Representation by Amanda Wells
- Date submitted
- 17 November 2023
- Submitted by
- Members of the public/businesses
Gatwick Airport Northern Runway Project The reasons why the Gatwick Airport Northern Runway Application should NOT be permitted include all of the following points below, and related matters. I oppose the expansion of Gatwick Airport and this development as proposed by Gatwick Airport Ltd. 1. Airport growth at Gatwick and air travel do not boost the economy Aviation and employment Gatwick is recognised to be reducing jobs through automation (baggage handlers, air traffic control, check-in), so the promise of new jobs is not what it seems.As the Aviation Environment Federation (AEF) noted in their 2009 report, between 1998 and 2004, despite a 30% rise in air passengers, the total employment attributed to airports and airlines actually went down. Reference: Aviation Environment Federation Connectivity and the economy pdf - Evidence to the Airports Commission from the Aviation Environment Federation Comments on Discussion Paper 02: Aviation Connectivity and the Economy 19.4.13 In March 2009 Aviation Environment Federation published Airport Jobs: False Hopes, Cruel Hoax by Brenden Sewill, which provided evidence that increased mechanisation of check-in and the rise of low-cost carriers with minimal staffing has in fact meant that the number of staff required per passenger has fallen over time and is likely to continue to do so. In contrast to the old rule of thumb (and countless press releases by airlines and airports) that a million passengers requires a thousand members of staff, more recent analyses, including for example by York Aviation, predict job creation figures of little over 150 jobs per million passengers. Even this may be optimistic. The importance of aviation as an employer should not therefore be exaggerated, and any promise of new jobs in relation to proposals for airport expansions should be independently assessed. Could aviation growth harm the UK economically? Questionable investment and use of public money Profit margins in aviation are slim and increasingly so. When the last Government was pushing ahead with Heathrow expansion, they undertook analysis suggesting that it would generate a £5 billion benefit for the UK economy. In 2010 the New Economics Foundation reran the model using updated values for oil prices and forecast economic growth, as well as adding in modest estimates of community and environmental costs, they concluded that in fact a new runway would generate a £5 billion loss (Reference: NEF 2010 Grounded: a new approach to evaluating Runway 3) In fact, it is worth considering whether at some point a continued high cost of oil, combined with a lack of cost effective alternatives to burning kerosene, will result in aviation becoming a ‘stranded asset’ of the kind under consideration by academics at Oxford University in a programme launched in February ‘to help businesses and policy-makers future proof against investments in assets that might become devalued or written off’ The need for a balanced evidence base Alongside official information sources such as ONS, government departments and the CAA, thereport cites evidence from numerous studies commissioned and funded by the aviation industry,including: Oxera (November 2009), “What is the contribution of aviation to the UK economy?”, Final report prepared for Airport Operators Association Oxford Economics (2005), “Measuring airline network benefits” – survey conducted on behalf of IATA In contrast, neither the various reports that critique the findings OEF and others, including by CEDelft, the New Economics Foundation and academic economists as part of the OMEGA partnership, nor the recent WWF surveys of leading businesses concerning future travel demand, have been quoted or acknowledged. Airport growth at Gatwick and air travel do not boost the economy Reference: New Economics Foundation report indicates UK airport growth and air travel growth do not boost the economy, July, 2023 A new report , Losing altitude - The economics of air transport in Great Britain by Dr Alex Chapman of the New Economics Foundation, sets out the real environmental downsides of the growth in flight numbers. It shows that the the sector has no realistic way to cut its carbon emissions. And contrary to the apparent impression given by the industry and the UK government, the economic assumptions that underpin support for growth in air travel are dated and have not been reviewed for some years. Contrary to expectations, growth in business passenger numbers has effectively ceased and new passengers now derive exclusively from the leisure market. The airline sector is one of the poorest job creators in the economy per £ of revenue. Two decades of evidence confirms that air transport growth runs counter to the interests of the UK’s domestic tourism industry, as far more money is taken out of the country than brought into it. The net national effect is a large travel spending deficit which contributes to the UK’s overall current account deficit. There is an urgent need for new, comprehensive UK aviation policy, and assessment of