Adding Capacity at Heathrow Airport

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					      Adding Capacity at Heathrow Airport


                                                      West London


Response to Government Consultation by West London
                Friends of the Earth

                                           Contents


   1. Introduction

   2. Executive summary

   3. Consultation process, document and questions

   4. Noise

   5. Air pollution

   6. Climate change

   7. Public safety

   8. Surface access

   9. Biodiversity

   10. Economics

   11. Summary and conclusions

   Appendices 1 to 7 (climate change)


27th Feb 2008

Contact: 020 8357 8426; nic@wlfoet5.demon.co.uk

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                                      1. Introduction

West London Friends of the Earth (WLFOE) is a network of local Friends of the Earth (FOE)
groups, comprising Brent, Ealing, Kensington, Chelsea & Westminster, Harrow, Hillingdon,
Hounslow, Kingston and Richmond & Twickenham groups. The network was set up to address
issues which have impacts across several boroughs in West London, such as Heathrow.

Evidence on specific issues affecting particular areas is being submitted by a large number of local
people and organisations. WLFOE does not feel the need to elaborate on these, but we fully
endorse their concerns. We believe that quality of life is crucial and that protection of the
environment is critical to that aim. We reject the implication, which runs throughout the
consultation and the pro-expansion campaign, that our environment and our quality of life should be
sacrificed for economic benefits. In any case, we are totally unconvinced by the economic
arguments, as is almost everyone else who has studied the matter.

This submission concentrates on the broader aspects of noise, air pollution and other impacts,
affecting West London, west of London and beyond. Although economics is critical, we do not
address this issue in detail because it is covered by the national FOE response.

A number of abbreviations are used in the response:
CD    consultation document
CO2 carbon dioxide
dB    decibel (sound level)
FOE Friends of the Earth
GHG Greenhouse gases
MM mixed mode
Mt    megatonnes (million tonnes)
NO2 nitrogen dioxide
NOx nitrogen oxides – NO2 and/or NO
R3    Runway 3
RF    Radiative forcing
RFI Radiative forcing index
WLFOE West London Friends of the Earth




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                                  2. Executive Summary
1. West London Friends of the Earth position

West London Friends of the Earth (WLFOE) strongly opposes the further expansion of Heathrow
and in particular, the introduction of mixed mode and the building of a third runway and sixth
terminal.

2. Consultation process, document and questions

WLFOE has great concerns about the nature of the consultation, the partial nature of the
information presented and the questions posed. We believe that the consultation was designed in
this way to minimise opposition to expansion or at least to enable the government to interpret the
answers in a manner favourable to its policy of Heathrow expansion.

3. Noise

1. The direct consultation unfairly excluded many people who are already affected noise or who
would be.
2. The single noise condition (16-hour 57dB contour) is completely inadequate.
3. Leq is an inappropriate metric for assessing noise around Heathrow.
4. A 57dB threshold seriously under-states the area or population affected. About 4 times as many
people would be enclosed within a 50dB contour as a 57dB one.
5. The base year of 2002 is inappropriate.
6. There should be a policy of improving the noise climate, not increasing flights and thereby
negating potential improvements.
7. No recognition is given to the significant effects of aircraft noise on children‟s learning.
8. No recognition is given to the health impacts of aircraft noise, including deaths.
9. Figures for the economic cost of noise used by the government are absurdly low. The real figure
could be 14 times or more higher.
10. It is unsatisfactory for a consultation to be based on “indicative” flight paths.

4. Air pollution

1. There has been insufficient time to evaluate the conclusions on air pollution.
2. Air pollution is major health and environmental issue and Heathrow is a major polluter. But the
impacts have been ignored.
3. EU limits are not the only consideration
4. The objective should be to reduce air pollution, not just remain within EU limits.
5. A considerable number of properties are forecast to be very close to the EU limit for NO2.
6. Air pollution estimates can never be accurate and full sensitivity tests have not been not been
done.
7. Given 5 and 6 above, the government cannot be “confident” about meeting EU limits.
8. Optimistic assumptions have been made about how aircraft and road vehicles will become
cleaner.
9. No control mechanisms are proposed to ensure that air pollution does stay within limits.
10. The government appears to be planning to use EU „derogation‟, which is a gross misuse of the
facility.
11. Consideration should be given to areas well away from Heathrow where relatively
proportionately small effects add to a big societal impact.
12. The economic cost of air pollution has been ignored.


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5. Climate change

Climate change is the most important issue on earth. Climate change is of great relevance to
aviation because aviation already contributes some 10% of the UK‟s greenhouse gases (GHG)
emissions and it is a very rapidly rising source. Scientists agree that 80% cuts in emissions are
needed by 2050 to avoid the worst effects of climate change.

Emissions from Heathrow represent nearly half of the UK‟s aviation emissions. An increase in
capacity and emissions of nearly 50%, as proposed by the government, is thus of great significance
in the context of climate change. It is reprehensible that the CD says virtually nothing about climate
change itself.

The DfT estimates that by 2050, aviation will contribute 20% of total UK CO2 emissions and 29%
of GCG emissions. These assume cuts of 60% in emissions compared with a 1990 baseline. FOE
considers there are 3 major flaws in the DfT calculations:
a) The 2050 aviation emissions imply a complete about-face in government policy in which „predict
and provide‟ is abandoned and no new capacity is added after 2030.
b) The target 60% cut is only applied to emissions other than international aviation and shipping
c) There are no calculations on the basis of 80% cuts.

FOE has re-calculate aviation‟s proportion of UK emissions, correcting for a,b and c above. The
result is that by 2050, aviation will contribute 51% of total UK CO2 emissions and 87% of GCG
emissions.

If emissions are apportioned according to the proportion of UK passengers instead of a 50%/50%
split between the UK and distant country, the figures are 79% of UK CO2 emissions and 122% of
GCG emissions.

Heathrow accounts for nearly half of the UK‟s aviation emissions. By 2050 it would account for
some 17% of the UK‟s total allowed CO2 emissions if just a third runway was added, but if it were
expanded to meet probable demand the figure would increase to about 27%. For all GHGs, the
figures are 28% and 42% of the total UK‟s allowed emissions.

These are very large figures and they show that it would be impossible for the UK to meet its
climate change commitments. An urgent change in UK aviation policy is therefore needed.

The EU „Emissions Trading System‟, while it may have role to play, cannot address the problems
raised by the rate of aviation growth forecast by the government and supported by its policies.

The Climate Bill does not recognise the issue because it omits international aviation from its targets.

6. Public safety (danger)

There is no substantive mention of public or third-party safely in the consultation. Heathrow is
already by far the most dangerous airport in the country in terms of total or „societal‟ risk.
Expansion would increase that risk, very approximately by 50%. It is reprehensible that this issue is
not covered in the consultation and no comment is invited from the public.

7. Surface Access

There are no plans for new railways and only a slight increase in modal share of public transport is
expected. This will lead to increased traffic and congestion. There is no coherent, sustainable plan

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for surface access. The issue is not covered properly in the consultation and no comment is invited
from the public.

8. Wildlife, habitats and biodiversity

Loss of biodiversity is the second greatest environmental issue, after climate change. Nothing of
substance is said in the CD or associated documents. Runway 3 would destroy part of
Harmondsworth Moor, which contains public open space and has considerable wildlife value.

9. Economics

Almost the entire justification for expansion of Heathrow is the claimed economic benefits. We are
totally unconvinced by the government‟s calculations which have major errors and omissions.
National FOE covers the issue in its response.

The claimed Net Present Value – over 70 years – is miniscule compared with other relevant
economic figures.

The „wider economic benefits‟ have not been demonstrated in any way. The consultation uses
unsubstantiated assertions, spurious facts, false logic and „facts‟ from the aviation‟s industry‟s
consultants to try and convince the reader.




                                                   5
               3. Consultation process, document and questions
3.1 Introduction

WLFOE has great concerns about the nature of the consultation, the partial nature of the
information presented, issues omitted and the questions posed. We believe that the consultation
was designed in this way to minimise opposition to expansion or at least to enable the government
to interpret the answers in a manner favourable to its policy of Heathrow expansion. The specific
issues are described in 2.1-7 below.

3.2 Key issues omitted from consultation

A number of key issues were omitted or were barely addressed in the consultation
    Climate change
    Public safety
    Public health
    Biodiversity
    The nature and reasons for demand at Heathrow
    Demand for a 4th runway and 7th terminal
These matters are considered in subsequent sections of this response.

3.3 Consultees selected too narrowly

The consultation was drawn too narrowly. Only those households which currently suffer 57dB leq
or just below were consulted directly, ie by post. There is unequivocal evidence that people are
affected by in areas with an leq much less than 57dB.

Many people will be affected by the air pollution, traffic, development pressures, etc even if they
are not within particular noise contours. They should be consulted.

Boroughs significantly affected by Heathrow, such as Ealing, were not given a DfT exhibition and
the DfT refused to attend public meetings.

3.4 Main consultation document (CD) dense and difficult to understand.

We recognise that the issue is complicated and that simplifying the issues such that the public can
understand and comment is a challenge. Nonetheless, there are some basic shortcomings.

For a detailed document of over 200 pages, the contents page is inadequate and there is no indexing.
For example, App B occupies over 80 pages and covers a wide range of issues and several options.
It is unreasonable to expect people to have to search 80 pages to find a section on, say, heritage or
on Option 2.

Unlike most „pdf‟ documents, the consultation document could not be searched and text could not
be extracted. This makes finding material of interest more difficult and makes responses more
time-consuming.

3.5 Questionnaire does not ask the basic questions

The most important of such questions would be “ .. do you support the removal of Mixed Mode”
(MM) and “do you support the building of a third runway” (R3).


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We are aware that the government is entitled to consult on whatever it wants and ask what questions
it wants. We are also aware that the government could argue that it has already consulted on the
principle of Heathrow expansion in the aviation White Paper. However, we do not consider there
are adequate reasons.

A large number of people responding are opposed to MM and R3. They should have the
opportunity to say so. If they are not given the opportunity, it engenders a feeling of mistrust and
alienation. The words “charade” and “done deal” are commonly heard. It engenders cynical, but
justifiable, comments about the planning, consultation and democratic systems. For example “Your
new terminal goes here. What colour would you like the departure gates?”

Another vital area is on economics. The main argument used by the government for expanding
Heathrow is the claimed economic benefits. There are many statements about these in the main text
and further statements and quantitative work in Annex B. Yet despite the evident importance of
these, no questions are asked or comment invited.

The approach on economics appears to be make a series of unproven, unreferenced and
questionable assertions about the economic benefits. Points which might cast doubt on the benefits
or the scale of them are excluded, the huge areas of uncertainly are not mentioned and comment is
not invited. It adds up to what is colloquially called a „stitch up‟.

It might be argued by the government that the economic issues are complex and it would therefore
be difficult for the public to make comment. We would not accept this for the following reasons.

Firstly, many of the public are sophisticated and can understand the arguments. Most certainly their
representatives in councils, NGOs etc can understand the arguments and respond.

Secondly, the consultation asks questions such as whether the respondents believe the air pollution
limits can be met. But air pollution analysis is at least as complex and technical as economics.

Finally, this document is a consultation. If the subject is not being consulted upon, it should not be
discussed (in any detail). The assertions about economic benefits without invitation to comment
make the document look like a lobbying or PR document as opposed to a genuine consultation.

3.6 Questions in the main consultation document difficult to answer or ‘leading’

Q1 (Terminal 6)
Insufficient information is given as to why a further terminal (T6) is needed. It is widely known
that T5 is far large than necessary to handle passengers from R1 and R2. Indeed, it has been called
“a great shopping mall”. A cogent argument is needed as to whether the space in T1-5 can or
cannot be used more effectively before building T6 needs to be presented.

Q3 (can air quality limits be met with R3 ?)
This is almost impossible for respondents to answer in an informed manner. Air pollution
forecasting is a complex and technical subject. The calculations were carried out behind closed
doors by the government and BAA – other parties were denied access. The results were not
published until the consultation was published, giving consultees just 14 weeks to analyse. This
makes it almost impossible for them to reach a fully informed and considered view.

The ability to go ahead with MM/R3 hinges on air pollution. The process of estimation should
therefore be undertaken with the utmost transparency. There should have been a rigorous peer-
review process which the public would be able to see (as there was with first stage of the work on

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methodology). There should also have been a guide to the issues to enable the non-technical reader
and readers who not have days to spare studying air pollution to understand the key results, issues
and uncertainties. These would have enabled the public to answer the question meaningfully

Q4 (can noise condition be met with R3 ?)
This is almost impossible for respondents to answer in an informed manner. Sound level forecasting
is a complex and technical subject. The calculations were carried out behind closed doors by the
government and BAA – we understand that other parties were denied access. The results were not
published until the consultation was published, giving consultees just 14 weeks to analyse complex
technical information. This makes it almost impossible for them to reach a fully informed and
considered view.

