Building Aviation Back Better: Developing an Environmental Aviation Strategy


EGAG responds to All Party Parliamentary Group Inquiry on Heathrow Expansion and Regional Connectivity


1. Aviation White Paper 

The delay to the publication of the Aviation White Paper provides an opportunity to pause and rethink its priorities to ensure that it delivers for the whole country. 

  • Is the mantra of ‘growth everywhere’ still feasible in a post-pandemic world? 
  • How much growth in aviation is compatible with the Net Zero targets? 
  • What incentive and penalties should be mandated to ensure technological improvements are delivered? 
  • What options should be considered for demand management? 

EGAG response.

Managed growth would be more appropriate.  This has to be consistent with our climate change obligations of net zero by 2050 at the very latest.  In the same way as society has to balance social, economic and environmental considerations, the airline sector must recognise that their operations have serious effects on the quality of the lives of millions of residents who find themselves overflown to an extent that significantly affects their life decisions on where to live and their social environment.

The amount of growth which is compatible with net zero is realistically zero. Carbon Offsetting by the sector is a fallacy, having failed in the last 20 years to provide meaningful reductions, as it is unable to be adequately policed and puts the burden on other sectors. In manufacturing industry carbon increases are not allowed and manufacturers have to seek unit reductions by improved technology. Why is the same standard not applied for the airline sector`?

We also believe that fuel charges on airlines should be introduced in line with taxes levied on road and rail transport

Demand management has to recognise that we are now part of a global holiday market so a frequent flier levy post one flight per annum should be introduced. The principle of polluter pays should be enshrined on ticket prices. 

There is ample evidence that commerce has found new ways of doing business without the need for such frequent flying since the current Coronavirus crisis. Incentives for businesses to use video conferencing by either tax breaks or capital incentives would be helpful.

2. Regional Balance 

Government policy is to help rebalance the economy and this should seek to focus any growth in aviation in the regions, within existing planning constraints and ensure that this is compatible with net zero climate targets. 

  • What support do regional airports require from Government? 
  • Where would growth in aviation best deliver economic benefit within existing environmental targets? 
  • What investments in surface transport are required to facilitate fewer car journeys to regional airports? 

EGAG response.

If the Government wishes the “Northern Powerhouse”rhetoric to become reality then the airline sector must have a joined up strategy which is not just southern centric. Further expansion in the south will inevitably remove opportunities in the midlands and north as well as in Scotland. The mantra from Heathrow is that passengers enjoy the experience of travelling from northern England and the regions to fly out of the UKs Hub airport. Our experience is contrary to that and we believe passengers would much prefer to fly from their local regional airport.

Local airports are more likely to be able to meet environmental targets than a monolithic southern Heathrow which if allowed to expand as they would wish will become more of a monopoly.

The airline sector should be viewed as part of the travel infrastructure in the UK and be linked seamlessly with both rail and road. A renewed national plan on infrastructure should be made public so that the people can plan their lives and their life decisions based on the full knowledge of a longer-term blueprint. (25 year?) 

Existing airport capacity should be detailed without commercial considerations and then planned in the way, which maximises utilisation before further expansions. Airport workers should be given free public transport to their place of work to minimise individual car usage. Drop off and pick up points for key employees local to the airports should be costed and given priority. Western and Southern rail links to Heathrow Airport would help meet the reductions in employee car journeys, as well as the flying public.

  1. 3. Bailouts 

It is likely that many aviation sector businesses will need financial assistance. The UK Government could include social and environmental objectives in any bailout approach as has happened in other European countries. 

  1. What financial support should Government be willing to offer to the aviation sector? 
  2. What conditions should be attached to any financial support? 
  3. Are there any regulatory mechanisms or legislative changes required? 

EGAG response.

The sector should only be financially supported subject to a moratorium on dividends. It would be unreasonable for the public purse to support the sector over and above other sectors whilst dividends and bonus payments to executives are being paid. Any loans should be repaid at commercial rates and repayments excluded from profit before tax. 

The cost structures between rail and air within the UK need further examination. The frequent lower cost of domestic flights against the equivalent rail journey is counter intuitive and not environmentally sound.

Any financial assistance should seek firm commitments on environmental pollution reductions for both air and noise.

