A TAG view on the Government’s consultation document ‘Beyond the horizon – the future of UK aviation.
This response sets out TAG’s views on the Government’s consultation document ‘Beyond the horizon – the future of UK aviation’ which can be located here.
The consultation paper recognises ‘the first duty of any government is to protect its citizens’ (para 1.21). It also refers in its Policy Tests to ‘the final outcome for the sector and society’.
TAG believes that the proposed strategy fails the very tests it sets itself. The aviation industry should work for the benefit of UK society. In many respects based on the strategy as described within the consultation document it appears that the converse will apply.
The aviation industry (particularly in the UK) is operated by globalised corporations and foreign sovereign wealth funds without a direct interest in the communities affected by their activities. Against this background it is unacceptable that the UK Government fails to adequately protect the rights and wellbeing of its citizens affected by the industry’s environmental impacts, both in law and policy terms. It seems that the DfT creates policy without significant oversight, input or limitations from other key areas of government including health, environment and education.
With the level of aviation expansion now proposed, the anticipated introduction of extremely concentrated flightpaths and a commitment to extend Heathrow come what may (pre-judging the outcome of the ongoing National Policy Statement (NPS) consultation and notwithstanding this airport already negatively impacts the lives of 29% of all people in Europe affected by aircraft noise), this approach could have very serious consequences for millions of people living in the UK.
At the heart of the problem with the proposed new strategy is the fact that whilst the consultation paper pays lip service to the importance of having a robust evidence base, the DfT doesn’t have a track record of doing this, and based on the way policies and objectives are expressed in the consultation document there is no reason to think things will be different in developing the department’s policies or strategies in the future. This is a hugely important issue – and could lead to a scandal of VW proportions – given that 100% growth in aviation demand is anticipated between 2011 and 2046 (para 1.25).
Underpinning many of the flaws in the strategy is the Government’s stated philosophical attachment to a ‘liberalised approach’. However, aviation doesn’t lend itself to light regulation for the following reasons;
- The environmental effects and detrimental health impacts on overflown communities cannot be mitigated effectively in system driven by private sector commercial interests. In economic terms externalities cannot be internalised under a liberalised approach.
- Notwithstanding a stated attachment to a market led system, especially with the assumed expansion of Heathrow (which is referred to many times in the consultation paper – effectively as a ‘given’) something very close to a private sector monopoly will be created.
- Safety considerations – not only for those who fly but those living under flight paths. What would happen if a plane crashed over a densely populated area? With a proposed 54% expansion of flights over London, the escalation of terrorist incidents and by the simple law of averages the Government is taking an enormous risk with peoples’ lives on this issue.
The consultation paper seeks to downplay aviation’s environmental impacts. When it refers to this consideration it invariably follows the DfT’s stated priority which is to support growth of the sector.
To make the industry work for the country a different starting point is required in establishing future aviation strategy. Health and environmental constraints must be defined as the first step and policies and regulation framed around these.
To address this the strategy should be contain a commitment to establishing at the outset an independent, impartial and robust evidence base with specific research addressing the impacts on people and the environment caused by aviation. Aviation should then be required to operate within limitations set having regard to its impacts. In no area of economic activity apart from aviation are the interests of private sector organisations and foreign investors put before those of UK citizens or the nation’s environment.
The Government has commissioned no independent, original or impartial research into the impacts of aviation although it is known to cause serious detriment to health, wellbeing, productivity and child development arising directly from its side effects. The UK has consistently failed to apply World Health Organisation (WHO) guidance and has no air quality plan conforming to international standards. This is despite the UK being a densely populated nation and already accounting for approximately 40% of all aviation impacts in Europe.
By way of illustration TAG has produced a critique of the Health Impact Analysis undertaken by the DfT in coming forwards with the NPS. This is attached as Appendix A.
Although the consultation paper acknowledges increasing public sensitivity to aviation noise it proposes nothing to address this; in fact the implications are ignored.
