Airports National Policy Statement
23 March, 2018
The full report is available here
CCA COMMENT: These conclusions and recommendations rather undermine the Transport Committees acceptance of expansion at Heathrow via the north west runway. These 25 recommendations effectively echo the views of the anti expansion lobby (CCA included) and our conclusion is that Heathrow remains undeliverable in the short to medium term. Heathrow’s fundamental problems (ignoring finances) revolve around air & noise pollution and night flights. We do not believe the airport will be able to comply with these recommendations.
Conclusions and Recommendations
1. We accept that there is a case as set out in the Airports National Policy Statement for additional runway capacity, in particular hub capacity. This is on the premise that any expansion is sustainable, consistent with legal obligations and that suitable mitigation’s will be in place to offset impacts on local communities affected by noise, health and social impacts.
The Government should redraft its final NPS, in line with the recommendations set out in this report, to minimise any chance of a successful legal challenge. (Paragraph 12)
2. We conclude that the Government is right to pursue development at Heathrow and accept the arguments it has made in favour of its preferred scheme. We endorse its approach of using a national policy statement and the planning process outlined in the Planning Act 2008. We conclude that there are valid concerns about the Government approach.
We recommend that both Houses of Parliament allow the planning process to move to the next stage by approving the Airports National Policy Statement, provided that the concerns we have identified later in our Report are addressed by the Government in the final NPS it lays before Parliament. Without addressing the concerns the Committee has raised, we believe there is a risk of successful legal challenge. (Paragraph 16)
3. We agree with the Government that the Northwest Runway (NWR) scheme offers the greatest strategic benefits. The scheme will consolidate Heathrow’s hub status, offering a greater number and variety of long-haul connections in the short-term, with a higher frequency than the other schemes considered by the Airports Commission. The scheme would deliver passenger growth that would not be realised without expansion. We accept the Government’s analysis that the economic benefits are broadly comparable across the three schemes and that the Department for Transport’s forecasts show that the NWR scheme’s advantage is more marginal over the longer-term. However, we conclude that in its comparative analysis of the three schemes, in Chapter 3 of the NPS, the Government should give more weight to environmental, health and community impacts. If Parliament is to make an informed decision on the designation of the NPS, members need to be confident that the final NPS reflects the weight of evidence as it is presented in the supporting documents.
We recommend that more detail be provided in Chapter 3 of the NPS on the evidence on environmental, health and community impacts and that the Department for Transport’s comparative analysis be expanded to reflect more accurately the balance of impact across the three schemes it compares. (Paragraph 30)
4. Sections of the draft NPS dealing with air quality should be revised before a final NPS is tabled for approval by both Houses of Parliament.
We recommend that the population impact estimates be updated to reflect the air quality impacts from the increased number of aircraft movements and surface access traffic that will result from a Northwest Runway scheme. We also recommend the air quality monetisation modelling and results be published to clarify the monetised costs of poor air quality. (Paragraph 37)
5. We recommend the Government adopts a more stringent interpretation of air quality compliance than what is currently applied by the Department for Transport to support the NPS. This should include an appropriate level of headroom to manage the 6 Airports National Policy Statement inherent uncertainty of predicting future air quality compliance. The applicant for a Development Consent Order should be required to show, with a reasonable degree of confidence, that their scheme can comply. (Paragraph 39)
6. We recommend that a condition be included in the NPS to the effect that development consent will only be granted if the Secretary of State is satisfied that the proposed scheme will: avoid significant adverse impacts on health and quality of life from air quality; mitigate and minimise adverse impacts on health and quality of life from air quality; and where possible, contribute to improvements to health and quality of life. (Paragraph 40)
7. We welcome the commitment to Western Rail Access provided by the Secretary of State
We recommend a written commitment of policy support for Southern and Western Rail Access be made by the Government in the NPS, including clarity around funding and the timeline for delivery. We also recommend the Government clarify which schemes are needed to support current two-runway operations at Heathrow and which are needed to support an expanded Heathrow. As part of this, we recommend the Department for Transport’s updated surface access modelling be published so that the likely impact on road and rail congestion of a NWR scheme is known. (Paragraph 43)
8. We recommend that the surface access costs in the appraisal, and which support the NPS, be updated and included in the final NPS to reflect the indicative costs of those additional schemes required to deliver on the target of no more road traffic. We are concerned about the absence of detail on proposed changes to the M25. We recommend that the Government work with Heathrow Airport Limited to clarify the proposals and bring greater certainty to the development plans. A key part of this must be the arrangements for diversion of traffic during any works. (Paragraph 44)
9. While we recognise the intention behind the current condition on surface access in the NPS, we conclude its drafting leaves too much scope for unintended surface access impacts from this scheme.
