Select Committee on Environmental Audit Written Evidence


Memorandum from Saffron Walden & District Friends of the Earth


  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.
responseevidence 1 severity 2number 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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