Environmentally Managed Growth€¦ · Heathrow – but only if those effects could be managed within acceptable limits. 1.1.6 Whilst we have based our assessment of operational effects

Classification: Public

ENVIRONMENTALLY MANAGED GROWTH

OUR FRAMEWORK FOR

GROWING SUSTAINABLY

JUNE 2019

Heathrow Expansion Airport Expansion Consultation

2 © Heathrow Airport Limited 2019

Environmentally Managed Growth

AIRPORT EXPANSION CONSULTATION (JUNE 2019)

Heathrow is consulting on proposals for an expanded airport.

The Airport Expansion Consultation is our statutory consultation and we will be seeking

your view on four key areas:

• Heathrow’s preferred masterplan for expansion: our proposals for the future

layout of the airport including the runway and other airport infrastructure such as

terminals and road access. The masterplan will also reveal the airport’s growth

in phases – from runway opening in around 2026, to the end masterplan in

approximately 2050;

• Plans to operate the future airport: how the future three runway airport will be

operated, including important elements such as night flights, as well as how

potential additional flights before the new runway opens could be operated on

our existing two runways;

• Assessment of impacts of the airport’s growth: our preliminary assessment of

the likely impacts of expansion on the environment and local communities;

• Plans to manage the impacts of expansion: we will set out the airport’s plans for

mitigating the effects of expansion, including property compensation, our Noise

Insulation Policy, a Community Fund, and measures to mitigate against air

pollution, carbon, and other environmental effects.

We are grateful for feedback provided at previous consultations, and have considered

these responses in developing our proposals. We now ask for your views on our preferred

proposals, so that we can further improve our project before we apply for development

consent next year. You can provide feedback:

• online using the feedback form on our website aec.heathrowconsultation.com • complete a feedback form, available at events or on request calling 0800 307 7996 • email us at [email protected] • write to us at Freepost LHR AIRPORT EXPANSION CONSULTATION

We have set out our proposals in a number of documents covering different topics and

different levels of detail. All of these are available on our website, at Document Inspection

Locations and at consultation events.







EXECUTIVE SUMMARY

This document sets out the proposed framework for Environmentally Managed Growth at

Heathrow.

Environmentally Managed Growth (or EMG) is a new concept for UK airports, although

there are precedents overseas. It means that throughout our planned growth and into the

future, Heathrow will always operate within clear, defined environmental limits.

This commitment responds to our sustainability strategy Heathrow 2.0 published in 2017

and it reflects our vision for sustainable growth. It is also consistent with the conclusions

of the Airports Commission and with the Government’s policy that supports the

development of Heathrow’s north-west runway, on the condition that clear environmental

limits can be observed.

Some who object to the expansion of Heathrow doubt that those environmental conditions

are achievable but our work shows that they are and we intend to put the matter beyond

doubt by formally committing to them.

The conditions relate to the effects arising from the growth in airport operations that would

follow the grant of DCO consent – those effects relate to:

- Air noise;

- Air quality;

- Surface access (transport); and

- Carbon

The Airports NPS contains clear polices which we propose to turn into defined limits or

envelopes, creating a framework within which the airport would be obliged to operate.

To achieve our forecast growth, therefore, we will be incentivised to drive continuous

improvement in the environmental performance of the airport and to invest in measures

which mitigate the effects of growth, such as public transport improvements.

Environmental performance would be central to the way in which we run the airport in the

future and our objectives would be closely aligned with those of our local communities.

Those communities would be given confidence that the approved effects of expansion

would never be exceeded.

To operate the framework effectively we will commit to a rigorous and transparent

monitoring process, which would be independently reviewed – and we propose that an

Independent Scrutiny Panel (ISP) is established to hold us to account.




The membership of the ISP would be established after this consultation through

engagement with key stakeholders including the HSPG local planning authorities and the

Heathrow Community Engagement Board. The ISP would be given binding powers of

enforcement through the terms of our DCO approval.

This document explains the approach proposed. The idea is clear and we welcome the

challenge that it presents – but we want to hear your views to help us develop the detail.




CONTENTS

EXECUTIVE SUMMARY 4

1. Introduction 7

2. Managing airport growth 9

2.2 UK best practice and policy 11

2.3 International examples 14

3. Environmental limits 18

3.1 Airports NPS environmental policy requirements 18

3.2 Surface access 19

3.3 Air quality 20

3.4 Aircraft noise 21

3.5 Carbon 22

3.6 Other effects of growth 23

4. Monitoring growth and operation 25

4.1 Monitoring 25

4.2 Independent Scrutiny Panel 25

4.3 Implementing this framework 27

5. Wider environmental monitoring and management 30

Appendix A: Proposed Environmental Limits A1

Appendix B: Unforeseen Local Impacts Mitigation Strategy (ULIMS) B1

Appendix C: First Draft Constitution for the Independent Scrutiny Panel C1




1. INTRODUCTION

1.1.1 This document sets out the proposed framework for Environmentally Managed

Growth at Heathrow. A document based on this approach would be prepared and

submitted as a formal part of the Development Consent Order (DCO) application.

1.1.2 Heathrow’s DCO application and its accompanying Environmental Statement will

contain a series of measures to assess, limit and manage the environmental

effects of the development and operation of the airport.

1.1.3 Many of those effects arise from the construction and physical development of the

new runway and associated development. The DCO will include a comprehensive

set of requirements and obligations to ensure that those effects are limited,

mitigated or compensated.

1.1.4 One particular aspect of the effects of Heathrow’s expansion, however, arises from

the progressive growth in the operation of the three-runway airport – effects from

aircraft operations or from colleagues, passengers and others travelling to and

from the expanded airport. Those effects will change over time and they will vary

with the pace of the growth in airport operations, which itself may alter depending

on the strength of demand and wider economic factors.

1.1.5 It is those operational effects (such as the effect of aircraft noise, traffic and

emissions affecting local air quality) which were the subject of particular attention

in the work of the Airports Commission and in the work of the Government during

the process of preparing the Airports National Policy Statement (Airports NPS).

The Airports Commission and the Government supported the third runway at

Heathrow – but only if those effects could be managed within acceptable limits.

1.1.6 Whilst we have based our assessment of operational effects on the best available

forecasts, circumstances may change. To manage these changes we have

considered, how we can commit to a series of environmental limits or “envelopes”,

which we can guarantee will not be exceeded in the long term.

1.1.7 Our objective is effectively to establish a series of envelopes which will ensure that

the airport will operate remain within limits – and that those limits are defined by

reference to the policies of the Airports NPS.

1.1.8 To ensure that those envelopes will be adhered to into the long term, a regime is

necessary to monitor and report on effects and ensure that they remain within the

relevant envelopes.

1.1.9 This framework identifies in draft the potential limits to which Heathrow could

commit, in order to ensure that the maximum effects of the expansion of the airport

do not exceed those considered acceptable having regard to Government policy.




1.1.10 The document describes a proposal for how the monitoring and enforcement

regime could work, to ensure the limits are adhered to, and to guarantee

transparency and clear reporting for local communities and other interested

parties. It is structured as follows:

Chapter 2: Managing airport growth:- this chapter provides relevant

background, including a review of UK and international policies and

precedents.

Chapter 3: Environmnetal Limits: - this chapter discusses the limits that might

be put in place.

Chapter 4: Monitoring growth and operation:- this chapter suggests how the

framework might operate and be enforced.

Chapter 5: Wider environmental monitoring and management:- this chapter

explains how the framework relates to other measures which manage

other aspects of Heathrow’s environmental performance.

The document is supported by a series of more technical appendices.




2. MANAGING AIRPORT GROWTH

2.1.1 Heathrow is committed to expanding the airport sustainably and responsibly. To

ensure we achieve this, to give local communities confidence in our plans, and to

achieve compliance with the Airports NPS, we intend to put in place a regime to

limit and control the environmental effects of the operation of the expanded airport.

