Department for Transport ‘The future of UK aviation: A call for evidence on a new strategy’


Response from West London Friends of the Earth


Responses to questions as listed on pages 77-79 of the consultation document follow.


Q1.  Nic Ferriday ;


Q2.  I and my organisation are concerned about the environmental effects of aviation (which affect everybody).


Q3.  I am responding on behalf of West London Friends of the Earth


Q4.  We do not consider that it is meaningful to simply rank these “policy challenges” in order.  It is not meaningful, for example, to simply say that “keeping pace with consumer expectations” is more or less important than “maintaining high levels of safety and security.”  One would expect to meet both of these objectives to some extent but not totally and there are policy decision to be made about, for example, the balance between thoroughness of security checks and the residual risk.


We do not accept “meeting increasing demand through sustainable growth” as a meaningful or adequate policy or policy challenge. With no definition of “sustainable growth” it is not meaningful.  And without any direct reference to environment, for example air pollution, noise, climate change human life, health – all of which are at risk – the policy is inadequate.


Q5.  We do not consider that “support growth while tackling environmental impacts” is acceptable.  Simply “tackling” is not enough – we need to ensure that environmental limits, such as WHO noise recommendations, legal air pollution limits and the UK climate targets - with consequential protection of life, health and quality of life for society at large – are met.


Q6. We do not agree a policy “consumer focused – it will put passengers and businesses at the centre of everything we do”.  We consider the aviation policy should be focused on benefits and impacts on society as whole, not just the consumers of air travel.  We consider that impacts on those do not fly and on everyone when they are not flying are just as important as the interests of consumers.


We agree that policy should be “evidence led”.  However, this consultation is not. The consultation document starts with the premise that there should be apparently unrestricted growth and then adopts hype, sound bites, and slanted statements to support that policy.  For example, claims are made about the benefit of inbound tourism to the UK (para 1.7) but no mention is made of the fact that outbound tourism takes far more money out of the country.  Huge economic benefits of aviation are claimed but no supporting evidence is cited.  Economic benefits of existing levels of air travel are conflated with benefit in ever-increasing levels of air travel.  No mention is made of the fact that a very small proportion of air travel is long-distance business such that trade beyond Europe is a very minor user of air travel and thus does not need significant increases in capacity.   


Q7.  We would support these policy tests but would wish to see the policy evaluated against these tests by someone independent of DfT and government.  Otherwise DfT, under direction from the minister, will simply be able to claim that whatever policy is chosen meets these tests.


Q8.  The government policy is patently not to “support airports throughout the UK making the best use of their existing runways”.  The government policy to build a third runway at Heathrow means there will be 18 to 52 million passengers less per annum by 2050 at airports outside London than there would be without a new runway.  (Figures derived from UK aviation forecasts, published as part of the Airports Commission final report.  Calculations available on request.)  Building a new runway at Heathrow when there is masses of spare capacity at every other airport in the country (except Gatwick) does not appear to be “best use” of UK airports.


Q9.  Basic questions about how to manage environmental impacts are not considered in this policy, which supports growth everywhere and proposed minimal government intervention.  We profoundly disagree with this ‘growth at any cost’ approach.


Q10, 11.  The government should use the extensive evidence available on noise, air pollution and climate change, of which it is already aware.


Q12, 13.  No comments.


Q14.  Supply balanced and unbiased information about the issues.  (We do not consider, as Sir Jeremy Sullivan claims, that it is acceptable to slant the consultation material to support the government’s policy.)


Q15.  Yes.


Q16.  Yes:

·        Health, quality of life and economic impacts of noise, air pollution and climate change from the proposed aviation policies.

·        Inequality, insofar as affluent to wealthy people are the main consumers of air travel while poorer and disadvantaged people suffer most of the impacts.

·        The fact that growth in air travel is being stimulated by tax exemptions such as tax-free fuel.  This distorts the economy in favour or excessive air travel and is inequitable because it benefits mainly the affluent.


Q17.  It is very apparent from this consultation that environment is being given a very low priority.  There is no proposed limit on environmental impacts of any type, especially noise, air pollution and climate change.  This is highlighted by “support growth while [merely] tackling environmental impacts” (see our response to Q5).  It is also highlighted by the fact that the government’s ‘Clean Growth Strategy’ was published on the last day of the aviation strategy, meaning that issues arising in the clean growth strategy could not be related to aviation in the consultation.


There is now a body of evidence which shows that noise affects health as well as reducing their quality of life by virtue of disturbance and annoyance.  This being so, there ought to be specific policies in the strategy to prevent increase in exposure and preferably to reduce it.  The most obvious policy would be meet WHO (World Health Organisation).  


The section on air pollution (para 7.13) only discusses measures which may help with reducing emissions from individual aircraft.  This omits the key issue of the effect on people, specifically pollution levels in the air people breathe and aircraft’s contribution to it.  With an estimated 29,000 people dying every year from particulates alone, this is a big issue.  There should be a policy to ensure that aircraft and airport-related emissions do not cause legally air pollution limits to be breached.   


Since the Climate Act was passed, the inclusion or other of aviation in the targets has been a grey area.  We see no evidence for the unequivocal statement in 7.16 “Emissions from international aviation (along with international shipping emissions) are currently excluded from the legally-binding 2050 target which was set by the Climate Change Act 2008”.  Nor is there evidence to support the statement in 7.17 “so that the UK is on a trajectory that could be consistent with a 2050 target that includes these emissions.”  The Committee on Climate Change (CCC) considers that emissions from UK aviation need to be limited to 37.5 million tonnes (mt) of CO2 at 2050 for the UK to be able to realistically meet its target reduction (80%) of CO2 and then only with great difficulty.  The DfT/Airports Commission, which were published as part of the case for a third runway at Heathrow, show that even without new runway capacity anywhere else, the 37.5mt would be exceeded.  The aviation strategy, being more pro-growth than the Airports Commission, implies even higher CO emissions.  It is obvious is therefore that the government has no intention of including aviation in its climate target (or of meeting the target if aviation is included).  As climate change is perhaps the biggest threat to us all, Friends of the Earth objects strongly to omitting aviation emissions.  We do not accept the bogus argument that aviation is international so that it can be left to ICAO and other international institutions (para 7.35-37) to deal with the problem. 


Aircraft flying at altitude emit greenhouse gases, especially NOx and water vapour.  (These are also emitted by surface transport but do not act as greenhouse gases at ground level.)  The climate change effects are less well characterised than those of CO2 but a fairly conservative estimate puts the effect of NOx and water vapour as 60% of the effect of CO2. (see ).


                                                                                                                                    15 October 2017