Transport CommitteeWritten evidence from the Aviation Environment Federation (AS 81)

The Aviation Environment Federation (AEF) is the principal UK NGO concerned exclusively with the environmental impacts of aviation. Supported by individuals and community groups affected by the UK’s airports and airfields or concerned about aviation and climate change, we promote a sustainable future for aviation which fully recognises and takes account of all its environmental and amenity affects. As well as supporting our members with local issues, we have regular input into international, EU and UK policy discussions. Last year we acted as the sole environmental and community representative on the South East Airports Taskforce. At the UN we are the lead representative of the environmental umbrella organisation ICSA which is actively engaged in the current talks aimed at agreeing global climate measures for aviation.

1. What should be the objectives of Government policy on aviation?

Aviation should, like all other sectors of the economy, play its part in meeting society’s collective demands for clean air, a pleasant living and working environment without intrusive noise, and the achievement of emissions goals to limit the risk of dangerous climate change. AEF believes that the Government has an essential role to play in setting the environmental limits within which the aviation industry can compete.

Government policy should, within this environmental framework, seek to maximise the benefits available to the UK as a result of aviation’s role in supporting business connectivity, and in allowing people both to visit friends and family and to go on holiday.

(a) How important is international aviation connectivity to the UK aviation industry?

The question focuses oddly on the aviation industry as a beneficiary of aviation connectivity. Government policy should instead look at the extent to which aviation can help support connectivity in the economy as a whole.

The debate on airport capacity often fails to consider what “connectivity” actually means. While in the current debate, lobbyists take a very narrow, often misleading, definition, implying that it is only related to direct flights between two destinations, in its broadest context, it is about how well-connected the UK is to other parts of the world, and the ease with which businesses can access foreign markets and vice versa. Connectivity can take many forms, including other transport modes such as rail, or transport replacement such as videoconferencing, in addition to air travel. For example, Eurostar and the Channel Tunnel connect the UK to many western European cities. The connectivity debate extends well beyond considerations about hub airports.

AEF has attempted to unpack some of the issues in relation to aviation, connectivity and hub airports in a 2-page briefing, which is attached to this submission.

(b) What are the benefits of aviation to the UK economy?

It is unfortunate that this consultation asks specifically about economic benefits, with no account taken of the fact that the sector may generate economic disbenefits.

Much of the evidence on aviation’s economic impacts has been either written or funded by the aviation industry, so there is an inevitable tendency to select data such as to increase the industry’s apparent benefit. A literature review by academic economists in 2009 identified a series of inconsistencies and gaps in such studies, critiquing work by OEF, ACI, BAA and others.1

While it is undoubtedly the case that aviation has a role to play in the UK’s economy (as does provision of electricity or of water, for example), it does not follow that increasing numbers of passengers, aircraft or runways will yield increasing economic benefit. The Committee should not assume that new airport infrastructure automatically yields economic advantage. And when all aviation’s impacts are accounted for, expansion may actually represent a cost to the UK. NEF’s 2010 report, Grounded: a new approach to evaluating Runway 3,2 predicted, for example, a £5 billion loss to the UK economy from expanding Heathrow, in contrast to the then government’s £5 billion predicted benefit.

(c) What is the impact of Air Passenger Duty on the aviation industry?

We are aware that, despite continuing to benefit from exemptions from fuel tax or VAT, the aviation industry has recently been lobbying hard against Air Passenger Duty, the only significant tax on UK aviation apart from universal company and payroll taxes. This inquiry concerns the Government’s aviation strategy, and we hope that any consideration of Air Passenger Duty and its impacts by the Government will look more widely at its impacts on society than a question focused only on impacts on the aviation industry.

The great majority of flying is by higher earners, with much of the increase in air travel in the UK over recent decades resulting from increasingly frequent flying by a small and wealthy proportion of the UK population.3 The tax advantages currently enjoyed by aviation therefore benefit mainly higher earners. Low aviation tax is regressive.

