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Further written evidence submitted by Heathrow Airport Limited (NPS0092)

1.    Introduction

1.1.         We have to date made the following submissions to the Committee:

1.2  This supplementary written submission:

2.    M25 realignment and costs

Proposition:  "We are still talking about options. There are huge elements of this plan that we have seen no detail about. I do not know how they are going to bridge or tunnel the M25 and how much that is going to cost."

(Willie Walsh, IAG)[1]

2.1.         As outlined in our response to the oral evidence session on 5 February 2018 (paras 7.4-7.5), the new section of motorway will be constructed off-line and the traffic will then be diverted onto it after construction is complete. The M25 will therefore go under the new runway and this can be achieved by either a tunnel or bridge structure; these solutions are similar in cost but they involve different construction techniques. There is more than one design option for this work with early costings ranging from £600m - £700m.

2.2.         Heathrow has worked closely with airlines, the Civil Aviation Authority (CAA), Highways England and the Department for Transport (DfT) in connection with these options, including in relation to costs. The airlines, including IAG and Virgin, are well represented within Heathrow's scheme development process, ensuring that these key stakeholders have sight of our emerging plans as they move through the optioneering process and governance. This process sits in the 'Capital Governance Protocol' which is agreed with the airlines and required by the CAA as part of their regulatory responsibilities.

2.3.         Our Scheme Development Report[2], which forms part of our current public consultation on our emerging options, provides more detail on the constructon options for crossing the M25 and related cost effects.

2.4.         Airlines are not, however, the only stakeholders in this process. It is for this reason that we are consulting publicy on options for the scheme (including the options in relation to the M25) to ensure that we have the benefit of feedback from a range of interests to help us refine our project and deliver the best design for expansion.

 

3.    Cost guarantee, financing & risk

Proposition: “[The risk that the risks are too high] …is why you have to have clarity around the costs. That is why you have to have the guarantees that we are looking for.”

(Willie Walsh, IAG)[3]

3.1.         We are currently in the process of working with stakeholders, including airlines, to optimise our expansion plans so that they deliver high quality infrastructure, they deliver on our commitments to our local communities and provide value for money for passengers and airline partners.

3.2.         We are currently undertaking the first of two public consultations in connection with the preparation of our DCO application. The responses to these consultations will provide important feedback on the options which have been developed in conjunction with our airline partners. This means that cost estimates are still at an early stage and necessarily dependent on the outcome of this and our scheme development process, and as such, a price guarantee is incompatible with this open and consultative early stage of the project. 

3.3.         For these reasons, a price guarantee in the NPS would not deliver the intended outcomes and could even compromise the selection of the most appropriate options for passengers, our local communities and airline partners.

3.4.         We have shown our intent to meet the Secretary of State's challenge to keep charges 'close to current levels' by developing options which reduce the estimated cost of the project by £2.5bn from the proposal submitted to the Airports Commission. Our ability to meet this challenge is backed up by CAA modelling referenced by Andrew Haines in Q635 and Q636 of his evidence to the Committee on 20 February 2018.

3.5.         The responses provided by Andrew Haines in Q641, Q645 and Q649 provide more detail on why a price guarantee would not be appropriate at this stage of the process. Any such guarantee could put off equity and credit investors, resulting in no expansion and consequently harming UK competitiveness by choking growth at the UK's only hub airport.

3.6.         In summary, there are a number of reasons why we believe it would be inappropriate at this stage to offer a price/cost guarantee or fix airport charges to current levels:

  1. Our current cost estimate of expansion is at a relatively early stage bearing in mind that the project is still some 2 years away from the point of submission of a DCO application, and some 3-4 years away from construction beginning. We are presently conducting the first of two extensive public consultations on our proposals and are at an early stage in both our detailed design development and environmental assessment of the emerging options. It would be inappropriate to bind the cost of the project when further changes to the key elements of the project are entirely possible in response to consultation feedback, including from the airlines, and in further addressing mitigation requirements. Any price guarantee imposed now is likely to conflict with the broad objective of the DCO process, which is to select the option that delivers the best balance between the benefits of the project and its impacts. As Andrew Haines commented in oral evidence[4], determining a cost now in the NPS would pre-empt the project to be determined through the DCO process;
  2. A price guarantee could drive the wrong outcomes. As highlighted in oral evidence by Andrew Haines[5], if a cost guarantee meant the scheme did not generate a fair return from an investment perspective, expansion would not happen – Heathrow’s investors cannot be forced to develop a project that is fundamentally uneconomic;
  3. It is not the role of the NPS to seek to determine the cost of the project. The principal role of the NPS is to establish the need for the project and to set out any environmental tests and parameters that the scheme needs to meet and fit within in order to be determined acceptable from a policy perspective. Fixing costs through the NPS would be an unprecedented approach for the nationally significant infrastructure consenting regime and could thwart the achievement of other policy requirements in the NPS, which of course has yet to be designated; and
  4. Fixing a price through the NPS would thwart the normal economic regulatory process of determining a suitable settlement and rate of return for Heathrow’s investment. Andrew Haines set out in oral evidence how the CAA intends to regulate Heathrow’s costs of expansion[6].

Proposition: “…we don’t really believe the £14 billion [cost for expansion]. Our complaint is that that risk in the process cannot come back to airlines and passengers.”

(Dale Keller, Virgin Atlantic)[7]

3.7.         The £14bn cost referred to in the proposition has been worked up as part of our optioneering work in relation to expansion. The scope, cost estimate and schedule have been shared at a high level with the airline community and the independent fund surveyor (IFS). The IFS has prepared a report on this work and has confirmed, in general, that the estimating process and high level benchmark rates are appropriate and we are still discussing the appropriate risk percentages for this stage

3.8.         As set out in previous evidence to the Committee on 29 January 2018,  we have a proven track record in delivering privately financed multi-billion pound transformational infrastructure. We have invested £10bn over the last decade including the delivery of Terminal 5 and Terminal 2, whilst managing and mitigating construction risks and keeping the busiest two runways in the world fully operational. With an asset base of more than £15bn and £2.75bn in revenues, we are uniquely well placed to fund a new runway.

3.9.         The ability to access markets globally to finance Heathrow’s development and transformation reflects global investor confidence in the stability of cash generation at Heathrow, even during multi-billion investment programmes. We have stated publicly that we aim to maintain our current investment grade credit ratings during expansion. Investors have confidence in the strength and resilience of Heathrow. This year, Heathrow is forecast to generate £1.8bn from its operations with close to 79 million passengers expected to use the airport. We have emerging options as part of our expansion plans that could enable us to further increase the number of passengers using Heathrow even before the opening of the new runway. This would further increase our turnover to support the ability to finance our expansion.