impacts of its future growth. The report says that despite booming air travel in the past few decades, only one in 12 flights in 2022 was taken for business purposes – half the proportion in 2013 – while the number of associated jobs was lower than in 2007. Wages fell faster in real terms between 2008 and 2022 than in any other UK sector. Far more passengers are flying on holiday abroad than into the UK, with the NEF report finding a £32bn “travel deficit” in net spending between outbound and inbound tourism in 2019. Airports around the UK are seeking to expand, despite the recommendation of the Climate Change Committee that there should be no additional capacity to meet the country’s 2050 net zero targets. Gatwick says its growth plans would “inject £1bn into the region’s economy every year'. However, the NEF report suggests that since the government’s previous comprehensive assessment of the economics of air transport growth, “strong evidence, grounded in government data and academic research, suggests that the economic merit of expanding the UK’s air transport sector has diminished considerably”. It recommends that the government pause all airport expansion until it has conducted a review of the economic evidence and compatibility with policies on climate change and levelling up. Dr Alex Chapman at the NEF, said: “[The government has] let the air travel industry balloon in size, based on dangerously outdated claims that it is boosting the UK’s economy. The reality is declining business air travel, declining wages for air travel workers, declining job numbers, and declining domestic tourism spending in the UK. And that’s before you consider the rise in noise, air pollution and dangerous emissions.” He said the beneficiaries were “the highly paid executives, the private shareholders and the wealthy minority of ultra-frequent flyers”. Gatwick’s overall case for expansion does not comply with the Airports National Policy Statement which requires airports (other than Heathrow) to demonstrate sufficient need to justify their expansion proposals, additional to (or different from) the need which would be met by the provision of a Northwest Runway at Heathrow. The economic benefits of expanding Gatwick have been overstated by Gatwick Airport Ltd. Significant economic, social and environmental costs have been ignored and/or understated. The economic benefits of air transport growth are subject to diminishing returns. In an already highly connected economy such as the UK, additional economic benefits from further expanding air transport are largely dependent on net inbound tourism and business travel growth. Both of these are absent in the UK today (more people fly on holidays overseas and business travel has flat-lined in the UK since 2006 ). When Gatwick's scheme costs, benefits, and the long-term societal risks are taken into account, the scheme’s economic case no longer stacks up and entails unreasonable levels of risk to local, national and international wellbeing. Gatwick’s proposals present a false economy to workers and residents. With recession and downturn of the economy, Gatwick Airport is hit the hardest due to its business model of leisure travel. Crawley Borough Council has recognised this and is now looking to greener industries to bring jobs and stability to the county, rather than being too reliant on Gatwick Airport that is seen as a volatile sector. Aviation and the economy – the Forgotten Facts Aviation’s contribution to the economy is less than the aviation industry and the Government suggest. The Government’s estimate of aviation’s contribution to the economy is based on a report largely paid for by the aviation industry. The report, The Contribution of Aviation to the UK Economy was carried out by consultants Oxford Economic Forecasting in 1999 with an update in 2006. The report ignored the tax-breaks the industry receives through tax-free fuel and being zero-rated for VAT – worth around £9 billion a year. Nor did it factor into its calculations the huge cost aviation imposes on society and the environment, which are estimated to be around £16 billion a year. Independent experts argue that the report over-estimates the number of jobs aviation expansion would create. And it skated over the point that UK air passengers take more money of the UK on their foreign trips to spend abroad, than foreign visitors bring in on their visits. Most of this deficit is accounted for by air travel and closely parallels the rise in low-cost flights. Reference: Gov.uk Publications 2010 to 2015 government policy deficit reduction UECNA Reference: European Union against Aircraft Nuisances - key issues economic issues: UECNA recommendation 1 Under the current business mode aviation does not pay its full external costs. It needs to do so. These downsides of aviation impose an economic cost on society. A 2016 Report (the Aviation Environment Federation Aircraft noise and public health the evidence is loud and clear - January 2016) estimated the costs of aviation noise in the UK alone to be at least £540 million a year. Across Europe the overall environmental costs of aviation, including their impacts on