2.1.2 Expansion at Heathrow is not a choice between the economy and the environment

– it must deliver for both. Heathrow is committed to a series of measures, including

environmental limits or “envelopes” within which the growth of aircraft operations

at Heathrow would be monitored and managed, subject to the granting of DCO

consent for Heathrow Expansion.

2.1.3 This framework provides the mechanism to ensure that the main operational

effects of Heathrow’s growth will remain within acceptable environmental limits,

having regard to the Airports NPS.

2.1.4 This approach is consistent with the conclusions of the Airports Commission and

of the Airports NPS itself, which supports the development of the north-west

runway, on the condition that environmental limits can be observed.

2.1.5 The timeline below explains the relevant background.

Sustainable Growth Within Limits

July 2015 – Airports Commission publishes final report recommending

the expansion of Heathrow with a new north-west runway, but only with a

“comprehensive package of accompanying measures” to make expansion

more acceptable to local communities, including a specific commitment that

expansion must be delivered within environmental limits.

May 2016 – Heathrow accepts the Airports Commission’s

recommendations, including a commitment to grow within environmental

limits as well as more specific commitments such as an extended night flight

ban on scheduled flights, a legally enforceable noise envelope, and creating

an ultra – low emissions zone for airport vehicles by 2025. Heathrow also

calls for the Environment Agency to provide independent scrutiny on air

quality and states its support for an Independent Aviation Noise Authority

(later to be committed to by Government as the Independent Commission on

Civil Aviation Noise – or ICCAN).

October 2016 – Government confirms support for Heathrow expansion -

the Secretary of State makes clear that expansion “will only be allowed to




proceed on the basis of a world class package of compensation and

mitigation”.

February 2017 – Heathrow launches its new sustainability leadership

strategy Heathrow 2.0, which sets out a comprehensive plan to meet

demand in a way that creates a positive impact on our community,

environment and economy.

June 2018 – Designation of the Airports National Policy Statement for

Heathrow expansion: parliament votes in favour by a large majority, with

the Airports NPS stating the need for “strong mitigations” to limit the impacts

of expansion and setting out clear criteria for an expanded Heathrow’s

environmental performance.

2.1.6 This framework formalises Heathrow’s commitment to operate within defined

environmental limits that accord with the relevant requirements of the Airports

NPS. It establishes comprehensive and transparent monitoring and enforcement

processes for the long term. It commits Heathrow to a future in which managing

the airport’s environmental effects will be central to day to day and longer term

strategic decisions about how the airport operates and grows.

2.1.7 The Environmental Statement accompanying the DCO application required for

expansion will set out a comprehensive assessment of the likely significant effects

arising from the development and operation of a three runway Heathrow. The

DCO will include detailed provisions and requirements, which will act together with

appropriate commitments in a section 106 Agreement to limit and manage the

impacts of Heathrow’s expansion.

2.1.8 The framework set out in this document complements those measures by putting

in place an effective long-term monitoring and management regime to assure that

the effects of Heathrow’s long-term growth permanently remain within acceptable

limits having regard to Government policy as set out in the Airports NPS. The

regime will hold Heathrow to account. It will mean that the effects of the growth of

the airport’s operations will always stay within environmental limits. It will involve

clear and transparent reporting, so that local communities and the general public

can understand the effects of our operation. It is aimed at creating public

confidence and trust between the community and the airport, that the effects of the

growth of the airport’s operations will always stay within clear environmental limits.

2.1.9 To do this, this framework defines environmental limits, or envelopes, for the

airport related to these four aspects:

• Surface access (traffic);




• Air quality;

• Aircraft noise; and

• Carbon.

2.1.10 As set out in section 3 below, the precise environmental limits proposed for

inclusion in the DCO application will be finalised following feedback from this

consultation, ongoing engagement and the completion of the Environmental

Impact Assessment.

2.1.11 These four aspects are selected because they represent the main effects that

arise from growth in operations (increased throughput of passengers and aircraft)

at the airport, rather than its construction or physical land use impact. It is these

effects which will increase as the use of the expanded airport intensifies, unless

they are mitigated. This is reflected in what is said about each of these effects in

the Airports NPS.

2.1.12 This framework sets out a regime which guarantees that those effects will remain

within acceptable limits, in accordance with the principal environmental policies in

the Airports NPS into the long term.

2.1.13 This issue of how to control long term operational effects is common to any newly

consented airport capacity around the world. The following sections set out the

findings of research into national and international best practice.

2.2 UK best practice and policy

2.2.1 The small number of airports in the UK and the relatively limited number of

planning permissions that have been granted for airport expansion in modern

times, means that the UK does not offer the best examples of ways in which to

manage airport growth within environmental limits.

2.2.2 The most traditional approach in the UK has been to impose a cap, or upper limit,

on air transport movements (ATMs).

2.2.3 The cap approach was adopted in 2001 as part of Heathrow’s planning permission

for Terminal 5. This limited the airport’s annual operational capacity to 480,000

ATMs (see the box below).

Imposing a capacity cap is a crude measure which provides no incentive to

continually enhance environmental performance as an airport grows. Once a cap

has been reached there is no ongoing incentive to continuously reduce effects.




Current planning caps at Heathrow

Heathrow Airport is currently limited to no more than 480,000 ATMs per

year as a condition of the 2001 Terminal 5 planning permission (the T5

cap). Heathrow is required to report its ATM numbers annually to the Local

Planning Authority. These submissions show that ATMs have been close to

the capped level for many years, albeit with a dip in numbers due to the

economic downturn in 2008 and a spike coinciding with subsequent recovery.

Graphic 2.1 Heathrow ATMs over time

Although Heathrow has always complied with the ATM cap, this method of

control does not drive sustainable growth, it provides no incentive for

Heathrow or its airlines to operate in an environmentally sustainable manner

or to innovate to achieve environmental performance improvement targets.

As written, the cap only requires Heathrow to keep its annual ATMs below a

numerical ceiling. Improved performance would not enable more flights, even

if the noise or other environmental impacts of the airport were reducing.

2.2.4 The Airports NPS does not seek to cap the number of aircraft movements at an

expanded Heathrow. In fact, the Airports NPS calls on Heathrow to bring forward a

scheme “enabling at least 260,000 additional air transport movements per

annum”.1

1 Airports NPS paragraph 1.15

445,000

450,000

455,000

460,000

465,000

470,000

475,000

480,000

Heathrow Airport ATMs




2.2.5 Capping the number of air transport movements would not be consistent with the

objectives of the Airports NPS – expansion of Heathrow is supported in the

Airports NPS because of the national economic benefit which additional flights

bring. It is Heathrow’s view that a cap on the effects of ATMs is more effective for

reducing environmental impacts than a crude cap on the number of ATMs. An

environmental cap – which is essentially what a cap on effects would be – would

limit effects of growth to those which are acceptable having regard to the ANPS.

2.2.6 For this reason, the Airports NPS requires the applicant to put forward plans for a

‘noise envelope’.2 The Noise Envelope is described further in our consultation

document Future Runway Operations, and Appendix 17.1 Annex A to Chapter

17: Noise & Vibration of the Preliminary Environmental Information Report

which is also published as part of this consultation. The use of environmental

envelopes or caps, rather than caps on the numbers of flights is directly

encouraged in the Government’s Aviation Policy Framework (the APF).3 The APF

explains that the Government wants to incentivise noise reduction and mitigation

and expects that ‘the future growth of aviation should ensure that the benefits are

shared between the aviation industry and local communities’.4 The APF explains

that the use of noise envelopes would “give certainty to local communities about

the levels of noise which can be expected in the future and to give developers

certainty on how they can use their airport” .5 The APF committed that the

Government would bring forward measures in the Airports NPS with ‘the objective

of incentivising airlines to introduce the quietest suitable aircraft as quickly as is

reasonably practicable’ .6

2.2.7 This commitment is made good at paragraph 5.60 of the Airports NPS which

requires a noise envelope to be designed at Heathrow in consultation with

stakeholders and the local community so that;

“…the benefits of future technological improvements can be shared between

the applicant and its local communities, hence helping to achieve a balance

between growth and noise reduction.”