3.10.     Demand at Heathrow is uniquely diverse and resilient with a balanced combination of business and leisure travel that is truly global and without geographic concentration. This provides a strong base from which to build a robust business plan, backed up by clear demand from new airlines that want to operate from Heathrow. Heathrow’s strength and resilience provides confidence to investors, particularly through economic cycles.

3.11.     The balance of affordability and financeability are key for any investment. We are currently consulting on our emerging options and our plans indicate that expansion is possible whilst keeping airport charges close to 2016 levels. These can be 100% privately financed within a fair and stable regulatory framework that provides appropriate risk and reward to investors.

3.12.     Reference is made to the Airports Commission’s forecast 50% increase in airport charges needed to fund expansion (Q644, Oral Evidence session 20th Feb). Our extensive options development work has indicated how we can reduce the cost of the scheme by over £2.5bn compared to the scheme we previously submitted to the Airports Commission to achieve the £14bn referred to above. This is a reduction of over £3.5bn if the Airports Commission’s higher overall cost estimate of £17.6bn is taken into account.

3.13.     This substantial reduction in capital expenditure can be achieved through more efficient phasing and build compared to our Airports Commission submission, and discussions with airlines indicate an opportunity to consolidate growth across Western and Eastern campuses; driving operating efficiencies for airlines. The measures driving this reduction, together with working with the airlines on how to increase passenger volumes, is expected to deliver charges close to current levels through to 2035.

3.14.     As explained earlier, our plans are at an early stage of design and will continue to be evaluated to optimise savings and mitigate risks. The options and detailed designs are currently subject to public consultation, and we will take the feedback provided into account in our further development of the scheme.

3.15.     In addition to the cost savings we are driving, and will continue to drive through our scheme development process, we note that the CAA has the role of regulating landing charges at Heathrow in its role as economic regulator of the airport. It has the power to set a cap for the fees that airlines are required to pay for use of the airport. Specifically, landing charges are set against Heathrow's regulated asset base and the CAA can regulate the costs of expansion that will be included in that regulated asset base. This can provide further mitigation for the cost risk referred to in the proposition above.

3.16.     As we have indicated in previous submissions, we are confident that expansion at Heathrow can be delivered whilst maintaining airport landing charges close to current levels.

 

4.    Competition in delivery of airport infrastructure

Proposition: “I do not believe it would be workable to say that we would have somebody else build a third runway, but it is eminently workable to have somebody else design and build the additional terminal capacity that will be required, and other facilities. Introducing competition within Heathrow would be very positive and would certainly help to achieve the objective, which is to ensure that the charges at Heathrow do not increase.”

(Willie Walsh, IAG)[8]

4.1.         Whilst it is feasible for third parties to develop the terminals at an airport, such an approach is not necessary for expansion at Heathrow as a mechanism to keep charges low. As explained above, we have already made good progress in seeking out cost reductions in order to keep charges close to current levels and this is based on a project delivered entirely by Heathrow.

4.2.         Other promoters putting forward different applications could lead to confusion around delivery without any certainty that the commitments we have made to local communities and regions across the UK will be kept.

4.3.         Furthermore, it is not at all clear that such an approach would be better for customers or lead to lower costs for airlines. In particular, examples from New York JFK Airport[9] - where the terminals are run by airlines - shows that separating terminal and airport ownership and operation can lead to much lower levels of customer service, due to less coordination and cohesion between the terminal management, particularly where there may be competing commercial interests.

4.4.         To our knowledge, Munich Airport is the only European example of terminal ownership being shared between an airline and the airport and was cited by Andrew Haines in his oral evidence7. In this example, the strategic priority was not to find better value for money or more efficient ways of working, but as a way for Munich to secure Lufthansa as a major carrier at the airport and incentivise the airline to base a large proportion of their fleet there. As such, the Munich example does not apply to the situation at Heathrow, as Heathrow does not struggle to attract – or need to incentivise – airlines to operate from the airport.

4.5.         One of the key enablers in Heathrow reducing costs whilst increasing customer service levels to become a world class airport has been the transition from silo workforces at each terminal to a proactive integrated whole airport team. This is because a multi-terminal airport like Heathrow needs centralised management to maximise flexibility, efficiency and economies of scale. This type of centralised management has been realised with the introduction of our Airport Operations Centre (APOC): transforming the way the airport is operated, leading to better command and control of airport infrastructure and more efficiency in airfield operations. To separate out one or more terminals from this centralised structure would decrease the efficiency of airport operations and add unnecessary elements of risk.

4.6.         Importantly, when it comes to delivering and operating airport infrastructure, Heathrow’s competitive procurement practices ensure a high-quality product and value for money. But Heathrow does not deliver this infrastructure in isolation. A large proportion of the cost is dependent on the final design and this final design will be informed by our airline community. Therefore, airlines have an important role to play in reducing costs and providing the quality product our passengers have come to expect.BA’s dominant slot ownership at Heathrow

Proposition: “Heathrow has been a competitive market. We have the position we have because we were buying slots off airlines that were abandoning Heathrow. That is the reality."

(Willie Walsh, IAG)[10]

4.7.         Comparing 2007 Heathrow slot ownership with the present day indicates that this statement is not correct. Airlines were not ‘abandoning’ Heathrow and nor were BA buying individual slots on a piecemeal basis from airlines. Instead, slots at Heathrow from BA, BMI, Iberia, Vueling and Aer Lingus were consolidated over time into British Airways' existing operation to mean that IAG today holds 56.6% of Heathrow's slots, of which 51.7% are held by BA.

4.8.         In 2007, BA, BMI, Iberia, Vueling and Aer Lingus combined slots accounted for 57.3% of Heathrow's slots, of which 40.9% were held by BA.  Therefore, it can be concluded that BA’s increase in slots between 2007 and 2017 was primarily down to British Airway's acquisition of BMI in 2012. 

 

5.    Night flight ban

Proposition: “It is not in the consumer or the economic interest for the country to have a hub airport that is not globally competitive. The European hubs are one hour ahead. Frankfurt opens at 05.00, so some of the times being talked about do not sit very well with a hub operation.”

(Dale Keller, BAR UK)[11]

5.1.         At this early stage we are consulting widely on the timing of the 6.5 hour ban on scheduled night flights and how this could be delivered, and no decisions have yet been made.  The NPS makes clear that there should be a 6.5 hour ban on night flights between 23.00 and 07.00 but the precise timing of where that falls within the 23.00 – 07.00 window should be determined through consultation and assessment.

5.2.         We know from previous consultations that a ban on scheduled night flights is important to our local communities. This is why we have committed to use the opportunity presented by expansion to increase the period of the scheduled night flight ban to 6.5 hours, meaning that communities would have a longer period of time during the night when they are not overflown compared to today.