The DfT’s approach towards assessing noise impacts in relation to Heathrow expansion has been strongly criticised by the Parliamentary Environmental Audit Committee (EAC). Whilst highly questionable assumptions about quieter planes and fleet transition are made no allowance for greater public sensitivity is reflected in the NPS evidence base; the opposite is the case as an assumption of quieter planes in future is not applied to the do minimum base case. In addition, inconsistent assumptions are applied between anticipated economic benefits (based on optimistic carbon traded growth forecasts) and noise (limited growth on the basis carbon capping will apply). Again, for illustrative purposes, a summary prepared by TAG highlighting the flaws in the NPS’s approach to noise is attached – Appendix B.
Instead of commissioning independent and impartial research the DfT instructed the pro-aviation (and almost entirely industry funded) Civil Aviation Authority (CAA) to undertake a Survey of Noise Attitudes (SoNA). The survey was undertaken in 2014 but the report not published until mid 2017. TAG considers this research is technically deficient, essentially seeking to sweep the problems caused by aviation under the carpet through inappropriate population sampling, a continued bias towards average noise metrics, the use of opaque logarithmic scales (which are unintelligible to the general public) and unreliable noise modelling.
The averaging approach to noise measurement (bringing down ‘headline’ levels by merging periods when areas are overflown with periods when they are not) is still advocated by the DfT and CAA as the future primary metric. This approach has been challenged by the WHO and severely criticised by the Australian Senate Select Committee following a public outcry after the opening of a third runway in Sydney. The Committee found that Sydney residents ‘felt they had been misled by the use of noise contours’ and declared that ‘once noise reaches a level high enough to be intrusive, the level of noise beyond would be irrelevant. This relates to the relative importance of the frequency of noise events against the loudness of individual events in determining annoyance’.
A summary of criticisms of SoNA is included as Appendix C.
Sustainability – achieving balance and complying within international obligations
Underlying the approach set out in the proposed aviation strategy document is a failure to address climate change, linkage to other modes of transport or achieving national economic balance.
Aviation should fit within the context of an overall national transport strategy. Airports rely very heavily on being accessed by car and generally are poorly connected by public transport. Heathrow is a prime example of this, with very little connectivity at a national level to rail for passengers and freight alike. It is most surprising that under the new strategy the DfT sees a principle benefit of Heathrow expansion being an enlarged national freight hub. This is notwithstanding Heathrow has no rail freight interchange and the motorways serving it (the M25, M4, M3, M40 and the M1) are already full. In fact, its non-central location is not easily accessible to most of the UK at all.
Critically the EAC concluded that if Heathrow is expanded, to comply with international carbon agreements in relation to climate change, permissible growth at other UK airports will either have to be limited or capped at the existing level (https://publications.parliament.uk/pa/cm201617/cmselect/cmenvaud/840/84003.htm#_idTextAnchor005). No reference is made to this consideration in the consultation paper. The result if the NPS is approved will be to concentrate future economic (and aviation) growth in London and the south east, notwithstanding a pressing need to rebalance the economy between London and the South East and the regions.
It is simply not appropriate to start considering the UK’s aviation growth strategy without addressing the fundamental question of how best to achieve a balanced national economy – within the context an integrated and sustainable national transport plan and international obligations in relation to carbon emissions. However, the aviation strategy consultation paper makes it very clear that the expansion of Heathrow has been considered in advance of considering these issues.
Treating people fairly
There is no doubt that many people find it very difficult – and in many cases impossible – to live under incessant aircraft noise (which is known to cause stress and sleep disruption). The Government’s current stated policy is to concentrate aviation noise so that the number of people ‘significantly affected’ is apparently minimised. However, this is based on the averaged noise measurement approach (criticised by the WHO and the Australian Select Committee) and artificially high thresholds which can be used to ‘gerrymander’ the numbers and misrepresent the real impact of aviation.
Notwithstanding this, the DfT and the CAA are still wedded to an averaging approach – as noted it is proposed as the primary metric in the latest airspace management proposals (also subject to consultation this year). This can be explained by the fact that if alternative approaches are adopted, very much greater numbers of people will be seen to be severely impacted in the UK already. The Government would be exposed as having a major problem on its hands even without expansion.
