This is the DfT Form upon which we have put our responses. The form must be filed by Thursday the 20th June 2019. Details on Government website at:
Aviation 2050: the future of UK aviation
1. Your name and email address (only used if we need to contact you).
2. Are you responding as:
|an individual? (Go to section 4. Chapter 2: Build a global and connected Britain)|
|X||on behalf of an organisation? (Go to 3. Organisation details)|
3. What organisation do you work for?
|Teddington Action Group|
4. What type of organisation is this?
Chapter 3: Ensure aviation can grow sustainably
17. This section contains questions on chapter 3 of the consultation document – Ensure aviation can grow sustainably. Which of the following topic areas are of interest to you as an individual or to the organisation on behalf of which you are answering? (choose all relevant options)
|X||A partnership for sustainable growth|
|X||Sustainable journeys to the airport|
18. To what extent does the proposed partnership for sustainable growth balance realising the benefits of aviation with addressing environmental and community impacts?
| We do not believe that it does for a number of reasons.
The partnership depends on the outmoded hub concept rather than point to point. A hub increases emissions and CO2 into the atmosphere due to the longer journeys required. The Transport Committee also showed that Heathrow expansion into a larger hub will reduce the choice of destinations from Regional airports, thus further increasing distances of travel. The proposed partnership contains no details or substance of how the environment or communities will be protected. As stated in our previous submission, there is no part of the aviation industry that takes responsibility towards the communities or for the environment. There is at present nothing to balance
On noise, the para 3.19 states that “The government recognises that while airspace modernisation will bring noise benefits for many people, it could create increased noise for others”. This is misleading since there is likely to be an increase in the total number of people affected by noise as is shown in the CAA Doc CAP1731 – the number of people highly annoyed by daytime noise will rise from 173,000 to a predicted 182,500 by 2030. In addition these figures are likely to be significantly underestimated due to the SoNA study ignoring changes in the noise profile or people becoming increasingly annoyed due to an alteration in the amount of noise.
SoNA is being used by the DfT in their decision making for Heathrow expansion. SoNA is inadequate, misrepresentative of the effects of noise, and leaves out certain vital factors. SoNA sampling was “designed such that one-third of the interviews were carried out in the 51 – 54 dB LAeq,16h band, and two-thirds for noise exposure in the >54dB LAeq, 16h band (stratification based on estimated population numbers falling within these bands).” The number of interviewees was 1,877 “in close proximity to the airport”. They were therefore already subject to extensive noise. Compare this to the World Health Organisation Guidelines both of 2009 (Night Noise) and 2018 and the difference is startling. The Lowest Observed Adverse Effect level is below 40 dB at night and 45 dB in the day rather than 51 dB now adopted by the Government and there are marked adverse effects from the change in noise environment, which SoNA did not consider. The Night Noise Guidelines of 2009 refer to cardiac problems starting at 50 dB LAeq. WHO went into detailed medical analysis and had a sample base of “nearly 37,000 citizens from all EU Member States and the five candidate countries (Albania, Montenegro, Serbia, the former Yugoslav Republic of Macedonia and Turkey).”
Last week the minister Michael Ellis stated in Parliament that SoNA had been used as the evidence base for aircraft noise but “My Department forms part of the Interdepartmental Group on Costs and Benefits (Noise), which has been convened to review its current guidance and consider whether any updates are necessary. The Group will give careful consideration to the evidence base for the WHO Guidelines”
Performance Based Navigation (PBN) is being introduced with no study of the effects that concentration of low flying aircraft has upon people on the ground. It has been universally condemned throughout the World by residents’ groups.
Communities therefore have not received one iota of benefit from “progress” and if SoNA is followed will not in the future.
19. How regularly should reviews of progress in implementing the partnership for sustainable growth take place?
|The concept of review is false. The Strategy suggests regular reviews in the light of climate change targets. However, is the Government seriously suggesting that following a review an airport is going to have its activities curtailed with all the consequent damage to the prior investment? That is simply not credible. A proper and full analysis of the effect of national aviation activity has to take place before development, and subsequent growth allocated and constrained in certain areas in accordance with a pre-determined plan.