Q5 (can noise condition be met with MM ?)
Same comments as Q4

Q7 (can noise condition be met with MM ?)
Same comments as Q3

3.7 Questions in summary consultation leading or impossible to answer properly

Question A3
 “To what extent do you agree or disagree that the environmental conditions are still appropriate
for the revised BAA proposal for a 2,200m runway”

The question states and the responses allowed range from “Strongly agree” to “strongly disagree”.
On the surface this appears to be normal, however closer inspection shows that there is significant
ambiguity here. For example, what is “Strongly disagree” actually supposed to mean? Many
residents may strongly disagree because they believe that the environmental conditions are wholly
inadequate and need strengthening, whereas an airline might strongly disagree because they felt that
the environmental conditions were too harsh. So, respondents with diametrically opposed views
would end up ticking the same box! As there is no facility on the form to state why the respondent
gave that view, there is no meaningful information that can be inferred from the answer given.
Therefore the DfT is able to interpret any “disagree” or “strongly disagree” in any way it chooses,
which makes the question invalid.

Question A4
See comments on Q1

Question A6
See comments on Q3

Question A7
See comments on Q4

Question B6
There are two questions here but only one tick is allowed. One question relates to what is a
worthwhile increase and the other to air pollution.

See also comments on Q3.

3.8 Misleading and partial statements in the consultation document


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There CD is full of partial and misleading statements, clearly designed to elicit support for, or
acquiesence to, Heathrow expansion. A selection, taken from just the first 48 pages (plus one in
Annex B), is given here. References to the item are to paragraph numbers or section titles in the
CD.

Introduction chapter

2. “Heathrow is crucially important to the UK, as our premier international airport.”
No evidence is given for this assertion.

3 “ .. given the economic benefits .. ”
Not demonstrated in the White Paper

Executive summary

Background, para 1. “ .. given the strong economic benefits .. ”
Not demonstrated in the White Paper

Background, para 4. “ .. revised proposal for adding a third runway .. 2,200 operational length
compared with the original length .. “
Although a correct statement, it misleads because the total length, including the non-operational
part has gone up to 2,500m (only explained many pages later). This real increase, reflecting land-
take, has therefore gone up by 25% ( {2500 - 2000 / 2000} x 100 ), not 10% ( {2200 - 2000 /
2000} x 100 ). This misleading impression is repeated in Q4 (page 114).

Chapter 1, para 1.
This is an attempt to associate in the public mind factors that are not correlated. The assertion about
the important contribution of aviation to the UK economy may be correct, but it simply does not
follow that the number of routes has any significance in this context. London has done rather well
compared with many cities; meanwhile Heathrow‟s routes have declined while other have
increased. Taken to its logical conclusion, we should get rid of all Heathrow‟s routes!

Chapter 1, para 7. “ .. with no additional environmental benefit.” It is manifestly untrue to say that
more constraints on aviation would not give more environmental benefits than less constraints. We
have not checked if Eddington actually said it, but even if he did, that is no excuse to make untrue
statements in a consultation document.

1.1.
This contains unproven assertions and „hype‟.

1.2 “ Schiphol .. has 5 runways .. ”
This is a totally misleading comparison. Schiphol‟s runways cannot all be used together – the 5th
runway was built to reduce noise impacts, not to increase capacity.

1.2 “ 70% of foreign companies‟ first location is Britain is within one hour of Heathrow. This may
be true, but is irrelevant. 70% of businesses locate within one hour of the Tower of London, but
that does not show that we need to expand it!

1.2 “.. hub airport .. damaging UK interests .. more widely across the economy . “
This is false logic. If aviation is important to business in the UK, it can only be for business
travellers wishing to travel to or from the UK, especially London. A hub airport specifically caters
for passengers changing planes, ie not visiting Britain and so not contributing to its economy.

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(Some travellers may wish to travel on from Heathrow to other destinations in the UK. But they
would better travel direct to, say, Manchester, or get a get a high-speed train.)

1.10
It is not “lack of capacity” per se that causes these problems. It is the business decision of BAA to
run more flights than it can reliably cope with that causes delays, threat to reputation, more fuel
burn and associated emissions.

1.15, etc
Throughout the document the expression “air quality” is used. This is a euphemism, intended to
play down the issue, which is “air pollution”.

Chapter 3

3.34 “ .. We believe that decisions on Heathrow should be based on the best evidence ..”
The best evidence is from studies from around the world in the last 20 years, accepted by the WHO
and others, which show that people are significantly affected by noise levels below 57dB leq. This
was confirmed by the government‟s own ANASE study. The fact that the government is ignoring
all this and using the 20 year old ANIS study shows clearly that the government is not using “best
evidence”. Instead, it is selecting „evidence‟ in order to claim the minimum impacts of noise.

3.33 “ the valuations coming from the study are not reliable and specifically counselled against
using the detailed results ..”
This is extremely misleading because this caveat was about valuations or economic cost, not about
annoyance per se, which is what is discussed in 3.33.

3.41 “ .. sustainable development. The need to strike a balance ..”
The government‟s policy on sustainable development is that we need to achieve economic growth
and protect the environment simultaneously. It is not about trading off the environment for
economic benefit or “balance” as it is euphemistically called.

Annex B

2.52 ” With 90 of businesses in the SE rating Heathrow as either vital or very important to their
business ..”
This is grossly misleading. This statement is based on a survey carried out by Oxford Economic
Forecasting (OEF), paid for mainly by the aviation industry. Only a very small fraction of firms
around Heathrow were consulted and only a very small fraction of those responded. The 90%
figure therefore derives from a meaningless OEF-selected and self-selected sample.




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                                             4.   Noise

4.1 Introduction

FOE does not find that all the questions are chosen or framed in a manner that facilitates responses
on the issue of noise. We therefore give structure our response is a way that is most convenient.
However, 3.14 addresses briefly each of the noise questions and refers, as appropriate, to other
paras.

4.2 The consultation

We consider the range of people consulted was unfairly limited. People were only consulted
directly, by means of documents in letter boxes, in areas where the noise is 57dB or just over. As
explained below, 57dB is palpably not the cut-off for noise nuisance - people within the 50DB
contour, and perhaps some outside, should have been consulted.

4.3 Wrong environmental measures and conditions

FOE considers that the environment conditions presented in the consultation are fundamentally
flawed. The 57dB contour does not in any way include all or most of the people who are
significantly affected by aircraft noise and those who would be significantly affected with Mixed
Mode or a 3rd runway (MM/R3). It is doubtful if a single simple metric such as 16-hour Leq
averaged over a season can be an adequate measure on which to base a decision affecting so many
lives. But if a single measure is to be used, a contour for 57dB 16-hour Leq averaged over a season
is palpably not the best. The flaws in the use of this measure are described in 4.5-9.

The whole principle underlying the condition is wrong. Noise is already a serious issue which
affect people lives and also health (see 4.11). A primary objective should therefore be to improve
the noise situation. But the thrust of the approach is to use any potential improvements from quieter
aircraft or re-aligning flights as an opportunity to increase flights and therefore restore noise.

We note that 2.17 of the consultation document states that the addition of a third runway might
provide the opportunity to increase movements in the night period (although a decision on this
would be a separate exercise nearer to the 2012 when the restrictions cans be amended. The
Government said it would “bear down on night noise”, a commitment included in the 2003 White
Paper, but this expansion is seen as opportunity to do exactly the opposite. The one and only noise
condition refers to day noise, so there is no constraint whatever on increasing night noise.

4.4 Flaws in the Leq measure

The statistic used by the government for assessing exposure of residents to aircraft noise is called
„Loudness Equivalent‟ or Leq. This takes the sound energy from each aircraft in „decibels‟ or dB.
The sound is averaged over a „day‟ of 16 hours and over a whole season. Based on the official
noise output of each aircraft type and historical data on aircraft movements and flight paths, the Leq
is calculated for a wide area around Heathrow. The results are shown by means of „noise contour
maps‟.

The only noise condition proposed by the government refers to a 57dB contour and the area
enclosed within. A single 57db contour is demonstrably not an adequate means of assessing noise
exposure and acceptability and is therefore not a satisfactory basis for environmental conditions for
MM/R3.

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While the 16-hour Leq is a commonly used metric, and one that is accepted by the EU, it has the
major shortcoming that, like any single metric, it cannot represent the complexity of noise and its
impacts on people. In this context of Heathrow there are several reasons why this is particularly
significant.

Leq is an average of the noise energy of a number of aircraft averaged over a period. However,
perception of noise is not closely related to noise energy. An increase of 3dB means doubling of
the noise energy, but the ear only hears a very slight difference. (The response is roughly
„logarithmic‟.) Two aircraft with a particular noise level have the same average noise energy as one
aircraft which is 3dB noisier. But the human ear hears twice as many aircraft which each sound
nearly as loud. Thus the disturbance or annoyance is far greater with two aircraft. This was
confirmed by the ANASE study (see below), which indicated that a metric related to NNI (Noise
Number Index) was a better predictor of annoyance than Leq. The upshot of this is that more
aircraft annoy more, even when the Leq is unchanged.

The proposal for MM/R3 increase the number of flights and therefore noise annoyance is likely to
increase, even though there may be no or little increase in Leq.

Another reason why Leq is an inadequate measure is the averaging period. The government
calculates contours by averaging noise over a whole day and over a whole season.

With the current system of runway alternation, aircraft fly overhead most people for half a day and
for the other half of the day there is relative quiet. If planes fly over for half a day and the average
over that half day is, say, 59dB, people will be annoyed because the noise level is over the 57dB
that has been show to cause annoyance. But if planes do not fly overhead for the other half of the
day, the average over the whole day is only 56dB. Being below 57dB, it can be claimed people are
not affected – which is obviously not correct.

A common sense approach would be say that people are half as much affected or half as much
annoyed by the pattern of noise lasting half the day corresponding to 59dB over that half day as
they would be affected by the same pattern of noise lasting all day and corresponding to 59dB over
the whole day. A more sophisticated relationship could probably be established with a modest
amount of research.

It is well known that residents affected by aircraft noise plan their day around Heathrow. Some
choose the timing of their barbecue for before or after 3pm so that they can have it free from aircraft
noise. Others will go to Kew Gardens or choose the time to sit in their own garden with reference
to runway alternation. By this means, residents are able to ameliorate the impacts of noise. With
Mixed Mode, amelioration will be impossible and it may therefore be the case that the annoyance
due to a full day of noise is more than double annoyance due to half a day.

A similar effect occurs by averaging over seasons. Flight paths alter according to the direction of
the wind. People may therefore be overflown with, say, easterlies but not westerlies. The noise
level on days with easterlies could be 60dB, which is clearly annoying. But when averaged with all
the days of westerlies, which occur about 70% of the time, the average is about 55dB. Being below
57dB, it is claimed – and when not claimed, implied by the use of a 57dB contour – that people are
not affected. This is obviously not valid.

A particular issue with easterlies v westerlies is that easterly wind usually occurs in fine weather
when people want to be out of doors, for example on a sunny summer afternoon. The people under
an easterly take-off path are thus more affected than the 30% occurrence might suggest. More

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people are overflown by the easterly paths because the population is much denser over West
London ie east of Heathrow than the area west of Heathrow.

4.5 Flaws in using 57dB as a threshold

Setting aside the problems that Leq does not take proper account of the numbers of planes or the
averaging over days and seasons, there remains a fundamental issue.

The 57dB figure was decided upon following an study published 23 years ago called ANIS. This
was interpreted by government to show that community annoyance generally becomes significant at
around 57dB. However there were flaws in the study and it was not peer-reviewed. More recent
work had led the World Health Organisation (WHO) to recognise 50dB as a realistic level for onset
of annoyance and 55dB for serious annoyance. In some cases, eg at night or in countryside, lower
levels of 45dB or even 40dB can be annoying. The EU has recognised 50dB and 55dB in its
legislation on noise mapping.

The ANASE study „Attitudes to noise from aviation sources in England‟ was a 6-year study set up
by the government and was finally published in Nov 2007. ANASE shows there is no sharp cut-off
level such that noise of less than that level figure does not annoy. However, the research indicated
that 50dB was a reasonable figure for onset of annoyance. This corresponds with what other
researchers internationally have concluded and the levels that EU and WHO recognise.

However, the government refuses to accept the 50dB figure or use it when discussing airport
expansion. It uses the lamest of excuses – that there is no sudden upturn in annoyance at 50dB or
cut-off below. This argument is untenable because there is no reason whatever to believe that there
should be some sudden threshold below which people are not annoyed and above which they are.
All the empirical evidence, backed up theoretical arguments and the real experience of people,
suggests that noise annoyance will rise very slowly per dB from low noise levels and will rise
gradually faster per dB at higher levels. That is, there is no real cut-off or sharp upturn. Indeed,
there was no sharp cut-off shown by the earlier ANIS study, so this argument provides no grounds
for staying with the 57dB figure.

