Aviation Policy Framework – Working together

Date added: 1 October, 2012

Draft Aviation Policy Framework

The section on Noise and local environmental effects is Pages 72 –  80

The questions on this section are:

25. Do you think Airport Consultative Committees should play a stronger role and if so, how could this be achieved?

26. Is there a case for changing the list of airports currently designated to provide consultative facilities?

27.  Do you agree that the Civil Aviation Authority should have a role in providing independent oversight of airports’ noise management?

28.  Do you agree with the Government’s overall objective on working together?

29. Is the high-level guidance provided in Annex E sufficient to allow airports to develop local solutions with local partners?

30.  Do you agree that master plans should incorporate airport surface access strategies?

31. Do you agree that, where appropriate, the periods covered by master plans and noise action plans should be aligned?

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Further comments made by AirportWatch members:

Question 25.   Do you think Airport Consultative Committees should play a stronger role and if so, how could this be achieved?

Consultative committees are normally run by the airport and are composed of representatives of airlines, passengers, local councils and environmentalists.  All have different interests.  Agreement can usually only be reached on minor issues where there is no significant cost to any of the participants.

They are useful as a forum for the exchange of views but it is therefore inherently unlikely that they will be able to play a stronger role.

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Yes, we refer you to our response to Q.41 in your Scoping Consultation last year,
The key failing of Airport Consultative Committees (ACCs) is that they lack independence and are viewed by many local residents as simply an extension of the airport’s PR department. In our view, this failing could largely be addressed by giving the CAA responsibility for appointing and remunerating the chairman of each ACC, funded by an airport levy per passenger. We estimate that the CAA would need to levy about 0.25p per passenger on average but with a de minimis figure to take account of smaller airports.

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The commitment to improve standards in relation to Airport Consultative Committees is very welcome, as is the suggestion that noise information should be presented using a variety of metrics.

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The consultation document refers to ACCs’ current statutory remit – but that remit is merely that the ACCs should exist; they have absolutely no power to require the airport operator to do, or not to do, anything.  To that extent, “consultation” perfectly matches the Devil’s Dictionary definition – “to seek the disapproval of others to a course of action already decided upon”. That is our experience over many years, especially on issues such as Night Noise Policy over which, at each quinquennial review and after lengthy ”consultation”, the airport does what it chooses despite pleas to the contrary.

We have asked, on several occasions, for DfT (which produces the Guidelines[1] setting out how ACCs should function) should systematically undertake “mystery shopper” work to establish for itself that its guidelines are being followed and, where they are not, to institute remedial action. In many cases the DfT Guidelines, which are non-statutory, are not well observed (see comment above in respect of Wycombe Air Park).

One major area of deficiency is that the meetings of many ACCs are not “open”.  Membership, and the right to make representations to them, is often very strictly controlled by the airport management as are any records of their proceedings, whose content is Bowdlerised almost to consisting of a list of attendees only.

Another area requiring attention is that of the breadth and depth of information about the airport made available to the public.  Some airports produce relatively informative Annual Monitoring Reports, and supplementary reports such as that from the Gatwick “Flight Evaluation Unit” (in the case of X we still await (August 2012) the Annual Report for 2011).  Others produce as little as possible – there should be a minimum standard of reporting, at least for airports with more than 50,000 movements per year, in terms of both content and timescale for production – it is suggested, no greater than 3 months after the end of the reporting period.

Question 26.  Is there a case for changing the list of airports currently designated to provide consultative facilities?

No comment.

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Unless ACCs are made genuinely independent, they will continue to be ‘box ticking’ institutions whose sole purpose is to fulfill a designated airport’s statutory obligation to provide consultative facilities. Under the present arrangements therefore we consider it to be of little consequence whether the DfT designates every UK airport to provide consultative facilities, or designates none.

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No comment; we assume that “airports” includes GA airfields. In general, if significant numbers from the local community, through their local elected representatives or bona-fide organisations, press for one, one is needed and the list should be expanded accordingly.

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It is considered that there is no need to change the list of airports currently designated to provide consultative facilities due to the limitations of such Committees. It is considered that there is a need to reflect the difference between the expected role of Airport Consultative Committees at the larger airports and the smaller aerodromes.

