

✓ Phase-2---ATS-Network/.

For more details on how Heathrow expansion is part

of the wider UK airspace modernisation please see

What is airspace modernisation? More sophisticated flight programming may result in future

improvements but would depend on better coordination and reliability

of take-off and landings so that “stacking” is less necessary.

✓

Queried whether the environmental statement for the airspace change

process will be the same as for the DCO application.

✓ These responses question the relationship between

the environmental information to be provided as part

of the development consent order application and the

airspace change process.

The development consent order application will be

made at an earlier stage than a decision is made by

the CAA on our airspace change proposal. For that

reason, the environmental information for the

development consent order will be based on

‘indicative’ flight paths rather than the final flight

paths. This is recognised in the Airports NPS which

states at paragraph 5.52 that "the applicant's

assessment of noise should be undertaken in

accordance with the developing indicative airspace

design”.

The development consent order will then set a noise

envelope that the airspace change proposal impacts

must fall within. Therefore the two submissions will

be linked, and the impacts of the latter limited by the

former.

More details on both processes can be found in How

do we seek approval to expand Heathrow?. More

Concern raised that until an airspace design is agreed it will not be

possible to define, consult on and agree the noise envelope.

✓

If the two are different they will need to be consulted on whether the

determination of flight paths could alter decisions about highway

networks.

✓




Issue Consultee17


detail on the role of the noise envelope can be found

in Developing our approach to noise management.

There must be no unacceptable safety, economic or airspace

consequences arising from the proposals that would prevent the

relevant regulatory approvals.

✓ We will be following the CAA's airspace design

guidance (CAP1616)21 for developing the airspace

change proposal.

This guidance covers all of the various elements

referred to in this response. Our proposals will be

subject to a full assessment under the airspace

change process.

There should be an analysis of the costs and environmental benefits of

extending the Southern Runway to the west to provide quieter landings

for planes from the east and decrease the number of residents within

the 65-decibel contour.

✓ As explained above, the Airports NPS confirms that

the Government believes that the need for additional

airport capacity in the south-east of England is best

met by a north-west runway at Heathrow.

Clear policy direction from the Government is urgently required to

ensure that the international commitments of the UK via ICAO’s

Balanced Approach to noise, carbon and air quality needs can be met.

✓ Any mitigation measures we put in place will need to

be developed through the application of the ICAO

Balanced Approach. This sets out a framework for

the development of a package of noise mitigation

measures with the goal of addressing an individual

airport’s environmental noise objective in the most

21 https://publicapps.caa.co.uk/docs/33/CAP1616E2interactive.pdf



Issue Consultee17


cost-effective way. EU Regulation 598/2014 requires

the application of ICAO's Balanced Approach in

relation to noise in the UK and the Airports NPS

requires compliance with that Regulation.

The Balanced Approach comprises four principle

elements:

• Reduction at source (e.g. quieter aircraft)

• Land use planning and management

• Noise abatement operational procedures

• Operating restrictions.

We also consider community engagement to be a

significant element of our approach. As part of our

approach we will also put forward plans for a noise

envelope to provide management, accountability,

and control of noise. Further information on the noise

envelope approach will be provided for consultation

at the Airport Expansion Consultation in June 2019.

The Balanced Approach does not apply to carbon or

air quality.

The masterplan should not be developed until environmental

conditions including the restriction of air pollution and noise as well as

flight paths, are finalised.

✓ The airspace change required for Expansion cannot

take place until the new runway is approved, so it will

happen after the development consent order is

made. However, the development consent order

application will include an assessment of impacts

based on prototype routes and will describe a noise It is unacceptable that the indicative flight paths that would form the

basis of the DCO may bear no relation to the actual future flight paths

✓



Issue Consultee17


used. envelope to ensure that the impacts of the final

routes are within acceptable limits.

The Airports NPS explains that at the time of the

development consent order process the airspace

design will not be finalised and so indicative airspace

designs should be developed (paragraph 5.52).

By the time we submit the development consent

order application we will have decided in broad terms

how many routes there will be and in which general

direction. Even though this will not tell us exactly

where the routes will be, we will be able to analyse

the scale of any potential benefits and adverse

effects. This will be fed into the development

consent order decision making process.

The development consent order, if approved, will

include the definition of a ‘noise envelope’. This will

set limits on impacts which the future design and

operation of the airspace must stay within and will

therefore give the Secretary of State, when deciding

whether to grant the development consent order, a

guarantee that the ongoing design process will

deliver an airspace design that meets specified

requirements.

More details on the noise envelope can be found in

Developing our approach to noise management.

In order to meaningfully address public concerns, the process should

be accelerated and actual flight path options used.

✓

Flights over central and SE/SW London are a major hazard in this age ✓ Our Environmental Statement will include an

assessment of major accidents and disasters as part



Issue Consultee17


of non-state terrorism. of the development consent order application. This

will be subject to scrutiny during Examination.

Highlighted the concerns and mistrust of Heathrow by local

communities following flight path changes in 2015.

✓ We have been working with communities in relation

to their concerns regarding airspace, for instance

through the ongoing Heathrow Community Noise

Forum.

In addition, we have established the Heathrow

Community Engagement Board and this will help

enable large scale community engagement

throughout the planning process for Expansion and

longer-term into the operational phase of the

expanded airport.

This will play an important role in building trust

between the airport and its communities and ensure

Heathrow delivers on its commitments today and in

the future.

In terms of consultation, this Airspace and Future

Operations consultation is part of a 3-phase

consultation process regarding airspace for

Expansion (as described earlier in this table). This is

to ensure that our design process is transparent and

so that all stakeholders get the chance to contribute

at key stages of the process.

Existing flight paths affect several areas of their land. ✓ This Airspace and Future Operations Consultation is

not about existing flight paths.

However, all flight paths are subject to review as part



Issue Consultee17


of the airspace redesign and we are asking for

information on the local factors that should be taken

into account in defining the flightpaths within design

envelopes for future operations.

Residents should benefit from quieter aircraft/airport technology and

systems.

✓ In accordance with the requirements of the Airports

NPS, we are developing a “noise envelope”, which is

a dynamic arrangement of legally binding controls

and limits for the ongoing and future management of

noise. Its aim is to provide certainty to communities

on the airport’s impacts, whilst allowing operators

(e.g. airlines) flexibility on how they can grow their

use at the airport. The noise envelope would be

legally binding and secured through the DCO

process. For more information on the noise envelope

and how we are developing it, please see the

document Developing Our Approach to Noise

Management which is part of the January 2019

Airspace and Future Operations Consultation.

Details of measures to incentivise the use of quieter

aircraft are set out in Heathrow’s Airspace and

Future Operations Consultation Document.

Concern that aircraft operating on the new runway would be flying at

significantly lower altitude than those on the current northern runway

and as there would be significantly more aircraft movements this will

make relief periods almost non-existent. Welcomed the added respite

that would be provided through runway alternation.

✓ This response suggests that aircraft using the new

runway would fly at a lower altitude than those on the

current northern runway. In fact, we will be applying

a minimum climb gradient of 5% and a ‘slightly

steeper’ approach angle of 3.14 degrees. This

means that the lowest aircraft seen in the future will

be higher than seen today for an equivalent phase of



Issue Consultee17


flight. These technical details are explained in Our

approach to redesigning our airspace network for an

expanded Heathrow.

The response also suggests references relief and

respite periods. We are seeking feedback on this

area, and describe the proposals in detail in Runway

Operations – Respite through Alternation.



CONSULTATION

Introduction

26.1.1 In response to Airport Expansion Consultation One, Heathrow sought feedback on

the Consultation, the printed material, maps, plans, website and feedback form.

A total of 2,268 consultees made comments relating to this topic.

26.1.2 Heathrow provided the following consultation material:


2. Development Consent Order Process Information Paper;

3. Environmental Impact Assessment Information Paper;

4. Property Policies Information Paper;

5. Our Emerging Plans;

6. Scheme Development Report;

7. Our Approach to Developing a Surface Access Strategy;

8. Our Design Approach to the Natural Environment;

9. Our Approach to Noise;

10. Our Approach to Air Quality;

11. Our Approach to Carbon and Climate Change;

12. Our Approach to Historic Environment;

13. Community Information Booklet – North;

14. Community Information Booklet – East;

15. Community Information Booklet – South West;

16. Community Information Booklet – West;

17. Interim Property Hardship Scheme – Panel Guidance and Policy Terms;

18. Fees and Costs Policy;

19. Commercial Property Policy;

20. Agricultural Land and Property Policy; and

21. Residential Property Policy.

26.1.3 Heathrow asked the following questions regarding the Consultation:



1. Please tell us your views on this consultation (for example, the information we

have provided, any printed material you have received, any maps or plans, the

website and feedback form etc.).















Local Authorities

26.2.1 Detailed comments were received from local authorities in relation to

the Consultation.

26.2.2 The London Borough of Brent expressed disappointment that no consultation

events were hosted in the Borough and suggested that this should be addressed

in future consultations.

26.2.3 Ealing Council said the consultation materials lacked information on the potential

regeneration benefits of the Project and the ways benefits would be maximised.

They also commented that the consultation materials could have included more

information about housing, including affordable housing and the provision of land

for housing, and surface access, such as cycle facilities and bus access.

26.2.4 Elmbridge Borough Council commented on the complexity of the Consultation,

noting that having two consultations in parallel was confusing and that materials

should be simplified to engage more people. They stated that the distinction

between the Consultation and the Airspace Principles Consultation (January 2018)

was not clearly explained, leading to further confusion. They also highlighted that

the consultation materials lacked information on the cost of the Project and that

Heathrow should explain how they consider residents' views against those of

other stakeholders.

26.2.5 The London Borough of Hammersmith and Fulham commented that the

presentation of the economic benefits of the Project was misleading, did not



include a breakdown of how it was generated and did not align with the figure in

the Airports National Policy Statement (ANPS).

26.2.6 They also felt the consultation material included misleading content and felt that

Heathrow did not quantify the airport’s current operations against the potential

impacts of a proposed new third runway, meaning that residents could not make

an informed assessment of the impacts and costs of the Project.

26.2.7 The London Borough of Hammersmith and Fulham also considered that important

information was omitted from the Consultation, such as the potential reduction of

respite currently provided to communities under existing flightpaths, that there

appeared to be a conflict between the two consultations and that information on

noise issues was limited. This meant that there was no clear way for residents to

identify where they lived in relation to noise impacts around the airport.

26.2.8 They also commented that it was not clear that the Consultation formed part of the

DCO and that the timetable for finalising flight paths needed be aligned with the

DCO timeline so that airspace decisions could be fed into the DCO process.

26.2.9 The London Borough of Harrow stated that the consultation materials did not

contain any baseline data which the Council could use to assess the impacts of

proposed changes, for example on noise, traffic and air quality. They considered

that because information was vague or missing, the impacts on the borough could

not be fully understood and firm comments on the proposals put forward by

Heathrow could not be made.

26.2.10 Hertfordshire County Council suggested that consideration should be given to

engaging with Hertfordshire communities more proactively and hosting a

consultation event(s) within the south west of the County.

26.2.11 The London Borough of Hounslow commented positively on the consultation

process, stating that Heathrow’s staff at the consultation events were helpful and

well informed and that materials available at the events were high-quality and well-

presented. They did however express concern over missed deliveries of

Community Information Leaflets in their Borough and the separation between the

timelines for the Development Consent Order (DCO) and airspace

change processes.

26.2.12 Slough Borough Council stated that the Consultation did not clearly present the

various options as coherent strategies. They stated that the public were being

asked to comment on options such as land usage and road layouts without fully

understanding the impacts once they are put together.

26.2.13 South Buckinghamshire District Council commented that they were dissatisfied

that not all the consultation documents had been shared with Councillors prior to

the start of the Consultation.



26.2.14 The South East England Councils commented that Heathrow should set out how it

will work with the public sector to ensure effective planning and delivery for

community infrastructure needs such as schools, healthcare facilities, utilities and

local services that will be required by new expanded Heathrow Airport and supply

chain employees and their families.

26.2.15 Spelthorne Borough Council shared a similar view, commenting that the

consultation documents were short on detail with no baseline data. They said that

Heathrow should provide comprehensive baseline data on issues including noise,

traffic and air quality. They also highlighted that many of the consultation

documents had imprecise wording and unrealistic options which made it difficult

for residents to understand and respond. They expressed concern that the

Consultation did not include information on important issues such as flight paths,

runway modes, baggage, park and ride, public transport interchanges, landscape

mitigation, temporary construction and displaced uses which they considered were

crucial to assessing the wider impacts on the borough. They also expressed

concern that limited consideration appeared to have been given to accommodating

the construction workforce.

26.2.16 Surrey County Council considered that the consultation materials did not provide a

coherent overview of the cumulative effects on their community. They commented

that the Project masterplan22 needed to extend beyond the red line boundary and

that the Consultation lacked a detailed surface access strategy.

26.2.17 They also commented on the presentation of noise impacts, stating that separating

information about noise between the Airport Expansion and Airspace Principles

consultation documents meant not all residents were aware of potential impacts or

the need to respond to both consultations.


26.2.18 Few statutory consultees made comments on the consultation process, instead

providing detailed comments on aspects of the Project or Heathrow’s approach to

managing its effects.

26.2.19 Natural England commented that the content of the Consultation was high-level

due to the scheme being in the early stages of development. They highlighted that

a lack of detailed information meant they were unable to respond to the

Consultation with certainty.

22 A long-term plan that provides a conceptual layout to guide future growth and development



26.2.20 Highways England commented that its response to the Consultation was

predicated on the information available at this early stage in the scheme

development process. They indicated that further information and extensive

engagement with Heathrow will be required to ensure the design delivers a safe

and serviceable strategic road network, to agree appropriate mitigation and the

use of robust modelling to ensure future proofing of the design.


26.2.21 Ivers Parish Council stated that the Consultation lacked a joined-up plan or map

showing the cumulative effect of the proposals on the area. They also stated that

the scale of the maps was too small to be able to clearly identify sites.

26.2.22 Bray Parish Council echoed the view that information was missing from the

Consultation and said that it prevented them and their residents from making a

fully informed response.

26.2.23 Colnbrook with Poyle Parish Council indicated that the Consultation was high-

quality and effective and presented opportunities to engage in face-to-face

discussions with Heathrow representatives throughout.

26.2.24 Network Rail did not make detailed comments about the Consultation but

suggested a bilateral workshop be convened to discuss their comments in relation

to impacts on the rail network and rail accessibility.

Local Communities


26.3.1 Roughly a quarter of respondents expressed positive views about the

Consultation but the majority of those that responded expressed opposition

or criticised the Consultation.

26.3.2 The main positive comments focussed on the level of detail and the accessibility of

documents and materials. Members of the public who were generally supportive of

the Project felt that the documents set out the case for expansion clearly and

informatively. Other positive comments said that the events were well-presented,

that event staff were helpful, that the Consultation was far-reaching and well-

publicised and that the website was accessible and contained useful information.

26.3.3 Positive feedback was also received about the inclusion of the sound

demonstration at the Heathrow Academy and the ability to express concerns to

team members face-to-face at events.

26.3.4 Members of the public that made negative comments expressed concern and

uncertainty about the purpose of the Consultation. They said that the Consultation

was biased, a ‘box-ticking exercise’ or PR exercise, that Heathrow would not listen



to and act on consultation feedback and that the Consultation presented a new

runway as inevitable and no longer open to debate. It was also stated that the

Consultation carried no weight because it was non-statutory and undertaken

ahead of the designation of the ANPS.

26.3.5 Members of the public criticised the consultation events for the following reasons:

1. concerns regarding accessibility of information and events and inclusiveness;

2. the Hendon consultation event was organised on a Jewish holy day, preventing

attendance by the Jewish community;

3. the Freepost return envelopes provided at some events were too small;

4. staff at the Stanwell Moor event did not provide feedback forms;

5. staff were insensitive to concerns and not appropriately informed on specific

issues; and

6. requests for documentation at the Hayes event were not fulfilled.

26.3.6 Respondents also commented that the Consultation did not attract a young

audience, that an online consultation exhibition would have achieved a wider

reach and that better use should be made of social media platforms and the

website.

26.3.7 Suggestions were also received that events should have been held in Chelsea

and Sipson.

26.3.8 In addition to these criticisms, consultees made the following comments about the

consultation materials and written information:

1. data was vague, inaccurate or missing;

2. maps needed to be of a higher resolution;

3. noise maps were missing; and

4. documents were too detailed, long and difficult to understand.

26.3.9 Members of the public also highlighted a range of information considered to be

missing or not covered in sufficient detail in the consultation materials. Information

was stated to have been omitted in relation to:

1. construction;

2. night time ban on aircraft movements;

3. changes to flight paths;

4. the number of aircraft;

5. transport and accessibility;



6. impacts of the M25 realignment works and local road diversion options;

7. road user charging;

8. noise;

9. pollution;

10. health effects and related mitigation;

11. demand for housing in the local area;

12. the environment;

13. loss of greenspace and agricultural land;

14. cost;

15. compensation and mitigation proposals;

16. project timescales;

17. alternatives to the Project;

18. historic assets and the historic environment impact;

19. safety and security issues;

20. impacts on local people, communities and businesses;

21. airline landing charges;

22. encouraging modal shift by using Crossrail;

23. relocation of the immigration centres; and

24. airport supporting facilities.

26.3.10 Members of the public expressed dissatisfaction with the Consultation Feedback

Form (Form) on the basis that it was long and tedious, cumbersome and difficult to

navigate. Others stated that the Form included questions which were leading and

too complex.

26.3.11 In relation to the online version of the Form, the following suggestions were made:

1. including ‘logout’ and ‘save’ options;

2. include a progress bar;

3. make related information accessible on each question page;

4. list all questions on one contents page up-front;

5. include relevant maps and figures

6. detail the number of answers required at the outset;

7. including multiple choice questions; and



8. offer the opportunity to complete the form while remaining anonymous.

26.3.12 In relation to the paper version of the Form, it was suggested that more blank

space should be provided for responses.

Businesses

26.3.13 The Copas Partnership and The Lanz Group commented on the accessibility of

consultation materials, indicating that they were well written and visually

appealing. The Lanz Group also commented that consultation materials could

have been improved by more clearly demonstrating how each element of the

Consultation linked together.

26.3.14 Businesses made general positive comments on the Consultation. Hatton Estates

commented that the Consultation seemed comprehensive, Suez UK stated the

Consultation was well-conducted and wide reaching and Surrey Chambers of

Commerce commented that it was excellent.

26.3.15 The Arora Group expressed concern at the scope of the Consultation, indicating

that to enable a full and proper consultation on component parts and the delivery

of the optimum overall scheme, a number of options should be consulted upon for

each component.