5.3.         We have received the airlines’ suggestion of an alternative way to deliver respite at night, and will be evaluating it along with all other suggestions and feedback received in response to our current public consultation. This evaluation will consider effects on communities, connectivity, passengers and the economic case for different timings and approaches to delivering this important community improvement.

5.4.         The outcome of the evaluation will be reported at our second public consultation, in 2019.

 

6.    Air quality compliance

Proposition: “…one of those legal challenges could be that it actually breaks the law, when we look at the environmental impact.”

(Huw Merriman MP)[12]

6.1.         We noted within our submission to the Committee dated 15 January 2018 that the available evidence (i.e. the air quality assessments completed by the Airports Commission, Government and Heathrow) has consistently concluded that expansion can be delivered without compromising the UK’s air quality legal obligations.

6.2.         We also identified the reasons why the analysis underpinning this evidence can be considered to be conservative, primarily because it does not take account of Heathrow’s full suite of proposed mitigation measures.

6.3.         We know from experience that growth at Heathrow does not need to be a choice between the economy and the environment. We have a strong track record of reducing emissions at the airport despite continued growth in passengers. Between 2008/09 and 2013, our emissions tracking demonstrated a 430 tonne, or 16%, reduction in total emissions of NOX from ground-based sources. Furthermore, NO2 levels on airport have decreased by 20% over the past 20 years.

6.4.         Heathrow has an equally strong track record of delivering modal shift for passengers and colleagues. This record highlights that where good quality public transport connections exist – with comparable journey times – the majority of people travelling to Heathrow use public transport, reducing car use and associated emissions: 

  1. Since the early 1990s, passenger numbers have increased from 40mppa to 78mppa today, whilst we have observed relatively static airport-related traffic, as a result of improved surface access opportunities and our commuter programmes.
  2. In parallel, since the 1990s, investment in rail infrastructure has improved access from London by rail, increasing overall public transport mode share from around 32% to around 40%.
  3. Committed and planned schemes like Crossrail, HS2 and Western Rail link will transform journey times to the rest of the UK and will help to deliver the NPS mode share targets, providing up to 34 trains per hour from 2030, compared to 18 today.
  4. In addition, expansion provides the opportunity to reduce the 40,000 daily passenger car trips from taxis or private hire vehicles per day, and tackle the c.80% which have an empty arrival or return journey associated with them. Passengers who are dropped off at the airport in a private car also generate an additional car journey.
  5. By changing our approach to charging, and prioritising access to the terminals for efficient operations, we can tackle these empty journeys and consequently reduce the impact of this traffic on the road network around Heathrow. Private hire backfilling schemes, charges for vehicle drop off and incentivising long stay parking are just some of the measures which are being considered to tackle empty car journeys.
  6. With regards to colleagues, our dedicated Heathrow Commuter team supports all 76,000 colleagues who work at the airport. Through an annual £4m investment, we have reduced colleague car trips from 77% in 2004 to just over 50% today. Heathrow has the largest single site car share scheme in the world, with 8,500 registered users. Changes to the way that car parking is managed and accessed with expansion will incentivise further take up of this scheme.

6.5.         In order for development consent to be granted, we must demonstrate that the impacts of Heathrow expansion are compliant with the stringent air quality tests defined within the NPS. However, the assessment of the air quality impacts resulting from an expanded Heathrow does not stop with the NPS. As part of our DCO application we will be preparing a detailed Environmental Impact Assessment (EIA) in relation to the project, and this will be based on the latest available data and best practice methodologies.

6.6.         Finally, through our ‘Triple Lock’ commitment, we have guaranteed that new capacity at an expanded Heathrow will only be released when it is clear that the airport’s direct contribution to air quality will not delay compliance with the UK’s legal air quality obligations. This commitment will be set out in and so secured by our DCO.

6.7.         Taken together, the existing evidence base; our commitments relating to surface access and air quality; the requirements of the revised draft NPS and those of the DCO process, should give decision-makers confidence that an expanded Heathrow can be delivered in a way that is compliant with the UK's air quality legal obligations.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

7.    Summary of Key Issues

The Journey from NPS to DCO

7.1.         In considering all the issues that have been raised as part of this inquiry, we ask that the Committee ensures that it considers the NPS in context, as part of a wider process leading up to authorisation to deliver the project.

7.2.         As emphasised by Andrew Haines at the oral evidence session on 20 February 2018, the designation of the NPS will not be a green light, but will only be the first stage in the consenting process for a third runway. The NPS will not allow any works to take place – it will only confirm policy support in principle for the development of a third runway, and will set clear tests and requirements that a subsequent development consent order (DCO) application will have to meet. During the next stage, as we prepare and submit our DCO application, our detailed proposals will be rigorously and publicly tested against those NPS requirements to ensure that our application is acceptable.

7.3.         The stages of the DCO consenting process, and what further assurances each will provide, are summarised in Table 1 below. How the DCO process will address specific concerns that have been raised by the Committee are set out in Table 2 below.

Table 1: The DCO Consenting Process

DCO Stage

Description & Assurance Provided

Pre-Application

Following designation of the NPS, we will continue to prepare our DCO application. This process involves extensive consultation legally required by the Planning Act 2008, designed to ensure that all interested parties have an opportunity to comment on our proposals, which will be more detailed than our current consultation. Information we have to provide at this stage includes Preliminary Environmental Information, which will provide more detail to consultees on the environmental effects of our proposed designs. We will also provide more information on how we plan to mitigate any impacts.

Bodies that must be consulted include local authorities (with whom we already have an established dialogue through the Heathrow Strategic Planning Group), the Heathrow Community Engagement Board, bodies like Natural England and the Environment Agency, other statutory undertakers (including Network Rail and Highways England) and the CAA.

Acceptance

After statutory consultation, we will refine our proposals and submit the application to the Planning Inspectorate (PINS). PINS will have 28 days to decide whether or not to accept the application for examination. During this period, PINS will consider whether or not the application meets the desired standards, including whether our consultation has been adequate, and as part of that PINS will ask the local authorities what they think about how we have carried out our consultation.

Our application with include a full Environmental Impact Assessment (in the form of an Environmental Statement) and a tracker setting out how all the requirements of the NPS have been met in our application.

Pre-Examination and Examination

If the application is accepted for examination, all affected parties are notified once again and have a chance to submit comments to PINS on the final application. The examination then follows, a six-month period in which the Examining Authority (which will be a panel of five examining inspectors appointed by PINS) scrutinises the application, principally through written questions and hearings. The Examining Authority will seek detailed assurances on any areas it is concerned about, including on compliance of the application with the NPS.