2.2.8 This framework delivers on the Airports NPS requirement by committing to a noise

envelope, (the design of which is being informed by detailed engagement with an

independently chaired Noise Envelope Design Group) but goes further by

additionally committing to envelopes for air quality, carbon and surface access.

2 Airports NPS paragraph 5.60 3 Cm 8584 2013 4 APF paragraph 3.3 5 APF paragraph 3.29 6 APF paragraph 3.29.




2.2.9 Directly in line with the Government’s objectives, these envelopes or limits would

enable the airport to continue to grow, i.e. handling more flights and passengers,

as long as the environmental envelopes or limits are not exceeded. This

commitment gives certainty to Heathrow’s local communities, local authorities,

Government, and wider stakeholders who will know what the maximum effects of

Heathrow’s growth will be into the long term. It also incentivises both Heathrow

and its airlines to optimise their environmental performance, so that the airport

operations can continue to grow within those envelopes or limits.

2.2.10 The effect of this framework is to encourage airlines to operate the best performing

aircraft on Heathrow routes and drive further technological innovation to reduce

effects. The framework has the effect of incentivising Heathrow to adopt

operational measures to optimise the number of flights and passengers that the

airport can host. It also encourages Heathrow to invest in measures or commercial

strategies which mitigate the effects of growth, such as investment in public

transport.

2.2.11 This approach is aligned to the most up to date Government policy set out in the

emerging Aviation Strategy green paper, which proposes the use of noise caps to

balance noise and growth with appropriate compliance mechanisms in place. The

draft explains:

“…a noise cap (also known as a noise envelope) is any measure which

restricts noise. In its crudest form this could be a simple movement cap, but

the Government proposes advocating caps which are based on setting

maximum noise exposure levels (such as a contour area or noise quota)."

2.2.12 Additionally, the emerging Aviation Strategy explains:

“The Government wants to explore mechanisms by which airports could ‘pay’

for additional growth by means of local compensation as an alternative to the

current sanctions available.”7

2.2.13 This framework suggests that additional growth is ‘paid for’ through enhanced

environmental performance.

2.3 International examples

2.3.1 Outside of the UK, an approach which unlocks growth through environmental

performance is not unusual. Airports such at Paris Charles de Gaulle, Amsterdam

Schiphol and Vienna all use independent bodies to scrutinise, arbitrate and make

recommendations to Government on the acceptable growth and operation of their

airports. More information can be found from the examples below which show both

7 Cm9714 Aviation 2050 The future of UK aviation, December 2018 paragraph 3.115




how noise limits can be used to control or share the benefits of growth and how an

effective monitoring and operational partnership can be established between an

airport and its community.

International Best Practice Examples

The Schiphol Environment Council (formerly Alders Platform)

In 2003 Amsterdam Schiphol Airport opened its fifth runway which brought

concern from local communities. It was immediately apparent that adverse

effects were being experienced in areas of higher population densities due to

different uses of the new runway system. Although the Dutch Government

had consulted with communities and capped both the total number of ATMs

and applied an Lden noise contour, these measures had not adequately

safeguarded against the impacts of the new runway.

In 2008, Hans Alders, Dutch politician and a former Environment

Minister, was identified by stakeholders as a suitable candidate to

consider airport growth and build consensus about how it should be

achieved. The Alders Platform was established with the objective of

bringing together all key parties affected by and influencing the impacts

of Schiphol Airport together to find one common solution. The Alders

Platform was established to de-politicise the process and focus more on

the needs of key stakeholders.

The Alders Platform is now called the Schiphol Environment Council and

advises the Dutch Government on the operation and growth of Schiphol

Airport. It has two high level objectives; (i) To maintain a strong ‘main port’

with a thriving hub carrier, and (ii) to reduce noise around the airport. The

Council is structured around an Advisory Board and Regional Forum led by

one chairman. These fulfil the following roles:

• Advisory Board – responsible for negotiation and advice on

development of Schiphol and surrounds.

• Regional Forum - provision of information and dialogue with wider

Schiphol area.

Membership of the Council is only allowed on the basis that members will

positively contribute to the discussion about the development of Schiphol or

the living environment.

The Schiphol Environment Council is a good example of how local

stakeholders can be empowered to hold the airport to account. The




most recent issue for the Council has been the growth of the airport

beyond the 500,000 ATM cap. Stakeholders recognise that quieter

technology could enable growth without exceeding specified limits and

have been discussing an approach in which 50% of the potential

capacity gains due to the use of quieter technology will not be used by

the airport but will instead be ‘returned to the community’.

Vienna Airport Dialogue Forum

The Vienna Airport Dialogue Forum came about in response to the planned

expansion of Vienna Airport. The Forum began as a ‘mediation’ process

between the airport, its anchor airline and communities when the

Airport’s expansion masterplan was first revealed in 1998. This mediation

process eventually evolved into a formalised Dialogue Forum in 2005 through

the drafting of ‘contracts’ between stakeholders to ensure goals could be

achieved and compromises accepted. Initially, building trust in the process

was the difficult first step. However, the key to unlocking this trust issue was

for Vienna Airport to make available extensive information regarding the

planning and requirements for its expansion proposals. This trust building was

set in the context of a 10-year legal process to secure the expansion of the

airport.

The overall purpose of the Forum is to address issues and conflicts related to

air traffic and expansion plans. Ultimately the Forum is a ‘conflict solving

platform’ based on the wider implications of airport operations and growth,

focused on areas of economy, ecology and social issues. The aim is to find

consensus between airport, airlines, government and communities and to

ultimately resolve the following:

• operational measures are to be agreed between aviation industry, local

government and communities;

• as are measures that might exceed minimum legislative requirements;

• to hold the airport to account by checking compliance with agreements

and propose further measures; and

• to evaluate and monitor initiatives that have been agreed and

implemented.

The Forum is structured around topic specific working groups focused on area

such as noise, air quality, flight paths and the environment fund. These

working groups are led by technical experts and are focused on presenting

practical solutions. The other main branch of the Forum is the district




committees who engage with the Forum on issues specific to specific regions.

In all cases, political influence of the Forum is kept to a minimum.

Membership of the Forum represents nine local communities from three

provinces as well as representatives from Vienna Airport, the Air Traffic

Control Services and Austrian Airlines. The Dialogue Forum has a large

degree of self-regulation and since its implementation in 2005 has delivered a

range of measures, some of which include:

• the extent of the noise protection programme for an expansion airport;

• agreed noise fees for aircraft and their implementation;

• extensive discussion and evaluation of the third runway environmental

impact assessment; and

• agreement of various operational measures.

2.3.2 We understand that it has not always been easy at those airports or elsewhere to

establish complete trust between an airport and its community in regard to an

airport’s operation and reporting of its effects. We will continue to learn the lessons

from these and other examples in order to establish a new benchmark for global

best practice at Heathrow.

2.3.3 In order to implement such a framework at Heathrow, it is necessary to put in

place the following:

• a clear, enforceable definition of the environmental envelopes or limits;

• a monitoring, reporting and modelling regime which enables the impacts of

Heathrow’s growth to be accurately recorded and predicted; and

• an independent body to scrutinise the monitoring and enforce the limits.

2.3.4 We are still developing our thinking in these areas, but our current proposed

approach to meet these needs is set out in the following sections.




3. ENVIRONMENTAL LIMITS

3.1 Airports NPS environmental policy requirements

3.1.1 Section 5 of the Airports NPS sets out clear policy criteria for an applicant’s

assessment, the approach to be taken to mitigation, and the framework for the

Secretary of State’s decision-making for a range of potential impacts. These

criteria will be relevant to any assessment of compliance with the Airports NPS.

3.1.2 These policy criteria have been derived in part from the work and

recommendations of the Airports Commission but also by detailed work

undertaken by the Government in the preparation of the draft Airports NPS. The

policies were the subject of public consultation and scrutiny by the Transport

Select Committee before being confirmed in the designated Airports NPS

approved by Parliament in June 2018.

