Response to Heathrow Airport Expansion Consultation
This is the response of Heathrow Southern Railway Ltd (HSRL) to Heathrow’s Airport Expansion Consultation, running from 18 June to 13 September 2019. We note this is a statutory consultation, which forms the prelude to an application from Heathrow Airport Ltd for development consent under the Development Consent Order (DCO) process.
HSRL is a private sector company established in 2016 for the sole purpose of promoting and building a Southern Rail Link to Heathrow Airport (SLRTH). The company was founded by individuals with extensive experience in railway development and raising private finance for publicly beneficial infrastructure. In 2017 the multinational engineering and design consultancy AECOM invested in the company.
The construction of under 8 miles of new electric railway by HSRL will enable Heathrow Airport to be connected by direct train to south west London, Surrey and Hampshire. Trains will be fast and frequent, can carry significant volumes of passengers, and will have journey times materially quicker than road. The creation of the HSRL link will trigger a modal shift from road to rail, easing motorway congestion, reducing carbon emissions and improving air quality.
Our plans for a SRLTH are well developed, fit within the capacity constraints of the national rail network and comply the Railways Regulations. We have discussed our plans with the Department for Transport (DfT), Office of Rail and Road (ORR), Civil Aviation Authority (CAA), Transport for London (TfL) and Heathrow Airport Ltd (HAL), and numerous local authorities, MPs, stakeholders and business groups.
Our proposed new rail link will be privately financed. Our business case modelling shows that the scheme’s costs can be covered by the farebox revenues brought by new to rail users. It is user funded, so does not need subsidy from Government or any capital contribution from HAL. Heathrow Southern Railway Ltd’s Reply to Heathrow Airport Expansion Consultation 13 September 2019
HAL’s own analysis in the Expected Case shows that a SRLTH scheme such as that promoted by HSRL raises the airport’s public transport mode share by 4% by 2040, brings another 1 million of the UK’s population within an hour of Heathrow by public transport, and will be used by 3.9 million passengers pa by 2040. It makes a significant localised difference: for example it raises Guildford’s public transport mode share from 9% today to 21% in future.
But the scheme will not happen by itself. It needs HAL and the DfT to move from their generic statements of support to a binding commitment that a SRLTH scheme will be used, and will proceed as a core part of HAL’s future plans. HAL can play a key role in maximising the likelihood of a SRLTH going ahead in the near term – we expand upon this in our response.
We also cite, as key, the report of the House of Commons Transport Committee on the Airports National Policy Statement (ANPS) published on 23 March 2018 which stated in paragraph 43: “Schemes such as Southern and Western Rail Access are essential for a two-runway Heathrow, never mind a three-runway airport with an extra 50% capacity.” This supports our view that a SRLTH is needed whether or not HAL’s plans to expand are ultimately successful.
In this consultation reply we focus our response by answering eight questions of most relevance to our interests. Our replies are informed by our studying of the consultation documentation provided by HAL on its website, with particular focus on the documents named Preliminary Transport Information Reports (PTIRs) and the Surface Access Proposals (SAP) documents, and answers by HAL on 6 September to some of the clarification questions we asked on 19 August.
Our reply explains our view that, if HAL proceeds to the DCO stage arguing that the ANPS June 2018 requirements on modal shift to public transport can be achieved without reliance on a well considered SRLTH scheme, the DCO is at risk of failing. This is because the current Assessment Case contains unrealistic assumptions about the ability of existing rail routes and road to accommodate significantly more passengers and staff, and is heavily reliant upon the hostile measure of a Vehicle Access Charge (VAC) which we think will be unacceptable to users.
We are happy to discuss our response, but ask that it is considered without prejudice to future statements we may make during a DCO examination in public.
Graham Cross – Chief ExecutiveDownload full PDF here