Aviation Strategy

Written evidence from the Wildlife Trusts (AS 95)

[Incorporating Berkshire, Buckinghamshire & Oxfordshire, Essex, Hertfordshire and Middlesex, Kent, London, Surrey and Sussex Wildlife Trusts]

Summary

1. The seven Wildlife Trusts whose interests are most directly affected by aviation and airport development in the South East [1] are pleased to have this opportunity to provide evidence to the Transport Select Committee’s Aviation Inquiry. We are acutely aware of the relentless pressures – through a range of both public policy and private initiatives – to expand airport capacity in the South East. The options and measures vary from more efficient use of and extensions to existing infrastructure, [2] to a completely new London airport. [3] Any one of the options could have damaging impacts on our wildlife.

2. The key question for us is simple:

Is airport development in the South East sustainable? [4]

3. We support development which has been properly tested for its sustainability, where environmental consequences have been fully considered and the impacts duly moderated through the application of the conventional planning hierarchy in order to minimise damaging effects on our natural heritage. We have examined the policy framework and the emerging development proposals for aviation and airport development.

Our primary concern arising from this assessment is that none of the public policies, including the Government’s new aviation policy framework, nor the various airport development proposals which focus largely on the South East take a proper strategic approach to aviation and, critically, none have been adequately tested for their sustainability.

4. We are further concerned that in the current climate of ‘enhancing economic performance over all else’, the process to define aviation policy and airport development strategy risks marginalising environmental considerations. Two particular examples which demonstrate the nature of problems which could act as barriers to proper consideration of the natural environment as we prepare the way for future aviation are:

· The recent Policy Exchange/CentreForum publication [5] takes a refreshingly clear and honest approach to factual matters concerning aviation. It unequivocally states (in the context of air quality and climate change) that "Flying is bad for the environment, and although it will improve it will remain bad for the environment." [6] It also takes inadequate, simplistic approach to assessing the environmental impact of its ‘preferred solution’ to maintaining an international hub by developing a 4-runway westerly extension to Heathrow; the importance of wildlife sites is assessed –and dismissed– in one paragraph. [7]

· The Marketing Director for an airport in Kent, during the process of public scrutiny of its proposed plans to expand is reported as saying "So what if a few rare species of plant get wiped out – we should have the right to cheap and easy air travel." [8]

5. If we fail to properly integrate the full suite of environmental considerations right at the start of aviation – and indeed wider transport and communications – policy formulation and strategic planning, then we risk that this sector will continue to erode our natural heritage and wildlife assets.

Introduction

Who are we and what do we do?

6. This joint submission of evidence is contributed by the seven Wildlife Trusts most directly affected by aviation and airport development in the South East. We have a combined membership in excess of 201,000 individuals; the total membership of the 47 Wildlife Trusts is ca 800,000.

7. We are partners in The Wildlife Trusts movement which has a coll ective vision of an environment rich in wildlife for everyone and a mission to create Living Landscape s and secure Living Seas . The 47 independent Wildlife Trust charities in the UK, Isle of Man and Alderney share the common primary objective: to safeguard nature. In parallel we promote access to and enjoyment of nature for the cultural, spiritual, aesthetic, educational and other benefits this brings to maintain and enhance our quality of life. We operate principally at a local level, supported by and working for our local membership and the wider communities in our areas. We manage our own nature reserves, provide advice to land, water and marine resource users and managers, develop and collaborate with others on landscape-scale actions to protect and to rebuild our natural assets in towns and cities, the wider countryside and marine and coastal environments. We undertake and support surveys, data collection and research to underpin our understanding and knowledge of the natural world, we provide educational services to children and young people in our communities and we lobby for governance (legislation, policy frameworks and strategic planning) and decision making at all levels –from local to European– which support our objectives.

Why are we interested in aviation policy and airport development strategies?

8. We support development which has been properly tested for its sustainability. We accept that aviation is part of our way of live and is likely to remain so for the foreseeable future. Our interest is to see that any development meets the highest standards of sustainability. This will include taking due account of new technologies and behaviours that can help to reduce the need and demand for air travel.

