Draft Aviation Policy Framework consultation. Ended 31st October 2012

What is the Aviation Policy Framework (APF)?

 What are the key points? 

Why is the APF important?

Why was it important to respond to it?

How various AirportWatch member organisations have responded on specific questions

See responses to the APF from a range of organisations, AirportWatch members and others



Draft Aviation Policy Framework is at Draft Aviation Policy Framework (PDF – 618 kB)   

and DfT Overview of the consultation 

End of consultation was 31st October 2012

What is the draft Aviation Policy Framework?

The DfT recently consulted on the future aviation policy for the UK. This is called the Aviation Policy Framework. The consultation was published on 12th July, and closed on 31st October 2012.  This was a public consultation open to all.

The Government’s primary objective is to achieve long-term economic growth, and the DfT is unambiguous in its view that the aviation sector is a major contributor to the economy. The Draft Aviation Policy framework document sets out the Government’s overall objectives for aviation and the policies by which it hopes to achieve those objectives.

The DfT supports the growth of UK aviation, though it conceded this should be within a “framework which maintains a balance between the benefits of aviation and its costs, particularly climate change and noise.”

The draft Aviation Policy Framework is a consultation, that has been shaped by responses to the DfT’s consultation in 2011, called the aviation Scoping Document.

The new Government aviation policy that will eventually emerge from this consultation will replace the Air Transport White Paper of 2003.  Its final form will be decided in Cabinet, and it is due to be published in March 2013.

Initially there would also have been a call for evidence, this autumn, on airport capacity and the UK’s connectivity. However, this was cancelled and instead there will be the Davies Commission, looking at future UK hub airports and capacity.  Its terms of reference and mode of operation have not yet been announced, and may not be before the close of the draft Aviation Policy Framework consultation (31st October 2012).


Why is the Aviation Policy Framework important?

The new Aviation Policy Framework will be a high level strategy, setting out overall objectives for aviation and the government’s policies to achieve those objectives. It will take the place of the 2003 Air Transport White Paper, and set out the Government’s aims for aviation and parameters for their delivery.

In the consultation, the DfT hopes that communities living near airports, who are going to be affected by aviation expansion, should be better consulted and informed; and that the aviation industry has confidence to underpin long-term planning and investment in aircraft and infrastructure.

The Aviation Policy Framework will set the parameters under which the Davies Commission will operate.

It will not be location specific, so will deal in general principles, but not specify details about  individual airports – unlike the 2003 ATWP.

It will be a statement of aviation policy, not the Airports National Policy Statement for planning purposes.  Local authorities will have to take the Aviation Policy Framework into account in the planning process.


Why should people have bothered to respond to it?

The now out-of-date and discredited Air Transport White Paper of 2003 was a seriously flawed policy that, from the perspective of AirportWatch members, did not properly address the noise, traffic and environmental impacts, including climate change impacts, of a growing aviation sector, and actively promoted unsustainable growth of aviation.

The current consultation, on the draft Aviation Policy Framework, is an opportunity to press for the changes needed, to give more protection to people living near airports, from the inevitable impacts of growing air travel.

The opportunity to influence future aviation policy does not arise often.  It could be many years before the chance arises again.

The aim of AirportWatch is to ensure that this time around the Government gets its policy right.  We want to end up with a policy framework that recognises that aviation growth comes with serious environmental impacts.

We need to reach a genuine balance between the perceived benefits of the aviation industry to the UK economy and the damage that aviation causes to local communities and the environment.

It was important that as many people as possible responded.


What are the key points?

The consultation is divided up into chapters as follows:

– Chapter 2. The benefits of aviation

– Chapter 3. Climate Change

– Chapter 4. Noise and other local environmental effects

– Chapter 5. Working together

On Economic issues, the consultation document is arguing the case on behalf of the aviation industry for its growth. It does not appear impartial, but there are many pages setting out the aviation industry’s case.  it is important to reiterate that the UK is currently very well connected with the rest of the world, and recognition of this in the consultation is welcome.  There is no urgent need to take decisions about airport capacity.  On Government figures the UK has enough airport capacity until at almost 2030. The Government is right to take its time and ensure future capacity needs are based on hard evidence – assessed through the Davies Commission – rather than bowing to the shrill slogans of the aviation industry and its friends.