26.3.16 They criticised the lack of reference in the consultation materials to their own

proposals to expand Heathrow Airport, stating that respondents had not been

given the full range of options to consider. They also criticised the lack of

information on construction costs, which they considered meant stakeholders

could not weigh up the costs and benefits.

26.3.17 Enterprise M3 Local Enterprise Partnership considered that the consultation

material lacked an overall coherent strategy and that there was too much focus on

individual specific elements rather than strategic options.

26.3.18 Heathrow Hub Limited shared a similar view indicating that the consultation

materials did not provide sufficient comparative analysis of issues such as costs,

benefits, risks and environmental impacts or explain the relationship between

options to help determine which were compatible. They also stated that the

consultation materials did not consider the timescales, costs and risks involved in

relocating residential, commercial and public property.

26.3.19 Petchey Industrial Properties Limited commented that the Consultation was

not broad enough as it only focused on one proposal for a third runway and

WeMoved Limited commented that no information had been provided about

local consultations.



Community groups

26.3.20 Certain community groups who provided feedback to the Consultation expressed

opposition to the Project but did not necessarily include specific feedback on

the Consultation.

26.3.21 Harrow U3A Sustainability Group said the consultation events were informative

and that the Consultation explained the proposals clearly and thoroughly.

26.3.22 Aircraft Noise Three Villages commented that it should have been made clear that

the Consultation was non-statutory and was being undertaken at a time when

feedback on the ANPS consultation was still being analysed. They considered that

the Consultation was a PR exercise and carried no weight.

26.3.23 Both Colnbrook Community Association and Slough and District Against Runway 3

commented that the Consultation was designed to elicit predetermined responses

which favoured the Project. Slough and District Against Runway 3 added that they

believed consultation events had only been held in areas already overflown, rather

than those which may be overflown in the future.

26.3.24 Dover House Estate Residents’ Association commented that the online version of

the Form should include a progress bar to show how much had been completed

and that there should have been a ‘click-through’ to the documents relevant to

each question.

26.3.25 The Camberley Society made similar comments criticising the online version of the

Form saying it took too long to complete. They suggested that it should include a

save button which allows users to return to it later. The Chertsey Society echoed

these views and commented that the online Form would have benefited from

alerting consultees that it could be partly completed and returned to at a later

stage, before submitting.

26.3.26 The Teddington Action Group considered the main consultation document to be

misleading as it implied only one consultation was taking place. They also

considered that the Consultation was a PR exercise and contained insufficient

information for people to make decisions.

26.3.27 St Albans Quieter Skies said it was disappointed with the lack of information about

the impact on areas to the North of London.

26.3.28 The Englefield Green Action Group were positive about the approach taken but did

not consider that the Consultation presented a balanced view of the environmental

and community impacts.

26.3.29 The Colnbrook Community Partnership expressed concerns about a lack of area-

specific information and thought more information should have been provided

around the impacts on Colnbrook and Poyle. They suggested that this specific



information could have included a composite map showing all possible local

impacts, such as road realignments and river diversions.

26.3.30 The Eastcote Residents’ Association expressed concern that the Consultation did

not make commitments to actions which would address community concerns, the

loss of land and properties, pollution or transport issues.

26.3.31 The Eastcote Conservation Panel commented that the consultation materials

contained unsubstantiated statements.

26.3.32 The Richmond Heathrow Campaign commented that the use of two columns in

documents made them difficult to read at appropriate magnification on a computer

screen.

26.3.33 HFT highlighted that further details on how Heathrow Airport will become a

champion for assisted travel should be provided in the next stage of consultation.

26.3.34 Local Conversation in Stanwell commented that the Consultation information was

too high-level which meant that it was not possible to comment in detail on issues

critical to Stanwell and Stanwell Moor residents.

26.3.35 The Local Authorities’ Aircraft Noise Council commented that the presentation of

the economic benefits of the Project was misleading, did not include a breakdown

of how it was generated and did not align with the figure in the ANPS.

26.3.36 They stated that the consultation material included misleading content, such as

presenting Heathrow as the only way to support economic growth and that it did

not quantify the airport’s current operations against the potential impacts of a third

runway. This meant that residents could not make an informed assessment of the

impacts and costs of the Project.

26.3.37 They also considered that important information was omitted from the

Consultation, such as the potential reduction of respite currently provided to

communities under existing flightpaths and commented that information on noise

issues was limited which meant here was no clear way for residents to identify

where they lived in relation to noise impacts around the airport.

Wider/Other Consultees

26.4.1 The Herts and Middlesex Wildlife Trust commented that information on the net

ecological impacts of the Project was lacking. They considered that this made

it impossible to conclude whether the development could provide a net gain

in biodiversity.

26.4.2 The London Wildlife Trust made similar comments, indicating that greater levels of

information were needed and that there should have been the option to provide

feedback on drainage/pollution control and light pollution. They also commented

that an effective means to engage stakeholders in the evaluation of the



biodiversity evidence, and the design of the green infrastructure plan should be put

in place.

26.4.3 The Colne Valley Regional Park welcomed the Consultation taking place when it

was a non-statutory DCO requirement. They did, however, comment that there

should have been more information on drainage and pollution control and that the

consultation materials should have provided information about the impacts on

groundwater levels through increased water consumption as a result of the

proposed third runway.

26.4.4 Church of England Diocese of London, Oxford and Southwark commented that the

maps and diagrams showing an expanded airport were clear and information

papers were helpful.

26.4.5 The London Parks and Gardens Trust said it was frustrating to have to cross-refer

to documents that did not always follow the same sequence. They considered it

would have been beneficial to present consultation booklets based on single

subjects e.g. conservation, noise, pollution, airport logistics. They also considered

the maps were inadequate due to changing scales and that the conservation areas

and historic buildings which would be lost should have been made clear.

26.4.6 Aviation Safety Investigations commented that the masterplan was inadequate

and requested the opportunity to discuss the necessary changes with the design

team.

26.4.7 The Major of London recognised the significant amount of consultation that had

taken place in relation to Heathrow. He considered that the Consultation was a

missed opportunity to address concerns about the proposals for an expanded

Heathrow and to set out clear commitments to address these concerns.

26.4.8 Justine Greening MP (Putney) commented that the Consultation gave the

impression that expanding Heathrow Airport was a “given” even before the

Parliamentary vote had been held. She also expressed concerns on behalf of her

constituents about the lack of detail in relation to the various elements of the

proposals and how Heathrow will manage an airport which is 50% than the

existing Airport or which will have a proposed 50% increase in freight.

26.4.9 Justine Greening MP also considered there was insufficient information to enable

MPs to arrive at an educated position regarding the plans. She referred to a lack

of information concerning flight paths, the management of an enlarged airport, the

M25 and the lack of substantial detail on the relocation of the Lakeside Waste

Management facility. The Campaign to Protect Rural England – Surrey and

Guildford indicated that the Consultation was premature as it included too much

unresolved information to allow respondents to make an informed response. They

expressed concern that that the whole exercise was a PR event.



26.4.10 The Guild of Air Traffic Control Officers made similar comments, indicating that the

Consultation was unnecessary as information necessary to inform consultees to

comment on some of the options is not available until the second consultation.




Table 26.1A below sets out a summary of the main issues raised by prescribed consultees, local communities and wider/other

consultees in relation to Consultation. The table presents a summary of Heathrow’s responses to the issues on the basis that

they relate to the proposals on which we are seeking feedback as part of the Airspace and Future Operations Consultation

(January 2019), and how in preparing those proposals we have had regard to the relevant Airport Expansion Consultation One

feedback.

Table 26.1A


PC MC WC

The consultation was overly complex and materials

should have been simplified to engage more people.

✓ The Airport Expansion Consultation One documents were designed

to ensure that highly technical concepts and information was

presented in a way that was accessible to a range of audiences. This

avoided persuasive language and jargon as far as possible and the

Airport Expansion Consultation One Document and accompanying

information papers provided more simplified information on the

proposals.

Heathrow welcomes feedback on its consultation approach and has

had regard to this feedback in planning our subsequent consultations.





PC MC WC

For example, the Airspace and Future Operations Consultation in

January 2019 and the planned Airport Expansion Consultation in

June 2019 provide a wider range of interactive online content and will

ensure that wording is accessible, un-biased and in plain English and

that information is presented using a tiered approach to ensure that

all audiences are able to access the information they require.

The distinction between the expansion and airspace

consultations was not clearly explained and running

two consultations in parallel was confusing.

✓ In 2018, Heathrow undertook two separate but parallel consultations for

airport expansion and airspace change. It was considered important

that we highlighted the two separate processes for airspace change

and the physical expansion of the airport given that they will be

assessed through different consenting procedures. To help consultees,

different colours and branding were used to indicate the separation

between the consultations and separate feedback forms and feedback

channels were provided. The Airport Expansion Consultation

Document provided information on the different consultation and

consenting procedures for airspace change and the airport expansion

and signposted consultees to the Airspace Principles Consultation

Document for further information.

Heathrow have considered the feedback received and have made

changes to subsequent consultations. For example, the Airspace and

Future Operations Consultation in January 2019 presents proposals in

relation to future operations (how we will use the runways following

expansion), airspace change for expansion and airspace change

following the introduction of Independent Parallel Approaches (IPA) as

'one consultation' under a single consultation brand. This includes the

use of one feedback form (rather than two). An interactive postcode

tool is also available on the project website and at exhibitions to help

consultees understand which aspects of the proposals would affect

them.

Separating information about noise between the

expansion and airspace consultation documents

meant not all residents were aware of potential

impacts or the need to respond to both

consultations.

✓




PC MC WC

Heathrow’s initial assessment of the environmental noise impacts

arising from the Heathrow Expansion Project (the Project) will be

contained within the Preliminary Environmental Information Report (the

PEIR). The PEIR will form part of the suite of documentation issued by

Heathrow during the Airport Expansion Consultation planned for June

2019.

Important information was omitted from the

consultation, such as the potential reduction of

respite currently provided to communities under

existing flightpaths, there appeared to be a conflict

between the two consultations and information on

noise issues was limited. This meant that there was

no clear way for residents to identify where they

lived in relation to noise impacts around the airport.

✓ Alternation

The Airspace and Future Operations Consultation commencing in

January 2019 provides information on our emerging proposals for the

provision of respite through alternation. For more information, please

see the Airspace and Future Operations Consultation Document and

the Runway Operations - Respite Through Alternation document for

more information.

It is recognised that for some communities which benefit from the current pattern of runway alternation that the level of respite that they currently receive each day will be reduced. This is acknowledged in the ANPS at paragraph 5.61. Why this is the case is explained in the consultation document Runway

Operations - Respite Through Alternation, which forms part of the

Airspace and Future Operations Consultation (January 2019).

Information on noise

The Airport Expansion Consultation One (2018) was very early in the

process for the development of a new airspace design for an expanded

Heathrow and as such there was limited geographically specific

information we could provide about likely noise impacts. In the January

2019 Airspace and Future Operations Consultation we are consulting




PC MC WC

on the broad geographical areas where future flight paths could be

positioned. These are known as design envelopes. The design

envelopes are accompanied by information about the height of aircraft

passing over a certain area within each envelope. On our consultation

website, it is possible for consultees to input their postcode to find

information relating directly to their area. We are seeking feedback from

the public on local factors which we should take into account when

designing future flight paths.

Heathrow’s initial assessment of the environmental noise impacts

arising from the Project will be contained within the PEIR. The PEIR

will form part of the suite of documentation issued by Heathrow during

the Airport Expansion Consultation planned for June 2019.

The consultation materials lacked information on the

cost of expansion.

✓ The Airport Expansion Consultation One information explained that the

proposed options for the Project had been evaluated against a range of

environmental, community, cost, operational, delivery and planning

criteria. The Scheme Development Report presented the findings of

this evaluation in Figure 22.

Given that a preferred masterplan had not been prepared at the time of

Airport Expansion Consultation One, it was not possible, therefore, to

provide a detailed breakdown of costs relating to the Project (although

the Airport Expansion Consultation Document and Scheme

Development Report did provide indications of more and less costly

options). The preferred masterplan for the Project, which will be

presented at the Airport Expansion Consultation in June 2019 along

with the Updated Scheme Development Report which will provide

further information relating to costs. This will include the findings of the

evaluation process that includes the ‘business case’ as one of the

seven criteria applied to the evaluation of masterplan options. This

Disappointed at the lack of information on

construction costs, which they considered meant

stakeholders could not weigh up the costs and

benefits.

✓

The consultation materials did not provide sufficient

comparative analysis of issues such as costs,

benefits, risks and environmental impacts or explain

the relationship between options to help determine

which were compatible.

✓




PC MC WC

includes scheme costs and operating costs.

The consultation documents lacked detail. ✓ ✓ The Airport Expansion Consultation One presented the process

followed and the progress made by Heathrow as of January 2018 in

developing options for the key components of an expanded airport and

its supporting facilities. This included information on proposed physical

changes to the airport, as well as in respect of Heathrow’s approach to

surface access and the natural environment. The primary aim of the

Consultation was to seek preliminary feedback to inform the ongoing

development of the masterplan.

The Airspace and Future Operations Consultation Document provides

more detail on proposed changes to airspace and Heathrow's emerging

thinking in relation to directional preference, respite through alternation

and a ban on scheduled night flights.

Similarly, in June 2019, as part of the Airport Expansion Consultation,

Heathrow will publish the preferred masterplan for the Project, which

will provide more detail about all of Heathrow's proposals.

Heathrow will also publish a draft Surface Access Strategy as part of

the Airport Expansion Consultation, which presents the preferred option

for park and ride and public transport proposals including for non-

motorised users.

The Airport Expansion Consultation will also include detail in the PEIR

on the construction process and mitigation proposals, including

potential impacts on housing.

The consultation provided insufficient information

for people to make decisions.

✓

The content of the consultation was high-level due to

the scheme being in the early stages of

development.

✓

The consultation information was too high-level

which meant that it was not possible to comment in

detail on issues critical to Stanwell and Stanwell

Moor residents.

✓

The consultation material included misleading

content and Heathrow did not quantify the airport’s

current operations against the potential impacts of a

new third runway, meaning that residents could not

make an informed assessment of the impacts and

costs of expansion.

✓

As information was vague or missing, the impacts

on an area could not be fully understood and firm

comments on the proposals could not be made.

✓




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Concern raised that the consultation did not include

information on important issues such as flight paths,

runway modes, baggage, park and ride, public

transport interchanges, landscape mitigation,

temporary construction sites and displaced uses

that are crucial to assessing the wider impacts on

the borough.

✓

The following should have been covered in the

Consultation; construction, the night time ban,

changes to flight paths, the number of aircrafts,

transport and accessibility, impacts of the M25 and

local road diversion options, road user charging,

noise, pollution, health effects and related

mitigation, demand for housing in the local area,

environment impacts, loss of greenspace, the

environment, cost, compensation and mitigation

proposals, project timescales, alternatives to

expansion, safety and security issues, impacts on

local people, communities and businesses, airline

landing charges, encouraging model shift by using

Crossrail and airport supporting facilities.

✓

Important information was omitted from the

consultation, such as the potential reduction of

respite currently provided to communities under

existing flightpaths. Information on noise issues was

limited which meant there was no clear way for

residents to identify where they lived in relation to

noise impacts around the airport.

✓




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The consultation materials could have included more

about housing and surface access, such as cycle

facilities and bus access.

✓

The consultation materials lacked information on the

potential regeneration benefits of expansion and the

ways benefits would be maximised.

✓ As part of Airport Expansion Consultation One, information on benefits

of the Project was provided in the Airport Expansion Consultation

Document. For example, this included Heathrow’s commitment to

“create 5,000 additional apprenticeships at Heathrow, bringing the total

to 10,000 by 2030.” Details of the proposed approach to the delivery of

high quality mitigation around the airport for biodiversity, the landscape

and the water environment for the benefit of both local communities

and wildlife were also set out in Our Design Approach to Natural

Environment.

The Development Consent Order (DCO) application will be determined

in accordance with policies contained in the ANPS weighing the

benefits against the impacts of the scheme. It is therefore important

that we present both the likely adverse and beneficial effects of the

Project. As part of the Airport Expansion Consultation planned for June

2019, the PEIR will present the preliminary assessment of the preferred

proposals which will consider both positive and adverse effects within

the context of relevant policy and guidance, and as informed by the

Scoping Opinion received in June 2018.

Heathrow should explain how the views of residents

are considered against those of other stakeholders.

✓ Heathrow consider all consultation feedback equally and take it into

account in the design and evaluation process for the Project.

This Interim Consultation Feedback Report (Interim CFR) outlines the

progress which Heathrow has made in responding to the wider

feedback received from Airport Expansion Consultation One. Where

the issues raised are directly relevant to the materials prepared for the

Airspace and Future Operations Consultation (January 2019),




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Heathrow has set out how it has had regard to the feedback from the

Airport Expansion Consultation One.

At the Airport Expansion Consultation in June 2019, Heathrow will

publish a Consultation Feedback Report on the response to the first

rounds of consultation, which will build on this Interim CFR, and will

include Heathrow’s responses to the combined feedback relating to

Airport Expansion from the two previous phases of consultation (i.e.

January 2018 and January 2019) and how that feedback has informed

the preferred proposals presented for consultation in June 2019.

The consultation material did not contain any

baseline data so that an assessment of the impacts

of proposed changes can be made, for example on

noise, traffic and air quality. Comprehensive

baseline date should be provided.

✓ Heathrow is collating baseline data for a range of topics as part of the

Environmental Impact Assessment (EIA) that is being undertaken in

respect of the Project. Preliminary findings of this assessment,

including the baseline data used, will be presented in the PEIR at the

Airport Expansion Consultation in June 2019. Airport Expansion

Consultation One was undertaken at an early stage in the design

process and provided an opportunity to seek early engagement on the

Project. It therefore only provided high level information on

environmental considerations.

Many of the consultation documents had imprecise

wording and unrealistic options which made it

difficult for residents to understand and respond.

✓ As explained in Chapter 3 of this Report, Heathrow provided a range of

information and held a number of public consultation events to explain

our proposals as part of the Airport Expansion Consultation One. Our

aim was to provide accessible, effective, meaningful and engaging

consultation materials.

We have reflected on the responses received in respect of the

effectiveness of Airport Expansion Consultation One in order to

improve subsequent public consultation processes. For example, the

Airspace and Future Operations Consultation in January 2019 and the

planned Airport Expansion Consultation in June 2019 provide a wider




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range of interactive online content and will ensure that wording is

accessible, un-biased and in plain English and that information is

presented using a tiered approach to ensure that all audiences are able

to access the information they require.

Concern raised that limited consideration appeared

to have been given to accommodating the

construction workforce.

✓ The Airport Expansion Consultation One provided information early in

the design process on options for the components of the masterplan. At

the Airport Expansion Consultation in June 2019 we will present the

preferred masterplan and provide information on environmental impacts

of the Project in a PEIR. This will include information on the

construction process and workforce.

