Birmingham Friends of the Earth has submitted evidence to the DfT’s consultation on Developing a Sustainable Framework for UK Aviation.

Our evidence is submitted in the form of a report, which is not always structured in the same way as the questions are asked in the DfT’s document, but covers the following questions directly when possible, but in order to maintain the flow of the argument, some also implicitly. Our comments should be viewed as supporting those from FOE EWNI and within this contribution we attempt to draw out some of the specifics that relate to Birmingham Airport and its catchment area.

Here are some very brief answers to the questions as a summary:

The aviation sector


How does the aviation sector as a whole benefit the UK? Please consider the whole range of aviation activities including, for example, air freight, General Aviation and aerospace.

We feel that others will highlight benefits, but that these will not be adequately balanced with the disbenefits, either in terms of carbon and other greenhouse gas emissions, environmental problems, noise or in terms of money lost from the economy through outbound tourism. Business investment by British firms abroad is also higher than that of foreign firms travelling to the UK.



What do you consider to be the aviation sector’s most important contributions to economic growth and social well-being?

The sector’s most important positive contribution is in permitting essential or important international connectivity, particularly in support of economic activity. Its most important negative contribution is the growing proportion its climate change emissions are forecast to make of the UK carbon budget. This negative contribution substantially qualifies (if not actually overwhelms) the positive one, principally because it then imposes additional emissions reduction burdens on all other economic and social sectors. The appropriate policy response should be an appropriately constraining framework, achieved principally by price and regulatory levers.



How, and within what constraints, can aviation growth occur as technological developments and improved operating procedures reduce CO2, pollutant emissions and noise impacts?

Aviation should only be able to grow on the basis of scientifically proven certainty of what is possible technologically. So far, the industry has not lived up to its promises to make planes more efficient, so before we allow growth, there must be evidence of an ability to operate within legally binding carbon emissions reduction targets and not unfairly shift the burden onto other industries to make deeper cuts.


Regional connectivity and regional airports


Can regional airports absorb some of the demand pressures from constrained airports in the south-east? What conditions would facilitate this?

Birmingham could be in the frame for huge expansion as an emerging London facility to make up for some of the lack of capacity in the South East. If this does happen there need to be extra levers to enable local people to exert some controls over the expansion of operations at Birmingham, whether that be in the form of physical expansion or operational times and surface access. There also needs to be a real effort to provide jobs for local people in areas of deprivation. This means improving sustainable transport links to residential areas from which potential employees could travel.

Preferable would be constraining the number of flights to meet environmental limits. If this is done through other methods than just airport capacity, there may not be a need for so much extra demand.



What more can be done – and by whom – to encourage a switch from domestic air travel to rail?

Price is the main issue that means air travel has an unfair advantage over rail. The aviation industry pays no tax on fuel, which gives it an unfair advantage, so this “subsidy” should be removed for all internal flights. On journeys with a direct line, rail can compete very well with air, but new rail infrastructure should be designed around getting from city to city not airport to airport. Business jets and internal flights across mainland Britain could be charged an additional levy to discourage their use.



How can regional airports and the aviation sector as a whole support the rebalancing of the economy across the UK?

As the aviation industry contributes to a massive tourism deficit in most regions, it is very unlikely to help at all in rebalancing the economy. Constraining it and encouraging domestic tourism would have a much more positive effect on regional economies.


Making better use of existing capacity


To what extent do UK airports meet the needs of their customers? How might those needs be more effectively met within existing capacity? What is the right balance between competition and regulation?

We would argue that “need” is a difficult term to define when it comes to air travel. Do customers need to fly, or are they doing so because the price of air tickets does not reflect the true cost of the activity? For true competition between different forms of transport, there needs to be transparency in taxation, mitigating the negative effects of the activity and subsidy levels.



Can we extract more capacity out of the UK’s existing airport infrastructure? Can we do this in a way which is environmentally acceptable? To what extent might demand management measures help achieve this?

