Memorandum submitted by The Centre for
Air Transport and the Environment, Faculty of Science and Engineering,
Manchester Metropolitan University
1.1 The Centre for Air Transport and the
Environment was established within the Manchester Metropolitan
University to contribute to the attainment of sustainable aviation
growth through research and knowledge transfer between the academic,
industry, regulatory and NGO sectors. The Centre's work focuses
on the principal environmental impacts associated with aviation
and their ability to constrain airport and airline growth.
1.2 In this paper we consider the environmental
issues of concern, the nature of the CAA's current engagement
with them and provide comments on the relevant issues the Committee
wishes to consider as outlined in its Press Notice updated on
24 October 2005.
2.1 Aviation is playing an increasingly
important role in the social and economic development of the UK.
Demand is strong and growing. The social and economic benefits
of meeting that demand are significant, but so too are the environmental
costs. The rate of growth in demand is outstripping the environmental
benefits offered by new technologies and operating practices with
the result that the key environmental impacts of the industry
could increase in the future, a trend that is unsustainable in
the longer term.
2.2 This is significant because:
at a local level noise, air quality
and biodiversity issues are starting to constrain the operational
capacity and growth of airports; and
at a Global level, the implications
of aviation for climate change is becoming an increasing concern,
leading to calls for constraints on growth. Meanwhile the forecast
supply and cost of aviation fuel will demand ongoing and significant
improvements in fuel efficiency if these factors are not to restrict
2.3 There is, therefore a direct link between
the way in which aviation addresses its environmental impacts,
its potential for future growth and its ability to contribute
to social and economic development. A recent study has shown that
about Û of medium and larger European airports already face
actual or potential environmental capacity constraints, with almost
80% anticipating such restrictions within the decade. This is
potentially a significant loss of capacity within the European
Air Transport System.
2.4 Growing demand will generate requirements
for more capacity both at airports and within en route sectors.
However it is becoming increasingly difficult to achieve planning
approval for additional airport infrastructure either as a result
of the environmental implications of the construction itself or
the additional traffic that would arise from it. Further, community
opposition is making it more difficult to release en-route capacity
through airspace changes.
3. EXISTING CAA
3.1 The UK CAA is the independent regulator
for civil aviation in the UK. Its objectives, as detailed in Section
4 of the Civil Aviation Act are to:
secure that British airlines provide
air transport services which satisfy all potential categories
of public demand (so far as British airlines may reasonably be
expected to provide such services) at the lowest charges consistent
with a high standard of safety in operating the services and an
economic return to efficient operators on the sums invested in
providing the services and with securing the sound development
of the civil air transport industry of the United Kingdom and
to further the reasonable interests of users of air transport
3.2 It also has a duty (under Section 5
of the Civil Aviation Act 1982) to consider environmental factors
when licensing certain aerodromes and, under Section 70(2)(d)
of the Transport Act 2000, to take account of guidance on environmental
objectives given by the Secretary of State, when carrying out
its air navigation functions. As yet, no airport has ever been
specified under Section 5 of the 1982 Act and therefore the CAA
has never had to exercise this duty.
3.3 The Department for Transport acts as
the regulator in respect of the aviation environment regulation
with the CAA providing a technical and policy advisory role. In
January 2002 the DfT issued Guidance to the CAA on Environmental
Objectives Relating to the Exercise of its Air Navigation Functions.
This reinforced the need to take account of the environmental
consequences of aviation whilst ensuring safety and expedition
of air traffic.
3.4 The CAA therefore has an implicit, as
well as explicit role in supporting the sustainable growth of
UK aviation. This means supporting the Government's efforts to
enable achievement of the correct balance between air transport
growth and environmental protection.
3.5 In the very recent past, the role of
the UK-CAA in relation to ICAO certification procedures relating
to safety, noise and aircraft emissions has been passed to the
European Aviation Safety Association (EASA) reflecting the organisations
growing international and EU engagement.
3.6 Meanwhile the Environmental Research
and Consultancy Department (ERCD), part of the Directorate of
Airspace Policy (DAP) within the CAA continues to carry out research
and provide technical support regarding the environmental impacts
of aviation, airspace policy and airspace changes.
3.7 The ERCD's primary focus is the management,
monitoring and modelling of the aircraft noise exposure. ERCD
provides technical support on such matters to the DfT, airport
operators and local planning authorities and is working at an
international level to secure harmonisation of noise modelling
3.8 Despite improvements in aircraft technology,
the disturbance caused by noise remains aviations single most
significant local environmental impact. Modelling indicates that
across the UK, several hundred thousand people are adversely affected
by aircraft noise on a daily basis and forecasts indicate these
figures could increase. The response of people to aircraft noise
and their tolerance of the resulting disturbance is, however,
a matter of lifestyle and perception and is affected by a wide
variety of socio-economic factors associated with expectation
of quality of life and an understanding or enjoyment of the benefits
of air transport.
