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Actions for Heathrow's Airport Expansion - September 2019

Each topic covered in the full response document contains an action for Heathrow to undertake. The list of actions below is the compilation of all those set out in the full response and should be read in conjunction with it.

Economic Opportunities
1.In accordance with the ANPS, Spelthorne would expect Heathrow to give greater promotion to the opportunities offered within the Heathrow Academy to residents in the Borough seeking employment. Heathrow are expected to make a commitment to engage with Brooklands College and provide 1,500 apprenticeships. They are also expected to provide adequate information on the Community Fund proposals; to provide an opportunity for Spelthorne to formally comment on revised assessments.
2.Ensure that there is sufficient warehouse space available for the increase in the capacity to export.
Economic Costs
3.Heathrow needs to re-run its statutory consultation exercise once the masterplan has been significantly amended, and there is a credible business plan in place. Heathrow's estimated £32.5 billion expansion plans are neither cost-effective nor sustainable and need significant revision. This statutory consultation is premature.
4.In order to achieve a more cost- effective solution, Heathrow should be required to actively work with different parties delivering more cost-effective and sustainable components.
5.Heathrow must ensure that the expansion is genuinely at no cost to the British taxpayer. It has failed to do so in the consultation materials, and Spelthorne would expect Heathrow to re-consult once it has revised its inappropriate proposals.
Strategic
6.As soon as is appropriate in the process, Heathrow to provide Spelthorne with detailed information regarding how the local authority fits in with the mitigations in place which have resulted in 'no significant effect' on the human and non-human receptors identified in the event of a major accident and disaster (MA&D). Additionally, where the mitigation is dependent on other parties fulfilling a duty, provide further details on the expected response from Spelthorne should the mitigations fail.
7.Spelthorne asks that Heathrow steps outside of its models and uses real information instead of an over reliance on computer models and desktop analysis. It is not clear how Heathrow's current approach complies with the requirements of diligent inquiry under the Planning Act 2008 or the requirements of the EIA Regulations.
8.Heathrow needs to ensure lessons learned from the building of Terminal 5, the HS2 project or the Olympics form part of its strategic vision for expansion and feed into the detail.
9.Spelthorne asks that Heathrow stop trying to pass over statutory duties to third parties.
Legacy
10.Heathrow to offer tangible legacy benefits as part of its Masterplan and set out funding sources with governance structures prior to DCO submission, which should be the subject of a further consultation exercise allowing Spelthorne and other statutory consultees to comment.
11.Spelthorne would expect Heathrow to provide an injection of capital to fully fund 2 new improved community facilities for Stanwell Moor and Stanwell Village as part of its compensation and mitigation proposals, and provide an on-going revenue stream to enable this facility to be run in perpetuity. It could include a 4 court sports hall, community meeting room, 2 multi-purpose studios, 3G pitches, MUGAS plus other formal and informal play facilities. This should be seen as part of a package to recompense both localities for the loss of open land.
Inadequate Compensation
12.Heathrow to propose and deliver genuine 'World Class' compensation for Spelthorne's communities. It has clearly failed to provide sufficient details to enable Spelthorne to have confidence in its proposals.
13.

There are insufficient positive proposals made by the Heathrow expansion to provide new, improved or compensatory land or facilities. Spelthorne requires the following:

