The CAA has sought views on how it can fulfil its duties as a reviewer of the effects of aviation upon the environment. This function was carried out by the European Union Aviation Safety Agency, but since Brexit, the function has has been transferred to the UK Civil Aviation Authority. The closing date has passed but the consultation document can be found on the CAA website at https://www.caa.co.uk/our-work/publications/documents/content/cap3039/
Our responses are in Bold typing
- What is your name? Teddington Action Group
- What is your email address?
- What country are you responding from? UK
- Are you responding from an organisation or as an individual? Organisation
- If responding from an organisation, which organisation are you representing? Teddington Action Group
- What type of organisation do you represent? Other – community group
- Can we publish your response? (required) Yes
AER: Ambition and Aims
- Please tell us to what extent you agree with the CAA’s ambition and aims for the AER.
Agree
Please explain your reasoning. (required)
We agree that environmental impacts of aviation should be reported. This should be immediately available not ‘in the coming years’. The measures and metrics agreed should be available today and performance gathered from previous 10 years. The Govt and other bodies need to see this data today given the very challenging timescales to get to net zero, proposed expansions and Airspace change. Decisions should not be taken without seeing the data and trends. As the CAA’s strategic aim and role is to grow aviation, where the negative environmental impacts are recognised, it is not a suitable body to provide this data. An independent body would be more suitable to provide this data and provide better, unbiased challenges to the industry and feedback to the Govt.
Climate Change
- In addition to reporting greenhouse gas emissions from domestic flights within the UK and international flights departing the UK, are there any other relevant areas we should consider reporting on with respect to climate change in future updates to the AER?
Examples of what we could consider reporting on with respect to climate change in future updates to the AER include:
- Greenhouse gas emissions emitted from additional sources, such as aircraft support vehicles and airport terminal generators
- Greenhouse gas emissions emitted from aircraft manufacturing processes
- Greenhouse gas emissions emitted from the production and use of new and emerging fuels, such as sustainable aviation fuels (SAF)
- The impact of offsetting and carbon removal initiatives on global greenhouse gas emissions.
Yes.
All four suggestions. Offsetting should have details on the method and actual quantities as there are potential risks of inaccurate information being given. Offsetting has a poor reputation and in particular short-term emissions (like an 8-hour flight) are offset against a long-term (several years) capture procedure (see para 11 response below regarding suggestions for reporting). We would like to see the UK remove carbon in the UK rather than relying on other countries to do our dirty work. Demand management and decarbonisation are better ways forward than trying to remove greenhouse gas emissions.
- There are various ways we can present climate change data in future updates of the AER. Please tell us how useful each of the following options would be to you.
Note these options are not mutually exclusive and may be used in combination.
Not useful/ Slightly useful/Useful/ Very useful/Extremely useful
Option 1: National Total Extremely useful
Option 2: Airport Cluster Not useful
Option 3: Airport Extremely useful
Option 4: Airline Extremely useful
Please explain the reasons for your selections.
We need to be able to see results from local airports and also compare progress that individual airlines are making towards reduction of greenhouse gas emissions through modernising their fleet and best practice in the way they fly. National results help us to see whether climate targets are being achieved. We don’t believe cluster data would add anything.
- Are there any other ways we could present climate change data which you think would be useful to include in future updates of the AER, outside of those already suggested?
If known, please provide examples of data sources and/or methodologies we could consider to inform the additional option(s) suggested.
Yes.
Compare the airline figures to the advice of the Committee on Climate Change (CCC). It is notable that the CAA has made no mention of the role of the CCC and how the AER should fit in with its role and advice given. Thus, the CCC has stated in its 2024 report to Parliament under “Priority policy recommendations for the next year” that the Government must “Stop airport expansion without a UK-wide capacity-management framework”. How does the AER fit in with this? If it does not, then it must do so.
It terms of reporting the results, the gross carbon emissions from aviation before carbon offsetting and capture should be shown for each year, together with the calculations and assumptions in relation to mitigation. As some of the mitigations, in particular in relation to carbon trading, will have long term effects rather than short term, the actual year on year gross and net carbon emission figures should be reported, together with any assumptions regarding the life cycle benefits of trading schemes which are taken into account.
