Responding to the latest consultation
The Third Runway at Heathrow will mean new flight paths directly over Bedford Park and north Chiswick, bringing noise and emissions’ pollution to our area. Below is some guidance on responding to the latest consultation which has been launched – The Airports National Policy Statement (ANPS) — the Government’s title for its plan to expand Heathrow. The consultation will run until 1 September and everyone is encouraged to submit their views.
This consultation is even more complicated and contradictory than the previous consultations and extremely time consuming to complete. Rather than trying to work through the online survey, the simplest way to respond is to send an email with your comments to: henpsconsultation@dft.gov.uk.
You might like to consider basing your submission on the response that has been drawn up by No 3rd Runway Coalition. It covers all the main issues in a clear and succinct way.
You can find a pdf version of the suggested response below which you should be able to cut and paste from. If you would prefer an email or Word version, please contact us at: information@bedfordpark.org.uk
Response Guide.
FYI the online version of the survey is here.
You can read the full Draft Heathrow Expansion National Policy Statement here: Heathrow expansion consultation.
Background
The Government support of rapid airport expansion in the UK brings the threat of a Third Runway at Heathrow back onto the agenda. An additional runway would cause major disturbance to all Chiswick residents with more flights, more noise and more pollution, at a time when proposals to ease nighttime flight restrictions and increase the number of daytime flights already posing serious threats for local residents.
Of immediate concern is the impact of new flight paths with additional low-flying aircraft, and planes turning over west London on their approach/departure.
We continue to monitor developments closely and will be ready for each stage of consultation. The Society will respond to them and provide guidance for members and local residents to submit their views, as in the past. We are once again working with the No 3rd Runway Coalition and CHATR (Chiswick Against the Third Runway).
How you can help
First, we urge everyone to submit a response to each consultation in order to maximise the impact on decision-making.
The Infrastructure & Environment Committee of the Society has access to some members who have an aviation background, but we would welcome additional volunteers to make our campaigning more effective. In particular we need help working with the Coalition group and other opponents, presenting clear arguments and rallying Chiswick residents to make their opposition clear.
You don’t need aviation experience to be involved. Please let us know on: information@bedfordpark.org.uk if you would like to help.
Major disturbance of Third Runway and increased flights
Heathrow’s proposals will cause major disturbance to all Chiswick residents with more flights, more noise and more pollution, possibly even if the Third Runway does not go ahead.
- Heathrow are proposing options that would result in 29 flights directly over Bedford Park and Chiswick between 06.00 and 07.00am – one plane every 2.4 minutes – at very high decibel levels, likely to wake people up. Up to 40 overhead flights per day are proposed at this stage, before implementation of the new runway.
- If the Third Runway is built, we would be even more significantly affected with incoming low-flying aircraft (at 2,000 – 3,000ft), 47 flights per hour (one every 1.5 minutes) and with all of the flights above the key 65-decibel level. There will be 17 departing flights per hour (one every 3.5 minutes), all above 65 decibels.
December 2025 development
In December the Government announced its support for Heathrow airport’s Third Runway proposal. The project includes building a 3,500m runway and Terminal 5 satellite areas to accommodate 66 million more passengers annually. Heathrow has said that the expansion would accommodate an additional 276,000 flights each year.
Press coverage emphasised the escalating costs, number of houses to be destroyed and re-routing of the M25, in addition to concerns about noise and pollution from increased flights.
Although ministers have backed the Heathrow runway design, the plans have to go to a public consultation in the summer of 2026. The Government’s intention is to fast-track the Airports National Policy Statement (ANPS), the planning policy document. Once the ANPS is approved, formal planning approval for the project is not expected to be granted until later this decade, although the Government has declared its aim of starting construction before the end of 2029.
If the plans go ahead, there will be a very significant impact on Bedford Park with increased aircraft noise, additional flightpaths and the possible inclusion of night flights. It will continue to be vital to respond to all future consultations.
Our work to challenge the development
We continue to closely monitor developments, supporting the work of CHATR (Chiswick Against the Third Runway), keeping in touch with the No Third Runway Coalition, and taking action when necessary. We remain committed to supporting any further efforts to challenge this development, which represents such a significant threat to Bedford Park and Chiswick.
David Blackburn, Chair of the Society’s Infrastructure & Environment Committee, attends the No 3rd Runway Coalition meetings in Parliament. The Coalition is a campaigning group of MPs, local councils, interested local organisations and charities affected by these proposals.