For the proportion of the construction workforce that would require

accommodation during construction we are exploring approaches

including the reuse of existing assets or the construction of new

temporary facilities in dedicated areas of the site. The approach to

construction workers’ accommodation considers the effects of the

construction workforce on local housing markets, services and

infrastructure. This information will be presented in the PEIR as part of

the Airport Expansion Consultation proposed for June 2019.

Consultation materials did not provide a coherent

overview of the cumulative effects on the

community.

✓ Airport Expansion Consultation One was undertaken at an early stage

in the project development process to obtain feedback on the options

identified for the various components of the Heathrow masterplan. As

such it was not possible to provide details of the cumulative effects of

the proposals on the local community or a ‘joined up’ masterplan. An

assessment of cumulative impacts will be presented as part of the

PEIR in the Airport Expansion Consultation in June 2019.

Heathrow has reflected on the responses received in respect of the

effectiveness of Airport Expansion Consultation One in order to

The consultation lacked a joined-up plan or map

showing the cumulative effect of the proposals on

the area. The scale of the maps was too small to be

able to clearly identify sites.

✓




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improve subsequent public consultation processes.

At the Airspace and Future Operations Consultation in January 2019

and at the Airport Expansion Consultation planned for June 2019 an

interactive postcode map tool will also be used on the Project website

and at exhibitions to help consultees understand which aspects of the

proposals would affect them.

Concerns raised over missed deliveries of

Community Information Leaflets.

✓ At the start of Airport Expansion Consultation One, all properties and

businesses within the Potentially Affected Zone (defined as the area

within which aircraft fly at 4,000ft or less) were sent a consultation

information leaflet (CIL). Over 2.2 million copies of the CIL were sent

via Royal Mail. In areas where Heathrow received notification that

copies of the CIL had not been received targeted leafletting was

undertaken during the consultation. Heathrow apologise if the delivery

of the leaflets was not successful in some cases.

The presentation of the economic benefits of the

Heathrow Expansion was misleading, did not include

a breakdown of how it was generated and did not

align with the figure in the draft ANPS.

✓ ✓ Heathrow is continuing to assess the potential economic benefits of the

Project, which will become more detailed as the masterplan is

developed. The benefits reported at Airport Expansion Consultation

One reflected our consideration of benefits of the Project at that time.

Further information will be provided at the Airport Expansion


It was not clear that the consultation formed part of

the DCO process and that the timetable for finalising

flight paths needs to be aligned with the DCO

timeline so that airspace decisions could be fed into

the DCO process.

✓ Airport Expansion Consultation One was not the statutory consultation

required by the Planning Act 2008 for a DCO application, but was an

additional consultation ahead of that. The Airport Expansion

Consultation Document for Airport Expansion Consultation One set out

clearly the role of the consultation in the DCO process (page 9) and

further information was set out in a further consultation document called




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Development Consent Order Process Information Paper That Paper

also explained that the air space change process would determine the

final flight paths and that the assessment for DCO purposes would be

made on the basis of indicative flight paths.

Heathrow has had regard to the feedback received in respect of Airport

Expansion Consultation One in the design and evaluation process for

the Project.

The process going forward, including the interaction between the DCO

and airspace change process is further explained in this consultation in

our document: How do we seek approval to expand Heathrow?

Indicative timelines for the 2 processes are set out in the Airspace and

Future Operations Consultation Document.

All Consultations will inform the ongoing development of the preferred

masterplan (for the purposes of the DCO application and the preferred

scheme for airspace change).

The consultation did not clearly present the various

options as coherent strategies.

✓ The Airport Expansion Consultation One presented the process

followed and the progress made to that point (January 2018) in

developing options for the key components of an expanded airport and

its supporting facilities. The work was at an early stage of development

and the aim of the consultation was to seek feedback to inform the

development of the masterplan.

The preferred masterplan will be presented at the Airport Expansion

Consultation in June 2019, along with the PEIR. The PEIR will provide

consultees with a comprehensible report on the information compiled

by Heathrow as at that point in time about the predicted environmental

impacts of the preferred masterplan and the measures proposed to

mitigate such impacts.

The public were being asked to comment on options

such as land usage and road layouts without fully

understanding the impacts once they are put

together.

✓




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Not all the consultation documents had been shared

with Councillors prior to the start of the consultation.

✓ Prior to the launch of Airport Expansion Consultation One consultation

documents were not shared with the local planning authorities.

Heathrow did however carry out a number of pre-consultation briefings

for Local Authorities in the run up to the consultation and following

launch to brief them on the content of the consultation and the factors

on which feedback was being sought.

Heathrow should set out how it will work with the

public sector to ensure effective planning and

delivery for community infrastructure needs such as

schools, healthcare facilities, utilities and local

services that will be required by the new airport and

supply chain employees and their families.

✓ Heathrow are undertaking an assessment of impacts on communities

as part of the EIA process. This includes an assessment of potential

temporary and permanent effects on the viability, sustainability and

accessibility of all physical community facilities and community-facing

businesses and public services. We are also working closely with

HSPG and relevant service providers to assess the wider growth and

infrastructure development which is likely to be generated by the

Project. Early findings including mitigation proposals will be presented

in the PEIR at the Airport Expansion Consultation in June 2019.

No consultation events were hosted in the Borough

of Brent, this should be addressed in future

consultations.

✓ When considering the geographical area within which public

consultation exhibitions should take place, Heathrow has had regard to

key principles, including the areas likely to be affected by the Project,

the need to provide a broad and even distribution across these areas

and to provide exhibitions in accessible locations.

In relation to noise effects and locations further away from the airport,

at this stage, we do not know where the flight paths will be positioned

and as a result it is not possible to undertake a Lowest Observable

Adverse Effect Level (LOAEL) analysis. As a result, we have identified

the land within which aircraft arriving and departing the airport will be

travelling at 4,000ft or less as this represents the maximum extents of

the LOAEL. Southern parts of Hertfordshire are within the outer extent

of this Zone.

Consideration should be given to engaging with

Hertfordshire communities more proactively and

hosting a consultation event(s) within the south west

of the County.

✓




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Heathrow will formally consult the London Borough of Brent and

Hertfordshire County Council on our Statement of Community

Consultation for the Airport Expansion Consultation in June 2019,

which includes a list of proposed exhibition venues. We will take all

feedback into account ahead of confirming our final locations for

exhibitions for the June 2019 consultation.

Heathrow will publicise all stages of consultation within the London

Borough of Brent and Hertfordshire, including locations of exhibitions.

Heathrow does not currently intend for consultation exhibitions relating

to the Airspace and Future Operations Consultation in January 2019 to

take place within the London Borough of Brent or Hertfordshire.

However, we are proposing to hold an event within the London

Borough of Harrow (at Harrow Leisure centre) which adjoins the

London Borough of Brent and the Hertsmere and Three Rivers District

of Hertfordshire.

Locations for exhibitions are based on areas most accessible to people

located within the Zone. We have reviewed the venues of exhibitions

for Airport Expansion Consultation One and replaced those that were

poorly attended with venues in areas of higher footfall.

Further information and extensive engagement with

Heathrow will be required to ensure the design of the

Heathrow Expansion Project delivers a safe and

serviceable strategic road network, to agree

appropriate mitigation and the use of robust

modelling to ensure future proofing of the design.

✓ Heathrow are engaging with stakeholders as part of the preparation of

the draft Surface Access Strategy. The Surface Access Strategy and

technical information underpinning the modelling process used by

Heathrow will be presented at the Airport Expansion Consultation in

June 2019 in relation to the preferred masterplan.

A bilateral workshop should be convened to discuss

impacts on the rail network and rail accessibility.

✓ Heathrow are continuing to engage with Network Rail and rail service

providers regarding the likely impacts and requirements of the Project




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on the rail network and rail accessibility.

Concern about the purpose of the consultation. ✓ The Airport Expansion Consultation Document (Section 1) explained

the purpose of the Airport Expansion Consultation One.

The purpose of the Airspace and Future Operations Consultation is

explained in the Airspace and Future Operations Consultation

Document.

Heathrow remain committed to engaging with the local community,

statutory consultees, the wider public and all those with an interest in

the Project throughout the design process in order to continue to seek

views to shape its expansion plans.

Concerns raised that the consultation was biased, a

‘box-ticking exercise’ or PR exercise and that

Heathrow will not listen to and act on consultation

feedback.

✓ ✓ The purpose of the Airport Expansion Consultation One was to seek

views early in the design process for the Project. Heathrow have

considered all feedback received and have published this Interim CFR

which sets out details of the consultation undertaken and feedback

received in relation to the Project.

This Interim CFR also sets out Heathrow’s response to the feedback

received during the Airport Expansion Consultation One and will inform

the Consultation Feedback Report that will be produced to accompany

Heathrow’s statutory consultation and the Consultation Report that is

required to accompany the DCO application.

Heathrow remains committed to engaging with the local community,

statutory consultees, the wider public and all those with an interest in

the Project throughout the design process in order to continue to seek

views to shape its expansion plans.

The consultation presented a new runway that is no ✓ At the time of the Airport Expansion Consultation One, the draft ANPS




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longer open to debate. had not been designated. To retain flexibility, Heathrow therefore

presented three options for proposed new runway of varying lengths.

Options A2 and A3 proposed a runway length of 3,200m and Option A4

proposed a runway length of 3,500m.

Since the Airport Expansion Consultation One concluded, the ANPS

has been designated. The ANPS clarifies the Government’s position on

the length of the new runway at Heathrow, stipulating that it needs to

be at least 3,500m in length.

As such, and in order to meet the requirements in the ANPS, Heathrow

have discounted the two runway options consulted on (Options A2 and

A3) which were less than 3,500m in length.

The consultation carried no weight because it was

non-statutory and undertaken ahead of the

designation of the ANPS.

✓ Although non-statutory in nature, the Airport Expansion Consultation

One was undertaken in accordance with the relevant guidance on

consultation associated with the proposed DCO application.

The overarching aim of the Airport Expansion Consultation One was to

gather views from all those with an interest in Heathrow’s expansion

about its emerging plans, options for components of the scheme and

approaches to key issues such as noise, air quality, surface access and

climate change. Heathrow considered that it was important to seek

views early in the design process for the Project at a stage when

options were still being considered.

Heathrow has considered and continues to have regard to, all feedback

received during the Airport Expansion Consultation One.

It should have been made clear that the consultation

was non-statutory and was being undertaken at a

time when feedback on the ANPS consultation was

still being analysed. The consultation was a PR

exercise and carries no weight.

✓

The Hendon consultation event was organised on a

Jewish holy day, preventing attendance by the

Jewish community.

✓ Heathrow regrets that the timing of the Hendon consultation caused a

conflict with a Jewish holy day. We will seek to ensure that future

consultation events are accessible outside of days of religious or




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cultural significance.

The Freepost return envelopes provided at some

events were too small.

✓ Throughout Airport Expansion Consultation One, large envelopes were

provided at the majority of events. Respondents were also able to write

the Freepost address on any envelope and post this free of charge.

Going forward, Heathrow will ensure that large envelopes are provided

at every consultation event and respondents will still have the option to

write the Freepost address on any envelope and post this free of

charge.

Requests for documentation at the Hayes event were

not fulfilled.

✓ Heathrow apologises for any unmet requests for documentation.

Heathrow aims to ensure that all requests for copies of consultation

materials received at consultation events and via our project phoneline

or email address are fulfilled with materials either sent via email or in

hard copy, dependent on the nature of the request.

The consultation did not attract a young audience.

An online consultation exhibition would have

achieved a wider reach and better use should be

made of social media platforms and the website.

✓ As part of the development of our approach to subsequent stages of

consultation we have explored different channels and mechanisms to

engage with and capture feedback from different demographics. This

includes using a wider range of traditional materials and interactive

digital technology, a more interactive website, using targeted social

media and holding consultation exhibitions in more publicly accessible

venues, such as shopping centres and terminals.

The staff at the Stanwell Moor event did not provide

feedback forms.

✓ Heathrow apologises if feedback forms were not made accessible to all

that attended the Stanwell Moor event. Heathrow provided feedback

forms for use at all consultation events.

Heathrow has had regard to this feedback in the planning of future

public consultation events and will ensure that feedback forms are




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made available at all events.

Staff were insensitive to concerns and not

appropriately informed on specific issues.

✓ In staffing the consultation events Heathrow sought to ensure that

members of the project team with a range of specialisms and

knowledge were available. Those staffing the consultation events were

also given training and briefed prior to each event.

Heathrow continues to aim to have relevant staff at consultation events

and where specific queries cannot be answered, Heathrow staff will

agree to respond to consultees with the relevant information by phone,

email or post should the consultee provide contact details. Alternatively,

consultees can contact Heathrow to request information by email, a

freephone number or by post. In any event, Heathrow will continue to

seek to improve consultation events going forward.

The feedback form is long and tedious, cumbersome

and difficult to navigate.

✓ At Airport Expansion Consultation One, Heathrow was seeking views

on a wide range of Project options and approaches and recognise that

the feedback form was long.

Heathrow has sought to improve the hard copy and online versions of

the feedback form for the purposes of the Airspace and Future

Operations Consultation (January 2019).

For the Airspace and Future Operations Consultation in January 2019

and the Airport Expansion Consultation in June 2019, we will ensure

that feedback forms are more structured and are simplified with fewer

questions.

The Project website will also be designed to allow respondents to

quickly and easily provide feedback as they view information (in-line

questioning), rather than having to make their way through the entirety

of an online feedback form, though the option of completing the online

The form included questions which were leading and

too complex.

✓

The feedback form could be improved by including

‘logout’ and ‘save’ options, a progress bar, making

related information accessible on each question

page, listing all questions on one contents page up-

front, including relevant maps and figures, detailing

the number of answers required at the outset,

including multiple choice questions and offering the

opportunity to complete the form while remaining

anonymous.

✓




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The feedback form should have provided additional

blank space for feedback.

✓ feedback form question by question will still be there if they wish. The

online feedback form will allow respondents to ‘logout’ and ‘save’.

As at Airport Expansion Consultation One, feedback forms used

throughout future consultations will offer the option for respondents to

remain anonymous.

The feedback form will continue to provide sufficient blank space for

responding to consultation questions. Blank paper will also be provided

at events and can be stapled into the form, should respondents need

additional space for their consultation responses.

Concern raised at the scope of the consultation, to

enable a full and proper consultation on component

parts and the delivery of the optimum overall

scheme, several options should be consulted upon

for each component.

✓ The Airport Expansion Consultation One included a range of options for

each Project component. Options were summarised in the Airport

Expansion Consultation Document and explained in further detail in

Our Emerging Plans and the Scheme Development Report including

the findings of the evaluation process. The preferred masterplan for

the Project will be presented at the Airport Expansion Consultation in

June 2019. This will include an Updated Scheme Development Report

which explains the evaluation process for the options considered.

There was a lack of an overall coherent strategy and

too much focus on individual specific elements

rather than strategic options.

✓ The overarching aim of the Airport Expansion Consultation One was to


about its emerging plans, options for the components of the scheme

and approaches to key issues such as noise, air quality, surface access

and climate change. Heathrow considered that it was important to seek

views early in the design process for the Project at a stage when

options were still being considered.

The Airspace and Future Operations Consultation (January 2019) will

provide more detail on proposed changes to flight paths and

Heathrow's emerging thinking on directional preference, runway




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alternation and a ban on scheduled night flights

The preferred masterplan will then be shared at the Airport Expansion

Consultation planned for June 2019.

The consultation materials did not consider the

timescales, costs and risks involved in relocating

residential, commercial and public property.

✓ The Scheme Development Report (issued as part of Airport Expansion

Consultation One) provided details on the progress made at that time in

developing options for the components of an expanded airport and its

supporting facilities. The Report explained how options for the Project

components had been evaluated against a range of criteria. Figure 22

of this Report summarised the findings of the evaluation including in

regarding to issues relating to the delivery and cost of the Project.

Further detail will be provided at the Airport Expansion Consultation in

June 2019.

The consultation was not broad enough as it only

focused on one proposal for a third runway.

✓ The Airport Expansion Consultation One presented three shortlisted

options for the proposed north-west runway (Options A2, A3 and A4).

The ANPS requires a new runway to be located to the north west of

Heathrow’s two existing runways between Sipson in the east,

Colnbrook and Brands Hill in the west and Harmondsworth in the north.

The shortlisted options presented in the Airport Expansion Consultation

One reflected this requirement.

The Airport Expansion Consultation One sought views on these options

and factors that should influence the precise location and length of the

new runway.

No information had been provided about local

consultations.

✓ Heathrow undertook an extensive process of advertising the

consultation and notifying residents and stakeholders. This involved

adverts in local newspapers, posters and billboards, radio, social




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media, media websites, local televised news and letters and leaflets to

properties located within the potentially affected zone. This is explained

in further detail in chapter 3 of this Report.

The consultation was designed to elicit

predetermined responses which favoured

expansion.

✓ The Airport Expansion Consultation One sought views on options for

the expansion of Heathrow, within the context of development

contemplated by the ANPS.

The consultation events had only been held in areas

already overflown, rather than those which may be

overflown in the future.

✓ As part of Airport Expansion Consultation One Heathrow carefully

considered the area in which public consultation exhibitions should take

place in regard to key principles including the areas likely to be affected

by the Project, the need to provide a broad and even distribution across

these areas and to provide exhibitions in accessible locations. During

the course of the consultation 40 exhibitions events were held across

the Potentially Affected Consultation Zone (the land within which

aircraft arriving and departing the airport will be travelling at 4,000ft or

less) and this included areas both currently overflown and those with

the potential to be overflown in the future.

As part of the identification of locations for exhibitions for the Airspace

and Future Operations Consultation in January 2019 Heathrow has

written to all local authorities within the 4,000ft consultation zone to get

their feedback and suggestions on potential exhibition locations. The

locations selected for the exhibitions take in to account the feedback

received and are based on areas most accessible to people located

within the Zone. We have also reviewed the venues used for

exhibitions for Airport Expansion Consultation One and replaced those

that were poorly attended with venues in areas of higher footfall.

The main consultation document was misleading as

it implied only one consultation was taking place.

✓ The Airport Expansion Consultation Document included a section on

the consultation process which explained how the consultation fitted in




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with the overall consultation plan for the Project and that a subsequent

stage of consultation would take place.

The Airport Expansion Consultation Document also provided

information on the different consultation and consenting procedures for

airspace change and the airport expansion and signposted consultees

to the Airspace Principles Consultation Document for further

information.

Not enough had been said about the impact on areas

to the North of London.

✓ The PEIR, which will be consulted on as part of the Airport Expansion

Consultation in June 2019, will report on likely environmental impacts

and where they are likely to occur.

The consultation did not present a balanced view of

the environmental and community impacts.