Recommendation and Decision

The Examining Authority will prepare a report to the Secretary of State for Transport on the application, and the Secretary of State for Transport will then take a decision on whether to make the DCO applied for (with or without modifications).  The Secretary of State will also prepare a letter setting out reasons for the decision.

Under the Planning Act 2008, unless certain exceptions apply, the Secretary of State must decide the DCO application in accordance with any relevant national policy statement, meaning that it will be a legal requirement for our application to demonstrate how all of the NPS requirements and conditions have been met in our application.  This means that the NPS has a particular legal role and significance, unlike normal government planning policy.

Implementation

If granted, the DCO will include numerous detailed requirements (akin to conventional planning conditions), including 'pre-commencement' requirements that will have to be discharged by the appropriate planning authority before the development can begin (for example, submission of final designs showing the details of building designs or mitigation plans). Many of these requirements will be implementing the requirements and conditions of the NPS.

We will then have to deliver the project in accordance with the requirements of the DCO and the details of the approved plans. It is an immediate criminal offence to breach the terms of a DCO.

Operation

In addition to the regular assessment and reporting that we already undertake, we expect that our DCO will include requirements to monitor, report on and update effects and impacts of the scheme as it progresses. This will help ensure that mitigation plans proposed are effective and that impacts are being managed and, where required, adjusted.

 

Scheme and DCO Promoter

7.4.         We have previously set out[13] why we consider that the NPS should specify Heathrow Airport as the only plausible promoter of the scheme or, at the very least, set out clear operational, funding and compliance criteria which any promoter would need to fulfil in order to bring forward the delivery of the scheme.

7.5.         Naming Heathrow Airport as the relevant statutory undertaker who will deliver the scheme would reassure those affected by the scheme that the complete mitigation package (as committed to by Heathrow Airport only) will be delivered by a responsible promoter, whilst providing confidence to investors.

7.6.         The NPS should be seeking to provide certainty for communities and landowners about how the scheme will be taken forward and by whom, not causing confusion about who the Government is now relying on to deliver the UK's much needed additional hub capacity.

7.7.         If the NPS will not name Heathrow Airport as the preferred promoter, it is important in the public interest for the NPS to set out at the very least clear criteria that any DCO applicant would need to satisfy in the course of promoting their DCO application, including during its examination.

7.8.         It would fall to the Secretary of State for Transport, as part of the process of determining the DCO application, and taking into account the advice and recommendations of the panel of examining inspectors who examined the application, to consider whether those criteria had been satisfied.

7.9.         We have said that the criteria could be expected to be focused around the following:

      1. the promoter’s experience, resources and capacity to deliver the scheme, to comply with all NPS requirements, and to honour all commitments given in relation to expansion, including during the DCO process;
      2. the promoter’s ability to finance and fund the scheme, including meeting all statutory blight obligations;
      3. the effect of construction of the scheme on the existing operating airport, including landing charges; and
      4. use, ownership and control of land required for the scheme.

7.10.     To provide appropriate reassurance, the criteria could be expected to have as their underlying objective the requirement for the promoter to demonstrate that:

      1. it has sufficient control of the entirety of Heathrow Airport to be able to deliver the fundamental reconfiguration of the existing airport that successful expansion will require;
      2. it can deliver a sufficiently integrated expanded airport so that the essential characteristic of a hub airport is maintained; and

it can utilise sufficient landing charges across the entire airport to fund expansion.

 

The Role of the Civil Aviation Authority in the DCO Process

7.11.     The Civil Aviation Authority (CAA) is a statutory consultee under the Planning Act 2008. This means that we will be required to consult with the CAA on our proposed DCO application. We are working with the CAA at present to agree the scope for that engagement but, having regard to the revised draft NPS, we expect it will include engagement on the following matters:

      1. Safety & National Security (see paragraphs 4.56 – 4.65 of the revised draft NPS);
      2. Securing noise mitigation (see paragraph 5.56 of the revised draft NPS); and
      3. Costs and affordability (see paragraph 4.36 of the revised draft NPS).

7.12.     We have previously set out[14] why we consider that it would be helpful if the NPS could do more to clarify the role of the CAA in the DCO process, so that both PINS, the Examining Authority (once appointed) and the CAA understand what is expected and to ensure an appropriate amount of information is provided to help the Examining Authority reach decisions on those issues where the CAA has specialist expertise.

7.13.     We think it would assist all parties, including the public, if the NPS was clearer and gave guidance on how and when the CAA should engage in the DCO process as a statutory consultee. It is clearly important for it to do so in order that matters relating to its functions and relevant to the DCO can be raised and considered by all concerned during the DCO process, including members of the public, but in a way that maintains the CAA’s independence and the integrity of its exercise of these functions.

 


Overview of how control is secured in relation to key issues

The summary table below sets out the key issues raised in evidence to the Committee, the way in which appropriate policy is set in relation to these matters through the revised draft NPS, and the way in which later “downstream” regimes will ensure appropriate further scrutiny, control and regulatory oversight in relation to such matters.

Table 2 - How the DCO process will address specific concerns that have been raised by the Committee

Topic

Issue

Revised Draft NPS wording

HAL's previous TSC submissions

How one or more of the 'downstream processes' (i.e. DCO, Airspace Change and/or the CAA's regulatory functions) will cover / deal with the issue

Summary

Air quality

How can expansion be delivered in a way that is consistent with the UK's legal air quality obligations?

"5.31 The applicant should undertake an assessment of the project, to be included as part of the environmental statement, demonstrating to the Secretary of State that the construction and operation of the Northwest Runway will not affect the UK’s ability to comply with legal obligations. Failure to demonstrate this will result in refusal of development consent."

 

"5.41 The Secretary of State will consider air quality impacts over the wider area likely to be affected, as well as in the vicinity of the scheme.  In order to grant development consent, the Secretary of State will need to be satisfied that, with mitigation, the scheme would be compliant with legal obligations."

