Select Committee on Environmental Audit Minutes of Evidence


Memorandum from the Aviation Environment Federation

  Our submission to the Committee's current Inquiry relates directly to the recently published Department for Transport White Paper "The Future of Air Transport" (Cm 6046). To begin with, we would like to state for the record that we support without reservation the Committee's 9th Report "Budget 2003 & Aviation".

  During the 3-year policy development process that has led to the Air Transport White Paper, we have been heavily involved participating in all the direct Government-facing opportunities that presented themselves such as workshops, seminars and numerous other formal and informal contacts with civil servants and politicians across Government departments. We are now firmly of the opinion that although most contacts clearly recognise the scale of the range of environmental impacts caused by air transport, the policy development emphasis is still heavily weighted towards economic imperatives to the exclusion of any meaningful strategies to control and reduce the sector's environmental impacts. There is little in the way of effective environmental protection measures at either local or global level set out in the White Paper. The "mitigation" measures contained within the White Paper are inadequate and ineffective as the circumlocutory example below from the White Paper, Chapter 8,The North of England, pages 84-86, concerning Manchester Airport shows:

  "8.11 We recognise that the location of Manchester Airport already causes large numbers of people to be exposed to aircraft noise nuisance. In 1999, around 45,000 people lived within the 57dBA noise contour. Our estimates suggest that, if capacity were increased to cater for a passenger throughput of over 50 mppa by 2030, this figure could rise to around 70,000 people unless noise improvements beyond those currently assumed in our analysis can be achieved.

  8.12  However, we have taken into account the potential that the growth of Manchester Airport has to generate significant benefits for the economy of the North of England. Having regard to the policies and principles set out earlier in this White Paper, we do not believe, on balance, that these impacts are so severe that constraints should be imposed on the development of the airport to prevent it growing to the levels of demand forecast. The Government considers therefore that Manchester Airport's capacity should in principle continue to grow to accommodate additional demand up to around 50 mppa by 2030. But it will be important that every effort is made to secure the maximum possible reduction in noise levels and to minimise the number of people affected.

  8.13  We have therefore concluded that the growth of Manchester Airport should be subject to stringent limits on the area affected by aircraft noise, with the objective of incentivising airlines to introduce the quietest suitable aircraft as quickly as is reasonably practical. The limits should look at least ten years ahead, and will need to be reviewed at intervals between now and 2030 to take account of emerging developments in aircraft noise performance. It is also essential that airport growth does not jeopardise legal air quality standards, notably in respect of NO2. This will require thorough monitoring and evaluation."

  Earlier in the White Paper, in Chapter 3, Environmental Impacts, Noise, pages 32-37, the Government states the following as its parameters for noise policy:

  "3.11 Our basic aim is to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise. This is a challenging objective, and meeting it will require a combination of measures . . ."

  The measures include:

    —  more & better R&D to achieve ACARE targets, which we support but consider extremely difficult to reach let alone bring into service, as the tighter international aero engine noise performance standards needed to "pull through" technological developments into fleet use are entirely in the gift of ICAO

    —  ICAO's so-called " balanced approach" of tighter noise standards, better land-use planning, noise abatement operating procedures, and operating restrictions, is a policy designed to facilitate expansion through piecemeal small-scale mitigation, rather than control and reduce rising environmental impacts

    —  EU directive 2002/49/EC noise mapping is fine as a tool and does include a helpful evening and night time noise weighting but lacks any standards or guidelines to link the required action plans to

    —  Strengthening current UK regulation of aircraft noise but no hint of any measures to achieve this

    —  More locally-based economic instruments such as differential landing charges based on noise—these have proved utterly ineffective at other European airports, in practice being just a cosmetic PR exercise

  And further on in the same Chapter:

  "3.15 Our approach to noise impacts is first, to seek to control the scale of the impacts; second, to mitigate remaining impacts; and third, to compensate for those noise impacts which cannot be mitigated. A variety of measures is available to help reduce noise impacts at source, as described earlier in this chapter, but there is a limit to how far noise nuisance near airports can be reduced."

  The limits that are referred to in the paragraphs from the White Paper quoted above will, in reality turn out to be simply the everyday uncontrolled operational environmental noise impact of the aircraft fleet needed to meet the passenger demand curve at each airport and its range of destinations. In our view, noise policies should aim to reduce the population affected by aircraft noise, not increase it! For instance, our research and experience tells us that any small increase in differential landing fees for noise performance reasons are simply accepted by airlines as the price of admission to that particular airport and do not act as deterrents nor do they encourage operators to change or re-equip with quieter aircraft. Whilst the proposed mitigation regime may produce the odd instance where impacts may be "less than they otherwise would be" our reaction is best categorised as "so what".

