There is scant recognition for the cumulative impact the expansion plans would have upon local communities and the explicit need for suitable localised compensation. The scope of insulation works offered by Heathrow to noise-affected residents are in general terms lower than international comparators. The structure and functionality of the proposed compensation packages, building on the opaque and unfit-for-purpose existing packages and processes, need to be properly re-structured to enhance their acceptability.

Evidence
Heathrow has not made clear who it considers to have a “relevant claim” for the purposes ofsection 42/44 of the  Planning Act 2008. It has, instead, adopted the terminology of “Wider Property Offer Zone” and “Compulsory Purchase Zone” which is not to be found in legislation, guidance nor precedent.

It is clear that if the suggestions in Spelthorne’s responses (above and below) are had adequate regard to, Heathrow will need re-evaluate those persons who will need to be considered to be “Category 3” persons (i.e., those with a relevant claim). In particular, given the inadequate environmental assessments, it is not clear that Heathrow will be aware either of the volume or extent of the necessary compensation impacting not just its economic case, but its ability to live up to its commitment to provide appropriate and adequate compensation. Spelthorne considers it imperative for the “WPOZ” to be expanded and any misalignment with the Category 3 persons explained and justified.

Irrespective of mitigation measures, local people will be significantly affected by the design of the current expansion plan. The Government accepted the Airport Commission’s report recommending that a ‘world class’ compensation package for local residents was required. This compensation package should address, for example, impacts on property values, noise and accumulative expansion impacts to ensure that local residents are both properly compensated and share the economic benefit of expansion.

To be ‘world class’ requires benchmarking the compensation packages offered by Heathrow with airports outside of the UK. International airports mitigate the impacts of their operations on local residents, with the most successful tailoring their offer to the specific circumstances of the airport impact upon surrounding communities. The combination of compensation and mitigation ‘volunteered’ by Heathrow for communities in Stanwell Moor and Stanwell Village fall short of being adequate, let alone meeting the ‘world class’ claim, particularly as the reach of the airport functionality significantly impacts upon the well-being of communities in those villages.

In October 2018, the World Health Organisation published its new guidelines for environmental noise [Environmental Noise Guidelines for the European Region (2018)]. They include tough new lower thresholds set for aviation noise, reflecting the growing body of evidence about the harmful effects of noise on health. Yet these community heath impact thresholds are ignored by Heathrow.

Non-compliance with ANPS
The ANPS states:

• 5.57 While the package and detail of noise mitigation measures should be subject to consultation with local     communities and other stakeholders to ensure
  the most appropriate and effective measures are taken forward, in the context of
  Government policy on sustainable development, the Government expects the
  applicant to make particular efforts to avoid significant adverse noise impacts and
  mitigate other adverse noise impacts as a result of the Northwest Runway
  scheme and Heathrow Airport as a whole.

Heathrow has plainly failed to comply:

The scope of insulation works offered by Heathrow Airport to noise-affected residents are in general terms lower than international comparators. The current proposals from Heathrow indicate that the full costs of works would be funded for only the worst affected properties, notably those properties within the 60dB Leq contour. However, to be a genuine ‘world leading’ offer, the lower contour of 55Ldn within which properties would qualify is consistent with other international comparable airports.

Spelthorne’s concerns highlight the need to structure the package to address local concerns through meaningful public engagement rather than simply impose a programme that has already been shown to have significant shortcomings.

Division
Inadequate Compensation

Need to Expand Wider Property Offer Zone to Cover Communities

Action
Heathrow to offer residents in Stanwell and Stanwell Moor a more “appropriate community compensation package” as stipulated in the ANPS para 5.239 to 5.253 to also extend the Wider Property Offer Zone (WPOZ).

Theme/Topic/Title
WPOZ should be expanded to cover the whole of Stanwell Moor and large parts of Stanwell.