We therefore recommend a condition be included in the NPS that ensures approval only be granted if the target for no more airport related traffic can be met, or that as a condition of approval, capacity be released at the airport, after construction, only when the target is met. (Paragraph 46)
10. We recommend that the Government provide a clear definition in the NPS of what constitutes a domestic route and that the Government outlines more clearly, in paragraph 3.34, how it intends to secure 15% of new slots for domestic connections, including the policy levers it will use to achieve this target. This should also include an explanation as to how the Government intends to deliver these slots in the immediate period after the third runway opens and how it will guarantee these slots are made available at suitable times spread across the day. The Government should also outline how it will enforce Heathrow’s domestic connectivity commitments once a NWR scheme is in operation. (Paragraph 50)
11. We accept that cost accuracies will improve as the project matures, but fundamental aspects of scheme design and surface access remain undefined, creating a perception of a cost risk that is high. There is only one mention of cost in the NPS. This is not a fair reflection of the legitimate concerns of airlines and passengers, who are likely to absorb much of the risk, about the cost of expansion. Before votes in Parliament to Airports National Policy Statement 7 approve a final NPS, we would like to see evidence to demonstrate that the Northwest Runway scheme is both affordable and deliverable and that steps are being taken to address the valid concerns we heard in evidence about the high cost of the scheme and the significant risk that costs will rise. (Paragraph 54)
12. We recommend a condition be included in the NPS that airport charges be held flat in real terms but with scope for a marginal increase provided the balance of benefits is in favour of the consumer, as assessed by the Civil Aviation Authority.We recommend that the Government consider whether the CAA has the powers necessary to regulate effectively future airport charges at Heathrow. (Paragraph 59)
13. We recommend that, at an appropriate early stage of the DCO planning process, the Government’s preferred scheme be tested by the Civil Aviation Authority to ensure it is both affordable and financeable. Such as test should offer an opportunity to halt the planning process if it is evident that the proposed scheme has no realistic prospect of being built. (Paragraph 60)
14. The evidence in the NPS shows that a Northwest Runway (NWR) scheme could have a seriously damaging effect on communities living under and adjacent to flight paths. Until actual flights paths are known the actual noise distributions resulting from the NWR scheme cannot be known. We believe that the approach taken by the Department for Transport has resulted in an analysis that tends towards the lower end of the range of possible noise impacts. It is right that Parliament and the public have a fair view of the range of possible noise impacts from a NWR scheme.
We recommend the noise modelling be updated to reflect a range of possible flight-path scenarios. The results from this modelling should also be presented using a range of metrics and across the full range of thresholds recommended in the latest guidance. We believe it would be helpful if the Department for Transport published the evidence base supporting their assumptions about future fleet mix. (Paragraph 66)
15. We recommend that a condition be included in the NPS to ensure noise impacts be measured, during the DCO process, against an updated baseline that incorporates the Government’s latest guidance and assumptions. We recommend that the NPS also specify the noise metrics and thresholds upon which noise will be assessed. These must be consistent with the Government’s updated guidance. (Paragraph 67)
16. We recommend that the Government defines in the NPS what constitutes “significant adverse impacts” and define an acceptable noise limit that reflects a maximum acceptable number of people newly exposed to noise due to the scheme. (Paragraph 69)
17. We recommend that the Government set out in the final NPS how it intends to regulate any noise envelope and what options for recourse will be available against the airport and/or airlines for breaching such an envelope. (Paragraph 70)
18. We recommend the Government define a minimum acceptable level of noise respite in the NPS. (Paragraph 71)
19. We endorse a night-flight ban and believe improved and predictable night-respite is long-overdue for nearby communities. However, we believe that the Government’s proposal for a blanket ban of six and a half hours pre-empts the DCO process and the community consultation within that. We recommend that affected communities 8 Airports National Policy Statement are provided with a minimum average period of 7 hours of respite a night. The exact timing of this respite should be determined through joint working between the airport, airlines and communities. Evidence received suggest such a scheme would be achievable. A future night flight ban should not prohibit unpreventable overruns, in the event, for example, of weather delays.
But we recommend a mechanism be established that provides stringent oversight of any night-flight regime to ensure that airlines and the airport are monitored and an effective enforcement regime is in place to incentivise much tighter control of overruns into the night-flight respite period where they are preventable. (Paragraph 72)
20. We support the proposed compensation measures put forward by Heathrow Airport Limited and are encouraged by their willingness to engage with communities. However, we believe it is too early in the process to specify exact sums for compensation when the detail of the scheme and its subsequent impacts remain unclear. The NPS should set the framework and principles upon which compensation will be offered, with the finer details determined during the planning process.
We recommend that: the threshold for £3,000 in compensation for acoustic insulation for residential properties be revised to reflect the significant noise annoyance thresholds in the latest Government guidance; the £3,000 committed for noise insulation be independently tested during the DCO process to ensure that this is a sufficient sum of money to mitigate properly the increased noise nuisance cause by the scheme; and the 125% offered to compensate residents whose homes are compulsorily acquired be independently tested during the DCO process to ensure it is appropriate and sufficient to cover the repurchase of an equivalent standard of housing at a suitable location. We recommend that the NPS clearly outline that there is no fixed limit on the amount of compensation offered to affected communities provided it meets the criteria set within the designated NPS. We also recommend that the £50m a year figure is increased by RPI each year so that the real terms value of this remains the same for each year of the 15 years. (Paragraph 76)
21. We recommend that a condition approval be included in the NPS which requires the scheme proponent to develop a strategy outlining how it intends on supporting local communities during and in the extended periods after the planning process is finished. This should be developed in consultation with the communities affected as well as the relevant local authorities. (Paragraph 77)
22. We recommend a condition of approval be specified in an updated NPS that provides the Lakeside Energy from Waste plant with equivalent recognition as the Immigration Removal Centres and that the replacement of its facilities be accounted for in the DCO process. (Paragraph 80)
23. We recommend that Government outline its intended policy approach to delivering airspace change for its preferred scheme as a matter of priority. We acknowledge the helpful work that the Government has already done through its 2017 airspace consultation and we recommend that the Government, in coordination with the Civil Aviation Authority and NATS, develop a clear approach as soon as possible. (Paragraph 81) Airports National Policy Statement 9
24. We recommend that the Government act immediately to identify, develop and implement the necessary policies needed to provide confidence that issues, such as airspace, air quality, surface access and noise, will be dealt with in a timely manner in anticipation of a development consent order being made. (Paragraph 82)
25. We recommend that the Government, in the immediate period after an NPS is designated, launch a specific policy consultation, looking at the best ways to maximise existing airport capacity across the whole of the UK. It may be prudent for the Government to consider how issues of air quality and surface access for other UK airports can be addressed in this broader strategy. (Paragraph 83)