  As far as the Department for Transport and Her Majesty's Treasury in particular are concerned, pursuing an economic imperative has resulted in the White Paper simply reflecting the proposals set out in the consultation documents. This means that passenger numbers "predicted and provided" for in the White Paper add up to approximately 470 million by 2030 with commensurate infrastructure capacity clearly identified and indeed strongly recommended at existing airports up and down the U.K.

  It is true that some of the more "blue sky" off shore proposals and green-field developments were dropped but again, this was largely because of their doubtful economic success, with construction costs judged against rate of return criteria, rather than for any overwhelming environmental case against them.

  As well as the environment NGO and community group lobby, which we are part of, many other bodies took part in the consultation and policy development process.

  This included Government approved and appointed organisations such as the Royal Commission for Environmental Pollution, the Sustainable Development Commission, the Commission for Integrated Transport, the Environment Agency and independent think tanks like the Institute for Public Policy Research. All submitted critical commentaries during the consultation process, as the Committee is well aware. We felt the Committee should know how one or two of these organisations responded immediately post-publication of the White Paper.

  On the 16th December 2003, the RCEP had this to say about the White Paper in a tough, uncompromising, press release:

  "The release of today's Aviation White Paper reveals a serious fracture between the government's policies on energy and aviation" said Sir Tom Blundell, Chairman of the Royal Commission on Environmental Pollution.

  Sir Tom expressed the Royal Commission's disappointment in the White Paper published today by the Department for Transport. Sir Tom explained:

  "The White Paper fails to take account of the serious impacts that the projected increase in air travel will have on the environment. Earlier this year the government published an Energy White Paper setting out its strategy for tackling global climate change, and set challenging but necessary targets for greenhouse gas emissions. Today's Aviation White Paper undermines those targets and continues to favour commerce over vital carbon dioxide reduction measures."

  Last year the Royal Commission's report on air transport pointed out that uncontrolled growth in aviation, to the extent predicted by the government, would mean it would become the major source of global warming emissions in the future, contributing more than half the UK's share of greenhouse gases and their equivalents by 2050. The Royal Commission made a number of recommendations to government on how to avoid this situation.

  The Aviation White Paper acknowledges this danger and the consequent need to take steps to make the cost of air transport reflect its environmental damage. It even recognises the role that emissions charges might play in this, as recommended by the Royal Commission. But it makes no clear commitment to action, and at the same time it announces a huge expansion in airport capacity. This leaves a major question mark over the extent to which the government is serious about the carbon dioxide reduction targets set out in its Energy White Paper. Aircraft emissions have between 2 and 3 times the global warming effect of carbon dioxide emitted at ground level.

  Sir Tom added:

   "The Royal Commission is not opposed to cheap air travel, and has no intention of suggesting that people should not have affordable access to their holiday destinations. However, the levels of growth predicted in the Aviation White Paper are simply not environmentally sustainable, and the government needs now to start moderating demand, both by increasing the cost of air transport to a fair and equitable level, and by encouraging affordable and environmentally more benign forms of transport."

  The Commission advises that the debate should not be about where to expand air travel capacity but how to resist this expansion.

  In its report last year, the Royal Commission made five recommendations to government:

    —  impose climate protection charges for aircraft taking off and landing within the EU;

    —  restrict airport development to encourage greater competition for available take off and landing slots in order to optimise their use;

    —  develop major airports into land-air hubs integrated with an enhanced rail network;

    —  support technological development to lessen the damage done by air travel;

    —  include international aviation in the emissions trading scheme under the Kyoto Protocol.

  The Royal Commission calls upon the government to explain how it reconciles the rift between aviation policy and energy policy, and what measures, such as those proposed by the Royal Commission, it will adopt to manage demand for air travel."

  And also on the 16th December last, the Environment Agency's Chief Executive, Barbara Young said in a press release:

  "The Environment Agency expressed concern about today's White Paper, particularly the increased levels of CO2 emissions that will result from the planned expansion. The Agency also calls for a full assessment of the environmental impacts associated with each development and early consultation with the Agency and other statutory bodies on development proposals. Barbara Young, Chief Executive of the Environment Agency, said:

  "The Environment Agency's main concern with today's proposals is that the environmental effects of this planned expansion are still relatively unknown. Further work on the environmental impacts of aviation, particularly a better understanding of its contribution to climate change, is now crucial. The Government needs to work with the EU, international bodies, its environmental advisors, and industry to reduce aviation's greenhouse gas emissions and to develop appropriate economic instruments that meet the environmental costs of aviation."