The worst aspect of the current concentration policy however is that it will result, particularly using new ‘satnav’ Performance Based Navigation (PBN), with people living under concentrated routes who will be affected to an extreme extent (far in excess of internationally recognised thresholds). Wherever PBN has been introduced around the world in populated areas it has met with universal opposition from communities and this has resulted in mass protests and successful legal challenges.
The consultation paper does not address these issues directly but makes passing reference to ‘fairness’ as it contemplates the scale of intensification now envisaged. In reality concentrated zones are likely to lead to areas which are unfit for human habitation – described even by the CAA as ‘noise sewers’.
In these circumstances, it is unfair and unreasonable that citizens should bear the burdens of aviation’s activities. To redress the problems caused by the industry the Government should accept that far more generous compensation schemes will be necessary than are currently proposed – including that properties affected significantly by aviation blight (at noise levels measured in accordance with fully independent international standards such as WHO guidance) should qualify either for comprehensive noise insulation schemes or purchase under blight notices served on whichever airport is primarily responsible for the generation of the pollution.
NPS – Health impact Issues – TAG commentary
- As acknowledged by the consultants employed by the DfT to consider health issues in relation to the NPS, a full Health Impact Assessment (HIA) on the effects of a third Heathrow runway has not been undertaken as there was insufficient information available on the proposed scheme. Instead a health impact analysis was carried out. It is irresponsible of the Government to support a third runway until the health impacts are properly understood and in particular a comprehensive HIA has been completed.
- It is highly inappropriate that the health impact study was carried out by an engineering consultancy firm whose stated business objective is to “plan, design and manage airport development projects”. There is a clear conflict of interest and motivation to play down the possible adverse impacts of expansion. It should instead have been led by either the Department of Health or Public Health England as the government bodies with responsibility for public health, given an expanded Heathrow will impact more than a million people.
- The health impact study identifies a range of very serious health and air quality impacts associated with expansion, but admits that a targeted stakeholder consultation (involving the people who are at the greatest risk of suffering these impacts) has not been undertaken. This is a major shortcoming of the consultation and the reason why this stakeholder engagement did not take place has not been explained.
- The health impact analysis acknowledges that a large number of those most affected by the expansion schemes are unlikely to benefit from the opportunities provided. The main NPS consultation document fails to disclose this critical fact. It is also unclear how the mitigation proposals put forward by London Heathrow clearly link to the health impacts identified within the health impact analysis.
- The health impact study included within the NPS consultation is based on unreliable noise contour maps produced using outdated and discredited methodologies. These flawed methodologies have been highlighted by the Environmental Audit Committee but have still been used to create maps and projections that seriously underestimate the number of people currently affected by Heathrow operations and the increased population who will be adversely affected by a third runway (for example all of Teddington and much of Twickenham, as directed by the CAA, was excluded from the Airports Commission’s Study Area). The affected population assessed as part of the NPS’s health impact analysis has been grossly underestimated, undermining its findings.
- The health impact analysis identifies a range of serious adverse impacts of a third runway including reduced life expectancy, huge numbers of people exposed to unacceptable NO2 emissions and much increased annoyance due to aircraft noise. These impacts have potentially significant and widespread implications for public health for tens of thousands of people. Incredibly, there is no mention of them in the main NPS consultation document which is a major omission and could give rise to accusations that the DfT is seeking to mislead the public by failing to clearly identify these impacts.
The effects of a third runway at Heathrow are assessed as moderately adverse for health outcomes and major adverse for children’s cognitive development. Yet despite this, the DfT as part of the NPS consultation has failed to give sufficient weight to these very serious impacts, or even to make it a condition of any shortlisted scheme that specific and proven mitigations are introduced which ensure that there is no increase in adverse health and educational impacts. This is a major failing of Government
NPS – Noise issues – TAG commentary
Noise impacts should be reviewed as part of the reopened consultation on the NPS.
The Parliamentary Environmental Audit Committee found in February 2017 that the DfT’s NPS and the Airports Commission’s (AC) evidence base is out of date and unreliable.
- The NPS fails to apply the metrics now proposed in the DfT’s own draft Airspace Management strategy. The NPS’s noise assessments are based on thresholds and metrics that are not supported by WHO guidance, international best practice or now even the DfT itself.
