AEF responds to consultations on airspace policy and expansion

24th May, 2017

AEF has today responded to the Government’s consultations on Heathrow expansion: draft Airports National Policy Statement (ANPS) and Reforming policy on the design and use of UK airspace. Both responses were informed by feedback from our members, including points raised during the discussion at last month’s AEF event on the Government’s proposals.

Responding to the ANPS for Heathrow

Our response to the ANPS consultation questions the economic rationale for additional capacity and highlights serious deficiencies in the approach taken to ensure that Heathrow expansion is consistent with environmental legislation and the need to protect public health. These include:

• The absence of any government plan to keep aviation emissions to a level consistent with the Climate Change Act (despite the fact that in the 2011 ruling on Heathrow expansion, the judge declared the Government’s claim that aviation policy was divorced from the requirements of the Climate Act to be ‘untenable in law or common sense’)
• The lack of a legally compliant air quality plan, with the Government consulting in parallel on its latest attempt to satisfy the courts that it has effective plans to meet air pollution targets as quickly as possible
• The lack of information on the flight paths associated with a three-runway airport, such that local communities can make only a limited assessment and judgement on the likely noise impacts
• The lack of any policy framework for assessing whether or not the increased risk to the public of an aircraft crash is acceptable, and the lack of information on the associated cost of this, including the need to limit housing development in the ‘public safety zone’

We have also written to Jeremy Sullivan, who has been appointed by the Department for Transport to oversee the consultation process, to argue that the deficiencies in the information provided are so significant that the process should be suspended.

Responding to the Airspace Consultation

Our response to the airspace consultation supports many of the measures proposed, including an options appraisal process for assessing the noise impacts of possible new flightpaths, the introduction of a call-in function for the Secretary of State in cases where the impacts of airspace change would be significant, and the creation of an independent commission on aviation noise.

However, we argue that significant shortcomings in the regulatory approach to noise remain given the lack of any meaningful strategy or targets for noise reduction and the Government’s reluctance to define limits beyond which aviation noise is unacceptable. Since the Strategic Rationale for upgrading UK airspace anticipates a 50% increase in air traffic by 2030, Government needs to step up to the challenge with a much tougher approach to noise regulation.