Birmingham Airport anti-Noise Group

Issues: BIA Master Plan Contact us

Towards a Genuinely Balanced Approach:
Submission to Birmingham International Airport Draft Master Plan consultation, March 2006

Contents

1. Introduction: a Balanced Approach?
   
2. Outline of a Genuinely Balanced Approach
   
3. Continuous environmental improvement versus 'mitigation'
   
4. Challenging 'predict and provide'
   
5. Applying the Genuinely Balanced Approach to the Master Plan
   
6. Conclusion: Putting economic and social impacts in perspective
   
7. Note on the Health Impact Assessment
8. References

1. Introduction: a Balanced Approach?

01. The process for securing implementation of the Government's 2003 White Paper, 'The Future of Air Transport', requires all major airport operators to produce, or update existing, airport Master Plans, to take account of the White Paper's conclusions. Birmingham International Airport (BIA) Ltd. published its new Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands' (henceforth 'the Draft Master Plan'), on 31st October 2005.

02. The Draft Master Plan claims that BIA 'can be developed in a sustainable way', and that a 'positive and pro-active approach to sustainability is an important part of both the Government's national policy agenda and also the Airport Company's development strategies' [1]. Taking its cue from the White Paper, the Draft Master Plan identifies a 'balanced approach', defined as 'development and operation in such a way as to encourage economic growth and social inclusion, whilst minimising the environmental impact of the Airport and its operations' [2], as the key to achieving sustainable development of air transport in the region.

03. Whilst there is a clear need for a strategic approach to airport development, and we support making 'best use' of the existing airport site to avoid the need for development of a new airport in a new location, BANG strongly disputes the assertion that the 'Government has promoted a sustainable approach to airport development in the White Paper though its proposals for a "balanced approach"' [3]. As the House of Commons Environmental Audit Committee points out, despite the numerous references in the White Paper to the need for a 'balanced approach', the 'balance the Government has in fact struck is skewed decisively in favour of aviation' [4].

2. Outline of a Genuinely Balanced Approach

Back to top

04. BANG welcomes the opportunity to respond to the Draft Master Plan and outline our alternative, 'Genuinely Balanced Approach' to the Airport's future development and operation (summarised in Table 1). The Airport Company defines a 'balanced approach' as one that entails seeking to 'reduce the impacts of the Airport on those that live nearby, and on the natural environment' [5], and central to our Genuinely Balanced Approach is the Airport Company's stated policy of 'continuous environmental improvement' [6]. But the current approach, based primarily on a strategy of environmental 'mitigation', is unable to deliver continuous environmental improvement, as is abundantly clear from the Draft Master Plan itself: the proposed programme of expansion is expected to increase the Airport's major environmental impacts [7] over the course of the plan period (2003-2030).

05. The current approach aims only to reduce the forecast impacts relative to the forecast impact of previous paper proposals for the Airport's expansion, such as those in the White Paper, the Department for Transport (DfT) 'Future of Air Transport' consultation documents, and the Airport Company's own 'Birmingham Alternative' (2002), or merely conform to 'industry good practice' [8]. Although the Draft Master Plan proposals are certainly 'more sustainable than previously proposed' [9], as far as local people are concerned the comparison that really matters is that between the Airport's actual impact on their lives today and its likely impact in the future. Therefore, the Genuinely Balanced Approach aims to reduce the airport's environmental impacts relative to their current levels, as well as relative to the forecast impact of previous proposals.

06. The Genuinely Balanced Approach reinforces the policy of continuous environmental improvement with clear, objective and unambiguous (i.e. based on raw data) targets to reduce (or at least prevent an increase in) the major adverse environmental impacts of the Airport's development and operation over the plan period. The Airport Company must also accept the lion's share of responsibility for delivering continuous environmental improvement, implementing proactive policies to meet its targets (and make future development conditional on meeting them). In contrast, the current approach relies too heavily on 'external drivers', such as favourable trends in 'emerging technologies', national government regulatory or policy action, and the fortuitous side-effect of other Airport Company policies, to deliver its environmental policies and mitigation strategy.