  1. Paragraphs 6.16 – 6.27 of the 24 March 2017 submission.
  2. Paragraphs 4.1.1 – 4.1.13 of the 30 November 2017 submission.
  3. Paragraphs 2.18 – 2.20; 5.1 – 5.5 of the 29 January 2018 (matters raised in oral evidence) submission.
  4. Paragraphs 8.1 – 8.9 of the 12 February 2018 submission.
  1. The revised draft NPS makes comprehensive provision in relation to air quality from a policy perspective.  It makes clear that development consent will not be granted unless expansion is compliant with air quality legal obligations.
  2. Under the Planning Act 2008, the DCO cannot be made if it would lead the UK or the Secretary of State to breach any international obligations or duties under statute.
  3. All the evidence to date indicates that expansion will be consistent with the UK’s legal air quality obligations.  We have set out (for example in paragraphs 6.24 onwards of the 24 March 2017 submission and paragraphs 4.1.9 onwards of the 30 November 2017 submission) our provisional means to ensure that.
  4. However, in any event, HAL's DCO application will be accompanied by detailed assessments (based on the final scheme design) which will develop those methods and demonstrate how it is possible to deliver expansion consistent with the UK’s legal air quality obligations. The environmental statement to be prepared as part of the application will describe the aspects of the environment likely to be significantly affected by the project.
  5. The DCO itself will include detailed proposals for managing air quality impacts (for example it could include an emissions charge), which will be legally secured via the DCO. 
  6. As required by Environmental Impact Assessment Regulations, the DCO will also include plans for the ongoing monitoring of air quality at the airport, setting out additional mitigation steps to be taken if required.  We will continue to consult on the details of those plans for mitigation and monitoring with key stakeholders and the community.
  7. Ultimately, it is the role of the Examining Authority considering the DCO application, and finally the Secretary of State for Transport in determining the DCO application, to consider the detailed evidence of impact and mitigation and to decide on the most effective and appropriate requirements to include in the DCO to ensure that the policy obligations set out in the NPS can and will be secured, met and then policed.

Air quality compliance, mitigation and monitoring will be assessed under the DCO regime and will be enshrined in the DCO itself.

Air quality and surface access

How will HAL be accountable for its commitments on surface access that are part of ensuring air quality legal obligations are met?

"5.37 In addition, Heathrow Airport should continue to strive to meet its public pledge to have landside airport-related traffic no greater than today. To achieve this, it should set out and regularly review its plans to meet the mode share targets set at paragraph 5.16 above.  Heathrow Airport should also develop and keep under review plans to improve the impact of road freight serving the airport."

 

"5.16 Any application for development consent and accompanying airport surface access strategy must include details of how the applicant will maximise 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. The applicant should also include details of how it will achieve a 25% reduction from the current baseline of all staff car trips by 2030, and a reduction of 50% by 2040 from 2017 levels."

 

"5.17 The applicant should commit to annual public reporting on performance against these specific targets..."

 

  1. Paragraph 4.1.9 and 5.2.3 of the 30 November 2017 submission.
  2. Paragraphs 3.28 and 3.55 of the 8 January 2018 submission.
  3. Paragraphs 2.1 – 2.7 of the 29 January 2018 (matters raised in oral evidence) submission.
  4. Paragraphs 6.15 – 6.19 of the 12 February 2018 submission.

 

  1. As stated above, the revised draft NPS makes comprehensive provision in relation to air quality from a policy perspective.
  2. HAL is required to satisfy certain public transport mode share targets and this will be captured by the DCO.
  3. HAL will evidence how the mode share targets are feasible as part of its DCO application and this evidence will be assessed and tested by the Examining Authority.
  4. The NPS requires that the DCO will secure that HAL will carry out annual public reporting on performance against the specific targets but rightly leaves it open to the Examining Authority and the Secretary of State to determine the best methodology for that.
  5. Ultimately, it is the role of the Examining Authority considering the DCO application, and finally the Secretary of State for Transport in determining the DCO application, to consider the detailed evidence of impact and mitigation and to decide on the most effective and appropriate requirements to include in the DCO to ensure that the policy obligations set out in the NPS can and will be secured, met and then policed.

 

HAL will be held to account in respect of the NPS mode share targets through requirements imposed in the DCO itself.

Airspace change

How has the airspace modernisation process been dealt with as part of the NPS process? How will this process interact with the other key processes going forward, such as the DCO regime?

"5.253 There will be many opportunities for communities to engage as expansion is taken forward. The Government is required to consult on and publicise the Airports NPS, and the applicant is subject to pre-application consultation duties. Additional consultations on issues such as airspace change, overseen by the Civil Aviation Authority, will take place outside of the planning process. Ongoing engagement will also be required as the applicant takes forward its compensation package."

  1. Paragraph 5.3.6 and 6.6.1 of the 30 November 2017 submission
  2. Paragraphs 3.9 – 3.16 of the 29 January 2018 (matters raised in oral evidence) submission.
  3. Paragraphs 4.1 – 4.5 of the 29 January 2018 (matters raised in written evidence) submission.
  1. The revised draft NPS clearly sets out the independence of the airspace change process, overseen by the CAA. It explains that at the time of the DCO process it is understood and accepted that the airspace designs will not yet be finalised and so indicative airspace designs should be developed and used instead for DCO purposes.
  2. The timing of the airspace change process is not wholly within HAL's gift because airspace designs are dependent on the development of other changes at neighbouring airports and airfields, and vice versa. HAL's timescales are linked to other airspace changes, which are not expected to be finalised before c.2021.
  3. Nonetheless, extensive public consultation is a major part of the airspace change process. HAL is satisfied that sufficient information (including environmental information on noise impacts) will be available during the DCO process to allow those interested to make their views known at the time.
  4. HAL has sought an amendment to the revised draft NPS to ensure that it explicitly states that the Secretary of State will not impose DCO requirements which risk undermining subsequent or parallel decisions, such as the airspace change process.

 

The ACP and the DCO processes are separate. However, sufficient information from the airspace process will be available to inform the DCO process, particularly the assessment of the environmental impacts of expansion.

Costs

 

How is it possible to be confident in the economic case supporting expansion when the costs of the project are uncertain?

"4.36 The applicant should demonstrate in its application that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime."

  1. Paragraphs 3.3.1 – 3.3.2 of the 30 November 2017 submission.
  2. Paragraphs 4.1 – 4.3 of the 29 January 2018 (matters raised in oral evidence) submission.
  3. Paragraphs 7.1 – 7.7 of the 29 January 2018 (response to maters raised in written evidence) submission.
  1. The conservative estimate of economic benefits set out in the revised forecasts is in the region of £72.8 to £74.2 billion whereas the costs of expansion (including surface access costs) were estimated by the Airports Commission at £16 billion (and our optioneering work has identified that costs could be lower than that).  As such the economic case is clear and would not be affected by any uncertainty as to costs. 
  2. That said, we take our obligation to control and reduce costs very seriously.  It is clear that via both the requirements laid out in the NPS and the regulatory oversight of the CAA, we will be held to strict requirements regarding cost-efficiency. 
  3. The revised draft NPS is clear that key elements of the CAA's economic remit, not least cost and affordability, are going to be important considerations as part of the examination and determination of our DCO application for expansion. Reinforcing this, under current regulations the CAA will be a statutory consultee in relation to the DCO application.  
  4. We have suggested, however, that the NPS could helpfully clarify that the CAA’s important economic regulation role should be very much brought into the DCO process so as to bring the two regimes closer together.  In particular, we think it would be helpful if the NPS gave clear guidance on how and when the CAA should engage in the DCO process.
  5. It is clearly important for the CAA to do so in order that matters relating to its functions and relevant to the DCO can be raised and considered by all concerned during the DCO process, including by members of the public, but in a way that maintains the CAA’s independence and the integrity of its exercise of these functions.