Many questions are still unanswered, such as safety; reconciliation with air pollution limits; binding Climate Change targets; the economics of the project, including creating access to the airport, and the adequacy of the government’s proposed compensation scheme.
We have encouraged members to respond to Heathrow Airport’s Airspace consultations, summarising the key points and providing responses that the Society and CHATR suggested should be made to make the strongest case, and also submitted formal responses from the Society.
The main focus of our work has been the continuing legal challenge to the building of the Third Runway and Heathrow’s application for planning permission (the Development Consent Order, or DCO).
Previous consultation on the night flight regime ending 22 May 2024
This consultation presented proposals for the next night flight regime, which will start in October 2025 when the current regime is due to expire. The proposals affect everyone who lives in the vicinity of Heathrow, Gatwick and Stansted Airports. Any easing of night flight restrictions at Heathrow would have a significant effect on Bedford Park and Chiswick residents.
The consultation objective was to confirm a decision on a night-time noise abatement objective for the three airports following the consultation carried out between 27 March to 9 May 2023.
The Society submitted a formal response which anyone could refer to or cut and paste selected text when submitting their own comments.
Outcome of consultation:
Following analysis of the consultation responses, the Government reached a decision in December 2024 that the following night-time noise abatement objective will be in place for the next night flight regime to commence in October 2025:
“To limit, and where possible reduce, the adverse effects of aviation noise at night on health and quality of life while supporting sustainable growth and recognising the importance to the UK of commercial passenger and freight services.”
A bridging night flight regime of 3-years was proposed that will cover October 2025 to October 2028.
Consultation ending 9 May 2023
This consultation sought views on the proposed night-time noise abatement objectives for Heathrow, Gatwick and Stansted, which will shape proposals for the next flight regime due to commence in October 2025.
We submitted a formal response from the Society and prepared a document: Suggested responses to night time flight consultation which could be used as as an aide in preparing responses re Heathrow. The note listed the questions posed in the consultation.
Full details of the consultation can be found on the gov.uk website.
Earlier rulings and consultations
Supreme Court overturns previous ruling
On 16 December 2020 the Supreme Court overruled a previous verdict that developing the Third Runway was in breach of the Paris Agreement on climate change, following an appeal by Heathrow Airport against the February decision. The five Supreme Court justices stated that the Transport Secretary had been correct in using a temperature increase limit of 2C (rather than the Paris Agreement aim of 1.5C) in determining that the expansion did not breach the requirements of agreements on climate change as that had been the applicable limit at the time the Airports National Policy Statement was finalised.
As a result, Heathrow could seek planning permission for the runway but still had to convince a public enquiry of the case for expansion and, if planning inspectors approved the scheme, the government would have the final say.
Ongoing campaigns and Friends of the Earth petition
Campaigners plan to launch legal challenges against each stage of the planning application, including at the European Court of Human Rights, arguing that relying on outdated emissions targets is inconsistent with the right to life. The No 3rd Runway Coalition said that a decision in favour of Heathrow would not change the underlying case against the proposed runway, pointing out that since the Airports Commission recommended Heathrow expansion five years ago, the “assessments on noise, air quality and carbon have been exposed as inadequate.”
You can read the No 3rd Runway Coalition’s outline of proposed next steps here and an article by the Chairman of the Coalition published in the Independent.
Friends of the Earth launched a petition demanding that the Prime Minister scraps his government’s plans for the Third Runway, saying they believe there’s a strong chance that the plans wouldn’t be compatible with climate policy if made today. You can find out more about the petition online.
February 2020 High Court ruling
The High Court ruling on 27 February 2020 stated that the government’s policy on expanding the airport was unlawful as it failed to take proper account of the impact on Britain’s climate commitments.
The judgement was delivered after a legal challenge brought by local councils, environment groups and the mayor of London. It ruled that legislation granting Heathrow the green light had ignored climate change commitments under the UN’s Paris Agreement, which limits global temperature rises and commits signatories to tackling climate change by taking measures to limit global warming to well below 2C.
In failing to take full account of the environmental impact, the current policy on a third runway at Heathrow was described as “legally fateful” to the Airports National Policy Statement (this effectively gave Heathrow outline planning consent) and should be withdrawn.
The judge emphasised that the court made no judgment on the merits of Heathrow expansion or whether a third runway could ultimately comply with the Paris Agreement. It was simply that it had not been considered when the statement was drawn up in 2017 and 2018, but should have been taken into account.
As well as producing suggested responses and information on how to submit responses for members, we work with CHATR to help publicise the importance of responding to all Chiswick residents. Our efforts have been appreciated by members and residents alike.