Response from the European environmental community to the issues raised by the aviation industry in relation 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 Federation for Transport and Environment, Friends of the Earth Europe and the Aviation Environment Federation are non-governmental organisations, who represent more than 3.5 million individual citizens across Europe, who are concerned with the degradation of their living environment, and who encounter health and disturbance problems for reasons of bad air quality and noise exposure.

In light of the important impacts of the aviation industry on the environment (air pollution, noise and climate change) and the European citizens, the above mentioned organisations consider it as their responsibility to voice their concerns about the way in which the industry is responding to this report.

The organisations mentioned above interact frequently with the aviation industry and "are moving" in the same political and technical committees as this. It is with great concern that the environmental community has noted over the course of the years a clear unwillingness from the part of the industry to consider seriously the problem of aviation and the environment.

It is the role of the environmental community to speak up for the environment and the citizens who are concerned for their health and well-being; and has done so in this particular context by preparing a response to the European Parliament’s report in addition to the paper at hand, which is attached.

The NGOs are particularly concerned about some of the points raised by IATA and AEA in their respective responses to the European Parliament’s draft report. Some of the arguments supporting these points appear, in many cases, to be unfounded or to misinterpret the objective or meaning of clauses presented in the draft report. The following comments follow the paragraph numbers used in the IATA/AEA papers.

NGO comments on IATA’s Response

Comment 5

This section implies that the aviation industry has been singled out for attention because of its environmental performance, and that such attention is not justified. If this is true, then it is because aviation lags significantly behind other modes of transport in terms of environmental regulation and policies. Furthermore, in many cases, its environmental performance merits special attention: aviation is the fastest growing source of GHG emissions (some of which are more effective as GHGs when emitted at altitude) and yet emissions from international flights are not governed by the Kyoto Protocol; a larger percentage of European citizens may be exposed to noise from road and rail, than from air, yet people are comparatively more annoyed by aircraft noise. Rather than being singled out, aviation is being brought into line with a coherent transport and environment policy.

The concept of sustainable development is indeed based on the three pillars (economic, social and environmental) but the meaning of sustainable development is misunderstood by IATA (see NGO response to the EP report).

Comment 7

While an international approach to environmental protection has many advantages, it should not be used as a barrier to prevent regions from meeting their own environmental objectives or targets. Environmental pressures vary from region to region. Consequently, it will not always be possible for ICAO to introduce measures that satisfy every region or member state. While international agreement should always be the first objective, flexibility is also required. In the particular case of ICAO, environmental legislation is not the first priority, and therefore any measures adopted in its environmental committee will likely be weakened at the assembly.

Comment 11, bullet point

"Bunker fuels" is the accepted terminology in the United Nations Framework Convention on Climate Change and only refers to international emissions. While domestic emissions are included in the national totals of the countries for emissions reductions, under the Kyoto Protocol, international emissions are excluded from the national totals

Comment 13, first bullet

While ICAO is indeed the specialised agency responsible for aviation, it is the United Nations Convention on Climate Change that has the ultimate, global responsibility for emissions reductions from all sectors. Thus in one way or another, emissions from international aviation will have to be curbed down.

Comment 15

Clause G does not suggest all night flights should be banned (and this is consistent with the recommendations in paragraphs 8 and 9 of the draft report). Clause G does highlight that noise can be particularly disturbing and intrusive, especially where there are no local or national restrictions to limit it. Paragraph 8 sets a target of 30 dBA Leq as a maximum interior exposure level for the night period: it is only when individual airports cannot achieve this standard that a ban is recommended. It is true that improved land use measures are required to prevent a build up of people living in the vicinity of airports, but at the same time, noise exposure levels at some airports have also increased in area.

Comment 20

The external costs of aviation are not being paid for by the industry. There are no external benefits; all benefits are internal, induced by the market.