  • direct replacement of facilities lost
  • compensatory provision for facilities (including open space generally) which is degraded by the scheme and
    • community compensation to make up for the general impacts of the scheme
14.Heathrow needs to properly compensate local communities for the prospective loss of around 220 Ha of green space and recreation facilities by providing suitable areas of alternative open space and facilities and, where appropriate, through the application of the Community Fund. Re-provided space must be equivalent or better than what is lost, in quantity and quality, and made available in perpetuity. Heathrow's proposals do not currently make provision for this. Spelthorne would expect to be consulted formally on the re-provision of open space within the Borough once Heathrow rectifies this.
15.Heathrow to offer residents in Stanwell and Stanwell Moor a more "appropriate community compensation package" as stipulated in the NPS para 5.239 to 5.253 to also extend the Wider Property Offer Zone (WPOZ).
16.Heathrow needs to deliver on clear, unequivocal commitments and promises given to local communities (specifically Stanwell Moor) between CON 1 and CON 2 that they would be part of the Wider Property Offer Zone (WPOZ), and should stop backtracking.
17.Heathrow should provide a new Environmental Accord with Heathrow Airport that will enhance our natural environment and offsets Borough-wide 'safeguarding' impacts.
Inadequate Engagement
18.Spelthorne requires Heathrow to engage with communities in a transparent way.
19.Spelthorne urge Heathrow to have a more open engagement strategy.
20.Spelthorne insists that Heathrow be honest about the benefits and disbenefits of the proposals and the effects of the expansion, including temporary effects from construction, on the affected communities.
21.The proposed Community Engagement Plan and other key documents relating to construction impacts need to be considered and consulted on in advance of the DCO submission.
22.Spelthorne is concerned that each of the PEIRs has been considered and assessed in isolation and therefore the wider picture or cumulative effects is not considered.
23.Spelthorne asks that Heathrow widen the scope of their consultation and include those who are newly impacted or who might be and those in hard to reach groups. Damaging the Community
24.Spelthorne asks Heathrow to finalise their Community Compensation Fund as a matter of urgency so that our communities are made fully aware of the compensation available to them and can engage in an informed way.
25.Spelthorne asks that Heathrow considers not only the direct effects of the proposed expansion but also the indirect or 'knock-on effects' adequately, as required by Regulation 12 of the EIA Regulations.
26.Spelthorne requests that Heathrow stop subjecting our most vulnerable and deprived communities, such as Stanwell Village and Moor, to the most significant and detrimental impacts of the proposed expansion.
27.Heathrow to reconsider the current and narrow scope of the community consultation PEIR, which is still not concluded. The scope is far too narrow, in terms of both the stakeholders that it identified and the geographic boundary.
28.To consider the wider impacts on local communities especially those with protected characteristics and address issues that are sensitive to the evolving LGBT+ community.
Surface Access - Transport
29.Heathrow must ensure that scientifically sound traffic and transport forecasts are used to assess the impact of the Surface Access Strategy (SAS) on the Borough's transport system so that the most appropriate remedial and mitigation actions can be taken.
30.Heathrow must ensure that scientifically sound traffic and transport forecasts (including forecast passenger numbers and the spatial distribution of their surface access trip origins and destinations) are used to assess the impact of the Surface Access Strategy on the Borough's transport system so that the most appropriate remedial and mitigation actions can be taken.
31.Spelthorne wants to ensure that Heathrow's ULEZ, and later VAC, does not cause additional traffic and/or additional parking on roads in the Borough. The ULEZ and vehicle access charge should be payable by all vehicles accessing any part of the airport campus. The ULEZ area needs to incorporate freight areas of the airport and all airport related development, not just terminal forecourts and car parks. Revenue from the charges should be ring-fenced for local transport infrastructure improvements and subsidising public transport fares as if they were a charging scheme under the Transport Act 2000.
32.Spelthorne objects to the location, quantum and massing of the Southern Parkway and has concerns with Heathrow's overall parking strategy.
33.Heathrow must ensure that detailed, fit for purpose, transport modelling is undertaken and the results published. Spelthorne requires that surface access impacts are assessed using industry best practice. With the treatment of car parking and parking charges in Heathrow's modelling suite, we do not believe this has been done.
34.Heathrow must ensure that its proposed measures increase road capacity or improve public transport provision, do not cause additional induced demand for travel in the Borough.
35.Heathrow need to ensure that additional buses are provided at the right time, in the right place, in perpetuity.
36.Heathrow must ensure that the definition of "colleague" covers all people employed in jobs supporting the airport to be included in the definition, so that airport expansion does not create additional commuting road traffic in the Borough. The definition of a "colleague" is important in measuring the colleague mode share target that Heathrow has committed to achieve.
37.Heathrow must provide effective measures to ensure that taxis and PHVs travelling to and from the expanded airport do not contribute to excessive additional traffic in the Borough, and that taxi and PHV drivers do not wait on roads in the borough to collect passengers at the airport.
