аЯрЁБс>ўџ ўџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџмЅhcр e€A.й9A+8Ш8ШШ8Ш8Ш8Ш8Ш8м8м8м8м8м8м8 ц8м8ў81ќ8ќ8ќ8ќ8ќ8ќ8ќ8ќ8ќ8ў8ў8ў8ў8ў8ў8/9X‡9Rў8Ш8ќ8ќ8ќ8ќ8ќ8ў8ќ8Ш8Ш8ќ8ќ8ќ8ќ8ќ8ќ8Ш8ќ8Ш8ќ8ќ8ѓPУMЏТм8м8Ш8Ш8Ш8Ш8ќ8ќ8ќ8ќ8FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UK BRIEFING FOR WEST LONDON Introduction A number of Non Governmental Organisations, including the Aviation Environment Federation (AEF), Transport 2000 (T2000), Friends of the Earth (FOE), Heathrow Association for the Control of Aircraft Noise (HACAN), Royal Society for the Protection of Birds (RSPB) and the Council for the Protection of Rural England (CPRE), are putting together a series of briefings on the consultation. Their aim is to inform their members and other parties as to the key issues and thereby help them to make informed and effective responses. This document is a special Heathrow- and West London-orientated briefing, which has been extracted from the emerging more detailed briefings. Key messages The NGOs are advising members not to respond to the questionnaire. The questions are ‘leading’ because they offer false and unnecessary choices which will elicit apparent support for massive and environmentally damaging expansion. People should make their own comments on the issues they consider important. The entire consultation is predicated on huge demand figures (180m passenger pa now to 500m in 2030 nationally; 114m now to 260m in 2030 in the SE.) This apparent demand is inflated because air travel is, in effect, hugely subsidised. It has been estimated that if air travel were to pay its ‘external costs’ and exemptions such as tax-free fuel and no VAT were removed, over half of the ‘forecast’ growth would evaporate. Respondents are urged not to say ‘just meet the demand somewhere else’. If people at, for example, Stansted or Cliffe also say put it elsewhere, the responses from the Heathrow and other locations will negate each other. The government will just claim we are all ‘nimbys’ and will feel it justified in imposing runways where it wishes. Respondents should resist ‘divide and rule’ tactics by challenging the forecasts and the need to meet such huge levels of growth. The adverse impacts around Heathrow can and should still be emphasised. Particular Heathrow issues Impacts are based on low assumed levels of throughput (89m passengers pa with two runways; 116m with three runways.) At the Terminal 5 inquiry it was widely accepted that 100m with two runways was a reasonable forecast. The rate of growth since then suggests that this is, if anything, an under-estimate. Alternative scenarios with at least 100m passengers for two runways and 127m passenger for 3 runways (100 + 116 – 89) are needed. More passengers and more flights, together with the extra road traffic, means greater environmental impacts. Air quality assessments are only conducted in term of EU directives which, for PM10 are far less stringent than the original UK standards. Those standards were set to protect human health. Only the effects of PM10 and other pollutants very close to Heathrow are considered. The effects of most of west London are ignored, despite the fact that in many areas, the pollution already breaches standards set to protect human health. Noise is based on the 57 dB (decibel) noise contour and flawed Leq (Loudness Equivalent) measure. Judging by these measures, the great majority of west London is ‘not affected by aircraft noise’. Very little of any borough except Hounslow is affected by noise and even with a third runway, with more incoming and outgoing flight paths over a wider area, the great majority of west London would still apparently ‘not be affected’. Impacts on wildlife, habitats and biodiversity are dismissed – “there are no high impacts”. As well as extensive loss of wildlife and habitat near the R3 site, there will be renewed pressure for road widening, extra demands for housing, warehousing, car parks, etc which threaten Green Belt and other open land. The consultation notes “ .. it is unlikely that the housing requirements or the employment land requirements could be met without loss of Green Belt to expanded urban areas”. . Public safety is ignored as far as almost all West London is concerned; only areas in and around the small ‘Public Safety Zone’ are considered. The risk of a major accident in West London – eg an aircraft crashing into a tower block – must be appreciable. Forecasts of extra road traffic are not made and congestion on the roads and railways is barely addressed. There is no policy to effect a major shift away from car access to Heathrow, so there would clearly be increases in traffic and congestion. The consultation is full of wild and unbalanced claims about economic and employment benefits of airport expansion. The reality for most of West London is that R3 would put more pressure on the labour market for local employers, increase costs for business, encourage migration into the region, drive up house prices and make it harder to obtain key workers such as police and nurses. Runway 3 would require more terminal capacity, ie beyond T5 . The consultation says, somewhat blandly “The additional terminal capacity (beyond Terminal 5) which would be needed to support a new short runway is assumed to be provided through reconfiguration of the Central Terminal Area – Terminals 1,2 and 3 – and the space between the existing runways at Heathrow and to the south of the airport site near Terminal 4.” The experience of Terminal 5 belies such assumption. Far more likely is that that a glamorous new terminal, with a huge shopping mall like T5, will be proposed either just east or just west of the link between R3 and the rest of Heathrow. T6 would have an additional impacts and this means that the impacts given for R3 are an under-statement of the real position. The current proposal is for a short runway. But as soon as this is built, one could expect lobbying for extension to a full length one in order to meet the unfulfilled demand. A full-length runway, together with the extra terminal capacity, could further increase the impacts. General issues 1 Sustainability 1.1 No definition of what it means in the context of air travel. 