The Long Read: Marking Heathrow's homework


The draft Airports National Policy Statement, published by transport secretary Chris Grayling, sets out why ministers believe a new runway at Heathrow is both needed and the best option and, crucially, how an application for expansion from the airport’s owners will be assessed.

Key issues for the wider transport sector are how surface access to an expanded airport will also be expanded and the related question of how – not to mention whether – environmental impacts will be mitigated, which also hinges on improving surface access.

An early look at the document gives anyone asking exactly what it means and how it will be applied, as well as the pedants amongst us, plenty of scope to point out a few holes and vagaries – not to mention the ability of a Government that has stressed the importance of an expanded Heathrow to a post-Brexit Britain to mark its own homework.

In the draft Statement, references to the applicant should be read as applying to Heathrow Airport Ltd, while the secretary of state who will decide whether the Government’s tests have been met is the transport secretary, even though it is fundamentally a planning decision under the Planning Act 2008.

Surface access to an expanded Heathrow is a key issue

Surface access is a slightly misleading term in that it includes people travelling underground to an airport, but it essentially covers access other than by flying. How do people get to and from an airport to take or following flights, to work there or to drop off or meet friends and family?

The draft Statement’s section on surface access begins blandly enough by setting out the Government’s objective as ‘to ensure that access to the airport by road, rail and public transport is high quality, efficient and reliable for both passengers and airport workers who use transport on a daily basis’.

Who would disagree? But it can already be seen that ministers are seeking ‘to ensure’ something for which definitions are vague.

The document then lapses into tautology: ‘The Government also wishes to see the number of journeys made to airports by sustainable modes of transport maximised as much as possible. This should be delivered in a way that minimises congestion and environmental impacts, for example on air quality.’

Here ministers are not setting benchmarks that imply positive outcomes but signalling that achieving all that can be achieved will suffice. More of this later.

As the document then acknowledges: ‘Without effective mitigation, expansion is likely to increase congestion on existing routes and have environmental impacts such as increased noise and emissions.’

So, what will the mitigation measures be and what will they actually achieve?

The paper makes clear that it is for Heathrow to ‘set out the mitigation measures that it considers are required to minimise and mitigate the effect of expansion on existing surface access arrangements’.

This will include showing how it ‘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.’

So it’s a question of drawing up a plan to meet targets. What about accountability for delivery against them? Well: ‘The applicant should commit to annual public reporting on performance against these specific targets.’

There doesn’t appear to be any accountability if the airport subsequently breaches its reporting obligations, let alone misses its targets.

As for the infrastructure that needs to be put in place beforehand, the document raises the possibility that ‘proposals in relation to surface access meet the thresholds to qualify as nationally significant infrastructure projects under the Planning Act 2008’.

Who will pay for works on such a scale? ‘The Government expects the applicant to secure the upgrading or enhancing of road, rail or other transport networks or services which are physically needed to be completed to enable the Northwest Runway to operate.’

So, Heathrow will pay, except for measures that are ‘not solely required to deliver airport capacity’. Is this a get out?

In addition: ‘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 all opens up at least one can of worms, and possible two, given Transport for London’s longstanding claim that the costs of new public transport links will cost nearly £20bn – far more than the Airport Commission’s estimates.

So does London mayor Sadiq Khan have a veto if he says he is not content with the deliverability of new schemes?

He has already said ministers must ‘guarantee that they will fully fund the billions of pounds needed to improve road and rail connections to Heathrow’.

Probably not, given that in deciding on expansion plans, ‘The Secretary of State will consider whether the applicant has taken all reasonable steps to mitigate these impacts’.

If not, he can ‘impose requirements on the applicant to accept requirements and / or obligations to fund infrastructure or implement other measures to mitigate the adverse impacts’.

But: ‘Provided the applicant is willing to commit to transport planning obligations to satisfactorily mitigate transport impacts identified in the transport assessment … development consent should not be withheld on surface access grounds.’

Interestingly, the document also says that when weighing the adverse impacts of expansion against its benefits, ‘the Examining Authority and the Secretary of State will take into account…any measures to avoid, reduce or compensate for any adverse impacts’. He ‘will also have regard to the manner in which such benefits are secured, and the level of confidence in their delivery’.

Mr Grayling doesn’t seem to have required himself to assess how likely it is that mitigation measures will actually work.

On the subject of marking one’s own homework, the document also asserts that work carried out within the Department for Transport ‘has helped inform the Government’s view that, with a suitable package of policy and mitigation measures, including the Government’s modified air quality plan, the Heathrow Northwest Runway scheme would be capable of being delivered without impacting the UK’s compliance with air quality limit values’.

That would be the modified air quality plan that is still being written after the Government’s last air quality plan was thrown out by the High Court last year – partly on the grounds that the Government had indulged in over optimistic modelling.

Mention of the High Court and this week’s warning that a Government court victory has only delayed the inevitable legal challenge to its Heathrow policy brings us back to the Labour Government’s attempt to expand the airport, which was ruled illegal just before the party lost power in 2010.

The then transport secretary, Geoff Hoon, had asserted that the Government’s ‘third condition’ for backing expansion – ‘the provision of adequate public transport’ – had been met.

Lord Justice Carnwath was not convinced: ‘I find it impossible to determine precisely what the secretary of state ultimately understood to be the scope of the third condition, or what if anything he has decided about it.’

Chris Grayling should be under no illusion that those campaigning today against Heathrow expansion will – eventually – ask the courts to decide whether he has set valid tests for backing it and then assessed objectively whether those tests have been satisfied.


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