38.Spelthorne would like to see cycling implemented as an effective part of Heathrow's Surface Access Strategy, with proposals that will realistically encourage cycling as a mode to access the airport.
39.Spelthorne considers it vital that detailed, fit for purpose, transport modelling is undertaken and the results published. The transport modelling is not fit for purpose unless it includes construction traffic. Spelthorne does not want construction traffic during the lengthy construction period to cause congestion, noise, and air quality problems in the Borough.
40.There must be a reconsideration of parking strategy and consolidated parkway to the south and resulting concentration of traffic in Spelthorne. Full consideration needs to be given to the location and access/egress for the relocated petrol filling station on Stanwell Moor Road and resulting impacts on Crooked Billet junction. Road alignments need to be amended to move Airport Way and the Southern Perimeter Road further away from Stanwell Moor and Stanwell Village.
41.Heathrow's freight proposals need to ensure that they do not cause additional HGV traffic in the Borough. Spelthorne also requires a freight link to be provided over or under the Southern Perimeter Road. Proposals for a Truck Park must be removed.
42.Given that DCO submission is not a consultation stage, it is vital that detailed, fit for purpose, transport modelling is undertaken by Heathrow and the results published prior to the DCO submission. There must be opportunity for public and stakeholder feedback on the "third phase" of transport modelling.
43.Heathrow needs to ensure that Heathrow southern rail access is built before the third runway is operational, in order to meet their surface access mode share targets and their "no more traffic" pledge. The Council will work positively with Heathrow to ensure that they deliver.
44.Heathrow therefore needs to positively incorporate the Southern Light Rail (SLR) system into their masterplan proposals. Spelthorne is concerned that Heathrow's proposals will substantially increase airport-related traffic in the Borough. Heathrow must ensure that its definition, and monitoring of the "no more traffic" pledge is robust and able to prevent this.
45.The proposed active travel proposals need to be fully integrated with the proposals for the 'green loop' around the airport and need to be considered in more detail and consulted on in advance of the DCO submission. There is a 5 need for a fully segregated crossing of the M25 completely separated from the complex upgraded Junction
Parking
46.Spelthorne would expect as a minimum Heathrow to fund the implementation and enforcement of controlled parking zones (CPZ) for Stanwell Moor, Stanwell Village, Ashford north of the A038 and other areas as deemed appropriate by the Council. These must be in place by the time the third runway is operational. Heathrow need to invest in alternative sustainable transport measures and implement local solutions.
47.Spelthorne expect Heathrow to maintain the existing cap on parking spaces from Terminal 5 inquiry and reconsider approach to consolidated parkways in two locations.
48.Heathrow to reconsider the approach to parking within the Masterplan and remove the Southern Parkway, or as a minimum significantly reduce the size of the Southern Parkway and the quantum of parking spaces.
Adverse Impacts on Green and Blue Infrastructure
49.Spelthorne requests that Heathrow review the ecological impact assessment on the completion of the ecological surveys, including a review of 'not significant' effects and 'scoped out' effects in terms of intra-project cumulative effects, so that impacts such as habitat loss and fragmentation are clearly assessed.
50.Spelthorne requests greater transparency in relation to the remaining ecological surveys that are to be undertaken, including information on the timing of such ecological surveys. Spelthorne would expect Heathrow to reconsult on the ecological effects once the assessments has been properly carried out.
51.Spelthorne requests that Heathrow provide further information on proposed biodiversity mitigation for Staines Moor SSSI with clear links to identified effects to ensure adequate and appropriate development of mitigation. Heathrow needs to protect Staines Moor SSSI in perpetuity, and ensure that no changes are made to the River Colne upstream which might have an adverse impact on its biodiversity.
52.Spelthorne requests that Heathrow provide further information on the proposed water environment mitigation for the Water Framework Directive (WFD) features within Spelthorne with clear link to the WFD assessment. Spelthorne expect that it and other consultees are provided an opportunity to consult on this information once provided.
53.Heathrow must ensure that future air transport emissions (including international aviation) are contextualised against the Committee on Climate Change (CCC) Further Ambitions scenario, which requires a reduction in aviation emissions to 30 MtCO2 in 2050.
54.Spelthorne requests that non-CO2 air transport emissions are considered as part of the quantification of Greenhouse Gas (GHG) emissions. Heathrow are currently understating the impacts of the proposed emissions.
55.Spelthorne requests that the claim that the growth in CO2 emissions from the DCO Project would be offset under Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) is assessed more fully including addressing the concerns of CORSIA's effectiveness.
56.Heathrow needs to properly compensate local plot holders for the loss of The Vineries Allotment Site, Spout Lane, Stanwell Moor in accordance with 6 section 131 and 132 of the Planning Act 2008. This needs to be in the form of compensation for current plot holders and reprovision of an allotment site with a commuted sum to ensure adequate maintenance.