  "The Government has committed to a 60% reduction in CO2 emissions by 2050. Today's White Paper does not alter that target but it's acceptance of growth in air traffic, without a full understanding of the industry's contribution to climate change, jeopardises its achievement. The Government's own forecasts suggest that by 2030 aircraft fuelled at UK airports could have a global warming impact equivalent to at least 30% of current CO2 emissions from all UK domestic sources. This is a massive growth from its 5% share in 2000."

  "The Environment Agency notes that airport development will have immediate environmental impacts as well as major knock-on consequences outside the airport vicinity, such as on surface access transport and housing development. The sum of the individual environmental impacts resulting from these knock-on consequences is often greater than that resulting directly from the airport itself. It is therefore imperative that promoters and planning bodies consult the Environment Agency at the earliest opportunity on development arising from this White Paper."

  "A long-term and sustainable aviation strategy must have proper regard for environmental costs and limits. Government should implement a package of regulatory and economic measures to take these into account."

  Both the RCEP and the Environment Agency have issued strong, trenchant criticism of the White Paper, which we agree with. The White Paper's analysis and policy framework for action on the climate change impacts that its expansion proposals would bring are lightweight and wholly inadequate.

  We find it particularly astonishing that the RCEP's views on air transport are so flagrantly ignored by Government. The same body produced a comprehensive, authoritative report on energy, its 22nd report "Energy—the changing climate" in June 2000. This report formed the basis for the subsequent Cabinet Office Performance and Innovation Unit Energy Review and the publication on the 24 February 2003 of the White Paper "Our Energy Future—Creating A Low Carbon Economy", by the DTI. Our question is—if the RCEP can be so right and have such strong influence on energy policy, why does the Government not accept and indeed disparage its views on air transport?

  Go to http://www.defra.gov.uk/environment/energy/review/ for the background to the Energy White Paper process.

  Even some parts of the Government believe air transport should be taxed as the extract below from the No.10 PIU Energy Review report shows:[1]

  Increased vehicle efficiency and investment in new options for transport fuels is required in the longer-term. The transport sector is likely to remain primarily oil-based until at least 2020. Access to oil supplies is not a current concern. Nevertheless, the economy's dependence on transport, coupled with increased imports as UKCS production declines, reinforces the need to improve the energy efficiency of oil-driven vehicles. Prospective advances in vehicle technology hold out the possibility of significant reductions in fuel use.

  The potential long-term requirement for significant CO2 emissions reductions from the transport sector combined with the possibility that oil will become scarcer, raise the need to develop alternative fuels. There is the long-term prospect that the technology for powering vehicles by fuel cells fed on hydrogen will fulfil its current promise, and so ultimately provide a substitute for oil. Other options, such as liquid biofuels may also have a role. International efforts are needed to develop these technologies.

  Handling the projected growth in aviation energy use and CO2 emissions must become a priority. Taxation and other measures to manage aviation demand should be prioritised for discussion in EU and other international forums."

  The Air Transport White Paper does include a section in Chapter 3, pages 39-41, on climate change and explains emission trading as a concept at Annex B. Measures discussed include:

    —  air traffic control measures to minimise the impact of these activities on climate change

    —  more R&D to reduce the climate change impact of future fleets

    —  voluntary action including emissions reporting and targets at company level

    —  emissions trading, either an open system internationally developed through ICAO or participation in the EU scheme from 2008

    —  hint of possible emissions charge in paragraph 3.42, page 41, with a commitment to move forward if progress at international level proves "too slow"

  What these pages show, however, is a superficially reasonable but understated grasp of the problem and a less than in-depth examination of any outcomes resulting from the available policy measures discussed. It is this almost total lack of any targets as to how to reduce and control the sector's climate change impacts, coupled with no analysis of the reductions needed from other sectors in the economy needed to "feed" air transport's growth under any emissions trading scheme, clearly making the running as the Government and industry favoured solution, that is most worrying.

  This seems to us to be an unacceptably lightweight area of the White Paper. In our previous submissions to the Committee we have made the point that emission trading is a flawed concept. We have and will continue to make it directly to Government as well. We simply don't agree either with the Government's statement in para 3.43 of Chapter 3 that ". . . because of its blunt nature, Air Passenger Duty is not the ideal measure for tackling the environmental impacts of aviation."

