AEF response to the Airports Commission’s draft Appraisal Framework
The AEF has responded to the Airports Commission’s draft Appraisal Framework. In our response, we highlight the need for more specific and measurable objectives which relate more specifically to the appraisal modules which outline how the environmental, social and economical impacts of the different expansion proposals will be measured. Here is a summary of our recommendations for some of our key issues:
We suggest modifying the objective to take into account the fact that the noise problem differs at Heathrow and Gatwick with many people being affected by aircraft noise under the Heathrow flight path but the impact of the aircraft noise being greater in the tranquil areas surrounding Gatwick.
We did welcome the Commission’s inclusion of a suite of noise metrics which would provide a better data set for analysing the noise impacts of each option than solely using the 57 Leq noise contour. However, we opposed the Commission’s decision to analyse the net national impact on noise for each scheme because localised nature.
We recommend that the objective should be broadened from “to protect local air quality” to include the need to keep air quality at or below legal limits to avoid harmful effects to human health.
In our response we emphasise the importance of including PM2.5 and Ozone in the list of pollutants measured, that the impact should be measured on a wide area around the airport and assessment should focus on health impacts.
We highlighted that legal requirements apply to biodiversity and should be included in the objective. We also draw attention to the impacts of expansion proposals on biodiversity outside of protected areas which should be considered.
The draft appraisal framework only refers to ‘carbon’ but we believe it should be broadened to the non-CO2 impacts of aviation including NOx and contrails. The appraisal module also needs clarifying about the assessment of carbon from aircraft operations as each runway option will result in differing volumes of total passengers, flights, aircraft types and routes.