Reports & Responses

Become a Golden Supporter

Air Transport Consultation 2002

Response to the Consultation on the Future of Air Transport in the UK - Midlands

This is a Local response and should be read in support of the West Midlands and National Friends of the Earth responses.

Introduction
Birmingham Friends of the Earth welcomes this opportunity to participate in the above Consultation. However, we are not persuaded of the need for the massive expansion in air transport infrastructure prescribed by the Consultation document. The Government must remove the hidden subsides and tax concessions afforded to the industry which help to inflate demand through artificially low ticket prices. Moreover, it must encourage the use of rail as an alternative to some short-haul flights. We also wish to see strict environmental limits imposed at airports to limit exposure to aircraft noise and pollution.

The aviation industry has to pay the costs it imposes on society as a whole. This would see it pick up its external costs. The cumulative impact of this will be to limit growth in air traffic over the next 30 years at a level that can be accommodated within existing capacity at the Midlands' airports. This would remove the need for new airport developments and the destructive impact these would have on the social fabric and health of thousands of people as well as the landscape, heritage and sensitive habitats of the West Midlands.

We would argue that rather than a 30-year prescriptive plan based on "predict and provide", we need a policy of planning, monitoring and managing demand. This would allow any growth that has to take place within the region to be accommodated within both local and international capacity thresholds. However, if expansion on the scale called for in the Consultation goes ahead then scores of communities will be blighted, regardless of whether or not the predicted growth in air travel materialises.

The White Paper has to be bold in setting out the future fiscal nature that the aviation industry will experience both from internal and external influences. The industry cannot assume that business as usual in a rigged market will continue indefinitely. The impact of Climate Change, oil prices, and incoming EU legislation will all bring pressure on the industry and as such the use of a plan, monitor and manage may well be better suited to all parties in the long run. A prescriptive 30-year plan may well be overtaken by events and the White Paper needs the flexibility to change course when necessary.

Inadequacies of the Consultation
Large economic benefits are claimed for the building and expansion of airports. But the economic and employment assumptions behind such claims are flawed because they do not take proper account of the large public subsidies and tax breaks for civil aviation and the industry's failure to pay for the pollution and other costs it imposes on society. These factors distort the demand to fly by lowering prices, which in turn artificially inflate the rate of air traffic growth, and therefore the 'need' for new airport capacity.

The assumption is that nothing will be done to start making the industry pay its way, e.g the withdrawal of subsidies and tax breaks. These include no tax on aviation fuel (£5 billion annual subsidy); no VAT on air tickets or fuel (£2.6 billion subsidy); income from duty free sales (£0.4 billion annual subsidy); a level of Air Passenger Duty that does not properly cover 'external costs' and artificially low airport charges.

It is stated Government policy to remove one of the above subsidies by introducing a tax on aircraft fuel and to ensure aviation meets its external costs as required under the Amsterdam Treaty. Yet this is not reflected in the Consultation's "central" forecasts. The Consultation assumes the price of flying continues to exclude external costs (e.g. cost of aviation's local to global impacts: air and noise pollution; climate change).

The number of jobs created by new airports and runways is massively overstated. The Government has relied on an industry sponsored economic study - Oxford Economic Forecasting (OEF) which has been found to be flawed by Berkeley Hanover Consulting. While it may seem obvious that building or expanding airports and runways will increase employment in a locality, in the wider economy there will be no net increase. This is because jobs in aviation are substitutable - if there were no aviation industry, an equal number of jobs would arise elsewhere in the economy (this is accepted both by OEF and by Berkeley Hanover). If the large public subsidies currently handed to the aviation sector were spent elsewhere in the economy they would create as many if not more jobs and employment and with less pollution and environmental damage. There is also the annual tourism deficit to consider. This year a £14 billion deficit in aviation tourism was caused as people deserted UK destinations to take 'low cost' flights abroad. The studies ignore this loss to the UK, especially felt by traditional UK resorts.

