Written evidence from the Aviation Environment Federation (ASM0030)
 

Executive Summary

• Airspace ‘modernisation’ is primarily about facilitating aviation growth. While this clearly benefits the aviation industry, many of its impacts in terms of local communities and the environment are negative. At its simplest level, more flights will mean more emissions and more noise – outstripping any marginal gains per flight – and the Government has yet to set out credible policies on how to tackle either problem.
• The use of Performance Based Navigation can allow the creation of either one or several accurate, predictable flightpaths in place of the historic swathe within which there was a degree of natural dispersal. Such a change may be welcomed by some households, if they are relieved of noise as a result. But it can create noisy motorways in the sky for those who are underneath them, sometimes for the first time. The Government’s recent consultation demonstrates a less prescriptive approach to noise management, allowing flexibility and encouraging more community engagement, but it doesn’t address community expectations that noise levels overall will be reduced.
• The level of anticipated demand growth underpinning the economic rationale for fundamental airspace change is very much higher than the maximum level compatible with Climate Change legislation. The Government should present its economic rationale for change on the assumption that the more moderate traffic growth rate that would be consistent with the recommendations of the Government’s expert climate advisers.
• The Government’s proposed Independent Commission on Civil Aviation Noise may go some way towards addressing the trust deficit that exists in many cases between communities and their local airports in relation to the airspace change process. But without either a formal role to advise Government on the adequacy of its noise policies or the powers to enforce its own rules and limits, the commission may prove a disappointment to many local communities seeking fundamental change in how their interests are represented.

1. The Aviation Environment Federation (AEF) is the principal UK NGO concerned exclusively with the environmental impacts of aviation. Our membership includes community organisations impacted by airports, airfields and flightpaths. As well as supporting our members with local issues, we have regular input into international, EU and UK policy discussions. In recent years we have contributed evidence both in writing and in person to the Airports Commission, the Civil Aviation Bill Committee, the London Assembly Transport Committee, the Environmental Audit Committee and the Transport Committee. At the UN we are a leading representative of the environmental umbrella organisation ICSA (the International Coalition for Sustainable Aviation). We welcome the opportunity to provide evidence for this inquiry.

The role of Government in facilitating improvements to the airspace

2. The role of Government in relation to airspace change should be to set the appropriate framework for aviation, taking into account the national interest with respect to both economic and environmental impacts. This should include protecting the public from noise impacts that give rise to significant effects on health and wellbeing. While the aviation industry will seek to protect its own interests and the CAA is now formally charged with protecting aviation consumers, no public body has a formal role to protect the public from aviation noise, despite research by Defra showing that 1 in 3 people in the UK are affected[1], and a growing body of evidence on the health effects of exposure to aircraft noise[2].

3. We are concerned that the primary reason for delivering ‘modernisation’ of airspace is to deliver growth, and that balanced decisions reflecting economic and environmental objectives cannot be achieved while there remains an assumption that the Government must ensure that aviation demand growth is be catered for.

4. In relation to noise impacts, the Government is currently proposing a number of changes to support new approaches to the distribution of noise. We welcome the fact that under the current proposals from Government and the CAA, more information on noise impacts will in future be made available to assess options, together with more systematic community engagement, following strong reaction from local communities to some of the changes and trials in recent years. The Government has not, however, set out a noise reduction strategy and has yet to define at what level aircraft noise becomes unacceptable. The World Health Organisation (WHO) is expected to release its revised community noise guidelines on environmental noise later this year and the UK’s airspace policy should anticipate and be able to reflect recommended noise exposure targets.

5. In relation to climate change, while airspace improvements may in some cases help to reduce CO2 emissions per flight, these savings are marginal and will be dwarfed by the additional emissions associated with growth of air traffic. The Committee on Climate Change (CCC) has advised that in order to ensure that CO2 emissions from UK aviation remain at a level compatible with the UK Climate Change Act, the Government should develop policy on the basis of a “planning assumption” that there will be no more than a 55% increase in air transport movements between 1990 and 2050. This reflects prudent assumptions, CCC advises, on likely improvements in fleet fuel efficiency and biofuels penetration. The CCC has never specified how to ensure that growth does not exceed this level but it is likely to require a combination of measures to manage passenger demand (such as ensuring that ticket prices reflect environmental costs) and to constrain the supply of aviation capacity.

6. The latest forecasts from the Department for Transport anticipate a significant overshoot of the maximum level of demand growth compatible with climate legislation. While, CCC recommends no more than 3.4 million ATMs per year by 2050, DfT anticipates 2.7 million ATMs by 2030 and 3.8 million by 2050. The forecasts from NATS recently published as part of the strategic rationale for airspace ‘modernisation’ are higher still. While no figure is provided for 2050, NATS anticipates as many as 3.25 million ATMs by 2030, even before allowing for additional flights from a third runway at Heathrow.