✓ The PEIR, which will be consulted on as part of the Airport Expansion

Consultation in June 2019, will include a range of environmental topics

(including community impacts) and will present Heathrow’s preliminary

assessment of both adverse and beneficial impacts and effects in

respect of each of these topics.

Concerns raised about a lack of area-specific

information, more information should have been

provided around the impacts on Colnbrook and

Poyle.

✓ Community Information Booklets were published as part of the Airport

Expansion Consultation One. The Community Information Booklet -

West provided information about the Project options that would impact

on the areas in and around Poyle, Colnbrook and Brands Hill.

This specific information could have included a

composite map showing all possible local impacts,

such as road realignments and river diversions.

✓ Heathrow welcomes suggestions regarding improvements to

consultation material and has taken these suggestions into account in

the planning of our subsequent stages of consultation.


and at the Airport Expansion Consultation planned for June 2019 an

interactive postcode map tool will also be used on the project website




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and at exhibitions to help consultees understand which aspects of the

proposals would affect them.

The PEIR, which will be presented at the Airport Expansion

Consultation in June 2019, will provide information on environmental

effects including a range of maps to identify specific areas impacted by

the Project.

The consultation did not make commitments to

actions which would address community concerns,

the loss of land and properties, pollution or transport

issues.

✓ The Airport Expansion Consultation One included draft policies for:

Residential Property, Agricultural Land and Property, Commercial

Property, (Interim) Property Hardship Scheme, and Professional Fees

(together the Property Policies).

The Airport Expansion Consultation in June 2019 will provide further

information on the Property Policies and the Community Fund, as

required by the ANPS. It will also present our draft Surface Access

Strategy which will set out the role of surface transport in regard to

reducing carbon and impacts on air quality in accordance with the

ANPS (see paragraph 5.9). A PEIR will also be published which will

present the early findings of our EIA, including impacts on air quality

and proposed mitigation measures.

The consultation materials contained statements

which were not supported.

✓ These comments have been noted. Heathrow aims to provide

balanced and accurate information but also seeks to make its

consultation materials user-friendly and clear. At the Airport Expansion

Consultation One, we included both user friendly documents such as

the consultation booklet as well as technical studies such as the

Scheme Development Report. All this information was publicly

available.

The expansion of Heathrow will support economic growth nationally

and this is verified by numerous independent studies including those

The consultation material included misleading

content, such as presenting Heathrow as the only

way to support economic growth.

✓




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published by the Airports Commission and the Department for

Transport. Heathrow recognise that there are other drivers for

economic growth.

The use of two columns in documents made them

difficult to read at appropriate magnification on a

computer screen.

✓ Heathrow welcomes feedback on the accessibility of our consultation

materials. We will seek to take account of suggestions regarding the

layout and design of our documents as part of the preparation of

materials for the Airport Expansion Consultation June 2019.

Frustrating to have to cross-refer to documents that

did not always follow the same sequence.

✓

Further details on how Heathrow Airport will become

a champion for assisted travel should be provided in

the next stage of consultation.

✓ Heathrow is committed to making every journey better and we welcome

the forthcoming Aviation Strategy’s focus on enhancing the passenger

experience. We have already made significant progress in this area

and are always looking for further improvements. We look forward to

working closely with disability groups, industry and government to make

air travel as accessible as possible and give all passengers more

control over their own journeys.

The consultation material did not quantify the

airport’s current operations against the potential

impacts of a new third runway.

✓ The PEIR that will be published as part of the Airport Expansion

Consultation in June 2019 will set out baseline data that reflects the

airport’s current operations and an assessment of impacts of the

preferred Project as against the baseline.

Heathrow need to establish an effective approach to

engaging stakeholders in issues concerning

biodiversity and the design of a green infrastructure

plan.

✓ Heathrow are undertaking a programme of ongoing engagement with

different stakeholder groups concerning different elements of the

Project. Chapter 29 of this Report provides an overview of our ongoing

engagement activities.

Engagement with Natural England and the Environment Agency is

ongoing in respect of the Project’s likely interaction with the natural




PC MC WC

environment. This includes a programme of meetings to discuss our

approach to, and findings of, ecology surveys, to discuss potential

significant effects concerning biodiversity and to discuss mitigation

options and our proposals for biodiversity offsetting. We also engage

with the HSPG, Wildlife Trusts, the Royal Parks and other specialist

interest groups (e.g. Bat Groups, Amphibian and Reptile Groups) to

provide information on our survey programme and results of our

assessments. As the design of our green infrastructure proposals

progresses, this will become a focus of our engagement with the noted

stakeholders.

It would have been beneficial to present consultation

booklets based on single subjects e.g. conservation,

noise, pollution, airport logistics. The maps were

inadequate due to changing scales and that the

conservation areas and historic buildings which

would be lost were not made clear.

✓ As part of the Airport Expansion Consultation One Heathrow produced

a single consultation booklet which provided an overview of the

proposals and the factors on which feedback was being sought. This

was supported by a number of topic specific information papers, such

as Our Design Approach to the Natural Environment, Our Approach to

Air Quality and Our Approach to Noise. Heathrow will continue to

provide topic specific information in the Airport Expansion Consultation

in June 2019, this will include environmental topics.


and at the June 2019 consultation an interactive postcode tool will also

be used on the project website and at exhibitions to help consultees

understand which aspects of the proposals would affect them.

The PEIR, which will be presented at the Airport Expansion

Consultation in June 2019, will provide information on environmental

effects including on the historic environment. This will include a range

of maps to identify specific buildings and conservation areas.

The consultation was a missed opportunity to

address concerns about the proposals for an

✓ The Airport Expansion Consultation One took place early in the design

and assessment process and before the ANPS had been designated




PC MC WC

expanded Heathrow and to set out clear

commitments to address these concerns.

by the Government.

Heathrow will provide further detail on its proposed approach to

mitigating impacts likely to arise from the Project in the PEIR which will


2019.

The consultation gave the impression that

expanding Heathrow was a “given” even before the

Parliamentary vote had been held.

✓ The Airport Expansion Consultation One took place before the ANPS

had been designated by the Government.





and climate change. The Consultation documents made clear that the

Consultation was undertaken in accordance with the framework for

airport expansion at Heathrow contemplated by the draft ANPS.

The ANPS has now been adopted and so provides the key policy basis

for the development of proposals for expansion at Heathrow.

Concerns about the lack of detail in relation to

various elements of the proposals and how

Heathrow will deal with managing an airport which is

doubled in size.

✓ Heathrow will provide further detail on the Project, including the

preferred masterplan and the PEIR, which will include likely impacts

and mitigation, as part of the Airport Expansion Consultation in June

2019.

The consultation was premature as it included too

much unresolved information to allow respondents

to make an informed response.

✓ Although undertaken before the ANPS had been designated by the

Government, Heathrow does not consider that the Airport Expansion

Consultation One was premature.


gather views from all those with an interest in Heathrow’s expansion The consultation was unnecessary as some of the

decisions the consultation asked consultees to make

✓




PC MC WC

depended on information not available until the

second consultation.



and climate change. The Consultation documents made clear that the

Consultation was undertaken in accordance with the framework for

airport expansion at Heathrow contemplated by the draft ANPS.

The Airport Expansion Consultation in June 2019 will provide detail on

the preferred masterplan for the Project.



COSTS

Introduction

27.1.1 In response to Airport Expansion Consultation One, consultees provided feedback

related to the costs of the Heathrow Expansion Project (the Project), its economic

benefits, cost of mitigation or how cost should be taken in to account in the

development of the Project. A total of 325 consultees made comments relating to

this topic.

27.1.2 Heathrow provided the following material that is directly related to the costs of the

Project:



3. Scheme Development Report.














Local Authorities

27.2.1 Bracknell Forest Borough Council acknowledged the economic benefits of the

existing Heathrow Airport and requested access for its residents to the proposed

£1bn community compensation fund.

27.2.2 Ealing Council welcomed the jobs and economic benefits of the Project but said

that it will cause more noise, pollution and traffic that will damage the quality of life

of local people. They indicated they were seeking a £150million package of

measures to maximise the economic benefits of the Project, to mitigate the

environmental impacts of a third runway and to compensate those affected.



27.2.3 Elmbridge Borough Council stated the proximity of Heathrow to Elmbridge has a

beneficial effect on the local economy through job creation, business location and

expansion but queried why the cost of the Project and the contributions that

Heathrow will make to related infrastructure projects was not set out in the Airport

Expansion Consultation One documents. They also expressed concern that

shortfalls in funding or a financial crisis during the construction of the Project could

lead to a cost to the tax-payer.

27.2.4 Essex County Council recognised the role that Heathrow plays in the airport

network and considered that the third runway will enable Heathrow to retain its hub

status, which is vital for future UK economic growth and productivity.

27.2.5 The London Borough of Hammersmith and Fulham said that no context or

breakdown of the stated £187 billion economic benefits of the Project was

provided. They queried why this differs to the figure calculated by the government

as part of its Airports National Policy Statement (ANPS).

27.2.6 They also stated that the consultation materials provided at Airport Expansion

Consultation One contained little information on the costs associated with the

proposed third runway and expressed concern that changes to the Project put

forward in Airport Expansion Consultation One are part of a cost cutting exercise.

27.2.7 Hertfordshire County Council stated that a more comprehensive and realistic

picture of collective growth in the sub-region needs to be agreed to allow an

assessment of the collective impact of growth on the road network, what mitigation

measures will be required and agencies responsible for delivery.

27.2.8 Runnymede Borough Council said there will be significant national benefits for the

economy through the creation of a third runway but expressed concern about the

impact on its local community and harmful impacts across a wider area than any

defined red line boundary to be identified by the Development Consent Order

(DCO) application. They also expressed concern that there was no assessment of

the infrastructure requirements or costs for the Project.

27.2.9 Spelthorne Borough Council recognised the importance of Heathrow’s ‘hub’ status

to the UK economy and its potential benefits to the local area but said that any

community facilities which need relocating must be enhanced and improved at

Heathrow’s cost.

27.2.10 The South East England Councils stated that the new jobs and economic

opportunities must not be gained at the expense of increased congestion, greater

noise, air pollution or reduced quality of life for South East residents. They also

highlighted the urgency of quantifying the increase in services and infrastructure

that will be required and funding to ensure they can be delivered in advance of the

demand for them.



27.2.11 Surrey County Council recognised the importance of Heathrow Airport in

supporting employment for its residents, generating investment in the County’s

economy and in attracting major businesses but commented that the

environmental and surface access issues associated with the Project must be

addressed.

27.2.12 The London Borough of Sutton commented that the potential cost of relocating the

Lakeside energy from waste facility would appear to be a significant obstacle to

the Project.

27.2.13 Wokingham Borough Council acknowledged the proximity of Heathrow Airport is

an essential factor in driving economic growth and maintaining economic activity in

the Thames Valley.

27.2.14 Buckinghamshire County Council expressed concern about the economic impact

to the film industry and the management of Black Park, Langley Park and Thorney

Park used by Pinewood Studios.


27.2.15 Highways England stated that Heathrow’s decision making needs to demonstrate

that whole life costs have been taken into account in the design of the Project, not

just capital construction costs. They highlighted that the Project must be designed

to minimise maintenance interventions and that Heathrow will need to pay

Highways England’s operational and maintenance costs for a period of 60 years

post completion, in line with government policy.

27.2.16 They also highlighted that Heathrow should not rely on the public road system to

provide resilience and should fund proportionate infrastructure improvements to

minimise the impact of the Project on the surrounding road network during

incidents.


27.2.17 The Civil Aviation Authority responded detailing its statutory functions and its role

in regulating the costs of expanding and operating Heathrow Airport and the extent

to which Heathrow can pass the costs of surface access schemes to airlines,

passengers and cargo companies.

27.2.18 The Heathrow Strategy Planning Group (HSPG) stated that Heathrow should

provide funding for monitoring and review of air quality across the HSPG area.

27.2.19 Windlesham Parish Council expressed concern that complexity, cost and land

issues had not been fully considered and stated that no false statements should

be made.



27.2.20 Bray Parish Council commented that the Project requires a considerable amount

of repositioning of recently constructed infrastructure and that this should be

avoided as it is uneconomic.

Local Communities


27.3.1 Members of the public commented that Heathrow should cover all the costs

associated with the Project and that the taxpayer should not have to contribute to

accommodation works, compensation, airport related development, the relocation

of Lakeside or noise insulation. Consultees also commented that there is a need

to consider the price of air travel and ensure the Project does not increase ticket

prices.

27.3.2 Members of the public raised concerns that the proposals for airport supporting

facilities may be too expensive and have not fully taken into account the cost of

relocating existing infrastructure, that the costs of the Project will be borne by

airlines and therefore passengers and at the costs of the infrastructure required to

deal with risk of flooding and diversion of rivers.

27.3.3 Concerns were also raised about the cost of infrastructure and public transport

connections with consultees querying how these will be paid for if Heathrow is only

contributing a small part of the funding. Many considered that the cost of these

improvements should not be at the taxpayers’ expense and should not be passed

on to rail companies.

27.3.4 General comments in relation to cost also comprised that details had not been

provided, that the costs of the Project should be weighed against alternative

schemes, that the costs would be recovered through an intensification of flights,

that the project is unaffordable and not financially credible and that the costs have

been underestimated.

27.3.5 Respondents also expressed a contrary view suggesting that the price of air travel

should be increased to reflect the burden on local communities, costs should be

met by government as much as possible or that Heathrow should minimise

compensation to save cost.

Businesses

27.3.6 The Airport Industrial Property Unit Trust (AIPUT) stated that it is vital to the local

and national economies that Heathrow Airport's hub status is secured and capacity

provided to ensure investment takes place in the many companies that depend

upon its international connectivity.

27.3.7 Airlines for America commented that to ensure that the Project provides maximum

value for the UK economy and the traveling public, the Project must be managed



with a strong focus on cost control and fair/equitable cost allocation. They

considered that proposals to reduce the high costs of the Project without

undermining its potential benefits should be investigated.

27.3.8 They stated that Heathrow’s charges are currently the highest of any other

commercial airport in the world and airlines and their passengers should not be

subject to the additional cost of pre-funding the Project and improving access to

Heathrow, as a result. To avoid this, they suggested that charges should be

capped rather than averaged over time as proposed.

27.3.9 Delta Airlines expressed a similar view stating that passenger charges are already

the highest in the world and any increase would erode the U.K.’s competitive

position relative to other global aviation hubs. They stated that cost control is vital

to ensure that their customers do not pay even more than they already do and

suggested that a passenger charges guarantee should be introduced.

27.3.10 The Arora Group said that the lack of cost information provided at Airport

Expansion Consultation One made it impossible to evaluate options. They

considered this a major flaw in Heathrow’s consultation and requested that cost

estimates and transparent information on each of the components is published so

that key stakeholders can be meaningfully engaged.

27.3.11 They requested that Heathrow:

1. confirm its absolute commitment not to increase in airport charges;

2. publish the detailed evidence for how its scheme, costs and options satisfy this

test; and

3. explain how a landing charge in excess of £20 will be compatible with the

strengthening of domestic air connections, these being highly cost sensitive.

27.3.12 They asked for confirmation on whether Heathrow is expecting to take any cost

risk in developing its proposals or whether it will expect all costs to be absorbed by

users. They also outlined that the Arora Group can deliver the Project more cost

effectively and that they have the support of airlines to do so.

27.3.13 Heathrow Hub expressed a similar view commenting that the consultation lacked

comparative analysis of cost, benefits, risk and environmental impacts of each

option and that there was no attempt to show the relationship between options in

order to determine which are compatible and which are not.

27.3.14 EasyJet highlighted that the cost impact to passengers is a key factor.

27.3.15 Enterprise M3 Local Enterprise Partnership (LEP) expressed support for the

proposals stating that expansion will bring better connections to emerging

markets, more tourists and support exporters and UK businesses to grow.



27.3.16 The Thames Valley LEP also expressed support for expansion and commented

that on, near and off-airport infrastructure needs to be well planned and co-

ordinated in order to reap the maximum benefits for the local economy and to

minimise the negative impact on local communities.

27.3.17 The Staffordshire Chamber of Commerce highlighted the importance of aviation in

connecting the Staffordshire economy to the rest of the world. For Staffordshire

businesses, air transport provides access to international customers and suppliers,

as well as an international labour force. They said that following Brexit,

Staffordshire businesses must be able to connect with high-growth and emerging

economies beyond Europe and considered that unless immediate steps are taken

to increase airport capacity and expand the UK’s international connectivity,

businesses will face increased costs and the economy will experience a loss of

trade, tourism and foreign direct investment.

27.3.18 Greengauge 21 requested that Heathrow undertake an analysis of the costs and

benefits of building the proposed Northwest Runway in two construction phases.

This should explore the concept that, while the full-length runway is desirable for

the long-term future of the airport, it might not be cost-effective now. They also

considered that the study should examine a variety of operating assumptions, a

variety of respite combinations and explore any operational benefit which would

result from runway-use being restricted to only more efficient, shorter-haul aircraft.

27.3.19 The Hampshire Chamber of Commerce commented that Heathrow has the

potential to add approximately 25,000 new flights a year before a new runway

opens and indicated that this should not be delayed so that the economic benefit

can be gained prior to the operation of the Project.

27.3.20 They also stated that increasing domestic air connections to Heathrow is important

and that the continued development of a globally competitive hub airport is

essential to the delivery of the industrial strategy, UK global competitiveness and

the development of international freight.

27.3.21 Petchey Industrial Properties Limited stated that the plans have too great an

impact on the surrounding area and are too costly.

27.3.22 Star Alliance expressed concern that as Heathrow seeks to reduce capital

expenditure, it will sacrifice the completion of Terminal 2 phase one (the baggage

system and a vehicular T2A/B transport link) and the further expansion of Terminal

2. They considered that the failure to deliver this so far is having a negative

impact on both the passenger experience and operational costs and requested

that the delivery of these infrastructure developments is fully costed and included

within all masterplan options for the Project.

27.3.23 The London (Heathrow) Airline Consultative Committee and the Board of Airline

Representatives UK expressed concern that too much of the risk and cost is being

transferred to airlines and passengers. They stated that the airline community is



agreeable to fair and reasonable surface access contributions based on ‘user

pays’ principles, provided these costs are directly related and prioritise integrated

transport schemes. They said that any move away or offer beyond this would not

be acceptable to the airline community.

27.3.24 They expressed concern that the crossing of the M25 may affect the viability of the

Project and suggested that the risks and costs associated with it should be

addressed and independently verified and costed, before progressing too far.

27.3.25 They also commented that any costs committed prior to the DCO being granted

must be borne by Heathrow and its shareholders. They should not be allowed to

make early and additional returns because they are regulated.

27.3.26 Sunvil Holidays stated that the Project needs to be in operation as soon as

possible to avoid the UK lagging behind the rest of Europe and that it must ensure

that passenger charges are not affected.