4.6 The effect of using a 50dB threshold

Any meaningful and relevant method of measuring noise nuisance must include noise down to
50dB. The simplest method would be to draw a noise contour enclosing the area suffering over
50dB. The CAA has refused to calculate such a contour, but there is a broad-brush relationship
which enables the impact to be seen.

Examination of published contours show that the area enclosed by one contour is typically about 1.8
times higher than the area enclosed by a contour for an Leq 3dB higher. Therefore, by
extrapolating from 57dB, the area enclosed by 50dB contour will be about 3.9 times larger than the
57dB contour. (It should be noted that although the lowest noise level shown in the Heathrow
consultation is 57dB, the government has in other cases published a 54dB contour; this was used to
help derive the 1.8 per 3dB factor. Thus our estimate of the 50dB is not just our own extrapolation
from 57dB, but uses government data down to 54dB.)

If the area covered by a 50dB contour is 3.9 times the area of the 57dB contour, the areas „affected‟
by noise are correspondingly greater. The table below gives the areas in km2 of the 57dB contour
from the consultation document (Table 6 and 12) and the corresponding 50dB contour. Where
enclosed populations are given for the 57dB contour, these are shown in brackets (thousands) and
the population enclosed by the 50dB is calculated by pro-rata of the areas.

                                                 13
  Year                     Base case ie no MM/R3                           Option 3 ie MM + R3
          57dB                            50dB                  57dB                    50dB
2002      126.6                           493                   126.6                   494
2015      119.8 (261.9)                   467 (1020)            119.7 (248.1)           467 (968)
2020                                                            126.7 (242.3)           494 (945)
2030      77.0 (142.2)                   300 (555)              112.9 (205.7)           440 (802)

                          Table FOE/12 – Estimated population within 50DB contour

It can be seen that nearly a million people will be affected by aircraft noise, not around 200k as
claimed by the government.

This figure is in fact an under-estimate because of the averaging problem described in 4.4. People
exposed to over 50dB for some of the time but under 50dB when averaged over the whole time
would actually be affected. So many more people will be affected than these numbers indicate.

Inspection of these figures reveals the real reason for the government ignoring the results of the
ANASE study. It is nothing to do with the reasons given in 3.36-39 of the consultation document or
the shortcomings of the study, of which there are indisputably some. It is because use of ANASE
would high highlight the fact that far more people are affected by noise than the government wants
to admit. To admit it would make the argument against expansion even stronger.

4.7 Measuring impacts and setting conditions

We recognize that use of a 50dB contour alone would be an adequate measure of noise nuisance.
Noise at higher levels, eg 57dB is more annoying and recognition of this is needed when
determining impacts and setting conditions. Either multiple contours are needed as part of the
conditions or some form of weighing by noise is needed so that the populations exposed to more
noise have a higher weighting as part of an overall index of noise exposure.

4.8 The wrong base year

Setting aside the problems of the 57dB metric, the contour area of 127 km2 is not appropriate. This
is based on the 2002 contour area. Since then, thankfully, there has been some decline in noise, the
figures for 2005 and 2006 being 117.2 and 117.4 respectively. (DfT web site -
http://www.dft.gov.uk/pgr/aviation/environmentalissues/nec/secnoise06/pdfnoiseheath06). A
condition based on 127km2 is therefore an increase of about 8% over the current level. It is thus
allows an increase in noise when, as noted in 4.3, there ought to be a policy to improve people‟s
quality of life by reducing noise.

4.9 Noise policy

As noted in 4.3, for people living near Heathrow, the noise is already excessive and needs to be
reduced. Simply keeping to the same level of annoyance is would not be satisfactory – but instead
proposes to increase the noise annoyance. The reasons why noise nuisance would increase have
been described above; in summary they are:
   a) Leq does properly reflect the number of flights, which is increasing
   b) Averaging noise by Leq over the whole day hides the impact over the noisy half of the day
   c) Averaging by Leq over the whole season hides the impact over the noisy days
   d) 57dB is not a valid cut-off for noise nuisance
   e) Future noise should be compared with current noise, not an inflated 2002 figure.


                                                       14
4.10 Learning

Aircraft noise is normally regarded just as a nuisance, albeit one which can significantly impact on
leisure and quality of life. Bu there are further impacts.

A body of research in Britain and abroad shows that children who go to school under the flight path
have their learning significantly impeded. Notable is the „Ranch‟ study, which looked included
Heathrow. There is no cognisance of this or allowance when setting the noise condition.

There are no doubt adverse effects on concentration and learning in adults too, but no definitive
studies have been published.

4.11 Health impacts

A report was published in Feb 08 of a major 4-year study called Hyena (Hypertension and Exposure
to Noise near Airports), funded by the EC. The study shows what other studies have suggested,
namely that there are health effects due to noise.

The study showed that those living closest to airports were almost 50 per cent more likely to suffer
from hypertension, a known trigger for heart attacks, strokes, kidney disease and dementia. In
England, heart disease kills 110,000 people annually and the deaths linked to noise could be around
3,300. The proportion of these deaths attributable to aircraft noise has not been worked out, but is
unlikely to be negligible.

4.12 Economic cost of noise

Although there are understandable ethical objections to reducing noise nuisance to a monetary cost,
it is widely recognised that such a process, not just for noise but for other impacts, is useful in
formulating public policy. At best it helps with reducing noise but, failing that, it enables taxes,
charges and compensation to be evaluated.

Such costs are not actually monetary because there are no monetary transactions involved. They are
often called economic costs – because economics deals with valuations in monetary terms of human
welfare even where there is no financial transaction. These sorts of costs are more specifically
termed „external costs‟ because they are outside the realm of monetary transactions, ie outside the
„market‟. Such costs are part of a broad definition of „pollution‟ in the „polluter pays principle‟.

There are great difficulties in estimating economic costs for noise; however there is an extensive
literature on the subject.

The government has estimated costs using two sources (2.26 bullet 2):
    a) DfT „WebTAG‟ figures for road and rail noise
    b) Values from a study by Pearce and Pearce – „Setting environmental taxes for aircraft: a case
        study of the UK‟, 1999.
Using these, the government estimates that the economic cost of noise is between £214 million and
£331 million from 2015 to 2080, that is over 65 years (Option 3, para 2.87). Even allowing for the
fact that this is an increase due to MM/R3 and not the total noise cost and that annual costs are
„discounted‟ (reduced to present values by means of an interest or discount rate), the figures are
absurdly low. They imply that noise gives rise to very little nuisance which contradicts completely
academic research and everyday experience.



                                                 15
A major part of the ANASE study was devoted to assessing a cost of noise. This indicated costs far
higher than the studies used by the government here and indeed higher than other studies. It is
generally recognised by the reviewers and commentator that the results were so out of line with
earlier studies that it would not be safe to rely on them. However, that does not prove they were
wrong and there is no excuse for the government to pretend the results do not exist and not mention
them in the consultation.

A major reason for the low figures is revealed in 2.26 bullet 3: “only household exposed noise
changes above 57dB are included in this analysis.” As described, a much more justifiable cut-off
for noise impacts is 50dB instead of 57dB. The fact that 3.9 times as many people are affected will
mean that the costs will be higher when all the extra people are taken into account. But there is a
further factor. Because a cut-off of 57dB is taken instead, the cost for those people that are included
in the government‟s calculations is under-estimated. The Pearce and Pearce study used a formula
which gave a cost for every extra dB of noise. Thus a person exposed to 58dB would be considered
as having an economic cost of only 1dB (58 – 57), not 8 dB (58 – 50). The combination of these
two effects is obviously large. A study by the Aviation Environment Federation in 2000 indicated
the effect of using a 57dB cut-off instead of 50dB was to understate the cost no less than 14-fold.

The Hyena study showed that noise is a health risk, not just an annoyance. However, the
government‟s estimates of the cost of noise do not include health impacts. For example, the Pearce
and Pearce study is based on the depreciation of house prices and there is no reason to assume that
health issues are factored in to the assessment. (While people are aware of noise nuisance and will
therefore factor it in their valuations, they are not aware of health impacts.) Health costs should be
included in the cost of noise.

There is clear evidence that children‟s learning is impeded by aircraft noise. It is unlikely that this
factor has been taken account of in the government‟s estimates. If it has not been, the costs should
be included in the cost of noise.

The methods used and the absence of relevant information makes it obvious that the government
aims to minimise the apparent cost of noise and thereby maximise the claimed net economic
benefits.

4.13 Flight paths

Flight paths shown in the consultation are merely “indicative”. That is, they may not be the ones
that would actually arise due to expansion of Heathrow. The landing paths are fairly clear-cut,
being in line with the runways for several km. However, the take-off paths are anything but clear-
cut. There is no technical or operational reason why they could not be different from those shown
in the document. We do not consider that indicative paths are a proper basis for consultation,
especially where noise impacts are the ones that arouse the greatest local concern.

4.14 Answers to consultation questions

Question 2
The first part of Question 2 says “Do you agree or disagree with the government’s view on the
continuing validity of the environmental conditions? What are your reasons?” The second part says
“Are there significant considerations you believe should be taken into account? If so, what are
they?” FOE does not consider that existing environmental conditions on noise are valid.
Semantically, therefore, we cannot say that we agree or disagree with the “continuing validity” of
conditions. We disagree strongly that the current noise conditions form a valid basis for the future.
See 4.3-9 for a full explanation.

                                                   16
Question 3 (is R3 achievable within gov‟s noise limit ?)
As made clear in 4.3-9, we do not consider that the proposed condition gives people around
Heathrow the protection they deserve. The condition would allow noise impacts to increase
considerably instead of decreasing from the present unacceptably high levels. The following
comments are „without prejudice‟ to this position.

We consider that adding a third runway within the 127 km2 57dB contour limit is achievable in a
literal sense. However the government has made a set of rather optimistic assumptions about fleet
mix and there is considerable doubt as to whether the limit will be achieved in practice under a
„business as usual‟ approach.

If the government is serious about achieving the limit, it needs to spell out what it will do if
subsequent measurements and/or projections show the limits are not likely to be achieved. There
are basically 3 options:
a) introduce a scheme to ban the noisier planes sufficient to achieve the necessary reduction in
overall noise
b) introduce noise-related charges of sufficient strength to achieve the necessary reduction in
overall noise (ie not like the tokenistic measures in place now)
c) put a limit on flight numbers until the noise limit can be reached
To not do any of these, and to do not offer or plan to do any of these would be a breach of trust for a
community that already has little trust in government or over Heathrow.

Question 7 (is MM achievable within government‟s noise limit?)
Similar comments apply as in Question 6. However, the uncertainty about the fleet and thus noise
levels is less in the near future when this applies (up to 2020) than after runway 3 (2020 onwards).
The probability of the noise target being met would therefore appear to be greater. However, we
would still expect measures such a, b or c to be available for use. As before, our comments are
„without prejudice‟ to the position that we do not accept the condition as valid.

Question 8 (getting rid of westerly preference)
We do not presently have a view on this. .

Question 9 (getting rid of Cranford agreement)
We do not have a firm view on this. However, we reject the argument in favour of abolishing the
Cranford agreement that it would remove some people from the 57dB contour. We have explained
at some length that 57dB is not a valid cut-off and why the 57dB is not a valid basis for the noise
condition. It follows that removing people from the 57dB contour is not a worthwhile objective per
se. To the extent that their noise is decreased, it is of course a benefit. But rmoving people from
the 57dB contour by reducing their noise by a small amount, while increasing the noise of others
already in the contour, would probably give a net disbenefit to residents. Yet it would help to
achieve the condition. It would, to put it bluntly, be a „fiddle‟.

Question 10 (keep rotation of easterly and westerly preference at night ?)
We do not presently have a view on this.

Question 11 (should runway alternation be retained between 6 and 7am ?)
We have not studied this issue, but we think that this alternation is beneficial and should be
retained.




                                                  17
                                        5. Air pollution
5.1 Inadequate consultation time

The Government says in the consultation document that expansion via Mixed Mode (MM) and the
addition of a 3rd runway (R3) could occur without the EU limit values for on NO2 being breached.
Importantly, no special measures, eg a congestion charge around Heathrow or putting the M4 in a
tunnel, would be required. This is a major change form the government‟s position in the White
Paper, where it was intimated radical measures might be required. (Para 11.61: “…we cannot be
confident that air quality limits at Heathrow with the addition of a third runway will be met, even
with aggressive mitigation measures”.)

