Dear Mr Franklin
Thank you for taking the time to write to me
regarding the Government's recent decision to expand Heathrow Airport by
building a third runway.
Air quality is a significant national health
issue that the Government takes extremely seriously. The Airports Commission concluded that a new runway
could be delivered without impacting the UK’s compliance with air quality limit
values for nitrogen dioxide.
The Government conducted further analysis to
compare these conclusions with updated projections provided in the Government’s
2015 Air Quality Plan. This analysis concluded that, based on the Government’s Air Quality Plan, the
Heathrow and Gatwick schemes would neither cause nor worsen exceedances of air
quality limit values.
While Heathrow is already taking action to
reduce air quality impacts, such as through introducing low emission vehicles,
the Government recognises that an expanded airport will need to go further,
including during the construction period. Measures to mitigate air quality
impacts will be determined through the National Policy Statement
and development consent process. They could include measures which an expanded
Heathrow have committed to, including:
I should note that the Secretary of State for
Transport has said that the Government will grant development consent only if it remains satisfied
that a new runway will not impact on the UK’S compliance with its air quality
obligations.
The Government agrees with the Airports
Commission that a new runway at Heathrow can be delivered within the UK’s
carbon obligations. The airport will use low-carbon, locally sourced materials
during construction, and its scheme includes plans for both improved public
transport links and an ultra-low emissions zone for airport vehicles by 2025.
The airport has a target of at least 50 per cent of passenger journeys to the
airport being made on public transport by 2030.
More widely, October saw an unprecedented UN
global agreement to combat aviation emissions. Under the deal, airlines will offset their
emissions with reductions from other sectors to deliver carbon neutral growth
for the aviation sector from 2020.
I certainly agree that we need to be developing
transport infrastructure outside of the South East but I believe reducing our
reliance on flights is increasingly difficult in the modern world. Sadly, I
feel that we would jeopardise the opportunities and life-chances of younger
generations by severing Britain’s connections with the wider
world.
I hope that this response is informative and if
you have any further concerns or queries that you would like to raise with me
please do not hesitate to get in touch.
Yours sincerely
Julian Sturdy
To which I have responded:
Dear Mr Sturdy,
Thank you for your letter on global warming and Heathrow expansion of 14 November. Unfortunately I must disagree with you as you have some of your facts wrong.
It is quite clear that the government does not take air quality seriously; to the extent that it has now had two judgements against it on air quality. The first ordering it improve the plan as it did not meet minimum legal requirements, the second that the revised plan still did not meet the minimum requirements. To quote from the recent judgement which can be found at http://www.documents.clientearth.org/download/11525/ and was published on 2 November (almost two weeks before your letter).
3….the Supreme Court made a declaration that the UK was in breach of Article 13 of the Air Quality Directive (2008/50/EC). In his judgment of April 2015 granting that declaration, Lord Carnwath, with whom the other members of the Court agreed, said (at paragraph 31), "The new government, whatever its political complexion, should be left in no doubt as to the need for immediate action to address this issue." [emphasis in the original)
16. The United Kingdom is divided, for the purposes of the 2008 Directive and AQPs, into 43 zones and agglomerations. It is common ground that in 2010 40 of those zones and agglomerations were in breach of one or more of the limit values for nitrogen dioxide.
21. The Supreme Court decision established, as had been accepted by the Secretary of State, that the Government had failed to meet the obligations set out in Article 13 in relation to non-compliant zones. The Government accepted that it was obliged to devise a new AQP in accordance with Article 23 and that that plan should be published by December 2015. The Government did indeed publish its plan, which was entitled "Improving Air Quality in the UK-Tackling Nitrogen Dioxide in our Towns and Cities", on 17 December 2015.
86. It seems to me plain that by the time the plan was introduced the assumptions underlying the Secretary of State's assessment of the extent of likely future non-compliance had already been shown to be markedly optimistic. In my judgement, the AQP did not identify measures which would ensure that the exceedance period would be kept as short as possible; instead it identified measures which, if very optimistic forecasts happened to be proved right and emerging data happened to be wrong, might achieve compliance. To adopt a plan based on such assumptions was to breach both the Directive and the Regulations.