Noise
- In addition to reporting the number of people exposed to aviation noise in the UK, are there any other relevant areas we should consider reporting on with respect to noise in future updates to the AER?
Examples of what we could consider reporting on with respect to noise in future updates to the AER include:
- The potential health impacts associated with noise exposure from aviation activities; and
- The effectiveness of noise abatement/reduction initiatives.
Please identify the additional relevant area(s) we should consider reporting on with respect to noise in future updates to the AER and explain why this would be useful to you.
If known, please provide examples of any relevant data sources and/or methodologies we could consider to inform your suggestion(s).
Yes – particularly the health impacts, including annoyance and quality of life.
Studies show that repeated noise events can damage the heart and increase the risk of strokes and we consider that further concentration of flightpaths will cause both physical and mental health harms to overflown communities. The Govt should commission and publish as a priority studies on the health and quality of life impacts of living under highly concentrated flight paths, based on international experience (particularly the US and from the UK the Heathrow PBN trials).
It is important to see the results of the health impact studies currently being undertaken (ANNE and ANAS) and to review health studies across the world where PBN has been operational to understand fully the impact of PBN flightpaths. The results and implications of these studies should be factored into environmental advice and transport decision making cost benefit tools, in particular webTAG, in respect of Airspace Modernisation flight path decisions.
Some people may get used to aircraft noise, but it still damages health through increased blood pressure even when asleep. Many others will simply move away if possible, leaving behind stigmatised zones and blighted communities. The scope for mitigation in heavily populated areas with high levels of overflight (such as in London and parts of the South east), may be significantly limited given the existing level and proximity of flightpaths in the congested London airspace.
Noise relief through modal alternation or planned respite are essential considerations in relation to mitigation – however their beneficial impact has to be thoroughly investigated and understood. Given the CAA’s remit to promote aviation growth, investigations into this should be undertaken independently and the results widely consulted on.
The CAA should apply the ICAO recommendations on noise abatement around airports and, in particular, justify why the CAA and particular airports do not, or should or should not, be required to follow the recommended ICAO procedure (see NADP1 vs 2 and research in ICAO Doc 9888)
13. There are various ways we can present noise data in future updates of the AER. Please tell us how useful each of the following options would be to you. Note these options are not mutually exclusive and may be used in combination.
Not useful / Slightly useful/ Useful/ Very useful/Extremely useful
Option 1: National Total Useful
Option 2: Airport Cluster Not useful
Option 3: Airport Extremely useful
Please explain the reasons for your selections.
We want to see how Heathrow is doing as well as the national total.
- Are there any other ways we could present noise data which you think would be useful to include in future updates of the AER, outside of those already suggested? Please identify the additional option(s) we should consider for presenting noise data in future updates of the AER and explain why this would be useful to you.
WHO (2018) recommend avoiding exposure above 45 dB Lden. Analysis should be tracked by airport and UK aviation noise reporting should be taken down to this threshold level.
We would like to see an independent review of the suite of metrics and noise thresholds used in UK aviation decision making.
ICAO has advised that long term average noise levels, in particular dBLaeq, reflect only one third of aviation’s known noise impacts. Yet the primary basis for UK airspace relies entirely on this metric.
There needs to be a better understanding of non-acoustic factors such as trust in authorities and, in particular, the change effect (where international research has shown an addition effective impact equivalent to 6-9 dBLaeq (Gelderblom et al & Guski et al) on those adversely affected). This should be acknowledged and reflected in UK noise guidance, reporting and decision making.
There is little justification for continued sole reliance on overall long term dBLaeq metrics, especially as these figures are usually presented only in terms of net numbers, failing to reflect the very different experiences and differential impacts on ‘winners and losers’ in assessing airspace change and expansion proposals.
