Richmond Heathrow Campaign                            AECN0044

Written evidence submitted by Richmond Heathrow Campaign (RHC)

The Environmental Audit Committee

Call for Evidence: Airport Expansion and Climate and Nature Targets

INTRODUCTION

Richmond Heathrow Campaign                            AECN0044

1. RHC represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green, and the Kew Society, which together have over 2000 members. We acknowledge Heathrow's contribution to the UK economy and seek constructive engagement in pursuit of a better Heathrow. We are an active participant in the Heathrow Community Noise Forum.

2. Our premise is that it would be preferable to aim for a better Heathrow rather than bigger Heathrow and to capitalise on the world beating advantage of London's five airports, in particular by improving surface accessibility to all five airports. Aviation growth should be shared across the UK and not concentrated at Heathrow and other South East airports.

3. There is a strong case for no new runways in the UK which is well supported by the evidence produced by the Airports Commission and the DfT in relation to the Airports National Policy Statement, 2017 and by the Climate Change Committee in its Sixth Carbon Budget, 2020.

4. Please see Call for Evidence for Topics

EXPANDING AIRPORT CAPACITY WITHIN THE GOVERNMENT’S CLIMATE AND ENVIRONMENTAL OBLIGATIONS

RHC Response to Topics 1, 2 and 3.

CLIMATE CHANGE

Richmond Heathrow Campaign                            AECN0044

5.                     The Paris Agreement. 196 countries (including the UK) adopted The Paris Agreement (a legally binding treaty) to limit global warming to well below 2 degrees above pre-industrial levels and preferably to 1.5 degrees. United Nations Climate Change Conference (COP21 2015).

6.                    The UK's Climate Change Act of 2008 sets legally binding targets for reducing greenhouse gas emissions and preparing for climate change impacts. It has been amended to include aviation and shipping and a net-zero target for 2050. Progress monitored by parliament annually.

7.                   The "polluter pays principle" in the UK, Environment Act 2021, means that the costs of environmental damage should be borne by those who cause it, rather than the wider community or those who suffer the damage.

8.                   Jet Zero Strategy 2021. Aims to deliver solutions that reduce the sector’s emissions whilst delivering economic benefits across the UK.

9.                    The Sustainable Aviation Fuel (SAF) Mandate, effective from January 1, 2025, aims to reduce greenhouse gas emissions from the aviation sector. The mandate will increase the required percentage of SAF over time, starting at 2% in 2025, 10% in 2030, and 22% in 2040 and is predicted to deliver emission reductions up to 2.7 MtCO2e in 2030 and up to 6.3 MtCO2e in 2040.

10.               Revenue Certainty Mechanism. The government intends to introduce a bill during this parliamentary session legislation for the revenue certainty mechanism is laid by the end of 2026. Provisions within the bill will provide powers to introduce a levy using subsequent regulations..

11.              There is substantial risk the aviation net zero target for 2050 will not be achieved by the UK and even greater risk it will not be met by nations globally.  More important than a single year target for 2050 is the global remaining carbon budget of an estimated 400 Gt of CO2[1] , which limits accumulated carbon in the atmosphere and oceans and thereby the temperature rise to no more than 1.5 degrees. Over the next 30 years to net zero in 2050, the cumulative global emissions could reach 600 Gt and far exceed budget. The current deferral of targets by nations and industries fails to recognise with irretrievable damage that warming is driven by accumulated carbon and not just annual net zero.

12.              Globally, there were around 4 bn commercial aviation passengers in 2018 (60% on international flights and 40% domestic). This varies considerably by nation. For example, 96% of the UK’s 292 million passengers were on international flights. This strongly suggests the UK should be controlling aviation CO2 emissions from international arrivals and departures and not just departures, as currently. The UK substantially under budgets aviation carbon and still does not include the substantial impact of contrails.

13.              The UK’s 6th Carbon Budget aviation pathway to net zero by 2050 is summarised in Figure 1. We comment on each key component - (A) demand, (B) efficiencies,  ( C) sustainable aviation fuels (SAFs) and (D) removal of carbon from the atmosphere (GGR). The UK Unconstrained Balanced Net Zero scenario starts with 51 Mt/yr of carbon emissions in 2050.

A. Aviation demand growth and management (Carbon reduction needed: 12 MT/yr)

14.               IATA, in support of its target net zero by 2050 (Fly Net Zero), predicted a global 3.1% a year growth or compound 250%; global passenger numbers rise from 4 bn in 2018 to an estimated 10 bn in 2050. Growth rates per nation differ significantly. By comparison with global predictions, the UK aviation industry and Government predict UK unconstrained passenger growth from 292 mppa in 2018 to 478 mppa in 2050, which is an average 1.6% a year or compound 65%. UK aviation is relatively mature and understandably the growth rate is less than for less developed nations and markets. But even so, the UK’s 6th Carbon Budget deems it necessary, in order to achieve net zero by 2050, to limit growth to 365 mppa in 2050, which is average growth of 0.7% a year or compound 25%. Aviation industry estimates of global and UK growth are no where near sustainable.