- The NPS is inconsistent and unbalanced. It uses cautious carbon capped growth assumptions relating to noise but optimistic carbon traded projections for estimating the economic benefits.
- Using inconsistent and unsustainable assumptions, the NPS reaches the incredible conclusion that an airport expanded by a third runway will affect fewer people with noise in future. However, whilst the DfT and CAA admit public sensitivity to aviation noise is increasing they still compare current levels of modelled noise from the existing two runway Heathrow against an expanded airport with 54% more traffic – but assuming the aircraft fleet will be around 30-50% quieter in future.
- The CAA is charged with facilitating aviation expansion and therefore cannot be regarded as either independent or impartial in relation to environmental impacts. Notwithstanding this it oversaw the AC’s work and is responsible for all noise modelling used by the AC and DfT.
- A study undertaken in 2016 for Heathrow by independent Dutch consultants, NLR, found significant discrepancies between modelled and measured noise using the CAA’s ANCON model. For this reason alone, the analysis produced by the AC cannot be relied upon.
- Notwithstanding the CAA’s conflicted role, the DfT commissioned it to undertake the 2014 Survey of Noise Attitudes (SoNA) in relation to aviation. Apart from being based on the unreliable ANCON model, SoNA reveals other serious deficiencies including unjustified demographics weighting (e.g. 50% of people surveyed lived in rented accommodation), six months’ delay between survey timing and the period it related to and conclusions that don’t correspond with the actual findings of the survey.
- The DfT has suggested the noise impacts can be dealt with through the planning process – after Parliament has approved the expansion in principle. This is totally unrealistic. The planning application for a third runway will cost £100 million or more to prepare. If the NPS is approved, it will be extremely difficult (if not illegal) for the Government to turn back for political, technical and financial reasons.
For these reasons, TAG considers that noise – along with health – should be re-examined prior to any final decision on the NPS.
TAG criticisms of the Survey of Noise Attitudes (SoNA)
The CAA has a central role in expanding capacity but has also been solely relied on by Government in undertaking research into the public’s attitude to aviation noise. Notwithstanding the inherent conflict of interest, in preparation for the NPS and the review of Airspace Management, the CAA undertook SoNA based on a 2014 survey, the findings of which were only published in mid 2017. There are fundamental issues with SoNA that are indicative of a clearly apparent pro-aviation bias:
- The demographics of the aviation survey sample differ markedly with other surveys undertaken directly under the supervision of DEFRA. Within SoNA there are very high proportions of apartment rather than house dwellers and renters (many social) rather than owner occupiers. No reasonable justification for departing from demographics of comparable public attitude surveys (relating to other transport modes) or consideration of the implications is given.
- The survey was undertaken in winter (when people were indoors) although the questions (which apparently were designed not to highlight noise from aviation) relate specifically to the previous summer period.
- The conclusions drawn within the SoNA report do not correlate well with the survey findings. The analytic techniques are opaque and complex but in any event don’t appear to fit any better than alternative conclusions – such as which metric has the best fit and whether the use of overall long term averages are appropriate.
- SoNA is not founded on any empirical health or independent social research.
Despite these criticisms of SoNA, the DfT is now proposing lower thresholds and to consider alternative approaches. However, the international research shows that they have not moved far enough.
To address these issues the following steps should be undertaken:
- The government should commit to have regard to WHO guidance in its decision making wherever possible in relation to general aviation policy and expansion options.
- As aviation benefits everyone the burdens of expansion should be shared on a fair and equitable basis wherever possible. This principle should be at the cornerstone of UK aviation policy.
- A new system of noise metrics should be devised by truly independent experts and adopted for decision making. These metrics should focus on times when areas are overflown – not overall averages that conceal the real impact.
- Based on international research, numbers of noise events above specified thresholds should be considered to become the primary benchmark for judging airspace changes or airfield development. The existing long term average Laeq system is highly misleading as well as incomprehensible to the public.
- The use of the ANCON model (which has been shown to be inaccurate in measuring peak noise levels) should be questioned and fully independent and internationally accredited noise models used in all aviation decision making.