How to respond to the Heathrow Airport expansion consultation

Heathrow Airport Ltd is currently consulting on plans to expand the airport by building a climate-wrecking third runway. The consultation closes on 13 September. Here’s the Friends of the Earth guide to having your say.

06 Sep 2019

Heathrow Airport Ltd is currently consulting on plans to expand the airport by building a third runway. This would mean 50% more flights, an extra 700 a day, and would be disastrous for the climate and air quality, as well as causing many other problems.

The consultation closes on 13 September. Here’s the Friends of the Earth guide to having your say.

Only have a few minutes?

If you only have 5 minutes to spare, copy and paste our template response into an email to [email protected].

If you have more time please do consider personalising it as many different personal responses are more effective than many identical ones.

Consultation closes 13 September 2019 – remember to have your say before then.

Have a little more time for a more detailed response?

Fantastic. It’s great that you can spare time to make a fuller response to the consultation – thank you. In the rest of this guide we’ve included some background, instructions on how to respond, and guidance on the key areas that are of most concern to Friends of the Earth.

  1. The problem
  2. What’s happening now?
  3. How to have your say
    1. How to respond
    2. Consultation response email template
  4. Further resources

The problem

If the expansion goes ahead the number of flights would increase by 50% – an extra 700 planes a day, on top of the 1,300 we already see at Heathrow. Given the climate emergency we’re facing, this would be a disaster. It would also unacceptably worsen air pollution, as well as bringing more noise pollution to more people, have ecological impacts, and destroy homes.
 

What’s happening now?

In June 2018 the government approved a third runway in principle. However, the airport expansion is far from being a done deal because the project must pass a set of tests to be allowed to go ahead. 

There will be opportunities for people to have their say during the process, including this public consultation. It’s important that Heathrow Ltd hear how damaging a third runway would be for the climate, air quality and people’s health. This consultation is a great opportunity to show them that lots of people are concerned about it.

Challenging Heathrow in the courts

As well as challenging Heathrow expansion through this consultation, Friends of the Earth and several other organisations are taking the government to court to challenge its in-principle support for a third runway at Heathrow. Friends of the Earth’s case is that the government didn’t properly consider the climate impacts on future generations of allowing a third runway, and didn’t properly comply with its sustainable development duties.

The court hearing will be at the Court of Appeal in October 2019. If Friends of the Earth’s claim succeeds, it could stop the third runway going ahead, or at least make it more difficult.

If the court case doesn’t stop the expansion, there’s still another chance to have your say when the planning application is consulted on.

How to have your say

How to respond

There are three ways to submit a written response to the Heathrow consultation – on the website, by email or by post. We recommend responding by email as the website doesn’t give you the opportunity to respond to all the relevant questions. 

To respond to the consultation by email you simply need to email your comments to [email protected] before 13 September 2019.

Details on how to respond on the consultation website or post are available on the consultation website.

Whichever method you use, we recommend your response references the question numbers the consultation uses, so your response will be clear. 

We’ve broken down our response template into the topic areas that are of key concern for this consultation for Friends of the Earth - overarching points, climate and air pollution – and listed which questions they are relevant too. Some topic areas are relevant to multiple questions. 

A full list of the consultation questions is available on the consultation website.

There are many other issues of concern in relation to Heathrow’s expansion plans including noise pollution, ecological impacts, loss of homes and more. More information on other issues is available in the No 3rd Runway Coalition’s briefing.

Consultation response email template

Use the below template response to inform your own response, edit it or copy and paste it directly to respond by email by 13 September 2019. Do try and edit it to be more personal as many different personal responses are more effective than many identical ones.

Overarching points

In response to:

  • Question 4: Please tell us what you think about our development proposals and the measures proposed to reduce effects in these areas.

I strongly object to the Heathrow airport expansion, and the expansion of any UK airport. 

We’re facing a climate emergency and people are already feeling the impacts of climate breakdown. Heathrow already has more passengers using its 2 runways than any other European airport and is the seventh busiest in the world1 . To stop climate breakdown getting worse Heathrow cannot be allowed to further increase the number of planes in the sky.

The adverse impacts of a third runway at Heathrow demonstrably outweigh the benefits and so the development should not go ahead. These negative impacts include:

  • More climate changing emissions – jeopardising the ability of the UK to meet its climate targets.
  • More traffic and air pollution – endangering health and wellbeing, and potentially breaking legal limits.
  • More noise pollution for more people - which would affect health and wellbeing.
  • Ecological impacts – local rivers are set to be diverted and local wildlife habitats will be impacted.
  • Loss of homes – thousands of homes will be destroyed or deemed unliveable.

Climate Change 

In response to:

  • Question 4: Please tell us what you think about our development proposals and the measures proposed to reduce effects in these areas.
  • Question 12: Please tell us what you think about our proposals to manage the environmental effects of expansion.
  • Question 19: Please tell us what you think of our proposed approach to manage the future growth of the airport within environmental limits. Is there anything else we should consider as we develop the framework and its potential limits?

I strongly object to the proposed expansion on climate grounds. With increased flights and associated carbon emissions I do not consider it possible to adequately reduce or manage the effects of expansion, or to manage the future growth of the airport within environmental limits.

Airport expansion at Heathrow (or any other airport) cannot go ahead if we’re to prevent further climate breakdown – the number of flights needs to be cut across the UK, not increased.

On 27 June 2019, the government legislated to change the UK’s climate targets to reach net zero emissions relative to 1990 levels by 2050 in order to meet the Paris Agreement climate targets, as recommended by the Committee on Climate Change (CCC). The CCC has recommended tighter levels for the aviation sector to achieve towards meeting the Paris Agreement targets – but a third runway at Heathrow would all but blow our chances of meeting these.