In the absence of an accurate plan, reviews should not only take place at every carbon budget review but also at every breach of air quality. If that is thought unreasonable then the growth should not be started at the particular airport.
Proper noise limits have to be set, as set out by the World Health Organisation, rather than SoNA. Those limits must be observed for the growth to be sustainable. The noise reduction figures set out in paras 3.102 et sec are not accepted. Nor is it accepted, as set out in the CAA’s analysis that a change in the amount of noise or the pattern of noise does not, of itself, bring about aggravation
20. Are there any specific ‘triggers’ (e.g. new information; technology development etc) that should be taken into account when planning a review?
· CCC review or budget
· Breach of air quality limit
· Breach of noise limit
The questions in the section below refer to policy proposals contained in chapter 3 of the consultation document – Ensure aviation can grow sustainably. As with the rest of this consultation, you are welcome to respond to any, all or none of the questions in this section.
21. How could the policy proposals be improved to maximise their impact and effectiveness in addressing the issues that have been identified?
|The policy proposals are nothing like strict enough. The WHO Guidelines show that significant annoyance from noise can start from as low as 40dB at night and 45dB during the day. It is thus completely inappropriate not to bring in noise insulation until 60 dB and to only set a new minimum threshold of an increase of 3dB LAeq, which leaves a household in the 54dB LAeq 16hr contour or above as a new eligibility criterion for assistance with noise insulation. Even on the Government’s own figures (which do not comply with WHO Guidelines) the annoyance level starts at 51 dB
Proposing new measures to ensure better noise outcomes from the way aircraft operate is positive but do not go far enough. As shown by the research carried out by the ICAO documented in ICAO Doc 9888, steep departures can dramatically reduce the noise footprint but there is no provision for this in the Strategy 2050
22. How should the proposals described be prioritised, based on their importance and urgency?
2. Increase powers for ICCAN
3. Adopt WHO standards
4. Best practice operating code with punishments for infringement
5.Extend noise insulation to areas down to 45 dB
6. Set rules on breach of air quality. Air quality is law and any operations that breach should trigger an immediate necessary diminution of operations until the limit is met. Paragraph 3.125 shows that it quite plainly wrong to depend on organisations such as “Sustainable Aviation” (whose membership is from entirely within the aviation industry). Other studies have shown the elevated levels of NOx and Ultra Fine Particles emitted from aircraft up to 40 kilometres from the airport boundary. The Strategy is built upon erroneous assumptions in paragraph 3.125
7. Greenhouse gas emissions targets for individual airports have not been mentioned
23. What implementation issues need to be considered and how should these be approached? (e.g. resourcing challenges, high levels of complexity, process redesign, demanding timelines)
|PBN; we have made statements on this in our prior submissions. There is not a single instance of PBN/Nextgen being welcomed by community groups and this represents one of the biggest challenges|
25. What are the regulatory burdens that need to be managed and how might these be addressed?
|Noise and emissions need to be managed. It is a matter for the industry and Government to manage them|
26. Are there any options or policy approaches that have not been included in this chapter that should be considered for inclusion in the Aviation Strategy?
| Yes;1. Noise to be to WHO standards
2. Emissions from planes should be properly calculated. The reality is that they have a significant effect (similar to being at the side of a motorway) for 20+ miles from the airport boundary see one study at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4215878/
3. Noise; the assumption is that aircraft are going to get quieter. However, on the Government’s own evidence that is not necessarily going to happen to any great extent – see the research of Southampton University produced as part of the Aviation Strategy 2050
27. Looking ahead to 2050, are there any other long term challenges which need to be addressed?
| Noise, emissions and climate change
Climate change is likely to be the biggest challenge and inevitably a contraction in the use of aviation will be required
The CCC has issued its Net Zero reports on the 2nd May 2019. The Government has responded by stating that it will amend the Climate Change Act 2008 to reduce Greenhouse Gas emissions to 100% below 1990 levels instead of 80%. However, carbon trading has been left in and international aviation and shipping have been left out. This is crazy and against the advice of the Climate Change Committee. The CCC has responded “The government has not yet moved formally to include international aviation and shipping within the target, but they have acknowledged that these sectors must be part of the whole economy strategy for net zero.”