The constraints should reflect environmental limits as well as capacity issues at airports. Building more infrastructure should not be considered while emissions from aviation are still rising. Once demand management measure and transparent taxation of the industry has been introduced, the true level of demand for aviation will be easier to assess.


Climate change impacts


What do you consider to be the most significant impacts of aviation, including its non-CO2 emissions, on climate change? How can these impacts best be addressed?

The fact that emissions occur at a higher level and this is generally considered to increase their effect (the radiative forcing index) must not be ignored any longer. If aviation emissions are allowed to continue to grow, far



What role should aviation play relative to other sectors of the economy in reducing greenhouse gas emissions in the medium and long term?

There is no justification for the aviation industry being treated differently from all other sectors of the economy, so we would call for this to end. Higher aviation abatement costs should be passed through to customers in the form of higher prices, and this in turn will act as a perfectly appropriate demand management and automatic emissions stabiliser mechanism.



How effective do you believe the EU ETS will be in addressing the climate impacts of aviation? Should the UK consider unilateral measures in addition to the EU ETS? If so, what? 

As the EU ETS will not introduce a carbon price that represents the actual social cost, the UK should consider unilateral measures in addition. This can be done via inclusion in the UK carbon budget.



What is the best way to define and quantify the UK’s share of the CO2 emissions generated from international aviation?

We follow the CCC 2009 report approach, but with the inclusion of at least an indicative figure for non CO2 effects – see question 5.30 above. 



What is the potential for increased use of sustainable biofuels in aviation and over what timeframe? What are the barriers to bringing this about?

Friends of the Earth is in favour of research into new ‘green fuels’ – as long as the cost is met by the industry without public subsidy – but that actual deployment should not be promoted by public policy until such time as the research demonstrates both sustainability and scalability. Currently, we have major concerns over indirect land use change not being taken into account when assessing the carbon and overall environmental impact of biofuels.



What more could be done to encourage the aviation industry to adopt new technology to reduce its climate change impacts?

If the targets to reduce its climate change impacts are in place, the industry will have to find the way to meet them, otherwise, as with any other industry, it will be unable to operate.


Local impacts


What do you consider to be the most significant impacts – positive and negative – of aviation for local communities? Can more be done to enhance and / or mitigate those impacts? If so, what and by whom?

One of the main negative impacts is the re-direction of public subsidies away from projects that could benefit the local community and stimulate more economic activity into building infrastructure for airports. Such subsidies should be re-examined.

Noise impacts and pollution will be covered in much more detail by other respondents, so we would only agree with the submissions by residents groups around busy airports, such as Heathrow and Gatwick who experience the kinds of levels of noise and pollution Birmingham will experience if expansion takes place as predicted.



Do you think that current arrangements for local engagement on aviation issues, e.g. through airport consultative committees and the development

of airport master plans, are effective? Could more be done to improve community engagement on issues such as noise and air quality? If so, what and by whom?

There needs to be a ‘fit for purpose’ review of the consultative committee and air transport Forum arrangements, driven by principles such as ‘independence, accountability and transparency’, probably with the local authority entrusted with the ‘independence’ leadership role, and with the airports stripped of their de facto ability to steer these processes in their own interest.

Our experience shows that there are considerable issues with the current system and the accountability of airport-controlled committees regulating their own activities.



Do you think that current arrangements for ensuring sustainable surface access to and from airports, e.g. Airport Transport Forums and airport surface access strategies, are effective? Could more be done to improve surface access and reduce its environmental impacts? If so, what and by whom?

See 5.41 for the question regarding Forums and question 5.17 on surface access for those seeking to work at airports.



What is the best way to encourage aircraft manufacturers and airlines to continue to strive to achieve further reductions in noise and air pollutant emissions (notably particulate matter and NOx) through the implementation of new technology?

We see three main ways this could be done;

  • Reducing the retirement ages below the DfT standards.

  • Imposing retro-fitting standards.

  • Imposing higher fuel burn improvements that follow the lower forecasts rates in the DfT forecast.