9. Aviation and airport development have direct and indirect impacts on wildlife and on the wider environment. Aircraft emit greenhouse gases (GHGs) and noise affects the environment at airports and along flight paths; surface transport used by passengers and staff and for freight and support services emits GHGs and other pollutants (such as NOx and PM10 particulates) into the air.

10. The expansion of airports damages important wildlife areas through direct land take of key habitats and fragmentation of the landscape. It increases local pressures on the environment, for both people and wildlife. Impacts on wildlife can range from loss of habitats to depletion of water resources, [9] noise and other disturbance of species populations, and both incidental and deliberate killing of birds arising from bird/aircraft collisions and management measures taken to reduce the risks of bird strikes. [10]

General observations

11. We have set out below our views and supporting evidence in response to the headline questions of the Inquiry.

12. However, we are concerned that, in common with the DfT’s new Aviation Policy Framework and the range of private sector proposals coming forward for new and/or expanded airport development in the South East, [11] the Inquiry is too narrowly focused to address the critical question: is airport development in the South East sustainable?

Detailed comments on the main questions of interest to the Aviation Inquiry

What should be the objectives of Government policy on aviation?

13. The briefing for this Inquiry raises the question ‘Where does aviation fit in the overall transport strategy?’ This presupposes that there is an ‘overall transport strategy’ for the country. But there is not. [12] We have an incomplete suite of public policies and strategies covering different elements of the transport sector, and of different ages. None of these appear to be integrated with each other, nor is there any apparent attempt to integrate these with the other key element of communications.

14. The new ‘Aviation Policy Framework’ is described as "… the Government’s draft sustainable framework for aviation." [13] There is no evidence from the consultation document or accompanying Impact Assessment [14] that the framework has been properly tested to determine its sustainability. The policy framework characterises "Aviation’s environmental impacts [as] both global (climate change) and local (primarily noise, as well as air pollution and congestion)." [15] These are, of course, very important issues; but they amount to an extraordinary and indefensibly narrow consideration of the environmental consequences of any country’s aviation strategy.

15. While we do not underestimate the scale of the task to provide the country with a comprehensive, integrated and up to date transport and communications strategy, we do believe that this is a task that a responsible Government should set itself for the benefit of the population and communities they serve. A fully integrated, long-term transport and communications strategy fit for the 21st century could be properly consulted upon in the normal way and tested for sustainability through the process set out in the EU Strategic Environmental Assessment Directive. [16]

How should we make the best use of existing aviation capacity?

16. Our key concern is that any plans to adjust frameworks and rules of operation (extension of ‘fifth freedoms’ to Gatwick, Stansted or Luton, or changes to periods closed to normal aircraft movements, for example) which could have the effect of altering the scale and pattern of airport use, including surface transport infrastructure and its use, should be subject to early assessment of their likely environmental effects making full use of the established tools and procedures for such assessments.

17. Surface access to airports is of particular interest to us. Poorly planned infrastructure is damaging to wildlife. [17] Proper consideration of the natural environment, using the conventional ‘planning hierarchy’ has the potential to ensure that surface transport infrastructure is integrated with wider environmental objectives, such as landscape scale enhancements, including habitat defragmentation. Combining enhancement opportunities with avoidance strategies, effective mitigation measures and, where absolutely necessary, proper compensation for unavoidable damage, would help to meet the new policy objectives for the natural environment. The challenge of shifting gear from an expectation of ‘no net loss of biodiversity’ to ‘net gain for nature’, as set out in the Natural Environment White Paper and reinforced in the National Planning Policy Framework. These policy considerations must be integrated with aviation policy and strategies for enhanced use of existing airport capacity.

What constraints are there on increasing UK aviation capacity?

Are the Government’s proposals to manage the impact of aviation on the local environment sufficient, particularly in terms of reducing the impact of noise on local residents?

18. In our view the Government’s proposals are not sufficient. They are unreasonably constrained. Our concerns over the local environment extend significantly beyond the impacts of noise on local residents.