Research suggests that APD at its current level is unlikely to impact people’s holiday choices as it is such a small proportion of the cost of a holiday itself. It came as no surprise, therefore, that Sir Brian Donohue, chair of the All Party Parliamentary Group on Aviation, which earlier this year published an attempt to attack Air Passenger Duty, admitted during an oral evidence session “I’ve not had a single person tell me they are not going on holiday because of APD.”4

(d) How should improving the passenger experience be reflected in the Government’s aviation strategy?

AEF took part in the South East Airports Taskforce, set up explicitly to address possible improvements to the passenger experience at London’s airports, and we endorse the recommendations of that report, noting that any long-term agreement to grant operational flexibilities must state clearly the limited circumstances in which they can be deployed, and must be based upon the community’s reaction to noise issues associated with the trials. Many of the recommendations of the task force could have wider applicability elsewhere in the UK.

(e) Where does aviation fit in the overall transport strategy?

We understand that the Department for Transport will publish a transport strategy by the end of this year (that will not be subject to consultation), under which the Aviation Policy Framework is to sit.

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

We have not provided detailed comments on this section. We would like to make two comments however:

(i)“Best use” of existing capacity may not mean “maximum use”; in particular, segregated mode operations at Heathrow and the night noise protections at the London airports provide a combination of predictability and respite that are hugely valued by local communities.

(ii)While some recent industry research indicates a link between direct air links and the volume of trade between two cities, it has been unable to show the direction of causality in this relationship. Expanding capacity or encouraging more flying at any given airport cannot by itself generate economic activity in the surrounding region.

3. What constraints are there on increasing UK aviation capacity?

AEF believes that increases in aviation capacity should be considered only within a framework of appropriate environmental limits, as indicated below.

(a) 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?

No. While the Draft Aviation Policy Framework considers noise problems in some detail, it proposes few policy solutions to these problems. In particular:

(i)Although a growing body of evidence, including the Government’s own study into Attitudes to Noise from Aircraft Sources in England in 2007, indicates that noise annoyance occurs at a lower level than was the case in the past, the Government persists without justification in referring to 57 Leq as marking the onset of significant annoyance.

(ii)While the Framework acknowledges that Leq is not sufficient as a means of expressing how people are impacted by noise, not least as it obscures actual numbers of noisy aircraft, no programme is set out for resolving this problem by developing or advising on complementary noise metrics.

(iii)Similarly, while the Framework acknowledges that noise can have significant health impacts, including stress and heart attacks, it sets out no timetable for achieving the World Health Organisation’s recommended noise limits.

(iv)No commitments are made as to how and where noise should be reduced from current levels and there is no clarity over what noise “tests” should be applied to proposals for new airport capacity. The concept of “noise envelopes” is introduced, but is characterised as being applicable only in cases where significant expansion has already been approved.

(v)No environmental criteria are set out for the basis on which airports are designated—or not—for noise control by the Government. Currently the Government imposes noise limits on Heathrow, Gatwick and Stansted, but other airports may experience noise problems that are equally bad if not worse in some cases. There is a particular problem with night noise at East Midlands Airport, for example; and evidence from Belfast City Airport Watch suggests that far larger populations are exposed to noise above 57 Leq as a result of Belfast City’s operation than at either Gatwick or Stansted, but without comparable Government protections.

(vi)The alternative to Government regulation, namely local resolution, is inadequate in a large number of cases. Either airports are being expected to police their own impacts, including, potentially, voluntarily imposing restrictions on their own operations, or local planning authorities, with very little government guidance, are expected to develop an unreasonable level of expertise in understanding noise impacts when considering planning applications at airports.

(b) 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?