It would make more sense to the general public (and reflect the lived experience better) if, rather than having noise events averaged out (into dBLaeq) it would be better to have figures for the highest noise event (Lmax) as well as knowing the number of noise events above a certain level (N metric). When reporting on individual airports, use should be made of single mode overflight metrics (both LdBaeq and dBLmax), with supplemental assessment of the impact of modal relief/respite, to show the impact of peak noise exposure.
We have been given SEL figures in the past but they are not helpful since a lower sound exposure level over a slightly longer period can give a higher reading and be made to look more disturbing that a higher noise event over a shorter period of time, when the opposite is the case.
Air Quality
- In addition to reporting emissions from civil aviation flights and airport support machinery for the five damaging air pollutants outlined, are there any other relevant areas we should consider reporting on with respect to air quality in future updates to the AER?
Examples of what we could consider reporting on with respect to air quality in future updates to the AER include:
- Reporting emissions from additional sources, such as airport terminal generators and airport-related road traffic;
- Widening the scope of air pollutants captured by our reporting; and
- Reporting air quality concentrations of air pollution around airports and assessing this against legal air quality standards.
Please identify the additional relevant area(s) we should consider reporting on with respect to air quality in future updates to the AER and explain why this would be useful to you. If known, please provide examples of any relevant data sources and/or methodologies we could consider to inform your suggestion(s).
Yes – all three. There are still a significant number of car journeys to Heathrow, affecting air quality round the airport but given the revenue airports derive from parking, we wonder what incentive there is to reduce this.
UFPs can be transmitted to the next generation though the placenta of expectant mothers (research of Queen Mary’s University). The amount of UFPs near a major international airport has been described as at a level “that are of the same general magnitude as the entire urban freeway network” (Hudda et al 2014 on Los Angeles airport) .
A recent study by Transport & Environment (T&E) ‘suggests that thousands of cases of high blood pressure, diabetes and dementia across Europe could be linked to the tiny particles emitted by planes’ and that ‘People living in a 5km radius from an airport breathe in air that contains, on average, anything from 3,000 to 10,000 ultrafine particles per cm3 emitted by aircraft.’ Ultrafine particles from planes put 52… | Transport & Environment
The proposed use of concentrated flightpaths at Heathrow and larger planes to increase capacity is concerning given that this may increase UFPs. This is a particularly important consideration in relation to UK Airspace Modernisation.
It is understood UK air quality assessments only reflect pollution modelling at very low level, 1000 ft, whereas international research has shown ground level pollution to be generated at much higher levels, circa 3000ft (see for example EASA European Aviation Environmental Report 2016). These assumptions should be reviewed independently, in order to form a reliable and trusted basis for undertaking environmental assessments.
- There are various ways we can present air quality data in future updates of the AER. Please tell us how useful each of the following options would be to you. Note these options are not mutually exclusive and may be used in combination.
Option 1: National Total – Slightly useful
Option 2: Airport Cluster – Not useful
Option 3: Airport – Extremely useful
We need to be able to monitor the performance of our local airport.
- Are there any other ways we could present air quality data which you think would be useful to include in future updates of the AER, outside of those already suggested?
No.
Additional Environmental Reporting Topics
- Not including climate change, noise and air quality, would you like to suggest any additional environmental topic(s) that the AER could report on?
Yes, all three options:
The UK aviation industry’s impact upon biodiversity
The UK aviation industry’s impact upon tranquillity
The UK aviation industry’s impact upon water quality
Other environmental reporting topic(s): Please specify.
Aviation noise can affect biodiversity in many ways impacting the ability of wildlife to communicate and reproduce. It can also disrupt pollination and seed distribution by wildlife.
PFA chemicals or ‘forever chemicals’ in water should be closely monitored. These chemicals build up in the body and may cause cancer, reduced fertility, birth defects and liver damage. The Environment Agency’s Chief Scientist’s Group Report in 2021 identified civilian and military airfields amongst the areas having the highest potential risk of PFAS to the environment.
We understand that the Environment Agency (EA) has been monitoring surface waters upstream and downstream of airports for PFAS contamination and has apparently identified some airports for further investigation.
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