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The draft Aviation Strategy: an environmental overview

21st December, 2018

On 17th December the Government published the Aviation Strategy Green Paper, a wide-ranging set of policies addressing all aspects of the aviation sector and its future development for the coming decades. The strategy is out for consultation for 16 weeks (until 11th April 2019). An Aviation White Paper setting out the final policies is due to be published next summer. 

The strategy’s objectives are unchanged from those set out in the earlier framework document, with the only reference to environmental impacts combined with an objective about growth: “support growth while tackling environmental impacts”. AEF, and a number of environmental NGOs and community groups, had argued that there is little hope of developing a meaningful environmental framework in the absence of any freestanding environmental objectives. 

The commitment to growth comes across strongly, however, in the Green Paper. This includes both support for expansion within existing airport capacities, and support for meeting anticipated demand for another new runway, in addition to the third runway at Heathrow, beyond 2030. The Government proposes to ask the National Infrastructure Commission to consider whether there is a ‘needs case’ for such expansion. Although the words ‘sustainable’, ‘sustainably’, or ‘sustainability’ appear over 80 times in the 200-page document, there are very few thresholds or clear policies to ensure that the sector’s future operation and expansion is conditional on meaningful environmental limits. The “partnership for sustainable growth” (primarily comprising government, regulators, airports and airlines”, the diagram in figure 8 suggests) is a new proposal, but it’s unclear what this can deliver. 


The paper announces the long-awaited launch of ICCCAN – the Independent Commission on Civil Aviation Noise – which will begin its work in January 2019 and will “advise the government on best practice on noise mitigation, and how the needs of affected communities can best be served in the airspace modernisation programme”. We have argued that ICCAN’s remit should include advising the Government on whether its aviation noise policy adequately reflects the latest evidence and responds to community issues. Full terms of reference have yet to be published. 

Alongside the strategy the Government has published what it describes as the most comprehensive aviation noise forecast ever undertaken in the UK. These appear to show a mixed picture, with the number of people affected by aircraft noise likely to increase according to some metrics even as airport noise ‘footprints’ reduce.

A number of specific noise measures are proposed in the strategy, including the following:

On targets and monitoring:

  • developing a new national indicator to track the long-term performance of the sector in reducing noise 
  • routinely setting noise caps as part of planning approvals (for an increase in passengers or flights)
  • requiring all major airports to set out a plan which commits to future noise reduction, and to review this periodically

On planning:

  • developing tailored guidance for housebuilding in noise sensitive areas near airports
  • improving flight path information for prospective home buyers so that they can make better informed decisions

And on insulation:

  • extending the noise insulation policy threshold beyond the current 63dB LAeq 16hr contour to 60dB LAeq 16hr 
  • requiring all airports to review the effectiveness of existing schemes
  • for airspace changes which lead to significantly increased overflight, setting a new minimum threshold of an increase of 3dB LAeq, which leaves a household in the 54dB LAeq 16hr contour or above, as a new eligibility criterion for assistance with noise insulation

The paper notes the recent publication of updated recommendations from the World Health Organisation’s Europe office on the levels of aviation noise that pose a risk to public health, but makes no commitment to meet them, or even to attempt to meet them, arguing that the “cost effectiveness” of limiting noise needs to be considered. 

Climate Change

In 2009, the Committee on Climate Change recommended that in order to ensure that aviation growth does not derail achievement of the UK’s 2050 emissions target under the Climate Change Act, the government should put in place measures to limit demand growth to no more than 60% over the level in 1990. This would, they advised, keep the UK’s share of international aviation emissions to around 37.5 Mt in 2050, a level the CCC describes as a “generous” allowance compared to the emissions cuts from other sectors and “at the limit of what is feasible” in terms of asking other sectors to do more. After dodging the issue for years, the Government had committed to officially clarifying its policy in the Aviation Strategy.

At first glance it looks as if the Green Paper is bringing good news on this. It says that: “the government proposes to accept the CCC’s recommendation that emissions from UK-departing flights should be at or below 2005 levels in 2050”. This is welcome, if very overdue, and should mean at least that the pressure on other sectors covered by the Climate Change Act to compensate for aviation emissions up to 37.5 Mt will be maintained. 