7. The Government should not be basing its plans for the provision of airspace capacity on traffic growth forecasts that exceed the level that its own expert advisers consider to be consistent with legal environmental objectives. It is impossible to know whether the strategic rationale for airspace change would stand up under the much more moderate levels of demand growth that the CCC has recommended, as this scenario has not been modelled in the DfT airspace strategy.

8. In the context of airspace management, the Government should set out clearly what its environmental objectives are, for climate change as well as noise, and should indicate what this is likely to mean for the CAA (as part of its guidance to the regulator) and the aviation industry. This will be fundamental.

9. Additionally, the Government will have a more specific role in airspace decisions if the current proposals for a call-in power are taken forward. Communities may welcome the additional scrutiny that a call-in could provide but remain concerned by the absence of any appeal process to the Secretary of State given the CAA’s decision not to pursue any appeal options as part of its revision of the airspace change process.

The need for modernisation, in terms of the economic and environmental sustainability benefits, and the risks for the aviation industry and wider economy from maintaining the current airspace structures

10. The primary justification for airspace ‘modernisation’ appears to relate to likely delays to flights as a result of airspace congestion. As noted above, in order to consider the economic justification for change the Government must analyse the scale of the benefits in a scenario where the UK meets its obligations under the Climate Change Act, which will mean a more moderate level of demand growth than that currently assumed in NATS and DfT forecasts. It is sometimes argued that maintaining current airspace arrangements will compromise both aviation safety and the quality of passenger experience, but this is only true, of course, in the context of assumed traffic growth.

11. In terms of sustainability impacts, as noted above, in the absence of policy to limit overall emissions, any savings in CO2 emissions per flight as a result of more direct routing will be easily outweighed by a growth in air traffic. Noise impacts are rightly understood to be complex meanwhile, but we iterate that the Government’s airspace consultation include few measures to reduce noise, focusing instead on where aircraft fly and how to engage and build trust with communities.

12. Flying aircraft along more predictable and accurate routes has the potential to allow communities to make more informed choices about where to live and to feel confident about what kind of noise they can expect. In some cases it could facilitate the provision of respite. However, numerous noise problems are likely to remain or be created, as considered below. Where trade-offs are to be made between environmental impacts, notably noise and CO2, it is also important to provide clear evidence about the scale of the net benefit. In particular, we are concerned that very marginal efficiency improvements could be used to justify widespread noise disturbance.

The essential changes that need to be made to UK airspace, particularly those associated with the development of an additional runway in the South East

13. AEF has argued that a conversation about airspace principles and policy should not be conflated with consideration of a new South East runway and in February 2016 we coordinated a letter from over twenty community groups to the Prime Minister calling for the consultation on airspace change policy to be brought forward[3]. In fact, this consultation has only just been published. The fact that MPs are to be asked to vote on the NPS supporting Heathrow expansion without knowing what airspace changes would be necessary to allow for its operation, or the environmental objectives that would inform such change, is unacceptable in our view as it means that the noise impacts are impossible to assess accurately.

Progress of the Civil Aviation Authority’s Future Airspace Strategy in achieving its core objectives of reducing congestion, improving safety and taking advantage of new technologies to enable a more efficient airspace system

14. We are unable to comment on progress to date. While AEF was consulted on, and participated in, the external peer review of FAS when it was developed, we have not been invited by the CAA to participate in the implementation of FAS. The CAA’s recently established Communities Discussion Forum, on which AEF has a seat, will give an opportunity going forward for communities to provide feedback. 

The barriers to modernisation of airspace, including the environmental and community considerations arising from changes to the current arrangements for managing UK airspace

15. Recent proposals to modify airspace have led to widespread public dissatisfaction about the process and the revised routings, leading to some applications being withdrawn and trials being abandoned. The Government cannot ignore the strength of public feelings that many describe as analogous to building roads over their heads and homes, with little opportunity to engage. In order to address the current trust deficit, both the Government and the CAA will need to address a number of concerns expressed by our members about recent and planned changes to UK airspace.

16. An increase in the use of precision-based technology has created a degree of concentration in flight paths that has, for some, created what feels like an intolerable noise environment. Members have described to us what feels like a wall of noise having been created, or a motorway in the sky above them. They have no rights, in this situation, to compensation, and the DfT’s current proposals to change its compensation policy are likely to apply in only a small number of cases given the high qualifying threshold.

17. In some cases, this increase in concentration has been accompanied by other changes in the pattern of aircraft use. If concentration and intensification come together with an increase in the proportion of larger aircraft that tend to fly lower, for example, noise can become very much worse even for communities that have always been overflown to some extent. While the CAA has decision-making authority in terms of where aircraft fly, it exerts no control over the environmental impacts of how flightpaths are used. A shift in the pattern of demand in relation to destinations can mean that the number or type of aircraft using these routes changes without consultation, and at the extreme there is potential for routes that have always existed but scarcely been used to be ‘switched on’. This issue of intensification is recognized by the Government in its proposed ‘tier 3’ classification, but it proposes only better engagement rather than a process to control the impacts.

