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Written Evidence submitted by Heathrow Airport Ltd

 

 

Heathrow is Europe’s largest airport and one of the world’s top international aviation hubs. As the UK’s global gateway, Heathrow handles over 475,000 flights and welcomes more than 80 million passengers every year. The airport is home to more than 80 airlines, connecting passengers to more than 200 destinations around the world. We recognise our responsibility to minimise the environmental impact of tourism while maximising the economic benefits for the whole of the UK.

 

Heathrow welcomes the opportunity to respond to the Environmental Audit Committee’s inquiry into sustainable tourism. Our response focuses on the following areas:

 

As a business and key provider of UK transport infrastructure, Heathrow has a responsibility to deliver on certain priorities as we grow and deliver our vision to give passengers the best airport service in the world. These include meeting our regulated obligations, transforming customer service, delivering a competitive return to our shareholders, and ensuring our plans are affordable. While we are confident in meeting these, we will only be truly successful if we achieve them while also improving the world around us; growth must be sustainable.

 

We have set a series of goals that will guide the future of our business as we grow, and will also guide us in the eight years before we plan to open a new northwest runway. We are going beyond simply reducing negative impacts to delivering positive impacts. Some of our ambitions for the future are only possible because of the extra revenue and opportunity that the proposed expansion creates. For example, many of our goals that are linked to the period after 2025 can only be delivered in the context of our new runway. Government must not hinder development, but ensure it is delivered responsibly and capitalises on the associated opportunities to improve environmental mitigation and promote sustainable growth.

 

We have been working hard to tackle our big environmental challenges; Heathrow is now quieter than at any time since the 1970s; we have reduced on-airport carbon emissions by 80% since 1990; and over 40% of our passengers and colleagues already travel to the airport by public transport.

 

Our plan for sustainable growth – Heathrow 2.0[1]– which was launched in 2017, is a step-change in the level of our ambition and captures the momentum of an industry-wide shift towards a sustainable future for aviation, a strategy fit for the future.

 

Heathrow 2.0 focuses on four key pillars:

 

 

Through Heathrow 2.0, we will help our colleagues fulfil their potential by providing thousands of rewarding employment opportunities that offer purpose and progress. And we will work with communities around us to find ways to improve their quality of life. We will also support the UK economy by connecting it more closely to the rest of the world, and create opportunities for businesses that are helping deliver a stronger, more sustainable UK.

 

We will lead our industry towards overcoming some of the greatest challenges it faces. We are committed to reducing waste, minimising noise, improving air quality around the airport, and playing our part in tackling carbon emissions.

 

By working with partners and stakeholders to devise solutions and by investing in and implementing breakthrough technology, we can create a future where our business, our people, our communities, our country and our world can all thrive.

 

Climate Change

 

Our planet is facing a climate emergency. Scientists agree the world must halve emissions in the next decade and reach net-zero by 2050 – Heathrow supports this goal. We also welcome the Committee on Climate Change’s recommendation to include aviation in the net-zero emissions target by 2050, as well as the call on Government to push for strong international policies that would avoid competitiveness impacts.

 

Everyone has a role to play. All businesses, governments and society must embrace this challenge. Because if we get it right, together we will avert the climate emergency, boost our economies and improve our quality of life. We will work with partners to innovate, invest and incentivise to make our contribution. Heathrow is one of more than 200 airports across 42 European countries that have now committed to reach net-zero by 2050 for the carbon emissions under their control. Based on Europe’s airports current traffic volumes and estimated carbon footprint, this net-zero commitment will eliminate a total of 3.46 million tons of annual CO2 emissions as of 2050[2]. This commitment comes alongside a call for the entire aviation sector and our global regulator, The International Civil Aviation Organisation (ICAO), to develop a long-term goal for a net-zero carbon emissions air transport system. This is needed to supplement the significant efforts already being made by the aviation sector under ICAO’s Basket of Measures, including CORSIA.

 

At Heathrow we don’t have all the answers yet. But, the journey to a decarbonised Heathrow, to decouple growth in aviation from growth in emissions and to drive change within the industry, is one we have been on for over two decades.

 

By shifting to renewable energy, generating our own energy, and investing in green technology, Heathrow has reduced on-airport carbon emissions by 80% since 1990 – despite passenger numbers rising from 43 million per year then to over 80 million today. To go further, we must be innovative, that is why we have launched a research think tank comprised of British universities to look at sustainable aviation challenges, and established a new Centre of Excellence which is a hub of learning and exploration, as well as engaging with Non-Governmental Organisations (NGOs) and other industries to test the development of a trading platform for UK carbon and ecosystem benefits that UK peatland and soil restoration activities generate.

