AEF analysis of the ITC report: its “conclusion that environmental impacts should be no barrier to expansion is unfounded”
A new report published by the Independent Transport Commission (ITC), a think tank supported by Heathrow and Gatwick, has argued that environmental concerns should not prevent a new runway being built. Now the Aviation Environment Federation (AEF)has come out with a damning assessment. The report argues that “it is foreseeable that a range of solutions will enable forecasts of future growth to be delivered within acceptable environmental boundaries even without a “step-change” in technology”. AEF points out that what “acceptable environmental boundaries” are not clearly defined. On CO2 emissions AEF says the ITC has put too much faith in future market based measures to trade emissions, and used unjustifiably optimistic forecasts of fuel efficiency improvements (1.6% per year, when others expect 0.8% at best). On noise AEF says the ITC does not even consider health impacts, uses implausibly optimistic assumptions and some unclear use of noise measurements. On air pollution, the ITC argues this is largely not the airports’ responsibility and hopes levels will improve soon. AEF concludes: “Without clearer definitions of what constitutes “acceptable environmental boundaries”, and evidence that these can be achieved, the report’s conclusion that environmental impacts should be no barrier to expansion is unfounded.”
The AEF view: ITC report on the sustainability of UK aviation
A new report published this week (7th March) by the Independent Transport Commission (ITC), a think tank supported by Heathrow and Gatwick Airports, has argued that environmental concerns should not prevent a new runway being built.
In this blog, AEF takes a look at the report, ‘The sustainability of UK aviation: trends in the mitigation of noise and emissions’, and considers its merits on noise, CO2 emissions and local air pollution.
The report argues that “it is foreseeable that a range of solutions will enable forecasts of future growth to be delivered within acceptable environmental boundaries even without a “step-change” in technology” and that “aviation can meet almost all of its targets for sustainability by following the current trend (in improvements), helped by pragmatic engagement with communities and some regulatory intervention.”
A starting question then for assessing whether environmental concerns about a new runway can be addressed is: what exactly are “acceptable environmental boundaries” which enable UK aviation to meet all of its “targets for sustainability”?
The ITC unfortunately doesn’t clearly define these “acceptable environmental boundaries”, so below we’ve used AEF’s definitions, many of which were used by the Airports Commission to assess the likely impact of airport expansion.
We then take a look at the ITC’s proposals for how the challenges could be addressed.
AEF considers the Committee on Climate Change’s recommendation that UK aviation emissions should be no higher in 2050 than they were in 2005 to be a minimum requirement for compatibility with the wider Climate Change Act.
The Airports Commission also considered any new runway within this framework. The ITC report acknowledged the Climate Change Act and the need for CO2 targets for the sector but stayed silent on whether the CCC’s recommended level should be regarded a “target for sustainability”. This could be because a new runway would make meeting these emissions levels much more challenging.
While acknowledging the limitations to take-up of biofuels and the fact that growth in aviation globally is forecast to outstrip efficiency improvements, the report argues that the issue of aviation CO2 emissions is “not an impossible problem to solve” due to market based measures combined with airframe technology and operating procedure improvements.
The report predicts annual efficiency gains of 1.6%, even without operational improvements or the use of alternative fuels, based on an analysis of fleet changes leading up to 2050. It’s a figure exceeding the UK aviation industry’s own forecast [“Sustainable Aviation’s CO2 Road-Map] of a 1.21% per annum improvement from the deployment of more fuel-efficient aircraft, and double the rate anticipated by official forecasts.
The Committee on Climate Change’s 2009 report recommended that Government should assume no more than a 0.8% annual average efficiency improvement, even allowing for an assumption that biofuel could comprise 10% of aviation fuel by 2050.
The Government’s own forecasts are similarly based on an assumed 0.8% annual average fuel efficiency assumption. A recent academic paper questioned whether the industry’s 1.5% annual efficiency gains goal could be maintained up to 2020 or beyond.
Sustainable Aviation have suggested that they have achieved average annual efficiency improvements between 2009 and 2014 of 1.9% but this is largely down to the baseline year used, and using 2010 as the baseline year leaves an average efficiency improvement of around 1% [source: AEF working based on Sustainable Aviation figures on page 19 here].
