APPENDIX 10
Memorandum from Saffron Walden & District
Friends of the Earth
2 INTRODUCTION
We represent members of Friends of the Earth
who live in the area in which Stansted Airport is situated. We
are a member of Stop Stansted Expansion and have participated
in the Response to the current consultation document on the Future
of Aviation. We have also submitted evidence on our own behalf
and have, over the years participated in the various issues concerning
the development of the airport. We do therefore believe we have
something to contribute to this inquiry.
2.1 The Identification of the costs of aviation.
(questions one and two).
Attempting to cost the damage that can be caused
by environmental pollution is a new kind of accounting exercise.
It needs to be done:
— In order to avoid permanent damage
to, human health, the environment and to preserve natural resources.
— Many markets have been operating
with an unrecognised subsidy from the costs of such damage. Costs
due to natural resource use and pollution have been born by the
health services, local public services, (eg floods probably from
climate change, drought from over extraction of water, building
and forest damage from acid pollutants) and from remedying local
deprivation over use of exportable materials (eg tropical forests).
— Such a subsidy is unfair both to
the public services and to the tax paying public as well as to
other competing businesses. A subsidy should be open and be granted
as a conscious decision by government for policy reasons.
2.2. Can these costs be properly quantified?
Since the "science" is in its infancy
probably only partly. There are however many aspects of damage
costing that are sufficiently well understood that can be costed
within a reasonable range of parameters. The Environmental Consultants
quoted in the Government's document "Aviation and the Environment",
namely, CE Delft have produced an analysis of the "External
Costs of Aviation" accompanied by technical annexes that
compare results with a number of other similar analyses. There
is enough similarity between these costings both in methodology
and results to suggest that an agreed costing programme is possible.
It would be far better to be carried out on a European basis through
the EU Commission if this could be undertaken within a reasonable
period of time.
2.3. Has the Government's discussion document
succeeded in identifying costs?
In our view, only partly:
— Sufficient agreed scientific evidence
has now accumulated for the quantification of some of the possible
costs of climate change. This has been carried out on (Page two).
the basis of the need to achieve Kyoto and Government targets
and while much still needs to be learnt about the effects of aviation
on the formation and effects of cirrus cloud there is enough evidence
to use in formulating costs.
— With regard to noise, house values
do appear to have a direct relationship with noise levels experienced
from aircraft. This has been used in the recent judgement on Dennis
v. the Ministry of Defence. We have reservations on the way it
is suggested in the document that these should apply. We discuss
these below in para 3.1.
— Local Air Quality. Here we disagree
with the document's analysis and discuss our reasons below, para
3.2
3.1 Noise damage
The suggestion is that only properties within
the contours of LAeq 57 dB (A) should be included in the costings.
We have, in our response to the Future of Aviation put forward
arguments that:
— It is time that the "annoyance"
level should be reviewed and that the WHO levels of 50-55 dB should
be regarded as a target, with proportionately lower levels at
night.
— That due regard should be given to
the nuisance caused to those living under flight paths but outside
the presently accepted 57dB contour. We commend the Australian
Report, "Expanding Ways to describe and assess Aircraft Noise—Discussion
paper. Airports operations, Department of Transport and Regional
Services, Canberra." This Report recognises that the noise
of an overflying aircraft will be annoying for some distance beyond
the contours, which represent average noise levels. The
extent of the annoyance will depend on the number of overflights
and the number of days in the year when they are experienced.
The annoyance level is set at a maximum noise level of 70dB as
this interferes with communication. This noise is measured as
the aircraft flies over (LAmax) and is recognised in the recent
EU Directive 2002/49/EC as a necessary measurement especially
in rural areas.
— These measurements have already been
recorded round Australian airports and we suggest that a standard
should be set with regard to the number of overflights over 70
dB and the number of days affected each year. Properties exposed
to levels above this standard should be included in the costings.
We have ourselves carried out a similar though very brief survey
round Stansted airport. We can confirm the annoyance effects of
a 70dB level.
— In addition, costings need to be
graduated according to the average noise level, ie the loss of
value must be recognised as worse for those living within the
higher noise contours.
3.5. Local Air Quality
3.5.1. The discussion document appears to
dismiss these effects as simply ones that might lead to a number
of extra admissions to hospital with costings too low to quantify.