In the light of this major change, it is essential that time is allowed for detailed examination and
evaluation of the new evidence. This has not been given by the DfT.

The first part of the air pollution studies – agreeing methodology – was conducted in an open and
transparent manner and was peer-reviewed. The second part was not. It was carried out behind
closed doors by the DfT and BAA; FOE and local authorities (LAs) were refused access to the
work. FOE and LAs only had the opportunity to examine the work at the time that the consultation
document was released.

The air pollution studies were complex and technical with hundreds of pages of technical
documentation. FOE therefore had to rely on consultants appointed by Hillingdon and Hounslow
councils to review the technical documentation. It was unfair to allow them just 14 weeks to
undertake this task, given that DfT and BAA had taken about a year to produce the estimates.

We understand that:
    the consultants commissioned had to ask further questions of the DfT during the
       consultation process
    that in certain areas the information supplied was inadequate
    in the case of a surface access request, the information was denied
    a meeting was requested between the 2M technical experts and the DfT technical experts to
       expedite the appraisal process but this was refused by the DfT
These point to a policy of unhelpfulness from the DfT, compounding the short time allowed to
make a response.

5.2 Air pollution is a major issue

Air pollution is a major public health issue. A large number studies have pointed to morbidity and
mortality arising from air pollution. Some of these have addressed airports and concluded that
airports are dangerous to health, eg “Public health impacts of large airports
(http://www.aef.org.uk/downloads/PublicHealthImpactsSummary.pdf)

The health impacts of air pollution are not mentioned in the consultation. This is a major omission.
It is estimated by the GLA that about 1000 people in London die every year because of air
pollution. Heathrow airport is by far the biggest single source of air pollution in London, so it
follows that Heathrow is a major public health issue.

There has been no health impact assessment at this stage. It is hard to see how a policy decision of
this magnitude can be taken without such in its absence.



                                                   18
There are also effects other than those on human health, for example corrosion of buildings and
structures, soiling of materials, interference with agriculture, damage to vegetation and habitats and
local extinction of species. These may occur at concentrations well below the health-based
standards. NO2 can lead to acid rain and „eutrophication‟ of habitats. (Eutrophication is the addition
of nutrients to water or land. It is usually harmful, upsetting the balance of species and leading to
the elimination of some of them.)

Air pollution levels are already high near Heathrow. In some areas, EU limits, set to protect human
health are breached. In much larger areas, other standards are breached.

We note that the government insists on using the term “air quality”. This is euphemism, intended to
downplay the seriousness of the issue by subtle use of language. It may be observed that the
government does not use the word “quietness” when discussing noise.

5.3 EU limits not the only consideration

The government‟s case for proceeding with MM/R3 depends solely on meeting EU limit values.
The only considerations are the EU mandatory limits. All other limits and guidelines - eg
vegetation standards for NO2, standards for ozone and original health-based standards for NOx -
are ignored.

EU limits should not be the determining factor. The government‟s approach is an entirely
'legalistic' one. The UK has a „National Air Quality Strategy‟ (NAQS) and this policy, which
crucially involves „Action Plans‟, should be an important consideration. But the government
completely ignores its own Air Quality Strategy. Its only concern is to meet EU standards and,
more precisely, to avoid sanctions from the EU if it does breach those standards (FOE has been told
by the DfT that the latter has taken legal advice on the possibility of action by the EU).

Air pollution levels are already high near Heathrow. In some areas, EU limits, set to protect human
health are breached. In much larger areas, other standards are breached. A primary objective should
therefore be to reduce air pollution in order to protect human health and the environment. But the
thrust of the approach is to use any potential improvements from less polluting aircraft or road
vehicles as an opportunity to increase flights and therefore restore air pollution.

The comments in 4.4-9 are without prejudice to this position that EU limit values should not be the
only or the most important consideration.

5.4 Estimated air pollution very close to limits

The consultation document (2.29, 2.70, etc) indicates that there would be virtually no exceedences
in future years with R3 in operation. However, there are large numbers of properties close to the
EU limit value even as far ahead 2030. This is shown in Table 3.7 of the “Population Exposure to




                                                 19
Air Pollution Report”, Atkins 2007:
                                         2015 SM         2015 MM         2015 MMrd        2030 R3T6 H
     Contour band                      No Properties    No. Properties   No. Properties   No. Properties
     38-38.9                               126               144              116              115
     39-39.9                                75                93               21               21
     40-41.9                                22                27                0                0
     42-43.9                                 0                 0                0                0
     44-45.9                                 0                 0                0                0
     46-47.9                                 0                 0                0                0
     48-49.9                                 0                 0                0                0
     50-59.9                                 0                 0                0                0
     60-69.9                                 0                 0                0                0
     Total Exceeding EU Limit Value         22                27                0                0

May properties are exposed to levels just below the 40ug/m3, but hardly any above. This seems just
too convenient.

5.5 Air pollution estimates are not accurate

Estimate of air pollution are never totally accurate. Even current levels of air pollution, estimated
with computer modelling techniques, do not always accurately reflect the actual measured pollution.
Estimates of future, incorporating projections of emissions sources and other assumptions are even
less reliable.

There is considerable uncertainty about the emissions of vehicles and it dangerous to rely on
assumptions about emission standards far into the future such as Euro V1, either in respect of their
adoption and timing or their emission factors. Nor is there transparency; the Surface Access
document by BAA published along with the consultation blandly states “Well into the project,
sufficient information became available to allow the assumption of expected future vehicle
emissions standards across all vehicle types beyond those in published material”.

Emissions from road vehicles depend critically on factors such traffic flows, vehicle speeds,
congestion, scenarios and types of vehicles in the fleet mix. For example, small changes in traffic
volumes can lead to large changes in congestion and consequential large changes in emissions. It is
not possible to forecast these factors with any great precision into the future; it follows that
emissions and concentrations cannot be estimated with precision.

Important assumptions have been made about the future aircraft fleet and technology and their
emissions, notably on aircraft not yet in operational circulation or, in some cases, not yet built.
There is no degree of transparency evident on what was provided by industry, manufacturers,
airlines to inform the future fleet, and, critically there have been no sensitivities performed.
There is no evidence of an independent, peer-reviewed audit of this future fleet, despite its
importance with regards to air pollution. It follows that emissions and concentrations cannot be
estimated with precision.

The rapidity of climate change can now be seen and significant changes in future meteorology and
atmospheric chemistry changes are entirely possible. For example longer, hotter summers with
extended easterlies and higher ozone concentrations could result in increased ground level
concentrations of NO2. It follows that emissions and concentrations cannot be estimated with any
precision.

The upshot of all these uncertainties is that air pollution at 2015, let alone 2020 and 2030 cannot be
forecast with any precision.


                                                   20
5.6 Sensitivity tests

Given the manifest uncertainties of air pollution forecasting, it is essential that sensitivity test are
carried out, varying the key modelling inputs and assumptions by the amount that are useful and
realistic. By useful and realistic we mean the parameters are varied singly and in combination by
sufficient magnitudes to illustrate the possible range of variation in the real world. There is no
evidence of this having been done. This means that there is no measure of the anticipated accuracy
of the results.

5.7 Government cannot be confident of meeting pollution limits

As indicated in 3, the air pollution estimates cannot, by any stretch of the imagination, be
considered as accurate. It would risky and unjustified to claim an accuracy of better than about
10% over 20 years into the future. But as the table in 2 shows, there are many properties forecast to
be within 5% of the 40ug/m3 annual limit for NOx. This means that is impossible to be “confident”
that the air pollution limits will be met.

5.8 No control mechanisms

The EU limits on air pollution are absolute, being set to protect human health. But the estimates of
air pollution, resulting from MM/R3 are approximate. It is therefore necessary for there to be
monitoring and control mechanisms to ensure that, should the projections prove optimistic, action is
taken to rectify the situation.

If MM/R3 are implemented, it is vital that the resulting air pollution levels are monitored and are
compared against projections and EU limits. If it becomes apparent that the limits will be breached,
remedial action will be needed. This could take various forms, for example limiting the number of
flights, banning the more polluting aircraft or constraining road traffic. The consultation gives no
indication that any control mechanism has been considered or would be put in place to ensure that
the air pollution remains within limits.

5.9 Derogation

Chapter 3 para 3.119 indicates that the NO2 limit can be met close to the airport and would be
consistent with EU obligations. This statement is under the assumption that a „derogation‟ has been
applied for, and granted, and that the deadline for compliance has been extended in this area to
2015.

This is a gross misuse of a derogation. The purpose of a derogation is made clear by the European
Parliament: “ .. where Member States have taken all reasonable measures the Commission will
propose that Member States be allowed to delay the attainment date in affected zones where limit
values are not yet complied with, if certain objective criteria are met. Any extension will have to be
notified to the Commission”. Derogation is intended to allow countries more time to address
problems that have built up over many years, for example traffic pollution in central London, Paris
and Milan. It is emphatically not an excuse to allow government to deliberately pursue policies that
would lead to breaches, such as MM/R3.

An attempt to use a derogation in this way could be found contrary to the letter of European law; it
would most certainly be contrary to the sprit of the law.




                                                   21
5.10 Air pollution away from Heathrow

Air pollution has only been modelled relatively close Heathrow. Although Heathrow emissions
may contribute a modest proportion of the total air pollution in places such as the boroughs of
Ealing and Hammersmith, the effects of aircraft and Heathrow traffic are important. This is
because large areas are already close to or exceed air pollution limits. For example, the whole
borough of Ealing has been declared an „Air Quality Management Area‟. Any extra emissions due
to Heathrow, or impediments to reductions to Heathrow could therefore have a significant effect on
achieving air quality standards in such areas.

A related and important consideration relates to the number of people affected. Although the
proportion of air pollution due to Heathrow away from the airport may be small, it affects millions
of people. A small increase for a large number of people adds up to a large overall or societal issue.
There ought to be an assessment of the impact across all of London and the areas west of Heathrow.
This might be expressed in terms of the numbers of people in areas where air pollution is
sufficiently close to standards and limits that Heathrow and Heathrow expansion are likely to
change the status (or cause it not to change).

5.11 Economic cost of air pollution

Although there are understandable ethical objections to reducing air pollution impacts to a monetary
cost, it is widely recognised that such a process, not just for air pollution but for other impacts, is
useful in formulating public policy. At best it helps with reducing air pollution but, failing that, it
enables economic costs, taxes, charges and compensation to be evaluated.

Given the demonstrable health impacts, it is obvious that there must be an economic cost or air
pollution. While there are difficulties in estimating economic costs for noise, there is a literature on
the subject and estimates could be made. Indeed, estimates were made, albeit poor ones, in the
aviation White Paper.

In this consultation, no attempt is made to estimate a cost and factor it in to the calculation of
economic benefits. The effect of this is, as with other omitted „external costs‟ to give misleadingly
optimistic figures for the economic benefits of Heathrow.




                                                   22
                                    6. Climate change
6.1 Introduction

Climate change is – quite simply – the most important issue on earth. Climate change is of great
relevance to aviation because aviation already contributes some 10% of the UK‟s greenhouse gases
(GHG) emissions and it is a very rapidly rising source.

Emissions from Heathrow represent nearly half of the UK‟s aviation emissions. An increase in
capacity and emissions of nearly 50%, as proposed by the government, is thus of great significance
in the context of climate change.

It is therefore remarkable, and indeed reprehensible, that the consultation document says virtually
nothing about climate change itself. It is not mentioned in the main text, notably „Policy context‟
and „Meeting the environmental tests‟. The only appreciable mention is in App B, where emissions
are considered just as one cost among many that are taken into account when estimating the
economic benefit of Heathrow in terms of NPV (Net Present Value). We contend that there are
major flaws in this economic assessment approach - see national FOE response and Section 10 of
this response.

There are no comments invited (questions asked) about climate, despite the fact that a large
proportion of the 238-page consultation document is devoted to environmental impacts (largely
noise and air pollution). In the view of FOE, the absence of climate change from the consultation
casts grave doubt on the credibility of the exercise. Nonetheless, we are responding to the
consultation and we are, most particularly, responding on the issue of climate change.

6.2 Scope and structure of comments

There is no comment in the consultation document on the climate change implications of expanding
Heathrow and no questions are posed. We have therefore structured this response in way that
seems most convenient in the context of the issue.

The climate impact of Heathrow cannot be considered in isolation from the impacts of UK aviation
generally. This response therefore addresses the issue of UK aviation emissions generally. The key
document is „UK air passenger demand and CO2 forecasts‟ published by the DfT in Nov 2007.
There was no consultation on this document, but some of the comments here are directly relevant to
that document. We therefore ask that this response on climate change is regarded as formal
comment on that document as well as on the Heathrow consultation.