health, amount to billions of euros each year. UECNA recommendation 2 Aviation already pays a significant amount of tax but it remains under-taxed and should pay its full and fair share of tax. UECNA recommendation 3 To recognise that higher taxes and charges will not damage the wider economy. UECNA recommendation 4 More government investment is put into rail in order to persuade a significant number of air passengers to switch to rail. 2. An expansion of Gatwick will increase air pollution. Please see the following reports: Ultrafine particles from aircraft engines can spread miles downwind of airports and can endanger lives, February, 2022 References: ScienceDirect Environment International Volume 161 March 2022 107092 - Sources of particle number concentration and noise near London Gatwick Airport The Guardian 11 February 2022 There is growing evidence that suggests tiny particles - ultrafine - of air pollution can affect the heart, lungs, blood pressure and risk foetal growth. These tiny particles, as well as larger ones, are emitted from vehicle engines and from plane engines. The tinier the particle, the further it can get into the lung, and thus into the blood circulation - and hence the widespread effects. Now research by Dr Gary Fuller at Gatwick has shown that the number of ultrafine particles 500 metres downwind of the airport was greater than those at the kerb of London’s busiest roads. They mostly came from aircraft during takeoff and landing, but traffic, car parks and a large catering facility used to cook airline food all added to the problem. Ultrafine particles can travel a long way downwind of an airport, eg. miles from the airport in Los Angeles, and also miles into London from Heathrow. Although known to be a health hazard, ultrafine particles are not included in the environmental assessments for planning applications, putting us at risk of increased air pollution for decades to come. In 2021, the Dutch Health Council and World Health Organisation highlighted the growing evidence that ultrafine particles are damaging our health. Reference: Risico’s van ultrafijnstof in de buitenlucht Samenvatting Rapport 15-09-2021) This includes 75 studies mostly relating to lung inflammation, blood pressure and heart problems, along with risks to foetal growth. Reference: Health effects of ultrafine particles: a systematic literature review update of epidemiological evidence- Springerlink Feb 2019 However, technical differences between the studies meant that the WHO has not set a standard. We are yet to understand the spread of ultrafine particles from Gatwick, but we do know they can travel a long way. Ultrafine particles from aircraft have been found across the Los Angeles suburbs. We have found ultrafine particles from Heathrow across large areas of west London and they can be detected more than 12 miles (20km) away in the city centre. It is a similar situation in several European cities meaning millions of people are exposed. Reference: Report Development and transferability of ultrafine particle land use regression models in London:ScienceDirect Vol.740 Oct 2020) Gatwick 2 ignores the new Environment Act that includes air quality as a major consideration. Gatwick already has a problem with the small PM2.5 particles that are released from plane tyres and roads. Teddington Action Group 20 January 2019 Heathrow air pollution does NOT stop 2km from the airport, or just 1,000ft altitude. DfT is wrong Teddington Action Group (TAG) have been doing research into how likely it is that air pollution will get worse, if Heathrow is allowed a 3rd runway. Their investigations indicate that government has not assessed this properly, and has ignored relevant available information from other airports. TAG say that according to Heathrow, emissions from planes do not contribute notably to emissions once the plane is above 1,000ft. The Airports Commission and DfT and its advisors set a study area of just 2 kilometres from the expanded airport boundary. There is much evidence to indicate that is wrong. Planes emit significant amounts of NO2 and particulates, which find their way down to the ground (and by definition into humans and living creatures as well as vegetation). The DfT deny this but the empirical evidence does not support the DfT. Studies between 2014 and 2016 at Los Angeles, Atlanta and Schiphol, Amsterdam, strongly suggest otherwise. Mobile monitors set up under the inward flight paths show that particulates and NO2 are transmitted by the wind up to some 20 kilometres down wind. King’s College study on Heathrow ultrafine particle air pollution shows it spreads far into London - January, 2020 Reference: Science Direct Environment International Volume 135 Feb 202 105345: Source apportionment of particle number size distribution in urban background and traffic stations in four European cities Jan 2020 In this study, researchers from King’s College London have measured ultrafine particles (UFP) in European cities and detected emissions from airports. Many studies have examined and quantified the levels of larger particles (e.g.PM2.5 – <2.5?m or PM10 – <10?m), but very few have studied UFP (< 