Our response to the Consultation on Revised Draft Airports National Policy Statement.

A joint response from the ‘Colnbrook Community Association’ and the ‘Slough and District Against Runway Expansion’ groups to the Consultation on Revised Draft Airports National Policy Statement



This consultation on a ‘national’ policy statement is largely viewed as being all about Heathrow as the current Government appears hell bent on seeing our bad neighbour as the future of aviation in the UK to the exclusion of our superb and underutilised provincial airports.


1. Do you have any comments on the revised draft Airports NPS or any of the documents set out in the table at pages 7 and 8 of the further consultation document?

Question 1 (about whether revised passenger demand forecasts and air quality assessments are complete and accurate)

Passenger forecasts

NO. Heathrow is notorious for painting a good picture to suit its case irrespective of facts and whether its models are suitable. The use of Carbon Traded Global Growth models is simply wrong. Carbon Trading merely pushes the can down the road and makes others responsible for the wrongdoings of the aviation industry.

Aviation emissions of greenhouse gasses have doubled since 1990, while other polluters have reduced their emissions by 30%. Aviation emissions will affect our children and grandchildren due to the long-lasting nature of the gasses. Along with severe weather events leading to increased incidences of flooding in local communities around Heathrow (Colnbrook, Wraysbury, Horton and Datchet in particular), we conclude that airport expansion at Heathrow must stop – for ever.

The UK emission targets seen to be woefully underestimated. Any further expansion at Heathrow will lead to contraction at regional airports; going against the general economic policy of adding activity to the regions.

One third of Heathrow’s passengers contribute very little to the UK economy, but the very nature of simply catching transfer flights. If these flights were transferred around the UK we would utilise spare capacity in the regions, reduce noise and air pollution around the airport and not add an extra 200,000 Londoners, including 43,200 children, to those exposed to harmful noise pollution.


Air Quality

NO – we quote Keith Taylor MP; -

“the Government estimates that 86% of the toxic air in the surrounding area is related to Heathrow flights and traffic – an increase from its previous estimate of just over 70%. At the same time, Nitrogen dioxide levels have risen at nine out of 12 monitors in west London within a 2km radius of the airport between 2015 and 2016. While sites in Hillingdon and Hayes already breach EU limits. Despite this and the clear warning from the Government’s own advisers that a third runway will see even more sites exceed EU air pollution limits, the Government still maintains that its feeble air quality plan – over which it is facing another legal challenge – will sufficiently bring down pollution levels across the country to allow Heathrow to pump out even more toxic fumes. It’s magical thinking, but, even if it wasn’t, the argument is a complete nonsense that assumes the only motivation for reducing air pollution elsewhere in the region is to allow the airport to pump more toxic air into our atmosphere.”


We also quote Teddington Action Group on Heathrow on Heathrow’s reputation for “laughable” promises; -

“Nearly 10,000 Londoners die each year from polluted air and London’s population is expected to grow to 11 million by 2050 which will increase traffic and air pollution. Heathrow’s public pledge that it can add another quarter of a million planes a year without increasing airport traffic is laughable, particularly as it makes so much money from parking – up again to £58 million in car parking revenue for the first 6 months of this year. Currently around 19 million (40%) of Heathrow passengers use public transport and if the airport is to increase this to 45% by 2019, that will add well over 2 million passengers a year to an already overcrowded transport system. We must not forget that Heathrow also plan to double freight to 3 million tonnes by 2040 much of it going back and forward on local roads, as well as local motorways M25, M3, M4 and M1, which are already full. Many current transport improvements were planned to cope with population growth rather than airport expansion and surface access is a major contributor to airport related pollution – yet there is no agreement about the costs between the Government, Transport for London and local authorities.”


The Health Impact Analysis stated that a third runway at Heathrow would result in increased noise, increased air pollution from aircraft and road traffic, poor air quality and a threat to housing conditions could increase respiratory disease and depression. It is not acceptable that a looming national disaster is passed to a few local authorities to deal with as the DfT has recently done. Air Quality knows no boundaries it is a nation-wide problem deserving of a national answer. Local Air Quality Zones will not solve the problem and the dubious projections arising from this recent change in policy must not be used to obscure the facts; Heathrow Airport cannot be expanded without damaging the health of local community members, costing the NHS untold £billions; costing the economy untold £billions in lost productivity due to workers pollution related illnesses; and the lifelong cost of children’s illness due to such pollutions.



Question 2 (Whether changes to NPS based on clarity/intention and or Government Policy since Feb 2017 are suitable)


The impact of noise.

This is a very difficult area to address. The Government, NATS and the CAA have all refused to disclose where the new flight paths will be; what the concentration of flight will be; what daytime respite will exist, and to confirm that a night time ban on ALL flights for eight hours will be implemented.

A lot of recent research details the mental health and physical health impacts of aviation and road transport noise on populations, which is very sadly not being honestly addressed by the Government or the aviation industry. Human beings need an average of 8 hours of uninterrupted sleep per night to perform effectively and have a good quality of life – this is not accounted for by Government or the aviation industry in any way, but is a ‘must do’ for any strong and caring legislator that truly values its citizens.