3.1.3 Airports NPS policies set the terms under which the Government would be

prepared to approve the DCO application. As set out in Chapter 2 of this

document, those terms are intentionally demanding. Those who have opposed the

expansion of Heathrow have often claimed that expansion cannot be achieved

within those limits – but Heathrow is confident that it can and this framework

commits to those limits.

3.1.4 This framework proposes limits in respect of the following topics which reflect the

principal requirements of the Airports NPS:

• Surface access (traffic)

• Air quality

• Aircraft noise

• Carbon

3.1.5 The proposed detailed wording for each topic is set out and explained in Appendix

A. These limits are set out as initial drafts at this stage, to invite views and

comments. The limits will be supplemented as required to comply fully with the

NPS. They will be reviewed with the benefit of the output of the completed EIA

process and consultation feedback.

The draft framework will be discussed further with key stakeholders, such as our

airlines, Heathrow’s independent Noise Envelope Design Group, statutory

authorities and the Heathrow Community Engagement Board before being set out

in our DCO application and then tested at examination.




The limits would be complementary to a number of planning requirements and

obligations which give effect to other mitigation strategies that will be necessary to

ensure compliance with the Airports NPS overall.

3.2 Surface access

3.2.1 As Appendix A sets out, in addition to the general requirements to mitigate and

minimise the effect of expansion on existing surface access arrangements, the

Airports NPS presents two clear limits or requirements. Any application for

development consent must include details of how the applicant will:

• increase the proportion of journeys made to the airport by public transport,

cycling and walking to achieve a public transport mode share of at least 50%

by 2030, and at least 55% by 2040 for passengers; and

• how, from a 2013 baseline level, it will achieve a 25% reduction of all staff car

trips by 2030 and a reduction of 50% by 2040.8

3.2.2 In addition, Heathrow has pledged to deliver expansion without increasing airport-

related traffic compared to today’s levels, generally referred to as the No More

Traffic (NMT) pledge. This is acknowledged in paragraph 5.38 of the Airports NPS,

which states that “Heathrow Airport should continue to strive to meet its public

pledge to have landside airport-related traffic no greater than today.” We stand by

our pledge, which we will continue to strive to meet as set out in our Surface

Access Proposals consultation document.

3.2.3 The first surface access Airports NPS limit relates to passenger mode share – the

proportion of passenger journeys made to the airport by public transport, cycling

and walking. For these purposes, this framework relies upon the statistics

published annually by the Civil Aviation Authority (CAA) in its “Departing

Passenger Survey”. This independent data source provides a consistent timeline

of information based on passenger interviews undertaken quarterly at Heathrow

terminals. Heathrow already works with the CAA to maintain and improve the

accuracy of this data.

3.2.4 The second surface access limit relates to staff car trips – the Airports NPS

requires specific reductions of “all staff car trips” by 2030 and a further reduction

by 2040.

3.2.5 In order to apply this requirement, it is necessary to derive a clear definition of “all

staff”, (at Heathrow we refer to staff as ‘colleagues’) as well as a means of

measuring colleague trips at the 2013 baseline required by the Airports NPS and

ensuring that monitoring can report results on a consistent basis going forward. 8 Airports NPS paragraph 5.17




The work undertaken by Heathrow to provide a solid basis for this requirement is

set out in detail in our Surface Access Proposals. With the benefit of that work,

Heathrow has devised a boundary for the airport so that surveys can accurately

measure all colleagues working within the airport boundary or travelling to the

airport for employment within the aviation industry.

3.2.6 The boundary is shown in Appendix A. It adopts the operational area of the airport

accessible by Heathrow-controlled roads. The appendix also shows a future

operational boundary for the airport based on the preferred masterplan.

3.2.7 The monitoring process would work as follows:

• within that area, the count of all colleague numbers is based on MAID (access

control system) data, which is the most comprehensive log of those working at

the airport. Adjustments have been made to ensure that the data is as accurate

as possible;

• in order to monitor the future, Heathrow has established a cordon of ANPR

(automatic number plate recognition) cameras on the airport boundary and

have plans to install cameras at colleague car parks. In the early years

following the grant of DCO consent, it is intended to continue to monitor the

MAID data and to compare this with the results from the ANPR data in order to

test the compatibility of the data. In time, it is hoped that the process of

monitoring can migrate to the use of ANPR surveys, with the agreement of an

Independent Scrutiny Panel (see section 4 of this framework).

3.2.8 The definition set out in Appendix A, therefore, will provide absolute clarity at the

baseline and in future years. It relates to the traffic within Heathrow’s control and it

maintains a consistent approach to measurement between now and the years

following expansion.

3.3 Air quality

3.3.1 A clear requirement of the Airports NPS is that the Secretary of State will need to

be satisfied that, with mitigation, the scheme would be compliant with legal

obligations that provide for the protection of human health and the environment9.

3.3.2 The limits presented in Appendix A reflect the legal obligations imposed on the

Government by the Ambient Air Quality Directive (2008/50/EC) ('the Air Quality

Directive'). The Air Quality Directive was transposed into domestic law by the Air

Quality Standards Regulations 2010.

9 Airports NPS paragraph 5.42




3.3.3 The Air Quality Directive establishes common, health-based and ecosystem based

ambient concentration limit values for the main pollutants including nitrogen

dioxide, carbon monoxide and PM10. Article 13 of the Air Quality Directive requires

that Member States must ensure that, throughout their zones and agglomerations,

levels of those pollutants do not exceed the specified limit values after defined

deadlines. Where those limit values have not been achieved by the deadline,

Member States are required to prepare air quality plans containing appropriate

measures, so that the exceedance period can be kept as short as possible.

3.3.4 The limits in Appendix A reflect these legal obligations by providing that new

capacity at the airport must not be released if it would:

• cause a compliant zone to become non-compliant with the limit values; or

• delay the date by which a non-compliant zone will achieve the limit values

within the most recent timescales reported to the European Commission.

3.3.5 These limits ensure that Heathrow Expansion will be delivered without impacting

the UK’s compliance with the health-based limit values which are imposed by the

Air Quality Directive.

3.4 Aircraft noise

3.4.1 The Airports NPS contains 3 principal requirements in relation to the acceptable

noise effects of aircraft in the air.

3.4.2 First, paragraph 5.58 of the Airports NPS provides that noise mitigation measures

“should ensure the impact of aircraft noise is limited and, where possible, reduced

compared to the 2013 baseline assessed by the Airports Commission”. A footnote

within the Airports NPS explains that the baseline was assessed by the Airports

Commission using the 54 decibel LAeq 16hr noise contour.

3.4.3 In addition, paragraph 5.68 of the Airports NPS provides that development consent

should not be granted unless the Secretary of State is satisfied that the proposals

will meet the following aims:

• avoid significant adverse impacts on health and quality of life from noise;

• mitigate and minimise adverse impacts on health and quality of life from noise;

and

• where possible, contribute to improvements to health and quality of life

3.4.4 Whilst the 54-decibel contour was used by the Airports Commission, other decibel

levels are important in measuring performance against these aims. In particular,

the requirement to avoid significant adverse impacts on health and quality of life is

associated with noise level exposure greater than 63 dB LAeq 16hr daytime and




55 dB LAeq, 8hr night time. The requirement to mitigate and minimise effects from

noise, however, can be aligned with lower noise levels of 51 dB LAeq 16hr

daytime and 45 dB LAeq 8hr night time. Again Appendix A explains the use of

these metrics in more detail.

3.4.5 This framework, therefore, commits to a process of monitoring the noise impact of

aircraft flying to and from Heathrow against all of these noise metrics and to set

the 2013 contour for those metrics as a baseline which should not be exceeded by

the effects of expansion. This approach aligns directly with proposals made by

Heathrow in its submissions to the Airports Commission in 2013 that the effect of

Heathrow’s expansion should be “no greater than today”.

3.4.6 An alternative approach would be to constrain Heathrow’s growth by reference to

its total noise output, measured though a quota count. Appendix A explains how

this could be managed.