The studies have not looked at all of the key pollutants from airports. The studies will also claim that fewer people will suffer poor air quality from aircraft and airport operations than will in fact be the case. The only significant pollutants covered by the studies are nitrogen dioxide and particulate matter. The studies ignore ground level ozone, a key health-threatening airport pollutant. Also, the omission of a discussion of aviation's contribution to global climate change is a major flaw in the Consultation.

There is no proper assessment of the risks to the public on the ground (third parties) from more aircraft overhead. The Government claims "public safety is best secured by preventing accidents to aircraft". But this does not necessarily reduce risk. Risks increase with the numbers of flights and the number of people flown over. This obvious equation is being ignored and so risks to public safety are underestimated. There is also poor recognition as to the role of National Air Traffic Safety and how this important operation will be funded.

The studies downplay losses of key wildlife species and habitats. They downplay the likely loss of greenbelt, green field sites and other land caused by new airport capacity. The studies mistakenly regard as "low impact" the potential loss of large amounts of wildlife habitat and significant reductions in populations of many wildlife species.

Finally, the Consultation Questionnaire does not allow for individual comment. It is heavily loaded towards support for airport expansion and is less than subtle in its bias. In particular, the UK Wide Constrained scenario is undermined from the start as bad for business. Consequently, we have chosen to present our response in writing rather than by completing the Questionnaire.

Effects on Birmingham of Expansion of BIA and its Associated Infrastructure
At worst, up to 180, 000 people would lie within the Government's noise envelope for an expanded BIA. The areas of Hodge Hill, Castle Bromwich, Sheldon, Shard End, Erdington and Boldmere in particular stand to be severely affected. The suffering of these people must be more widely acknowledged and as such they should be given much better mitigation measures and far greater compensation if they are going to continue to live under flight paths. This could be a discount from their Council Tax banding or reduction in Council rents. It should also apply to a much wider range of community buildings. Furthermore, we would urge the DfT to adopt the World Health Organisation's (WHO) figure of 50 dbA for the onset of noise disturbance instead of the current figure of 57dbA.

We have found that within Birmingham there are still many residents who will be subject to increased disturbance from a greater number of flights along existing and future flight paths who do not know about the full implications of the Consultation. It has largely fallen to local volunteers and campaign groups to do the job of Government in informing people of what the proposals will mean for them. Birmingham City Council's Ward Sub Committee Meetings and it's one Sustainability Forum devoted to airport issues were poorly attended with most of those present comprising individuals already tuned in to the issues. Local residents have for the most part been left out of the process.

It is imperative that the industry operates a far more open and inclusive form of participation and engagement. It is also time that much more open consultative committees were set up, funded by the industry but operated independently of it, to secure much better mitigation and compensation for local people.

The area immediately adjacent to BIA is heavily congested and close to large areas of domestic and commercial development. Indeed the M42 corridor is already overburdened and placing great strain on the environment, most notably the River Blythe. The road infrastructure required to support an expanded BIA would be huge. Rail improvements would more than likely be at the expense of local rail travel. Who would fund this infrastructure? Inevitable pressure will be placed upon local roads as well as the need for additional lanes of the M42. The local area will not be able to cope with this amount of road infrastructure and the associated rat running which will accompany it. The public transport target of 20% arrivals at BIA needs to be set against a fixed target, not a percentage of the total. Otherwise the growth in car traffic will not be checked in any way at all.

The rail investment is important for the wider area and as such should place the local traveller above the long distance traveller to ensure that the residents of the West Midlands have viable local train services for work, leisure and visiting the airport location.

Conclusion
Birmingham Friends of the Earth objects to the proposed expansion of the UK's airport infrastructure. The options outlined in the Government's Regional Air Studies would, if implemented, cause environmental destruction and human suffering completely out of proportion to any economic gain.

The Government must abandon the discredited policy of "predict and provide" that has informed its projections of growth in air travel. Aviation must be made to pay for the environmental and human cost it imposes on society. Demand for air travel must be managed by ending the £7 billion worth of hidden subsidies and tax breaks the industry currently enjoys.

Birmingham International Airport was given permission in 1996 to almost double its capacity over ten years. We believe that expansion of Birmingham Airport should now be capped at the level agreed in 1996 and no further expansion should go ahead.

James Botham