  1. 4. Jobs 

It is vital that transition arrangements are put in place which ensure that good quality employment in the sector is protected, while also facilitating the development of the skills necessary for roles in the future. 

  1. What level of demand is likely to return to aviation in the next few years and at what pace? 
  2. What policy options does Government have to protect workers (particularly low- skilled and lower-paid workers) in the sector? 
  3. What skills and training do workers require to transition into alternative sectors? 

EGAG response.

We support the creation of high quality jobs for the sector. We are concerned at the present level of job reductions. This  highlights the problems of allowing a sector to overwhelm a local area which becomes too reliant on a single employer such as an airport. The consequential potential of local relative poverty in adjacent vicinities should a catastrophic downturn happen is self evident.

The alleged new jobs that were being created by the proposed third runway expansion at Heathrow were significantly in the largely semi skilled and low paid service worker areas such as catering, cleaning, security and logistics. The lack of affordable housing and public transport now is not the massive problem that it would have been had the 3rd runway been imminent. This is now an opportunity to re-examine what alternative employment and career opportunities are available to local people. The electrification of transport, the continuing growth of high tech sectors, the R&D in pharma and environmental sciences are all areas where further support is required. Small scale manufacturing with capital allowance and start up funding are all matters where new initiatives could be taken rather than continuing to blindly support the airline sector without question.

Green new jobs should be promoted and replace those displaced.

Finally high level technical training with practical applications rather than esoteric quasi academia should be encouraged at all universities.

  1. 5. Taxation 

The Government is due to review the tax arrangements of the aviation sector. 

  1. Are existing aviation taxes fit for purpose? 
  2. How can Government ensure that all aviation companies make a fair contribution to the reduction of emissions? 
  3. Should revenue raised from aviation taxes be directed to investing in emissions reductions technologies? 

EGAG response.

The current system of tax needs reform and is part of an historic legacy when air transport was in its infancy and not available to the masses. It has a disproportionate advantage over rail in particular and its polluting effects on vast swathes of the overflown public is without accountability. Aviation fuel should attract the same levies as road and rail, along with VAT added to the ticket price. With its privileged  position it must have enforceable minimum standards on noise, air quality and carbon emissions. These standards must be at least World Health Organisation standards. As the UK is one of the most densely populated countries with aircraft movements over its land mass the minimum standards should be world leading to protect our population.

There should be a greater ability for airports to insist that airlines use best operating practices to minimise noise i.e. NAPD1 versus NAPD2. Quieter planes should be given preference on key routes and during “shoulder hours” to minimise noise on the ground.

The balance between the airline industry and the general population is wrong. Local communities are at a constant disadvantage to be able to challenge data produced by the sector because the lack of truly independent specialist knowledge and science led advice in this very complex area. The amount of information and highly detailed papers from the CAA, NATS the Dft , Heathrow and Government has been overwhelming.  Frequently the amount of time to respond to these documents has been very short and is being dealt with by residents whose roles in this area are far from full time. We believe that there should be a per ticket levy “ring fenced”, very much as the model at Vienna to allow the funding of independent research for resident groups to ensure a fairer balance. This could be part of any quid pro quo for reductions in the APD should Government be so minded to further assist the airline sector.

Part of any such passenger levy could also be directed for research into redefining metrics on noise (which are not airline sector biased ) and for technologies to reduce emissions. Left to the sector these matters will never be priorities.

6. Policy Framework for Decarbonisation 

In order to meet Net Zero targets there will need to be a robust framework for decarbonisation from Government with strict targets and incentives to help boost investment and innovation. 

  • What would these targets and incentives look like? 
  • What role might be played by electric and hybrid aircraft? 
  • Are any changes required to the Renewable Transport Fuels Obligation? 

EGAG Response.

There should be a clear reference period of current carbon levels and a tapering reduction set over a period of years. Breaches should result in prohibition notices on operators and airports as well as meaningful fines.