3.4.7 In relation to aircraft noise the Airports NPS sets criteria against which the project

is to be considered and puts in place policies which seek improvement in

Heathrow’s noise performance. Paragraph 5.58 of the Airports NPS requires noise

impact to be limited to the 2013 baseline “and where possible reduced”. Equally,

paragraph 5.60 requires a noise envelope to be established “tailored to local

priorities and include clear noise performance targets” within which the benefits of

technological improvement should be “shared between the applicant and local

communities”.

3.4.8 The definition proposed for Heathrow’s noise envelope is;

Heathrow’s noise envelope is a set of legally binding and enforceable limits and

controls to manage noise in the future while enabling growth.

3.4.9 The Noise Envelope is described further in our consultation document Future

Runway Operations, and Appendix 17.1 Annex A to Chapter 17: Noise &

Vibration of the Preliminary Environmental Information Report which is also

published as part of this consultation.

3.4.10 Accordingly, this framework commits to progressive improvement in Heathrow’s

noise performance by a stepped reduction in Heathrow’s noise contour or a

progressive reduction in the total noise output of flights to and from Heathrow.

Exactly like the best practice example described above at Schiphol airport,

Heathrow would not use, or would ‘return’ a percentage of the environmental gain

achieved through the use of quieter planes and operating procedures.

3.5 Carbon

3.5.1 Climate change is a global threat and Heathrow is committed to take a lead in

addressing it. Heathrow is working with industry, commercial partners and




academics to innovate, invest and incentivise to make our contribution. This

Framework will be one way we achieve this and ensure that the airport and airlines

are incentivised to reduce emissions and invest in new technology, in order to

make use of additional capacity.

3.5.2 Following updates to the Airports Commission’s initial analysis and forecasts, the

UK Government concluded in the Airports NPS that a new runway at Heathrow is

deliverable within the UK’s carbon obligations.

3.5.3 Paragraph 5.82 of the Airports NPS provides that any increase in carbon

emissions alone is not a reason to refuse development consent unless the

increase is so significant that it would “have a material impact on the ability of

Government to meet its carbon reduction targets, including carbon budgets”.

3.5.4 Appendix A provides detail on how Heathrow’s carbon effects would be

considered between now and 2050. As the context for these is an international

and national one, compared with the more localised effects of airport growth in

terms of air quality, noise and surface access, the provisions and measures

contained in Appendix A approach the issue of carbon and what this Framework

can properly cover differently to the other three aspects of air quality, noise and

surface access.

3.5.5 We are aware of the ongoing work being done by the Government’s advisors the

Committee on Climate Change in relation to aviation following their May 2019

advice to Government; Net Zero. The UK's contribution to stopping global

warming. Depending on how this advice is subsequently acted upon by

government, we will then consider appropriately in line with the wider aviation

industry response.

3.6 Other effects of growth

3.6.1 In addition to envelopes for these four headline effects, there will be other effects

arising from the growth of the airport operations. These too will be the subject of

detailed Environmental Impact Assessment, the findings of which will be set out in

the Environmental Statement accompanying the DCO application. These other

effects will be the subject of mitigation requirements and obligations which will be

set out in the DCO itself and the accompanying Section 106 agreement.

3.6.2 The Airport is already regulated by the Environment Agency (EA). The EA have

statutory responsibilities for checking compliance with environmental permits

controlling emissions to the environment. These include emissions from

combustion facilities such as energy centres, and discharges to watercourses from

the surface water pollution control system serving the airfield. The detailed design

and subsequent operation of the expanded airport will continue to be subject to




this form of regulation, albeit outside of the scope of this framework. This wider

environmental regulation is shown in Graphic 4.1 below labelled as ‘other’.

3.6.3 It is also possible that the effects of growth for some environmental aspects or

topics may in time turn out to be different from those assessed in the

Environmental Statement, effects might develop which were not anticipated in the

mitigation measures set out in the DCO.

3.6.4 To address this possibility, Heathrow is proposing an Unforeseen Local Impacts

Mitigation Strategy (ULIMS). Details of how the ULIMS would work are set out in

Appendix B – essentially ULIMS commits to monitor the effects of the airport’s

growth and to put in place a mechanism to address any significant effects of

growth which were not anticipated at the time of the DCO consent. We propose

that any expenditure necessary for the ULIMS would be funded from the

Community Fund. We are seeking feedback on the fund and how it works, as

part of this consultation. Please see the ‘Proposals for Mitigation and

Compensation’ document.

3.6.5 ULIMS might be called upon, for example, where the growth of the airport

operation generates impacts on public transport capacity, beyond those forecast in

the DCO Environmental Statement but which should be mitigated if the airport is to

be allowed to continue to grow.

3.6.6 In relation to the four principal topic areas listed above, however, the maximum

permissible effects would be guaranteed, as explained in the next chapter of this

framework.




4. MONITORING GROWTH AND OPERATION

4.1 Monitoring

4.1.1 Heathrow already publishes a large volume of monitoring data about the effects of

the airport’s operations. For the purposes of this framework, however, Heathrow

will prepare a document titled Environmentally Managed Growth – Our

Monitoring which will set out the detail of how the effects of the airport’s

expansion will be monitored in relation to the four principal topic areas covered by

this Framework. This will enable the airport’s performance against the limits

identified in Appendix A to be monitored and enforced.

4.1.2 We propose that monitoring data will be updated regularly on Heathrow’s website

and will be the subject of a formal Monitoring Report published annually and

submitted to the Independent Scrutiny Panel (see further below).

4.1.3 The Monitoring Report would include all relevant data and identify the relevant

impacts of Expansion. It will place those impacts in the context of the

environmental limits or envelopes and will contain a ‘look forward’ discussing how

Heathrow’s forecast growth relates to those limits, taking account of any existing

or planned mitigation measures.

4.2 Independent Scrutiny Panel

4.2.1 Appendix C comprises a potential constitution for an Independent Scrutiny Panel

(ISP). The establishment of the ISP will be committed to within the DCO in

accordance with that constitution. It is important for public confidence that

Heathrow’s Environmentally Managed Growth framework is overseen and

enforced independently by an organisation which is technically capable and

appropriately resourced.

4.2.2 The precise details of the membership of the Independent Scrutiny Panel (ISP)

need to evolve through consultation feedback and direct discussion with

stakeholders. The purpose, however, is to gather together in one enforcement

body all specialist agencies who may have a role in assessing and enforcing the

environmental limits to Heathrow’s growth, so that Heathrow can be held to

account in a comprehensive and coordinated way.

4.2.3 The Airports NPS identifies an important role for the Heathrow Area Transport

Forum in monitoring the surface access effects of growth, whilst other bodies also

have a very clear interest in ensuring the satisfactory operation of the airport.

These include Heathrow Community Engagement Board, the Environment

Agency, the Civil Aviation Authority and the newly formed Independent




Commission on Civil Aviation Noise (ICCAN). Direct discussions are being held

with each of these bodies to agree their role within the ISP.

4.2.4 It is anticipated that the Heathrow Strategic Planning Group (HSPG) – the

grouping of Heathrow’s local planning authorities – should also have an important

role in overseeing the future of the airport and ensuring that the various

requirements and commitments made in the DCO are observed.

4.2.5 The role of the ISP would be to oversee and facilitate the sustainable growth of the

airport, in line with the Airports NPS and the DCO, subject to the clear terms of this

framework. That role would include both monitoring and enforcing the

environmental limits within the Framework but also managing the operation of the

Unforeseen Local Impact Mitigation Strategy (ULIMS) where monitoring identifies

significant effects from growth that were not anticipated in the DCO.

4.2.6 A possible structure for the way in which the ISP may work is illustrated in Graphic

4.1 below. The intention is to ensure a role for all relevant stakeholders to inform

the decisions that may need to be taken by the ISP.