Dense Population

Heathrow Airport currently affects more people with its own related noise pollution than the next three largest airports in Europe; with just two runways. Adding a third runway would be an inhuman act of such proportion that third world nations will feel free to ignore any United Nation regulations on a ‘Right to a Quality of Life’.  Freedom from excessive air and noise pollution is a fundamental human right which obliges the UK government to pass an Act of Parliament to forever ban any future expansion at this most antisocial of UK airports.

We must quote Teddington Action Group again as there is no better way to express our views; -

“TAG views Heathrow’s noise mitigation plans with scepticism and we already object to the way Government measures noise (by averaging it out over a 16-hour ‘day’ period and where the reported level is suppressed using quiet periods when areas are not overflown to hide the real impacts when they are), disguising the true numbers affected. Heathrow proposes compensation of up to £3000 for acoustic/noise insulation for residential property from 55 to 60 dB LAeq (16hr) contour but many thousands will fall below 55dB and not be eligible at all.”


Job promises

The communities around Heathrow have; -

-          amongst the lowest levels of unemployment in the UK;

-          lack of land for new housing

-          lack of land for new schools

-          lack of land for new medical facilities

-          high housing cost, whether buying or renting

-          a ‘full’ road network

-          a ‘full’ rail network

-          a greater risk of flooding due to global warming

-          amongst the largest housing waiting lists in London / SE England


The West of London, Slough, East Berkshire, South Bucks and Surrey simply cannot support the job numbers ‘promised’ by Heathrow Airport.


Unfounded economic benefits

Again, we must concur with the TAG statement; -

“The economic benefits, originally mooted as £211billion by Heathrow’s PR, were revised downwards to £61 billion by the Airports Commission. However, the total net benefit for 3rd runway, to the UK over 60 years, was just £1.4 billion in the carbon capped scenario. The figure has now been bumped up to £74 billion (with carbon trading) for Heathrow 3rd runway and £75 billion for Gatwick 2nd runway, after the revised passenger forecasts. Now the NPS predictions for the Heathrow scheme (i.e. after costs are accounted for) are between minus £2.2 billion to plus £3.3 billion – so either a LOSS of £0.57 per head of population or a gain of just £0.87, over 60 years. Not even enough for masks and earplugs.”

Heathrow Airport, under its various ownerships, has been always been disingenuous with its claims, forecasts and promises.  It is not a ‘Good Neighbour’ and always deigns to coerce residents by using PR people or ‘consultants’ to achieve its objectives without allowing residents access to the people that will design, quantify and engineer its projects. We have absolutely no faith in Heathrow’s promises, projections, designs etc as it refuses access to the real people that are responsible for these functions; it simply uses PR people who cannot answer questions or explain our questions. ‘Bull shite baffles brains’ is there guiding principle and residents groups have long seen through that scenario; we need open and honest engagement in order to restore a long broken relationship.


Infrastructure costs

In order to cross the M25, Heathrow has suggested: -

-          a tunnel

-          a bridge

-          a ski slope

We do wonder what comes next. The process is becoming bizarre as they switch to low cost alternatives in order to save on their own costs whilst totally ignoring the potential costs to the taxpayer.

Terminal 6 already exists in the form of the British Airways headquarters; two underground stations exist along the A4 Bath Road (all built at the same time as terminal 5) so are Heathrow now going to benefit from previous expenditure by the taxpayer, for they will use it if at all possible.

There is no land availability to fulfil Heathrow expansion promises, either those by Heathrow itself; the Davis Commission or the Government. The strategy to expand Heathrow is totally flawed and cannot be delivered. The land on which Heathrow propose to build the “North–West” runway option is highly contaminated due to 18 old infill sites containing all sorts of material that would not be allowed in any infill site today. The site is also a “Strategic Gap” between Slough and London deemed to be of such importance that the ‘Slough International Freight Exchange’ project proposed for the same site was rejected by the Planning Inspectorate and upheld upon appeal after being opposed by Slough Borough Council. It should be noted that just this week contractors were on site undertaking test bores to ascertain the level of contamination, accompanied by security guards who intimidated residents using the public footpaths crossing the proposed site.

We have recently been informed that the Western Rail Link cost estimates have been increased from £600 million to £1.2 billion due to the scale of contamination and difficulty building on a sand based sub structure on the same site. It is unlikely to proceed.


Other matters for consideration; -

-          There is excess capacity in the South East of England’s five airports to cater for aviation growth over the next 50 years

-          The provinces, in accordance with recent government policies, need new infrastructure and international connections in order to stimulate growth. The south east is full.

-          Due to the use of PR Consultants and the sheer factual inaccuracy of Heathrow’s claims they could be guilty of ‘Wilful Blindness’, and or ‘Recklessness’; ‘and or Wilful Violation’ and or ‘Vincible Ignorance’; or of condoning and encouraging such individual or joint acts.

-          The health and wellbeing of residents is paramount to ensuring mental health, physical health, and longevity for all citizens; Heathrow does not offer that in any of its plans.

-          Eight hours sleep per night is good for our economy. (W.H.O)

-          Davies Commission stated that a third runway would increase the risk of a serious aviation incident by 13% – any such increase is unacceptable over such a highly populated area.

-          Terrorism, the greatest threat we face in today’s world, has not been mentioned in any Heathrow consultation. How will Heathrow provide for this possibility during the construction period?


“There have been so many wildly varying predictions for both benefits and mitigation that there is little public trust in many of the modelled statistics which seem to alter according to the required conclusion.”  

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