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Government publishes its ‘next steps’ towards an aviation strategy

On Saturday 7thApril the Government published the outcome of its call for evidence on the Aviation Strategy ‘Beyond the Horizon’. It’s not a particularly inspiring read in terms of environmental ambition. While the Government aspires for the UK to be a world leader in aviation when it comes to facilities and services, the same cannot be said for environmental protection, at least when it comes to climate change. A world-class package of environmental protection doesn’t currently seem to be on the agenda.

But the document does at least put many of the right issues on the table (including some, such as aviation’s non-CO2 impacts, that have long been neglected) and we plan to engage actively with the Government and others on the environmental aspects of the strategy between now and publication of the Green Paper. We’ve taken a look back at five points we argued in our response to the call for evidence, looked for evidence in the outcome document of any changes in the Government’s position on these, and set out what we’ll be calling for as the policy develops.

  1. We said: The Aviation Strategy objectives should include an environmental objective that is not wrapped up in a commitment to growth, and the implications of this objective should be considered from the start

In our response to the call for evidence, we highlighted evidence that unlimited growth is incompatible with achieving environmental commitments, and that these objectives could not properly be dealt with together. The outcome document notes that “Environment and community groups felt that the document gave insufficient prominence to carbon emissions and downplayed other environmental impacts as secondary to supporting growth, without questioning whether growth was a positive outcome to aim for.”

Nevertheless the Government plans to stick with its original wording for the objective to “support growth while tackling environmental impacts” with the justification that “the interdependencies of these issues has confirmed the Government’s view that they should all be addressed together as part of a single objective in the aviation strategy”.

Meanwhile, the plan to run three separate consultations over the next 18 months, with environment at the end, has been replaced by a proposal for a single Green Paper this autumn. We hope that this allows for environmental impacts to be considered throughout the period of policy development and not as an afterthought (as it originally appeared).

What we’ll be arguing for in the Green Paper

We’ll continue to present evidence for the need to keep environmental impacts within acceptable limits, whether or not they align with industry and government aspirations for growth.

  1. We said: The commitment to put consumer interests at the centre of the strategy could prevent effective policy-making

The aviation strategy will be strongly consumer-focused and market-driven, the call for evidence had specified. We argued that government policy on aviation, including on its environmental impacts, should be in the interest of the whole population, not just consumers, including the half who don’t take a single flight in any given year.

The ‘market-driven’ language is less evident in the outcome document, but the consumer focus remains clear. In particular, the document makes clear that action on environment, and investment in new technologies, will be considered only if that’s not too costly for consumers and the industry. UK action on climate change could, for example, put our airlines at a competitive disadvantage and increase fares for passengers, the document argues, while the possibility of noise reduction will be considered “in the context of airport growth”. The possibility that environmental objectives should be met even if they conflict with direct passenger interests is not addressed.

What we’ll be arguing for in the Green Paper

AEF will continue to make the case that the Government won’t be able to meet its own aim of a sustainable aviation sector if its key test for all policy decisions is focused narrowly on serving direct consumer interests, and that Government policy should focus on the wider public interest.

  1. We said: Heathrow expansion should not be decided till the strategy is in place

It makes no sense, we argued, for expansion of the UK’s biggest, noisiest airport (in terms of the number of people affected), and its biggest single source of CO2 emissions from any sector, to take place in the absence of national policy on environmental impacts. The outcome document has not acknowledged any concern about this issue.

Meanwhile some airports, such as Luton, have set out expansion plans that are large enough in scale to fall under the NPS process (the one being used for Heathrow expansion). It’s unclear at present how the Government plans to treat such applications – whether it would amend the current Airports NPS (which deals only with Heathrow) or draft new legislation.

What we’ll be arguing for in the Green Paper

Heathrow expansion is not yet a done deal and we’ll continue to argue that MPs should vote against the National Policy Statement in the absence of convincing evidence that it can and will be compatible with meaningful environmental limits. These limits should be set out or reflected in the Aviation Strategy, to ensure a common baseline for all UK airports, and to allow the impact of UK aviation as a whole to be considered.

  1. We said: The proposal to take action to support airports where there is urgent need for growth, in advance of the strategy being finalised, is either meaningless, or a cause for concern

The call for evidence had an odd section on ‘Making Best Use of Existing Capacity’ that noted likely demand among airports to increase passenger throughput and argued that “Due to the recent rise in growth, the Government believes that this issue cannot wait until the publication of a new Aviation Strategy.” We said that it was unclear what the proposal was, since applications would still need to go through the planning process and the Government doesn’t typically stand in the way. We would nevertheless strongly oppose, we said, a policy whereby these authorities were encouraged to approve any applications for growth in the absence of strategic guidance from Government on how to assess environmental impacts.

The outcomes document doesn’t shed any light, that we can see, on this issue. Some airports have been hoping that the strategy will include specific policy support for expansion at particular airports or in particular regions. There’s no evidence so far that the Government plans to get involved in this level of detail.

What we’ll be arguing for in the Green Paper

Airport development decisions taken at the local level should be guided by a strong policy framework on environmental impacts, which provides a common baseline, and takes into account cumulative impacts, where relevant, from more than one airport.

  1. We said: The proposed ‘policy tests’, including that policy should be evidence-led, should be rigorously implemented

The Call for Evidence proposed that the Government’s approach to developing the strategy would be guided by a set of policy tests:

  • What is the rationale for action?
  • What is Government’s role?
  • What does the evidence say?
  • Have all of the options been considered?
  • What is the effectiveness of any proposed action?

We said that we fully supported the application of these tests. There is no mention of them, however, in the outcome document.

What we’ll be arguing for in the Green Paper

We’ll be making the case for effective, evidence-led government action on aviation’s environmental impacts, focusing on areas where the market won’t deliver what’s needed unless the Government gives the right policy steer.

 

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