Graphic 4.1 Environmentally Managed Growth - illustration of potential process

4.3 Implementing this framework

4.3.1 This framework will require Heathrow to:

i. undertake and publish detailed monitoring of Heathrow's performance against

the limits set out in Appendix A;

ii. establish the Independent Scrutiny Panel through engagement with key

stakeholders;

iii. work closely and collaboratively with the Independent Scrutiny Panel; and

iv. comply with the terms of this framework in all respects, including being subject

to the enforcement powers provided to the Independent Scrutiny Panel.

Heathrow would work closely with the ISP at all times to enable the sustainable

growth of the airport whilst establishing an effective means of monitoring the

operational performance of the airport to ensure its impacts remain within the

environmental limits set in the Airports NPS and the DCO, as defined precisely in

Appendix A:




- the Monitoring Report will first be submitted in draft to the ISP for specialist

review and validation;

- The Monitoring Report will not only account for Heathrow’s performance to

date, it will compare that performance with the limits in Appendix A and contain

a ‘forward look’ which discusses the effect of Heathrow’s planned growth and

mitigation measures in relation to those limits;

- Where monitoring shows that Heathrow has come close to the defined limits

(the definition of these ‘amber’ effects will be agreed) or where growth is

proceeding on a trajectory showing greater effects than those forecast for a

given level of growth, the ISP can call on Heathrow to provide further

information, including more frequent or more detailed monitoring;

- Where monitoring shows that the airport’s effects have exceeded any of the

limits defined in Appendix A, the ISP can require Heathrow to produce a

Mitigation Strategy to bring the effects back within the defined limits;

- Where monitoring continues to show a breach of any limits, the ISP can direct

the implementation of its own Mitigation Strategy with which Heathrow must

comply.

4.3.2 This regime is summarised in Graphic 4.2 below.

Graphic 4.2 Environmentally Managed Growth – Illustration of monitoring response




4.3.3 In the event of a dispute, the issue can be referred to the Secretary of State for

Transport, or their delegated agent such as the CAA, for resolution.

4.3.4 The overall framework could have the effect of limiting the growth of the airport

unless the Environmental Limits are observed. Rather than growth being allowed

to continue, the framework (and particularly the powers available to the ISP) would

prevent its growth beyond a certain point until further mitigation can be found. In

this way, Heathrow would have to ‘earn the right to grow’.

4.3.5 The DCO will certify this framework and place a legally binding statutory duty on

Heathrow to implement and comply with the obligations set out in the document.




5. WIDER ENVIRONMENTAL MONITORING AND MANAGEMENT

5.1.1 In addition to its specific limits or envelopes to growth, Heathrow’s DCO

application will commit to a full range of environmental requirements and

obligations to limit and mitigate the impact of the airport’s development.

5.1.2 Heathrow already publishes an annual report to update on our progress against

Heathrow 2.0. This is the sustainability strategy which sets out Heathrow’s plan for

responsible growth across four pillars; make Heathrow a great place to live, great

place to work, build a thriving sustainable economy, and keep a world worth

travelling. It contains ambitious targets across all of these areas, some relate to

internal corporate performance and others are concerned with actions addressing

issues external to the airport.

5.1.3 Heathrow will continue to produce this document and will report against published

targets, across a wide range of areas. This complements the Environmentally

Managed Growth framework, but the two are distinct documents.

5.1.4 We propose that the four key effects in Environmentally Managed Growth; noise,

air quality, surface access, and carbon, are monitored additionally against the

binding limits set out in this framework, and that the monitoring would be

scrutinised and validated by relevant specialist stakeholders, such as the

Heathrow Airport Transport forum, the HSPG, the highways authorities etc. and

then reported to the Independent Scrutiny Panel.

5.1.5 Heathrow 2.0 reports remain an important element of Heathrow’s public

accountability, but a separate, dedicated monitoring and reporting process is

necessary to ensure the clarity of the framework for ensuring Environmentally

Managed Growth in the context of DCO as set out in this document.


A1 © Heathrow Airport Limited 2019


APPENDIX A: PROPOSED ENVIRONMENTAL LIMITS

The following are presented as draft candidate limits. They will be developed further following consultation and engagement to ensure compliance with the Airports NPS and following the completion of the Environmental Impact Assessment.

It will be important to ensure the success of this Framework approach to establish limits that can act as true incentives to drive environmental performance improvement rather than to penalise the airport, airlines and their operational partners.

1. SURFACE ACCESS

The framework for Environmentally Managed Growth will include limits based on two key surface access targets in the Airports NPS:

Passenger mode share

1. The proportion of annual passenger journeys made to the airport by public transport, cycling and walking must be not less than:

(a) 50% in the year 2030, and

(b) 55% in the year 2040.

Colleague car trips

2. From a 2013 baseline level, Heathrow must achieve a 25% reduction of all staff car trips by 2030, and a reduction of 50% by 2040. Based on a 2013 baseline of 47,700, the annual average number of daily staff car trips must not exceed:

(c) 35,800 in the year 2030, and

(d) 23,900 in the year 2040

For the purposes of the passenger mode share target, the proportion of annual passenger journeys made to the airport by public transport will be as reported in the Civil Aviation Authority's Departing Passenger Survey for the relevant year unless otherwise agreed with the Independent Scrutiny Panel.

The framework will also include a mechanism whereby the definition of 'public transport' can be reviewed and, if necessary, updated to take account of new forms of transport. This mechanism is appropriate given the long-term nature of the targets. It ensures that Heathrow can respond to and take advantage of the opportunities presented by future advances in transport technology which will result in changes to what is considered 'public




transport' to include, for example, sustainable forms of transport that will be shared by different users, most likely using low or zero emission vehicles.

For the purpose of the staff car trip target, a "staff car trip" will be defined as a journey made by car by an employee to or from their place of work within the airport. The figures below show the proposed airport boundary to be used in order to measure performance. The boundary includes all land that is accessible only by Heathrow-controlled roads and Heathrow will record the number of car trips made by people who drive across the airport boundary to go to work.




Graphic A.1 Boundary of existing airport

Graphic A.2 Indicative boundary of future airport




For the purpose of monitoring this target Heathrow will use:

• MAID (access control system) data, which is the most comprehensive log of those working at the airport; and

• data from a cordon of ANPR (automatic number plate recognition) cameras on the airport boundary.

Heathrow has previously presented an estimated figure of 46,000 for the annual average number of daily staff car trips for the 2013 baseline. Further analysis of the 2013 data and the Heathrow employment survey on which it was based, has now produced a 2013 baseline of 47,700 average daily staff car trips. This revised baseline figure of 47,700 has been used to calculate the targets at 2030 (-25%) and 2040 (-50%) as 35,800 and 23,900 respectively.10

Both the passenger mode share and staff car trip targets apply to the years 2030 and 2040. Heathrow will consider whether the Environmentally Managed Growth Framework should include a mechanism for appropriate targets to be set in the future for the period beyond 2040 having regard to the underlying objectives of the Airports NPS and transport technology and policies existing at the time.

Managing surface access

In accordance with the Airports NPS Heathrow will submit a Surface Access Strategy with its DCO application. The Strategy will set out the measures by which Heathrow will manage surface access to the airport and support the additional transport demands generated by airport expansion. As well as setting out how Heathrow will achieve the passenger mode share and staff car trips targets set out above, the Surface Access Strategy will include a wider range of targets related to surface access arrangements and set out actions, policies and defined performance indicators for delivering against targets and the wider surface access requirements of the Airports NPS.

The Airports NPS also states that Heathrow should assess the implications of airport expansion on surface access network capacity and set out the mitigation measures that it considers are required to minimise and mitigate the effect of expansion on existing surface access arrangements. Heathrow must demonstrate in its assessment that the proposed Surface Access Strategy will support the additional transport demand generated by airport expansion. The preliminary results of this analysis are included within the Preliminary Transport Information Report (PTIR), which is part of the Preliminary Environmental Information Report (PEIR). The results of the full analysis will be presented in a Transport Assessment (TA) which will accompany the DCO application.