0.1 ?m). The researchers identified, characterised and quantified the sources UFPs in Barcelona, Helsinki, London, and Zurich between 2007 and 2017. They measured particle and gaseous pollutants at different sites and used a statistical model to identify and quantify the contribution of the different sources of ultrafine particles. They found that London had the highest concentration of UFP compared to other cities. The greatest concentrations of the smallest particles (called nucleation particles) when the wind was blowing from the airport in all cities. This indicates that airports are a major UFP source and that these small particles can travel many kilometres. Traffic emissions contributed the most. So it is confirmed that Heathrow pollution – with very negative health impacts – spreads far into London, many miles away. Effects on cardiovascular and respiratory systems of short-term exposures to ultrafine particles in air, near an airport, in healthy subjects. Effects of short-term exposures to ultrafine particles near an airport in healthy subjects Reference: Science Direct Environmental International Volume 141 August 2020 105779 There is a growing body of research into the negative health impacts of very tiny particulate air pollution. The nanoparticles of ?20 nm are produced by vehicle engines, but seem to be produced in considerable amounts by jet engine. A new study in the Netherlands looked at impacts on the respiratory and cardiovascular systems of 21 healthy young (18 - 35), non-smoking volunteers. They were exposed between 2 and 5 times to 5 hour periods of the ambient air near Schiphol airport, while doing intermittent moderate exercise like cycling. Various aspects of their circulation and respiration were measured. The study found the exposures were associated with decreased FVC (forced vital capacity - a measure of lung function) and prolonged QTc intervals (the time it takes the heart to re-polarise for the next beat).The effects were relatively small, but they appeared after single exposures of 5 h in young healthy adults. "As this study cannot make any inferences about long-term health impacts, appropriate studies investigating potential health effects of long-term exposure to airport-related UFP, are urgently needed”. Air pollution is likely to increase the chance of developing Type 2 diabetes, August, 2020 Reference: Air Quality News 21/08/2020Research in 2015 showed that there is a link between air pollution and the development of Type 2 diabetes. The study looked at 102 published studies from various countries. The results stated: "Air pollution is a leading cause of insulin resistance and incidence of type 2 diabetes mellitus. The association between air pollution and diabetes is stronger for traffic associated pollutants, gaseous, nitrogen dioxide, tobacco smoke and particulate matter." And the conclusions: "Exposure to air pollutants is significantly associated with increased risk of type 2 diabetes mellitus. It is suggested that, environmental protection officials must take high priority steps to minimize the air pollution, hence to decrease the incidence of type 2 diabetes mellitus." There is probably more research needed, to establish details, but it appears that there is definite positive link between the two. So areas with high levels of particulate and NOX air pollution, such as around Heathrow, are likely to see more ill health, including more diabetes. Heathrow air pollution down dramatically during Covid lockdown, June, 2020 With very low numbers of planes using Heathrow (97% down) over the past 3 months, due to the Covid lockdown, this has been an excellent opportunity to get data on air pollution - comparing days with, and without, the planes. Using data from Air Quality England, local group Stop Heathrow Expansion have found that five air quality monitors around Heathrow which breached the maximum legal limit in March – May 2019 have shown an average 41% improvement in the same period in 2020. Our current air quality laws state that nitrogen dioxide concentrations must not average more than 40 micrograms per cubic metre (µg/m3), per year. This level is often exceeded at a range of locations around Heathrow. Readings from a site on the Northern Perimeter Road showed a 50% improvement in air quality. Another site outside Cherry Lane Primary School had a 46% reduction in NO2 emissions, from 44.1µg/m3 in March – May 2019 to a safer 23.9 µg/m3 in the same period in 2020. As well as fewer planes, there were fewer road vehicles. Air pollution figures from inside the airport boundary were substantially lower, showing the source is planes, not only road vehicles, as Heathrow likes to claim. 