How well did the Airports Commission’s interim report do on the AEF’s 3 environmental & social tests?
The Aviation Environment Federation has set out three tests, to apply to the Airports Commission’s Interim Report, published on 17th December 2013. These are on climate: “Does the Commission demonstrate a pathway to meet our national climate change target in a one or two new runways scenario using realistic assumptions?”. On quality of life: “Does the Airports Commission only short-list options that will not worsen the quality of life for communities around airports?” and on Social Cost Benefit Analysis: “In light of extensive challenges to the assumptions of economic benefits of expansion and recommendations by a well known economic consultancy firm, does the Airports Commission commit to carrying out a Social Cost Benefit Analysis of each of the short-listed proposals over the course of 2014?” They have had a quick, initial look at the Interim Report, and set out areas on each of these where there is evidence of “positive steps” and areas of “missed opportunities”. On climate AEF regret that there is uncertainty on international agreements, and that non-CO2 impacts of aviation may need to be taken into account in the future – but are not yet. On quality of life, AEF regrets that noise, air quality and local impacts have not yet been satisfactorily addressed. AEF say a clear and transparent social cost benefit analysis of each of short-listed options is needed as part of the Commission’s appraisal in 2014.
The AEF’s 3 tests of the Airports Commission’s Interim Report
The Aviation Environment Federation has set out three tests, to apply to the Airports Commission’s Interim Report, published on 17th December 2013. These are:
Does the Commission demonstrate a pathway to meet our national climate change target in a one or two new runways scenario using realistic assumptions?
2. Quality of life
Does the Airports Commission only short-list options that will not worsen the quality of life for communities around airports?
3. Social Cost Benefit Analysis
In light of extensive challenges to the assumptions of economic benefits of expansion and recommendations by a well known economic consultancy firm, does the Airports Commission commit to carrying out a Social Cost Benefit Analysis of each of the short-listed proposals over the course of 2014?
Below there is more detail about these tests.
Three tests for the Airports Commission’s Interim Report
The Commission has emphasised that a ‘predict and provide’ model of airport capacity would be insufficient, and that the scale of capacity needed must be assessed within the context of environmental limits and social considerations that “takes into account the potential constraints on expansion” .
Below, we pose three tests against which the Airports Commission’s Interim Report should be judged.
We ask interested parties to conclude for themselves whether the Interim Report passes these tests and delivers a well based analysis of the potential constraints on expansion, or simply provides the infrastructure the industry claims is necessary.
Does the Commission demonstrate a pathway to meet our national climate change target in a one or two new runways scenario using realistic assumptions?
- In his October speech Sir Howard recognised the advice of the Committee on Climate Change. This Committee estimated using ‘likely’ improvements in technology and operations that a 60% growth in passenger numbers over 2005 levels would not compromise the UK’s emissions target. There is already sufficient space in existing runway capacity to accommodate this growth[ii].
- This means building and using one new runway would require capacity limitations on existing airports in the South East and the rest of the UK if we are to meet our national emissions target[iii].
- The use of a second runway would be dependent on ‘speculative’[iv] technology improvements and a heavy reliance on alternative fuels if the UK is to have any chance of meeting climate targets.
Does the Airports Commission only shortlist options that will not worsen the quality of life for communities around airports?
- Aircraft noise is the main driver of community opposition to airport expansion and is an unacceptable burden on many people living close to airports. Nearly ¾ million people already live within the EU contour of noise annoyance at Heathrow[v], a third of the total number of people affected by aircraft noise across the entire EU.
- Airports likely to be shortlisted, such as Heathrow, are close to and often breach EU limit values on air quality introduced to protect public health[vi].
- Both air pollution and aircraft noise pose risks to public health. Air pollution is estimated to cause 29,000 deaths a year and costs the economy £16 billion each year[vii]. A recent study found that people living in areas around Heathrow with the most aircraft noise were 10-20% more likely to have heart problems and suffer from strokes[viii].
