AirportWatch’s initial comments on the Government’s Aviation document

This is an initial comment, after a quick reading of the government’s aviation policy consultation document.  John Stewart comments that the consultation is still a document which envisages a lot of growth in air travel.  Whether that level of growth is compatible with climate change and noise concerns is highly debatable. But the consultation document is more honest than we have seen from previous governments.  It recognises that there is a tourism deficit, due to air travel, and that the UK is already about the best connected country in the world, contrary to the aviation industry’s spin.  It also recognises that landing slots need   to be sorted out, as they are a major hindrance to efficient use of airport capacity. However, the document is weak on climate.

AirportWatch’s initial comments on the Government’s Aviation document


(Comment from John Stewart, Chair of AirportWatch)

The Government’s consultation document on its draft aviation policy was published today –  Its second paper, asking for evidence on whether more airport capacity, particular hub capacity, is needed in London  and the South  East has been postponed until the autumn.

Today’s consultation is still a document which envisages a lot of growth.  Whether that level of growth is compatible with climate change and noise concerns is highly debatable.

The consultation document is more honest than we have seen from previous governments.

It recognizes:

1.  That some schemes may never be politically feasible. 

“proposals for a third runway at Heathrow demonstrate that without sufficient support, particularly at a political level, it would not be possible for

any government to deliver new capacity, however hard some shout for it.”


2.  It is important to devise the overall framework first, before looking at detailed proposals to increase capacity. 

“By starting to consult on this framework first, we are encouraging stakeholders to consider the ‘big picture’ before putting forward any proposals for new capacity”.


3.  A tourism deficit may well exist 

“Scoping document responses were divided on the economic impacts of outbound tourism. Some respondents considered that there was a “tourism deficit”, as more UK residents travelled abroad than overseas residents travelled to the UK. Other respondents highlighted that outbound tourism supports UK-based jobs in the travel and airline industry and boosts high street consumer demand before trips are made. The latter has been valued at around £27 billion per year. Responses confirmed that the “tourism deficit” question is a complex one.”


4.  The UK is one of the best connected countries in the world. 

“The UK is currently one of the best connected countries in the world. We are directly connected to over 360 international destinations. Using available airline seat kilometres as a connectivity metric, only China’s and the USA’s aviation networks are more extensive than the UK’s, and Germany and France are in fifth and eighth place respectively”.


5.  Landing slots need sorting out

“We have started a new piece of work to identify options, within the EU legislative framework, aimed at ensuring that slots at our congested airports are used in the most economically beneficial way for the UK. The focus of this work is on seeking to optimise the functioning of the secondary trading market for airport slots. We expect to engage with key stakeholders later in the summer and publish a progress report in the autumn”.


6. Teleconferencing has a role to play

“Alternatives to travel, such as the use of teleconferencing, videoconferencing or remote working, could help to reduce the demand for air travel and hence emissions from aviation. However, as the CCC noted in its 2009 report, there is some evidence suggesting that meetings based on videoconferencing may be additional, rather than substituting for meetings which require air travel. These meetings may give rise to further meetings which require air travel. Nevertheless, the success of the WWF’s “1-in-5” initiative demonstrates what can be achieved when companies adopt ambitious targets to reduce their air travel”.


7. The role of consultative committees needs to be updated

“We will be updating and consulting on the Government’s 2003  guidance to ACC following this consultation and will use this as an opportunity to seek detailed comments, building on useful feedback received from environmental non-Governmental organisations on the effectiveness of ACCs In particular, to ensure independence, we believe that the chairmanship of ACCs should be advertised externally and appointments should be for a fixed term in accordance with good practice in public appointments”.

But it is disappointing on climate change where it has deferred crucial decisions about the level of expansion, if any, may be compatible with climate change considerations

“The Government will continue to support action through ICAO towards a global aviation climate change agreement. While we would have preferred to see more rapid progress, steps are being made in the right direction. Before making a decision on whether the UK should retain a national emissions target for aviation, the Government believes that it is important to have considered the best available evidence, including in relation to the effectiveness of EU ETS allowances. The CCC’s advice on whether international aviation (and shipping) emissions should be brought within the Climate Change Act will help to inform our decision about the national aviation target”.


The position on noise is mixed, but more hopeful: 


a). There is a welcome recognition that there may be a need to move away from 57 Ldb Leq method of measuring noise as so many people disturbed by noise live outside that contour.

