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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