The ITC’s forecasts on efficiency improvements, the central component of its proposal for addressing CO2 emissions, appear highly optimistic.
AEF believes a sustainable limit would be for noise to reduce towards WHO recommended levels in the long-term. This reflects evidence that long-term exposure is associated with health impacts including increased risks of cardiovascular disease, an issue not considered in the report.
The Government, we believe, needs to set a clearer noise policy framework for airlines and airports to operate within, and against which the noise impacts of a new runway would need to be considered.
While technology can undoubtedly play a role towards reducing aircraft noise, as highlighted by ITC, annoyance from aircraft noise has been increasing even while individual aircraft have become quieter and noise exposure across the EU has been forecast to increase.
The ITC’s anticipated rate of take-up of quieter aircraft also needs scrutiny. The report argues that the introduction of new aircraft and retro-fitting of existing models will lead to the average aircraft being 9dB quieter by 2050, while changing operations in order to prioritise noise reductions could cut noise by an additional 9dB.
The driving force behind continued noise improvements is unclear, with ITC calling for clearer policy from Government and the use of limits based on ICAO standards for aircraft.
However, the most recent ICAO noise standard, which doesn’t take effect until next year, requires aircraft to be 7 dB quieter than its predecessor and represents an improvement of only 17dB since 1978.
These improvements are cumulative. In other words, they are the sum of the improvements at each of three tests points – approach, take-off, and sideline – meaning that the latest standard could permit aircraft to be as little as 1 dB quieter on landing (anything less than 3 dB is imperceptible to the human ear) and still pass the test.
Whether the technology improvements the report envisages will materialise without additional forcing is unclear, given the future trade-off the report acknowledges about fuel burn and noise.
Air quality limits designed to protect public health are laid down by law, but have been breached for many years in the Heathrow area.
The Airports Commission argued that although a new Heathrow runway would increase emissions further above the legal limit, it would not strictly ‘delay compliance’ with the legislation as long as other London roads are more polluted.
The ITC report argues that air pollution around airports is largely not the airports’ responsibility and, despite presenting no new modelling, that NOx levels are likely to reduce over time even without any new action. A new runway should therefore not be delayed, the report argues, even if the surrounding area is in breach of local air quality limits.
AEF’s view is that the report makes implausible assumptions on technology development to cut CO2 emissions, fails to acknowledge the scale and nature of the noise problem, and dismisses air pollution as something that is bound to resolve itself over time despite the UK Government currently facing the prospect of further legal action for failure to tackle a problem costing some 40,000 premature deaths a year in the UK.
Without clearer definitions of what constitutes “acceptable environmental boundaries”, and evidence that these can be achieved, the report’s conclusion that environmental impacts should be no barrier to expansion is unfounded.
See also, by AEF:
“Independent” transport think tank, pro-runway, finds the environmental challenges can all (honestly…) be overcome …
Heathrow is well aware that it has an almost insurmountable set of environmental obstacles that, in any logical system, would make a 3rd runway out of the question. However, it keeps hoping that it can persuade enough key people that all is well, and all environmental problems will just melt away. Now, in a slightly desperate attempt to get politicians etc to ignore the evidence, a report has been done by an organisation called the “Independent Transport Commission.” This is a body partly funded by Heathrow, by Gatwick, by NATS and many others. The report “The sustainability of UK Aviation: Trends in the mitigation of noise and emissions”, written by RDC Aviation Ltd, sets out to show that the aviation industry can soon overcome problems of noise, air pollution and carbon emissions – and adding a new runway will be problem-free. The report is thin on good detail to back up these claims. It is high on hopes, aspirations and what could be termed “mindless optimism” that new technologies will work out well, and everything that could help the aviation industry will do so. None of the real problems of an expanding industry, with additional problems from the sheer increase in plane numbers are dealt with. A report, which is hard to describe as “independent” in any meaningful sense of the word, advocates sacrificing the environment if holds the industry’s growth back.