In this response, references to table numbers such as 3.7 and K13 refer to „UK air passenger
demand and CO2 forecasts‟ as do references to “the document”. Other references, especially
paragraph references and table numbers of the form FOE/x, refer to this response.

6.3 The climate change imperative

Climate change is happening and is recognised by many as being a major threat to human lives and
livelihoods and to all the planet‟s other life-forms. The debate about whether human activity is
causing climate change is, for all practical purposes, over.

Drastic cuts in emissions are necessary to avoid dangerous and irreversible warming. These are the
stark conclusions of the IPPC (Intergovernmental Panel on Climate Change).


                                                23
The UK government accepts this and has stated that taking action on climate is a priority and that
the UK is, and intends to remain, a world leader on the issue.

In recognition of this (and in response to public pressure), the government is introducing a Climate
Change Bill to Parliament. This bill has all-party support, although there are differences of opinion
about some of the provisions of the bill.

The bill proposes a 60 per cent cut in UK CO2 emissions, compared with a 1990 baseline, by 2050.
This is in line with IPCC and other authorities who say that we need to limit the increase in CO2
concentration to about 550 ppm (parts per million) at 2050. This is to limit the average increase in
temperature to about 20C, this being needed to avoid the worst effects of climate change.

However, the proposed cut of 60% by 2050 cannot be taken in isolation – a rapid downwards
trajectory of emissions is needed, starting from now. This is because CO2 builds up in the
atmosphere (it has an average lifetime of 100 years or more) and therefore it is cumulative
emissions, rather than those in any one year, that determine CO2 concentrations. Unless action
starts now, it will be virtually impossible to reduce emissions fast enough in the latter part of the
next 43 years (beginning 2008 to end 2050 is 43 years) to reduce annual emissions by 60% (let
alone even deeper cuts - see below).

The most up-to-date scientific evidence from IPCC and others indicates that a target to limit CO2
concentrations to 550ppm is unlikely to prevent a temperature increase of 20 or more. Instead, a
450ppm is desirable requiring reductions in developed countries of at least 80%from 1990 levels.
The Prime Minister has said, for this reason, that the government will consider whether a revised
target should be set. Hilary Benn announced on 18/2/08 that a new target will be set by end 2008.

There is no doubt that limiting temperature rise to 20C 80% - will be very challenging; all people,
all countries and all sectors of the economy need to play their part.

It is agreed by all nations, rich and poor, that the richest nations must make bigger cuts than poor
ones. This is because the per-capita emissions of rich nations are far higher than those of poor
nations. It is also because the emissions of rich nations are far easier to cut; most of the emissions
are to due to wasteful modes of consumption which could be changed without impacting on the
basics of life or quality of life.

Britain is a hugely rich country with the fifth largest economy in the world and a high per-capita
income. (Although there are pockets of poverty, this is a matter of distribution and inequality,
rather than the size of the UK economy.) Britain therefore has a major responsibility, not just to its
own citizens but to the world at large, to greatly reduce its emissions

Emissions from civil aviation make up a significant proportion of the UK emissions already. But
most significantly, emissions are rising very rapidly, unlike virtually all other sectors of the
economy. It is therefore essential that aviation plays its part in reducing the UK‟s total emissions.

6.4 UK’s emissions and targets - excluding international aviation

The UK estimated emissions of CO2 in 2006 were 556.5 million tonnes (mt) compared with 589.5
mt at 1990i. This is a reduction of 5.6%.

As noted in 6.2 above, reductions of at least 60% and probably 80% are needed. These are
reductions at 2050 compared with 1990 levels. An 80% cut from 1990 to 2006 implies a cut is
needed of between 2006 and 2050 of 78.8% [ {(100 – 5.6) – 20 / (100 – 5.6)} ]. This corresponds

                                                   24
to an average from 2006 to 2050 of 3.5% pa (compound). The reduction from 1990 to 2006 was
just 0.4% - so a vastly increased rate is needed from now on.

These figures show clearly that progress since 1990 has been totally inadequate and that far more
now needs to be done. These cuts exclude international aviation and also international shipping.
However, as argued below, the same depth of cuts need to made for the total UK emissions
including international aviation and shipping.

6.5 UK aviation emissions – DfT forecasts

CO2 emissions from aviation were forecast in the paper „UK air passenger demand and CO2
forecasts‟ (pages 50-71). The method used is described in App 1, where a summary table of result
is given (Table FOE/1). In summary, CO2 emissions are forecast by the DfT to rise from 37.5mt in
2005 to 58.0mt in 2030 but then suddenly level off to reach only 60.3mt in 2050.

There is much debate about whether the passenger forecasts which underpin the CO2 forecasts
are valid. There are valid arguments as to why the forecasts are too high, not least because they
assume continuation of „predict and provide‟, huge tax exemptions and no credible plan to make
aviation play its part in addressing climate change. However, for the purpose of these calculations
of emissions, the government‟s figures (up to 2030) are taken. The reason being that they
demonstrate the implications of current government policy and the need to change it.

6.6 FOE re-forecast of emissions using Government assumptions

While we accept the forecasts for 2030 as being consistent with the Government‟s assumptions and
current policies, we emphatically do not accept the forecasts for 2050, because they assume a
dramatic policy change which suddenly takes effect after 2030. It appears the government is
assuming that its „predict and provide‟ policies, confirmed in the 2003 White Paper, will be
continued for many years and then suddenly abandoned. No justification is given for this policy
about-face.

A more consistent approach would be to assume continuation of the present government policy
beyond 2030, namely only slight capacity constraints such that constrained demand continues to be
only a few % below unconstrained demand. The constrained capacity and CO2 emissions are
therefore re-calculated on the assumption of no about-face in policy at 2030, as described in App 2.
The result of this is to increase the forecast passengers and the CO2 emissions at 2050 by 14.8%.
The revised figures are shown in Table FOE/2 in App 2.

6.7 Aviation’s share of total UK emissions – DfT estimates

Table K1 of „UK passenger demand and CO2 forecasts‟ calculates aviation‟s share of UK
emissions. It is assumed that the UK emissions, excluding international aviation, are cut by 60%
from 1990 levels at 2050. The results are 6.4% at 2005 and 20.6% at 2050. There are also
calculations for 2020, where two alternative levels of cut (on the way to 60%) are postulated. The
use of two figures seems to complicate matters unnecessarily, but, far more importantly, there is no
calculation for 2030. 2030 is a key date, being the timescale for the government‟s aviation policy
and it thus of great importance that the public should be able to see what implications the policy has
for CO2 emissions.

The second part of Table K1 repeats the calculations for GHGs as whole, using an RFI of 1.9 for
aviation. RFIs for other sources are allowed for in the calculations, but are not shown explicitly.
Aviation‟s share of emissions is then 9.9% at 2005 and 29.0% at 2050.

                                                  25
The results are:

                   Year         Aviation % of UK CO2       Aviation % of UK GHG
                                emissions                  emissions
                   2005         6.4                        9.9
                   2020         10.3 to 11.1               15.0 to 15.9
                   2030         20.6                       29.0

                     Table FOE/8. Aviation as % of UK emissions according to DfT

6.8 Aviation’s share of total UK emissions – FOE calculations

There are some very important shortcoming in the DfT estimates:
a) The 2050 aviation emissions are unjustifiably low.
b) The target 60% cut is only applied to emissions excluding international aviation.
c) There are no calculations on the basis of 80% cuts.
These points are addressed in turn.

a) The reasons why the 2050 aviation emissions are unjustifiably low are described in 6 above,
where the FOE correction is described. The effect is to increase emissions in 2050 by 14.8%.

b) The government has already accepted that a 60% cut in UK‟s emissions by 2050 is necessary in
order for it to play its part in avoiding the worst consequences of climate change. This is based on
the advice of its own scientists and those around the world, reporting through and mediated by the
IPCC. There is no suggestion from these scientists or IPCC that the 60% cut does not need to
include aviation. Indeed, they would lose all credibility if they were to claim that emissions from
aviation in some way do not affect climate as do all other sources and therefore do not need to be
included when it comes to setting targets. It is therefore unhelpful and misleading to publish figures
that purport to show aviation‟s share of emissions when the denominator of the equation allows for
massive increases in aviation emissions outside target for overall cuts.

c) As noted in 6.3, there is a developing consensus among scientists that 80% cuts are needed
rather than 60%. This has been acknowledged by government and the Prime Minister.

6.9 Aviation’s share of total UK emissions – FOE calculations

FOE has re-worked the DfTs figure for CO2 emissions to take account of the above shortcomings.
The calculations are shown in detail in App 3.

FOE has also re-calculated the DfT figures which include other GHGs and an RFI of 1.9 for
aviation. The calculations are shown in detail in App 4

A summary of the results follows:




                                                 26
Year     Method                                                  Aviation % of UK CO2   Aviation % of UK GHG
                                                                 emissions              emissions
1990     Historical                                              2.8                    4.3

2005     Historical                                              6.4                    9.9

2050     DfT method                                              20.6                   29.0

         DfT method with FOE revision of emissions (correction   23.0                   32.0
         „a‟)
         FOE method with FOE revision of emissions – 60% cuts    28.5                   43.7
         (corrections „a‟ and „b‟)
         FOE method with FOE revision of emissions – 80% cuts    56.9                   87.5
         (corrections „a‟ and „b‟ and „c‟)

                      Table FOE/9. Aviation as % of UK emissions according to FOE

While each of the corrections - a, b and c - makes a modest difference, when they are all applied,
they make a massive difference at 2050. They show that the DfT figures hugely under-state
aviation‟s contribution to UK emissions by 2050.

The implications of aviation‟s share 58.9% of allowed UK CO2 emissions are very significant, but
bringing in the other GHGs means that no less than 87.5% all the UK‟s allowable GHG emissions
could be used up if aviation is not controlled. The implications for both aviation and climate
change policy are thus even greater - see 6.11.

There has been increasing recognition of the fact that the majority of passengers flying to and from
the UK are British. Some 77% of passengers in 2005 were British (Table G2) and is forecast to
decline slightly to 75% in 2030. We assume that this gradual decline continues so that in 2050,
73% of passengers are British. It is assumed that the figure was 77% in 1990.
.
It can therefore be argued that UK should be allocated 73% of all emissions from international
flights instead of the 50% assumed in the DfT calculations and the FOE re-workings. 50% of
emissions would only be fair if 50% of passengers from were from the UK and 50% were
foreigners. (Although this argument has much validity, it should be recognised that the principle is
not applied in other sectors. For example, emissions from manufacturing are allocated to the
country where manufacturing takes place, not where the goods are consumed.)

The emission %s for a selection of the figures in the above two tables have been re-calculated on
the basis of an allocation of emissions according to the % of UK passengers.




                                                         27
Year      Method                                         Aviation % of UK CO2    Aviation % of UK GHG
                                                         emissions               emissions
1990      Historical                                     4.1                     6.3

2005      Historical                                     9.3                     14.1

2050      DfT method                                     27.0                    36.8

          DfT method with FOE revision of emissions      29.9                    40.2
          (correction „a‟)
          FOE method with FOE revision of emissions –    40.1                    61.2
          60% cuts (corrections „a‟ and „b‟)
          FOE method with FOE revision of emissions –    78.6                    122.5
          80% cuts (corrections „a‟ and „b‟ and „c‟)

   Table FOE/10. Aviation as % of UK emissions according to FOE: emissions apportioned according to
                                      nationality of passengers

The difference is considerable (as one would expect, given that the allocation of international
aviation is increased by about half as much again). The most telling figure is 122.5%. This figure
tells us that if aviation is allowed to grow under a „predict and provide‟ scenario and emissions are
apportioned in proportion to UK passengers, it will be physically (mathematically) impossible to
achieve 80% cuts by 2050.

Although the thrust of these figures is clear, it should be noted that the %s are less reliable than the
previous ones that were based on a 50% apportionment. This is because the 77% and 73%
apportionments do not distinguish between domestic and international aviation and they do not
include transfer, for which figures are not given in Table G2

6.10 Heathrow’s emissions

The DfT estimates that Heathrow was responsible for 18.2 mt of CO2 in 2005 and is forecast to
produce 24.0 mt in 2030 – an increase in about 6mt. The increase is largely due to the effect of a
third runway and the extra flights, but it is compounded by the changes that would be expected even
if there were no third runway.

The DfT also compares the CO2 emissions expected with a 2-runway airport with the 3-runway
airport. At 2030 CO2 emissions are 16mt with 2 runways and 25mt with 3 runways, a difference of
9mt. This is the figure which has been widely quoted and has been noted as being equal to the
entire emissions of Kenya (before the current troubles). At 2050 CO2 emissions are 15mt with 2
runways and 22mt with 3 runways, a difference of 7mt.