57.Heathrow must adopt high level proposals for managing surface water run-off to avoid any increase in flood risk downstream, protect water quality and manage groundwater pumped from excavation.
Noise and Health Impacts
58.Full details of the proposed 'parameters' and process for the replacement of Control of Pollution Act 1974 section 61 consent must be submitted to all stakeholders and the public for full consultation prior to submission of the Environmental Statement (ES); along with the proposed list of the Joint Planning Committee.
59.Drop plans for early growth of Heathrow Airport through the early release of 25,000 ATMs per year once the DCO has been approved. If the proposals proceed despite opposition from this and other local authorities, Heathrow needs to produce an accurate comparison of 'with development' and 'without development' contours need to be plotted. This information must be made available before the submission of the detailed Environmental Statement (ES).
60.Full details on the assessment and impacts of any replacement Compton Route need to be provided, along with any proposed mitigation scheme, if the early release of 25,000 ATMs before expansion still progresses, despite our and others' opposition.
61.Spelthorne objects in the strongest possible terms to the "environmentally managed growth" approach. The precise environmental limits mentioned below are proposed for inclusion in the DCO application. It must be clear that where the impact relates to Spelthorne (eg, physical infrastructure, impacts), these should be discharged by Spelthorne, rather than the Independent Scrutiny Panel. This must be reflected in the DCO Requirements. In addition, any such limits must be quantifiable and reducing against the 2013 baseline, and must be within the scope of the assessments carried out by Heathrow. More details need to be worked up in the Environmentally Managed Growth proposals for an independent monitoring board to ensure they are robust enough in terms of enforcement.
62.For the protection of residents' health Heathrow must have regard to guidance provided within Building Regulations 2010, guidance document F (ventilation) in the design of insulation of affected properties.
63.Heathrow to provide reasonable justification/clarification as to why the same values have been used for aircraft air noise and aircraft ground noise within the noise assessments, or to reassess noise levels based on standard methods/assumptions.
64.Heathrow must provide further justification for the rate improvement in noise production from future generation aircraft used in the PEIR assessment, or update the assessment to account for the more realistic rate of improvement because there values may not fall as quickly as the current DCO analysis suggests. Spelthorne and its residents (and indeed other statutory consultees) should be provided a formal opportunity to comment on these assessments.
65.Heathrow to explore and justify the adoption of the selected intervention values, which must be reassessed to ensure that residents are fully protected and that anomalies are removed.
66.Heathrow be required to review the proposed night time departures and arrivals to ensure that residents receive 8 hours of respite from night flights (except for emergencies) in line with WHO guidelines. As an absolute minimum residents should receive at least 6.5 hours as required by the ANPS.
67.Heathrow need to review the runway and alternation procedures to ensure that the residences of Stanwell and Stanwell Moor are given proper predictable periods of respite from aircraft related noise.
68.A legally binding agreement is required of Heathrow to ensure that the 2013 noise baseline presented within the ANPS, and the environmental limits proposed by themselves within Appendix A for Environmental Managed Growth are continually improved upon for the protection of public health.
Air Quality Impacts
69.A full transport assessment and revised detailed air quality modelling should be consulted on prior to DCO submission with routing and mode share scenario sensitivity testing and clarity of inputs and assumptions. Heathrow needs to deliver continuous improvement and enchained mitigation to neutralise air quality impacts to below legal limits on local communities. The current consultation materials fail to comply with the requirements of Regulation 12 of the EIA Regulations as they do not provide information reasonably required to understand the impacts of the proposed expansion.
70.Air Quality Impacts 69. 70. Detailed air quality modelling is required for Staines Moor SSSI, Wraysbury Reservoir SSSI and the South West London Waterbodies SPA/Ramsar site. Resultant quantitative information will generate extensive new information on the simplistic qualitative assessment presented to-date and so further consultation is required before DCO submission
Adverse Impacts on Health and Wellbeing
71.Heathrow need to act as an exemplar and to ensure that it delivers a genuine world class integrated compensation and mitigation package. It should apply the World Health Organisation (WHO) guidelines now.
72.Prior to the submission of the Environmental Statement (ES), a separate health impact assessment for each Heathrow community (Stanwell and Stanwell Moor for Spelthorne) for both the construction and operation phases needs to be carried out and submitted to stakeholders and the local communities in full consultation.
73.Heathrow (as part of their DCO) need to provide for additional Local Authority (LA) resources to ensure robust and independent monitoring and enforcement of the construction works can take place. This will ensure the health of residents is protected.
Airspace
74.Drop plans for Independent Parallel Approaches (IPA) as part of the early growth of Heathrow Airport for release of 25,000 ATMs per year once the DCO has been approved.
Airspace
75.