The CAA will oversee the cost (and affordability) of the scheme through its regulatory role. HAL believes the NPS should be bolstered by giving guidance in relation to the CAA's role during the DCO process.

Deliverability

Can the NWR be delivered a) on time; and b) to budget?

"4.36 The applicant should demonstrate in its application that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime."

 

  1. Paragraphs 3.3.1 – 3.3.2 of the 30 November 2017 submission.
  2. Paragraphs 7.1 – 7.7 of the 29 January 2018 (response to matters raised in written evidence) submission.
  1. The revised draft NPS is clear that the need identified is to increase capacity by 2030. In order to benefit from the policy support set out in the NPS, we will have to satisfy the Examining Authority that the north-west runway scheme can be delivered on time.  If we do not, we will not get the DCO. 
  2. We are confident that we can deliver it in the timeframes envisaged and  will look to improve upon the methodologies assumed by the Airports Commission as we move through our consultation exercises. Notwithstanding that, the Airports Commission concluded that our scheme could be delivered by 2026 (para 11.33 of the Airports Commission Final Report).
  3. The revised draft NPS challenges HAL to demonstrate in our DCO application that the scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime.
  4. HAL will demonstrate in our DCO application that we can fund and construct the scheme in line with the stated timelines. Alongside other key considerations such as airport operations, sustainability, environmental and community effects, cost and affordability have been two of HAL's principal measures for evaluating the scheme options.
  5. Ultimately, it is the role of the Examining Authority considering the DCO application, and finally the Secretary of State for Transport in determining the DCO application, to assess whether HAL has satisfied this requirement in the revised draft NPS.

In respect of deliverability:

a) HAL will demonstrate in its DCO application that it can deliver the scheme within the stated timelines; and

b) HAL will be required to satisfy the test in the NPS that it can fund the scheme (i.e. the proposals are cost-efficient and sustainable).  This is a specific requirement of the DCO process (i.e. the requirement to demonstrate adequate funding for the project).

Domestic connectivity

How will the boost to domestic air connections to the airport be secured?

"3.34 The Government recognises that air routes are in the first instance a commercial decision for airlines and are not in the gift of an airport operator. But the Government is determined that new routes will be secured, and will hold Heathrow Airport to account on this. The Government requires Heathrow Airport to demonstrate it has worked constructively with its airline customers to protect and strengthen existing domestic routes, and to develop new domestic connections, including to regions currently unserved."

  1. Paragraphs 4.16 – 4.17 of the 24 March 2017 submission.
  2. Paragraphs 7.2.1 – 7.2.5 of the 30 November 2017 submission.
  3. Paragraphs 2.7 – 2.14 of the 8 January 2018 submission.
  4. Paragraphs 3.5 – 3.9 of the 12 February submission.
  1. Expansion provides a great opportunity to boost air connections to the UK's only hub airport.
  2. HAL is committed to playing its part in boosting those domestic air connections.
  3. The revised draft NPS requires that the applicant demonstrates that it has worked "constructively" with its airlines customers for the purposes of strengthening existing and developing new domestic connections.
  4. The Examining Authority and, ultimately, the Secretary of State will determine whether this has been satisfied in the DCO application.
  5. As set out in paragraph 4.17 of our 24 March 2017 submissions (and the others referenced) we have committed to a range of measures to support the growth of domestic routes, including the Route Development Fund. However, Government must take a leadership role in using the necessary legal powers to secure these domestic routes permanently.

 

 

 

HAL will be required to demonstrate its efforts to work with the airlines in respect of promoting domestic connectivity as part of its DCO application.

Landing charges

How will HAL fulfil its commitment that landing charges will remain close to current levels?

"4.36 The applicant should demonstrate in its application that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime."

 

"5.38 Other mitigation measures which may be put forward by the applicant could include, but are not limited to:

- Landing charges structured to reward airlines for operating cleaner flights (for example NOx emissions charging);"

  1. Paragraph 3.3.2 of the 30 November 2017 submission.
  2. Paragraph 5.1 of the 12 February 2018 submission.
  1. As mentioned above, the revised draft NPS is clear that key elements of the CAA's economic remit, including cost and affordability, are going to be important considerations as part of the examination and determination of our DCO application for the north-west runway. Reinforcing this is that the CAA will be a statutory consultee in relation to the DCO application.
  2. In respect of landing charges specifically, the CAA has the role of regulating landing charges at Heathrow in its role as economic regulator of the airport. It has the power to set a cap for the fees airlines are required to pay for use of the airport. Specifically, landing charges are set against Heathrow's regulated asset base and the CAA can regulate the costs of expansion that will be included in that regulated asset base.
  3. Heathrow is confident that the expansion project can be delivered whilst maintaining airport landing charges close to current levels.

The CAA has the power to regulate landing charges.

Night flight ban

How will the scheduled night flight ban be enforced?

"5.61 The Government also expects a ban on scheduled night flights for a period of six and a half hours, between the hours of 11pm and 7am, to be implemented. The rules around its operation, including the exact timings of such a ban, should be defined in consultation with local communities and relevant stakeholders, in line with EU Regulation 598/2014. In addition, outside the hours of a ban, the Government expects the applicant to make particular efforts to incentivise the use of the quietest aircraft at night."

  1. Paragraphs 3.18 – 3.22 of the 29 January 2018 (matters raised in oral evidence) submission.
  2. Paragraphs 2.21 – 2.23 of the 29 January 2018 (matters raised in written evidence) submission.
  1. The precise period for the 6.5 hours ban on scheduled night flights is not prescribed in the revised draft NPS. This will be determined through consultation and assessment as part of HAL's DCO application and HAL would expect the structure of the ban to be enshrined in the DCO.
  2. As set out above in relation to other topics, it will be for the Examining Authority and, ultimately, the Secretary of State for Transport to establish the most effective and appropriate requirements in the DCO.
  3. The night flight ban, once determined by the Examining Authority and Secretary of State, will be included within the DCO.

The night flight ban will be enforced under requirements included in the DCO and also through the separate night flights regime.

Noise

When will there be clarity in respect of those affected by noise in terms of flightpaths and envelopes?

Paragraphs 5.43 – 5.67 comprise the section on noise in the NPS. It sets out in detailed terms what must be assessed and what the tests that must be met are.