3. Noise - Gatwick Night Flights Night flights A ban on night flights should be a condition of any expansion at Gatwick. The airport should also be required to set out a comprehensive package of measures to incentivise the use of the quietest aircraft at night outside the hours of a ban. Gatwick is one of the very few European airports which operates at night without restriction. Heathrow has to cease flights operations at night, but not Gatwick, whilst all mainland European cities also shut their airports at night. Gatwick already causes significant noise nuisance at night across the AONB areas of south east England (often with flights passing overhead every 3 minutes in the middle of the night). What will the European Court of Human Rights say about this when this is challenged? Night Flights and the Right To Sleep Reference: European Union Against Aircraft Nuisances (UECNA) Key Issues Night Flights 2023 What are the health impacts of night flights? The evidence is clear: night flights are bad for people’s health. The Hyena-Study was carried out by Dr Lars Jarup and his team at Imperial College in London and published in 2008. It looked at nearly 5,000 people aged between 45 and 70 who had lived near Heathrow, Berlin Tegel, Amsterdam Schiphol, Stockholm Arlanda, Milan Malpensa and Athens Eleftherios Venizelos airports for at least five years. The study found that noise from night flights causes immediate increases in blood pressure in sleeping people, even if they are not woken up by the noise. It discovered a 14% increase in the risk of high blood pressure (hypertension) for each 10 decibel increase in night-time aircraft noise. Hypertension can lead to heart problems and even early death. The Greiser-Study, was carried out by the German Federal Environmental Authority and published in 2010. It covered the area around Köln-Bonn Airport and showed a significantly increased risk of coronary heart diseases, strokes and cancer due to aircraft noise. The Guidelines for Community Noise were produced by the WHO in 2000 Here are the main findings:If sleep is regularly disturbed for any reason, it has an effect on people’s health. Even if people don’t wake up, there is “sufficient evidence” to show that noise increases people’s heart-rate, exactly the same finding as the HYENA Report.People whose sleep is regularly disturbed take more medicines.There is some, but “limited”, evidence that noise at night can cause depression and other mental illnesses.Children, including babies, because they spend longer time in bed, are “considered a risk group” even though they usually sleep through noise better than adults.Since older people, pregnant woman and ill people find sleeping more difficult. They are particularly vulnerable to being disturbed by night noise. Does freight need to fly at night? Most freight does not need to arrive at night. A report from the International Logistics Quality Institute in 2004 found that just 10% of short-distance express freight is time critical. And there is no evidence that most of the freight on long-distance night flights is time-critical. Ban on night flights at Heathrow Airport The CE Delft ‘A quick scan Social Cost Benefit Analysis’, commissioned by HACAN, is a report released on January 27th, , 2011. In this report CE Delft analyses the social, environmental and economic effects of night flights at Heathrow airport and shows that a ban on night flights could be beneficial for the British. Reference: cedelft study: ban on night flights at Heathrow airport/1126. Noise: Expansion of Gatwick would significantly increase aircraft noise both for those living near the airport and for those further away under flight paths. The noise envelope Gatwick has proposed is not consistent with government policy and CAA guidance and is wholly one-sided. They should be substantially revised. Aircraft noise is a major issue for Gatwick, but Gatwick continues to mislead residents. The poor, complex, long (over 1,000 pages) consultation in 2021 did not give Gatwick a mandate to go forward with noise envelopes (which are supposed to be legally binding). These are mentioned, but no further details are provided, and they do not cover the areas that are impacted today. They can also be changed to accommodate the modernisation of airspace (FASIS), to allow for continued growth of the airport – many new flight paths are proposed, many of which are over new areas. Gatwick is already designing this modernisation based on a 2-runway airport – very misleading to residents as Gatwick 2 say no new flight paths! Gatwick offer a Noise Envelope as a guarantee of the noise that residents can expect with 2 runways, but this does not cover the area recognised by Gatwick as to be impacted the most by the significant increase in plane movements. Areas of AONB ignored: constructing a motorway in the sky above our heads means that human and animal habitats are being destroyed by aircraft noise and pollution. The tranquillity in AONB’s has already been shattered by planes flying at less than 4,000 feet over rural areas, depriving residents and animal habitats of sleep and tranquillity. Prof Whitelegg: How the aviation sector should be reformed following the Covid-19 crisis 9 July, 2020 Prof John Whitelegg says the Covid pandemic provides a key opportunity for major reforms to the aviation sector. The sector is not likely to reduce its carbon emissions to the extent necessary, even for the net zero target for 2050. The Committee on Climate Change has said there will need to be measures to limit demand for air travel, and it "cannot continue to grow unfettered over the long-term.” They