Commitment from Heathrow is required to meet a minimum 60% Public Transport mode share for construction workers. Additional mechanisms are 8 needed in the Preliminary Outline Construction Worker Travel Plan (POCWTP). Monitoring (air quality, dust, noise, odour, etc.) is required within Spelthorne of constructional and operational phase impacts. I

ndependent monitoring and enforcement of implementation of CoCP and other environmental management plans is required (see further Spelthorne's comments on Heathrow's proposed environmentally managed growth approach). Firm commitments need to be made, and kept, for measures to manage construction impact.

Updated construction phase dust assessment, added assessment years between 2022 to 2030 and updates to baseline information still needed. Justification is required why construction traffic has been excluded from the no more airport related traffic pledge.

76.Routing of Construction traffic through the centre of Stanwell Moor is unacceptable. If alternative routing cannot be found, CS11 must be discontinued as an option. CS10 should be discontinued as an option. The Transport Assessment for Construction and the Construction Worker Accommodation Strategy needs to be consulted on ahead of DCO submission. Transparency needed on what specific mitigation proposals will be and how they will be managed, monitored and enforced.
77.Clarity and firm commitments are needed for communities on when 'temporary' construction sites will be restored to permanent use and the quality, quantity and nature of the end use.
78.Consultation needed before DCO submission on details in the Code of Construction Practice relating to working hours, in particular, locations and activities where 24/7 working may cause unacceptable effects.
79.Proper consideration of the need for worker accommodation on site and contingency plans for additional demand. Development and consultation required on Construction Worker Accommodation Strategy before DCO submission.
80.Protect residents from noise disturbance caused by construction by ensuring that Heathrow's Construction Management Plan complies with good practice and legislation.
Adverse Pollution Impacts
81.

Engagement is needed on the proposed scope and timing of forthcoming ground and water investigations for land in the Borough. Consultation is needed on the site investigation data, risk assessments and interpretation well in advance of the DCO submission.

Clarity is appropriate on whether Heathrow will be mitigating and compensating local communities for the loss of agreed restoration schemes at temporary mineral processing sites.

82.Land set aside for airport drainage and pollution control should be fully justified and minimised. Further assessment is needed in respect of use of Hithermoor. Further justification is required of extent of land take at Mayfield Farm. Options for biological treatment need to be reassessed in light of the existing Heathrow trial.
83.Implications of preventing processing of minerals from King George VI at Hithermoor Quarry must be appropriately assessed and not dismissed. Discussions are needed with Surrey and Spelthorne about compensatory 9 provision for loss of agreed restoration schemes at Hithermoor Quarry, Stanwell Quarry and Homers Farm. Firmer commitments are required on transportation of raw materials and wastes by rail.
Enforcement
84.

Heathrow must ensure that all construction related works are procured in a way that ensures that their contractors and sub-contractors do not breach planning, public health and environmental protection regulations. Control measures should be designed to prevent problems at source wherever possible. Through robust contract management, Heathrow must ensure that they properly monitor contractors/sub-contractors and that they take swift remedial action to ensure compliance with these requirements.

Where intervention by public authorities is required, Heathrow should agree to underwrite the costs of enforcement action which is rendered necessary by public bodies as a result of Airport related development. Spelthorne (and other local authorities) should have enforceable rights in all Heathrow construction related contracts against both Heathrow and third parties for unrecoverable enforcement costs.

85.Heathrow must ensure that there is an effective Traffic Management Plan (TMP) to control deliveries to the development sites and reduce the impact of road freight on Spelthorne's residents. This should include the implementation of engineering solutions (e.g. width restrictions) where appropriate to prevent HGVs from passing through residential areas to access construction sites; and an automatic traffic management system including strategically placed CCTV cameras with automatic number plate recognition to track HGV movements and ensure that only designated freight routes are used at times which are specified in the agreed TMP. Heathrow should fully fund the implementation of these systems and agree to underwrite the costs of all consequential monitoring and enforcement action throughout the duration of all construction activity (not just the third runway).

 

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