Reasons to Object

1. Anyone can continue to express their objections to Eastleigh’s ELAC – you don’t need to be an expert and you don’t need to live in Eastleigh or Southampton. It’s much more effective to use your own words, and just writing a sentence or two is great. If you want some guidance there is a summary of our four main arguments against expansion below.

2. Southampton City Council will be deciding whether to renew their opposition to airport expansion and are asking for comments . It is vital that they continue to oppose the extension. Please ALSO email saying something like ‘I continue to object’ with the subject line ‘Airport expansion ref 20/00843/CONSUL.’ However you can say as much as you like! Good idea to explain why the development would affect your regular experience of Southampton.

There are four key parts to our objection to the expansion of Southampton Airport:

  1. The economic case does not stack up
  2. The noise impacts of expansion make this the worst UK airport to expand
  3. More air pollution will affect local health and mortality rates
  4. Expansion will contribute to climate change and a ‘carbon-neutral’ airport is a myth

An extended runway is not needed for the airport’s economic survival

The airport is claiming that expansion is essential for its survival following the collapse of FlyBe. This seems rather tenuous given that Eastern Airways and other airlines have rapidly taken over the most important routes…even in the face of Covid-19! This includes a number of new routes announced since the Environmental Impact Assessment was submitted; e.g. Dublin as well as various holiday destinations. Indeed, the airport itself suggests in its Sensitivity Test (2.6) that the disruption of the collapse of FlyBe and even the Covid-19 crisis are temporary issues. It could even be argued that compared with the airport’s previous vulnerability to loss of its one major customer, it will be in a stronger position with several different airlines already taking over these routes. Moreover, while the airport claims passenger levels may drop to 1 million a year, there is nothing in the Impact Assessment to suggest that even a drop to this level (which was based on analyses carried out before the new routes were added) would threaten the overall viability of the airport.

No economic benefit to the region from expansion

Given the airport’s stated ‘hard cap’ on road traffic, which they anticipate will restrict passenger numbers at 3 million, the extension will only allow a fairly small increase in passenger numbers by 2037 over the no-expansion baseline of 2.26 million (which was 3.37 million as recently as 2017) (Section 6 of the revised socio-economic section), further weakening the economic case against expansion, especially given the enormous health consequences that extension would allow. In fact the revised socio-economic assessment states that the these two scenarios are so similar that there will be ‘neutral’ economic benefit and zero increased jobs. Furthermore, no account at all is taken of financial harms such as increased health costs (in a population already suffering increased mental health issues) and reduction in house prices under the flight path. When these are included the net economic impact would be negative!

National statistics show that each tourist spends £691 abroad per person on each European holiday. According to the airport’s own figures the majority of Southampton’s passengers live in the Solent area, and 78% of flights begin as outbound flights. Business travel accounts for around 30%. If just half of the rest are for holidays, then (assuming 3 million passengers per year} this means 0.819 million people spending £691 abroad, depriving the UK (if not the region) of nearly £600 million a year. Admittedly this would be offset by UK-based spending from the smaller number of inbound tourists, but this figure is significantly greater than the benefit the airport claims would be brought to the UK under any of its various scenarios and is not included in their economic analysis.

Unrealistic assumptions

Only with the completely unrealistic scenario of 5 million passengers (which the ES admits would place an impossible strain on the road network) do the airport claim an economic benefit. To obtain this result the airport assumes an unrealistic linear increase in jobs with increasing passenger numbers – not taking economies of scale into account. The economic assessment also over-estimates the number of jobs which will be local, but using the same “leakage factor” (jobs held by people who live outside the Solent Local Enterprise Partnership region) for “indirect” and “induced” jobs. Indirect jobs are those resulting from non-wage spend by the airport and its onsite businesses. Since only 32% of the airport’s non-wage spend is in our region and very little airline spending is likely to be mainly local, the number of local indirect jobs will be far fewer than estimated, and so therefore will the resulting induced jobs.