Aviation would emit more emissions than any other sector by 2050, according to the CCC’s core “further ambition” assumptions.

An expanded Heathrow alone could effectively take up all the emissions aviation should be allowed to produce if we are to meet the Paris target, leaving none for other airports.

For the UK to meet the goals of the Paris Agreement, an aviation emissions target even more ambitious than the one the CCC suggests (under their speculative option to constrain demand) is necessary. This is because the CCC targets don’t consider other climate warming emissions from aviation, such as nitrogen oxides. These emissions could double the climate impacts from flying. Heathrow expansion would make it impossible to achieve this necessary lower target.

Technology developments are not able to keep up with the growth of passenger numbers. Planes are gradually becoming more efficient and will continue to do so, but not at the pace necessary to allow for unconstrained growth in flights and passenger numbers. This means that aviation needs to be constrained and an expanded Heathrow is not compatible with this.

The proposed expansion of Heathrow Airport fails to protect the interests of future generations by compromising the UK’s ability to meet its climate targets. Intergenerational fairness is a key part of achieving sustainable development in the context of the climate crisis.

I strongly object to Heathrow saying that offsetting would be used to mitigate its emissions. The Committee on Climate Change has said the UK must meet the Paris Agreement target through domestic effort without using international offset carbon credits. In fact no offsetting should be used at all.

The vast majority of cases offsetting just don't work. A small number of projects could contribute to absorbing carbon emissions, but these should focus on offsetting those emissions which will be unavoidable (rather than avoidable leisure flights which make up the majority). Offsetting should not be used as a method for justifying an increase in avoidable emissions such as those arising from airport expansion.

Rather than seek to expand the airport, Heathrow should look to ways to ensure the existing airport operates within environmental limits.

Air Pollution

In response to:

  • Question 4: Please tell us what you think about our development proposals and the measures proposed to reduce effects in these areas.
  • Question 13: Please tell us if there are any other initiatives or proposals that we should consider in order to address the emissions from airport related traffic or airport operations.

I strongly object to the expansion of Heathrow Airport on air quality grounds.

Air pollution from Heathrow comes from flights, airport operations and traffic associated with the airport, and can pollute areas well away from the airport. It would be made unacceptably worse by the proposal.

London is already failing UK/EU legal limits on the toxic gas nitrogen dioxide. Air pollution is estimated by the Greater London Authority to be responsible for nearly 10,000 early deaths a year in the capital. Heathrow’s contribution to London’s nitrogen dioxide problem is already significant. 

London, as with the rest of the UK, is required by law to lower levels of nitrogen dioxide to below legal limits as soon as possible, and to keep them there. But even at levels below current legal limits the World Health Organisation (WHO) have found health effects2 , so levels must be continued to be driven down. Expanding Heathrow would unacceptably risk being incompatible with this. 

Heathrow’s preliminary information available for this consultation3 shows that the plan for a third runway would add to air pollution and mean unacceptably worse air quality.

The information provided shows at least one new breach of the annual nitrogen dioxide legal limits, and other areas would see a worsening of air already over this limit. Neither of these are acceptable. 

London currently fails WHO standards for the most health damaging particulate matter (PM2.5) pollution. In order for London to meet these standards the strongest action is needed, including cutting traffic. Any extra traffic from an enlarged Heathrow would unacceptably add to this problem.

WHO standards for particulate matter should be met by 2030 at the latest, yet London is forecast to still be breaching standards at this point. The WHO have found health impacts below even these standards, so levels must continue to be driven down. Expanding Heathrow could unacceptably risk being incompatible with this.

The best way to keep air pollution in areas near Heathrow within limits would be to not expand the airport.

Other ways of responding

You can also respond to the consultation by visiting the Heathrow consultation's general comment website. Here's how:

1. Visit the Heathrow consultation’s general comment website and you’ll see the first question: ‘Do you have any other comments in response to this consultation?

2. Write your response. You might like to cover some of the following points:

  • Say no to a bigger Heathrow, or any other airport expansion.
  • We’re in a climate emergency and are seeing the impacts already. To stop this getting worse Heathrow cannot be allowed to increase the number of planes in the sky.
  • The adverse impacts of building a third runway outweigh the benefits, including:
    • More climate changing emissions – jeopardising the ability of the UK to meet its climate targets.
    • More traffic and air pollution – endangering health and wellbeing, and potentially breaking legal limits.
    • More noise pollution for more people – endangering health and wellbeing.
    • Ecological impacts – local rivers may be diverted and local wildlife habitats impacted.
    • Loss of homes – thousands of homes will be destroyed or deemed unliveable. 

3. Click the Save my response button.

4. After you’ve saved your response, you’ll see the My Responses banner at the top of your screen. Click on View my responses and finish in the top right-hand corner.

5. On the next page, click Next step in the Ready to Send box in the top right hand corner of the My Responses section.

6. On the next page, click Submit my responses now in the Complete your response box. That’s it – you’re done. Thank you.

We need as many responses as possible, so it’s worth responding even if your response is short. And don’t forget responses have to be submitted before the end of Friday 13 September.

Further resources

If you have any further questions about responding to the Heathrow consultation, please contact:

  • 1https://en.wikipedia.org/wiki/List_of_busiest_airports_by_passenger_traffic
  • 2 http://www.euro.who.int/en/media-centre/sections/press-releases/2013/01/newly-found-health-effects-of-air-pollution-call-for-stronger-european-union-air-policies
  • 3https://aec.heathrowconsultation.com/documents/peir-vol3-chap7-airqual/
Heathrow