3.9 Community attitudes and the numbers
of people affected varies significantly at airports across the
UK with the result that with the exception of Heathrow, Gatwick
and Stansted, where the Secretary of State for Transport has taken
responsibility for aircraft noise, Government policy is that noise
issues need to be addressed at a local level with the proviso
that under Section 78 and 79 of the Civil Aviation Act 1982 the
Secretary of State has the reserve power" to intervene and
impose direct control where issues cannot be resolved locally.
3.10 Noise related operational charges and
penalties can be employed to promote use of the quietest aircraft
and encourage pilots to fly them in such a manner as to minimise
disturbance on the ground. The economic aspects of such environmental
management tools, particularly for airports whose charges are
regulated, can fall within the sphere of interest of the CAA-Economic
Regulation Group (ERG).
3.11 The ERCD enjoys international recognition
for its work in the field of aircraft noise, it is highly respected
by all airport stakeholders (including environmental NGO's and
academic groups) for its expertise and independence. In this context
it plays a very valuable role supporting both Government and industry
alike to achieve the appropriate balance between development and
environmental protection at a local level.
Local Air Quality
3.12 ERCD has also developed more limited
expertise and knowledge on local air quality, sufficient to provide
internal advise to the CAA and comment to the DfT. The DfT however
secures most of its resource in this field from external organisations.
In part, the lack of a more active role in this field reflects
the fact that local air quality is a function of not only the
air transport industry but also road traffic emissions and emissions
from other industries.
3.13 The emergence in the recent past of
emissions related charges at UK airports has implications in the
context of the work of the CAA-ERG.
3.14 The ERG is engaged with the emerging
aviation emissions trading scheme in Europe and is providing advice
on this matter to both the DfT and Treasury.
Landscape and Habitat Issues
3.15 The need to protect, conserve or even
enhance habitat and biodiversity can act as a constraint upon
airport growth. Sensitive sites on airport or in surrounding areas
can be of considerable ecological value, particularly where the
airport is located in a green belt. The ability of an airport
to extend its boundaries or even build upon parts of its own land
can be restricted by the value of the habitats threatened. Mitigation
is possible but such action has the potential to attract birds
that can pose a risk to aircraft safety.
3.16 The apparent conflict between aviation
safety and the need to protect or enhance biodiversity has featured
at Manchester, Stansted and Heathrow airports. While this lies
within the remit of the CAA Safety Regulation Group, each airport
has responsibility for managing its risk of birdstrike (subsequent
to Joint Circular 1/2003 on Aerodrome Safeguarding). The requirement
to ensure safe operations can bring the airport and SRG into direct
conflict with the statutory body responsible for nature conservation
in the UK (English Nature) which has acknowledged this issue in
a recent publication (Aerodrome Safeguarding and Nature Conservation"
Birds Network, Information Note).
3.17 This is another area where the UK (the
UK-CAA and other organisations such as the Central Science Laboratories
in York) are internationally recognised for their expertise in
Land Use Planning
3.18 The CAA is providing technical support
to the DfT assisting revision of planning guidance PPG24. Land
use planning to prevent inappropriate developments in the vicinity
of airports and their approach and departure routes can be used
with air space planning to minimise the number of people exposed
to aircraft noise and third party risk, thereby protecting future
4.1 Environmental issues have, over the
past 10-20 years, come to have an increasing impact upon the growth
and development of aviation and it is acknowledged in the Future
of Air Transport" that this will continue, not the least
because of the rapid growth of the industry.
4.2 Although the regulation of aviation
environmental impacts falls within the remit of the Department
for Transport, the Department places considerable reliance upon
the well established work of the CAA's ERCD in respect of the
technical issues associated with the management, measurement and
modelling of aircraft noise.
4.3 As the costs of the environmental impacts
of aviation are internalised (eg through noise and emissions charges,
emissions trading regimes) this will have implications for the
CAA's Economic Regulation Group.
4.4 This paper has highlighted a potential
conflict between the need to protect biodiversity and aviation
safety. While safety can never be compromised, a balance still
has to be found between environmental protection and aviation
growth within the context of sustainable development. The CAA
Safety Regulation Group has a role in ensuring the correct balance
4.5 Following the emergence of environmental
capacity constraints within the air transport system and the increasing
costs of managing such issues, it is evident that environment
is likely to become the biggest business risk to the future growth
of UK aviation, impacting both locally and globally. The UK-CAA
can continue to play an independent advisory role, taking account
of the effects of growth and highlighting and supporting the adoption
of policies that promote sustainable development. It will therefore
be important that it continues to develop it's own environmental
expertise across a variety of disciplines.
11 January 2006