This is an extraordinary conclusion in view of the very many research
papers that have been published on the effects of engine emissions,
including that of their own advisory body, COMEAP (Committee on
the Medical Effects of Pollution) and the work carried out on
by the National Expert Group on Transboundary Pollution. (Page
3). Their recent annual Report describes the damage done to plants,
the soil , water courses and to crops. This is of course damage
from all sources, but aviation contributes a significant share.
3.5.2. Evidence for quantifiable Health
risks.
— *Common Air Pollutants. A Brief Review.
Most of the pollutants liable to cause adverse
effects are derived from the burning of fossil fuels. They may
arise from transport operations, domestic heating or manufacturing.
Advice on ambient air quality standards is provided to the Government
by an Expert Panel on Air Quality Standards, EPAQS.
Standards have been recommended for the
following pollutants:-
Benzene. 1-3 butadiene, carbon monoxide, lead,
nitrogen dioxide, ozone, particles, PM10, and sulphur dioxide.
Nitrogen Dioxide, sulphur dioxide and ozone are
lung irritants, as are PM 10 particles. However particles come
in all sizes and contain a wide variety of constituents. Those
under 10 microns in size are the dangerous variety as they can
be inhaled into the lung tissue. They also attract onto their
surface whatever other chemicals are present in the surrounding
air. This means that their toxicity and carcinogenicity will vary.
Recent research has shown that the smallest, under 2.5 microns
and even less (ultrafines), are likely to be the most harmful.
Most come from the burning of diesel fuel but evidence is emerging
that the ultrafines are far more widespread than has previously
been thought.
The evidence is presented in the Philosophical
Transactions of the Royal Society[37]
that not only are the ultrafines probably responsible for the
accepted effects on health of PM10 particles but that the current
method of measurement by weight is quite inadequate to assess
the level of ultrafines, whose presence must be evaluated through
particle numbers per unit mass, or by surface area. Evidence as
to the mechanism by which ultrafines are thought to affect the
cardiopulmonary system is provided in the Lancet Review (Ref.
1).
Ozone is not a primary pollutant, it is
formed from the inter-reactions with the oxygen in the air of
nitrogen dioxide and the mixture of volatile organic compounds
(VOCs) present in unburned fuels as well as in engine emissions.
These include formaldehyde, benzene and 1.3-butadiene, both the
latter are carcinogenic.
Other chemicals will include the range of
hydrocarbons found in fossil fuels whose toxicity varies, some
with a chemical ring structure (polycyclic aromatic hydrocarbons,—PAHs)
are carcinogenic (benzpyrene) plus a large number of additives
whose composition are not publicly available for commercial reasons.
Residents living around airports will definitely
be at risk from exposure to all these compounds if the amount
in the local atmosphere exceeds the recommended level.
Research is now suggesting that long term
effects can be found at levels below the recommended limits[38].
In the case of those living round airports
emissions from aircraft, airport related vehicles, and airside
activities will all contribute, as well as the back ground emissions
that will have dispersed from other areas, especially from major
roads and industrial activities. In (page 4) practice experience
has shown that the most likely pollutants round airports are Nitrogen
Dioxide, Particles- PM10 and 2.5, (with the reservations expressed
above on ultrafines), Benzene, and 1.3-butadiene VOCs from unburned
aircraft fuel also causes problems. Ozone is not usually measured
as it's formation is very dependent on weather conditions. It
is measured as part of the national air quality monitoring service.
It is recognised as a serious health hazard and levels are related
to NO2 and VOC emissions but not on a simple linear scale.
— Specific Studies of the Effects of
Airport Pollutants around Airports.
"The public health impact of large
airports[39]."
This is the most comprehensive survey of
the effects of an airport on the health of the local residents.
The committee focussed on the public health impact of local changes
in the environment and considered the effects of all the airport
and airport related activities within a large study area of tens
of kilometres. They considered the effects of air pollution, noise,
accidents, soil and water pollution and studied 281 research papers
and reports as well as the continuing investigations taking place
at Schiphol airport.
They had no doubt that the airport operations
system affects public health.
They reached the following conclusions concerning
air pollution round airports.
— Air monitoring studies show that
Sulphur dioxide, carbon monoxide and black smoke (which would
probably include PM10) are below guideline values. Nitrogen dioxide
levels are often exceeded. VOCs vary but are expected to decrease.
PM 2.5 have yet to be evaluated.