 

"5.49 The Airports Commission’s assessment was based on ‘indicative’ flight path designs, which the Government considers to be a reasonable approach at this stage in the process. Precise flight path designs can only be defined at a later stage after detailed airspace design work has taken place. This work will need to consider the various options available to ensure a safe and efficient airspace which also mitigates the level of noise disturbance. Once the design work has been completed, the airspace proposal will be subject to extensive consultation as part of the separate airspace decision making process established by the Civil Aviation Authority.

 

5.51...The noise assessment should include the following:

  • A description of the noise sources;
  • An assessment of the likely significant effect of predicted changes in the noise environment on any noise sensitive premises (including schools and hospitals) and noise sensitive areas (including National Parks and Areas of Outstanding Natural Beauty);
  • The characteristics of the existing noise environment, including noise from aircraft, using noise exposure maps, and from surface transport and ground operations associated with the project, the latter during both the construction and operational phases of the project;
  • A prediction on how the noise environment will change with the proposed project; and
  • Measures to be employed in mitigating the effects of noise.

These should take into account construction and operational noise (including from surface access arrangements) and aircraft noise. The applicant’s assessment of aircraft noise should be undertaken in accordance with the developing indicative airspace design. This may involve the use of appropriate design parameters and scenarios based on indicative flightpaths. "

 

  1. Paragraphs 3.9 – 3.16 of the 29 January 2018 (matters raised in oral evidence) submission.
  2. Paragraph 2.5 and 2.8 of the 29 January 2018 (matters raised in written evidence) submission.
  1. Before we submit our DCO application, we must conduct a further, statutory consultation on our proposed application. This will include Preliminary Environmental Information on the impacts of the scheme, including noise impacts. This preliminary information will be informed by the airspace design envelopes we will be consulting on at the same stage, so consultees will have a better indication of the likely noise effects of the scheme at this consultation stage.
  2. With our DCO application, we will provide a more detailed Environmental Impact Assessment including a full noise assessment as required by the NPS. As the NPS indicates, this assessment will not be based on final flight paths, as the final routes will be selected by the subsequent airspace change process, but will be based on the latest available airspace design information following the airspace design envelopes consultation.
  3. This, combined with the noise envelope (see paragraph 5.59 of the draft NPS), which will include clear noise performance targets, will provide at the DCO stage assurance to local communities on future noise impacts.
  4. The grant of the DCO will then be followed by the third stage of the airspace change consultation, at which time final flight paths will be consulted on. This consultation will include an environmental assessment of noise, which will also be reviewed by the CAA when the application for airspace change consent is submitted.
  5. The airspace change process will complete the exercise of determining the flightpaths but that process is itself subject to full assessment of noise impacts and the policy requirement to avoid significant adverse impacts from noise and to mitigate and minimise adverse impacts from noise.

We are confident we can provide sufficient clarity regarding noise impacts from flights at all stages of the DCO process to allow anyone affected to provide meaningful feedback. 

Phasing

What elements of the scheme will be phased in? How will this be achieved in terms of process?

The NPS acknowledges that the delivery of the scheme may be phased, and states expressly that:

 

"4.9…The need for requirements in respect of the phasing of the scheme is likely to be an important consideration, so that effects of construction and operational phases are properly mitigated, as well as any changes in the operations of the airport that may occur in line with the phasing of physical works and commencement of operations. Guidance on the use of planning conditions or any successor to it should be taken into account where requirements are proposed.

 

 

"4.17  Effort should be made to refine the detail of the proposed development. However, where details are still to be finalised, such as in respect of the phasing of the development and operational changes at the airport, the applicant is advised to set out in the environmental statement the relevant design parameters used for the assessment. The environmental statement should explain, with reference to the parameters, what the maximum extent of the proposed development may be (for example in terms of site area) or the extent of change in respect of operational impacts, and assess the potential adverse effects which the project could have, to ensure that the impacts of the project as it may be constructed have been properly assessed.

 

  1. Paragraphs 7.3.1 – 7.3.4 of the 30 November 2017 submission.
  2. Paragraphs 21 – 25 of the 15 December 2017 submission.
  3. Paragraphs 4.1 – 4.6 of the 12 February 2018 submission.
  1. HAL will undertake further work to determine the most appropriate way in which the project should be phased, taking into account the scheme development process, feedback from public consultation and stakeholder engagement, as well as an assessment of environmental effects.
  2. Phasing of construction and operation of major projects is common, and is regularly dealt with in the DCO process. The Environmental Statement will assess the impacts of the phasing proposed, and the DCO will set out controls to manage the process, for example requirements that would have to be discharged before the construction or operation of phases can be commenced. Specific requirements will relate to specific phases.

 

Our phasing plans will be developed, assessed and secured through the DCO process.

Respite

How much respite from noise will there be for local communities? How will this be enforced?

"5.60 The applicant should put forward plans for a runway alternation scheme that provides communities affected with predictable periods of respite (though the Government acknowledges that the duration of periods of respite that currently apply will be reduced). Predictability should be afforded to the extent that this is within the applicant's control. The details of any such scheme, including timings, duration and scheduling, should be defined in consultation with local communities and relevant stakeholders, and take account of any independent guidance such as from the Independent Commission on Civil Aviation Noise. "

 

  1. Paragraph 6.30 of the 24 March 2017 submission.
  2. Paragraph 6.3 of the 29 January 2018 (matters raised in written evidence) submission.
  3. Paragraphs 3.1 – 3.8 of the 29 January 2018 (matters raised in oral evidence) submission.
  1. Respite can be provided in two ways: respite through runway alternation, and respite through design of flight paths.
  2. The NPS requires us (paragraph 5.60) to consult on proposals for a runway alternation scheme, and we have started this process in our current consultation. This consultation will inform the development of the alternation scheme.  At our second consultation in 2019 we will present proposals for a runway alternation scheme.  That scheme will then  be legally secured in the DCO, as the NPS also requires us (paragraph 5.65)  to "put forward proposals as to how these measures may be secured and enforced, including the bodies who may enforce the measures". The final proposal will then be assessed as part of the Environmental Statement that must be submitted with our DCO application.
  3. Respite through the design of flight paths will be approved through the airspace change process. Our current consultation on airspace principles will help inform how the airspace should be designed to provide respite.

The NPS contains clear requirements as to the provision of predictable periods of respite for communities, and the required runway alternation scheme has to be secured in the DCO itself.

Safety

How will safety be guaranteed under the expansion proposals?