15.              The world’s population travelling by air in 2018 was just 11 per cent, with at most 4 per cent taking international flights. Most people do not have the economic means. The harm from the climate emergency will disproportionately impact the less well-off. The benefit to the few who fly will be at the expense of the many who do not fly. There is a substantial moral issue.

16.              Heathrow and individual airlines raise a high level of opposition to managing growth RHC calculates average ticket prices need to rise by 70%, which accords with the polluter pays principle enshrined in the Environment Act 2021.

17.              RHC proposes increased air passenger duty (APD) for fiscal and not pollution control reasons but with the effect of constraining demand. RHC estimates passenger demand is inflated as a result of under-taxation by around 10%. Full and fair tax on aviation, based on the exemption from fuel duty and VAT, would have been around £15.8bn in 2019 instead of actual £3.6bn. The shortfall, net of actual APD, was a substantial £12.2bn (£9.4bn from terminating passengers and £2.8bn from International to International (I-I) transfers’ exemption from tax). The substantial increase in HM Treasury income could support the less well off, social care, etc. UK aviation is substantially under-taxed compared to other sectors of the economy.

18.              Figure 2 shows the Heathrow Passenger Mix and in particular the small and declining proportion of business passengers. Figure 3 shows a small increase in incoming leisure tourists but the economic benefit to the UK is small. The increase in UK resident international travel while beneficial to people’s health and well being adds to the UK balance of payments deficit.

Figure 2.  Heathrow Passenger Mix 2023 and Business Proportion 2010 to 2023.  Source: RHC prepared from CAA Passenger Survey Reports 2010-2023 Tables 1 and 3.1

19.              Figure 3 highlights these issues and is similar to evidence provided by the Airports    Commission in its Final report July 2015.  In 2050 Heathrow’s 3rd runway would add 43 mppa to Heathrow but 17 mppa would be taken from growth at airports across the rest of the UK resulting in 26 mppa net additional UK passengers.

20.              I-I transfer passengers increase from 5 mppa to 16 mppa, all at Heathrow, resulting in only 27 mppa net additional Terminating passengers at Heathrow and only 10 mppa net additional Terminating passengers across the UK including Heathrow.  The UK aviation market outcome surely cannot be justified and it is extraordinary that the Airports Commission in 2015 and Government in its revised Airports National Policy Statement 2017 seemingly ignored the evidenced they had produced.

21.              The Airports Commission said I-I transfers provide little economic value to the UK (a view supported by consultants Oxera and PWC). They do not leave the airport. Moreover, unlike passengers terminating in the UK they are exempt from Air Passenger Duty. As Figure 2 shows, 24% of Heathrow’s passengers in 2023 were I-I transfers. The claim that Heathrow is a hub airport that needs transfers to make routes viable is fiction.  Evidence from the CAA and DfT demonstrates only around 2% of transfers are on Heathrow's thin long-haul routes. For the most part, transfers are on popular routes. International to International transfer passengers contribute to a substantial environmental cost in terms of noise pollution and they use up capacity at the expense of UK Terminating passengers.

22.              Heathrow terminal capacity is around 95 mppa (with some modernisation) the current 83 mppa can be increased as aircraft in Heathrow’s fleet become larger to an average load of 200 passengers and the planning limit of 480,000 ATMs a year in segregated mode can still be maintained. The approx. 20 mppa of I-I transfers would be better replaced by UK Termination passengers.  Current Terminating passengers of around 63 mppa could be increased to 95 mppa - an increase of round 50%.  Heathrow’s capacity is nowhere near efficiently full. 

23.              The Airports Commission and DfT evidence also resulted in Heathrow’s 3rd runway making no material change to the number of destinations from the UK or domestic destinations. The increase in flights adds to the frequency of flights to popular destinations such as New York, often with less than full occupancy and no overall increase in UK connectivity.

B. Additional Efficiencies and Hybrids (Carbon reduction needed 8 MT/yr)

24.              RHC broadly agrees with the estimates for efficiencies. The introduction of hybrids is optimistic but is only a small part of the estimated reduction in carbon anyway.

C. Sustainable Aviation Fuels (SAFs) (Carbon reduction needed 8 MT/yr)

25.              We have significant doubts as to an SAF mandate’s efficacy in reducing aviation carbon during its limited potentially useful 25 year life span, i.e. between the scaling up of SAFs in the 2030s to peak production in say 2050 and subsequent decline as zero carbon propulsion increasingly populates the aircraft fleet and removal of GHGs from the atmosphere becomes price competitive. Promoting zero carbon propulsion and GHG removal hastens the demise of SAFs and a viable SAF investment payback.

