Comments provided by the European Federation for Transport and Environment, Friends of the Earth Europe and the Aviation Environment Federation to the European Parliament’s draft report on the Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions - Air Transport and the Environment: Towards Meeting the Challenges of Sustainable development (COM(1999)640 - C5-0086/2000-2000/2054(COS)); Rapporteur: Caroline Lucas
The European NGOs European Federation for Transport and Environment (T&E has 37 organisations in 20 countries), Friends of the Earth Europe (FOE Europe has 30 member organisations in 29 countries) and the Aviation Environment Federation (AEF has 112 members in the UK), representing some 3,5 million European citizens, welcome the report as a comprehensive and intelligent report, and as an important step forward in the discussion on regulating the impacts of air transport on the environment.
The report is particularly important as it provides a coherent response to the requirements of the Rio Declaration, the World Commission on Environment and Development, the WHO guidelines, the Amsterdam Treaty and the EU Common Transport Policy.
The Rio Declaration on Environment and Development from June 1992 states:
Principle 15
In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to promote environmental degradation
Principle 16
National authorities should endeavour to promote internalisation of environmental costs and the use of economic instruments, taking into account the approach that the polluter should, in, principle, bear the cost of pollution, with due regard to the public interest and without distorting international trade and investment
The World Commission on Environment and Development (chaired by Gro Harlem Brundtland) defines sustainable development as follows:
"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
It contains within it two key concepts:
According to article 70 of the Amsterdam Treaty, articles 2 and 6 of the same need to be integrated in the Common Transport Policy.
Article 2 (ex Article 2)
The Community shall have as its task, by establishing a common market and an economic and monetary union and by implementing common policies or activities referred to in Articles 3 and 4, to promote throughout the Community a harmonious, balanced and sustainable development of economic activities, a high level of employment and of social protection, equality between men and women, sustainable and non-inflationary growth, a high degree of competitiveness and convergence of economic performance, a high level of protection and improvement of the quality of the environment, the raising of the standard of living and quality of life, and economic and social cohesion and solidarity among Member States.
Article 6 (ex Article 3c)
Environmental protection requirements must be integrated into the definition and implementation of the Community policies and activities referred to in Article 3, in particular with a view to promoting sustainable development.
The NGOs welcome the Parliament’s report as a first step towards the application of these principles to the aviation industry, as part of a sustainable European transport policy; and as the first move to apply the polluter pays principle and the precautionary principle to a very fast growing sector with multiple impacts on the environment: noise, air pollution, and climate change.
The NGOs also welcome the Parliament’s report as responding to the EU commitment under the Framework Convention on Climate Change and the Kyoto Protocol. In this framework, the EU has committed to reduce its overall greenhouse gas emissions by 8%.
Article 2.2 of the Kyoto Protocol states that the "Parties should pursue limitation or reduction of emissions working through the International Civil Aviation Organisation". At the same time, the international community has committed to a -5% reduction of overall emissions. While ICAO is working on some market based options to respond to this requirement, this means that international pressure will be increasingly big to regulate emissions from international aviation, as the strong growth in aviation could offset efforts made in other sectors to reduce emissions.
The Parliament’s report is also consistent with the IPCC Special Report on Aviation and the Global Atmosphere. Responding to the United Nations Framework Convention on Climate Change Secretariat request for comments on the IPCC report, the European member states under the Finish Presidency developed the following position:
"Although considerable uncertainties still exist and the need for future research remains, the report clearly points out the growing contribution of aviation to global climate change. The implementation of the overall greenhouse gas reductions, as agreed in the Kyoto Protocol, will result in a decrease of 5,2 % of Annex I GHG emissions in the first commitment period compared to 1990 levels. Emissions from international aviation are not subject to this commitment. However, the IPCC projection for total aviation emissions from 1992 to 2010 shows an increase of fuel use of 3 % annually. If compared to 1990 Annex I GHG emissions, this would contribute as much to total warming as an increase of 1990 Annex I GHG emissions by +4,6 %, of which about half would be due to international aviation. Hence, the overall greenhouse gas reductions, as agreed in the Kyoto protocol, will be offset by up to 50 % due to the projected increase of emissions from international aviation.
The report offers an excellent overview of the scientific state of the art regarding impacts on the global atmosphere. Findings include the following: the overall greenhouse impact from the aviation sector is a factor of about 2-4 larger than the impact of CO2 alone; there is an effect of aviation on climate through cirrus cloudiness; and the impact of supersonic aircraft is about 5 times larger than of subsonic aircraft. Further research needs exist, and the report contains a relevant list of issues for future work. In this context there is a need to pay more attention to mitigation options as well. Efforts should be intensified to reduce the uncertainty of some results of the report.