1.2 Consultation infers that environmental impacts can increase without limit, yet still be sustainable. 1.3 Mitigation, limitation and minimising of impact does not ensure that aviation is sustainable. 2 Noise 2.1 Use of 57db cut-off for noise disturbance means that the demonstrable noise nuisance beyond the 57dB contour is ignored (notwithstanding 54dB sensitivity test). 2.2 Leq does not measure nuisance well, eg increasing flight numbers offset by small reductions in noise of each plane. 3 Air pollution 3.1 Reference is only to EU standards; nothing about original UK standards. 3.2 Ozone not mentioned. 3.3 Nothing directly about health and nothing about non-human health impacts (which are not addressed by EU standards). 3.4 Nothing about relationship with Air Quality Management areas (AQMA) or Action Plans. 4 Climate change 4.1 Only effects of CO2 discussed in detail; H2O and NOx ignored or given little emphasis. 5 Biodiversity 5.1 Major losses of wildlife and habitat dismissed as not “high” impact. 6 Safety 6.1 Emphasis on PSZ (Public Safety Zones) – total or ‘societal’ risk ignored. 7 General environment 7.1 Consistent understating and playing down of environmental issues. Only environmental “concerns”, which implies they are not intrinsically important (unlike, say, the economy). 7.1 Nothing on approaches to limiting impact eg ‘environmental bubbles’, regulatory measures as allowed by EU, or punitive compensation. 7.2 Reliance on estimates and promises on improvements in emissions. Expansion should be conditional on the improvements being realised. 8 Demand 8.1 Treatment of demand as a ‘given’. Lack of emphasis that it depends entirely on all sorts of assumptions and policies, many of which are under government control. 8.2 Demand assumes that ‘Polluter Pays’ policy will be ignored. 8.3 Most of the demand is for ever-shorter holidays. Thus total size and growth has few implications for business travel and resultant claimed economic benefits. 9 Employment 9.1 Unnecessary reference to jobs in and associated with the aviation industry. It is considered by economists and accepted by government that the total employment is not affected by the amount or growth of air travel. The emphasis on (national) employment is gratuitious and clearly intended to lead the reader into supporting growth. 9.2 Jobs generated by airport growth will only reduce unemployment if a whole set of conditions are met. This is not spelt out. 10 Economics – general issues 10.1 Complete unbalance in that benefits are emphasised while corresponding disbenefits are ignored. Eg business travel can bring investment and money into the UK, but by the same token it can take it out. Eg tourism brings money in but it takes it out (and much more). 10.2 Gratuitous reference to economic benefits without supporting evidence. 10.3 The ‘contribution’ of aviation in terms of its % of GDP is irrelevant to the debate. Like employment, the mere volume of economic activity in aviation makes no difference to the size of the economy. (It is only the extent to which aviation increases productivity in other sectors that a general economic benefit can be claimed.) 10.4 An increase in Ѓ100 is given in the price of a ticket if the extra capacity is not provided. This is misleading as it depends on a series of assumptions which are not explained, still less justified. Even accepting all the assumptions, this would only be the increase in a longish return flights in 2030. 10.5 Estimate of benefit of extra capacity or cost of constraints ignores external cost (and maybe other things too). 10.6 Tax avoidance, eg no fuel tax and no VAT, invalidates calculations of costs and benefits. 11 Economics – external costs 11.1 Main scenario based on assumption of no ‘Polluter Pays’. 11.2 CO2 costs confusing. 11.3 Other greenhouse omitted or not fully covered. 11.4 Other environmental costs not covered properly or at all. 11.5 Noise costs too low (AEF study). 11.6 Non-environmental costs, eg road congestion, safety and bringing in disease, ignored. 12 General issues 12.1 Hype about growth, success etc as if growth in aviation is a good thing in its own right. 12.2 Use of “competition” argument without supporting evidence. Further information From more information, see the Airport Watch web site www.airportwatch.org.uk . On the site can be found a number of briefings covering the various issues raided by airport expansion. (Some briefings are still in course of preparation and are therefore not yet posted. The site should therefore be re-visited periodically.) If you would like to register an interest and be kept up to date, you can register on the web site or phone 020 7248 2223. 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