Comment 21

Under the Parliament's proposal, airlines will have a total period of 11 years to phase-out non compliant aircraft, starting in 2002. Furthermore, since airlines are asking ICAO for an operational noise-standard rather than a "certificated" standard, non-compliant aircraft will not necessarily have to be phased out: options will exist to meet the new standard by implementing a variety of measures, from hushkitting to operational or payload restrictions. The burden on airlines will also depend on the level of stringency agreed for Chapter 4.

Comment 22

Paragraph 7 of the draft report explicitly states that the attainment of the WHO guidelines for community noise exposure is a long-term target. The short-term target for 2002 is to ensure that there is no increase in the number of people exposed to noise levels in excess of 55 dBA Leq. This should be used to measure the benefits that increased stringency and transition rule discussions, within CAEP, can bring. Furthermore, since the industry points to the recent reduction in noise exposure levels at airports, there should be no reason why this is not achievable.

Comment 23

ICAO standards relate to individual aircraft performance – they do not address the cumulative noise effect of aircraft operations. The latter has traditionally been taken into account through land use and planning policies, which are the responsibility of regions and member states. If ICAO standards cannot ensure noise levels at airports then local restrictions are the only mechanism that provides a viable alternative. Adopting the WHO guidelines ensures a common framework for all European airports.

Comment 24

The 1992 base line is consistent with the IPCC scenario and the work carried out in CAEP.

Comment 25

While indeed the Kyoto targets apply to countries or groups of countries, the aviation sector has been singled out in the Kyoto Protocol, and can thus be regarded as one entity; given also the fact that it’s emissions count in some cases as much as those of some countries.

Comment 26

All reduction targets under Kyoto are net values; these will apply to all other industry sectors, where some will reduce more and some less.

Comment 29

Noise, in particular noise at night, is of foremost concern to communities around European airports. The Dutch Health Council published a report last year on the "Public Health Impact of Large Airports". This report, which was internationally peer reviewed prior to its publication, was based a review of studies undertaken world-wide. In relation to sleep disturbance, the report noted: "The available data allow the conclusion that there is sufficient evidence that exposure to noise can induce sleep disturbance in terms of changes in sleep patterns, in sleep stages, in subjective sleep quality and awakenings. In addition, noise exposure during sleep causes other effects such as an increase in heart rate. Moreover exposure to night time noise has also been shown to induce after effects such as decreased mood the next day." (Health Council of the Netherlands, 1999, page 84).

IATA quotes the work of UK Civil Aviation Authority and highlights that its study showed that the chance of an average person being wakened is about 1 in 75. The results actually show that the chance of being wakened is 1 in 75 for every aircraft noise event. Given that most airports will have a number of aircraft noise events during the night time period, and that different people may be awoken by each, the proportion of people whose sleep is affected by night operations is likely to be much higher.

Comment 30

A doubling of noise energy (due, for example, to a doubling in the number of aircraft movements at an airport) results in a change of 3 dBA Leq. However, if the number of aircraft movements is predicted to double, it is reasonable to seek the maximum feasible reduction in individual noise levels to protect European citizens. Some engine manufacturers are confident that they can achieve a reduction target of 10dBA (based on 1998 levels) within the next 10 years. This represents a halving of the perceived loudness of an individual event. Noise targets and certification levels should be continually revised to reflect what is technically achievable.

Comment 31, bullet point

The argument of the "small contribution" of aviation to total emissions is a recurrent theme in this document. It is therefore important to remind the reader that aviation is one of the fastest growing sectors in terms of emissions; that the greenhouse gases are emitted at high altitude where they have a higher impact; that new technologies, if they exist, have a very long lead time to make their way into the market, and do not offset the growth in demand; and that under the current CAEP work only CO2 is taken into account, although CO2 only represents one third of the impacts of aviation on global warming; the effect on global warming could grow up to 15% of total emissions by 2050. The EU, under the Finish Presidency also stated that: "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."

Comment 35

The principles of internalisation of external costs have long been accepted at all levels of decision-making, including within ICAO itself, and several methods exist to actually calculate those costs.

