Written evidence submitted by PCS (NPS0040)

PCS Submission to Airports National Policy Statement Inquiry – March 2017

1. Introduction

1.1.       PCS trade union has around 180,000 members working in the UK civil service, public sector and on privatised, commercial contracts. Our members work across a broad range of roles including direct delivery of public services to policy development and drafting legislation.

1.2.       We have around 1,540 members in the aviation sector covering Air Traffic Management (ATM), Civil Aviation Authority (CAA), Heathrow Airport Ltd (HAL) and Gatwick Airport Ltd (GAL), as well as staff at other regional and international airports. Our members’ jobs include administrative roles to airport security and management, air traffic assistants, as well as working in border security and customs at Gatwick and Heathrow.

1.3.       Whilst predominately in the private sector, we believe our members provide a crucial public service where security, safety and sustainability are the highest priority.

1.4.       Since 2008, PCS national policy has been to oppose a third runway at Heathrow on environmental grounds. Aviation is one of the most energy and carbon intensive forms of transport. Expansion is incompatible with the UK’s carbon reduction targets as set out in the Climate Act 2008, and its commitments under the Paris climate agreement to limit global temperature rise to “well below” 2 degrees Celsius.

1.5.       As is well documented, pollution at Heathrow is already running at dangerous levels, affecting the health of workers and surrounding communities. We therefore believe that the UK government should be developing an alternative transport policy that looks at reducing demand for air travel, better use of aviation capacity at other London and regional airports, providing a well-resourced and affordable rail network, and charging points for electric vehicles.

1.6.       The jobs claims that a third runway is stated to provide are also highly questionable. As our response, and independent research conducted by the union show, there is little evidence to substantiate these claims.  Equally, given current moves to de-skill workers at Heathrow and hire new entrants on lesser pay gives rise to real concerns about the quality of any new jobs that may be created.

1.7.       Our response to this consultation is therefore framed within these core concerns.

2. How well the proposal reflects government policy on airports and aviation more generally

2.1.       The proposal does reflect the government’s policy, which is predicated on three basic assumptions:

- Airport expansion is essential to remaining competitive with ‘rival’ European hub airports (Amsterdam, Paris, Frankfurt) 

- Jobs and the economy will benefit from an expanding aviation industry 

- Environmental targets will be met.

2.2.       PCS would challenge these assumptions and propose that greater long term benefit and sustainability could be achieved by pursuing alternative courses of action.  This position is driven by our national policy of opposition to the third runway at Heathrow on environmental grounds, backed up by a commitment to protecting the jobs, and terms of conditions, of our members at the major UK airports.

2.3.       PCS has commissioned two studies to look in more depth at issues facing our members in the sector and specifically the jobs claims related to a third runway: “PCS Aviation Review – Protecing jobs/ Projecting the planet” by Caroline Molloy and Roger Sealey; “Heathrow Jobs: Final Report” by Professors Roger Seifert and Steve French.

2.4.       We have collated these along with an article on “Aviation and Climate change – the continuing challenge” by Alice Bows-Larkin et al into a single document – Heathrow: Climate and Trade Unions.[1] These all challenge the assertions on the need for further airport capacity and jobs, and provide the evidence to back up our position.  

2.5.       In terms of the amount of flying, we are acutely aware that 70% of flights are taken by 15% of the population[2], thereby raising a question as to who would be doing the additional flying, and how much further flying do they really need to do.  Demand for flying does not imply an absence of concern for the environment: “a lack of alternatives and the habitual nature of flying lead people away from sustainable choices” (Bows-Larkin, p. 8).

2.6.       We believe that much more stringent efforts need to be made to promote alternative modes of transport to replace domestic and short-haul European flying, e.g. high speed rail, as well as further development and use of videoconferencing and other communications technology, and that progressing these options would be a source of jobs and economic stimulus.  

2.7.       To the extent that there might be a case for additional flying in the short term, we believe that better use of existing capacity at other London airports, and at regional airports across the country, could accommodate the requirement without building any new runways.  That would require abandoning the inefficiency of airports in competition with eachother in favour of a planned approach to the UKs airport infrastructure. 

2.8.       In terms of the economic benefits, the PCS position is not disputing that, with the current economic and political orientation, there would be an economic benefit to the UK from runway expansion.  Rather we believe that the environmental price for those economic benefits is too high, and that it is imperative that the government look to alternative means of stimulating economic recovery. The climate change impact of an additional 260,000 flights per year is more than we can afford, and would ultimately be hugely expensive, so a clear alternative strategy based on renewable energy, green transport jobs and other initiatives that would have significant benefits for local infrastructure, commuters, and quality of life, needs to be developed as a matter of urgency.