19. Paragraph 4.104 of the Draft Aviation Policy Framework states that looking for the least environmentally damaging solution is a policy imperative, and continues that the planned call for evidence (subsequently cancelled) "…will make it clear that environmental sustainability, including protection of habitats, species...is one of the factors which respondents should aim to address." [18] This aim of environmental sustainability should be the keystone of any future policy and supports our view that, rather than the environment being a constraint, sustainable development principles should guide strategic planning of aviation capacity development.

20. However, we are concerned that the development of a national policy statement (NPS) on aviation as set out in paragraph 4.103 of the Policy Framework will follow the conventional practice of excluding costs of environmental damage when assessing the ‘net economic costs and benefits’ of a development. This would result in the costs in terms of loss and damage to natural capital – ecosystem functionality (and services) and biodiversity – being ignored. The National Ecosystems Assessment [19] recognises that the benefits that we derive from the natural world and its constituent ecosystems are critically important to human well-being and economic prosperity. Aviation strategy must ensure that aviation pays for the environmental damage it causes. Currently, the external costs associated with environmental impacts are not internalised in the planning system and decision making processes.

Will the Government’s proposals help reduce carbon emissions and manage the impact of aviation on climate change? How can aviation be made more sustainable?

21. Aviation is the fastest growing source of greenhouse gas (GHG) emissions. Aviation strategy must be consistent with the country’s legal obligations to address climate change. [20] The Government’s own estimates put the total cost of aviation’s climate change impacts at £69.5bn for the period 2000-2060, £20bn more than the cost without expansion. This cost is ignored when aviation’s net economic impact is assessed.

22. The draft Aviation Policy Framework does not extend to a consideration of the full range of GHG emissions associated with the proposed options to expand aviation. Consequently, we believe that no predictions can be made of the implications for changes to carbon emissions.

23. We are aware that there are a number of technological solutions being actively investigated that would have the effect of reducing carbon emissions from aircraft. Some of these appear to be well developed technologies that could be introduced in the relatively near future, including the use of more fuel efficient propfan engines; [21] others are innovative airframe design concepts that seem to be a considerable way from commercial production. [22] There is a wide range of options available for sustainable forms of transport, investment in which would help to reduce carbon emissions by surface access transport. These sorts of measures would clearly help the aviation industry to be more sustainable. However, from the perspective of wildlife and habitats and ecosystem functionality we feel it is essential that a strategic assessment of the implications for the natural environment of a range of aviation scenarios should be undertaken. This must be done properly and as an integral part of the development of ideas, solutions and proposals from other sectoral perspectives.

Do we need a step-change in UK aviation capacity? Why?

What should this step-change be? Should there be a new hub airport? Where?

24. Our focus here is on the proposals for a new London airport in the Thames Estuary. As a general observation, we are not aware of any evidence to demonstrate that aviation and airport development will not result in unsustainable impacts on the natural environment in the South East. In our experience the calls for increased capacity/expansion, including new airports, are not supported by rigorous evidence of their likely costs and impacts.

25. There have been several proposals for hub airports in or around the Thames Estuary in recent years, from both the private and public sector, with most of the recent proposals for coastal developments in North Kent [23] as well as the relatively recent and well-known proposals by the Mayor of London, dating from 2008. The concept goes back several decades, and clearly none of the proposals has been implemented.

26. The environmental arguments against using the Thames Estuary as a location for an airport are stronger than they have ever been. The importance of the area for coastal and marine wildlife is recognised through international, European and national site designations and increasing evidence of the scale and diversity of wildlife the estuary supports. Some of the important assets are the internationally important populations of breeding, migrant and over-wintering birds, marine mammals including small cetaceans (harbour porpoise and bottle-nosed dolphins), grey and common seals and less conspicuous but equally important species like water voles.

27. There is a wider, more complex interaction between the Thames Estuary to the functionality of adjacent marine ecosystems in the English Channel and North Sea. The Environment Agency reports that the estuary plays a major role in maintaining North Sea fish stocks. [24]

28. Landward environmental impacts of a Thames Estuary airport have barely been given any thought by the proponents. At the very least, major new surface transport infrastructure in the area would add to the overall impacts on the environment.

24 October 2012