Photo: Little Owl by Paula Redmond
12th September 2019
Via email: feedback@heathrowconsultation.com
Dear Sirs,
Richmond Park and Heathrow Expansion
I am writing on behalf of the Friends of Richmond Park[1] regarding the improper treatment of Richmond Park in the current Heathrow Airport Expansion Consultation’s Preliminary Environmental Information Report (PEIR).
Richmond Park is world famous, and of national and international importance for wildlife conservation. It is the quietest (extraordinarily quiet at <30dB(A)[2]) and at night the darkest place in London. The Heathrow expansion project includes numerous flight paths over Richmond Park with noise levels of around 80dB(A) including with landing lights on in darkness. These changes, brought about by the Heathrow Expansion Project, will have profound significant effects on the Park’s wildlife, its users, and even its sustainability. Yet Richmond Park, the most heavily protected urban park in the UK, is almost completely absent from the PEIR. The only conclusion we can reach is that the PEIR is flawed.
This error is beyond matters of detail. It has four common root causes:
- fundamental flaws in Heathrow’s PEIR scoping request, not subsequently picked up by Natural England in their response to the PINS consultation, and not noted by the Planning Inspectorate in their scoping opinion;
- the objective function of residents affected is inappropriate for large open spaces;
- the preferred noise metric in entirely driven by perceived human impact, not by environmental damage; and
- the earlier airspace principles consultation[3], notably principle 6h prioritising routing flight paths over parks, was endorsed despite the 1,000 consultees not including a single body responsible for managing or protecting large open spaces like Richmond Park.
We are concerned that, if these clear flaws are not corrected and Richmond Park treated properly, the Examining Authority’s assessment will be based on a fundamentally flawed PEIR stage, and so its recommendation to the SoS DfT on the Heathrow expansion project will be open to legal challenge.
Further details are provided in our full submission attached and the detailed Appendix to the submission.
The onus is on Heathrow to do the necessary work to provide sufficiently robust assessments to satisfy the Independent Examiner. This must cater for the decades ahead that these changes will inevitably impact, and it follows that a precautionary approach is required.
I am copying this response to Paul Maynard MP, Parliamentary Under Secretary of State DfT, The Planning Inspectorate, Natural England, The Royal Parks, the CAA, Zac Goldsmith MP, Vince Cable MP, Justine Greening MP, Ed Davey MP, Baroness Kramer, The Royal Ballet Junior School, the Holly Lodge Centre in Richmond Park, Historic England, the London Parks & Gardens Trust, the Mayor of London, the London Assembly Member for the area (Tony Arbour, who is also Chair of the Assembly) and Richmond Council (which is the planning authority for Richmond Park).
Yours sincerely,
Ron Crompton
Chairman
The Friends of Richmond Park
chairman@frp.org.uk
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