say, "we still expect the sector to emit more than any other in 2050.” Aviation continues to receive an effective subsidy, due to the absence of VAT and fuel duty that amounts to about £11 billion per year (compared to about £3.8 billion taken in APD). There are well known negative health impacts caused the plane noise, with some of the best researched being cardiovascular. We need to change the dominant expectation that air travel with continue to grow. There has to be realisation that air passengers must pay the costs of the environmental damage they cause. Some necessary changes would be charging VAT; taxing frequent fliers; adopting WHO noise standards for health; full internalisation of external costs; fiscal instruments to shift all passenger journeys under 500kms in length from air to rail. And more. 4. Illegal Airspace Change at Gatwick - See The Civil Aviation Authority (Air Navigation) Directions 2023. The key schedule is: Schedule1 Direction 9 - Planned and Permanent Redistribution of air traffic (PPR) (The Civil Aviation Authority (Air Navigation) Directions 2023) There has been Type 3 PPR at Gatwick which has not obtained consent and is therefore illegal. This relates to the changes to the minimum joining point which has been moved at Gatwick at least 300 feet vertically or 1 nautical mile horizontally within a rolling 36-month period. This is considered as “significant” and thereby constitute a Type 3 PPR. In accordance with section 70(2)(d) of the Transport Act 2000, the CAA has failed to take account of the Air Navigation Guidance issued to it by the Secretary of State when carrying out its functions under direction 10. In particular, the CAA shall apply guidance relevant to its functions, in considering whether or not to approve a permanent airspace change involving a relevant PPR (direction 9). Type 3 11. A Type 3 PPR is a PPR which results from a significant change to the written specified landing arrangements of aircraft at a UK airport referred to in paragraph 1 of this Schedule (or more than one such change within 36 months whose cumulative effects are significant). 12. “Change to the written specified landing arrangements” means a change to the established minimum, or where applicable maximum, distance of the joining point onto an airport’s Instrument Landing System (ILS) or any significant changes to the height at which aircraft must establish onto the ILS. 13. Changes to the written minimum joining point at such airports greater than a cumulative total of at least 300 feet vertically or 1 nautical mile horizontally within a rolling 36-month period will be considered as “significant” and thereby constitute a Type 3 PPR. 5. Climate Change and Gatwick Expansion on the scale proposed would increase very substantially the CO2 emissions and other climate effects associated with Gatwick’s operations and flights. There are currently no proven technologies for reducing aviation emissions at scale. Expansion of Gatwick would therefore have a material impact on the UK’s ability to meet its carbon reduction targets. Carbon emissions will also result from construction works and increased road traffic to the airport. Flights and traffic will make air pollution worse. A 2nd runway would add over 1 million tonnes of extra carbon a year, plus other greenhouse gases, soot, and vapours. Gatwick continues to ignore this pollution in its consultation. Gatwick 2 also ignores the housing/storage of alternative fuels and the rising cost of fuel (both fossil fuel, and the cost of a greener fuel which is estimated to be 3 times the current costs, once developed). There is no silver bullet to an alternative fuel, say aviation, which is set to continue burning fossil fuel for the foreseeable future. The Government advisory body, the Committee on Climate Change, called for a stop to all airport expansion (June 2022) and continues to warn the UK Government of not meeting carbon reduction targets (October 2022). Aviation Emissions Reference: Aviation Environment Federation 5 May 2022: Raising the public visibility of aviation emissions. In 2019, the Foundation for Integrated Transport commissioned AEF to provide a report estimating the emissions from flying and comparing the results with the emissions associated with common, everyday activities. The aims of the project were to improve understanding of, and publicise, the climate change impact of aviation emissions; provide information on the climate change effects of flights of different lengths and in different seating classes; and make clear comparisons with emissions from other activities. The report estimated that: -Taking a single long haul return flight from Birmingham to Delhi (emitting just over 1 tonne CO2 adjusted for additional climate impacts) would wipe out all the savings made by switching from moderate meat consumption to being vegan for a year. - Annual emissions per capita in the UK from driving are around 1 tonne CO2, equivalent to the emissions of a single long haul return flight - Flying economy from London to Paris generates 27 times the CO2 emissions of making the same journey by Eurostar (53 kg compared with 2 kg for a