Despite the scoping consultation singling out the lack of weight given to climate change in the Air Transport White Paper as a reason why it was no longer fit for purpose, the Framework sets out no new proposals in relation to aviation’s climate change impact. Under the last Government, agreement was reached to “take account of” aviation emissions in the UK’s world-leading 2008 Climate Act and to formally include them by 2012, unless the Government of the day could explain to Parliament why this was not possible. In addition, a climate cap was introduced for aviation, namely that gross aviation emissions in 2050 (aside from any purchase of credits under the EU ETS) should be no higher than in 2005.

The current Government, however, notwithstanding its clear and commendable stance on expansion at Heathrow, has not committed to maintaining the aviation emissions cap and has yet to come to a decision over whether or not aviation will be included in the UK’s carbon targets. The Framework commits only to ongoing support for EU and international measures, both of which are under significant pressure.

AEF supports aviation’s inclusion in the EU Emissions Trading System as one step towards bringing the sector into line with wider strategy on climate change. We very actively support efforts to agree on global measures for aviation emissions, and we are participating in the current series of talks with this aim at ICAO. Nevertheless, we consider that European and international policy should be supported with appropriately ambitious domestic action, and believe that the UK’s credibility in these fora would be significantly bolstered if we could confidently show that we were walking the talk.

The Climate Act was designed to deliver an economy-wide reduction in emissions of 80% of 1990 levels by 2050, in order for the UK to play its fair part in limiting the risk of global warming exceeding 2 degrees to no more than 50%. For this climate objective to be achieved, total UK emissions in 2050 should be no higher than 160 million tonnes of CO2, according to the Committee on Climate Change. If aviation and shipping were to be excluded from this figure, however, and the 80% cut applied only to other sectors of the economy, our national emissions would be likely to hit 200 million tonnes of CO2, and would thus fail to deliver the original climate objective that convinced Parliament to draw up the Act.

AEF considers it essential that aviation continues to be accounted for in the 2050 target, as required by the Climate Act, and believes that there is no good reason for not formally accounting for the sector’s emissions in forthcoming carbon budgets, as recommended by the Committee on Climate Change.

(c) What is the relationship between the Government’s strategy and EU aviation policies?

See section b) above.

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

No. The concept that the UK is currently facing an airports capacity crisis is a myth.

(i)The official forecasts, last updated in August 2011, indicate that even if all demand was to be catered for there would be no shortfall, even in the South East, until nearly 2030. These forecasts have gone down each time they have been updated since 2003 and it is very likely that the latest figures will again be revised downwards as the predicted economic recovery has not materialised. AEF has produced a detailed analysis indicating a number of reasons why we consider the current forecasts up to 2030 will probably prove too high.5

(ii)In fact, however, “predict and provide” was abandoned by Government many years ago as an inappropriate approach to planning airport capacity, given the need for environmental protections. In April this year the Committee on Climate Change advised the Government to plan on the assumption that gross emissions from aviation in 2050 will be no higher than they were in 2005. The advice indicates the ongoing relevance of their 2009 study which concluded that for UK emissions to be no higher in 2050 than in 2005, passenger numbers could grow by not more than 60%. AEF has conducted analysis for WWF-UK that concludes that sufficient airport capacity already exists in the UK to accommodate all this permitted growth without building a single new runway.6

(iii)In addition to the climate impacts, the noise impacts of airport expansion anywhere in the UK will be significant, and will inevitably play an important part in framing the debate about new capacity. The recent study by MIT and Cambridge University on air pollution arising from airport operations highlights the significant number of annual deaths likely to occur even from an airport built in the Thames Estuary, much further away from densely populated areas than existing South East airports.

Rushing to approve new airport capacity in this context would be worse than foolhardy.

19 October 2012

1 D Gillingwater et al, January 2009, Omega study 40— Economic benefits of aviation technical report, Loughborough University,


3 See for example Civil Aviation Authority, January 2008, Recent trends in growth of UK air passenger demand, page 55

4 Travel Weekly, 17 May 2012 “‘Give us solid data’ on APD and Heathrow, MPs tell industry”

5 See

6 See

Prepared 31st May 2013