In light of extensive challenges to the assumptions of economic benefits of expansion and recommendations by a well known economic consultancy firm[ix], does the Airports Commission commit to carrying out a Social Cost Benefit Analysis of each of the shortlisted proposals over the course of 2014?
- The economic benefits of airport expansion are frequently highlighted in the media at the expense of wider economic and social costs.
- Each shortlisted proposal should be assessed against a “no new runways” benchmark. Given sufficient capacity exists, it is important to only to consider the additional benefits of funding a new runway.[x]
[i] Quote taken from Sir Howard Davies’ speech ‘Emerging thinking: aviation capacity in the UK’ made at the Centre for London on the 7th October 2013
[ii] In 2011 AEF and WWF carried out research to examine how much growth in passengers and number of movements is possible within existing airport capacity when an aviation carbon target is in place. ‘Available UK airport capacity under a 2050 CO2 target for the aviation sector’ is available from:http://assets.wwf.org.uk/downloads/airport_capacity_report_july_2011.pdf
[iii] AEF and seven other environmental NGOs recommended this to the Airports Commission in an open letter to Sir Howard Davies’ speech on 7 October available online from:http://www.aef.org.uk/?p=1651
[iv] The Committee on Climate Change defines the speculative scenario as very unlikely. The scenario requires technological breakthroughs and a significant increase in the pace of aircraft fuel efficiency improvements. In addition, it would require the development of sustainable biofuels which are speculative, such as algae, or developments in land use so that biofuels can be grown at a large scale.
[v] EU noise annoyance contour is 55 Lden. A definition of Lden can be found on the CAA website:http://www.caa.co.uk/default.aspx?catid=7&pagetype=70&gid=2124&faqid=1268. The actual figure around Heathrow is 725,500 as used in the Airports Commission Discussion paper on noise.
[vi] In 2012, Heathrow breached the annual NO2 limit at the measuring station within the airport compound. Levels of PM10 also breached legal limits on eight separate periods around the Heathrow area. More information is available in the Heathrow Airport air quality review for 2012:http://www.heathrowairwatch.org.uk/documents/Air_Quality_at_Heathrow_Aiport_2012_Report_Issue_1.pdf
[vii] These figures are taken from the Defra webpage on ‘Protecting and enhancing our urban and natural environment to improve public health and wellbeing’.https://www.gov.uk/government/policies/protecting-and-enhancing-our-urban-and-natural-environment-to-improve-public-health-and-wellbeing
[viii] The study was carried out by Kings and Imperial College London. The press release is available here:http://www3.imperial.ac.uk/newsandeventspggrp/imperialcollege/newssummary/news_8-10-2013-16-59-51
[ix] CE Delft released a report in March 2013 titled ‘The Economics of Airport Expansion’. Available from:http://www.cedelft.eu/publicatie/the_economics_of_airport_expansion/1363
[x] Under DfT’s 2013 central forecast, the unconstrained passenger demand will be 320 mppa in unconstrained compared to 315 mppa constrained which would only squeeze out 1.6% of growth forecasted. DfT figures are available from:https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/223839/aviation-forecasts.pdf
AEF then asks:
How well did the Airports Commission’s interim report do on the AEF’s three environmental and social tests?
Dec 20 2013
Before publishing the interim report, Sir Howard Davies and the Airports Commission he chairs emphasised the importance of not simply providing the capacity that industry demands in deciding the need for additional runway capacity.
Instead, Sir Howard argued that the Commission engaged with wider social and environmental issues, that the Commission was “alive to the climate problem” and that local issues such as air pollution and noise would “play a key part as we identify our interim recommendations”.
We therefore set three tests for the Airports Commission in advance of the interim report to see how far it engaged with these wider concerns (the basis for each test is set out above).
Below we compare the main findings of the report with each of the tests. In the New Year, AEF will be releasing a series of policy briefs looking at the Airports Commission’s work in more detail. A summary of the interim report’s findings and recommendations is available here.
First Test: Does the Commission demonstrate a pathway to meet our national climate change target in a one or two new runways scenario using realistic assumptions?
