Old Chiswick Protection Society calls for stronger evidence and safeguards in Heathrow expansion policy

Old Chiswick – Photograph of the day by Bridget Osborne

Church Street, Old Chiswick

Residents of Old Chiswick add their voices to the long list of organisations and individuals raising concerns about adding a third runway to Heathrow

Old Chiswick Protection Society (OCPS) has submitted its response to the Government’s consultation on the draft Heathrow Expansion National Policy Statement (HENPS), calling for the proposed policy framework to be strengthened before it is adopted.

The Government launched the public consultation over the expansion of Heathrow at the beginning of the summer. OCPS and the Bedford Park Society have both urged their members to submit their comments to the consultation. Old Chiswick and Bedford Park are both areas of Chiswick not currently overflown, which would find themselves on a flight path if the expansion goes ahead.

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OCPS’s response does not challenge Heathrow’s established role as the UK’s major international hub and its need to remain competitive. Instead, it questions whether the HENPS contains sufficient evidence and information to guide decision makers and whether it can do better in providing adequate protection for communities and the environment.

Economic case needs stronger evidence

The response identifies a number of concerns with the evidence supporting the expansion case, including differing methodologies for assessing benefits and disbenefits, potential double counting, assumptions which are not sufficiently supported by evidence, and contradictions between some of the claims made.

OCPS therefore considers that the economic case could be strengthened by ‘more robust and transparent’ evidence.

The leaders of Richmond, Wandsworth, Southwark, Hillingdon, Kingston, Sutton and Windsor & Maidenhead councils have also written to the Transport Secretary making the same point, amongst others, while Mayor of London Sadiq Khan has stressed the impact the expansion would have on London in terms of air pollution and traffic congestion – points which have been made repeatedly by MP for Hammersmith & Chiswick, Andy Slaughter.

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Heathrow Airport

The four tests should afford future-proofed protections

The draft HENPS proposes four tests for expansion: economic growth, climate change, air quality and noise.

OCPS’s assessment concludes that the tests should provide sufficient longer-term assurances.

On air quality, the draft policy could result in deterioration in air quality provided that new legal breaches are not created and existing breaches are not materially worsened. OCPS considers that stronger monitoring and measurement requirements are needed as Heathrow’s footprint expands.

On noise, OCPS notes that Heathrow already affects more people with aircraft noise than any other airport in the UK or Europe. While newer aircraft are already quieter, expansion will increase flight numbers and alter flight paths, runway patterns and periods of respite. OCPS also notes that the proposed policy introduces few new requirements for noise mitigation and calls for additional noise monitoring.

On climate change, OCPS argues that the policy needs to address the economy-wide risks, consequences and mitigations of expansion more rigorously, particularly given the scale of emissions reductions required across the UK post implementation.

Cumulative impacts need to be properly assessed

‘A central concern is that the proposed third runway cannot be considered in isolation’ the Society says.

The expansion would coincide with major works associated with Heathrow’s wider modernisation programme, including terminal expansion, changes to existing terminals and major road and tunnel works. These projects will be delivered in phases, but together they amount to the rebuilding and expansion of a substantial part of a major airport while it continues operating.

OCPS recommends that the combined effects of these projects, including their consequences for local roads, communities and the environment, are explicitly recognised in the HENPS rather than left largely to later project-level assessment.

Heathrow Airport

Surface access must be addressed

OCPS also questions the proposed passenger public transport mode-share target.

READ ALSO: Government launches ‘Strategic Vision’ for transport to an expanded Heathrow Airport

Public transport currently accounts for around 45% of Heathrow passenger journeys, yet the proposed target is only 50%, rising to 55%. OCPS considers this insufficiently ambitious for an expansion of the scale envisaged, particularly given the need to reduce emissions and congestion.

The response also asks for improved rail connectivity and the wider transport network to be taken into account.

Questions over Critical National Growth Infrastructure designation

The draft HENPS proposes designating Heathrow expansion as Critical National Growth Infrastructure (CNGI), creating a policy presumption in favour of the development.

OCPS believes that this makes the quality of the underlying evidence particularly important.

If the economic and strategic case for expansion is subsequently found to have been overestimated, or if external circumstances change, the CNGI designation could reduce the weight given to significant environmental, health, heritage and community impacts.

The Society therefore asks that the Government ensure the case for expansion is demonstrably robust before such a strong policy presumption is established.

Photograph of the day by Bridget Osborne

Chiswick Mall

Heathrow’s importance as an existing international hub does not remove the need for rigorous scrutiny of the case for expanding it

OCPS’s overall conclusion is that the draft HENPS contains useful information and provides a framework for future decision-making but should be convincing that the best outcome for the country, affected communities and the environment will be achieved.

The Society therefore asks that the document contains:

• stronger evidence supporting the economic and strategic case for expansion;
• more rigorous assessment of cumulative and combined impacts;
• stronger air-quality and noise monitoring requirements;
• more ambitious public transport targets and proper assessment of wider rail connectivity;
• clearer assessment of national and regional impacts;
• and greater clarity over how significant environmental and community impacts will be weighed against the proposed benefits.

OCPS believes that Heathrow’s importance as an existing international hub does not remove the need for rigorous scrutiny of the case for expanding it:

‘The greater the policy presumption in favour of expansion, the more important it is that the evidence supporting that presumption is robust, transparent and capable of standing up to detailed examination’.

Photograph of the day by Bridget Osborne

Old Chiswick