APPENDIX 14
Memorandum from the Woodland Trust
The Woodland Trust welcomes the opportunity
to contribute to this inquiry. The Trust is the UK's leading woodland
conservation charity. We achieve our purposes through a combination
of acquiring woodland and sites for planting and through advocacy
of the importance of protecting ancient woodland, enhancing woodland
biodiversity, expanding native woodland cover and increasing public
enjoyment of woodland. We own over 1,100 sites across the country,
covering around 19,000 hectares (47,000 acres) and we have 250,000
members and supporters.
1. Can the Full Environmental Costs of Aviation
be Identified? What are the Main Issues of Principle and Methodological
Difficulties in Attempting to do so? Can Remote but Potentially
Catastrophic Risks be Properly Reflected in such an Approach?
1.1 Aviation has been shown to have a clear
link to increasing climate change. The industry looks set to become
one of the biggest single contributors to climate change by 2050[45]
The Woodland Trust believes that climate change is perhaps the
greatest threat to the survival of ancient woodland, which is
land wooded since at least AD1600, our richest habitat for wildlife
and is irreplaceable. Since it is difficult to predict the costs
of potentially catastrophic future events as a result of climate
change, it is important that there is a focus is on preventative
measures to attempt to slow the rate of climate change.
1.2 The Government recently accepted the
recommendation of the Royal Commission on Environment and Pollution
(RCEP) that the UK should be aiming for at least a 60% reduction
in emissions by 2050[46]
In order to come close to achieving this is it essential that
the impact of aviation on the environment be reduced. It is impossible
to predict the exact cost of future potential catastrophes and
defining the exact level of responsibility of individual industries
in contributing to the problem both historically and in the future
is difficult. It makes more sense to concentrate on ensuring the
precautionary principle is central to aviation policy, managing
the impact of aviation on the environment to ensure that its greenhouse
gas emissions are reduced at the outset.
2. How Comprehensive and Accurate are the
Environmental Costs Included in Aviation and the Environment:
Using Economic Instruments, and in the Department for Transport's
Consultation The Future Development of Air Transport in the United
Kingdom.
2.1 Aviation and the Environment
deals with some externalities such as noise and climate change
and there is a degree of agreement, at least in principle, on
the need to factor in these costs. It also deals with local air
quality but only deals with its impact on human health and does
not mention the impact of deteriorating local air quality on the
natural environment. This represents a major gap in the document
and the wider consultation process in that there is no effort
made to factor in the costs to biodiversity and ecology of sites
that will be affected by increased over-flight or indeed clearance.
The Woodland Trust is opposed to any development that would damage
ancient woodland and we believe that it is impossible to compensate
for destruction of irreplaceable habitats, however, this does
not prevent us from looking at the impacts of increased usage
of existing airports on valuable habitats.
2.2 Given that many of the main airports
in the South East are in the middle of important concentrations
of ancient woodland, even an increase in flight numbers will have
a significant impact on ancient woods. Commenting on the prospect
of additional pollution due to increased passenger numbers at
Stansted for example, respected woodland historian Oliver Rackham
has predicted that Hatfield Forest "may get soaked with short
blasts of nitrous acid whenever planes take off in heavy drizzle.
The prospects for...sensitive plants are not good."[47]
Increases in atmospheric nitrous oxide when deposited on the ground
are similar to dumping loads of fertiliser on woods. Eutrophication
of semi-natural habitats including ancient woodland is a serious
issue and nitrates from aviation artificially fertilise the habitat,
which causes some of the rare plants associated with semi-natural
habitats to lose out to more competitive species such as nettle,
which means the value of the habitat is undermined.
2.3 Increased usage would also damage ancient
trees in the areas affected. The National Trust has shown that
"in the case of the ancient trees, increases in nitrogen
can lead to them losing their resistance to stress. The bacteria
which live in close proximity to tree roots and are essential
to the tree's health and vitality, multiply very quickly when
excess nitrogen is available. Having used up all the nitrogen,
the bacteria population crashes leaving the tree less able to
cope with environmental stresses such as drought and disease.
The EU Habitats Directive suggests that above 30 kg of nitrogen
deposition per hectare changes start to take place in habitats."
They go on to state that BAA's crude mapping at Hatfield Forest
suggests that part it "will receive in excess of 75 kgN per
hectare."[48]
2.4 It is a significant gap in thinking
regarding external costs that the impact on valuable habitats
is not seen as a factor that should be considered. Aviation
and the Environment does recognise that there "are a wide
variety of other environmental effects particularly associated
with the development of airport capacity. These include impact
on land use and properties, heritage and ecology"[49]
but fails to address the issues. Given that the Government recognises
that these environmental effects exist, it is strange that the
issue is not given any more consideration in Aviation and the
Environment, instead it is stated that these issues are addressed
in the main consultation documents. In fact, impacts on heritage
are significantly underplayed in the main consultation documents
too. This is not simply as Aviation and the Environment
suggests, a land use issue, the impact of increased numbers of
flights on habitats should be taken into account, and so should
the impact of increased congestion in the surrounding area. These
issues should not be dealt with in crude monetary terms, but they
should be at least recognised as factors that need to be taken
into account. The Woodland Trust believes that further detailed
research is needed into this issue as a matter of urgency.
3. HAS
THE GOVERNMENT
DEFINED THE
CORRECT ENVIRONMENTAL
POLICY OBJECTIVE
FOR AVIATION—THAT,
WHERE APPROPRIATE,
THE INDUSTRY
SHOULD PAY
FOR ITS
ENVIRONMENTAL COSTS?