The actual economic contribution of aviation to the UK economy needs to be impartially assessed, and this requires an estimate of the cost to the economy of the tax-breaks the aviation industry enjoys in terms of tax-free fuel and its exemption from VAT. It must also take account of the economic costs of the noise, air pollution and climate change gases (the negative externalities) that aviation produces.  It is estimated that tax-free fuel and zero-rating for VAT costs the country  around £9 billion a year, and it artificially increases demand for air travel, and costs everyone in Britain (those who fly and those who do not) a considerable amount every year in extra tax. Air Passenger Duty would need to rise four-fold to make up the difference.

The recognition in the consultation that a tourism deficit (the difference between what visitors spend in this country and UK citizens spend abroad) may exist is welcome. But more work needs to be done on it. The claim that the deficit is offset by a alleged £27 billion spent by UK tourists before they leave the country is highly dubious and its figures are speculative.

On Climate Change, the consultation is very weak.  The consultation document merely goes over what is being done already, and asks two general questions. Why is there no mention of ICAO, or more detail on how the ETS is not working, or about how the expansion of UK aviation will endanger UK climate targets? The key point is that the Government needs to use all the tools it has available to tackle climate change from aviation.  The Government cannot rely solely on “cleaner” technology, the EU Emissions Trading System and the Single European Sky Agreement to guarantee emissions will fall sufficiently.  It also needs to bring in clear targets by including aviation in the UK’s carbon budgets and to endorse the target of cutting aviation emissions to at least their 2005 level by 2050.

Aviation accounts for at least 13% of the UK’s greenhouse gas emissions (if non-CO2 effects including cirrus cloud formation is included – about 6.5% without it) and the proportion is growing.  The Committee on Climate Change (CCC): the Government advisors, recommended emissions from aviation should be back at their 2005 levels by 2050. This would permit growth in air passengers of 60% above the 2005 level by 2050. This is a challenging target, but less so than for other sectors of the economy – which have to make huge actual CO2 cuts, not merely stop increasing.

If UK aviation was allowed to grow as much as it wants to,  it will account for perhaps 25% of the UK’s CO2 emissions by 2050 – leaving every other sector struggling to meet their targets, and having to make cuts of well over 80%.


On Noise,the key points are that this Government has become the first in generations to take the problem of aircraft noise seriously.  However, a two-tier system may emerge unless government is prepared to give some direction to all airports, not just confine its proposals to the designated airports (the consultation document very much tends to focus on the designated airports – Heathrow, Gatwick and Stansted).  Noise and other environmental impacts will not be dealt with effectively at the non-designated airports by leaving their management to planning conditions imposed by the local authority, noise action plans, master plans and “voluntary arrangements.” A particular concern is that a number of local authorities have a conflict of interest in that they own or part-own the airports. The Government envisages an expanded role for the CAA.  It could play a particularly important role at non-designated airports.

The 57 dB LAeq, 16h noise measurement should no longer be used.  It is at variance with the lower limits recommended by the World Health Organisation and the one used by the European Union. The consultation floats the idea of using 55 Lden or 54 Leq.  Both are more in line with WHO recommendations and EU practice.  Noise maps using either of these metrics should be produced annually for both designated and non-designated airports.  They would make matters more transparent for the local community and would seem to be essential evidence for accurate decisions on any future growth.  There needs to be recognition that the 57 dB contour is not an adequate measure of where people are not only annoyed, but have their quality of life diminished, by aircraft noise. This limit is too high, and in reality, a lower figure needs to be set.  People do not recognise noise measured by Leq – an averaging system. What they hear is actual noise events, and the number of those noise events matters, not merely averaged sound energy, averaged over a number of hours. Additional metrics are needed, which make more sense to people being overflown, and which they can better understand.

People living with the burden of aircraft noise are wary about the concept of a noise envelope.  The fear is that it could be used to push through excessive growth.  A carefully defined envelope, ideally containing a cap on the number of movements, could potentially give local residents faced with growth the sort of certainty they have not had before – but the devil would be in the detail. Local residents need certainty that the amount of noise will fall, not merely stay the same. If aircraft do become slightly quieter over time, those on the ground should get part of the benefit of the reduction. Slightly less noisy engines should not be an excuse for there to be more flights.  The technological benefit should be shared, with those on the ground, living below flight paths.