The interim report makes significant improvements on DfT forecasts of growth in passenger demand up to 2050 which had limitations in terms of how they handled uncertainty beyond 2030 (as the Department of Energy and Climate Change (DECC) provides forecasts of oil prices up to this year only). Our concern over the long-term uncertainty of DfT forecasts was referenced in the interim report.
In the revised forecasts, the Airports Commission also include carbon traded and carbon capped scenarios. This is an improvement on the scenarios currently considered by the DfT. The carbon traded scenarios include the assumption that aviation emissions will be included in an emissions trading system such as a global offset scheme. Carbon capped scenarios include the assumption that aviation emissions will be limited to the recommendations by the Committee on Climate Change that emissions can be no higher in 2050 than they were in 2005.
The latter scenario produces the lowest forecast of constrained and unconstrained growth. In an unconstrained carbon capped scenario, the Airports Commission estimate that passengers can increase by 67% above 2009 levels while the number of movements (number of planes flying) can increase by 38% (compared to 60% and 55% respectively in the CCC’s 2009 analysis).
The interim report highlights the ongoing uncertainty in international negotiations and the fact that non-CO2 impacts of aviation may need to be taken into account in the future, but offers no indication of how much the industry can grow in the absence of an effective emissions trading scheme in the future or if non-CO2 impacts are included in climate targets.
Second Test: Does the Airports Commission only shortlist options that will not worsen the quality of life for communities around airports?
At the very beginning of the executive summary, the report emphasises the negative impacts of air quality and noise on the quality of life for people who live or work nearby, and that the planning process must ensure that decisions on airport capacity balance local considerations with the national interest. However, the Airports Commission will only be able to take the local impacts into account next year when it considers the short-listed options in detail.
The Airports Commission also recommended the creation of an Independent Aviation Noise Authority which would provide advice and recommendations on an impartial basis. As the Commission points out, there is a real need for improved transparency in noise reporting by the industry as noise causes the most tension with communities. The interim report also points to good examples from Australia and France of independent noise bodies providing accurate and impartial information to all stakeholders.
As we highlight in a Huffington Post blog post, the Airports Commission’s staged approach means that local considerations appear an afterthought, which will leave people living in communities seeking reassurances from politicians.
However, the Commission is to set out its draft Appraisal Frameworkin early 2014 on how the different options should be considered and analysed. That will present an opportunity for the Commission to demonstrate how local concerns will be considered.
There is also a concern that forming an independent noise body would constitute passing the baton of noise regulation on and not actually contribute to improve the current noise problem.
Third Test: In light of extensive challenges to the assumptions of economic benefits of expansion and recommendations by a well known economic consultancy firm[ix], does the Airports Commission commit to carrying out a Social Cost Benefit Analysis of each of the shortlisted proposals over the course of 2014?
The interim report highlights that the Commissions has not followed a “mechanistic predict and provide model.”
The Commission states that their approach has been informed by the principles of the Strategic Environmental Assessment (SEA) Directive to support the Government’s decision. The Commission also says that the methodology used takes account of the social and environmental costs of policy options alongside their anticipated benefits.
The interim report also states that social cost-benefit analysis is the standard methodology used in the public sector but then says that the costs involved are primarily those of a constrained airport and calculates the overall cost to the economy by 2080 will be up to £45 billion.
It appears that the social cost-benefit analysis calculated only takes into account the possible negatives of a constrained airport, and not the potential benefits. We would like more detailed information on the different factors that were included in the analysis.
However, as well as stating the need for one additional runway by 2030, the Commission states that it is likely that there will be “a demand case for a second additional runway way by 2050”. The Commission commits to analysing this possibility in the next phase of its work programme.
We expect the Airports Commission to carry out a clear and transparent social cost benefit analysis of each of shortlisted options as part of their appraisal in 2014, as the Commission has promised to take into account the economic, social and environmental impacts.
The AEF will go into more detail on each of these issues in the New Year with a series of policy briefs about the Airports Commission’s work.