Electric and hybrid aircraft are a long term aspiration, currently the best battery energy density is less than 1% that of aviation fuel, so unrealistic for anything other than short domestic flights in the medium to long term.  For example, a 747 flight with 90 tonnes of fuel to fly from London to New York would require the equivalent of 9,000 tonnes of batteries to provide the equivalent energy, without taking into account the increased energy to move that additional weight and inconveniently, if were even possible, to accommodate that weight, it would still weigh the same as on take off when it arrived at New York, whereas a normal 747 would be 90 tonnes lighter at 180 tonnes, having burnt its fuel, and thus be able to land. Also electric propulsion is only suitable for propellor driven aircraft, which cannot fly at speeds of jet engined aircraft. In short, electric flying is not an option and actually a diversionary way to advance the problems of fossil fuel flying. The life time analysis of electric propulsion should be included in any analysis of environmental damage and emissions. The science may not be as overwhelming as the rhetoric!

Sustainable Aviation Fuel (SAFs) in 2018 added up to 8 million litres. That is equivalent to 10 minutes of flight for the whole year. The aviation industry attempts to hoodwink society in believing that SAFs are the future! KLM are currently being taken to the Dutch Advertising Standards body for their misleading advertising, where they infer that biofuels are used extensively, whereas the reality is less than 0.18% biofuels are used at KLM. 

7. Community Impacts 

The operations of aviation have significant impacts on local communities near airports and under flight paths. As demand returns to pre-pandemic levels there is an opportunity to ensure that the most robust mitigation measures are in place. 

  • Do current noise impact assessments consider changes in the noise environment? 
  • What impact will the intensification of existing flight paths have on local communities? 
  • How can improvements in local air quality be secured for the long term? 
  • What schemes or incentives are required to increase the number of people accessing 

airports via public transport? 

  • Can the impact of night flights be mitigated? 

EGAG response.

The development of new flight paths are not defined in terms of where and when they will happen. It is therefore unfair to ask communities to comment without this basic data. The industry promotes  the introduction of Performance Based Navigation (PBN) yet the evidence is that its introduction will not necessarily improve throughput performance – it has fallen way short of the predicted benefits in the USA and has ended up with numerous lawsuits and reversion of the flight paths, due to community outrage. The unintended consequence particularly on departures from Heathrow is that it may result in concentrated flight paths over residents in a way never previously predicted, but experienced in 2014 departure trial flights, which resulted in widespread community uproar, political fallout and the cancellation of the PBN trials. 

EGAG, having sat on the Heathrow sponsored PBN Workshops in 2019, held by consultants Taylor Fairey, where the question that these consultants often put to the industry is ‘why PBN?’ – it was rejected at Schiphol Airport in 2009, by the airport because of reduced throughput on arrivals to 23 flights an hour compared to 38 flights per hour when under air traffic control and rejected by communities on departures due to the concentrated flight paths blight communities under the 10’s metres wide “Motorway in the Skys” it created; also termed as “Noise Sewers” by Andrew Haines, the CEO of the CAA, at an HCNF meeting in February 2017. Dispersed and multiple routes on departures would help to alleviate these potential issues but the sector is silent on their plans as they appreciate the negative push back that is likely from communities. They are therefore reluctant to divulge this information until the last moment and this is seen by many as disingenuous.

Noise metrics are not fit for purpose and a suite of metrics were accepted by Heathrow at their HCNF meetings as being more appropriate. This has never been followed up. The issue of the errors in SoNa data is also outstanding with the CAA.

The significant reduction in noise since the Coronavirus pandemic has shown communities how life could be. It is now incumbent on the sector to understand that they have a bigger responsibility to be accountable for the huge disturbance they have on those overflown and to be humble about their privileged position.

Free transport for workers at airports should be introduced with convenient pickup and drop offs. The network of public transport to airports should offer significant savings to travellers as an incentive not to bring cars to airports.

Night flight bans should be for 8 hours. Shoulder times outside the 8 hours should be permitted for only the latest and quietest aircraft and operational reason exemptions should be gradually reduced. Too often commercial considerations trump the concerns of those overflown and this should be challenged more vigorously.

SoNA 2014 Night was promised at the same SoNA 2014 day came out, but as yet has mysteriously not been published, with many requests at the HCNF and promises by the CAA being made that it was ‘almost there’


1 comment on Building Aviation Back Better: Developing an Environmental Aviation Strategy

  1. A fine response, straightforwardly worded. We are particularly grateful to you for drawing attention to the demands made of CAA et al’s consultations on those of us unqualified within the sector and science to respond at times adequately, or even to have the necessary time available to respond.

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