27.3.27 Virgin Atlantic Airways Limited commented that the Project must deliver the right

scope and benefits at the right price if it is to deliver on the business case for the

Project. They said that it should ensure passengers are not asked to pay more

and that a Passenger Cost Guarantee should be introduced which sets out:

1. the total budget for delivering expansion;

2. a commitment that passenger charges after the construction of the Project will

be no more than today’s in real terms; and

3. a guarantee to cover the costs of any overspend.

27.3.28 They expressed support for the ‘user pays’ principle indicating that the airport and

its users should not pay for the full cost of road infrastructure improvements where

the benefits are shared between airport and non-airport users. They also

requested clarity over how the ongoing maintenance costs of the M25 tunnel and

runway would be allocated.

27.3.29 They expressed concern about the immaturity of the Project and commented that

a lack of detail on capital expenditure and operational expenditure is preventing

them from being able to scrutinise the Project. They also expressed concern that

the new runway capacity would never be fully utilised if noise, traffic or emissions

targets are breached. They considered that this would undermine the economic

case for expansion and increase the cost of development both per passenger and

over its lifetime.

Community groups



include specific feedback on cost.



27.3.31 Aircraft Nosie Three Villages expressed concern about conflicting and overstated

economic benefits, a high risk of the taxpayer having to fund the development and

other UK regions being starved of investment. A similar view was shared by

Teddington Action Group who suggested that to subsidise the Project from the

public purse would be completely unconscionable.

27.3.32 Residents Association HVG CA asked Heathrow to be honest about cost and SCR

Residents for a Fair Consideration of Heathrow Expansion suggested that the

cost, social and environmental impact of the Project was unacceptable. Wentworth

Residents Association commented that the expansion plans involve too much

cost.

27.3.33 Englefield Green Action Group stated that all infrastructure costs for the M25, M4,

M3, A4 and A30 roads should be funded by Heathrow and there should not be any

public subsidy. Ealing Aircraft Noise Group shared a similar view commenting that

there is no justification for local or national taxpayers having to pay for the

proposed diversion and tunnelling of the M25, or for any proportion of the cost of

such a Project.

27.3.34 Eastcote Residents Association commented that the Project will cost tax payers

billions of pounds and considered that the proposed Gatwick Second Runway

could be delivered with greater economic benefits, at lower cost and with no

taxpayer funding. The Eastcote Conservation Panel expressed a similar view.

27.3.35 The Heathrow Association for the Control of Aircraft Noise (HACAN) expressed

support for the establishment of an independent Community Engagement Board

which will influence how money is spent on compensation and community support.

27.3.36 The Richmond Heathrow Campaign commented that the options presented at

Airport Expansion Consultation One are only descriptive and not sufficiently

developed for objective response. They said that topics are not linked into an

overall decision-making framework so it is impossible to discern and balance the

priorities and assess the economic and environmental uncertainties and risks.

27.3.37 John Ruskin Street Residents expressed concern that the costs of the Project had

not been effectively calculated and as a result the tax payer and council tax payer

will be forced to pay the difference.

27.3.38 West Windsor Residents Association suggested that rather than lowering air fares,

the Project would result in an increase in fares particularly if the cost of expansion

is taken into account.


27.4.1 The Association of British Travel Agents stated that the Project offers opportunities

for both the UK economy and the consumer but must be cost-efficient, deliver



increased competition and improve international connectivity to both existing and

emerging new markets.

27.4.2 They stated that their priority was to ensure that consumers do not carry the risk of

meeting the costs of the Project. They also expressed concern that the high costs

of additional airport capacity might lead to higher passenger charges and

increased fares.

27.4.3 The Chartered Institute of Logistics and Transport stated that road replacement

and diversion schemes should be publicly funded if they include additional

capacity to meet general traffic growth.

27.4.4 Justine Greening MP (Putney) commented that a lack of detail means it is not

clear how much the Project will cost. She expressed concern that the costs will

increase so much that Heathrow will not be able to recover costs and the tax payer

will be expected to contribute to the cost of the Project.

27.4.5 The Hounslow Green Party said the economic analysis shows an increasingly

uncertain economic case where the benefit to the national economy looks minimal

and risk to investors is likely to require state guarantees.





wider/other consultees in relation to Costs.








Table 27.1A


PC MC WC

The economic impact to the film industry and the

management of Black Park, Langley Park and Thorney

Park used by Pinewood Studios is a concern.

✓

Heathrow is promoting plans to modernise its airspace at the

same time as it is preparing its application for development

consent for expansion. Changes to our airspace will be consented

in accordance with the Airspace Change Process (ACP).





PC MC WC

As part of the Airspace and Future Operations Consultation in

January 2019, Heathrow will be seeking feedback on the broad

geographic areas within which future flight paths could be

positioned. Heathrow will ask what local factors should be taken

into account when developing new flight paths within these

geographically defined areas known as ‘design envelopes’.

We will treat this response as feedback in relation to these local

factors.

The potential to add approximately 25,000 new flights a

year before a new runway opens should not be delayed so

that the economic benefit can be gained prior to

expansion.

✓ As a first phase of our expansion plans, we are proposing

to make increased use of our existing two runways, once

approval for the physical expansion of Heathrow has been

granted.

More information is available in the document Airspace and Future

Operations: Consultation Document, available as part of the

January 2019 Airspace and Future Operations Consultation.

Our intention is to bring forward proposals for early growth as part of the Airport Expansion Consultation in June 2019.



Table 27.1B


PC MC WC

The business case for expansion does not justify the

significant impact on the biodiversity and natural

environment in and around the airport.

✓ The Airports National Policy Statement (ANPS) recognises that

there is an urgent need for new airport capacity in the South East

(paras. 2.10-18), that the Heathrow Northwest Runway scheme is

best placed to deliver this capacity and that overall it would

deliver the greatest net benefits to the UK (para. 3.74). The

Government has also made it clear in supporting expansion at

Heathrow that any application for development consent must

demonstrate and secure a number of supporting measures in

order to mitigate the impacts of expansion on the environment

and affected communities (ANPS, para. 5.4).

The Development Consent Order (DCO) application will comply

with the ANPS and will include an Environmental Statement (ES)

to identify any likely significant environmental effects during

construction and operation of the Heathrow Expansion Project

(the Project) and any proposed mitigation relating to the same.

Preliminary findings will be available in the Preliminary

Environmental Information Report (PEIR) as part of the Airport

Expansion Consultation in June 2019. As part of this consultation

Heathrow will also be published a draft Surface Access Strategy.

The environmental and surface access issues associated

with expansion must be addressed.

✓

The plans have too great an impact on the surrounding

area and are too costly.

✓

New jobs and economic opportunities must not be gained

at the expense of increased congestion, greater noise, air-

pollution or reduced quality of life for South East

residents.

✓

The economic case for expansion had been overstated

and that airport expansion should be at Gatwick.

✓ The Airport Commission shortlisted three options to maintain the

UK’s status as a global hub for aviation: a new northwest runway




PC MC WC

Gatwick could be delivered with greater economic

benefits, at lower cost and with no taxpayer funding.

✓ ✓ at Heathrow Airport; a westerly extension of the northern runway

at Heathrow Airport and one new runway at Gatwick Airport. The

Airport Commission’s Final Report (July 2015) concluded (page

9): “Each of the three schemes shortlisted was considered a

credible option for expansion, capable of delivering valuable

enhancements to the UK’s aviation capacity and connectivity.

Each would also have environmental impacts, which would need

to be carefully managed. The Commission has nonetheless

unanimously concluded that the proposal for a new Northwest

Runway at Heathrow Airport, in combination with a significant

package of measures to address its environmental and

community impacts, presents the strongest case”. The ANPS

also contains an analysis on why the Government prefers the

Heathrow Northwest Runway Scheme to the Gatwick Second

Runway scheme in terms of delivering additional airport capacity

by 2030 (paras. 3.16 – 3.55).

Based on the Department for Transport’s (DfT’s) assessment of

direct benefits, and Frontiers assessment of catalytic benefits, the

economic benefits of expanding at Heathrow at £187bn are

significantly greater than that for expanding at Gatwick at £116bn.

The Project is a privately funded infrastructure project which will

be delivered in a cost effective and sustainable way.

Costs of Heathrow expansion should be weighed against

alternative schemes.

✓

Access for Bracknell Forest Borough Council residents to

the proposed £1bn community compensation fund.

✓ Heathrow will develop a community compensation fund (CCF).

The size of the CCF will be proportionate to environment impacts.

Further information will be available as part of the Airport

Expansion Consultation in June 2019. Heathrow should provide an £150million package of

measures to mitigate the environmental impacts of a third

runway and to compensate those affected in Ealing.

✓




PC MC WC

Heathrow should minimise compensation to save cost. ✓

Expansion will cause more noise, pollution and traffic that

will damage the quality of life of local people.

✓ Heathrow recognises that the Project will have some impact

during construction and operation and is committed to manage

and mitigate effects on the environment and local communities.

As part of the application for development consent, Heathrow will

need to assess likely significant impacts, including community

impacts, which will then form part of the Environmental Statement

(ES). This will be submitted with the DCO application.

In June 2019, as part of the Airport Expansion Consultation,

Heathrow will be publishing more details of the assessment,

including proposals for how Heathrow will manage, monitor and

report on impacts in the future. Further information on

environmental impacts will be available in Chapters 19 and 21 to

24 of the PEIR.

The project’s impact on its local community and harmful

impacts across a wider area than any DCO ‘redline’ are

concerning.

✓

There is an urgent need to quantify the increase in

services and infrastructure that will be required and

funding to ensure they can be delivered in advance of

demand for them.

✓

Heathrow is engaging with the relevant utility and service

providers and will ensure that adequate provisions are put in

place in the DCO to protect their interests.




PC MC WC

Any community facilities which need relocating must be

enhanced and improved at Heathrow’s cost.

✓ As part of the Environmental Impact Assessment (EIA), a

community impact assessment is being undertaken. This will

include an assessment of appropriate provision and mitigation

proposals for affected community facilities. Early findings of this

assessment will be presented in the PEIR published as part of


Heathrow should provide funding for monitoring and

review of air quality across the Heathrow Strategic

Planning Group (HSPG) area.

✓

At the Airport Expansion Consultation in June 2019, Heathrow

plans to publish more detail on managing and mitigating effects of

growth, including proposals for monitoring and enforcement for

areas such as air quality.

The cost of expansion and the contributions that

Heathrow will make to related infrastructure projects was

not set out in the consultation documents.

✓ Airport Expansion Consultation One January 2018 sought to

provide information and obtain feedback on a range of

masterplan component options. As such it was not possible to

provide detailed cost information because the plans were still at

an early stage of development. The masterplan scheme

development process has been designed to ensure that

affordability considerations are fully taken into account, alongside

criteria within the other discipline areas (operations and service,

delivery, sustainability and community and planning and

property). Cost is an important consideration and the masterplan

is being carefully prepared to balance all the different design

requirements. Heathrow is evaluating the costs of all masterplan

options and will keep a record of this as progress is made to a

preferred masterplan. The outputs from the evaluation process

were presented in the Scheme Development Report at Airport

Expansion Consultation One and an Updated Scheme

The options provided are only descriptive and not

sufficiently developed for objective response.

✓

Consultation materials contained little information on the

costs associated with the 3rd Runway.

✓

The consultation lacked comparative analysis of cost,

benefits, risk and environmental impacts of each option

and that there was no attempt to show the relationship

between options in order to determine which are

compatible and which are not.

✓




PC MC WC

A lack of detail on capex and opex prevents scrutiny of

the development proposals.

✓ Development Report will be available as part of the Airport


Topics are not linked into an overall decision-making

framework so it is impossible to discern and balance the

priorities and assess the economic and environmental

uncertainties and risks.

✓

Heathrow have not provided a detailed breakdown of cost. ✓ ✓

Cost information and information on each of the

components should be provided in order to evaluate

options.

✓

The lack of assessment of the infrastructure requirements

or costs for an expanded Heathrow is concerning.

✓

The project’s the benefit to the national economy looks

minimal and risk to investors is likely to require state

guarantees.

The Airports Commission estimated that the Project would deliver

up to 180,000 jobs across the UK, the majority predicted to be

outside London and the South East. Furthermore, the ANPS

recognises that the Project is best placed to deliver additional

runway capacity and overall would deliver the greatest net

benefits to the UK (Para 3.74).

The Project will be privately funded at no cost to the taxpayer.

Heathrow has already invested over £12 billion of private money

into the airport since going private in 2006 and will be able to

secure further attractive private financing for its expansion without

Shortfalls in funding or a financial crisis during the

expansion of Heathrow could lead to a cost to the tax-

payer.

✓

Repositioning recently constructed infrastructure should

be avoided as it is uneconomic.

✓




PC MC WC

Heathrow should cover all costs associated with

expansion.

✓ ✓ ✓ public loans or guarantees. Heathrow’s shareholders are

amongst the most experienced infrastructure investors in the

world, with over $1 trillion of funds under management.

The Project will be delivered affordably and sustainably, while

aiming to keep airport charges close to 2016 levels.

Heathrow is regulated by the Civil Aviation Authority (CAA). The

CAA will scrutinise Heathrow’s business plan.

The taxpayer should not have to contribute to

accommodation works, compensation, airport related

development, the relocation of Lakeside or noise

insulation.

✓

Costs should be met by government as much as possible. ✓

Any costs committed prior to the DCO being granted must

be borne by Heathrow and its shareholders.

✓ ✓

There should not be any public subsidy. ✓

Ensure that consumers do not carry the risk of meeting

the costs of expansion.

✓

Complexity, cost and land issues have not been fully

considered.

✓

No context or breakdown of the stated £187 billion

economic benefits of expansion was provided.

✓ The ANPS identified total benefits of up to £74 billion over 60

years for the Northwest Runway scheme at Heathrow (paragraph




PC MC WC

Heathrow’s stated £187 billion benefit of expansion differs

to the figure calculated by the Government as part of its

NPS.

✓ 3.26 refers) but this did not include wider trade benefits). The

draft ANPS (October 2017) identified the same benefit at

paragraph 3.26 but again that did not include wider trade

benefits.

£187bn is based on the DfT’s latest estimate of benefits, added to

catalytic impacts that Frontier have calculated.

The DfT estimated that Heathrow will generate £74.1-75.3bn over

the 60-year appraisal period (2026 - 2085). These benefits are

calculated as a sum of passenger benefits, Government revenue,

and wider economic impacts but significantly excludes trade and

foreign Direct Investment (FDI) benefits.

Frontier Economics has performed a catalytic impact analysis of

a 3rd runway at Heathrow, measuring the effect of additional

trade, FDIs and additional tourism spending on GDP – all of

which are not included in the DfT’s figure. They estimated that the

Project will lead to £113bn of catalytic impact.

The catalytic impact and those estimated by the DfT are based

on separate methodologies and capture different benefit types.

Heathrow consider them largely additive. Therefore, taken

together, the catalytic impact and the DfT’s impacts could lead to

a total benefits figure of up to £187bn for Heathrow.




PC MC WC

The potential cost of relocating the Lakeside energy from

waste facility would appear to be a significant obstacle to

the expansion proposals.

✓ Heathrow has been working with Grundon Waste Management &

Lakeside Energy from Waste (EfW) to identify potential suitable

sites for the relocation of its facilities. The objective has been to

replace these facilities and discussions are well advanced.

The Lakeside EfW’s operation cannot meet the definition of

Associated Development required for inclusion within the DCO

application, nor does the ANPS require its replacement. It will not,

therefore, be possible to include proposals for its relocation as

part of the DCO application. A replacement facility will require

consent from the relevant local planning authority.

Decision making needs to demonstrate that whole life

costs have been taken into account in the design of the

scheme, not just capital construction costs.

✓

The Project will be delivered affordably and sustainably, while

aiming to keep airport charges close to 2016 levels.

Heathrow is confident that the work it is doing and on-going

engagement with airlines, communities and other stakeholders

will enable it to meet that affordability challenge.

The ANPS states that the scheme should be “cost-efficient and

sustainable, and seeks to minimise costs to airlines, passengers

and freight owners over its lifetime” (paragraph 4.39).

Within that context, the scheme development process has been

designed to ensure that costs are fully taken into account,

alongside criteria within the other discipline areas such as

sustainability, community, operations and service and others.

Heathrow is regulated by the CAA and the CAA will be

responsible for scrutinising the business plan.




PC MC WC

The proposals for supporting facilities may be too

expensive and have not fully taken into account the cost

of relocating existing infrastructure.

✓ The masterplan scheme development process includes a wide

range of considerations in the evaluation criteria used for

appraising different options and masterplan components

(including supporting facilities) which will form part of the decision

making process, including cost, buildability, land use,

environment and impact on existing operations.

The Updated Scheme Development Report and preferred

masterplan, including preferred options for supporting facilities

will be published as part of the Airport Expansion Consultation in

June 2019.

Heathrow should undertake an analysis of the costs and

benefits of building the Northwest Runway in two

construction phases.

✓ It has always been intended that the north west runway scheme

would be phased. There are a number of reasons why it is likely

to be desirable to phase the introduction of new capacity,

including:

• it is a more cost-efficient way of delivering large scale

infrastructure;

• new assets can be brought into use as and when ready,

whilst other parts of the Project remain under

construction, thereby delivering early benefits;

• it enables passenger growth to be accommodated whilst

ensuring the programme is affordable and keeping the

passenger charge close to current levels;

• it also reduces operational impacts on airport users and

ensures the best customer experience; and

• it allows time for airlines to schedule and develop new

routes.




PC MC WC

New runway capacity will never be fully utilised if noise,

traffic or emissions targets are breached.

✓ Heathrow is proposing legally binding obligations to ensure that

growth of the airport’s operations can only take place if it respects

each of the environmental limits as set out in the ANPS related to

areas such as noise, traffic, or emissions.

As part of the Airport Expansion Consultation in June 2019,

Heathrow will publish proposals on how these should be

monitored or enforced.

A more comprehensive and realistic picture of collective

growth in the sub-region needs to be agreed to allow an

assessment of the collective impact of growth on the road

network, what mitigation measures will be required and

agencies responsible for delivery.

✓ Heathrow is working closely with the Heathrow Strategic Planning

Group (HSPG) to assess the wider growth which may be

generated by the Project, including effects on the road network

and any necessary mitigation measures required. This is

intended to inform future Local Plan reviews.

The cost of infrastructure and public transport is

concerning if Heathrow is only contributing a small part of

the funding.

✓ Where transport infrastructure benefits airport users, Heathrow is

committed to make a fair and reasonable contribution.

The ANPS (para. 5.20) states “Where a surface transport scheme

is not solely required to deliver airport capacity and has a wider

range of beneficiaries, the Government, along with relevant

stakeholders, will consider the need for a public funding

contribution alongside an appropriate contribution from the airport

on a case by case basis”. Heathrow has a track record of

investing in surface access improvements at the airport and will

fund all of the road diversions required by expansion alongside a

fair and reasonable contribution to new rail infrastructure, where

Infrastructure and public transport improvements should

not be at the taxpayers’ expense and should not be

passed on to rail companies.