Large numbers of local people in deprived areas will be affected

The airport’s revised figures show that an additional 42000 local people (up from 20000 to 62000) will be exposed to significant levels of noise from aircraft. The airport’s own assessment shows that the areas affected by noise contain highly deprived areas, with a high concentration of non-white people, and higher levels of mental health issues, long term unemployment, and alcohol-related hospital admission, and lower income levels than Eastleigh generally. This increase in noise will not only cause annoyance; it has major health and educational consequences, as the Queen Mary College report on aircraft noise outlines. The airport will offer money for insulation for the most affected areas, but this will be only 650 households (2.5% of the total). Moreover, sound insulation is not an effective option during hot summer days (which are likely to increase, due to climate change) when people are most likely to be outside and the airport will be at its most busy. Many local open spaces will be affected by noise, and nearly half of those currently exposed at in 63-66dB will move into 66-72dB, further reducing the enjoyment of these spaces by locals. There is no possible mitigation for this.

Schools in the area will suffer

Importantly, reading comprehension drops below average levels at noise levels above 55 dB, and mathematical ability is also adversely affected above this threshold. Bitterne Park Secondary school, as well as Townhill Park primary schools are already at roughly 57 dB; the expansion would lead to levels raising to nearly 63 dB (50% increase in loudness, as dB are on the logarithmic scale). Indeed, a 5 dB increase in aircraft noise corresponds to a 2 month delay in reading age. Given that 11 primary schools, 2 secondary schools and one college would experience increases in noise due to the proposed expansion (to levels of at least 51 dB) by 2037 (Figure 15.3 – Population and Health Impacts), this alone is a major social impact. Moreover, an increase in noise of 10 dB leads to a 7-17% increase in likelihood of serious health conditions like hypertension. Only one of these schools will be offered noise insulation, and even this will not be effective during hot summer days when exams are taking place, and windows need to be opened.

With its flight path directly over residential areas, the airport is in the wrong place to expand

The flight path over densely populated areas means Southampton is the worst airport in the country to expand (worse than Heathrow!) in terms of the noise impacts per passenger flying out of the airport. This is based on information in the Impact Assessment and then simply working out the number of people affected per passenger flying out of the airport. For the projections for both 2021 (3 million passengers) or for 2037 (5 million passengers), Southampton has 2-4 times as much of a noise impact per passenger than Heathrow, which is the second noisiest (per capita) airport in the country. It is worth pointing out that in absolute terms (number of people affected) the runway expansion would lead to Southampton being 2nd or 3rd in the country (after Heathrow and Manchester; it depends on which noise contour is considered). Given all the spare capacity in the region (Gatwick, Bournemouth) there is absolutely no justification whatsoever for expanding Southampton.

Regarding the aircraft using Southampton, Appendix 11.3 (submitted by the airport) clearly shows that it will not just be the same planes flying (see the table on page 2) but rather a massive increase in the use of the Airbus 320, which is much noisier than existing planes. It is this increase in the use of the A320 that is driving the massive increase in noise the runway expansion would entail.

It is extremely unlikely that many of the people who will be adversely affected will benefit significantly from the development, with the Impact Statement admitting (1.17.2 table p1.51) “it is likely that the majority of users of the airport will not be residents of Eastleigh”. Even if all the promised new jobs were taken up by people from this area it would benefit only 0.7% of those affected.

The proposed cap on aircraft noise is meaningless

The proposed “noise cap” is unlikely to make any difference in practice to communities under the flight path because the airport specifies that it would only apply “unless and until the airspace at the airport is updated”. Prior to the coronavirus pandemic the government was consulting on changes to the UK’s airspace. These changes have been put on hold for the moment but as soon as the virus is tamed the process will no doubt continue. Therefore it is extremely likely that by the time any runway extension is completed and more of the larger, noisier jets begin using the airport, the airspace will have changed and there will be no noise cap after all!


The revised chapter on population and health (Chapter 15) provides more details on the air pollution impacts of the proposed extension. Here, critically, it is acknowledged that the ‘human receptors’ (presumably those living within the 0.2 or 0.4 areas of Fig 7.6; Appendix 7 Air quality; no numbers are given) will experience a 5% increase in mortality due to increased NO2 emissions (15.6.14), due to the 272% increase in NOx emissions resulting from the expansion (7.5.16!). This is flagged as a moderately adverse effect! This is a new analysis done to address issues raised by Eastleigh Council, and still does not fully address how many people are likely to suffer premature death as a result of the proposed expansion.

Completely ignored by the Impact Assessment is the impact of Ultra Fine Particles (UFPs) emitted from airports. These UFPs are even worse for humans than PM2.5 and PM10 as they can gain more direct access to the body, especially lungs and brain. A paper published this year identified UFP emissions from Heathrow picked up as far away as 11 miles at Marylebone Road in Central London. If expansion goes ahead we will see UFP and NO2 polluting thousands of residents across the area. Several studies have found that aviation is a source of such particles and that the impact of major airports on air quality has been underestimated.