26.              The cost of producing SAFs is far higher than fossil jetfuel. We expect considerable difficulty in introducing a Revenue Certainty Mechanism (see para 6). Airlines seem likely to resist the substantial price required in contracts for difference which the Government needs to encourage investors to develop SAF refineries.

D. Removal of carbon from the atmosphere (GGR)(Carbon reduction needed 23 MT/yr)

27.              Engineered greenhouse gas removals include bioenergy with carbon capture and storage

(BECCS) and Direct Air capture of CO2 with storage (DACCS).The 6th Carbon Budget

assumes out-of-sector removal of 23 Mt a year by 2050 - paid for by aviation. In RHC’s view carbon removal remains highly speculative and is over-relying on offsetting, which by 2050 may be limited in availability

28.              The ICAO offsetting scheme for international aviation (CORSIA) will be largely ineffective in our view, on account of the un-reliability, low carbon price that lacks commercial incentive and the temporary life of the scheme - to 2035.

Airport Carbon Quota Scheme

29.              RHC has proposed an airport carbon quota scheme for airports to incorporate in Action Plans. Heathrow, Gatwick and Manchester together emit around 80% of the UK aviation carbon.

AIR QUALITY

30.              Air quality around Heathrow has been improving to levels matching or below UK Air Quality Standards but still far above the WHO recommendations 2021 as shown in Figure 4.  Action is needed and a major part of this relates to ground traffic of staff and passengers involving road, rail, Elizabeth Line, underground and the Western Rail Access and Southern Rail Access Projects. This includes traffic congestion caused by five level crossings on the southern rail Waterloo line.  Heathrow expansion would have a substantially negative impact on many communities due to adverse surface access to/from Heathrow.

AIRCRAFT AND GROUND NOISE             

31.              WHO Guideline noise levels are not measured despite existence of the Guidelines for 25 years and the wide ranging update in 2018. There has been a serious failure of policy in not translating the Guidelines into active management of aircraft noise.

32.              Comparison of Heathrow noise with other UK and European airports further confirms the disproportionate impact of Heathrow.

33.              The Government should place the WHO community noise guideline values on a statutory footing and set a timetable and targets for reducing the levels for air traffic and other major noise sources to the WHO guideline values.

34.              Local noise objectives including the nighttime should be provided for Heathrow and improve on those provided by existing UK policies. There should be equitable dispersion of noise and its reduction and limits on increase as well as benefits from scheduled respite. but recognising that respite also has a cost to communities sharing in the noise they may not otherwise have experienced. Based on the polluter pays principle, communities should not have to share the benefit of less noisy aircraft with the aviation industry by there being an increase in traffic - the passenger should pay for investment in less noise aircraft.

35.              RHC recommends the transfer of Heathrow’s night flights into the daytime, given the capacity available at Heathrow and the little if any incremental costand possible benefits to the airlines.

HEATHROW AFFORDABILITY AND FINANCIAL VIABILITY

36.              In 2017 we concluded that Heathrow, the world’s most expensive major airport, would have to increase its aero charge from £27 per passenger to £38 to breakeven with a 3rd runway or suffer a net present value loss before interest and tax of £11billion which its balance sheet would not support. Airlines seemingly do not agree to this increase, especially during the development phase.  This involves Heathrow’s Regulatory Asset Base mechanism.

HEATHROW’S IMPACT ON THE UK ECONOMY

37.              Figure 5 is an RHC summary of DfT 2017 economic forecasts with adjustments RHC believes were needed based on consultant reports. The forecasts represent a poor return by any standards and are worse after RHC adjustments, especially in relation to the UK GDP of around £2,500 billion.             

SCOPE FOR DEVELOPMENT WITHIN CURRENT CLIMATE AND ENVIRONMENTAL OBLIGATIONS

Response to Topic 4.

38.   See Topics 1 to 3. Additionally, Gatwick, Luton, Stansted and others are already ahead of Heathrow in preparing plans and seeking approvals and we believe there is already more than sufficient existing UK runway capacity to allow for growth constrained by the Carbon Budget.

Response to Topics 5 and 6.

39.   See Topics 1 to 3

REVIEW OF THE AIRPORTS NATIONAL POLICY STATEMENT

Response to Topic 7.

40.   See Topics 1 to 3.  We strongly believe that there is substantial existing evidence requiring a new ANPS and that this evidence plus any updates would negate the expansion of Heathrow.

Response to Topic 8.

41.  RHC has not yet focused on the scope of a new APNS.

Response to Topic 9 and 10.

42.  See Topic 1 to 3

ENSURING CONTINUED COMPLIANCE WITH CLIMATE AND ENVIRONMENT OBLIGATIONS

Response to Topics 11 and 12.

43.  Not answered here.

END

April 2025