HOW DOES
THIS RELATE
TO THE
GOVERNMENT'S
PRIMARY OBJECTIVE
FOR AIRPORTS—TO
MAXIMIZE THE
SIGNIFICANT SOCIAL
AND ECONOMIC
BENEFITS, WHILST
SEEKING TO
MINIMIZE THE
ENVIRONMENTAL IMPACTS?
3.1 In our view, the Government has so far
failed to follow its own policy of minimising environmental impacts.
The proposals outlined in the consultation paper The Future
Development of Air Transport in the UK would in fact cause
immense environmental destruction. As The Woodland Trust showed
in its report Flight Path to Destruction, the expansion
proposals taken together could for example result in the loss
of up to 425 hectares (1050 acres) of ancient woodland[50]
Even individual proposals such as those at Stansted or Gatwick
would result in the loss of over 86 and 75 hectares respectively
and indirectly damage at least a further 150 hectares. Despite
this, the main consultation documents only once refer to the impact
on ancient woodland. This undermines the idea that the Government
is seeking to minimise the environmental impacts of expansion.
Central to any dialogue about environmental costs is the need
for the Government to commit not to sanction any expansion that
would destroy irreplaceable environmental assets such as ancient
woodland.
3.2 As discussed above, it may indeed be
correct for the Government to state that where appropriate the
industry should pay for its environmental costs, but there is
a gaping hole in the equation at present. The costs of expansion
to biodiversity and heritage interests are not factored in which
means that the external costs of expansion are significantly underrated.
It is important that these factors are recognised in any discussion
of external costs of air travel.
4. WOULD
THE INCORPORATION
OF ENVIRONMENTAL
COSTS BE
SUFFICIENT TO
ACHIEVE SUSTAINABILITY
IN THE
AIR TRANSPORT
SECTOR? WHAT
ADDITIONAL MEASURES,
IF ANY,
WOULD NEED
TO BE
TAKEN IF
THIS WERE
TO HAVE
LITTLE IMPACT
ON RATES
OF GROWTH?
TO WHAT
EXTENT IS
THERE A
TENSION BETWEEN
THE POLICY
OF INCORPORATING
ENVIRONMENTAL COSTS
(ESPECIALLY OF
CARBON) AND
THE GOVERNMENT'S
LONG-TERM
OBJECTIVE OF
A 60% REDUCTION
IN CO2 BY
2050?
4.1 Incorporation of environmental costs
would only be sufficient to achieve sustainability in the air
transport sector if they resulted in an end to the predict and
provide approach and inducements to inflated growth that the industry
currently enjoys. Sustainable development requires limits to be
placed on activities that irreparably harm the environment. We
agree with the RCEP that "plans to facilitate the growth
of air transport [are] inconsistent with many other policies of
the UK government and with its stated commitment to sustainable
development."[51]
The Government is also well advised by the Sustainable Development
Commission on this issue when it states that "wise policy
should be leading us towards decoupling the growth of economic
well-being from growth in air travel, not reinforcing their connections."[52]
4.2 The tension between incorporating costs
rather than managing growth is evident in this approach. There
is a danger that if external impacts are addressed on the through
cost analyses then the imperative to address the fundamentally
polluting nature of air travel could be reduced. Unless the Government
takes a wide range of measures to slow demand then it seems doubtful
that we can even come close to reaching the 60% reduction in CO2
emissions we need as a minimum by 2050. As the RCEP stated "the
government shows few signs of bringing forward policies that will
address these issues, either in the short or the long-term. On
the contrary, the policies set out in the consultation exercise
on regional airports are likely to exacerbate the problems."[53]
The Government should re-assess its approach to air transport
against the principles of sustainable development to ensure that
irreplaceable assets are not lost.
5. GIVEN
THE INTERNATIONAL
CONTEXT, WHAT
PRACTICAL OPTIONS
FOR INCORPORATING
ENVIRONMENTAL COSTS
ARE REALLY
AVAILABLE TO
THE TREASURY
AND THE
DEPARTMENT FOR
TRANSPORT, AND
HOW SHOULD
ANY REVENUES
BE USED?
5.1 It is vital that well-documented anomaly
of the tax status of aviation compared to other polluting transport
modes is addressed through taxation measures. The recommendation
of the RCEP that the Government should push for a Europe-wide
emissions charge where aircraft operators would be charged on
the basis of emissions caused47 should also be adopted by Government
to help to redress the balance.
5.2 The money from the subsidy currently
provided to the air industry should be re-directed to more sustainable
forms of transport such as high-speed rail, which would help to
limit demand for domestic air travel. If agreement is reached
on developing a means to charge for the external costs of air
travel we believe some of the funding should go towards funding
research into the effects of increased air pollution on habitats
and the development of strategies to avoid and mitigate these
effects.
April 2003
45 Transport 2000 & The Ashden Trust (2000) The
Plane Truth: Aviation and the Environment, p.22. Back
46
Department for Trade and Industry (2003) Energy White Paper:
Our energy future-creating a low carbon economy, para 2.12. Back
47
Rackham, O. (1998) The Last Forest, p.264. Back
48
National Trust (2002) Presentation to Uttlesford District Council,
Development Control and Licensing Committee, Wednesday 24
April 2002. Back
49
HM Treasury/Department for Transport (2003) Aviation and the
Environment: Using Economic Instruments, para 3.2. Back
50
Woodland Trust (2002) Flight Path to Destruction. The impact
of UK airport expansion plans on ancient woodland. Back
51
RCEP (2002) The Environmental Effects of Civil Aircraft in
Flight, para 5.3. Back
52
Sustainable Development Commission (2002) Air Transport &
sustainable development-a submission from the SDC, para 9. Back
53
RCEP (2002) The Environmental Effects of Civil Aircraft in Flight,
para 5.2. Back
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