✓

There is no justification for local or national taxpayers

having to pay for diversion and tunnelling of the M25, or

for any proportion of the cost of such a project.

✓




PC MC WC

The scheme must be designed to minimise maintenance

interventions and Heathrow will need to pay Highways

England operational and maintenance costs for a period

of 60 years post completion.

✓

this is required to secure planning permission for expansion or

enhance the efficient operation of the airport, in accordance with

the CAA policy on surface access.

Heathrow should not rely on the public road system to

provide resilience and should fund proportionate

infrastructure improvements to minimise the impact of

airport expansion on the surrounding road network during

incidents.

✓

The crossing of the M25 may affect the viability of the

project and suggested that the risks and costs associated

with it should be addressed and independently verified

and costed.

✓ ✓

All infrastructure costs for the M25, M4, M3, A4 and A30

should be funded by Heathrow.

✓

The project needs to provide clarity over how the ongoing

maintenance costs of the M25 tunnel and runway would

be allocated.

✓

Road re-provision schemes should be publicly funded if

they include additional capacity to meet general traffic

growth.

✓




PC MC WC

The costs of infrastructure required to deal with risk of

flooding and diversion of rivers is concerning.

✓ The costs associated with the Project will be privately funded.

Heathrow will comply with National Policy on flood risk

management, including the Water Framework Directive (WFD).

The scheme development process has been designed to ensure

that costs and affordability considerations are fully taken into

account, alongside all other relevant considerations including

sustainability and community and others. Preliminary findings will

be available in the PEIR as part of the Airport Expansion


Costs will be borne by airlines and therefore passengers. ✓ The Project will be privately funded. Heathrow have already

invested over £12 billion of private money into the airport since

going private in 2006 and will be able to secure further attractive

private financing for our expansion without public loans or

guarantees. Heathrow’s shareholders are amongst the most

experienced infrastructure investors in the world, with over $1

trillion of funds under management.

The Project will be delivered affordably and sustainably. while

aiming to keep airport charges close to 2016 levels. Furthermore,

research from the CAA has shown that additional capacity will

increase competition and choice for passengers and has the

potential to drive down costs on airfares.

ANPS para. 3.26 states that “Expansion at Heathrow Airport

would increase the availability of services and increase

competition between airlines. This would lower fares that

passengers can expect to face relative to no expansion, leading

Ensure expansion does not increase ticket prices. ✓

Agreeable to fair and reasonable surface access

contributions based on ‘user pays’ principles, provided

these costs are directly related and prioritise integrated

transport schemes. Any move away or offer beyond this

would not be acceptable.

✓

Airlines and their passengers should not be subject to the

additional cost of pre-funding expansion and improving

access to Heathrow.

✓

Prefunding should be avoided by capping charges rather

than averaging over time.

✓




PC MC WC

Cost control is vital to ensure that customers do not pay

even more than they already do and a passenger charges

guarantee should be introduced.

✓ to significant benefits to business and leisure passengers and the

wider economy.”

To strengthen domestic connectivity between airports in the UK,

Heathrow has committed to introduce a package of measures to

increase connections to the UK’s hub airport. This has included

the introduction of a £15 discount on domestic departing

passenger charges to strengthen connectivity to other UK

regions.

Heathrow is regulated by the CAA and the CAA will scrutinise the

business plan.

Where airport users will benefit from transport infrastructure

proposals, Heathrow is committed to make a fair and reasonable

contribution in accordance with Government policy. Any

contribution to transport infrastructure will be made in line with,

and subject to approval through, the CAA’s surface access policy.

Heathrow is still developing a preferred masterplan in

consultation with airlines, communities and other stakeholders

and will publish the preferred masterplan as part of the Airport


Heathrow should confirm its absolute commitment to no

increase in airport charges and publish the detailed

evidence for how its scheme, costs and options satisfy

this.

✓

Heathrow should explain how a landing charge in excess

of £20 will be compatible with the strengthening of

domestic air connections.

✓

Heathrow should clarify if it expecting to take any cost

risk in developing its proposals or whether it will expect

all costs to be absorbed by users.

✓

As Heathrow seeks to reduce capital expenditure, it will

sacrifice the completion of Terminal 2 phase one and the

further expansion of Terminal 2.

✓

Too much of the risk and cost is being transferred to

airlines and passengers.

✓ ✓

The project must ensure that passenger charges aren't

affected.

✓ ✓




PC MC WC

A Passenger Cost Guarantee should be introduced which

sets out; the total budget for delivering expansion, a

commitment that passenger charges after expansion will

be no more than today’s in real terms and a guarantee to

cover the costs of any overspend.

✓

Rather than lowering air fares, expansion would result in

an increase in fares.

✓

Costs of Heathrow expansion should we recovered

through an intensification of flights.

✓

The project is unaffordable and not financially credible. ✓

The costs have been underestimated. ✓

The project must be managed with a strong focus on cost

control and fair/equitable cost allocation to provide

maximum value for the UK economy and travelling public.

✓

Proposals to reduce the high costs of expansion without

undermining its potential benefits should be investigated.

✓

Changes to the scheme put forward in the consultation

are part of a cost cutting exercise.

✓

The price of air travel should be increased to reflect the

burden on local communities.

✓



PLANNING

Introduction

28.1.1 In response to Airport Expansion Consultation One, consultees made comments

about planning policy applicable to the proposed expansion of Heathrow and/or

the important planning factors that should be taken in to account in the

development of the Heathrow Expansion Project (the Project). A total of 292


28.1.2 Heathrow provided the following material that is directly related to planning:


2. Development Consent Order Process Information Paper;

3. Environmental Impact Assessment Information Paper;


5. Scheme Development Report.

28.1.3 Heathrow asked the following questions regarding planning at Airport Expansion

Consultation One:

1. Do you have any views on how the demand for additional airport related

development such as hotels and offices might best be delivered?














Local Authorities

28.2.1 Bracknell Forest Borough Council commented that Extant Minerals and Waste

Local Plans should be recognised and that there must be engagement with the

appropriate authorities on this matter.



28.2.2 The London Borough of Brent expressed disappointment that Heathrow had not

made a commitment to work with local authorities to propose policies in their local

plans that would prevent third party car parks. If they are to control the number of

vehicles accessing the airport and meet the targets in the draft Airports National

Policy Statement (ANPS), Heathrow will require the support of the local

authorities.

28.2.3 Buckinghamshire County Council commented that it had not received any

information to demonstrate how the modal share and transport targets in the draft

ANPS would be achieved. They highlighted that policy considerations should not

just include the London Plan but also the policies of Buckinghamshire County

Council, South Bucks District Council and the Chilterns District Council and other

local planning authorities.

28.2.4 They also requested funding for the Council’s work to assist Heathrow in taking

forward the Project and suggested a Planning Performance Agreement as an

appropriate mechanism.

28.2.5 Ealing Council expressed a similar view commenting that proposals for airport

supporting facilities are best addressed through emerging evidence base studies,

the proposed Joint Spatial Planning Framework for the wider Heathrow area and

where appropriate, specific site allocations in individual local development plans.

They stated that in the absence of a holistic strategy and supporting evidence it

was premature to comment.

28.2.6 The London Borough of Hammersmith and Fulham stated that consulting on a

shorter runway did not comply with the draft ANPS and was confusing. They also

expressed concern that mitigation measures set out in the draft ANPS were not

referenced in the Airport Expansion Consultation Document.

28.2.7 The London Borough of Hounslow commented that their emerging Local Plan

Review for the west of the borough proposes significant additional housing and

employment areas across Feltham and Bedfont but Heathrow’s proposals are for

low-density logistics or directly displaced functions such as the Immigration

Removal Centre. They requested that Heathrow review its plans to ensure

consistency with theirs and neighbouring Local Plans.

28.2.8 Runnymede Borough Council expressed concern that the draft ANPS does not

recognise the severity of congestion problems on the surrounding road networks

and considered that freight traffic should be included in any targets linked to

Heathrow’s ‘no more traffic’ pledge.



28.2.9 Slough Borough Council stated that the following planning principles should apply

to any development at Heathrow:

1. Protect Colnbrook and Poyle villages in a “Green Envelope25”;

2. Enhance Colnbrook Conservation Area and built realm;

3. Prevent all through traffic but provided good public transport and cycle routes

to the airport;

4. Provide for the replacement of Grundon energy from waste plant and the rail

deport north of the new runway;

5. Ensure that there are good public transport links into Heathrow from Slough;

6. Enlarge the Poyle Trading Estate for airport related development but with

access only from the M25;

7. Provide mitigation for the Colne Valley Park and ensure that existing North

South connectivity is maintained through Crown Meadow;

8. Develop tangible measures to improve air quality in the Heathrow area; and

9. Ensure that all homes in the Borough that are eligible for noise insulation are

provided for under the Quieter Homes Scheme.

28.2.10 They considered that elements of the Project presented at Airport Expansion

Consultation One are in direct conflict with these principles and demonstrate a

disregard for the Council’s objectives for mitigating the impact of the expanded

airport.

28.2.11 Surrey County Council also sought clarification as to why Heathrow presented

options for runway length that did not comply with the draft ANPS. They stated

that airport related development should take account of any adopted and emerging

Local Plans (including site allocations) and should be delivered through the

Heathrow Strategic Planning Group (HSPG) on a joint strategic planning

framework.

28.2.12 The Royal Borough of Windsor and Maidenhead expressed concern about the

lack of detail around the quantity and distribution of additional housing required to

meet the needs of the proposed expanded airport. They commented that scope to

accommodate additional housing over and above the levels set out in the Local

Plan is severely restricted. They also stated that Heathrow should support local

authorities to develop an area-wide response to the spatial distribution of

25 A network of green spaces protected from development



economic activity rather than leave it to local authorities to bear the risk and cost of

dealing with individual planning applications.

28.2.13 Wycombe District Council stated that over 75% of the district is green belt or an

Area of Outstanding Natural Beauty (or both) and this means that it is not able to

meet all of its housing and economic development land needs. They commented

that additional development arising from Heathrow alongside increased national

housing requirements will make the accommodation of future growth even more

difficult.


28.2.14 Highways England sought clarification on what reference would be made to the

National Networks National Policy Statement in the Heathrow Development

Consent Order (DCO) application. They also commented that demand for

additional airport related development needs to be taken forward in consultation

with local planning authorities as they develop their local plans.

28.2.15 Historic England shared a similar view stating that airport related development

must be integrated with the local plans of the adjacent local authorities, to ensure

a properly plan-led approach to new development beyond the boundaries of an

expanded airport.

28.2.16 The Environment Agency highlighted the importance of adopting the sequential

approach to locating development in the areas of lowest flood risk in accordance

with the National Planning Policy Guidance for flood risk and coastal change.

28.2.17 Natural England commented that to satisfy the requirements of the National

Planning Policy Framework (NPPF), sufficiently detailed agricultural land

classification information must be submitted in support of Heathrow’s DCO

application.


28.2.18 The HSPG requested further explanation on why Heathrow had presented options

for a 3,200m runway when the draft ANPS states a length of 3,500m, the only

option that appears to offer full operational and respite benefits.

28.2.19 They commented that while national policy for nationally significant infrastructure

projects will be set out in National Policy Statements, other planning policies are

material including the NPPF policies and local development plans (adopted and

emerging). They also stated that normal planning principles should apply to airport

related development.

28.2.20 Watford Borough Council commented that it had previously provided information

on currently permitted/allocated developments to feed into the modelling of the



traffic impacts of proposed growth and noted that this only makes up a relatively

small proportion of actual future development.

Local Communities


28.3.1 Members of the public that provided comments related to planning made

comments about perceived deficiencies in the draft ANPS or made general

comments about the need for the proposals to comply with planning policy.

Respondents commented that the planning process should be speeded up as the

expansion of Heathrow is long overdue and in the national interest.

28.3.2 Consultees also commented on the use of brownfield sites for development and

avoidance of impacts on the Green Belt. This comprised comments that car

parking should be on brownfield sites and not on green/open space in Stanwell

and Harlington, that hotel development needs to conform to local plan strategies

for housing and regeneration of underused brownfield sites and that the removal of

green spaces would be detrimental to Green Belt between West Drayton and

Slough.

28.3.3 Specific comments were also received that any development between Airport Way

and Stanwell Moor would not justify the very special circumstances required to

develop in the Green Belt and that the use of Green Belt and the loss of Little

Harlington Playing Fields for car parking must be avoided.

28.3.4 Other comments expressed concern that Heathrow would not be able to comply

with the NPS target to restrict airport related traffic, that proposals to introduce

road user charging need to be considered in accordance with national policies and

that evidence-based site analysis should be carried out to the determine the

suitability of sites for development.

Businesses

28.3.5 The Arora Group considered that as the ANPS had not been adopted, Airport

Expansion Consultation One was premature. They considered this particularly

important as key project decisions had been reached based on the Airports

Commission scheme and the draft ANPS.

28.3.6 They considered that discounting options based on unadopted policy was

premature and challenged why Heathrow was consulting on two runway options

that do not meet the criteria in the draft ANPS. They also highlighted that legal

challenges in respect of the ANPS will be brought forward which will address key

issues which Heathrow has used to discount options and on which the

consultation was based.



28.3.7 Wiggins Building Supplies Limited commented that if the DCO application makes

no reference to land at Poyle Manor Farm for airport related car parking or for

uses including warehousing, industry and offices they intend to submit a planning

application for one or more of these uses.

28.3.8 Jayflex Construction Limited stated that it has promoted the Horton Brook Quarry

site for housing, commercial and amenity use in the Royal Borough of Windsor

and Maidenhead Borough Council’s recent ‘call for sites’ request. They

highlighted that the site is suitable for mixed use development servicing Heathrow

that will replace amenities lost through the Project.

28.3.9 Segro expressed concern about the delivery of airport-related development as the

majority of land identified (approximately 97%) is in the green belt. They requested

greater clarity on how development will be delivered on these sites given the

enhanced Green Belt safeguarding policies in the draft London Plan and NPPF.

28.3.10 They also commented that all of the sites for airport-related development should

be delivered through planning permissions separate from the DCO.

28.3.11 The Lanz Group highlighted that under the Section106 Agreement attached to

planning permission PP/10697/009 all site HGVs must exit their site east away

from the village of Colnbrook. They stated that any closure of the A4 east would

significantly affect this planning permission and current operations, making the

business unviable.

28.3.12 Crane Road Properties commented that it had submitted a representation to

Slough Borough Council in January 2017 as part of the “Call for Sites” exercise to

confirm that their site (Land at Green Acre Farm) could be released from the

Green Belt and made available for airport related development.

28.3.13 Harleyford Aggregates commented that the safeguarded status of Mayfield Farm

under the NPPF, the London Plan and London Borough of Hounslow’s Local Plan

does not appear to have been considered. They stated that this may not preclude

development proposals at the site providing mineral extraction is completed prior

to development.

28.3.14 Global Grange Limited expressed concern that consideration had not been given

to the proposals included within Hounslow’s ‘West of the Borough Plan’. They

highlighted that given the need for growth, development and regeneration within

this part of Hounslow, Heathrow should carefully consider the emerging planning

policy framework and work with Hounslow Council and landowners to deliver the

vision for development within this part of the Borough and ensure that there is no

conflict with the expansion proposals.

28.3.15 Greengauge 21 stated that the planning analysis should document the predicted

change in noise levels in Hounslow and Stanwell Moor compared to both current

levels and the Project.



28.3.16 Goodman commented that land to the north of the A4 Colnbrook Bypass has been

the subject of two planning applications to Slough Borough Council for the creation

of a Strategic Rail Freight Interchange (planning application references:

P/10792/000 and P/14961/000). More recently, this land has been identified by

Slough Borough Council as a potential future location for new employment

development in the emerging Review of the Local Plan.

28.3.17 Ingrebourne Valley Limited stated that its site is identified in the Hillingdon Local

Development Plan as suitable for mineral extraction and a planning application for

this use was submitted in November 2017. They stated that they would resist any

proposals that would sterilise this site but would work with Heathrow and

potentially enter into agreements over the land once the mineral extraction

operations have been completed and the site has been fully restored.

Community groups



include specific feedback relating to planning or the planning policy context.

28.3.19 The Local Authorities Aircraft Noise Council and Aircraft Noise Three Villages

stated that the consultation was premature as there was no government policy to

support the Project.

28.3.20 Teddington Action Group considered that it was not appropriate for Heathrow to

consult on alternative positions and lengths of runway that do not accord with the

draft ANPS.

28.3.21 Richmond Heathrow Campaign commented that conditions of expansion are

vague and provide little assurance to those potentially harmed. They considered

that the conditions of expansion should be placed on a legal footing with penalties

applied to Heathrow’s shareholders for any breach.


28.4.1 Transport for the South East commented that passenger demand will grow faster

than initially expected. As a result, they considered that without additional

sustainable surface access the airport will not become successful, meet

sustainability requirements nor meet the demands of future air travel growth.

28.4.2 The London Wildlife Trust highlighted that its continued engagement in the pre-

application planning process will incur costs and as a result they were keen to

explore how this could be addressed.

28.4.3 The National Trust highlighted the importance of requirements of relevant

National, Regional and Local planning policy including the draft London Plan, the



London Environment Strategy and the All London Green Grid, and the need to

address the potential impact on the Colne Valley Regional Park.

28.4.4 Surrey Wildlife Trust highlighted the relevance of Surrey Biodiversity Opportunity

Area (Staines Moor and Shortwood Common) as the basis for achieving Surrey’s

local ecological network.

28.4.5 The Friends of the River Crane expressed concern that there is no single

overarching authority with responsibility to ensure that networks of green

infrastructure identified in development plans are protected from development and,

where possible, strengthened by or integrated within it.



Issues Raised and Heathrow’s Response


consultees in relation to Planning. None of the feedback received in relation to Planning are directly related to the proposals

on which we are seeking feedback as part of the Airspace and Future Operations Consultation (January 2019) but instead

relate to other aspects of the Project. The table therefore provides a summary of the way in which we are seeking to consider

the issues raised, and are provided for information only. No further feedback is being sought on the basis that a full

consultation feedback report will be published as part of the Airport Expansion Consultation in June 2019.

Table 28.1B


PC MC WC

Heathrow has not provided information to

demonstrate how the modal share and transport

targets in the draft Airports National Policy

Statement (ANPS) would be achieved.

✓ The Airport Expansion Consultation in June 2019 will include our draft

Surface Access Strategy and supporting technical information in the

Preliminary Transport Information Report. This will explain Heathrow’s

preferred approach to transport infrastructure needed to support the Project

in the context of increasing the use of public transport by passengers and

colleagues, and our preferred plans for a new parking strategy and

freight/logistics strategy. In addition, it will propose measures and incentives

which would help to manage demand by car users travelling to and from the

airport, as set out in the Airports National Policy Statement (ANPS) at

paragraph 5.17.