 

As part of our plan, we also want to play a lead role in developing the next generation of high quality, cost-effective carbon offsetting in the UK. We recently funded a project to restore 70 hectares of peatland in the north-west of England, in partnership with the Lancashire Wildlife Trust. Peatlands act as a natural carbon sink, absorbing CO2 from the atmosphere. 94% of the UK’s natural peatlands have either been damaged or destroyed. Rather than absorbing carbon, this means they are currently emitting around 16 million tonnes of CO2 – similar to the emissions of all flights at Heathrow. Over time, if all of the UK’s peatlands were in a healthy condition they would stop emitting carbon and have the potential to remove 3 million tonnes of carbon each year. Successful peatland restoration would deliver carbon credits that can support airlines in offsetting their emissions at Heathrow, whilst providing wider environmental and social impacts. Following the good progress with the first phase of our UK peatland restoration project, we have planned our second phase for later in 2019.

 

Further work on our carbon offsetting approaches and options is currently being undertaken and we look forward to sharing this in due course.

 

Our targets are set, the day-to-day running of airport infrastructure will be carbon neutral by 2020 and zero carbon by 2050. And as we deliver expansion, we know our plans are compatible with UK climate targets. Just as Heathrow acts as a cornerstone of the UK economy, airports like ours must be cornerstones of the effort to tackle climate change around the world. Acting together with our airline and industry partners, we can accelerate the adoption of new technology, aircraft and sustainable fuels, which is the only way to get aviation to net-zero.

 

As detailed in our Carbon Neutral Growth Roadmap (2018)[3], the UK Government can also help in the following areas by:

 

 

 

 

 

The UK Government can also support industry investment in this area by reforming Air Passenger Duty (APD) to use some of the £3.7 billion of revenue raised from this tax to contribute to initiatives and measures that help tackle climate change, such as investing in sustainable fuels, carbon offset projects or acquiring carbon credits which would offset UK emissions from aviation, as well as improved sustainable surface transport access to airports.

 

We are among a number of major European airports who do not believe that passenger aviation taxes are effective instruments to incentivise sustainability in the aviation industry. Currently, they are a rather blunt instrument as they do not take the actual environmental impact of per passenger or flight emissions into account. Most have two rates, one for intra-EU or domestic destinations, and one for destinations further away, which does not take into account actual distances and emissions that can vary significantly within each rate. Therefore , the reform of APD should also consider including multiple differentiated rates that better account for the actual distances and emissions of departing flights.

 

Most importantly, the Government must avoid raising APD to meet these challenges. There remains significant public opposition to increasing air fares to reflect environmental impacts, with European governments urged to prioritise development of sustainable fuels and new technology instead[4]. It is crucial that we maintain the delicate balance of ensuring a thriving industry that is both internationally competitive and sustainable – carbon is the enemy, not aviation.

 

Air quality

 

Air quality in our cities is a major focus in the UK and around the world. Heathrow has reduced ground-based NOx emissions from airport activity by 16% over five years between 2008 and 2013. Air quality monitors closest to the airport already meet air quality standards, but those next to the M4 motorway stationed a couple of kilometres away do not. This illustrates that road traffic rather than aircraft is the main contributor to local air pollution. Although most of the traffic on the motorways around Heathrow is not related to the airport (and is already improving thanks to the Government and Mayor’s focus on reducing pollution), we still have a role to play.

 

We are taking various measures to encourage our stakeholders to reduce emissions, such as incentivising suppliers to ‘green’ their delivery fleets. We are also targeting the conversion of our own entire fleet of cars and vans to electric or plug-in hybrid by 2020, with ultra-low emission standards for all airside vehicles to follow by 2025. Additionally, our fully autonomous zero-emission PODs have been transformational in helping to manage congestion and air quality impacts by eliminating 70,000 bus journeys every year.

 

Figure 1 – Heathrow PODs in numbers

 

 

Heathrow also subsidises local public transport, hosts the largest single-site car sharing scheme in the world and promotes new direct rail links. To take us to the next level, we will ensure that at least 50% of our passengers will travel to and from Heathrow by public and sustainable transport by 2030.

