Consultation Environmental Introduction

We found this section of the consultation here very confusing. It lists fourteen different environmental topics, some of which have their own questions, and some of which don’t.

This section asks “…what you think about our proposals to manage the environmental effects of expansion” – this is such a vast topic it is rather unclear what exactly we are being asked about.

We would most like to draw your attention to the section on Carbon. Many people will think carbon emissions to be the most compelling reason for objecting to airport expansion. Yet this section invites no comment – neither in the text, nor by containing a consultation question.

The UK has recently announced that it will reduce its carbon emissions to net zero by 2050. As a result of this, the Department of Transport has written to the charity Plan B that the department will carefully consider a request for a review of the airports national policy statement, which includes Heathrow.

In order to justify its expansion, Heathrow intends to offset its international aviation emissions through a scheme called CORSIA.

There is widespread doubt about the effectiveness of carbon off-setting in general, and CORSIA in particular. When an aircraft emits carbon, someone else somewhere else has to not emit carbon when they otherwise might have done, or has to be paid to re-absorb it on your behalf. Typical schemes involve planting of trees, replacing cooking appliances and so on. But such schemes are flawed – trees take a long time to grow, and may anyway later be cut down and burnt, releasing the carbon they have previously absorbed. The cooking appliance may have been replaced anyway.

The most significant criticism of carbon off-setting is that we should be doing all of this anyway, even without further carbon emissions. There is an excellent and easy to read article on carbon off-setting here.

One last point about carbon emissions. The government Committee on Climate Change has recognised the flaws in carbon offsets, and has stated that offsets should not be used as a means to meet climate targets.


We therefore recommend that you respond to this section in your own words by pointing out

  • that it is not clear what the question in this section is consulting on
  • that you consider the single biggest objection to expansion is our climate emergency, yet the section on Carbon fails to invite a response
  • that carbon off-setting in general, and the CORSIA scheme in particular, is flawed
  • that you support a review of Heathrow’s expansion by the Department of Transport

Click here to comment on the Environmental Introduction in Heathrow’s consultation.