Heathrow is consulting on its proposals for the Surface Access Strategy as part of this consultation – see our Surface Access Proposals.

10 All numbers rounded to the nearest hundred.




2. AIR QUALITY

The Environmentally Managed Growth framework will include the following limits which ensure that the scheme will not affect the UK's ability to comply with the legal obligations in the Ambient Air Quality Directive (2008/50/EC) that provide for the protection of human health and the environment:

The scheme must not:

(a) result in a zone or agglomeration which is reported as being compliant with the Ambient Air Quality Directive (2008/50/EC) ('the Air Quality Directive') becoming non-compliant; or

(b) affect the ability of a non-compliant zone or agglomeration to achieve compliance within the most recent timescales reported to the European Commission at the time.

The Air Quality Directive establishes common, health-based and ecosystem based ambient concentration limit values for the main pollutants including nitrogen dioxide, carbon monoxide and PM10. Article 13 of the Air Quality Directive requires that Member States must ensure that, throughout their zones and agglomerations, levels of those pollutants do not exceed the specified limit values after defined deadlines. Where those limit values have not been achieved by the deadline, Member States are required to prepare air quality plans containing appropriate measures, so that the exceedance period can be kept as short as possible.

The limits above will ensure that Heathrow Expansion will be delivered without impacting the UK’s ability to achieve compliance with the health-based limit values imposed by the Air Quality Directive.

In addition to these limits, Heathrow will develop further measures and commitments based on the outcomes of the air quality assessment currently being undertaken as part of the Environmental Impact Assessment.

The preliminary results of the air quality assessment are reported in Chapter 7: Air Quality & Odour of the PEIR which also includes preliminary details of the measures proposed to mitigate and manage the air quality impacts of airport expansion.

3. AIRCRAFT NOISE

The Environmentally Managed Growth Framework will include limits for noise of aircraft in the air, from within the noise envelope, which reflect the requirements of the Airports NPS. The Airports NPS contains three core requirements in respect of aircraft noise:

The noise mitigation measures should ensure the impact of aircraft noise is limited and, where possible, reduced compared to the 2013 baseline assessed by the Airports Commission. (para 5.58)




Development consent should not be granted unless the Secretary of State is satisfied that the proposals will meet the following aims for the effective management and control of noise, within the context of Government policy on sustainable development:

(a) Avoid significant adverse impacts on health and quality of life from noise;

(b) Mitigate and minimise adverse impacts on health and quality of life from noise; and

(c) Where possible, contribute to improvements to health and quality of life. (para 5.68)

The applicant should put forward plans for a noise envelope. Such an envelope should be tailored to local priorities and include clear noise performance targets. As such, the design of the envelope should be defined in consultation with local communities and relevant stakeholders, and on the basis of the expert advice of an independent third party. This third party could be the Independent Commission on Civil Aviation Noise proposed by the Government in its separate consultation on UK airspace policy. The benefits of future technological improvements should be shared between the applicant and its local communities, hence helping to achieve a balance between growth and noise reduction. Suitable review periods should be set in consultation with the parties mentioned above to ensure the noise envelope’s framework remains relevant. (para. 5.60)

Heathrow is currently working with the independent Noise Envelope Design Group to develop its plans for the noise envelope required by paragraph 5.60 of the Airports NPS and it is proposed that the noise limits set out in the Environmentally Managed Growth Framework will form part of the overall noise envelope approach.

It is proposed that the noise limits will be defined in the Noise Envelope according to either of two key metrics (total emissions and/or exposure) in the format shown below:

Aircraft noise emissions

The total annual quota count (QC) for all air transport movements at the airport during the relevant period must not exceed the limits specified below:

(d) a daytime limit of XXX; and

(e) a night-time of YYYY.

Noise exposure

Daytime

The area of any of the noise contours specified below must not exceed the following limits for the relevant period:

(a) the area of the 51dB LAeq, 16hr contour shall not




exceed XXXX,

(b) the area of the 54dB LAeq, 16hr contour shall not exceed XXXX,* and

(c) the area of the 63dB LAeq, 16hr contour shall not exceed XXXX.

*note that it may not be necessary to include this contour as compliance with the other two contours would necessarily bring compliance with the 54 dB contour – to be explored.

Night-time

The area of any of the noise contours specified below must not exceed the following limits for each the relevant period:

(d) the area of the 45 dB LAeq, 8hr contour shall not exceed XXXX, and

(e) the area of the 55dB LAeq, 8hr contour shall not exceed XXXX.

The way in which these limits respond to the requirements of the Airports NPS is explained below.

Better than 2013 baseline

The Airports NPS is clear that the reference in paragraph 5.58 to 'the 2013 baseline assessed by the Airports Commission' means the 54 decibel LAeq, 16h noise contour – which indicates the annual average noise levels for the 16-hour period between 0700 – 2300. Accordingly, it is proposed to include either total noise emissions limits which reflects the 2013 baseline or an exposure limit which requires the overall area of the 54 decibel LAeq, 16h noise contour not to exceed the area of the 2013 baseline.

Compliance with aims of noise policy

The stated aims of Government noise policy referred to in paragraphs 5.67 and 5.68 of the Airports NPS are as follows:

a) Aim 1 is to “avoid significant adverse effects” which are associated with noise level exposure greater than the significant observed adverse effect level ("SOAEL"). The scoping report produced for Heathrow Expansion defines SOAEL as 63dB LAeq, 16hr daytime and 55dB LAeq, 8hr night-time.

b) Aim 2 relates to “mitigate and minimise” effects from noise exposure greater than the lowest observed adverse effect level ("LOAEL. The scoping report defines LOAEL as 51dB LAeq, 16hr daytime and 45dB LAeq, 8hr night-time.




c) Aim 3 is a combination of the above showing a reduction in the effects associated with noise exposure overall greater than LOAEL values. It would also be met through a commitment to sharing the benefit of technological improvements in aircraft noise - see further below.

To comply with the aims of noise policy, it is proposed to either set total noise emissions or area contour limits which reflect the daytime and night-time LOAEL and SOAEL values. The limits are expressed in terms of the area of the associated contours. These limits are in addition to the 54 dB LAeq, 16hr contour which represents the 2013 baseline, although that limit may be automatically met if the other two limits are met.

Total emissions limit

The primary noise reduction mechanism associated with the International Civil Aviation Organization (ICAO) 'Balanced Approach to Aircraft Noise Management' is reduction of noise at source and therefore (in addition to the exposure limits) Heathrow also proposes an additional limit based on total noise emissions.

The “Quota Count” (QC) system provides a suitable alternative framework for this purpose. It provides a simple quantification of the relative noise performance of all aircraft types that operate. It can be adapted to ensure that it remains relevant over time and provides a manageable means for ongoing reporting and management of “exposure”. Total QC is a reliable proxy for the way in which the area of the contour changes (once other mitigation remains constant). It can be easily separated to provide limits for day and night-time periods and therefore provides a guarantee that noise from aircraft will also be “no worse than today”.

It is therefore being considered whether a QC value limit or noise contour area could be a better way of meeting the Airports NPS requirements.

Sharing the benefits of future improvements

Paragraph 5.60 of the Airports NPS states that "The benefits of future technological improvements should be shared between the applicant and its local communities, hence helping to achieve a balance between growth and noise reduction. Suitable review periods should be set in consultation with the parties mentioned above to ensure the noise envelope’s framework remains relevant."

To ensure this requirement is met, it is proposed that noise limits would to be set for an initial 5 year period, with a process for review to be set at appropriate intervals (every 5 years for example) to establish the limits for the next period. This review process would require the limits to be updated to reflect:

a) a sharing of the benefit of technological improvements in reducing aircraft noise with the local communities; and

b) a progressive improvement in Heathrow’s noise performance by a stepped reduction in Heathrow’s noise contour and a progressive reduction in the total noise output of flights to and from Heathrow.




Further development of noise limits and noise envelope

As noted above, the noise limits described in this section will form part of the noise envelope plans which will be included as part of the DCO application.

