23rd January, 2012
The CAA has published for consultation its first ever environmental strategy programme, setting out in a 50-page document areas in which its work already has relevance for environmental objectives, and those where it considers it could play a greater role in future. It follows the publication by CAA of three Insight Notes, which make a series of policy recommendations for Government – Aviation Policy for Consumers, Aviation Policy for the Environment, and Aviation Policy for the Future – the unifying theme of which is a call for increases in airport capacity.
In the case of the Environment note, environmental impacts are – rightly – described as imposing a possible brake on airport development. But the measures proposed by the CAA for tackling them fall a long way short of what AEF believes is necessary.
In relation to climate change, for example the CAA notes that UK aviation emissions have doubled since 1990 (while most of UK industry has been cutting its emissions), and that to achieve the ICAO target of 2% per annum efficiency improvements “further, faster progress will need to be made over the coming decades”, given that since 2000 the improvement rate has been around 0.6% per annum. Yet it opposes the national emissions cap for the sector (requiring stabilisation of emissions at 2005 levels) that was put in place under the last Government. This could help to drive the faster efficiency improvements that CAA wants to see, and reflects both industry forecasting of its own emissions trajectory and modelling from the Committee on Climate Change.
On noise, the CAA notes that despite improvements over time in terms of the numbers of people affected by high noise levels measured in Leq terms, many people continue to report high levels of annoyance, and night noise can have tangible impacts on health. But it makes no reference to the range of studies now showing clearly that aircraft noise annoyance is increasing over time, even as Leq contours are shrinking – evidence that increases in the number of aircraft passing overhead (which Leq does not reflect well) matter to people more than marginal reductions in the volume of individual planes. The CAA’s recommendations that noise-affected communities might be appeased through discounts in airport shopping precincts or car parks (page 36) are a very long way from the protections those communities tell us they want and need.
AEF welcomes the fact that the CAA is beginning to engage actively in environmental issues, and we have supported proposals that the organisation’s legal remit be reformed to allow it to take into account environmental considerations when exercising its existing functions – a reform that the draft civil aviation bill published recently would abandon. Yet we have always argued that CAA’s role as regulator should be to deliver environmental goals set out by Government, and to advise on technical issues when requested to do so. The CAA’s consultation on its own environmental role expresses a similar vision, stating ‘We will use our expertise to develop and test new ideas, and work to ensure the evidence base for policy development is clear.’
To be blunt, the CAA’s expertise does not extend to aviation’s impact on the UK economy, carbon leakage, or community experience of aircraft noise – all issues on which its environmental insight notes give advice. AEF will of course respond to the CAA’s consultation on its environmental strategy. But statements to Government and the press on wider policy matters are unlikely to be an appropriate part of it.