On other environmental impacts, other than noise, air pollution is one of the most important. There is concern about the lack of questions on air pollution and air quality, and insufficient focus on this within the draft APF consultation. Air quality was a key issue for Heathrow, and EU air quality limits are already being broken in many places in the UK.  It  is illegal to increase the source of emissions  (such as expanding an airport, and the traffic that feeds it) when the level are already too high.


On Working Together, the key  points are that the Airport Consultative Committee, as currently constituted, could not fulfil the wider role that the Government has in mind for them.  Thus the intention to review, update and consult on the 2003 guidance to consultative committees is welcome.  The Government is looking for suggestions on how they can be improved.  It may be our opportunity to help shape the consultative committees, many of which at present are dreadful and appear to function largely to serve vested interests, often ignoring genuine concerns from local residents. Merely consulting local residents, and explaining matters to them, is not a substitute for actually causing the airport to produce less noise, or becoming a better neighbour.  The consultation needs to be actual, and not merely at matter of going through the motions.




How some AirportWatch member organisations have responded to questions in each section of the consultation

For details, see pages on the various sections:

– Chapter 2. The benefits of aviation

– Chapter 3. Climate Change

– Chapter 4. Noise and other local environmental impacts

– Chapter 5. Working together



Consultation responses from the following organisations that are AirportWatch members:


Draft aviation policy framework –  BCAW Sept 2012 (Belfast City Airport Watch)  

Draft Aviation Policy Framework – SSE  (Stop Stansted Expansion)

Aviation Policy Framework Response – LLATVCC (London Luton Airport Town & Villages Communities Committee)

LADACAN response to DAPF consultation  (LADACAN at Luton)

 Aviation Policy Framework Consultation   (AirportWatch response)

Draft aviation policy framework response   (AEF – Aviation Environment Federation response)

Aviation Policy Framework reponse from HACAN  and Joint submission by HACAN with Heathrow Airport and BA

 Aviation Policy Framework Response  – Ealing Aircraft Noise Action Group

Aviation Policy Framework response from CPRE Kent  – (CPRE Kent)

Response to APF from CPRE Hampshire    (CPRE Hampshire)



More will be publicised in due course.

Some initial thoughts from John Stewart earlier in the summer


Responses from other organisations, that are not AirportWatch members:

Draft Aviation Policy Framework response – from Tandridge District Council

STACC Aviation Policy Framework Response – from Stansted Airport Consultative Committee

Response to the Aviation Policy Framework consultation PDF  London Assembly  (and statement about it)

Response to the Draft Aviation Policy Framework – The Air League

Giving wings to airports across the UK  – from Bristol Airport. They say  “Bristol Airport has submitted a formal response to the DfT consultation on the Draft Framework, alongside a position paper containing policy proposals which would help rebalance the economy.   ‘Giving wings to airports across the UK’ sets out five recommendations for Government policy which would enable airports outside London to more effectively serve their local markets by making best use of existing capacity, easing congestion in the South East as a result.  More on this on their website.

“An Integrated Policy Framework for UK Aviation: Connecting the Economy for Jobs and Growth”   From the Airport Operators Association (AOA).  Not so much a consultation response but a long document in which the AOA sets out what they believe “a bold and integrated aviation policy would look like. It takes a cross-Government-departmental view on what is needed for UK aviation”,

Draft Aviation Policy Framework consultation response   – from the CAA 

Draft Aviation Policy Framework consultation response  – from BATA (British Air Transport Assn)   And  Press release on it

“Wider Growth; wide connectivity” response to Draft APF   – by Birmingham Airport  and their press release on it

ABTA response to Draft Aviation Policy Framework  – ABTA  and press release about it

View the full ANEC response to the Department for Transport’s Draft Aviation Policy Framework –  Association of North East Councils 

Response to the Draft National Aviation Policy Framework consultation.  – Institution of Civil Engineers (ICE) and Chartered Institution of Highways & Transportation  

 West of England Aviation Policy Framework response  – West of England councils

Aviation Policy Framework response  – London Councils and their page about  it.


…. and there are many, many more …..