2.9.  In terms of jobs, our members at Heathrow and Gatwick have been led to believe that runway expansion offers protection in terms of job security.  PCS supports their efforts to ensure that job numbers, and terms and conditions, are not eroded, but we also recognise that our members have been offered no alternative to runway expansion and that the government therefore confronts them with the choice only between having a job or not.  Our members are also extremely concerned about environmental consequences, but are forced to adopt a pro-runway position by the absence of any alternative.

2.10.   The early signs are that aviation workers job opportunities, even with the proposed third runway at Heathrow, are likely to be limited in number and reduced in quality.  Cost efficiencies are needed by the employer, who is already acknowledging that new contracts on lesser terms are integral to meeting the cost of the operation and that they will seek to implement these further.  “Given the decrease in jobs per flight over the last decade it is clear that industry growth / protection does not equal jobs growth / protection. Indeed industry expansion has arguably led merely to intensification of work.” (Aviation Review, p. 34)

3. The suitability of the Government’s evidence and rationale in support of a north-west runway at Heathrow

3.1      In common with many other organisations[3], PCS finds the case made by the government and the airport for the new runway to be based on aspiration, speculation and exaggeration.  Very little in the way of tangible evidence is cited, the argument being based largely on ‘assurances’ that do not stand up to scrutiny.

3.2      As stated above, the economic case is vague and unconvincing, who is doing this travelling, what alternatives are there.  Is the primary purpose simply to, as per the Channel Four Dispatches[4] programme findings, force as many people through the airport terminals – and the associated retail outlets - as possible, since that is where the ‘real’ money is.

3.3      PCS’s own research into the job claims concludes that “The case for runway expansion is entirely a business one…there is no explicit job model and no clear job creation analysis.  Jobs are seen as an automatic by-product of commercial expansion” (Seifert, p. 2). 

3.4      In terms of the airport’s case, many of the claims are spurious and over-optimistic: enhanced connectivity is linked to unspecified job creation, a 25-year time frame is used but unclear what that means, more far-flung jobs (in Scotland, Wales, Northern Ireland) are not analysed and based on tenuous assumptions, while jobs in the local boroughs are outside of Heathrow’s control and are entirely dependent on decisions made by other organisations (Seifert, p. 4-5).

3.5      In terms of the Airport Commission’s claims, there is little analysis of job creation as such, and it is taken as a function of an increase in passenger numbers.

3.6      Even in accepting the basic point that expansion will create some jobs, both directly at the airport, and indirectly elsewhere, our concerns are:

i)                    Low pay and low quality

ii)                   Potential job loss elsewhere in the economy

iii)                 Lost opportunity of investing in other projects

“While it cannot be disputed that expansion would lead to an increase in jobs, the evidence suggests that previous claims have significantly over-estimated job growth” (Seifert, p. 6).

3.7      In terms of the jobs of our members, there is likely to be a positive impact but our analysis suggests that the numbers are likely to be marginal.  And, as highlighted in 2.10, there remain concerns as the employer is already looking at lower level entry salaries that are significantly below average earnings in the five adjacent local authorities.

3.8      Loss of jobs at other airports, even closure of those airports as a consequence of Heathrow expansion, is not legislated for in the claims.  “The Government’s policy of breaking up the airport operators, significantly hinders the likelihood of the airport operators working co-operatively together to manage capacity” (Aviation Review, p. 8).

3.9      The imminence of Brexit, and the uncertainty that brings to our relationship with the rest of the world, adds to the complexity of the economic picture.

3.10  Our overall position is that the government should be looking at alternative ways of re-stimulating the economy and providing long term, secure jobs, via the challenge to combat climate change:  “We need to make a new, greener infrastructure (from wind turbines to bus and rail networks) to protect all our quality of life in the long run.  We are calling for government, company and investments policies that create a ‘million climate jobs’ as part of a ‘just transition’ that manages the transition towards a more sustainable use of resources, quickly enough to protect the environment, but also in a way that delivers sustainable, quality jobs” (Aviation Review, p. 33).

4. How well the proposal takes account of other aspects of the Government's transport strategy

4.1.  Current transport ‘strategy’ is characterised by its disjointedness, as a result of privileging the free market above public service provision. The concept of joined-up thinking about the transport system runs counter to this tendency.  “The fragmented and largely privatised nature of wider public transport provision hinders moves towards an integrated transport policy that could encourage shifts towards more sustainable transport and the protection of high quality jobs within the sector.” (Aviation Review, p. 8)

5. How comprehensive the proposal is in terms of the supporting measures for affected communities

5.1.  Local communities will be decimated and demolished, schools will be affected. Compensation is not the answer for residents who have lived in the affected areas for generations. 