It is imperative therefore that the Strategy includes aviation and its reduction of greenhouse gases. The Technical Report of the CCC states that
“The Further Ambition scenario allows for a 60% growth in passenger demand by 2050 compared to 2005 levels. Without additional policies being put in place government projections suggest demand could be higher than this (e.g. their central case is for around a 90% growth in demand by 2050 compared to 2005 levels). New UK policies will therefore be needed to manage growth in demand. These could include carbon pricing, reforms to Air Passenger Duty, or policies to manage the use of airport capacity. Recent research commissioned by the DfT176 shows that UK policies to manage demand in aviation would not lead to carbon leakage from the UK to other countries in aggregate, given the relatively small amount of emissions affected [that is on carbon leakage not overall greenhouse gas emissions]. Policies to manage demand can therefore be pursued without significant risk of perverse impacts.”
That DfT study 176 stated that: “In contrast, this study finds that leakage associated with passenger behaviour is usually negative. In this case, a decrease in emissions from UK aviation is matched by a decrease in emissions from non-UK aviation. This is because the main effect of a policy which increases UK-specific ticket prices is to decrease passenger demand to and from the UK. Although long-distance connecting passengers who use UK hub airports may switch to competing non-UK airports, the overall impact of this is small compared to the demand impact on passengers who start or end their journey in the UK. In 2015, there were more than twenty times as many passengers on itineraries which started or ended in the UK than passengers who used a UK hub on journeys which started and ended elsewhere.”
The Strategy needs to incorporate the advice of the Government’s own specialist statutory body and plan for a phased and orderly reduction in international aviation. This should be possible. The CCC states that “Given that in a given year half the population do not fly, and a quarter take two or more flights, this implies scope for rebalancing without removing opportunity to travel.”
It is particularly disappointing that the Government have chosen to close the consultation before the CCC has set out its recommended policy approach. The CCC has stated “A net-zero target will require more effort from all sectors, including aviation. The Committee’s advice is that a net-zero target for 2050 should cover all sources of GHG emissions, including international aviation and shipping. We will set out our recommended policy approach for aviation in follow-up advice to DfT later in 2019.”
Are you aware of any relevant additional evidence that should be taken into account?
Sustainable growth evidence
29. Please give a brief summary of the additional evidence that you wish to provide.
|The Government has consistently put the cart before the proverbial horse. This Aviation Strategy is published before the Committee on Climate Change has published all of its findings and recommendations. It is not appropriate to close the consultation on strategies such as this when the Government does not know what is and is not possible to carry out. See Manchester University research as part of Aviation Strategy 2050 and Committee on Climate Change Net Zero Contribution to Stopping Global Warming Report May 2019
The proposal that the Government should accept the CCC’s recommendation that emissions from UK-departing flights should be at or below 2005 levels in 2050 (para 3.87) has now been superseded by the CCC May 2019 Report
For Heathrow expansion, there is insufficient evidence of the health consequences of the extra noise and there is insufficient evidence that air quality can be compliant with the extra activity from both road traffic and aircraft.
1. Further report from the CCC to the Government on aviation
2. International aviation and the Paris Agreement temperature goals by David S Lee
3. Technology’s Influence on the Levels of Environmental Emissions from Aircraft and the Trade-Offs Involved – Review and Future Prospects by Rod Self of Southampton University
4. Health Impact Assessment on the effects of Heathrow expansion
Chapter 4: Support regional growth and connectivity
30. This section contains questions on chapter 4 of the consultation document – Support regional growth and connectivity. Which of the following topic areas are of interest to you as an individual or to the organisation on behalf of which you are answering? (choose all relevant options)
|Public service obligations (PSOs)|
|Start up aid|
|Air passenger duty|
|X||Surface access to airports|
|Regional employment and skills|
31. To what extent do these proposals provide the right approach to support the complex and varied role that airports play in their regions?