— As road traffic emissions decline
the contribution made by nitrogen dioxide from aircraft emissions
is likely to rise and will depend on any increase in the number
of flights. Previously levels of pollutants in airports have been
similar to those in urban areas[40]
— Several studies in the Amsterdam
Schiphol region show a negative relationship between the distance
of the residents' homes from the airport with respiratory complaints
and the use of asthma medicines. Corrections were made for other
factors.
— There was no difference in cancer
rates between airport related areas and the city of Amsterdam,
but ambient air levels of carcinogenic pollutants (benzene, polycyclic
aromatic compounds and other VOCs derived from both jet fuel and
vehicle fuels) were similar. (Another study of Chicago airport
has shown an increase in cancer in the surrounding area)[41]
— Several recent studies have shown
a direct relationship between variation in pollutant levels and
day to day variations in mortality rates and hospital admissions
for respiratory and cardiovascular events. These include NO2,
SO2, CO and PM10 and PM 2.5. The elderly and those already suffering
from chest complaints were most affected[42]
(page 5).
— A number of studies have shown that
exposure to air pollutants contributes towards long term decline
in lung function and the development of obstructive respiratory
disease[43][44].
They include PM10 and NO2.
Tabulated Conclusions of the Health Council
of the Netherlands.(Public Health Impact of Large Airports. Sept.
1999).
Overview of acute and chronic health effects
related to exposure to air pollutants.
| response | evidence 1
| severity 2 | number affected 3
|
premature death and loss of life expectancy
| *** | *** | *
|
aggravation of symptoms, respiratory and cardiovascular (hospital admission)
| *** | *** | *
|
decreased lung function | ***
| * | * |
chronic respiratory symptoms in children
| ** | *** |
|
increase in chronic respiratory conditions
| *** | ** | **
|
aggravation of asthma | **
| *** | |
prevalence of asthma | *
| ** | |
b. * inadequate evidence. ** limited evidence. *** sufficient
evidence.
c. * slight. **moderate. *** severe.
d. * susceptible indiividuals.**specific groups *** substantial
part of exposed population
3.5.2. The Costings by CE Delft.
These have included all aspects of Local Air pollution,
health, buildings and vegetation and have assessed how reliably
damage can be costed. Their conclusions would appear to represent
a far more reasonable assessment of average costs per passenger
of £1-2 rather than the nil return of the discussion document.
3.6. Will the inclusion of environmental costs be sufficient
to achieve sustainability?
If passed on to passengers they should reduce demand. There
is a case for a differential rate to discourage the environmentally
more polluting short haul travel where there are much more sustainable
alternatives in train and also, for holidays, coach travel, also
potentially cheaper than even today's air fares (as in the past).
With regard to the carbon tax and noise elements this should
contribute to the vital need to develop less polluting aircraft
since airlines will wish to reduce costs and manufacturers are
already committed to improvement through ACARE targets if the
airlines will buy the new aircraft.
3.7. We suggest that any costs received by the exchequer
should be used to improve the least polluting forms of transport,
rail and water, subsidies justifiable for achieving sustainable
transport
April 2003
37
Phil. Trans. Royal Society, Vol. 358, No 1175 Ultrafine particles
in the atmosphere: pages 2563-64 and pages 2611 to 2621. Back
38
Association between mortality and indicators of traffic-related
air pollution in the Netherlands. G. Hoek & others, Lancet.
Vol. 360, No. 9341. Oct. 2002. Back
39
Public Health Impact of Large Airports. Health Council of the
Netherlands. September 1999. Back
40
COMEAP. The quantification of effects of air pollution on health
in the United Kingdon 1998. Dept. of Health. London. Back
41
Environment Protection Agency. 1993. Estimation and Evaluation
of Cancer Risks attributable to Air Pollution in Chicago. EPA.
Washington DC. USA. Back
42
COMEAP. The quantification of effects of air pollution on health
in the United Kingdon. 1998. Back
43
Tashkin D.P, Detels R, Simmons M. The UCLA population studies
of chronic obstructive respiratory disease. X1. Impact of air
pollution and smoking. Am. J Respir. Crit. Care Med. 1994: 149:
1209-27. Back
44
Jammes Y, Delpierre S, Devolgo M.J. Long term exposure of adults
to outdoor air pollution is associated with airways obstruction
and higher levels of bronchial hyper responsiveness. Arch. Environ.
Health. 1998. 56(3). 3720-1. Back
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