07. Finally, whereas the the current approach aims to 'exhaust' [10] existing capacity and develop new capacity to accommodate the increasing passenger throughput, the Genuinely Balanced Approach rejects the 'predict-and-provide' approach to future airport development, and views existing airport capacity as a resource to be managed. A shift to this latter perspective will be essential if the rate of growth in air transport is not to overtake the rate at which Airport Company policies and innovations in aircraft design and operational methods can deliver continuous environmental improvement.

Table 1. Summary of the contrasts between the current approach of the Draft Master Plan and the alternative, Genuinely Balanced Approach.

3. Continuous environmental improvement versus 'mitigation'

Back to top

08. In this section we illustrate the contrast between the current approach and the alternative, Genuinely Balanced Approach in two key areas of environmental impact: noise and air quality.

Noise
09. In order to assess the impact of the Draft Master Plan proposals on the local noise 'climate', BIA commissioned the Civil Aviation Authority's Environmental Research and Consultancy Department (ERCD) to undertake an Air Noise Study. The Study forecasts a growing noise impact resulting from the Airport's expansion: the increasing volume of air traffic from 2010 to 2030 is expected to lead to an increase in both the size of the corresponding day and night noise contours and the populations exposed [11]. The population exposed within the daytime 57, 63, 66 and 69dBLAeq contours, and the night-time 57 and 63dBLAeq contours, are all forecast to rise between 2010 (under the existing runway system) and 2030 (by which time when the Airport will be operating two runways). BIA is clearly unfazed by this clear evidence of a growing noise impact, and is content to point to the 'significant reduction' the Draft Master Plan proposals have achieved in the forecast size of the affected population compared to the White Paper and 'Birmingham Alternative' [12].

10. The tendency to rely on 'external drivers' to deliver environmental policy goals is evident in the Draft Master Plan's approach to noise 'mitigation'. The ERCD study is 'rather cautious in its assumptions' concerning 'future noise improvements that are expected to be achieved from advances in aircraft engine technology' pre-2030, and therefore represents a 'worst case Scenario'. The study 'assumed current aircraft types and noise assumptions in 2010, 2015 and 2020, but a 14dB improvement, relative to the 'Chapter 3' noise certification standard for aircraft types, is assumed in 2030 (the 14dB figure is the cumulative noise reduction achieved at the three noise measurement points used during noise certification) . . . Although it is still not absolutely certain that all aircraft types would achieve the 'Chapter 3 14dB' improvement by 2020, many (or most) aircraft types will' [13].

11. Such 'techno-optimism' may be misplaced. The White Paper admits that 'action is needed to prevent a deterioration in the noise climate as growth in air traffic overtakes the rate of technological advance' [14]. 'Chapter 4' standards already met by 98 per cent of aircraft currently in production and there will be no global phase-out of existing 'Chapter 3' aircraft [15] so the older noisier aircraft will be around for years to come. The trend towards larger aircraft means that 'Chapter 3s' are not necessarily quieter, since the maximum permitted noise levels for each Chapter allow heavier aircraft to make proportionally more noise [16]. In any case, aircraft certifications can be misleading. A Boeing 747-400 with Rolls-Royce engines landing at Heathrow in the early hours has twice the effect assumed in its noise rating, almost double the legal limit [17].

12. In addition to the air noise study, the Airport Company voluntarily undertook a ground noise study to assess the future noise impact of aircraft ground running and engine testing. The ground noise study demonstrated that 'the unmitigated noise levels at the worst affected residential areas are all below the 'moderate annoyance' criterion. At worst, the noise levels are no higher than 48dBLAeq,16h which is not substantial having regard to the predicted background noise levels' [18]. However, the London Health Commission notes that there is 'a fair degree of consensus' that 'environmental noise above 40-55dBA Leq is likely to lead to significant annoyance' and 'outdoor noise levels of 40-60dBA Leq may disturb sleep' [19]. Moreover, as there are currently 'no definitive methods for the assessment of the impact of ground noise' [20], it would seem premature to conclude that the ground noise issue has been resolved.