6. How well the proposal takes account of sustainability and environmental considerations and the adequacy of relevant documentation and information published alongside the draft proposal

6.1.  Assurances around carbon emissions have been inadequate, with little or no evidence to back them up, only highly questionable aspirations based on unfounded assumptions.  The government has opted not to take the advice of the Committee for Climate Change[5] on the limits that should be adhered to and the level of passenger demand which is compatible with those limits, preferring its own targets.

6.2.  Aviation emissions are likely to make up an increasingly large proportion of UK emissions – up to 15–20% by 2050 if current trends continue unchecked, according to the Aviation Review (p. 13) or even 30-40% according to Bows-Larkin et al (p. 15). The assertion is that Heathrow can be delivered within emissions limits but without defining what these limits are.

6.3.  A number of different areas of potential climate mitigation need to be considered carefully:

a)      Operational improvements, namely air traffic management to reduce track mileage per flight and to avoid stack holding.  Some work has taken place on reducing route lengths, but, arguably, these issues could also be mitigated by the third runway to some extent. However that then requires enhanced airspace capacity to ‘feed’ the runway, which in turn drives further increase, leading to a situation of the UK seeking to accommodate more than a quarter of a million additional flights annually.

b)      Technical developments, specifically new, generally larger, aircraft, improved fuel efficiency of new aircraft, and less polluting fuel types.  These will not outweigh the impact of 260k additional flights but we have to ‘bank’ what we have and should therefore be pursuing these avenues of development as a matter of course.  What is clear is that none of these developments will be fully realised by the free market, and needs concerted international co-operation, regulation, and public ownership.

c)      In addition, there are concerns around the environmental impact of biofuels, while in terms of the aircraft, the long life of an air frame means that it is not economically viable for airlines to introduce a replacement fleet within a timeframe compatible with climate change targets.

6.4.  Carbon trading and offsetting: “Any assumption that sufficient [industrial] sectors will be in a position to make much greater cuts than aviation misunderstands the scale of the mitigation challenge… pinning hope on [carbon] trading to deliver on mitigation objectives is arguably misplaced (Bows-Larkin, pp. 15-17).  

6.5.  We agree with the Environmental Audit Committee's assessment that “additional emissions reduction requirements on other sectors of the economy and the resulting costs to those sectors…should be tested with industry and subjected to independent scrutiny by the Committee on Climate Change.”[6]

6.6.  As a consequence, even if all of the above changes are enacted in a positive manner, it would not be sufficient for aviation to play its part in meeting climate targets, and agree with the conclusion that “There is a clear role in aviation for demand management…either the sector acts urgently on climate change and curtails rising demand, or it will be failing to take responsibility for a considerable and growing portion of climate change impacts" (Bows-Larkin, p. 16).

6.7.  The air quality case cannot be made as air quality is already poor and will become worse.  Comparison with central London does not work, as air quality budgets for the year are now routinely broken in early January. PCS agrees that the Government needs to set out new modelling on air quality following the High Court’s latest ruling[7] and a new approach to air quality post 2019.

6.8.  Noise impacts on a significant portion of the population.  Because of prevailing winds, about three-quarters of flights into Heathrow fly over heavily populated parts of London. Under the third runway scheme, which extends Heathrow to the north, the number of people affected by new traffic increases, because its east-to-west final approach will go over places that have hitherto been relatively plane-free (Aviation Review, p. 31).

6.9.  Four councils are suing and there is huge local opposition.  PCS supports the call for effective noise mitigation measures enforced by an Independent Aviation Noise Authority.

7. How well the proposal address changes to surface access 

7.1.  Surface access is widely considered the main contributor to airport related pollution. Road traffic assurances – the “no more cars on the road” pledge – has yet to be demonstrated, and appears counter-intuitive given the road-widening plans to increase surface access by road. Additionally, the Highways England assessment[8] notes that “substantial variance between the Commission’s figures and our estimates of operation and maintenance costs for interdependencies that each represents significant risk to the timeline (and as such cost).” (p.6). The Government must produce a fair assessment of the costs of expected transport improvements needed.

8. Conclusion

8.1.  In summary, PCS believes that the national Policy Statement falls down in a number of areas in terms of its own evidence base. Essentially however it is driving through a policy of additional aviation at all costs without considering alternative transport policy measures that would be job creators and remain compatible with the global ambition to decarbonise our economies in line with the Paris climate agreement.

24 March 2017