One of the most important message from the report is that improvements in aircraft and engine technology and in the efficiency of the air traffic system will bring environmental benefits, but will not fully offset the effects of the increased emissions resulting from projected growth in aviation. Hence, policy options to limit or reduce greenhouse gas emissions are necessary. "
Thus, in terms of aviation’s impact on the global atmosphere, emissions are not only limited to CO2, and the total effect could be four times higher than that of CO2 alone. Despite this, the International Civil Aviation Organisation has decided to consider market-based options only for CO2 emissions, thus ignoring the other effects. Furthermore, ICAO may not be the appropriate institution to develop environmental standards, its primary goal being safety and "protection of the aviation industry" (therefore not the environment), as stated by ICAO officials. Therefore, it is unlikely that effective environmental instruments will be adopted at the assembly of ICAO autumn 2001, where 186 states "promote" their different economic and political interests.
Furthermore, the Ministers and representatives of the European Member States of WHO responsible for transport, environment and health have agreed a Charter on Transport, Environment and Health (WHO, 1999). The provisions of this Charter commit Ministers to:
"2. Establish the concepts and long-term goals of transport sustainable for health and the environment, building on the work already done in the relevant fora.
3. Adopt targets …. based on scientific knowledge and work and the guidelines of WHO and incorporate them into the relevant policies to reduce inter alia:
7. Develop further or introduce policies to reduce air, soil and water pollution, accidents and noise, greenhouse gas emissions and the damaging of forests associated with transport and its infrastructures (airports, motorways, railways, terminals, harbors, petrol stations, etc.), in similar ways to other major industrial sources.
The Ministers also:
… call on WHO, in cooperation with other international organizations, to :
9. Develop scientific guidelines for the attainment of transport sustainable for health and the environment, and in particular for the integration of environment and health requirements and targets into policies and plans, based on knowledge of the full and combined impacts of transport-related health risks, including the establishment of threshold values to protect public health, where possible."
In respect of article 9 above, the World Health Organisation (WHO) has also published its Guidelines for Community Noise Exposure. These state that outdoor daytime noise levels should not exceed 55 dBA Leq; and night-time levels should not exceed 30 dBA Leq (measured inside a dwelling). Millions of European citizens are already exposed to aircraft noise levels in excess of these values. While ICAO sets maximum noise levels for individual aircraft, this measure alone cannot ensure a reduction in noise exposure levels at airports, especially given the forecast growth in air traffic.
Based on the above, three important factors call the need for pre-cautionary action:
The NGOs welcome the report of the Parliament as being consistent with the needs to take action in the European Union, given the likelihood of inaction at the international level.
The European Union has the means and the competence to issue and implement measures to protect the European environment and its citizens. While aviation in Europe has undoubtedly benefits for the development of the internal market, this development cannot take place at the expense of the environment and the citizens.
In light of the principles mentioned earlier, it is unacceptable that an industry with such a high impact on the environment (noise, air pollution, climate change) should not pay its share for the environmental damage it causes: the price of which is currently borne by the whole society.
Given the global nature of the aviation sector, measures at the ICAO level will have the biggest environmental impact. However, ICAO decision-making processes are extremely slow and global measures reflect little more than the lowest common denominator. Therefore they do not meet all needs of a region such as the European Union. Due to the high population density, the large number of airports close to urbanised areas and the rapidly increasing number of flights, environmental problems related to aviation are more pressing than in other parts of the world. The situation around European airports - regarding LTO emissions, noise, emissions from ground services, safety risks and traffic to and from airports - is rapidly worsening. If the ICAO Assembly in 2001 cannot decide on measures that do meet the needs of European citizens, more stringent measures at the regional level are crucial for reducing the environmental impact around airports. At the same time, the likelihood that Europe will go ahead with measures that do address the problems around airports in Europe, will create an enormous stimulus for ICAO to adopt stronger global measures.
Since the aviation sector is currently privileged by not paying a tax on kerosene while other mineral oils are being taxed, it is obvious that such kerosene tax would be fair towards society. It would also reduce the environmental impact of aviation. Despite these obvious benefits of taxation, it is currently not politically feasible to introduce a tax on kerosene, as taxation requires unanimity voting within the European Union legal framework. However, other instruments that would make the aviation sector step in line with other sectors of the society when it comes to environmental protection are available. An emission charge will internalise the environmental costs of aviation. Such emission charge should particularly address greenhouse gas emissions (such as CO2 and Nox) and emissions from the landing and take-off (LTO) cycle.
One has to wonder on what possible grounds the lack of decision and political will has been justified until today!
For further information:
Beatrice Schell (T&E): +32-2-502 9909
Paul de Clerck (FoE): +31-20-550 7384
Tim Johnson (AEF): +44-171-329 8159