one-way trip) - One return flight between Manchester and Southampton generates more emissions than running a tumble drier for a year (0.18 tonnes). - A return business class flight between the UK and Delhi generates more emissions (at just over 2 tonnes) than the annual average emissions per capita in India (1.8 tonnes). Climate change will mean aviation will have to change, even if very reluctantly – see the Dutch example, April, 2023: Reference: Financial Times 13 April, 2023 Climate crisis means aviation must change — whether it likes it or not Though the Dutch government lost its legal battle recently, trying to limit the number of flights using Schiphol, this was not the triumph the airlines hoped for. Airlines are scared that governments, realising the high CO2 emissions from the sector and no realistic plan to reduce them for several decades, will bring in measures to limit flights or demand for air travel. UN secretary-general António Guterres has said that the latest report by the IPCC showed a “quantum leap” in climate action was now required – and that should include aviation. The Dutch government only lost its case, on a technicality – so it may press on. The aviation sector may try to bring in restrictions itself, in the hope of avoiding more draconian measures being imposed. It is increasingly apparent that the sector’s decarbonisation road maps, largely relying on huge amounts of sustainable aviation fuel (SAF), operational efficiencies and technological breakthroughs, will not deliver the “net zero” emissions target by 2050 – especially while the sector tries to grow each year. The chief executive of French airport operator Aéroports de Paris has openly admitted that demand growth has to slow for a time — at least in developed countries. Report for the Aviation Environment Federation, by Element Energy shows air travel demand reduction is essential, to cut UK aviation carbon, May, 2022 Reference: Aviation Environment Federation May 2022 - The role of aviation demand in decarbonation Element Energy, looks at the reality of the UK government's reliance on novel technologies to eventually cut aviation carbon emissions. The DfT is depending on greatly improved aircraft energy efficiency, as well as electric planes, planes powered by hydrogen, and a huge component of new lower-carbon fuels, SAF (sustainable aviation fuels) replacing kerosene, and carbon capture and storage. The DfT does not consider reducing demand for flying, and considers an increase of 70% above the level in 2018, by 2050, as acceptable. Element Energy show the aspiration of 2% annual plane efficiency gains is unrealistic, and even 1.5% will be difficult. They consider that novel fuels might, at best, produce a carbon saving of 60%, not the 100% the DfT hopes for. The price of carbon in future needs to be high, for international flights, and if it does not increase enough, flying demand will not decrease - to the DfT forecasts are unreliable. The study concludes that, even with a high proportion of SAF being used, and optimal fuel efficiency gains, by 2050 there would need to be a reduction in flights and passengers of around 45%, if the sector is to achieve the target of 15MtCO2 (even that is a huge amount of carbon). Head of Boeing not optimistic that SAF will be cheap enough any time soon, May, 2023 The head of Boeing has warned that biofuels will “never achieve the price of jet fuel”, expecting that this central pillar of the aviation sector’s strategy to slash emissions is not likely to be successful. Or the UK’s dubious “Jet Zero” strategy. Airlines say that so-called “sustainable aviation fuels” (SAF) — made from food wastes, agricultural and forestry waste, and domestic rubbish, could enable lower CO2 from the sector, by replacing the kerosene-type fuels, such as Jet A, used in aircraft today. But SAF currently accounts for less than 1% of global aviation consumption and its price is at least x2 or x3 that of kerosene fuel. If the fuel could be made in anything approaching the scale the aviation industry wants, and without other serious unintended agricultural and environmental impacts, it would still be expensive. The extra cost would have to mean more expensive flying, and thus fewer people flying – less future growth for the sector. “There are no cheap ways to do SAF — if there were, we would already be doing them.” Governments want to mandate use of SAF by airports, even though it is not available in large amounts. Climate Change Committee stresses need to reduce demand for air travel, December, 2021 Reference: Climate Change Committee COP26 Key outcomes and next steps for the UK December 2021 The Climate Change Committee (CCC), in its report following up the outcome of the COP26 talks, says that rolling out the Net Zero Strategy must lead to emissions falling in all sectors (i.e. going beyond recent progress dominated by the power sector). They say there is a gap on behaviour change (e.g. shifting diets away from meat and dairy and limiting aviation demand growth). That needs to be changed, in order to get emissions reductions. Reductions in aviation are especially important for the UK, as we have very