The 2030 figures have some validity because they compare the two most likely situations at 2030,
namely a 2-runway and a 3-runway Heathrow. But the situation at 2050 is far more hazy. The
consultation assumes that a new runway could be available by 2020 but, due to pent-up demand,
and it would be largely full by 2050. It is therefore reasonable to assume that BAA and the
government would start pressing for a 4th runway (and 7th terminal) to be operational around or soon
after 2030. Indeed, the Chief Executive of BAA has virtually given notice of this. The emissions at
Heathrow at 2050 could therefore be far higher than estimated by the DfT.

The situation could be even more extreme than a 4th runway and 7th terminal implies. The DfT
paper does not show unconstrained demand by airport, but examination of the constrained figures


                                                    28
suggests that there would be demand and therefore lobbying for a 5th runway (and 8th terminal) to
be in operation by 2050.

The DfT has said that the figures for CO2 emissions at Heathrow should not be taken in isolation,
but that the impact on UK aviation emissions as a whole should be considered. On this basis, a
third runway at Heathrow adds about 4 mt CO2 at 2030. At 2050, the additional amount due to a
third runway is still 4mt but, as noted above, there could be a fourth and even a fifth runway if the
present „predict and provide‟ policy continues.

6.11 Heathrow’s emissions as a proportion of UK emissions

Heathrow‟s proportion of aviation emissions can be readily calculated, given Heathrow‟s and the
UK aviation‟s emissions. Details are given in App 6 (Table FOE/5). Heathrow‟s proportion of the
UK‟s total emissions can also be readily calculated – details are in App 7. The results are:

     Year                     Heathrow CO2 and   Heathrow CO2        Heathrow GHG
                              GHG emissions as   emissions as % of   emissions as % of UK
                              % of UK aviation   UK total            total
     2005                     48.5%              3.1%                4.8%

     2050 (assuming no        31.8%              17.1%               27.8%
     further expansion at
     Heathrow beyond R3)
     2050 (assuming further   48.5%              27.1%               42.4%
     expansion at Heathrow
     beyond R3)

                  Table FOE/11. Heathrow emissions as proportion of UK total emissions

It should be noted that these could be considered significant under-estimates, because, as noted
previously, all these figures are calculated on the basis of apportioning emissions equally between
the UK and the distant country instead on being apportioned in proportion to the nationality of the
passengers.

6.12 Implications for public policy

Aviation‟s share of the UK CO2 emissions under current government policy are calculated by FOE
from government data be 56.9% CO2 and 87.5% of all GHG emissions at 2050 if an overall 80%
cut is to be achieved (table FOE/9 in 9.12). This means that either:
a) all the sectors other than aviation will need to make cuts bigger than 80%,
b) government policies on aviation must change such that emissions do not increase as currently
forecast, or
c) the UK will fail to meets its obligations on climate change.
It is thus clear that under the Government‟s growth assumptions „predict and provide‟ will have to
be abandoned at some point if an 80% emissions cut is to be achieved.

If the emissions attributable to UK passengers are taken - the „moral‟ approach - as opposed to
splitting emissions equally between the UK and the distant country - the „legalistic‟ approach -
above, aviation‟s shares of emissions are greater still. (Tables FOE/9,10). On this basis, aviation‟s
share of UK allowable GHG emissions is a staggering 122/5%. In other words, it will be physically
(mathematically) impossible to achieve a target of 80% cuts by 2050. The only answer is to address
the growth in aviation‟s emissions by changing aviation policy. In our view, the imperative of
urgently addressing climate change means the policy change needs to happen now.


                                                  29
     As shown in 6.11, Heathrow alone would contribute an impossibly large proportion of the entire
     UK‟s allowable emissions by 2050. Expansion beyond the present two runways represents a large
     part of this. It is therefore necessary to abandon plans to expand Heathrow. It is necessary because
     of the emissions themselves, but it is also necessary because of the message it puts out. Heathrow is
     iconic in the fight against climate change and a government decision to expand would broadcast to
     UK citizens and the rest of the world more plainly than any government rhetoric, its true attitude to
     climate change.

     6.13 Aviation and Emissions Trading

     The government is fully aware of the conundrum posed by the imperative to reduce emissions and
     the increasing emissions from aviation. Whenever confronted with this, ministers and civil servants
     just cite the government‟s policy of support for bringing aviation into the European Emissions
     Trading System (ETS) in about 2011 and claims that it will address the conundrum and allow the
     UK to meet its commitments.

     Unfortunately, there is no evidence to support this assertion. On the contrary, there is a range of
     compelling reasons why emissions trading may not, will not or cannot solve the problem:

a)     There is no certainty that ETS for aviation will be introduced. The US is likely to oppose it in the
     courts.
b)      Even if emissions trading is introduced, there is no assurance that effective caps will be set. The
     present ETS caps have been completely ineffective to date because they were set on the basis of
     lobbying and political expediency, not on the basis of analysis and science.
c)      The ETS proposals deal only with CO2. The other GHGs produced by aviation, which represent
     nearly half the climate impacts, are ignored.
d)      The majority of the emissions cuts planned in phase 2 of the EU ETS will be accounted for by
     clean development mechanism projects in developing countries. These are not emissions cuts, do
     not take place in the EU and the efficacy / credibility of many of the projects themselves is suspect.
e)      The ETS is an imperfect trading system, covering less than half of EU emissions and is not
     international. Aviation is not subject to international competition like other sectors and in an open
     trading system with a declining emissions „cap‟, aviation‟s appetite for carbon permits could drive
     up the price of carbon to the point where other sectors such as steel manufacture would relocate
     outside the EU. The figures might show that the EU had achieved its targets, but the benefits would
     be illusory.
f)      Any emissions trading system designed to meet an 80% emissions reduction target would, by
     necessity, restrain demand through increases in air ticket prices as the shortage of carbon permits
     inflates the carbon price. The European Commission‟s own impact assessment shows that the
     current ETS proposal will have hardly any impact on demand or prices up to 2020. Analysis by the
     Tyndall Centre in 2007 found that current and envisaged carbon prices will have virtually no impact
     on emissions and that the ETS proposal must be made much more effective for aviation to be part of
     an EU committed to limiting carbon concentrations to 450ppm. Cutting overall emissions by at
     least 80% by 2050 is highly challenging target for the economy as a whole and across all sectors;
     rising aviation emissions will require and effectively force other sectors to make even more drastic
     cuts to meet the target and make up for aviation‟s ineffective contribution, if indeed this is possible
     given the science of aviation‟s atmospheric emissions and the economic load on other sectors.

     6.14 Aviation and the Climate Change Bill

     A climate bill is shortly starting its passage through the Houses of Parliament. The current
     provisions seek a 60% cut in CO2 emissions by 2050, as compared against a 1990 baseline. But


                                                       30
crucially, international aviation emissions (and international shipping emissions) are left out of the
targets. There is no scientific or logical justification for doing so.

Ministers and civil servant use two main arguments to defend the exclusion of aviation from the
targets. The first argument is that aviation is an international activity; therefore international
agreements are needed to effect change and emissions are outside government control. This is not
so. The UK government and the EU have almost complete power to control aviation in their
respective countries. While there are international regulations and treaties aiming to prevent
unilateral action, these are mainly aimed at preventing discrimination between carriers of different
countries. They do not prevent action to prevent local environmental damage or to prevent climate.
The fact that there are planning conditions at airports, that there are night flight restrictions, that
there are noise charges, that there is APD (Airport Passenger Duty), that there is VAT (on domestic
flights in some countries) and that an ETS is being implemented all attest to the fact that individual
countries can control aviation and its impacts.

The second main argument used by ministers and civil servants is that there is no internationally
recognised way of allocating emissions between countries. This is simply untrue. The UK and
other countries measure and report on a regular basis international aviation emissions as a “memo
item” to UNFCC (see for example DEFRA inventory (UK Greenhouse Gas Emissions 1990-2006:
breakdown of headline results at http://www.defra.gov.uk/news/2008/images/080130a/annex-
b.pdf). The convention is that all outgoing flights are allocated to the country of departure. (This is
equivalent to dividing the emissions of all flights between any pair of countries equally between
those countries.) But even if there were no internationally agreed method, this would not be a valid
argument. The climate bill is UK legislation and does not require the agreement of any other
country or international body. The UK can thus choose whatever method it thinks fit to allocate
aviation emissions to the UK for the purpose on inclusion in its targets.

If the Government believes aviation emissions growth can be balanced by additional cuts in other
sectors, then it should have no issue with including the UK‟s share of international aviation (and
shipping) emissions in the climate change bill from the start. At present it is resisting doing this.




                                                  31
                                 7. Public Safety (Danger)

7.1 Safety ignored in the consultation

There is no substantive mention of public or third-party safely in the entire CD and there are no
separate publications in the Annex list. The danger to communities around Heathrow of a crash is a
serious concern, just as are noise, air pollution, etc. The consultation ignores the increased risk of
people being killed on the ground in a crash. It is reprehensible that this issue is not covered in the
consultation and no comment is invited from the public.

7.2 Third party and societal risk

There is no doubt that safety is taken seriously by airlines, BAA and NATS; and there is no reason
to suppose that Heathrow is more dangerous than other airports in terms of risk to passengers.
However, the situation with respect to people on the ground is quite different. Without any doubt,
Heathrow is by far the most dangerous airport in the country in terms of total or „societal‟ risk. This
is because of the large number of big planes flying over large populations.

The risk to any one person on the ground is recognised in the existence of Public Safety Zones
(PSZ). There is the very briefest mention of these but there is no discussion of actual risk or how
existing buildings may be brought into areas of highest risk. We understand that there will be,
among others, a school that near the 3rd runway which not be allowed planning permission for
safety reasons if attempts where made to build it now. Yet there are no plans to re-locate the school
and children to a safe place.

Although increased risk to individuals is important, it is perhaps the total or „societal‟ risk that is
most significant. This is the „expected‟ number of people injured and killed, „expected‟ being used
in the statistical sense. That number consists of the risk to each person summed over all the people
exposed to risk. Because so many people are overflown by each plane, the societal risk around
Heathrow tends be much higher than around other airports. (The individual risk to one person on
the ground is not affected by the number of people overflown.)

While PSZs take account (to a limited extent as noted above), of individual risk, they do not address
societal risk. This does not mean that societal risk should be ignored where, as for Heathrow, it is
clearly relevant. If societal risk were ignored, it would be considered as acceptable to build a
nuclear power station in London as on an isolated part of the coast because the risk to an individual
who happens to live near the nuclear plant is the same.

7.3 Increased risk with MM/R3

It is obvious that increasing the number of aircraft using Heathrow will increase societal risk. A
very rough approximation is that the societal risk will increase in proportion to the total number of
flights. Thus risk is increased by 12% with MM (540,000 / 480,000) and 46% by R3 (702,000 /
480,000). If flights were to rise to 800,000, which has been intimated if MM remains after a third
runway is operational, the increase in risk would be 66.7%.

In fact the increase in risk could be even greater. There is a trend towards ever-larger aircraft and
larger planes tend to cause more casualties when they crash. (However, it should be noted that
aircraft size will also tend to increase in 2-runway Heathrow.) There would also be a slightly
increased of a mid-air collision due to increased number and complexity of flight paths.



                                                  32
                                       8. Surface access
8.1. Consultation

The consultation asks no questions and seeks no view on transport improvements to serve
Heathrow. This is a major omission; indeed it was stated in the Aviation White Paper (para 11.58)
that “Further expansion of Heathrow will place pressure on already congested road and rail
networks.”

8.2 Roads

The government estimates that the number of people travelling to Heathrow by car (including taxi
and „kiss and fly‟) will increase from 28 million in 2004 to 51m by 2030. A figure of 25m extra
trips a year is also quoted. The roads around Heathrow are already heavily congested, but there are
no plans announced for road building or widening. FOE is strongly opposed to road building for
environmental reasons, but we believe that there must be alternatives. In the case of Heathrow,
walking and cycling options are not generally relevant; therefore the answer lies in public transport
- buses, coaches and trains.

Major improvements are needed to public transport but it is also necessary to have a transport
strategy that ensures public transport is used instead of cars. In the absence of this, there will
increases in demand for roads and, inevitably, lobbying for road-building and road-widening.

This has already happened with Terminal 5 (T5). Although it was said to be government policy at
the time to build or widen motorways, the government proposed to expand the M25 to a total of 14
lanes between Junctions 12 and 15 to serve T5. This demonstrates what happens when insufficient
public transport is provided and when there is no policy to ensure it is used in preference to cars.
It is clear that a decision to expand Heathrow will lead to pressure to widen the M25 (beyond the
J12-15) and the M4. Widening would devastate Green Belt and Metropolitan Open, would increase
air pollution and would have serious knock-on effects on the local road network.