The noise envelope plans are currently being developed with the independent Noise Envelope Design Group (NEDG) and those plans may include other appropriate metrics and measures (such as runway alternation and controls on night flights) to mitigate noise impacts at particular locations. Heathrow will continue to work with the NEDG between the PEIR and Environmental Statement to refine proposals for enforceable limits for the noise envelope. Final proposals will be included as part of the Environmental Statement and DCO application.

Appendix 17.1 Annex A to Chapter 17: Noise and Vibration of the Preliminary Environmental Information Report which is also published as part of this consultation, contains further detail on the ongoing work to develop the noise envelope. The chapter also sets out the preliminary results of the noise assessment along with details of the measures proposed to mitigate and manage the noise impacts of airport expansion.

4. CARBON

Paragraph 5.82 of the Airports NPS states:

Any increase in carbon emissions alone is not a reason to refuse development consent, unless the increase in carbon emissions resulting from the project is so significant that it would have a material impact on the ability of Government to meet its carbon reduction targets, including carbon budgets.

As part of the Environmental Impact Assessment Heathrow is carrying out a full assessment of the likely impacts of the carbon emissions resulting from airport expansion, including how expansion will affect emissions in the context of Government policy. The preliminary results of that assessment are presented in the PEIR at Chapter 9: Carbon and Greenhouse Gases as part of this consultation, including details of measures that would be taken to reduce emissions.

To ensure ongoing compliance with the Airports NPS requirement above, it is proposed that Heathrow will commit to:

(a) the implementation of specific mitigation measures during construction and operation of the scheme which the EIA assessment shows would be likely to be effective in ensuring the scheme does not have a material impact on the ability of Government to meet its carbon reduction targets. These measures would include good practice measures for reducing carbon emissions identified in the UK’s Aviation Strategy which the Government recently consulted on; and

(b) a mechanism for an ongoing review and reporting of carbon emissions involving independent oversight to ensure the scheme is not having a




material impact on the ability of Government to meets its carbon reduction targets, and a requirement to take additional action in the event that that objective is threatened.


B1 © Heathrow Airport Limited 2019


APPENDIX B: UNFORESEEN LOCAL IMPACTS MITIGATION STRATEGY (ULIMS)

INTRODUCTION

The purpose of this Strategy is to recognise there may be environmental effects arising from the expansion of Heathrow beyond the headline effects covered by the framework for Environmentally Managed Growth. The large majority of those effects will have been identified through the process of detailed Environmental Impact Assessment, reported in the DCO Environmental Statement and limited, mitigated or compensated through a detailed set of DCO requirements and obligations.

However, for any development of this scale and long-term duration, whilst the DCO Environmental Statement will set out a thorough assessment of likely significant effects, it cannot be guaranteed that other significant effects will not arise as circumstances change over time, particularly as airport operations grow.

This Strategy puts in place a mechanism for mitigating those impacts, to the extent that they have not already been mitigated through other measures committed in the DCO, or existing environmental regulatory regimes.

Those impacts would be identified through a programme of annual monitoring reported in Monitoring Reports, which would be independently validated and submitted to the Independent Scrutiny Panel.

The purpose of the ULIMS is:

• to recognise that the 4 headline environmental limits covered by the Environmentally Managed Growth Framework are not the only effects of growth;

• to recognise that growth might take place beyond that anticipated in the DCO but within the overall limits identified in the framework for Environmentally Managed Growth Limits – such growth could have other impacts which Heathrow is committed to mitigate;

• to recognise that even the most robust Environmental Statement cannot predict with certainty all of the precise environmental effects of a long term and complex development such as the expansion of Heathrow Airport and that some impacts could arise differently from those anticipated and assessed within the DCO Environmental Statement; and

• to provide a mechanism to regulate the process.


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SCOPE

The principles of the way in which ULIMS would operate are set out below:

a. The ULIMS would cover all significant environmental effects arising from the

approved growth of Heathrow through the DCO application, where these have

not been addressed within the DCO and its requirements/obligations.

b. The baseline for ULIMS will be the assessment of effects set out in the DCO

application.

c. In relation to traffic impacts, for example, the Transport Assessment would

identify specific links or junctions where there is some uncertainty or dispute

exists with the transport authorities about the significance of expansion

impacts. Monitoring or subsequent assessments may demonstrate effects

sufficient to trigger the operation of the ULIMS mechanism.

d. Monitoring would establish a process for isolating the impacts of expansion and

reporting those impacts against the defined thresholds.

e. The principal candidate topics for ULIMS are expected to be public transport

links and traffic capacity, local air quality impacts, etc. but ULIMS can apply in

principle to any significant effect of growth which is not already mitigated

through the consented DCO.

Heathrow would commit to ULIMS as a contingent liability or obligation to address significant effects arising from growth not previously identified or mitigated. In the event that monitoring triggered reference to ULIMS, the Independent Scrutiny Panel may have a role in mediating the necessary solution, within a clear qualifying and governance framework.

The ULIMS would identify a dispute resolution mechanism.

It is proposed that any expenditure from the ULIMS would be funded by the Heathrow Community Fund.

As the DCO Environmental Statement and the full suite of environmental information that will be submitted with the DCO application is intended to be comprehensive, it is not anticipated that ULIMs would be called upon often – it exists to respond to exceptional, unforeseen circumstances arising from growth.


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APPENDIX C: FIRST DRAFT CONSTITUTION FOR THE INDEPENDENT SCRUTINY PANEL

INTRODUCTION

The Independent Scrutiny Panel (ISP) would be established by the DCO and its constitution would be set out in a Schedule to the DCO.

This document provides a draft list of the matters for which provision will be made in the DCO.

The purpose of the ISP is to publicly hold Heathrow to account against the Environmentally Managed Growth limits (and potentially to administer the ULIMS).

ESTABLISHMENT

A DCO article will provide for the establishment of the ISP, giving the body a statutory status.

FUNDING

The operation of the ISP would be funded by Heathrow.

ROLE

Reference will be made to the ISP's specific role in relation to various matters under the Environmentally Managed Growth framework.

The ISP will conduct its oversight and facilitation role in the context of the Airports NPS, which sets out the Government’s policy on the need for new airport capacity, and the DCO.

This will be done by cross-references to the provisions of those DCO certified documents relating to the Environmentally Managed Growth Framework where the ISP's role is specified, e.g.:

• reviewing and validating Heathrow's annual Monitoring Report;

• requiring Heathrow to submit a Mitigation Response Plan;

• taking enforcement action in the event of a continuing breach of the limits; and

• mediating mitigation disputes under the ULIMS.

MEMBERSHIP

A provision setting out the ISP's membership. As noted above, it will likely include representation from the Heathrow Area Transport Forum and from other bodies, likely to


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include Heathrow Community Engagement Board, Independent Commission on Civil Aviation Noise, the Environment Agency and the CAA. Heathrow Strategic Planning Group should also have a significant role.

Provision should be to enable changes to the membership where necessary (e.g. new members and dissolution of existing member organisations).

CHAIR

Either a Chair should be specified, or alternatively the procedure for appointing a chair should be set out.

MEETINGS

Provision as to meetings, to include:

• frequency;

• attendance;

• quorum; and

• decision-making.

The constitution could be prescriptive about ISP decision-making/voting, or alternatively it could provide for the ISP to determine its own procedures.

APPOINTMENT OF SPECIALIST ADVISERS

The ISP would need to be properly resourced with relevant topic experts appointed as independent advisers where necessary.

The Heathrow Airline community will be invited to give evidence to the ISP.

RECORD KEEPING AND REPORTING

Provision to ensure the ISP's proceedings and decisions are transparent and appropriately recorded.

DURATION

The ISP's role will continue for the duration of the Environmentally Managed Growth framework.

DISPUTES

Provisions for dispute resolution or appeals to the Secretary of State for Transport in the event that matters required to be agreed between Heathrow and the ISP cannot be agreed.

Find all the consultation information on our website aec.heathrowconsultation.com

Email any questions about the consultation to [email protected]

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