The draft Surface Access Strategy will set out how we intend to meet the





PC MC WC

ANPS requirements for increasing passenger mode share by public

transport and reducing the number of colleague car trips (paragraph 5.9).

At the time of Airport Expansion Consultation One in January 2018 the

ANPS was in draft. In June 2018, the ANPS was designated by the

Secretary of State for Transport with only minor changes. Regarding surface

access, paragraph 5.17 now includes additional text that states the surface

access strategy should also include an assessment of the feasibility of the

measures proposed. This information will be included in the draft Surface

Access Strategy which will be published in June 2019.

Policy considerations should not just include the

London Plan but should also include policy

documents of other local planning authorities

including Buckinghamshire, South Bucks and the

Chilterns District Council.

✓ As the Project is defined as a National Significant Infrastructure Project, it

can only be consented through an application for a Development Consent

Order (DCO) made to the Secretary of State. Under this process, the

proposals will be examined principally against the policy set out in the ANPS

and the National Networks National Policy Statement (NN NPS) for those

elements of the Project concerning proposals for the M25.

In addition to the ANPS and NN NPS, Heathrow is considering relevant

policy at national, regional and local levels (recognising that the ANPS and

the NN NPS represents the primary planning policy). The Project is being

designed and assessed in accordance with the National Planning Policy

Framework (NPPF) and National Planning Practice Guidance (NPPG)

where relevant. We are engaging with local authorities concerning local

development plan documents and will accord with policy objectives where

practicable for the Project to do so. This will be reported in a Planning

Statement to be submitted with the DCO application.

We have also had regard to specific evidence base and strategy documents

including the London Plan Environment Strategy and the All London Green

Grid, as referenced in our Environmental Impact Assessment (EIA) Scoping

Report (May 2018).

Heathrow should review its plans to ensure

consistency with Local Plans.

✓

The Project should have regard to the London

Plan Environment Strategy and the All London

Green Grid.

✓

Concern that elements of the Project are in direct

conflict with principles in Local Plans and this

demonstrates a disregard for the Councils’

objectives for mitigating the impact of the

Project.

✓

Extant Minerals and Waste Local Plans should be

recognised and there must be engagement with

✓




PC MC WC

the appropriate authorities on this matter. We are undertaking an EIA of the Project and early findings will be reported

in the Preliminary Environmental Information Report (PEIR) to be published

as part of the Airport Expansion Consultation in June 2019. The PEIR will

provide a legislative and policy overview and demonstrate where policy is

relevant to and has been considered in relation to the preliminary

assessment of likely environmental effects of the Project. It will guide the

preparation of the Environmental Statement (ES) to be submitted with the

DCO application.

In addition to the National Policy Statements, the

National Planning Policy Framework and

Guidance is also relevant to the proposals.

✓

✓

Heathrow need to assess and address the

potential impact on the Colne Valley Regional

Park and take this into account.

✓ Heathrow are undertaking ongoing engagement with the Colne Valley

Regional Park Interest Company who are part of the Heathrow Strategic

Planning Group (HSPG). Heathrow are undertaking an Environmental

Impact Assessment, which includes an assessment of potential impacts on

the Regional Park. This assessment has informed the design of the Project,

through an ongoing evaluation process. Early findings of this process will be

reported in the PEIR and the Updated Scheme Development Report to be

published at the Airport Expansion Consultation in June 2019.

Airport related development should take account

of any adopted and emerging Local Plans

including site allocations and accord with

standard planning principles.

✓ Where airport related development (ARD) is classified as associated

development, the intention is that it would be part of the DCO application,

and so assessed primarily against the ANPS. Where ARD is not included

with the DCO application, it will require separate consent by the relevant

local planning authority in response to applications submitted in accordance

with the Town and Country Planning Act. Such applications would need to

accord with the relevant local development plan. The ARD chapter of this

Report provides further detail on Heathrow’s response to related issues.

Heathrow are taking an evidence-based approach to determine the

suitability of sites for associated development, including both ARD and ASF,

that would form part of the DCO application. Decisions on the suitability of

sites are informed by a range of evidence in addition to local planning policy

Evidence-based site analysis should be carried

out to determine the suitability of sites for

development.

✓

Suggestion that proposals for airport supporting

facilities are best addressed through emerging

evidence base studies, the proposed Joint Spatial

✓




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Planning Framework for the wider Heathrow area

and where appropriate, specific site allocations in

individual local development plans.

and engagement with the HSPG and other stakeholders.

The sites required for airport-related development

should be delivered through planning

permissions separate from the DCO application.

✓

An emerging Local Plan review proposes

significant additional housing and employment

areas across Feltham and Bedfont. Heathrow’s

proposals are for low-density logistics or directly

displaced functions such as the immigration

removal centre. Heathrow should review its

plans to ensure consistency with Local Plans.

✓

Airport related development should be delivered

through the Heathrow Strategic Planning Group

(HSPG) on a joint strategic planning framework.

✓ Heathrow have undertaken detailed studies to determine the quantum of

ARD that the Project is likely to demand. Where proposed ARD can be

defined as associated development in accordance with the principles set out

in the Guidance on associated development applications for major

infrastructure projects (April 2013: CLG), it is intended to be included in the

DCO application. The remaining quantum of demand will need to be

planned for by the local planning authorities around Heathrow.

Heathrow are working closely with HSPG to identify all growth required to




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2041. The work will provide an evidence base for the local authorities in the

study area27, in the context of the wider region and sub-region, concerning

the potential impacts of the expansion of Heathrow Airport in addition to

planned ‘background’ growth in the sub-region. It looks principally at

potential impacts on the local economy, labour market and associated

demand for employment land and housing. It assesses associated

infrastructure requirements to support this level of development. The work

may inform the way HSPG plans for future growth.

Funding should be supplied to Councils for the

cost of the work required to assist Heathrow in

taking forward its proposals. A Planning

Performance Agreement would be an appropriate

mechanism for this.

✓ Heathrow have entered into a Service Level Agreement with the HSPG,

under which Heathrow funds agreed staffing costs for HSPG members in

relation to review of our emerging plans and assessments and for inputs to

joint evidence base/sub-regional planning work.

Continued engagement in the planning process

for the Project with wider consultees will incur

costs. This needs to be explored by Heathrow.

✓

Consulting on a shorter runway did not comply

with the draft ANPS and was confusing.

✓ ✓ During Airport Expansion Consultation One in January 2018, the ANPS was

still at draft stage (and subject to consideration of further consultation).

27 A Study Area was defined in partnership with the HSPG group, and following Planning Practice Guidance approach to defining commercial property

markets and housing market areas. This found that the HSPG area is very similar to the Heathrow and Slough Travel to Work area and also contains

the authorities accounting for a high proportion of current Heathrow employees. All of the authorities in the Core Study Area are members of the HSPG,

apart from LB Hillingdon.




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Heathrow included Option A2 within the Airport Expansion Consultation One

to retain openness and flexibility in the options that should be evaluated.

The ANPS has now been designated, and the Government has made it

clear in supporting the Heathrow Expansion that the ANPS “applies to

schemes at Heathrow Airport…. that include a runway of at least 3,500m in

length and that are capable of delivering additional capacity of at least

260,000 air transport movements per annum” (paragraph. 4.3). Heathrow

continues to consider the preferred option for the exact length of the third

runway and will present the preferred runway option in June 2019 as part of

the Airports Expansion Consultation. Heathrow will not be proposing any

runway options shorter than 3,500 m in length. Chapter 7 of this Report

provides further information on our response to runway related feedback.

Mitigation measures set out in the draft ANPS

were not referenced in the Heathrow consultation

document.

✓ Consultation documents provided at Airport Expansion Consultation One

provided information early in the design and assessment process, focused

on design components and options. The Airports Expansion Consultation in

June 2019 will outline proposals on mitigation measures, in a PEIR, which

will reference the requirements of the ANPS.

Heathrow should make a commitment to work

with local authorities to propose policies in their

local plans that would prevent third party car

parks. If Heathrow are to control the number of

vehicles accessing the airport and meet the

targets in the draft ANPS, Heathrow will require

the support of the local authorities.

✓ Heathrow have committed to working with local authorities on Controlled

Parking Zones. We continue to work with local authorities, including through

ongoing engagement with the HSPG.




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Concern about the lack of detail provided

regarding the quantity and distribution of

additional housing required to meet the needs of

the Project.

✓ Heathrow are working with the HSPG to undertake research in to the wider

growth implications of the project. This will include looking at the impact of

the Project on future employment growth and housing demand.

As part of the socio-economic impact assessment, to be reported in the

Environmental Statement, we are also assessing potential additional effects

on the housing market as a result of operational employment generation

linked to the Project. Early findings of this assessment will be reported in the

PEIR at the Airport Expansion Consultation in June 2019.

Concern from some local authorities that they

have limited scope to accommodate additional

housing to support the Project over and above

the levels set out in the Local Plan.

✓ Heathrow has proposed generous compensation payments for those losing

their homes, mitigation strategies where it is necessary to intervene to

ensure the re-provision of certain types of housing (such as affordable

housing) and we are working with the HSPG planning authorities to assist in

the planning of new housing in the wider area through Local Plan reviews,

which take account of the growth of the airport alongside other housing and

employment needs for which the authorities already need to plan.

Suggestion that Heathrow should support local

authorities to develop an area-wide response to

the spatial distribution of economic activity rather

than leave it to local authorities to bear the risk

✓ Heathrow recognise the need for strategic planning regarding economic

growth. Heathrow and HSPG have started to consider how this can be

planned for to help inform future Local Plan reviews. This includes the

consideration of an Economic Development Strategy. Early research shows




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and cost of dealing with individual planning

applications.

that the labour market impacts (jobs for residents) and business

opportunities will be the main direct benefit of the expansion for most

authorities. Maximising such benefits will require a combination of

accessibility improvements and ‘soft’ investments in jobs, training and

brokerage.

Concern that the draft ANPS does not recognise

the severity of congestion problems on the

surrounding road networks and that freight traffic

should be included in any targets linked to the

‘no more traffic’ pledge.

✓ Heathrow will publish a draft Surface Access Strategy for consultation at the

Airport Expansion Consultation in June 2019, which will help set out how we

will meet the requirements of the ANPS around modeshare. The strategy

will also support Heathrow’s commitment to strive for no more additional

landside airport-related traffic.

Concern that Heathrow would not be able to

comply with the ANPS target to restrict airport

related traffic.

✓

Protecting Colnbrook and Poyle villages in a

“Green Envelope” should be a planning principle

that applies to any development at Heathrow.

✓ Impacts at Colnbrook and Poyle villages will be assessed as part of the

Environmental Impact Assessment (EIA) of the preferred masterplan for the

Project. This will include a range of environmental topics including

biodiversity, nature conservation, land use and green infrastructure. Early

findings will be reported in the PEIR for consultation in June 2019. The

findings of this assessment will inform mitigation proposals. This will include

a green infrastructure strategy that is informed by engagement with a range

of environmental organisations regarding green infrastructure design.

The preferred masterplan for the Project will be presented at the Airport

Expansion Consultation in June 2019. The preferred masterplan will be

selected following an evaluation of masterplan options and which is

informed by the Airport Expansion Consultation One feedback. This

evaluation includes sustainability criteria, which includes a consideration of

impacts on landscape character and value and green infrastructure

provision, including opportunity to provide a network of multifunctional green




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spaces. The findings of the evaluation that have informed the decision-

making process will be presented in the Updated Scheme Development

Report at the June 2019 consultation.

Enhancing the Colnbrook Conservation Area and

built realm should be a planning principle that

applies to any development at Heathrow.

✓ Potential impacts on the Colnbrook Conservation Area are being assessed

as part of the EIA, as required by the ANPS and the NPPF. Early findings

will be reported in the Historic Environment chapter of the PEIR as part of

the Airport Expansion Consultation in June 2019. This will also include

proposed mitigation measures.

Preventing all through traffic but providing good

public transport and cycle routes to the airport

should be a planning principle that applies to any

development at Heathrow.

✓ Heathrow is committed to meeting the targets for increasing passenger

mode share by public transport as set out in the ANPS and reducing

colleague car trips. Heathrow will publish a draft Surface Access Strategy

(supported by technical information in a Preliminary Transport Information

Report) at the Airport Expansion Consultation in June 2019. This will set out

our preferred options for meeting these targets.

There are several new rail and coach routes proposed to improve

connectively to Heathrow, improving connectivity to the west and east.

There is likely to be a Western Rail Link scheme (promoted by Network

Rail), which would connect Heathrow to Reading, via Slough. The Western

Rail Link is not essential to deliver the modal share targets in the ANPS. We

are working closely with the Department for Transport and Network Rail on

the planning and design of the Western Rail Link Scheme to ensure

compatibility with the Project.

Ensuring that there are good public transport

links into Heathrow from Slough should be a

planning principle that applies to any


✓

Providing for the replacement of the Lakeside

Waste Management Facilities and the rail depot

north of the new runway should be a planning

principle that applies to any development at

Heathrow.

✓ Heathrow has been working with Grundon Waste Management & Lakeside

Energy from Waste (EfW) to identify potential suitable sites for the

relocation of its facilities. The objective has been to replace these facilities

and discussions are well advanced.

The Lakeside EfW’s operation cannot meet the definition of Associated




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Development required for inclusion within the DCO application, nor does the

ANPS require its replacement. It will not, therefore, be possible to include

proposals for its relocation as part of the DCO application. A replacement

facility will require consent from the relevant local planning authority.

Land is likely to be required near the existing rail depot to provide a

relocated rail head, which is a critical component of our Construction

Strategy to minimise Heavy Goods Vehicle (HGV) traffic. The existing rail

depot site was identified at Airport Expansion Consultation One as an

opportunity site for development in the Scheme Development Report. It is

noted that the site is safeguarded as an aggregate rail depot site in local

planning policy. The preferred masterplan will be presented at the Airport

Expansion Consultation in June 2019 and this will confirm land

requirements at the existing rail depot site and impacts on existing facilities.

Enlarging the Poyle Trading Estate for airport

related development with access only from the

M25 should be a planning principle that applies to

any development at Heathrow.

✓ Heathrow are considering a range of options for ARD and are engaging

stakeholders in the process. Heathrow will present its preferred option at the

Airport Expansion Consultation in June 2019. The Airport Related

Development chapter of this Report provides further information on

Heathrow’s response to feedback received on ARD issues.

Providing mitigation for the Colne Valley Park

and ensure that existing North South connectivity

is maintained through Crown Meadow should be

a planning principle that applies to any


✓ The preferred masterplan for the Project, will be presented at the Airport

Expansion Consultation in June 2019. The preferred masterplan will be

selected following an evaluation of masterplan options informed by

consultation and stakeholder feedback. This evaluation includes

sustainability criteria, which includes a consideration of impacts on

landscape character and value and green infrastructure provision including

opportunity to provide a network of multifunctional green space. The

findings of the evaluation that have informed the decision-making process

will be presented in the Updated Scheme Development Report at the Airport


We will propose an approach to mitigating likely impacts at Colne Valley




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Park and Crown Meadow in the PEIR, which will be published for

consultation in June 2019. We are considering approaches to green

infrastructure design and engaging with a range of environmental

stakeholders and HSPG on green infrastructure to inform the preferred

masterplan.

Developing tangible measures to improve air

quality in the Heathrow area should be a planning

principle that applies to any development at

Heathrow.

✓ Heathrow will provide details of mitigation for likely impacts on air quality as

a result of the Project in the PEIR, which will be published for consultation in

June 2019. Heathrow will commit to air quality mitigation as part of the DCO

application. This will accord with paragraph 5.32 of the ANPS, which

requires that the ES demonstrates that the construction and operation of the

Northwest Runway will not affect the UK’s ability to comply with relevant

legal obligations. The Air Quality chapter of this Report provides further

information on Heathrow’s responses to air quality related issues.

Ensuring that all homes that are eligible for noise

insulation are provided for under the Quieter

Homes Scheme should be a planning principle

that applies to any development at Heathrow.

✓ The Quieter Homes Scheme is an existing scheme to provide insulation for

homes currently impacted by noise related to [the existing] Heathrow Airport

and is due to complete in 2020. Heathrow are preparing a compensation

scheme for those impacted by the Project, which includes a noise insulation

scheme. Further details of this scheme will be provided in June 2019. The

Noise chapter of this Report provides more information on the feedback

received concerning noise issues and Heathrow’s response.

Concern from local authorities that additional

development arising from the Project in addition

to increased national housing need will make the

accommodation of future growth even more

difficult.

✓ Heathrow understands the need for strategic planning in relation to future

growth around the Airport. We are working with the HSPG and have

recently commissioned a Joint Evidence Base and Infrastructure Study to

identify growth required to 2041 and HSPG have started to consider how

this can be planned for. In regard to housing, this research has found that

the impact of the expansion on population and housing demand is likely to

be small. However demographic and economic trends, as well as housing

targets, change and it will be important to keep a watching brief.




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Clarification sought on what reference would be

made to the National Networks NPS in the

Heathrow DCO application.

✓ The Project requires significant alterations to the M25 west of the airport.

Those works also meet the definition of an NSIP in their own right. For the

M25 works, the NN NPS is the principal policy document.

It is important that a sequential approach is taken

to locating development in areas of the lowest

flood risk in accordance with the National

Planning Policy Guidance for flood risk and

coastal change.

✓ Heathrow are undertaking a Flood Risk Assessment in accordance with the

ANPS, the NN NPS and relevant national planning policy guidance. Early

findings of the assessment will be included as part of the PEIR to be

published at the Airport Expansion Consultation in June 2019.

Detailed agricultural land classification

information must be submitted to support the

DCO application and to accord with the

requirements of the National Planning Policy

Framework.

✓ Heathrow are undertaking an assessment of impacts on agricultural land

quality, which will be reported as part of the ES. Early findings will be shared

in the PEIR to be published at the Airport Expansion Consultation in June

2019. The approach to this assessment is set out in Chapter 14 of the

Scoping Report, with comments received by the Planning Inspectorate as

set out in section 4.10 of the Scoping Opinion.

Consultees provided information on permitted

and allocated developments that should be

included in the traffic modelling process.

✓ Heathrow are undertaking traffic modelling to inform the draft Surface

Access Strategy and the transport assessment. A Preliminary Transport

Information Report will be published at the Airport Expansion Consultation in

June 2019 that explains the approach to including proposed development in

the traffic modelling process.

The time required for the consenting process

should be reduced as the expansion of Heathrow

is long overdue and in the national interest.

✓ The Heathrow Expansion Project is recognised as An NSIP, and as such is

following a prescribed consenting process in accordance with the Planning

Act 2008.