8.3 Public transport

According to the consultation document R3/T6, the public transport mode share will increase from
36% to 40-42% (para 3.170). This represents an increase from about 16 million passengers in 2004
travelling by public transport to 38 million passengers by 2030 which is more than double the
current number.

While an increase in public transport mode share is welcome, it is not nearly enough. As noted in
8.2, the government is forecasting a massive increase in car trips. Such an increase in car traffic
would have a massive impact on local people and their environment and would run counter to all
policies for sustainable transport.

This increase from Heathrow is in addition to increases for non-Heathrow traffic. For example, the
London Underground Piccadilly Line is already crowded, but demand on is estimated to be up 50%
by 2020. Meanwhile, planned enhancements will only increase capacity by about 20%. The line
will barely be able to cope with the non-Heathrow demand, let alone new demand from R3/T6. The
comments about Airtrack, Crossrail and the Piccadilly Line do not address the issue. These are
schemes already planned and are needed to support a two-terminal Heathrow as well as big
increases in demand for non-Heathrow traffic. Radical new measures are needed.



                                                   33
Given the need for massive increases in public transport, it is astonishing and unacceptable that no
clear measures are proposed. The consultation merely talks about things which might be done or
need to be done and states that proposals for public transport improvements will be brought forward
by BAA as part of any planning application. This is not acceptable. It is not possible for BAA to
produce a sustainable transport strategy for the area, which is what is required. That is a job for
government. In the same way the government is promoting MM/R3/T6 and has done work on
noise, air pollution and economics to support it, the government should have a this stage a transport
strategy and proposals for public transport improvements.

It is stated in the BAA „Surface Access Report‟, that “public transport improvements on their own
would have little impact on road traffic measures.” (para 266). Yet the CD makes it clear that such
measures, eg a congestion charge, are not planned. This demonstrates that there is no coherent,
sustainable plan for surface access.




                                                 34
                        9. Wildlife, habitats and biodiversity

Loss of biodiversity is a huge and pressing issue. It is the second greatest environmental issue, after
climate change. Biodiversity impacts should therefore be critical in assessing developments such as
expanding Heathrow.

The only substantive statement in the CD is “The direct biodiversity impact from Option 1 would be
limited to loss and disturbance to localised areas in proximity to the proposed development.
However there may be indirect effects beyond the boundaries of the development as a consequence
of air quality [ie air pollution] changes resulting from the proposal and especially associated with
traffic generation. These effects may have consequences for sites of significant importance for
nature conservation.”

This is all that is said in over 200 pages of the CD and closer to 700 pages if the associated
documents are included. A „throwaway‟ statement such as this would have rightly caused outrage if
had been made about noise or air pollution.

This statement is remarkably and unacceptably vague. It says nothing about the nature and the
scale of the threats. “Limited to loss and disturbance to localised areas in proximity to the proposed
development” could be said about any development and is virtually meaningless. The nature and
scale of the “indirect effects” is not specified. The only useful statement is that which suggests that
air pollution and road traffic might be particularly likely to have impacts. But even here, there is
nothing at all specific.

Runway 3 would destroy part of Harmondsworth Moor, some of which is public open space. This
land is of far greater conservation value than the vast majority of land near Heathrow, which is built
over. Thus there is a specific and tangible threat, not mentioned in the CD.




                                                  35
                                       10. Economics

Almost the entire justification for expansion of Heathrow is the claimed economic benefits.

WLFOE has studied to some extent the government‟s calculations, summarised in Annex B of the
CD. We are totally unconvinced by the claims and have detected errors and omissions which
invalidate the results. National FOE has studied this in more detail and covers the issue in its
response. We therefore do not comment in detail, but endorse their comments.

We add a few broad comments on the Net Present Values of £4.4bn to £6.6bn (Table 1 in Annex
B).
     This is a benefit achieved by costing over an 80 year period. No ordinary investment would
      be calculated or justified over such a time period. The uncertainties in the UK and the world
      up to 82 years ahead are such that no credence can be placed on the result.
     Although sounding large, the scale of benefit is minute in the greater scheme of things. The
      GDP of Britain over one trillion pounds or £1000bn in a single year and is expected to
      increase greatly over the next 70 year.
     The benefit over 70 years is less than the tax exemptions of £10bn in a single year in the
      form of tax-free fuel and no VAT.
     The benefits would be wiped out (and more) if the appropriate cost of carbon from the Stern
      report was used.
     The benefits would be wiped out if other external costs were properly factored in.

The „wider economic benefits‟ have not been demonstrated in any way. The CD simply uses
unsubstantiated assertions, spurious facts and false logic to try and convince the reader.. A
selection of these are given in 3.8.

The few „facts‟ on economic benefits, other than the government‟s „consumer surplus‟ exercise
come from Oxford Economic Forecasting (OEF). OEF‟s work has been paid for mainly by the
aviation industry and has been demolished by other consultancies. We refer the DfT to reports by
the likes of Berkely Hannover (on Terminal 5), Buchanan and CE Delft. These are respected and
reputable consultants who do work for a side range of bodies, including the EU.




                                                36
                             11. Summary and conclusions

The impacts of noise and air pollution from expanding Heathrow would be very large and have
been seriously and systematically downplayed in the consultation.

The issues of public safety, biodiversity and climate change are virtually ignored.

The climate impacts of a third runway, both in its own right and symbolically, would make
nonsense of the government‟s claims to be leading in the fight to address climate change.

The economic arguments and the calculations of economic benefit do not stand up to scrutiny.

For these reasons West London Friends of the Earth is utterly opposed to the expansion of
Heathrow, by means of mixed mode or a third runway.




                                                 37
                App 1. DfT forecast of aviation’s CO2 emissions

CO2 emissions from aviation were forecast in the paper (pages 50-71). The approach, in simplified
terms, is to forecast passenger traffic, estimate present fuel use per passenger or passenger km,
forecast a rate of improvement of fuel efficiency and use these to estimate emissions up to 2030.
Allowance is made for other factors, such as freight-only flights and improvements in operational
efficiency in air traffic control. The following table summarises the key figures.

                       Year        Unconstrained      Constrained       CO2 m tones
                                 passenger demand       Passenger          (mt)
                                        (m)           demand (m)
                   2005         228                 228               37.5
                   2010         270                 270               42.0
                   2015         335                 310               ????
                   2020         385                 375               50.0
                   2025         440                 410               ??
                   2030         495                 480               58.9
                   2040         ??                  540               61.1
                   2050         ??                  580               60.3

                                              Table FOE/1

„Unconstrained demand‟ is the demand that would be realised if there were no airport capacity
constraints at any airport. „Constrained‟ demand is the demand that is realised if capacity is added
in line with the policy in the government‟s White Paper of 2003. It can be seen that at 2030,
constrained demand is only 3% less [ 100 x ( 495 – 480 ) / 495 ] than unconstrained demand. The
policy is therefore virtually „predict and provide‟ at a national level. (It can be argued that the
policy is not „predict and provide‟ at the detailed level in that capacity is not necessarily provided to
meet the demand that arises at every airport. However, where there is unsatisfied demand at one
airport, the normal response is for the demand to be „diverted‟ to a nearby UK airport. This means
that the total UK traffic and emissions are unchanged.)

The unconstrained demand figures above are called the „central‟ forecasts, these being considered
by the government as a best estimate. In addition to the central, „low‟ and „high‟ forecasts are given
as „sensitivity tests‟. However these are only 5% or 6% different from the central forecasts and
FOE does not consider they in any way represent the range of uncertainty.

There is much debate about whether the passenger forecasts are valid. There is much debate about
whether the passenger forecasts which underpin the CO2 forecasts are valid. There are valid
arguments as to why the forecasts are too high, not least because they assume continuation of
„predict and provide‟, huge tax exemptions and no credible plan to make aviation play its part in
addressing climate change. However, for the purpose of these calculations of emissions, the
government‟s figures (up to 2030) are taken. The reason being that they demonstrate the
implications of current government policy and the need to change it.

These forecasts make the following explicit or implicit assumptions:
    Very little restraint due to limiting airport capacity (see above)
    Cost of oil is constant at $53 per barrel (it is over $100 now)
    No physical or regulatory constraints for environmental reasons
    No general revenue-raising taxes such as VAT or fuel tax (the government is now claiming
       APD is an environmental tax)
    Climate costs charged at a highly „optimistic‟ cost of a little over £70 per tonne
    No attempt to charge full environmental costs for noise and air pollution

                                                    38
      No attempt to charge for social costs such a loss of heritage, loss of landscape, blight,
       sterilisation of land, dislocation of communities, health impacts (some could be included in
       environmental costs) and third party risk.

It must be emphasised that FOE does not agree with these assumptions on future policy; they are
used to demonstrate the climate implications of current government policy, of which a third runway
is and integral and key part.

Fuel efficiency is of equal importance to passenger forecasts in determining CO2 emissions. The
expected improvements in fuel efficiency are therefore a matter of much importance and debate.
The aviation industry and its supporters claim that great improvements have been made over the
years and that even greater improvements may be achieved in future. However, IPCC (Inter-
Governmental Panel on Climate Change) and independent commentators make more sober
assessments. It is generally agreed that an improvement of between 1% and 2% pa is realistic, with
a figure around 1% with a „business as usual‟ scenario in future and nearer 2% if there is „forcing‟
by means of technological, regulatory and economic measures.

The government forecasts a modest rate of increase of 29.7% between 2005 and 2030 (Table 3.4 of
the paper), which is equivalent to a compound rate of 1.03% pa. We consider this reasonable and
that the government is right not to be swayed by highly optimistic or „aspirational‟ forecasts from
the industry. Given that there are no „forcing‟ measures even on the horizon (due to the
intransigence of ICAO and national governments), a rate of around 1% pa seems reasonable.




                                                 39
                     App 2. FOE re-forecast of CO2 emissions

While we accept the forecasts for 2030 as being consistent with the Government‟s assumptions and
policies, we emphatically do not accept the forecasts for 2050, because they assume a dramatic
policy change which suddenly takes effect after 2030. The paper says that these forecasts use a
“simpler, yet still robust” methodology. We accept that a simpler method beyond 2030 is necessary
and that the forecasts in later years are inevitably prone to more error. However, we consider the
emissions forecasts from 2030 to 2050 are seriously flawed. They show a sudden slowing of
growth from 2030 to 2050 that cannot be justified unless an unprecedented policy change takes
place.

After 2030, the paper forecasts that passenger growth will slow: “ .. capacity constraints begin to
bite again, so that growth in passenger demand slows.” It appears the government is assuming that
its „predict and provide‟ policies, confirmed in the 2003 White Paper, will be continued for many
years and then suddenly abandoned. No justification is given for this policy about-face.

A more consistent approach would be to assume continuation of the present government policy
beyond 2030, namely only slight capacity constraints such that constrained demand continues to be
only a few % below unconstrained demand. The constrained capacity and CO2 emissions are re-
calculated on the assumption of no about-face in policy at 2030, as described below.

The constrained forecasts are analysed in the table to show the growth rates in 5-year bands up to
2030. It is then assumed the growth rate will continue after 2030 in the same way as before, namely
declining but declining progressively less fast. The net effect is that over the period from 2030 to
2050 the growth is 39% compared with 105% between 2005 and 2030. Despite this massive
reduction in growth rate, our estimated constrained demand at 2050 is 14.8% larger than the DfT‟s
figure.

       Year                Constrained passenger forecast – normal     Annual growth rate over 5 years
                           font means from Table 2.11; italics means   (linear) - normal font means from
The                        derived here                                Table 2.11; italics means derived
                                                                       here
       2005                228
       2010                270                                         3.7%
       2015                320                                         3.7
       2020                375                                         3.4
       2025                430                                         2.9
       2030                480                                         2.3 (rates trended down from here
                                                                       onwards)
       2035                528                                         2.0
       2040                576 cf DfT of 540                           1.8
       2045                622                                         1.6
       2050                666 cf DfT of 580, ie 14.8% higher          1.4
                                                Table FOE/2

CO2 emissions can be calculated by a simple pro-rata. The emissions estimated by the DfT for 2050 are
60.3 Mt. If the passengers are in fact 14.8% higher than the DfT assumes, the CO2 emissions will be, to a
first approximation, also 14.8% higher, namely 69.2 mt.




                                                      40
                                  Appendix 3. Aviation emissions as a % of total UK CO2 emissions

The following table shows in detail calculation of the % of UK CO2 emissions represented by aviation in 1990, 2005 and 2050. For 2050, there are 4
different methods of calculation – see main text for the rationale.