Topical Issue
Spelthorne is particularly concerned that, under the current proposals, no Spelthorne residents will benefit from the package of measures known as the “Wider Property Offer Zone”. These measures include residents being able to sell their homes at the market value of the property “as if expansion had never been promised or taken place” plus a 25 percent uplift.

Evidence
Excluding south of the airport from the WPOZ suggests that Heathrow has come to the conclusion that Spelthorne communities will not be newly impacted by expansion. That assumption is simply wrong.

Communities will be newly impacted by:

• airport development brought far closer to homes, families and schools
• construction, bringing enormous disruption to the local area
• more flights, both before and after expansion, with associated noise and air quality challenges
• more traffic coming on to local roads due to planned reconfiguration of routes
• more airline passengers parking in local roads to avid airport parking costs
• more taxi and private hire vehicles waiting in residential roads with associated littering and annoyance to local residents
• loss of valued open space, both existing and what would have been delivered
  through restored mineral sites
• ecological impact on Staines Moor
• loss of community spirit effect on property prices and being able to sell their homes

As mentioned above, Heathrow appears to have adopted terminology that has not been found in the Planning Act  2008, guidance nor precedent. Heathrow should explain the discrepancy between its Category 3 catchment zone and the Wider Property Offer Zone. Spelthorne’s view would be that the Category 3 boundary would clearly be wider than the WPOZ, and on that basis, the WPOZ should be expanded.

Non-compliance with ANPS
The ANPS states:

• 5.240 The Secretary of State expects the applicant to provide an appropriate community compensation package,  relevant to planning. This will include financial compensation to residents who will see their homes compulsorily acquired, as well as ongoing financial compensation to the local community. In addition to controlling and reducing aircraft noise impacts, the applicant will be required to commit appropriate resources to mitigate the impacts of aircraft through noise insulation programmes for both private homes and public buildings such as schools.
• 5.244 People are entitled to know what steps will be taken to help protect them against aircraft noise and, where appropriate, to help them to move house.

As per Spelthorne’s response to the non-statutory consultation (Jan 2018) (which appears to have had no regard to), both Stanwell Moor and Stanwell will be newly impacted by the expansion of Heathrow and therefore the WPOZ must, as a result, include both those communities. In respect of compensation for off-site owners, the statutory compensation for nuisance (and other actionable harm) caused by construction works (CPA 1965 s10) and
devaluation due to the use of public works also includes aerodrome and any highway effects.

Division
Inadequate Compensation

Need to Deliver on Promises given to Local Communities

Action
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.

In line with Frankfurt, Heathrow must put in place an extensive proactive public engagement programme to ensure that locally affected communities actively shape the structure of the compensation and mitigation package.

Heathrow must also put forward a compensation scheme which more accurately reflects the impacts on communities by adopting a similar approach to HS2.

Title
Stop backtracking and deliver appropriate compensation

Topical Issue
Communities will be newly impacted by an expanded airport and the ‘associated infrastructure’ required to deliver the new northwest runway (See WPOZ sheet for more detail). Communities will be affected and Heathrow has seemingly reneged on assurances to local residents that they would be part of the WPOZ.

Evidence
Heathrow has (at public and other meetings) advised the local community in Stanwell Moor in particular that they would be included within the WPOZ. . Spelthorne is severely disappointed that this commitment is not reflected in the consultation materials.

(See WPOZ sheet for more detail on how the communities are newly impacted)

Non-compliance with ANPS
The ANPS states “The Secretary of State recognises that, in addition to providing economic growth and employment opportunities, airport expansion will also have negative impacts upon local communities… The Secretary of State expects the applicant to provide an appropriate community compensation package”.

This is WHY I fight to get us what we deserve and I will continue to fight until we get justice and what we rightly deserve. WPOZ that has been denied to my friends, my neighbours and every single resident of Stanwell Moor.

Best regards,
Jim.

Jim McIlroy,
Founder  WPOZ
for Stanwell Moor Campaign