  APD is an effective proxy for the lack of fuel duty and VAT on tickets and set at the right level to achieve effective pollution reduction targets through demand management would work well. However, we understand that such a policy doesn't fit the Government's thinly disguised "business as usual" scenario set out so uncompromisingly on every page of the White Paper.

  We know that the Committee fully understands the importance of the way in which aircraft emissions have a much greater climate change impact than just CO2 alone.

  The Committee might like to know that the recent EC commissioned research project, "TRADEOFF—Aircraft emissions: Contributions of various climate compounds to changes in composition and radiative forcing—tradeoffs to reduce atmospheric impact" found that the latest look at the potential cirrus cloud impacts directly related to aviation emissions in the atmosphere raised the radiative forcing multiplier significantly, as the comparison below shows:

  2000 TRADEOFF best estimate: g4.4

  2000 TRADEOFF low: 3.3

  2000 TRADEOFF high: 5.5

  2050*TRADEOFF best estimate: g4.7

  2050* TRADEOFF low: 3.6

  2050* TRADEOFF high: 5.7

  1992 IPCC best estimate: 2.7

  1992 IPCC low: 1.9

  1992 IPCC high: 4.0

  2050* IPCC best estimate: 2.6

  2050* IPCC low: 1.9

  2050* IPCC high: 5.3

  *  UN IPCC Fa1 scenario. Sources: UN IPCC Special Report & EC TRADEOFF study.

  This report gave rise to press coverage that aircraft would have to fly lower to avoid creating condensation trails but at the risk of creating more turbulence. We would ask the Committee to recognise that there is a significant difference between 2.7 and 4.4-4.7!

  The Committee is well aware of our scepticism towards emissions trading schemes. We have come across a set of well-researched and written papers by Curtis Moore, an American commentator and researcher on environmental affairs. The USA has seen a number of emission trading schemes and Mr Moore's papers throw an illuminating light on their practical difficulties and outcomes. We have sent these papers to the Committee's secretariat electronically for your information.[2]

  The Department for Transport's excellent attitudinal survey "Attitudes to Air Travel", part of the series of documents produced for the consultation exercise is an item we have drawn the Committee's attention to before. The extract below shows that there is a clear "willingness to pay" the costs of air travel's environmental impacts amongst individual flyers:

  "All respondents were then told that although air travel does harm the environment, the cost is not included in the price of flights. They were asked how acceptable they would find it if the cost of flights went up by different amounts (5%, 10% and 15%) to cover environmental costs. Examples of the additional costs were given.

  16. (You said that) Air travel can harm the environment but this cost is not included in the price of flights. To cover environmental costs, how acceptable would you find it if the cost of flights went up by . . .

    (a)  5%? This would, for example, add £5 to a flight costing £100 or £15 to a flight costing £300.

    (b)  10%? This would, for example, add £10 to a flight costing £100 or £30 to a flight costing £300.

    (c)  15%? This would, for example, add £15 to a flight costing £100 or £45 to a flight costing £300.

  Four in five people (79%) said they would find an increase of 5% either very (28%) or fairly (51%) acceptable. One in five (21%) would not find it acceptable. A half (50%) would find an increase of 10% acceptable, and a quarter (25%) would find an increase of 15% acceptable. (Chart 16) Slightly higher proportions of men found the increases more acceptable than women (two or three percentage points higher). All increases were less acceptable to 16-24 year olds. Acceptance levels were lower in London (69%) and Scotland (71%) and higher in the South West (89%) figures are levels of acceptance for an increase of 5%. And, as one might expect, acceptance was highest in affluent areas and lowest in striving areas (differences of ten to fifteen percentage points). However, it did not vary that much by frequency of flying, with levels of acceptance only slightly lower amongst people who had flown in 2001 than amongst those who had not."

  The full report can be read at:

www.dft.gov.uk/stellent/groups/dft—transstats/documents/page/dft—transstats—505963-01.hcsp

  Surely this Government with all its powers of persuasion could manage to utilise such research to educate the travelling public about the damaging environmental impacts of frequent flying and actively "sell" not just the notion of the "polluter pays" principle but a realistic environmental tax scheme for air transport that would begin to ensure that passengers started covering some, if not all, of the external costs of their flights?

  With regret, we are of the view that the Department for Transport White Paper "The Future of Air Transport" is not a vision we share or are comfortable with. We will continue to campaign and press for a sustainable aviation policy as set out in the AEF submission to the Government policy development process, a process perhaps best described as "they consulted, we replied—and they ignored us."

January 2004


1   The Energy Review, A Performance and Innovation Unit Report-February 2002. Back

2   Not printed here-available on request. Back


 
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