13. The ground noise study neatly illustrates the Airport Company's aversion to the clear and objective targets for environmental improvement central to the Genuinely Balanced Approach. In deliberating over how to evaluate the impact, the Draft Master Plan mentions the benchmark values given by the World Health Organisation (WHO) report 'Guidelines for Community Noise' (1999). WHO recommends that 'to protect the majority of people from being seriously annoyed during the day time the sound pressure level in outdoor living areas should not exceed 55dBLAeq,16h', a guideline BIA considers to be 'very onerous' [21]. But surely, if it is indeed the case, owing to the 'conservative' [22] assumptions made with regard to future aircraft engine technology improvements, that the Draft Master Plan presents a 'worst case scenario' in terms of future noise impact, then BIA can afford to set such an ambitious target and work towards meeting it over the plan period through its policy of continuous environmental improvement?

14. The ground noise study 'focussed on aircraft ground noise and did not specifically undertake a ground noise study of road noise' [23], but considering that, local to the Airport and 'on key access routes within the West Midlands', the forecast growth of BIA 'will place increased demands on the surface transport network and systems' [24], the impacts of road traffic are likely to be significant. Indeed, evidence suggests that road traffic, because it is 'more changeable and less predictable', is more likely to cause sleep disturbance than air traffic. One study suggests living less than twenty metres from a busy road is a predictor of insomnia [25].

Air quality
15. As well as contributing to the deteriorating noise climate, the forecast precipitous increase in the volume of background and airport-related surface traffic over the plan period will have an adverse effect on local air quality. Road traffic at and around airports is the most significant source of local air pollution, after aircraft exhaust fumes and emissions from ground service equipment and auxiliary power units. The White Paper admits that 'compliance with mandatory air quality standards' will be 'particularly challenging at very busy airports served and surrounded by high levels of road traffic' [26]. According to the Environment Agency, transport is now the main source of air pollution (now that pollution from industry has fallen), and the main culprit in 95 per cent of designated Air Quality Management Areas in the UK. Transport is likely to have the most significant impact on air quality of all sectors over the next ten years unless further action is taken [27].

16. The results of the Air Quality Study commissioned by BIA from Manchester Metropolitan University's Centre for Air Transport and the Environment (CATE), while not indicating any 'future year exposure air quality standard exceedences' compared with UK Air Quality Standards, 'generally show increases in emissions' from airport-related sources (including the M42) 'in line with expectations that would result from increased air and road traffic' [28]. The table on page 92 of the Draft Master Plan shows emissions of five air pollutants (nitrogen dioxide, carbon monoxide, sulphur dioxide, hydrocarbons and particulate matter) from airport-related sources (including the M42) will increase during the plan period and even (except in the case of sulphur dioxide) reversing the downward trend in emissions from 2003-2010 after 2016, when emissions start to rise again. As with noise, despite clear evidence of declining air quality and increasing emissions of several major pollutants, the Draft Master Plan is content to conclude that 'it is reasonable to assume that the actual 2030 position will be one of lower emissions' [29] than forecast in the CATE study.

17. The reliance on 'external drivers' is evident here also. Like the ERCD study, the CATE study is assumed to represent a 'worst case' scenario regarding aircraft emissions, owing to how 'the data was obtained by projecting forward an aircraft fleet mix based on current types'. The emissions reductions expected as a result of newer aircraft types coming 'on stream' and older aircraft being retired, and the effect of the new ICAO standard for nitrogen oxides emissions applicable from 2008, and ACARE's target for an 80 per cent reduction in nitrogen oxides emissions for new aircraft in 2020, were not built into the study [30].

18. Techno-optimism in this area must contend with the relative maturity of gas-turbine engine technology [31]. According to the DfT, the Advisory Council for Aeronautics Research in Europe (ACARE) believes that 'the consensus view is that the rate of progress for conventional engines will slow down significantly in the next 10 years' [32]. Future aircraft fuel efficiency savings will be lower than those already achieved: from 1960-1970, an annual technology-induced fuel efficiency improvement of 6.5 per cent was achieved but this rate fell to 1.9 per cent during the period 1980-2000.