Comment 37

The other market-based options are well mentioned in the report, which rightly recognises that large uncertainties exist regarding these options. These will have to be address by the appropriate bodies, the Climate Convention being the authority to decide on the methods for emissions trading and carbon offsets. Voluntary agreements are also mentioned in the report, but are recognised in general to be less environmentally effective than charges and even emissions trading and need to be accompanied by additional measures.

NGO comments to the AEA response (points not addressed above)

Comment 2

The report of the Parliament follows the principles of the Rio Declaration, the World Commission on Environment and Development, the WHO guidelines, the Amsterdam Treaty and the EU Common Transport Policy, in the same way that the Commission Communication comes in response to the Helsinki Council and the same requirements.

Comment 5

The Common Transport Policy is included in the Amsterdam Treaty (chapter 5) and has to comply with the objectives 2 and 6 of the same, stating that "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."

Comment 12

AEA assumes that the phase out will take place over 7 years, not 11 as proposed. With a start date of 2002 this effectively means the target date is 2013. This target year is consistent with many of the CAEP options under discussion (that envisage phase-out of aircraft not compliant by a cumulative margin of 8 or 11 dBA over the same period). Aircraft which cannot comply with the next generation of noise standards should be phased out. Removing the noisiest aircraft in the fleet is the only way to ensure constant improvements in airport noise levels, especially since the predicted increase in movements is likely to erode the benefits of more stringent certification.

Comment 13

Cost-benefit analysis does not pre-empt the application of the precautionary principle where environmental legislation is concerned.

Comment 19

In addition to not referencing the figures proposed, AEA seems to assume that all reductions will come from the demand side, by passing everything on to the consumer; or in the IPCC report there is clear reduction potential in the way the aircraft is operated, in load factor, in air traffic management, as well as in technology changes and demand.

Comment 20

Again, the figures presented and their assumptions are not referenced and are based on data which comes from the sector itself. For it to be credible, this data should be made available to the public and the decision-makers. Even better, the data used should be from independent sources.

Comment 24

Other modes of transport have for a long time been subject to environmental regulation and standards at the European level, not so the aviation sector. So far, this has worked to the advantage of the aviation sector. Environmental charges can not fully cover the environmental costs, but are the first step in the right direction.

Comment 26

The High Level Group is indeed saying that aviation has a complex charging system. What it does not say, is that this is applied to external costs.

Comment 32

While individual aircraft have become, on average, up to 20 dBA quieter, the benefit has been offset by a significant increase in the number of aircraft movements at European airports. Community reaction to noise is often determined as much by the incidence of noise events as it is by their intensity. The scope for further significant technological reductions in aircraft noise is limited (based on our current understanding). This means that while historical trends are to be applauded, they should not be used as an accurate guide to what might be achieved in the future.

Comment 35

While it is difficult to respond to this emotive statement, one should however note that the new (air) transport policy in Europe will have to take account of the requirements of integration of environmental concerns, as committed to by the EU heads of states. Policies at the European level, will thus have to ensure that the polluter is paying for the damages caused to the European citizen’s environment and health; and which is currently paid for by the whole society (including the staff of airlines).

Comment 36

The IPCC Reports, which is the uncontested scientific reference report in this area, states that in 1992 aviation accounted for 0.14 Gt C/year. This is equivalent to 514 million tonnes of CO2. Based on annual average increases in fuel consumption, the figure today is around 600 million tonnes.

Comment 37

The European aviation charge is looking not only at CO2, but at the global effect of aviation on the climate change and also applied to the LTO cycle. It should also be applied to international flights.

Comment 39

Because the aviation is not paying for its environmental costs, it will be cheaper for the consumer to travel in the air rather than on the rail; the consumer does not have a real choice if it does not get the right price signal.

A simple shift from air to rail cannot indeed be assumed, as the quality of the railways also needs improvement. However, the competition is still very unfair to the consumer.

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