18. There is a strong impression among our membership that more aircraft are flying lower than in the past. This could be for a number of reasons including incremental change of the kind described above. But it is also related to changes in controlled airspace that have implications for general aviation and business aviation traffic. For example, at Farnborough, there is a concern that proposed increases in the volume of controlled airspace will mean that business jets are flying at lower altitudes than in the past, while neighbouring general aviation operations are concentrated or displaced in order to make space.

19. As noted above, the primary motivation for changes to the structure of airspace relates to facilitating aviation traffic growth. Such growth is likely to result in increased noise disturbance, with small reductions in the noise footprint of individual aircraft outweighed by an increase in the numbers of overflights. The Study of Noise Attitudes published by the Government alongside its consultations on airspace change and on the National Policy Statement meanwhile confirmed what our members have been telling us for many years – that people are significantly annoyed by aircraft noise at lower average levels than in the past.

20. Meanwhile, many of our members feel that there is a lack of consideration given to areas where background noise levels are low or where populations are less densely concentrated, including areas designated for the protection of their character, in particular their relative tranquility. 

21. Finally, a perceived lack of transparency and honesty from both airports and the CAA has been cited as a key concern. Comments on this are provided below.

The effectiveness and adequacy of engagement with affected communities when planning and introducing airspace changes and the lessons to be learnt from recent trials, particularly at Heathrow and Gatwick

22. The approach to engagement and consultation with local communities in the context of airspace change has been recognised by both the Government and the CAA as in need of fundamental reform.

23. In 2015, the CAA commissioned the consultancy Helios to advise on whether its airspace change process was fit for purpose. Helios found that the process was viewed with great suspicion among some communities, with change ‘sponsors’ considered to be acting as both judge and jury in relation to public consultation and the CAA seen to be conflicted. To help manage this, Helios recommended the CAA (i) taking a much more hands-on approach in its handling of the change process and ensuring that consultation by change sponsors meets appropriate standards and (ii) operating in a much more transparent fashion than in the past, with all documents assumed to be public except where sensitive information needs to be redacted.

24. Issues identified by our members in relation to engagement include the following:

• Some airspace change trials have taken place over recent years without any effective communication taking place in advance with local communities. In the case of Gatwick, for example, when members of the public contacted the airport for information about what was happening, the information provided was often confused, partly because a number of different changes were being made or trialled simultaneously.
• The reason for specific changes taking place is sometimes unclear and in some cases communities feel that sponsors are deliberately misleading the public about their intentions, particularly in relation to future increases in traffic. A sponsor may claim, for example, that it is pursuing a given change in order to improve fuel efficiency despite the fact that on a map the route appears longer.
• Many of our members feel that their participation in consultations or similar engagement exercises has had little if any impact on the final decision and has been regarded as a ‘tick box’ exercise.

25. Both the CAA and the DfT are in the process of making changes to the requirements and expectations of the aviation industry in relation to local engagement on airspace change issues.  We hope that these changes will prove beneficial but it remains to be seen how effective they will be. 

The merits of an Independent Aviation Noise Authority and desirability of classifying airspace within the National Infrastructure Commission’s remit

26. An independent aviation noise authority could have a valuable role to play in tackling aviation noise impacts given the lack of trust in many cases between local communities and both their local airport and the CAA. However, the Government’s current proposal is not for an authority but for a ‘commission’ (ICCAN) without enforcement powers or decision-making capability. For many communities this appears a downgrading compared even with the proposal by the Airports Commission on the creation of a noise body.

27. ICCAN’s proposed functions will include the provision of advice on the best noise management techniques and on the accessibility of noise information; verification of noise forecasts and noise data; and provision of best practice guidance. Much of this advice is aimed at informing industry and local authorities and supplementing the CAA’s own knowledge on some of these issues. The body is expected to play a role in the oversight of process in relation to airspace change, providing ‘assurance’ of the information provided by sponsors, although it is unclear at present how this role will differ from that of the CAA in the airspace change process.

28. As we argued in our comments on the role of Government, airspace policy should include an aviation noise reduction strategy – a commitment, for example, to work towards the recommendations of the World Health Organisation on environmental noise, or, in the context of airspace change, criteria for the CAA to use to judge when the noise impact of a given change is too great to allow it to proceed.

29. The ICCAN should, if is to be created, have a specific mandate to monitor the latest evidence on impacts, metrics and mitigation and advise the Government on whether its policies are fit for purpose. Similarly, the ICCAN should be able to advise on whether the processes it has to oversee adequately tackle the aviation noise problem. If the ICCAN is unable to advise Government on what noise policies and decisions are necessary in order to tackle aviation noise it is hard to see how it can have much standing or respect in the eyes of the public.

The UK’s relationship with the European Union in terms of airspace management and any potential issues arising from Brexit

30. Any attempt to improve the UK’s competitiveness following Brexit should not compromise or dilute existing environmental commitments or the need to plan for effective mitigation to protect communities.

31 March 2017