|The Government has failed to consider that the Transport Committee found that if Heathrow were expanded, the international flights from regional airports would fall as would the choice of destinations from those regional Airports.This will harm the Regional Airports ability to serve point to point (and even harm any large airports in the north from being their own hubs)
The Government has also failed to consider the extra distances that will be travelled due to its “Hub” concept and the effect on CO2 or total Greenhouse Gas emissions
36. What are the financial burdens that need to be managed and how might those be addressed?
|Aviation should make its proper financial contribution. The current level of demand is entirely artificially induced through preferential treatment. Para 4.28 states that “In line with ICAO rules, the UK does not tax fuel used for international or domestic flights and no VAT is imposed on ticket prices”. That is not correct. ICAO does not prohibit the taxation of aviation fuel on the ground purchased prior to delivery into the aircraft (it only prohibits taxing the fuel in the aircraft on entering another territory). Other countries (even the USA) tax aviation fuel. The EU does prohibit taxing aviation fuel under the Energy Taxation Directive 2003/96/EC, but the EU is perfectly free to alter this – as is the UK after leaving the EU. Much revenue could be raised, and demand constrained by insisting that aviation pays its proper dues. Aviation enjoys a totally unjustified advantage compared to other forms of transport. For example, considering the environmental damage done by a single flight, it is truly absurd that flying from London to Scotland or London to the west country is cheaper than taking the train|
38. Are there any options or policy approaches that have not been included in this chapter that should be considered for inclusion in the Aviation Strategy?
|Yes; tax aviation fuel and supplies|
39. Looking ahead to 2050, are there any other long term challenges which need to be addressed?
1. Demand versus supply that is sustainable
2. Allocation of Greenhouse Gas emissions amongst all London and Regional airports
40. Are you aware of any relevant additional evidence that should be taken into account?
Chapter 7: Support general aviation
65. This section contains questions on chapter 7 of the consultation document – Support general aviation. Which of the following topic areas are of interest to you as an individual or to the organisation on behalf of which you are answering? (choose all relevant options)
|Reducing regulatory burden|
|General aviation (GA) strategic network|
|Training and skills|
|Refreshing the GA strategy|
66. To what extent do these proposals strike the right balance between the needs of general aviation and the rest of the aviation sector?
|The cost of expanding Heathrow is quite disproportionate to the benefit. The Strategy states that income from air transport is some £14 billion per year. Heathrow expansion is estimated to cost £17.6 billion and may well be considerably more if TfL’s estimate on surface access costs is correct. It is high risk to sacrifice one whole year’s income from the entire air transport sector of the whole country on one project. Because of the terms of the “Relationship Framework Agreement” of June 2018 between the Secretary of State for Transport (1) and Heathrow (2), there is some risk to the public purse should certain events occur|
Chapter 8: Encourage innovation and new technology
76. This section contains questions on chapter 8 of the consultation document – Encourage innovation and new technology. Which of the following topic areas are of interest to you as an individual or to the organisation on behalf of which you are answering? (choose all relevant options)
|Digitalisation and data sharing|
|Public acceptance of emerging technology|
|Anticipating future developments|
|Aerospace sector deal|
|Improving cross government working|
77. To what extent are the government’s proposals for supporting innovation in the aviation sector the right approach for capturing the potential benefits for the industry and consumers?
| It is entirely right and proper that the Country should support innovation and to the extent that it includes electrification, then all to the good. What is not good is to make false assumptions and predictions. Heathrow are reported to have claimed that fully electric planes will be touching down at major international airports by 2030. Expert opinion is that is highly unlikely, and that electrification of commercial airliners is a long way off and should not be used at present in any plans for emissions reduction. In support of this the CCC’s Technical Report on May 2019 states that:
“There are options to improve fuel efficiency through new engine and aircraft designs. The engine measures we consider include more efficient iterations of conventional jet engines (e.g. ultra-high bypass ratio turbofans) and use of hybrid-electric engines. We also consider use of composite materials and high-aspect ratio wings in aircraft design. We do not include potential from open rotor engines, full-electric propulsion, or blended wing aircraft, all of which are judged to have significant barriers to delivery on a 2050 timeframe. Pure electric aircraft may be an option post-2050, particularly for short-haul flights, but will require breakthroughs in battery energy density to become a commercially viable proposition.”