How, then, can the Government square this policy with growth at Heathrow and elsewhere? The answer is not spelled out in the text but involves a quiet – and dangerous – redefinition of the CCC’s recommendation. The Committee have always treated 37.5Mt as an absolute level of emissions. The Government appears to want to treat it as a net target, with any exceedance potentially dealt with simply through participation in the UN carbon offsetting scheme CORSIA (which it hopes will in time be strengthened in line with the global Paris Agreement).

“In order to implement the government’s long term vision for addressing UK aviation emissions”, the strategy says, “the government will maintain its current policy not to mandate sector specific emissions reduction targets to ensure reductions are made wherever it is most cost effective across the economy.” This statement appears to refer to the global economy. For other sectors, UK carbon budgets ensure that any overshoot in emissions from one sector is compensated for by a reduction from another sector. But the Government says it does not propose to include international aviation emissions in carbon budgets.

Meanwhile, between now and publication of the final white paper, the CCC will be publishing two important reports, one on whether and when the UK should increase the stringency of its 2050 climate target and another on aviation, reviewing the assumptions and recommendations made in its 2009 report. It is very hard to see how an emissions level as high as 37.5 Mt for aviation could be accommodated in the context of more stringent climate targets. Evidence commissioned by the Government on the potential consequences of updating UK policy in line with the Paris Agreement, and published alongside the Green Paper, argues that: “for 1.5°C global scenarios, any[our emphasis] continued emissions of CO2 from aviation using fossil fuels beyond around 2050 will be inconsistent with the Paris Agreement goals in the absence of extra measures, or alternatively, correspondingly increased negative emissions.” 

The Aviation Green Paper does not make clear whether this scientific evidence and the CCC’s analysis will be taken into account in the climate policies set out in the white paper.

Air pollution

Aircraft, airports, and passenger and freight vehicles all generate emissions that contribute to air pollution. With growing public awareness of the dangers of toxic air, and strong evidence that current legal limits on air pollution need to be strengthened, we’ve argued for an evidence review, and better ongoing monitoring of aviation air pollution. In particular, we’d like more clarity about what happens to particulate matter and other emissions at higher altitudes, as currently aircraft emissions are only accounted for if they occur in the landing and take off cycle.

The Government has proposed a number of new measures in the strategy in relation to air pollution, including:

  • better monitoring of air pollution, including ultrafine particles (UFP)
  • ensuring the availability of comprehensive information on aviation-related air quality issues
  • requiring all major airports to develop air quality management plans, and 
  • validation by the Government or a third party of air quality monitoring to ensure consistent and robust monitoring standards

General aviation

The strategy and accompanying documents give a fair bit of attention to how to “enable, facilitate and encourage” growth in General Aviation (GA), which largely comprises pleasure and business aviation flights. Opportunities for lighter regulation are considered, as well as the potential for a network of ‘strategically significant’ airfields to be identified and given special protection in the planning system. At the same time, the Government argues that in order to ensure the most efficient allocation of airspace to different users in future, greater ‘electronic conspicuity’ is needed for small aircraft, and proposes that there should be mandatory identification of all aircraft in UK airspace. For those impacted by noise from light aircraft, this may help with monitoring and enforcement of any rules or guidelines on when and where aircraft are allowed to fly. A review of the risk posed by GA activities, including to the public, is also proposed. 

Other documents

Numerous related publications came out alongside the draft strategy, including the following which contain significant environmental evidence and analysis:

Understanding the potential and costs for reducing aviation emissions: air transportation analytics report

Carbon leakage: air transportation analytics report

International aviation and the Paris Agreement temperature goals

The current state of scientific understanding of the non-CO2 effects of aviation on climate 

Competing priorities: technology’s influence on the levels of environmental emissions from aircraft and the trade-offs involved – review and future prospects

Aviation noise: CAA report

Next steps

We’ll be undertaking a detailed review of the proposals and the associated evidence base in the coming months, including how these match up to the recommendations made in our aviation strategy discussion papers (available under ‘Related Articles’).