Question 27.   Do you agree that the Civil Aviation Authority should have a role in providing independent oversight of airports’ noise management?

We consider that the CAA has an inbuilt bias towards the aviation industry.  It would not be trusted by local people to be properly independent.

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Yes, we refer you to our response to Q.53 in your Scoping Consultation last year, where we argued for the CAA to be given a role in providing independent oversight of airports’ noise management and other airport-related environmental impacts. We explained that there was widespread mistrust amongst local communities close to airports, in relation to the fairness, objectivity and transparency of the current ‘in-house’ arrangements for reporting upon aircraft noise, emissions and track-keeping and for recording and handling public complaints regarding aircraft noise and other environmental impacts.

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Independent oversight: yes.  But CAA, being a wholly-financed subsidiary of the aviation industry, cannot claim to be independent. This issue is one which would be much more appropriate for DEFRA or for a respected environmental consultancy such as Bureau Veritas, an agency already well known to and respected by DEFRA, acting on their behalf.

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It is considered appropriate for the Civil Aviation Authority to contribute to the oversight of airport operators’ noise management schemes working in concert with other bodies to improve such schemes.  It is also considered that the Civil Aviation Authority has the expertise to contribute to the process of airport noise management.

Question 28.  Do you agree with the Government’s overall objective on working together?

It has always been hoped that the lion will lie down with the lamb, but in the real world when the lion wishes to eat the lamb, this may not be easy to achieve.

Airports and local residents have different interests.  We would prefer to rely on the DfT to lay down rules for environmental protection.

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We fully agree with the Government’s overall objective of encouraging the aviation industry and local stakeholders to strengthen and streamline the way in which they work together.

We also fully agree with the Government’s objective of encouraging airport operators to be more transparent and open and one very tangible way of making progress in these areas would be for airport operators to be deemed to be public authorities for the purposes of the Environmental Information Regulations 1992 (pursuant to 90/313/EEC), noting that airport operators are deemed to be public authorities in relation to the compulsory purchase of land, under s.50 of the Airports Act 1986.

We start from a position of scepticism that airport operators will pay much heed to the DfT’s exhortations in this area. In our response to last year’s Scoping Consultation we explained our experience at X and included the example of the airport master plan, as follows. ‘The 2003 Air Transport White Paper called upon airport operators to produce master plans ‘as quickly as possible and preferably within the next 12 months’. The best [that the airport] managed to do was to produce an interim master plan and that was not published until 2006. A final master plan was supposed to follow ‘within a few months’ but it never did. Moreover, the interim master plan now bears no relation to reality. On the basis of our experience the master plan process seems to be a waste of time and money.’

There is also a need for greater transparency on the air quality standards that are being achieved in the vicinity of airports and so we believe there should be a requirement for airports with a throughput of 5 mppa or above to have an approved AQ policy and to publish quarterly results which are subject to independent monitoring and oversight by the CAA.

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We agree with the Government’s overall objective of “working together”. The Government’s objective for strengthened joint working is supported and reflects the approach being adopted in the X area.  The Government should recognise the importance of translating non-statutory plans  (so called Master Plans) prepared by the airport in consultation with the local community into local planning polices so that they can be formally examined.  This will help provide confidence to the airport and the local community that airports can grow in a sustainable and environmentally acceptable way.

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The Government’s big hope, it seems, is that better relationships can be built between airports and local communities, to alleviate the conflict that has become typical of airport growth, and a whole chapter of the consultation is devoted to “working together”. The new role of the CAA in providing environmental information about airports to the public, as proposed in the Civil Aviation Bill, is discussed, but airports too are encouraged to review how information about noise is presented in order to make it more meaningful and accessible including the use of “additional metrics to help people to better understand other factors such as frequency and pattern of aircraft movements, the precise tracks used, the average noise of individual aircraft and the highest noise levels which can be expected.”

Airport Consultative Committees (ACCs) continue to be seen as a key forum for engagement though the policy acknowledges the need for improvement. While a separate consultation on the Government’s guidance to ACCs is promised, proposed improvements include a role for the CAA in providing independent oversight, and a recommendation that ACC chairmanship should be for a fixed term, with appointments advertised externally. There is no suggestion that the guidelines will be made mandatory.