 

Surface access - sustainable travel

 

How people travel to and from the airport is a vital consideration for Heathrow. In May 2019, Heathrow announced tough new measures to tackle the main source of local air pollution – road vehicles – and reduce congestion by encouraging greater use of public transport. Heathrow’s Ultra-Low Emission Zone – the world’s first airport ULEZ – proposes to target older, more polluting passenger cars and private hire vehicles by 2022. Over time with the opening of the proposed new runway from 2026 and improvements to public transport access to the airport, the Heathrow ULEZ will transition into a Vehicle Access Charge (VAC) on all passenger cars, taxis and private hire vehicles coming to car parks or drop-off areas.

 

Figure 2 – Heathrow Ultra-Low Emissions Zone

 

 

Charges will help fund new measures to improve sustainable transport modes at the airport and public transport access proposed as part of Heathrow’s expansion plans, and will contribute to community compensation. This provides further demonstration of our balanced approach to ensure expansion is not a choice between the economy and the environment – it will deliver for both.

 

We are committed to promoting sustainable journeys by improving both the choice and range of options for our passengers and enhancing the quality of their experience.

 

Our vision is to transform the airport into a fully integrated national transport hub offering connectivity to allow all the UK to connect to its hub airport. This will support better local transport solutions that allow communities around the airport to benefit from the improving connections that will evolve over time, and ensures local areas can thrive without increased congestion. Heathrow’s Draft Surface Access Proposals[5] were published in June 2019, outlining our approach to delivering new and sustainable modes of transport to the airport. The strategy includes policies and initiatives for each mode of transport, forming our ‘toolbox’ approach to ensure our plans are responsive. This includes proposals on road user charging, taxis and private hire vehicles, Heathrow colleagues and freight. With support from and in collaboration with Government, industry and interest groups, our ambitious plans will help set the standard for other airports across the UK.

 

As such, the Government should also look at improving surface access to airports; ensuring high-quality 24-hour public transport options; delivering committed projects such as HS2 and Elizabeth Line; and progressing with planned projects including Western Rail Access and Southern Rail Access. Such projects enable airports to accommodate additional passengers without further air quality impacts from their travel to the airport. For example, transport improvements over the last 20 years has meant that while our passenger numbers have risen by almost 80%, airport-related road traffic has remained broadly static.

 

It is critical that the Government places a greater priority on the importance of surface access links to airports and sets out a clear framework within which stakeholders can work together to deliver a joined-up surface access strategy.

 

Noise

 

Heathrow brings huge economic benefits both locally and nationally – as one of the largest single-site workplaces in the UK, we are proud to provide the workplace for over 76,000 people, over half of whom live in our five local boroughs. But for all the benefits that Heathrow delivers, we know that aircraft noise remains an issue for those living around the airport. That is why we strive to work together with our airlines, NATS, the Government and the communities themselves to manage and reduce the effects of aircraft noise.

 

Heathrow has some of the world’s toughest rules and regulations on noise, which have played a major role in driving developments in quieter aircraft technology. These technological improvements have meant that, despite the doubling of aircraft numbers since the 1970s, we have seen a tenfold decrease in the numbers of people falling within Heathrow’s noise footprint.

 

Limits and restrictions, particularly on flights at night, promote the use of ‘best in class’ aircraft; the financial incentives we provide also encourage airlines to use the quietest aircraft through variable landing charges. Together, these have contributed to more of the quietest aircraft being used at the airport. On average the aircraft used by airlines at Heathrow are 15% quieter than their total global fleets.

 

However, managing the impact of aircraft noise for local communities is not just about improving technology. How and where aircraft are flown are also important factors. Airlines, airports and air traffic controllers employ a number of procedures to limit noise in this way and Heathrow has been at the forefront of promoting the use of these.

 

Heathrow has a range of relevant, major initiatives and publications that cover noise in relation to our current operations and expansion plans:

 

 

Resources and waste

 

Resources and waste is a key sustainability issue for Heathrow, an issue that is also tangible for our passengers – most passengers generate waste in their journey through the airport. We have set an ambitious leadership commitment to operate a zero-waste airport by 2050. In practical terms this means we will prevent, reuse or recycle 100% of current waste by that date.

 

Heathrow will follow the waste hierarchy as our principal guide and draw inspiration from the circular economy model, working with partners and suppliers to develop and implement ‘circular’ solutions that will maximise the usefulness and quality of the resource used by ourselves and our business partners and cut waste.

 

Waste is a broader societal issue and Heathrow cannot achieve its goal in isolation. Clear leadership and action from the Government is necessary. Heathrow welcomes the publication of the Government’s resources and waste strategy[9]. We support the Government’s ambition and intent which aligns well with Heathrow’s resource and waste goals.