“The Government acknowledges research in recent years which suggests that the balance of probability is that people are now relatively more sensitive to aircraft noise than in the past, though there is insufficient evidence to indicate a clear threshold noise level at which it can be said with any certainty that there is an “onset of significant community annoyance”. We recognise that people living outside the 57 dB LAeq,16h contour are also affected by aircraft noise and that for some, the annoyance may be significant.

Indeed many complaints about aircraft noise come from outside the 57 dB LAeq,16h contour, reflecting the fact that frequency of movements can be a source of annoyance for some people living in areas exposed to lower average levels of noise across the whole day”.

“However, in order to facilitate improved monitoring, to provide more information about noise impacts, and to recognise that people living outside the 57 dB LAeq,16h contour are also affected by aircraft noise, we would also welcome views on whether it would be useful to ensure that the contour maps produced annually to show noise exposure around the airports designated for noise management purposes are drawn to a lower level. We consider that there are two options: either to use Lden and produce contours down to 55 dB(A), which aligns with the level to which airports are required to map noise exposure under the END, or to continue to use LAeq,16h  but produce contours down to 54 dB along with the concurrent production of night noise contours (LAeq,8h)”.

b). There is a welcome for  need for respite periods

“For those who are already affected by noise, and especially where frequency of movements has increased over time, the Government believes that it is important to give respite wherever feasible. This principle has been a longstanding one at Heathrow, which practises runway alternation in order to offer periods of respite, a principle for which the Government has made clear its strong support”.

c). We welcome the fact that noise penalties could be raised

“Penalties for breaches of departure noise limits have for some time been set at relatively low levels: £500 if up to three decibels over the limit and £1,000 beyond this. We are aware that airports have plans to review these penalties, and the Government believes that they should consider setting them much higher to reflect the cost to local  communities of aircraft breaching the limits. The Government also believes that there is a risk of a conflict of interest when the airport is responsible for enforcing the regime which affects its own customers. This is an area where greater transparency and the role of an independent body would help. Consequently, the Government is proposing a greater role for the CAA and ACCs in overseeing noise management at airports.”

Our worry is that the impact of these welcome measures could be off-set by the growth in flight numbers at many airports.


We welcome the recognition that there are problems with biofuels but note the Government is uncertain how to deal with them

“Sustainable biofuels have a role to play in reducing CO2 emissions from transport, particularly in sectors such as aviation where there are limited alternatives to fossil fuel. It is essential that biofuels lead to a worthwhile reduction in full life-cycle CO2 emissions, taking into account indirect land use change (ILUC), where production of biofuel from crops grown on existing agricultural land results in the displacement of production on to previously uncultivated land. The aviation sector will be competing with other sectors for limited sources of such sustainable biomass. The inclusion of aviation within the EU ETS already provides an incentive to develop sustainable biofuels as an alternative to kerosene. The Government needs to provide the right framework to ensure that only sustainable biofuels are used. We recently published a coordinated, evidence-based bio-energy strategy which looks at the best use of available biomass resources for a long term transition in technology. The European Commission is also due to come forward with proposals to address ILUC at a European level. Once we have a better understanding of these issues we will be in a better position to decide where Government intervention may be justified and the extent to which biofuels offer a way forward”.


We note the recognition that EU legislation in air pollution is binding

“Air pollution costs the UK up to £19 billion per annum in terms of reduced life expectancy. Emissions from transport, including at airports, contributes to this. EU legislation sets legally binding air quality limits for the protection of human health. Air pollution is one of the indicators in the DoH’s framework on public health outcomes.”



See also

Comment on the government aviation consultation from RSPB, Stop Stansted Expansion and AirportWatch



There have been several comments from environmental groups to the government aviation policy consultation. Below are those from RSPB, from AirportWatch, and from Stop Stansted Expansion.  The RSPB said “The government has also delayed consultation on the economic arguments for a hub airport until later this year, and in doing so has harmfully segregated the debate. We cannot consider the economic arguments for expansion and specific hub proposals without taking into account the environmental impacts such as noise, pollution and climate change. We need a bold new vision for the UK’s wider transport strategy. Instead of thinking about aviation expansion, the government should be investing much more in improving the UK’s surface transport network, in new technologies for efficient and electric vehicles, and in using existing airport capacity better.”