The power of local communities to have a real influence over the direction of the airport’s operations, however, is questionable. We are particularly concerned about the policy role foreseen for airport master plans. Originally envisaged as the means for airports to communicate how they planned to pursue Government-approved expansion plans, in the absence of such airport-specific recommendations in future they can surely be no more than airport wish lists designed to please shareholders. It is therefore extraordinary that the policy argues that “perhaps one of the most important issues master plans should seek to address is what the long term land requirements are for future airport development”; land, it is argued, should be ‘safeguarded’ by planners for airport development on the basis simply of airport business plans. “The additional land and property involved, including those associated with PSZs and safety surfaces, should be clearly identified to minimise long term uncertainty and non-statutory blight.”

The Government is keen to have our input in terms of how airports and communities could engage more effectively. The first step will perhaps be for the Government to explain how local people can possibly achieve an equal footing with airports in the context of airport development applications given this apparent official sanction being given to purely commercial documents.

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Do you agree with the Government’s overall objective on working together?

As stated, this is “to encourage the aviation industry and local stakeholders to strengthen and streamline the way in which they work together.”  As such, it is another “motherhood statement” with which nobody could disagree. But, insofar as local communities and their representatives, elected or otherwise, are concerned, the dice are permanently and heavily loaded against them.  Even the best Airport Consultative Committees represent all of the illusion but virtually none of the reality of consultation.

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Do you agree with the Government’s overall objective on working together?

(Helicopters)

Not unless the industry has suitable regulation in the event of consultation not working.  Consultation must include all stakeholders, not just “local” ones.  Improved means of reporting complaints about helicopters are needed, as well as noise metrics that are user-friendly to communities that are affected by helicopter noise.  Until and unless communities and airports or airfields have a satisfactory means of communicating, the objective of working together better on helicopter issues will not be achieved.

Question 29.  Is the high-level guidance provided in Annex E sufficient to allow airports to develop local solutions with local partners?

We strongly disagree with the assumption in Annex E that master plans can be relied upon.  In practice they are little more that wish lists prepared by the commercial company running the airport.

Employment forecasts are routinely exaggerated in order to secure local support from local councils.[i]

We have had recent experience with the production of the new Gatwick Master Plan.  The consultation was totally falsified by the fact that the substantial increase in noise was concealed, and by claims of bogus economic benefits.[ii]

As noted earlier, the Gatwick master plan forecasts that the number of people within the 57 Leq contour will double by 2021 – in flagrant breach of the Government’s over-riding objective to limit or reduce aircraft noise.  It is not clear how ‘local solutions’ will solve this problem.

Question 30.   Do you agree that master plans should incorporate airport surface access strategies?

No comment.

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Yes, so long as those strategies are meaningful rather than aspirational.

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Yes, as part of the reform we propose in response to Q29 above.

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(Helicopters)

Yes.  These strategies should heavily discourage the use of helicopters in preference to surface access.

31.  Do you agree that, where appropriate, the periods covered by master plans and noise action plans should be aligned?

At Gatwick the noise action plan is incorporated in the Section 106 agreement with West Sussex County Council.  Unlike the situation at other airports, there are thus legal sanctions to ensure that it is implemented (or reasons given why not).  This might cause difficulty in aligning it with the master plan.

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Yes, as part of the reform we propose in response to Q29 above, and we would delete the phrase ‘where appropriate’ because this may provide a basis for evading responsibility

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Giving airport master plans the status of official or semi-official planning documents, however, despite these being no more than commercial plans designed to impress shareholders, seems very likely to invite just the kind of antagonism that the Government wishes to avoid from communities who are effectively sidelined.

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Cannot comment: what does “appropriate” mean?  It would be better to require that those periods should always be aligned.  It has to be said that the speed of Government response to the last round of Noise Action Plans left much to be desired, especially when compared with the demanding timescale set for their production.

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We consider that where appropriate the periods covered by airport master plans and noise action plans should be aligned with the aim of facilitating community engagement in discussions around noise and aviation activity. Such alignment would allow for more effective joined up planning and the consideration of associated issues.

Noise action plans should be a key driver for airports to manage and mitigate the impact of aircraft noise in their area and should be seen as “living” documents with a transparent monitoring and reporting regime as well as a mechanism for regular review.

Posted: Monday, October 1st, 2012. Filed in Recent News.