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A Government consultation document has asked for comment on the proposal to build a third runway at London Heathrow airport. The Society's response was prepared by Derek Done, a consultant on aviation matters, and was endorsed by the Sub Committee. COPY OF MARLOW SOCIETY LETTER: Freepost RRRR-TARL-ABJS Adding Capacity at Heathrow Airport (DfT Consultation) Research Services House Elmgrove Road Harrow HA1 2QG 24 February 2008 Adding Capacity at Heathrow Airport - Consultation Document The detailed responses of the Marlow Society to the questions set out in the consultation document are contained in the attached note: ‘Adding Capacity at Heathrow Airport - Responses to detailed questions 1 – 11 contained in Chapter 4 of the Consultation Document’. However, the Marlow Society feels that these questions deal with only relatively minor issues compared with the larger questions surrounding the justification for the Government’s support, albeit conditional, for the principle of a third runway at Heathrow. Although the consultation document suggests an alternative proposal that is considered to meet such conditions, this proposal still involves a (shorter) third runway and more intensive use of the existing runways, and these questions appear to us simply to be asking how much additional air and noise pollution local communities are prepared to accept. For these reasons we attach a second note: ‘Adding Capacity at Heathrow Airport – Some Unresolved Issues’ setting out our more fundamental objections to the concept of a third runway at Heathrow. Yours Sincerely, Derek Done Executive Committee Member Marlow Society LETTER ENDS _ _ _ Adding Capacity at Heathrow Airport Responses to detailed questions 1 – 11 contained in Chapter 4 of the Consultation Document 1. If a third runway is added, should it be supported by associated passenger terminal facilities? Response: No. The case for a third runway was based on the argument that more runway capacity was required to match the increased terminal capacity provided by Terminal 5. What guarantee is there that additional terminal capacity will not subsequently lead to a call for yet more runway capacity? 2. Do you agree with the Government’s view on the continuing validity of the environmental pre-conditions for policy support? Response: No. These should be tightened. As is pointed out in para 3.32 of the consultation document, ‘it is highly probable that annoyance with a particular level of aircraft noise is higher than when the last aviation noise study (ANIS) was carried out in the 1980s’. 3. Do you agree that a short third runway could be built without requiring further air quality control measures? Response: No. It is not just a matter of meeting existing air quality standards. These should be further tightened. 4. Do you agree that a third runway could be added without leading to a breach of the noise contour limit of 127 sq kms? Response: Insufficient knowledge to answer this technical question, but also see answer to Q2. 5. Do you agree that mixed mode operations could be added within the noise limits set out in the 2003 White Paper ‘The Future of Air Transport’? Response: Insufficient knowledge to answer this technical question, but also see answer to Q2. 6. To what extent would you support the introduction of mixed mode operations: a. throughout the day; b. limited to specific hours; c. within the current planning cap (i.e. with no extra capacity overall)? Response: No opinion regarding the precise periods during which mixed mode operations would take place, but since the objective of this approach is to increase the number of aircraft movements, we would oppose this as leading ‘ceteris paribus’ to an increase in movements over Marlow and its surroundings. 7. Do you agree with the Government’s view that full mixed mode operations could be introduced by 2015 and be compatible with compliance with the air quality limits in the vicinity of the airport? Response: Insufficient knowledge to answer this technical question. 8. Do you agree with the government’s views on retaining westerly preference? Response: Yes. 9. Do you agree with the government’s proposal to end the Cranford Agreement? Response: No. It is admitted that ending this agreement would adversely affect the very people it was designed to protect. What does this say about government commitment to any future agreement? 10. Do you agree with the government’s views on continuing night time rotation? Response: Yes. 11. Do you agree with the government’s view that runway alternation in the 0600 -0700 period should be retained? Response: Yes. Marlow Society February 2008 Adding Capacity at Heathrow Airport - Some Unresolved Issues ![]() Intrusive aircraft noise Why is it uncritically accepted that continued expansion of the air transport industry is essential in order to secure increased employment and economic growth, when many of the problems of the South East region are those of over-heating rather than economic stagnation? Aviation policy has to be seen as part of broader UK economic strategy. Even were it to be accepted that the UK needs a growing civil aviation sector, that does not have to mean expansion at Heathrow. The fastest growing sector of the industry at present consists of low cost carriers whose growth has taken place at other airports. From a sustainability perspective, if competing airports, either UK regional airports, or continental airports such as Paris Charles de Gaulle, are more able than Heathrow to accommodate growth, especially where we are talking about growth to meet international transfer passenger movements, then that might be the preferred option. Although benefits to such passengers were not included in the economic assessment, proponents of a third runway frequently emphasise the need for Heathrow to be a ‘hub’ airport on the basis that transfer traffic is needed in order to support a route network that serves an ever increasing number of destinations. However, passengers who change planes at Heathrow contribute nothing to the UK economy except revenue to British Airways, and Spanish-owned BAA. They also add to pressures on the environment, creating more of an impact than direct point-to-point passengers, since their journeys involve two take offs and two landings. The loss of such international transfer passengers, were it to occur in the absence of a third runway at Heathrow, might also be considered a benefit, releasing capacity to be used to meet demand from passengers originating in, or destined for, the UK. There are around 20 flights a day from Heathrow to Manchester. The train should be able to provide a realistic alternative for point-to-point traffic, but not, of course, for transfer traffic, but, if more international flights operated into Manchester, the number of Heathrow – Manchester flights could be reduced. The North is under served particularly with long haul flights. Flights serving the regions outside the South East tend to have lower yields and to be less profitable, but it is interesting to compare the situation with the USA where Delta has more transatlantic traffic out of Atlanta than JFK, not all of it transfer. Regional development policies need to encourage more regional air services. In the seventies a continuing increase in aircraft size was seen as being inexorable, but subsequently competitive pressures contributed to the move towards smaller aircraft, as service frequency became a weapon in the competitive battle. However, there now seems to be a return to larger aircraft, at least on long haul routes. This should have a largely beneficial impact in terms of a reduction in the need for additional runway capacity. The argument that an additional runway must be built to enable more people living in the South East to fly (i.e. where demand exists) is a circular argument. Good communications are needed to serve the needs of existing businesses, but it is also true that businesses move to areas offering good communication. This then requires more infrastructure and so on. If a major airport were to be built elsewhere demand would grow around it. The best place might be in a deprived location but with good links to key centres such as London. The air travel demand forecasts do not take full account of the full effect of factoring into fares and freight rates all compensation payments, such as those related to purchase of land and property, and the costs of meeting environmental targets. These costs should be calculated according to the principle 'the polluter pays', whether the incidence of such costs falls initially on airports, airlines, aircraft manufacturers or end users. All environmental costs should be taken into account, not just costs related to CO2 emissions and noise pollution. Examples include costs attributable to road congestion, visual pollution, the destruction of natural and built heritage and the impact on the health of the populations affected. The cost of 'necessary' road and rail infrastructure has been taken into account in the assessment, but it appears that no account has been taken of the environmental impact of additional traffic, unrelated to the airport development. It is not clear why the generally accepted conclusion that additional roads generate additional traffic is assumed not to apply in the case of road infrastructure aimed at improving access to airports. There is nothing to prevent such roads being used by non airport related traffic. The third Heathrow Runway Option is proposed despite assurances given at the time of the Terminal 5 Inquiry that a third runway would not be considered at any time in the future. The British Airways case for T5 included an assurance that although additional terminal capacity was required, additional runway capacity was not, since aircraft were getting larger. Both assurances have proved worthless. LETTER ENDS Marlow Society February 2008 |
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