Safety is referred to in paragraph 4.5 (general assessment principles) and paragraph 4.31 (good design) but the key requirement is as follows:
 

"4.64… Air transport is one of the safest forms of travel, and the UK is a world leader in aviation safety. Maintaining and improving that record, while ensuring that regulation is proportionate and cost-effective, remains of primary importance to the UK. Since 2003, rules and standards for aviation safety in Europe have increasingly been set by the European Aviation Safety Agency. The UK will continue to work closely with the European Aviation Safety Agency to ensure that a high and uniform level of civil aviation safety is maintained across Europe. The preferred scheme at Heathrow must comply with the UK’s civil aviation safety regime, regulated by the Civil Aviation Authority. "

 

  1. Paragraphs 24 – 26 of the 15 December 2017 submission.
  2. Paragraphs 6.1 – 6.7 of the 29 January 2018 (matters raised in oral evidence) submission.
  3. Paragraphs 4.1 – 6.5 of the 29 January 2018 (matters raised in written evidence) submission.
  1. As explained in section 7 the CAA has a role as a statutory consultee in the DCO process. As part of preparing our DCO application, we will be engaging with the CAA to ensure the requirement of paragraph 4.64 of the NPS is met. If necessary, the Examining Authority may also ask the CAA to provide assurance on safety during the Examination phase. The DCO will impose any requirements the Secretary of State considers are necessary to ensure the safety of the scheme.

The safety of our proposals will be tested rigorously as part of the DCO process.

Surface Access

How will HAL ensure that its proposals in respect of the M25, once finalised, are deliverable? How will significant disruption on this major strategic road artery be avoided?

"5.9 The applicant should assess the implications of airport expansion on surface access network capacity using the WebTAG methodology stipulated in the Department for Transport guidance,132 or any successor to such methodology. The applicant should consult Highways England, Network Rail and highway and transport authorities, as appropriate, on the assessment and proposed mitigation measures. The assessment should distinguish between the construction and operational project stages for the development comprised in the application.

5.10 The applicant should also consult with Highways England, Network Rail and relevant highway and transport authorities, and transport operators, to understand the target completion dates of any third party or external schemes included in existing rail, road or other transport investment plans. It will need to assess the effects of the preferred scheme as influenced by such schemes and plans. Such consultation and assessment, both of third party schemes on which the preferred scheme depends, and others which interact with it, all of which may be subject to their own planning, funding and approval processes, must be understood in terms of implications of the timings for the applicant’s own surface access proposals.

5.11 The applicant will need to demonstrate that Highways England, Network Rail and relevant highway and transport authorities and transport providers have been consulted, and are content with the deliverability of any new transport schemes or other changes required to existing links to allow expansion within the timescales required for the preferred scheme as a whole. This includes changes to the M25 to allow a new runway to cross the motorway, local road diversions, and improvements including the diversion of the A4 and A3044, and on-airport station works and safeguarding."

 

  1. Paragraphs 7.4 – 7.5 of the 12 February 2018 submission.
  1. Highways England, which is responsible for the M25, is a statutory consultee in the DCO process, but is also given a specific role by paragraphs 5.9 – 5.11 of the draft NPS. As part of our application, we will be required to demonstrate (paragraph 5.11) that Highways England "have been consulted, and are content with the deliverability of any new transport schemes or other changes required to existing links ".
  2. We are already working with Highways England to develop designs for the M25 changes and put in place the legal arrangements necessary to govern this important and complex piece of infrastructure delivery. We expect to submit joint statements with Highways England as part of our DCO application, and the DCO will include formal protective provisions (a section of the DCO designed to protect statutory undertakers) to manage interfaces and protect the strategic road network during construction of the expansion scheme.

The NPS requires us to evidence in our DCO application that Highways England is content with our proposals for the M25, and we are already working towards that with Highways England.

Surface Access

How will the Western Rail and Southern Rail Access schemes interact with the NPS and DCO processes?

"5.10 The applicant should also consult with Highways England, Network Rail and relevant highway and transport authorities, and transport operators, to understand the target completion dates of any third party or external schemes included in existing rail, road or other transport investment plans. It will need to assess the effects of the preferred scheme as influenced by such schemes and plans. Such consultation and assessment, both of third party schemes on which the preferred scheme depends, and others which interact with it, all of which may be subject to their own planning, funding and approval processes, must be understood in terms of implications of the timings for the applicant’s own surface access proposals.

 

 

  1. Paragraphs 4.3, 8.11, 4.11 and 4.12 of the 24 March 2017 submission.
  2. Paragraph 5.2.5 of the 30 November 2017 submission.
  3. Paragraphs 2.22 – 2.24 of the 29 January 2018 (matters raised in oral evidence) submission.

As required by paragraph 5.10 of the NPS, our DCO application will need to take account of other proposed schemes and projects, including the Western Rail Access to Heathrow Project which has begun its own DCO process. Our Surface Access Strategy and Environmental Impact Assessment will have to be clear about what (if any) assumptions our DCO application makes regarding the delivery of other schemes.  

 

We are engaged in discussions with the Network Rail Western Rail Access team to ensure that our respective DCO applications will be compatible. As a statutory undertaker, Network Rail is a statutory consultee in the DCO process and like Highways England, we would expect to agree ‘protective provisions’(a section of the DCO designed to protect statutory undertakers) with Network Rail to manage interfaces and protect Network Rail assets.

The evidence and engagement-based nature of the DCO process will ensure that all interfaces and dependencies between expansion and rail projects servicing Heathrow are adequately managed.

 

February 2018

[1] Willie Walsh (Chief Executive, IAG), Q585 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[2] https://www.heathrowconsultation.com/wp-content/uploads/2018/01/Scheme-Development-Report-100118-Medium-Res.pdf

[3] Willie Walsh (Chief Executive, IAG), Q590 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[4] Andrew Haines (Chief Executive, CAA), Q635 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[5] Andrew Haines (Chief Executive, CAA), Q642 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[6] Andrew Haines (Chief Executive, CAA), Q638 and Q649 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[7] Dale Keller (Chief Executive, Virgin Atlantic), Q598 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[8] Willie Walsh (Chief Executive, IAG), Q596 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018).

[9] McGeehan, Patrick “How Boston’s Airport Bounced Back from the Storm that Crippled JFK” The New York Times, Feb 27th 2018. https://www.nytimes.com/2018/02/27/nyregion/boston-logan-jfk-airports-snowstorm.html

 

[10] Willie Walsh (Chief Executive, IAG), Q624 of Oral Evidence: Airports Commission National Policy Statement (Tuesday, 20 February 2018)

[11] Dale Keller (Chief Executive, BAR UK), Q630 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[12] Huw Merriman MP, Q675 of Oral Evidence: Airports National Policy Statement (Tuesday, 20 February 2018)

[13] Transport Select Committee Inquiry, Draft Airports National Policy Statement, Further Submission by Heathrow Airport Limited, 30 November 2017, paragraph 3.4.

[14] Transport Select Committee Inquiry, Draft Airports National Policy Statement, Further Submission by Heathrow Airport Limited, 30 November 2017, paragraph 6.6.