89….[I]t seems to me likely that fixing on a more proximate compliance target date and adopting a less optimistic assumption for likely emissions might well mean that CAZs are required in more cities, but ultimately that will depend on the outcome of further modelling.
95 iv) that it would be appropriate to make a declaration that the 2015 AQP fails to comply with Article 23(1) of the Directive and Regulation 26(2) of the Air Quality Standards Regulations 2010, and an order quashing the plan.
In short the government has failed to meet its minimum requirements. The autumn statement has also failed to help, when it might, for instance, have introduced a scrappage scheme for the most polluting cars or changed car tax and fuel duty rates to encourage people to use cleaner cars.
Moving on to Heathrow airport. Firstly, on clean air, the declaration by the government that either Heathrow or Gatwick schemes would not cause or worsen exceedances [sic] of air quality limits in the 2015 AQP is rendered moot as the plan has been found to be unlawful. With an improved plan that meets Article 23(1) of the directive it is clear that the proposals for Heathrow would not meet the minimum requirements.
I also find it worrying that you can have confidence in a secretary of state who has twice been found to be failing to meet minimum requirements.
As to meeting our CO2 obligations, it is clear that a whole variety of government decisions have made this nigh on impossible, but here we need only consider aviation. According to a parliamentary answer in 2007 “in the UK, flights leaving UK airports are responsible for 13% of the country’s entire ‘climate impact’”, and since then aviation has been growing faster than most sectors of the economy which will only worsen the impact of aviation on climate change.
The government’s own aviation White Paper, the DfT’s ‘high scenario’ predicts that by 2030 passenger numbers will treble compared with 2003 levels and their central scenario predicts passenger numbers will double from 228 million to 455 million on 2005 levels. (Department for Transport (2009) - CO2 and Passenger Demand Forecasts, P45 http://www.dft.gov.uk/pgr/aviation/atf/co2forecasts09/co2forecasts09.pdf). Government forecasts say that as a result, CO 2 emissions will increase from 37.5 MtCO2 to around 59 MtCO2 by 2030. The government’s own forecasts show that even conservative aviation growth estimates mean this one industry alone would absorb nearly 50% of the UK’s carbon budget by 2050.
In other words, the entire rest of the economy is expected to subsidise the airline industry by billions of pounds through much harsher reductions in their own CO2 use.
Until, and unless, the government can clearly demonstrate that we can, and will, meet our CO2 obligations it should do nothing that would lead to an increase in climate changing emissions, and on the precautionary principle should not allow any airport expansion. I have read the UN global agreement to combat aviation emissions (http://www.icao.int/environmental-protection/Documents/Resolution_A39_2.pdf) and there is nothing there that requires the industry to do anything. There are a large number of get outs and some aspirations (such as increasing efficiency by 2% per year), but nothing that requires reductions to be delivered.
Finally, in your penultimate paragraph you state “I believe reducing our reliance on flights is increasingly difficult in the modern world. Sadly, I feel that we would jeopardise the opportunities and life-chances of younger generations by severing Britain’s connections with the wider world.” I hope you appreciate that the effects if global warming would do far more to jeopardise the life-chances of younger generations than not flying as often as people currently do.
You do not address my points about renewable energy generation and fracking at all. I must therefore again request that you:
- Press the Prime minister and transport minister to cancel airport expansion as this is not compatible with even meeting our current emission targets.
- Press the Prime minister, Secretary of State for Business, Energy and Industrial Strategy transport minister and Chancellor of the exchequer to cancel HS2 as unnecessary and polluting.
- Press the Secretary of State for Business, Energy and Industrial Strategy, Secretary of State for Environment, Food and Rural Affairs and the Secretary of State for Communities and Local Government to change planning regulations to make it easier to install wind turbines
- Press the Secretary of State for Business, Energy and Industrial Strategy, Secretary of State for Environment, Food and Rural Affairs and the Secretary of State for Communities and Local Government to ban fracking as incompatible with meeting our global warming targets and a danger to health and industrialisation of the countryside.
Yours sincerely
Tom.
Tom Franklin
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