Car parking should be on brownfield sites and

not on greenfield sites or open space in Stanwell

and Harlington.

✓ Heathrow will present its preferred option for car parking as part of the

Project, at the Airport Expansion Consultation in June 2019. Heathrow has

been engaging with stakeholders in the ongoing design and evaluation

process in relation to car parking options, which seeks to reduce adverse




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environmental impacts in balance with other requirements.

Proposed hotel development needs to conform to

Local Plan objectives for housing and

regeneration of underused brownfield sites.

✓ Heathrow are considering options for hotel development, to be proposed as

part of the DCO application, against a range of criteria which includes local

planning policy. The preferred option for hotel development will be

presented at the Airport Expansion Consultation in June 2019. The Updated

Scheme Development Report will explain the reasons for the preferred

option.

Removal of green spaces would be detrimental to

the green belt between West Drayton and Slough.

✓ Through the design and evaluation process Heathrow is seeking to

minimise adverse impacts on the green belt as a result of the Project.

Where there is a need to use green belt land Heathrow are required to

demonstrate very special circumstances in accordance with green belt

policy and the ANPS. We will present an assessment of likely impacts of the

Project on open space and green belt land in the PEIR as part of the Airport

Expansion Consultation in June 2019. We will also present its preferred

approach to ARD in June 2019. The Updated Scheme Development Report,

to be published in June 2019, will set out the reasons for the preferred

approach to ARD, and the results of the evaluation process that has

informed the decision-making process.

Development between Airport Way and Stanwell

Moor would not justify the very special

circumstances required to develop in the green

belt.

✓

The use of green belt and the loss of Little

Harlington Playing Fields for proposed car

parking must be avoided.

✓

Concern about the delivery of airport-related

development as most of land identified is in the

Green Belt. Greater clarity on how development

will be delivered on these sites is needed given

the enhanced green belt safeguarding policies in

the draft London Plan and draft NPPF.

✓

Proposals to introduce road user charging need

to be considered in accordance with national

✓ In accordance with the aims of the Project and broader policy trends

towards lower emissions and mode sustainable modes of transport,

Heathrow is considering a charging strategy as part of its overall surface




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policies. access strategy to effectively bring down vehicle use and associated

emissions. We will consult on a charging strategy as part of our draft

Surface Access Strategy which will be published at the Airport Expansion


As the ANPS had not been adopted the first

round of consultation was premature. This is this

particularly important as key project decisions

had been reached based on the Airports

Commission scheme and the draft ANPS.

✓ Heathrow does not consider that the consultation was premature. Airport

Expansion Consultation One provided an opportunity for early feedback on

options and approaches at an early stage in the design process for the

Project. The draft ANPS provided a framework for the early design process

and has since been adopted, and now provides more certainty and direction

for the Project going forward. Furthermore, the changes between the draft

ANPS and the adopted ANPS are minor.

Legal challenges in respect of the ANPS will be

brought forward which will address key issues

that Heathrow has used to discount a number of

options and on which the consultation was

based.

✓ The ongoing design and assessment of the Project is undertaken in

accordance with a programme of evaluation and engagement. This process

was explained in the Scheme Development Report published at Airport

Expansion Consultation One. Heathrow is aware of the legal challenges to

the ANPS. We are confident that the Government’s decision-making

process was robust.

If the DCO application makes no reference to land

at Poyle Manor Farm for airport related

developments a planning application will be

submitted for these uses.

✓ Heathrow will present the preferred approach for ARD as part of the

Heathrow Expansion Consultation in June 2019. Inclusion of land within the

DCO application does not preclude any planning application being

submitted to a local planning authority. Further detail on the feedback

received regarding ARD and Heathrow’s response to that feedback is set

out in the Airport Related Development chapter of this Report.

Horton Brook Quarry site is suitable for mixed

use development servicing Heathrow that will

replace amenities lost through the Project.

✓ Heathrow will present its preferred approach to ARD as part of the

Heathrow Expansion Consultation in June 2019. Further detail on the

feedback received regarding ARD and Heathrow’s response to that

feedback is set out in the Airport Related Development chapter of this




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Report.

A Section 106 Agreement attached to planning

permission PP/10697/009 states that all site HGVs

must exit the site east away from the village of

Colnbrook. Any closure of the A4 east would

significantly affect this planning permission and

current operations, making the business

unviable.

✓ The proposed new runway location would most likely result in the loss of the

Western Perimeter Road and parts of the Northern Perimeter Road. It will

likely also result in severance of the A4 (Bath Rd) and A3044 (Stanwell

Moor Rd). These changes will require close working with a number of

interested highway authorities: Slough Borough Council (A4), Transport for

London (A4, A30 and A312), London Borough of Hillingdon (A3044), as well

as Highways England as an interested party operating nearby and parallel

roads. To maintain traffic connectivity in the area and reduce potential

effects on road users, we recognise that the existing A3044 and A4 would

need to be maintained until the new replacement roads are complete. The

draft Surface Access Strategy to be published at the Airport Expansion

Consultation in June 2019 will explain Heathrow’s preferred options for re-

providing the A4. The Surface Access chapter of this Report provides

further detail on Heathrow’s response to surface access related issues.

A representation to Slough Borough Council has

been made for a site to be released from the

green belt and made available for airport related

development.

✓ Heathrow are undertaking ongoing engagement with Slough Borough

Council. Heathrow monitor local policy and changes to site allocations and

decisions regarding ARD will be informed by local planning policy. We will

present the preferred approach to ARD as part of the Airport Expansion


The safeguarded status of Mayfield Farm under

the NPPF, the London Plan and London Borough

of Hounslow’s Local Plan does not appear to

have been considered. This may not preclude

development proposals at the site providing

mineral extraction is completed prior to

development.

✓ Heathrow are aware of the minerals allocation at the Mayfield Farm site.

Where we propose development on land that is safeguarded for minerals,

we will examine the feasibility of these being worked in advance.




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Concern that consideration had not been given to

the proposals in the Hounslow West of the

Borough Plan. Heathrow should carefully

consider the emerging planning policy framework

and work with Hounslow Council and landowners

to deliver the vision for development within this

part of the Borough and ensure that there is no

conflict with the Project.

✓ Heathrow is working closely with local authorities and is aware of the local

planning policy context at Hounslow and Slough.

We are considering local planning policy and site allocation as part of our

assessment of the suitability of sites for ARD and ASF that may be included

in the DCO application as associated development. Our preferred

masterplan will be presented at the Airport Expansion Consultation in June

2019 and this will include our preferred sites for associated development.

The Updated Scheme Development Report will present our reasons for

selecting these sites. Land to the north of the A4 Colnbrook Bypass

has been the subject of two planning applications

for the creation of a Strategic Rail Freight

Interchange. This land has also been identified by

Slough Borough Council as a potential future

location for new employment development in the

emerging Review of the Local Plan.

✓

A site identified in the Hillingdon Local

Development Plan is suitable for mineral

extraction and a planning application for this use

was submitted in November 2017. Any proposals

to sterilise this site would be resisted.

✓ Where we propose development on land that is safeguarded for minerals,

we will examine the feasibility of these being worked in advance.

The planning analysis should document the

predicted change in noise levels in Hounslow and

Stanwell Moor compared to both current levels

and the proposed Project.

✓ The noise impact assessment, which will be reported in the ES will report

baseline noise conditions and predicted changes in the noise environment

related to the Project. Early findings will be published in the PEIR, as part of

our Airport Expansion Consultation in June 2019. The Updated Scheme

Development Report, will also be published in June 2019, and will set out

how noise considerations have informed the preferred options for the

Project. The Noise chapter of this Report provides further information on

Heathrow’s response to noise issues.




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Concern that there is no single overarching

authority with responsibility to ensure that

networks of green infrastructure identified in

development plans are protected from

development and, where possible, strengthened

by or integrated within it.

✓ ✓ Heathrow seeks to minimise adverse impacts on green infrastructure as a

result of the Project. However, as a NSIP the Project will result in adverse

effects on green infrastructure. We will report on the impacts of the Project

on the natural environment and open space in the PEIR as part of our

Airport Expansion Consultation in June 2019. The Project represents an

opportunity to provide green infrastructure for the benefit of biodiversity, the

landscape, water environment and people. This will include biodiversity

offsetting areas and the re-provision of public open space to compensate for

the loss of these areas as a result of the Project. We continue to engage

with the HSPG and a range of environmental stakeholders on a strategy for

green infrastructure.

Effects of the Project are vague and provide little

assurance to those potentially harmed. The

effects of expansion should be placed on a legal

footing with penalties applied to Heathrow’s

shareholders for any breach.

✓ Heathrow will publish the PEIR as part of the Airport Expansion

Consultation in June 2019. This will present details on adverse and

beneficial effects of the Project and proposals for mitigation and monitoring.

More detailed information will be provided as part of the ES to be submitted

with the DCO application.

Passenger demand will grow faster than initially

expected. As a result, without additional

sustainable surface access, the airport will be

unsuccessful, will not meet sustainability

requirements nor meet the demands of future air

travel growth.

✓ At the Airport Expansion Consultation in June 2019 Heathrow will present its

draft Surface Access Strategy that will explain Heathrow’s plan for meeting

the surface access requirements of the ANPS. Technical information will be

presented in a Preliminary Transport Information Report that will set out

assumptions used regarding passenger growth, as part of the June 2019

consultation. The Surface Access Chapter of this Report provides further

detail on Heathrow’s response to surface access related feedback.

The Surrey Biodiversity Opportunity Area

(Staines Moor and Shortwood Common) are the

basis for achieving Surrey’s local ecological

network and therefore are relevant to the Project.

✓ Heathrow is assessing impacts on environmental resources as part of the

EIA and early findings will be reported in the PEIR in June 2019. This will

include consideration of the sites of special scientific interest (SSSI) at

Staines Moor and Shortwood Common.



OVERVIEW OF ONGOING ENGAGEMENT AND NEXT STEPS

Introduction

29.1.1 Throughout 2018, Heathrow has maintained a regular programme of engagement

with its stakeholders. This engagement has been designed to keep community

groups, stakeholder forums, prescribed (statutory) consultees and local authorities

informed of progress on the Project as well as providing a forum for them to find

out more, test the emerging proposals and contribute to the ongoing technical

assessment work.

Overview of ongoing engagement


Local authorities and statutory consultees

29.2.1 As part of the development of the proposals and the environmental assessment

process, Heathrow has set up a number of topic-based stakeholder groups. These

groups are made up local planning authorities, statutory and other bodies and

meet on a regular basis to discuss and obtain feedback on our emerging

proposals, gather information about different elements of the Project and develop

potential mitigation proposals.

29.2.2 The list of topic-based stakeholder groups includes:

1. Air Quality

2. Biodiversity

3. Carbon

4. Climate

5. Community

6. Energy

7. Historic Environment

8. Natural Capital

9. Land Quality

10. Lighting

11. Landscape and Visual Impact Assessment

12. Major Accidents and Disasters



13. Noise

14. Socio-economics

15. Waste

16. Water Environment

29.2.3 In addition to the above, Heathrow has also held meetings, provided information

and sought feedback from local authorities in relation to:

1. The proposed event venues to be used for the Airspace and Future Operations

Consultation in January 2019 (October 2018)

2. The content and approach to the Airspace and Future Operations Consultation

(November – December 2018)

3. The emerging draft of the Statement of Community Consultation for Airport

Expansion Consultation planned for June 2019 (November 2018)

Heathrow Strategic Planning Group (HSPG)

29.2.4 The HSPG is made up of local authorities for areas that will be or are potentially

going to be affected by the Project, Local Enterprise Partnerships (LEPs) and

other organisations in the vicinity of Heathrow. Heathrow engages with this Group

on a very regular basis and the focus of the Group’s work is principally

masterplaning, wider future land-use planning, transportation, regeneration,

economic development and environmental matters including mitigation.

29.2.5 The Group is an important conduit in providing ongoing feedback about the plans

from the communities and businesses affected by the emerging proposals, and

from elected members and officials in the member authorities and organisations.

29.2.6 We also engage bilaterally with individual local authorities on a range of issues

including masterplanning, mitigation options, and our approach to consultation.

Local Communities

Heathrow Community Engagement Board (HCEB)

29.2.7 The Heathrow Community Engagement Board (HCEB) was established in January

2018 and is a key focal point for engagement with local communities in the vicinity

of the airport. The independent board provides constructive challenge and scrutiny

to Heathrow with the aim of improving Heathrow’s consultation and engagement

and ensuring that communities are meaningfully engaged with and are able to

contribute effectively to consultations and evidence gathering in respect of the

Project. It also plays a key role in ensuring communities are consulted on matters

concerning the management or administration of the airport today which affects

their interests.



29.2.8 Heathrow and the HCEB meet formally on a fortnightly basis at a Joint Working

Group. These sessions include presentations and the sharing of information on a

range of issues and topics including:

1. operational procedures;

2. scheme development;

3. surface access strategy;

4. managing community and environmental impacts;

5. expansion construction management and mitigation;

6. sustainable growth of the airport;

7. future airspace change;

8. noise management;

9. approaches to public consultation; and

10. community engagement.

29.2.9 The HCEB makes formal recommendations to Heathrow which Heathrow are

obliged to have regard to. The HCEB also provides advice to Heathrow for

example with regards to engagement materials or approaches to consultation.


Listening events

29.2.10 A programme of events was held between March and May 2018 to give local

communities the opportunity to share their views about what elements of their

community are important to them, what they value and what could be improved.

Table 29.1 details the time, date and locations of these events.

Table 29.1 Listening Events

Date Time Location

20 March 2018 6.30pm – 8.30pm Stanwell Moor – Stanwell Moor Village

Hall

28 March 2018 6.30pm – 8.30pm Colnbrook and Poyle – Hilton Heathrow

T5, Colnbrook

16 April 2018 6.30pm – 8.30pm Harmondsworth – St Marys Church Hall

17 April 2018 6.30pm – 8.30pm Iver and Richings Park – Iver Village Hall

18 April 2018 6.30pm – 8.30pm Cranford and Cranford Cross – Cranford

Baptist Church

19 April 2018 6.30pm – 8.30pm Stanwell – Stanwell Rose Community

Centre



Date Time Location

23 April 2018 6.30pm – 8.30pm Heston – Heston Hyde Hotel

25 April 2018 6.30pm – 8.30pm Hatton – Hilton Garden Inn, Hatton Cross

26 April 2018 6.30pm – 8.30pm Sipson – Sipson Community Hall

30 April 2018 6.30pm – 8.30pm Bedfont and Feltham – St Giles Hotel,

Feltham

1 May 2018 6.30pm – 8.30pm Longford – Thistle Hotel, Longford

2 May 2018 6.30pm – 8.30pm Brands Hill – Heathrow Windsor Marriott,

Langley

3 May 2018 6.30pm – 8.30pm Harlington – Harlington Baptist Church

Hall

Information sessions

29.2.11 A programme of events was held throughout July 2018 for communities affected

by Heathrow’s expansion proposals (see Table 29.2). The events provided an

opportunity for communities to view information such as exhibition boards,

information flyers and short presentations and speak directly to members of the

Heathrow Expansion project team and the HCEB. Each of the events focussed on

the following topics:

1. An overview of the proposed timescales for submitting a DCO application and

starting construction

2. An update on the property compensation schemes available to residents in the

Compulsory Purchase Zone (CPZ) and Wider Property Offer Zone (WPOZ)

3. Bat surveys and their impacts on land and property owners

4. The role of Heathrow’s community engagement team

5. The role of the HCEB



Table 29.2 – Information sessions

Date Time Location

4 July 2018 5pm – 9pm Stanwell Moor Village Hall

5 July 2018 11am – 5pm St Mary’s Church, Harmondsworth

9 July 2018 3pm – 7pm Colnbrook Village Hall

10 July 2018 8am – 12pm Double Tree Hotel, Hounslow

10 July 2018 3pm – 7pm Thistle Hotel, West Drayton

11 July 2018 12pm – 4pm St Mary’s Church, Harmondsworth

12 July 2018 12pm – 4pm Sipson Community Centre

17 July 2018 4.30pm – 8.30pm Iver Village Hall

21 July 2018 9am – 12pm Heathrow Academy

Community Workshops

29.2.12 A programme of community workshops was held throughout November and

December 2018 for local communities potentially affected by Heathrow’s

expansion proposals (see Table 29.3). The workshops provided an opportunity for

communities to provide feedback on specific elements of the emerging masterplan

design, including ways to improve connections, proposed land uses and ways of

improving communities. They were designed to be interactive and attendees were

encouraged to sketch their ideas with architects, draw onto maps of the local area

and either submit feedback postcards or submit feedback through an online portal,

which was kept open for ten days after each event.

Table 29.3 Community workshops

Date Time Location

6 November 2018 5.30pm – 8.30pm Stanwell Moor Village Hall

19 November 2018 3pm – 7pm St Mary’s Church, Harmondsworth

21 November 2018 3pm – 7pm Colnbrook Village Hall

26 November 2018 3.30pm – 8pm Stanwell Rose, Stanwell

28 November 2018 3pm – 7pm St Peter and St Paul’s Church, Harlington

Wider Consultees

MPs

29.2.13 Throughout 2018, both before and after the parliamentary vote on the ANPS in

June, Heathrow maintained a regular programme of engagement with local MPs to

inform them of the expansion process, anticipated timelines and how and when



Heathrow would be engaging with their constituents. This included regular

meetings and updates. Heathrow also held meetings and provided information to

local MPs in relation to:

1. The proposed event venues to be used for the Airspace and Future Operations

Consultation in January 2019 and the desire for pop up events in their

constituency (October 2018)

2. Land Referencing letters that their constituents would receive and the

emerging draft of the Statement of Community Consultation that had been

shared with local authorities (November 2018)

3. The content and approach to the Airspace and Future Operations Consultation

(November – December 2018)

Next steps

29.3.1 The information set out in this report will be considered alongside the findings of

our ongoing evaluations and the feedback received from our ongoing process of

engagement to develop our preferred masterplan and proposed DCO application.

This will form the basis for our statutory consultation under sections 42 to 48 of the

Planning Act 2008 proposed to take place in June 2019 (the Airport Expansion

Consultation).

29.3.2 The Airport Expansion Consultation will be accompanied by a Consultation

Feedback Report (CFR). The CFR will set out Heathrow’s response and the

regard had to the feedback received at the Airspace and Future Operations

Consultation relevant to the proposals being put forward in the consultation. It will

also explain Heathrow’s response to matters raised at Airport Expansion

Consultation One which have not been the subject of the Airspace and Future

Operations Consultation.

29.3.3 Prior to the Airport Expansion Consultation, Heathrow will consult Local Planning

Authorities in Spring 2019 on a draft Statement of Community Consultation

(SoCC) which explains how it will undertake Community Consultation as part of its

wider statutory consultation for the Project.