The development will lead to a massive increase in carbon emissions, at a time when we need urgent action to reduce these to avoid catastrophic climate change. The airport estimates that there will be an average annual increase of 370,000t carbon emissions [up 20,000 since the first application – probably because more flights by A320 jets in the revised application]. For comparison, the total emissions of the entire Borough of Eastleigh are 608,700t. Moreover, since the average emissions of 370,000t is obtained over the 120 “lifetime of the project” and assumes significant emissions reduction in the later years of this timescale, the initial carbon emissions are significantly higher – namely 526,000 tonnes of CO2 each year from 2021. This would be equivalent to an 87% increase in CO2 emissions currently attributable to Eastleigh.

A “carbon neutral” airport is nonsense

The only mitigation the airport offers is to make itself “carbon neutral”; this makes a trivial difference, not least because this is being achieved by “offsetting” rather than genuine reduction in emissions at source. The offsetting only applies to ground-based emissions and staff travel, not passenger travel, which is by far the biggest portion. The airport’s statement ‘all of our CO2 emissions identified in our carbon footprint are offset’ – is simply untrue, and for want of a better metaphor, a ‘Carbon Neutral Airport’ is like ‘fat-free lard’. It’s just not possible.

Most carbon offset projects are highly, highly dubious. The project the airport highlight in their the Salkhit Wind Farm in Mongolia is a UN Clean Development Mechanism project. 85% of such projects were found by an EU investigation to not be ‘additional’ and not actually reduce net emissions (in other words, projects would have happened anyway, without the offset cash from airlines/airports/anyone else wishing to offset their emissions).

Reducing the need for people to drive to more distant airports doesn’t offset air emissions

The airport claims expansion will reduce emissions because people will not need to drive to more distant airports. Material presented at their 2019 drop-in sessions comparing a journey to Bordeaux from Southampton with one from Gatwick shows an overall saving of 21.94 kg per passenger. However in both cases the carbon emissions from the road journey are significantly lower than those from the flight itself, and because the example has chosen a destination that is nearer Southampton than Gatwick, 30% of the carbon saving is due to the shorter flight. The road carbon emissions saving is only 15.04 kg per passenger. This is less than 8% of the average emissions per passenger per flight identified in the environmental assessment and shows that there is no way this can offset the aviation emissions. Even if 1 million passengers were to switch to Southampton from elsewhere the total carbon saving would be 15.04 million kg or 15,040 tonnes. This is just 4% of the 370,000 tonnes arising from the extra flights. Furthermore, not every journey will take place at all if there is no flight from Southampton. The airport’s own calculations suggest that only 58% of the local catchment for the airport would travel to London if a flight was not available in Southampton. The other 42% might not bother. So increasing capacity at Southampton would overall likely massively increase the number of people flying (by about 161,000 passengers in the airport’s own example). Indeed, increasing flights (and therefore increasing emissions) is the very point of expansion.

No mitigation possible for aircraft emissions

Previously reduction in aircraft emissions had been claimed possible as part of CORSIA, (Carbon Offset and Reduction Scheme for International Aviation) which is the United Nations’ scheme intended to regulate aviation emissions. Since in the post-Covid situation CORSIA has been weakened and delayed, there is no effective mitigation of the additional carbon emissions at the international level. So responsibility to reduce aviation emissions therefore comes down to local action by local authorities like Eastleigh Borough Council.

The airport has claimed that electric planes could be part of its future. But electric planes have not been shown to be commercially viable at scale and are unlikely ever to be large enough to require the extended runway. Alternative fuels such as hydrogen are decades away to the long development and testing timescales required.

The revised Impact Assessment challenges the comparison of the increased aviation emissions with the size of Eastleigh Borough Council’s non-airport related emissions on the grounds that aviation is excluded from the government’s carbon targets. But simply ignoring aviation emissions doesn’t make them go away! Eastleigh claims it wishes to be a leader in tackling climate change. It cannot do this while permitting a development on its doorstep that would increase emissions by 50% just the time we need to reduce them.

When you enter Eastleigh, the road signs say the town is ‘tackling climate change’. Now is time to see if that is true.

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