A         B                                            C                   D                    E                 F                    G                    H
Year      Scenario                                     Aviation –          Aviation -           Aviation -        UK total incl        UK incl Dom and      Aviation %
                                                       International       Domestic             Total             Dom                  Int
1990      Historical                                   15.7                1.2                  16.9              592.4                608.1                2.8
                                                       (Inv)               (Inv)                (C+D)             (Inv)                (C+F)                (E/G)
2005      Historical                                   35.0                2.5                  37.5              554.2                589.2                6.4
                                                       (E-D)                (DfT email)         (K1)              (K1)                 (K1 or C+F)          (K1 or E/G)
2050      DfT method                                   56.2                4.1                  60.3              236.9                293.1                20.6
                                                       (G-H)               (E-C)                (K1)              (K1; note 1)         (K1 or C+F)          (K1 or E/G)
          DfT method with FOE revision of              64.5                4.7                  69.2              236.9                301.4                23.0
          emissions (correction „a‟)                   (note 2)            (note 2)             (note 2)          (K1; note 1)         (C+E)                (E/G)
          FOE method with FOE revision of              64.5                4.7                  69.2                                   243.2                28.5
          emissions – 60% cuts (corrections „a‟ and    (note 2)            (note 2)             (note 2)                               (note 3)             (E/G)
          „b‟)
          FOE method with FOE revision of              64.5                4.7                  69.2                                   121.6                56.9
          emissions – 80% cuts (corrections „a‟ and    (note 2)            (note 2)             (note 2)                               (note 4)             (E/G)
          „b‟ and „c‟)

                                                                                      Table FOE/3
Abbreviations and codes
A to H – column numbers
Dom – domestic
Int – international
Inv – DEFRA inventory (UK Greenhouse Gas Emissions 1990-2006: breakdown of headline results at http://www.defra.gov.uk/news/2008/images/080130a/annex-b.pdf).
K1 Table K1 in „UK passenger demand and CO2 forecasts‟

Notes
1. This figure corresponds to the 1990 figure reduced by 60% (592.4 x 0.4).
2. The total aviation emissions forecast has been increased by 14.8% from the DfT figure for reasons described in App 2. It has been assumed that this uplift applies equally to Int
and Dom - while this may not be accurate, any resulting error will be very small.
3. The 2050 target with the FOE method is a 60% cut on 1990 figures (608.1 x 0.4)
4. The 2050 target with the FOE method is an 80% cut on 1990 figures (608.1 x 0.2)



                                                                                          41
                         Appendix 4. Aviation emissions as a % of total UK greenhouse gas emissions

The following table shows in detail calculation of the % of UK GHG emissions represented by aviation in 1990, 2005 and 2050. For 2050, there are 4
different methods of calculation – see main text for the rationale. The government‟s radiative forcing factor of 1.9 x CO2 for aviation is used.

A         B                                           C                   D                    E                 F                   G                    H
Year      Scenario                                    Aviation –          Aviation -           Aviation -        UK total incl       UK incl Dom and      Aviation %
                                                      International       Domestic             Total             Dom                 Int
1990      Historical                                  29.8                2.3                  32.1              721.7               751.5                4.3
                                                      (note 1)            (note 1)             Note 1 or         (note 2)            (C+F)                (E/G)
                                                                                               C+D)
2005      Historical                                  66.5                4.7                  71.2              656.3               722.8                9.9
                                                      (G-F)                (E-C)               (K1)              (K1)                (K1 or C+F)          (K1 or E/G)
2050      DfT method                                  106.9               7.7                  114.6             288.7               395.6                29.0
                                                      (G-H)               (E-C)                (K1)              (K1)                (K1 or C+F)          (K1 or E/G)
          DfT method with FOE revision of             122.7               8.8                  131.5             288.7               411.4                32.0
          emissions (correction „a‟)                  (note 3)            (note 3)             (note 3)          (K1)                (C+E)                (E/G)
          FOE method with FOE revision of             122.7               8.8                  131.5                                 300.6                43.7
          emissions – 60% cuts (corrections „a‟ and   (note 3)            (note 3)             (note 3)                              (note 4)             (E/G)
          „b‟)
          FOE method with FOE revision of             122.7               8.8                  131.5                                 150.3                87.5
          emissions – 80% cuts (corrections „a‟ and   (note 3)            (note 3)             (note 3)                              (note 5)             (E/G)
          „b‟ and „c‟)
                                                                                     Table FOE/4
Abbreviations and codes
RF – Radiative forcing (index)
See App 2 for other abbreviations and codes
Notes
1. CO2 figures multiplied by 1.9
2. FOE does not have CHCs corresponding to CO2, which would require RF figures for sources other than aviation. However, a 1990 figure can be inferred from the DfT figure for
2050, which presumably represents a cut of 60%. The 1990 figure is thus 288.7 / 0.4 = 721.7.
3. The total aviation emissions forecast has been increased by 14.8% from the DfT figure for reasons described in App 2. It has been assumed that this uplift applies equally to Int
and Dom - while this may not be accurate, any resulting error will be very small.
4. The 2050 target corresponds to the inferred 1990 figure reduced by 60% (751.5 x 0.4).
5. The 2050 target corresponds to the inferred 1990 figure reduced by 80% (751.5 x 0.4).




                                                                                         42
                             App 5. Heathrow’s emissions
Table 3.7 of „UK passenger demand and CO2 forecasts‟ shows that Heathrow was responsible for
18.2 mt of CO2 in 2005 and is forecast to produce 24.0 mt in 2030. That is an increase in about
6mt. The increase is largely due to the effect of a third runway and the extra flights, but it is
compounded by the changes that would be expected even if there were no third runway.

Table G13 compares the CO2 emissions expected with a 2-runway airport („maximum use‟
scenario) with the 3-runway airport (scenarios „s05‟, „s12s2‟, „s12s2mm1‟ or „s12s2mm2‟). At
2030 CO2 emissions are 16mt with 2 runways and 25mt with 3 runways, a difference of 9mt. This
is the figure which has been widely quoted and has been noted as being equal to the entire
emissions of Kenya (before the current troubles).

Corresponding figures to those in Table 13 are given in Table G14 for 2050. As noted above, the
UK forecasts for 2050 are not believable as they assume a complete about-face in government
policy in 2030. While the total figures are not believable, the difference between a 2-runway and 3-
runway Heathrow should be reasonable as it depends on the respective capacities at Heathrow and
not on total demand/capacity at UK airports. At 2050 CO2 emissions are 15mt with 2 runways and
22mt with 3 runways, a difference of 7mt. The somewhat lower figures for 2050 than 2030 are
presumably accounted for by improved fuel efficiency but compounded by other factors such as
increased passenger throughput due to larger planes etc.

The 2030 figures have some validity because they compare the two most likely situations at 2030,
namely a 2-runway and a 3-runway Heathrow. But the situation at 2050 is far more hazy. The
consultation assumes that a new runway could be available by 2020 and, due to pent-up demand,
would fill up very rapidly, being full before 2030.

It is therefore reasonable to assume that BAA and the government would start pressing for a 4th
runway (and 7th terminal) to be operational around or soon after 2030. Indeed the Chief Executive
virtually gave notice of this where he said at hearing by the GLA in January 2008 that, unlike his
predecessors, he would make no promises about not expanding Heathrow further. The emissions at
Heathrow at 2050 could therefore be far higher than estimated by the DfT.

The situation could be even more extreme than a 4th runway and 7th terminal implies. The DfT
paper does not show unconstrained demand by airport, but examination of the constrained figures
suggests that there would be lobbying for a 5th runway (and 8th terminal) to be in operation by 2050.

The DfT has said that the figures for CO2 emissions at Heathrow should not be taken in isolation,
but that the impact on UK aviation emissions as a whole should be considered. Table G15 shows
that at 2030 the third runway at Heathrow would give rise 57mt for the UK (scenario „s05‟)
compared with 53mt with 2 runways (scenario „s02‟), a difference of 4mt. This assumes that there
is no second runway at Stansted (scenario „305‟). If there is a second runway at Stansted, the UK
emissions are than 59mt, a difference of 6mt. So a third runway at Heathrow adds 4mt and a
second runway at Stansted adds a further 2mt.

Table G15 also shows that effect of a third runway at 2050. Heathrow would give rise 58mt for the
UK (scenario „s05‟) compared with 54 with 2 runways (scenario „s02‟), a difference of 4mt. This
assumes that there is no second runway at Stansted (scenario „305‟). If there is a second runway at
Stansted, the UK emissions are than 60 or 61mt, a difference of 6 or 7mt. So a third runway at
Heathrow adds 4mt and a second runway at Stansted adds a further 2 or 3mt. However, as noted
above, these figures are very dubious. By 2030 there could be a 4th and 5th runway, in which case
the increase of emissions could be far higher.

                                                 43
App 6. Heathrow’s emissions as a proportion of UK aviation emissions

The CO2 emissions from Heathrow in 2005 and 2030 are shown in Table 3.7 and these can be
expressed as a % of the total UK emissions.

As noted in App 5, a figure for Heathrow in 2050 has been given in Table G15, but ignores the
possibility of a 4th and 5th runway. Also, the total UK figures forecast by the DfT is not credible
and has been amended by FOE as described in App 2.

As no figures are provided by DfT for the unconstrained demand for Heathrow, it is not possible to
calculate directly from DfT data Heathrow‟s emissions if it were expanded to meet demand up to
2050. However, rough estimates can be made.

It is clear that demand is strong at Heathrow and the DfT considers it will remain so. It is for this
reason that a new runway in 2020 would be largely full by 2025. Given this strong demand, it is
reasonable to assume that the demand for Heathrow will increase roughly at the rate that demand is
increasing elsewhere in the UK. Heathrow‟s current (2005) proportion of 48.5% of UK emissions
is already suppressed by shortage of capacity (as compared with demand) and the figure of 42.3% at
2030 is also going to be suppressed by shortage of capacity with 3 runway. It is therefore
reasonable to assume that if capacity were provided to meet all demand at 2050, the emissions at
then, as a % of the UK, could be as high as now, namely 48.5%. The table below shows the
position.

 Year                   Heathrow (mt)         Total UK aviation (mt)   Heathrow as % of UK
                                                                       aviation
 2005                   18.2                  37.5                     48.5%

 2030                   24.9                  58.9                     42.3%

 2050 - assuming no     22 (FOE figure)       69.2 (FOE figure)        31.8%
 further expansion at
 Heathrow beyond R3
 2050 - assuming        33.6                  69.2                     48.5%
 expansion to meet
 demand at Heathrow
 beyond R3

                                             Table FOE/5

Figures for total GHGs are not provided by the DfT. However, the proportion of total GHGs to
CO2 for Heathrow will be very similar to the rest of UK aviation. (There will be a slight difference
because of Heathrow‟s larger proportion of long-haul as the planes spend proportionally longer at
cruising height where water vapour and NOx cause a larger proportion of radiative forcing.)




                                                     44
  App 7. Heathrow’s emissions as a proportion of total UK emissions

The contribution of Heathrow to the UK‟s aviation emissions in App 6 above and the contribution
of aviation to the UK‟s total emissions in Apps 3 and 4 enable Heathrow‟s CO2 contribution to total
UK emissions to be readily calculated:

 Year                     DfT method - 60% cut by   FOE – 60% cut by   FOE – 80% cut by
                          2050 ignoring aviation    2050               2050
 2005                     3.1%                      3.1%               3.1%

 2050 - assuming no       6.6%                      9.1%               18.1%
 expansion at Heathrow
 beyond R3
 2050 - assuming          10.0%                     13.8               27.6%
 expansion of Heathrow
 beyond R3

                                             Table FOE/6

As noted in App 6, figures for total GHGs are not provided by the DfT. However, the proportion of
total GHGs to CO2 for Heathrow will be very similar to the rest of UK aviation. Corresponding %s
can therefore be worked out for GHGs:

 Year                     DfT method - 60% cut by   FOE – 60% cut by   FOE – 80% cut by
                          2050 ignoring aviation    2050               2050
 2005                     4.8%                      4.8%               4.8%

 2050 - assuming no       9.0%                      13.9%              27.8%
 expansion at Heathrow
 beyond R3
 2050 - assuming          14.1%                     21.2%              42.4%
 expansion of Heathrow
 beyond R3

                                             Table FOE/7

It should be noted that these could be considered under-estimates. As noted previously, government
figures and most of the figures in this response are calculated on the basis of apportioning emissions
equally between the UK and the distant country. If emissions were apportioned in proportion to the
nationality of the passengers, the % emissions would be even greater. The proportion of UK
passengers at Heathrow is 64% and is forecast to remain at that level in 2030 (Table G2). It is
therefore a reasonable assumption that it will be around 64% at 2050. Table FOE/10 (main text)
shows the large change when this approach is used to calculate national figures. There will be a
significant effect for Heathrow, but it will be less dramatic because the proportion of UK passengers
is less (64% at Heathrow compared with 73% nationally at 2050).




                                                    45