 

The Government should go further and faster to ensure that packaging placed onto the market can be commercially recycled, and that the waste management and reprocessing industry has the capacity and markets to handle and sell recycled material. Heathrow, like other airports can directly control the collection and segregation of discarded material, however, we have limited influence to improve the recyclability of packaging material used by other organisations, often with national or international supply chains, and the commercial markets for recycled material.

 

Where Heathrow does have control or the ability to influence more sustainable outcomes, we will lead. We have already started implementing a programme of waste improvements with a particular focus on single-use plastic items. We are aware of our role in reducing the environmental impacts associated with this waste. Examples of current initiatives include:

 

 

However, in some areas regulation does not yet align with the Government’s strategic intent and reduces options for airports to generate a meaningful increase in recycling. We urge the Government to consider these particular areas and consider where regulations can change to strike a better balance between action on waste and existing priorities.

 

 

 

 

International Catering Waste

 

Currently, 25% of total waste handled by Heathrow originates in the cabin of arriving aircraft. This waste stream is primarily made up of recyclable material such as plastic drinks containers, newspapers and magazines but also some food, drink and associated packaging which is consumed by passengers in-flight. It does not include in-flight meals and other galley waste which is collected whilst airborne by airline crew and removed and managed by the airline’s in-flight catering providers.

 

All material collected from aircraft is managed in accordance with the Animal By-products regulations to protect animal health and Heathrow and our partners work closely with the local Regulator. There is currently a zero-tolerance enforcement approach. Waste is incinerated if there is any trace of food, drink or associated packaging regardless of whether this is derived from animal products. Heathrow has invested in dedicated screening facilities and personnel to recover any compliant waste. We also work with airlines to improve on-board segregation processes. Despite this investment only 10% of aircraft cabin waste can be recycled under the current regulations. Most waste bags of newspapers, plastic bottles and other material recyclable material taken from the aircraft cabin are incinerated as they contain a coffee cup or bread roll, or other trace of catering waste.

 

Recent research commissioned by IATA indicates the current regulation of international catering waste globally is not risk-based and highlights an opportunity for smarter regulation[10] which Heathrow would strongly support. It sets out a series of recommendations which would maintain the current level of animal health controls whilst increasing recycling and supporting the circular economy. Those include updated regulatory guidance that allows for the recycling and reuse of materials uncontaminated by animal by-products specifically (meat), and mutual recognition of the animal health controls by countries with a similar status, downgrading the risk classification from flights originating in these countries, facilitating reuse and recycling.

 

Heathrow strongly recommends the Government considers the findings of the IATA research and looks at where changes can be made to increase recycling of waste from aircraft whilst applying proportionate risk-based controls to address the risks to animal health.

 

Security screening processes and waste generation

 

As part of the security screening process at airports, single use plastic bags are used to hold the liquids, aerosols and gels (LAG) that passengers are able to take with them into the Critical Part of the Restricted Security Area (CPRSA). Heathrow supports any viable opportunity to design out the requirement for single use plastic bags through the adoption of new technology or other means in future improvements to aviation security regulations and standards. Whilst the technology develops to allow LAGs to be carried outside of plastic bags, Heathrow is looking at innovative ways to reduce the environmental impact of the bags whilst complying with the regulations, we welcome continued Government support to achieve this.

September 2019

 

 

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[1] Heathrow 2.0 https://your.heathrow.com/heathrow-2-0/

[2] ACI Europe https://www.aci-europe.org/component/downloads/downloads/6103.html

[3] Heathrow Carbon Neutral Growth Roadmap 2018 https://your.heathrow.com/wp-content/uploads/2018/12/Heathrow-Carbon-neutral-growth-online.pdf

[4] IATA https://www.iata.org/pressroom/pr/Pages/2019-06-19-01.aspx

[5] Heathrow Draft Surface Access Proposals https://aec.heathrowconsultation.com/topics/surface-access-introduction/#surface-access-proposals-1

[6] Heathrow Noise Action Plan https://www.heathrow.com/noise/making-heathrow-quieter/noise-action-plan

[7] Heathrow Airspace and Future Operations Consultation (AFOC) https://afo.heathrowconsultation.com/

[8] Heathrow Airport Expansion Consultation (AEC) https://aec.heathrowconsultation.com/

[9] Resources and waste strategy for England, December 2018, DfT https://www.gov.uk/government/publications/resources-and-waste-strategy-for-england

[10] International catering waste: a case for smarter regulation; IATA https://www.iata.org/whatwedo/environment/Documents/summary-icw-case-for-smarter-regulation.pdf