high per person aviation emissions. The Committee has repeatedly stressed that an element of demand reduction for air travel is needed. The Government has repeatedly ignored that, knowing that anything restricting or make flying more expensive, is a vote-loser. The COP26 Glasgow Pact said there should be no “inefficient” fossil fuel subsidies. The CCC has said that the absence of VAT or fuel duty on air travel are post-tax subsidies. AEF questions the CAA’s effectiveness on environmental issues, 30 January, 2023 Reference: AEF response to DfT CAA survey January 2023 The Department for Transport recently called for evidence as part of a review of “the effectiveness and efficiency of the CAA. The consultation, which opened on the 28th of November 2022, closed on 29th January 2023. The main duties of the CAA are on safety and the well-being of its consumers, the air passengers. Its effectiveness on environmental issues is a subsidiary concern. Aviation Environment Federation submitted comments. Their opinion is that “the CAA’s strategy is inadequate in relation to all environmental issues. Many, perhaps most, of the deficiencies in the CAA’s strategy arise because it has no meaningful environmental duty and few powers to require the industry to achieve positive environmental outcomes. We believe this can only be remedied if the Government provides the CAA with an environmental duty, regulatory functions and clear guidance.” The AEF says the CAA is required to “have regard to the growth of the aviation sector”, but not to prioritise it over environmental sustainability. It does not act to regulate appropriately the climate or noise impacts of the aviation industry. Airlines’ unrealistic hope that sustainable fuels will propel them to a guilt-free future, June, 2023: The Guardian 10 June 2023 Airlines are desperate to believe, and get everyone else to believe, that flying can be made “low carbon”, so everyone can continue to fly, with a clear conscience about their impact on irrevocably altering Earth’s climate. But the only real option,(while the sector is trying to grow as much as possible) that might make a significant reduction in aviation carbon emissions, is using other novel fuels. So-called SAF (Sustainable Aviation Fuel). Currently if aviation used every drop of available SAF, it would be about 0.1% of total aviation demand. There are grandiose plans to aviation to use 10%, 20%, 30% or whatever within the next 2 or 3 decades. ie. unrealistic growth. AEF says "there is increasing scepticism about the possibility of scaling up SAFs … There’s no feedstock – everything is in demand elsewhere. They work really much more like an offset. ...The idea of using waste from processes such as intensive agriculture or animal fats, or plastic manufacture, that are fundamentally unsustainable" Government consultation about cutting AIRPORT CO2 emissions, but ignores AIRCRAFT emissions, April, 2023 The Government is currently consulting on proposals to introduce a target for airports to achieve zero emissions without offsetting by 2040. But the target doesn’t include the emissions from flights, despite these being responsible – according to the Government’s own consultants – for 95% of airports’ emissions. The government’s target would actually require a massive reduction, or complete cessation, of flights if it included the CO2 emissions from planes too. While it is possible to decarbonise (largely by use of electricity) airport operations on the ground, there are no technologies that can do this, on a large scale, for aircraft. The only plan for flights, other than so-called “sustainable aviation fuels” would be speculative future CO2 removal from the atmosphere. The consultation document says that “The zero-emissions airport target is not intended to hamper economic growth at airports, but to provide a social licence for growth.” ie. making it look as if the aviation industry is working hard to cut its emissions. It would be necessary, for the airport CO2 targets, to include full reporting of the emissions from flights using the airport. Other impacts of expansion at Gatwick Transport impacts Gatwick’s targets to increase how many people travel by bus, train, walk and cycle are insufficient to prevent a massive increase in road traffic around the airport. This increase in traffic would increase congestion on local roads and increase off-airport parking. Gatwick is not providing any extra rail services but the project will increase pressure on future train services. There is no taxpayer funding for further rail improvements of the Brighton Line. Recent improvements were designed to improve daily usage and not to accommodate a 2-runway airport. Flood Risk Over the years the River Mole and its tributaries have flooded, especially when the Airport and sewage treatment plants discharge water in extreme events. Climate change is making these extreme events more frequent and severe. Expansion of the Airport, and other developments locally, need to properly take this into account. The application for the Gatwick Airport Northern Runway Project should be refused for the reasons above and other related matters.