19. A recent report by the National Aerospace Laboratory (NLR), an independent non-profit research institute based in the Netherlands, raises serious questions about forecasts of future increased aircraft fuel efficiency. According to the authors, the common practice of defining future cuts in energy consumption per seat-kilometre in terms of a constant annual percentage reduction is 'not very accurate' because it 'ignores the fact that current aircraft configurations can never achieve zero fuel consumption. Nor does it take into account that the annual reduction rate is not a constant, but is itself also falling'. The authors conclude that 'many studies on predicted future efficiency gains are rather optimistic' [33].

20. If the benefits of cleaner engines and stricter emissions standards are to be realised, then BIA must use their policy of continuous environmental improvement, backed up by clear, objective targets, to ensure that the overall emissions output is not allowed to rise faster than technological refinements can be introduced to reduce emissions. Although the Airport Company makes many welcome commitments to undertake further studies and monitoring, 'conserve energy', 'promote the use of public transport', 'ensure cleaner and more efficient ground services equipment', and 'raise awareness of air quality issues' [34], a clear commitment to adopt and enact policies to prevent air quality deterioration as a result of the growth in airport and airport-related activity over the plan period is absent. Without clear targets it is unlikely that the policy to 'measure, monitor and report on ambient air quality levels' and 'impose operational measures to improve local air quality' [35] will be successful.

4. Challenging 'predict-and-provide'

Back to top

21. The Genuinely Balanced Approach challenges the policy of 'predict-and-provide' implicit in the White Paper and the Draft Master Plan. Predict-and-provide assumes that the main drivers of growth in demand lie outside policy control and therefore views the aim of policy as providing capacity where and when it will be required. On the road network, predict-and-provide essentially 'involved planners estimating future traffic levels and politicians sanctioning large road building programmes in response' [36].

22. The Government has since come to realise that no feasible road programme can keep pace with unrestricted traffic growth, and the building of new roads has become 'a measure of the last resort rather than one of the first' [37]. Labour has frequently stressed that it rejects the predict-and-provide approach to road building. In its 1998 White Paper, 'A New Deal for Transport', the Government declared that simply 'building more and more roads is not the answer to traffic growth . . . The days of predict and provide are over'. The White Paper instead pledged to 'give top priority to improving the maintenance and management of existing roads before building new ones' [38]. In 2004, Secretary of State for Transport Alistair Darling said, 'we must be smarter than predict and provide, managing people's need to travel and respecting our environment' [39].

Predict-and-provide in the White Paper
23. According to the DfT, 'use of the Government's UK air traffic forecasts does not imply a commitment to the "predict and provide" approach; that would only be the case if Ministers were to decide to provide airport capacity to meet unconstrained demand without regard to the consequences' [40]. However, the White Paper has been widely criticised for pursuing predict-and-provide. The House of Commons Environmental Audit Select Committee has pointed out that the White Paper's recommended programme of national air transport infrastructure expansion provides for a forecast growth in air traffic from the current level of 180 million passengers per annum (mppa) to 476 mppa by 2030, a figure close to the DfT's central demand estimate of 500 mppa. The Committee concludes that the 'eagerness with which the Government is promoting growth is palpable' and that, despite Government protestations to the contrary, 'it is abundantly clear that the aviation White Paper adopts a "predict and provide" approach. The DfT has forecast future demand and then provided the framework to meet practically all of it. It is actively promoting growth on the scale envisaged, and indeed the urgency with which it is requiring airport operators to implement expansion plans bears this out' [41]. As one MP said of the White Paper, 'If that is not a predict and provide approach, I don't know what is' [42]. The Royal Commission on Environmental Pollution (RCEP) states that an 'unquestioning attitude toward future growth in air travel, and an acceptance that the projected demand for additional facilities must be met, are incompatible with the aims of sustainable development' [43].

24. Alistair Darling has defended the White Paper against the predict-and-provide charge, on the grounds that expansion was conditional on the achievement of stringent environmental criteria. However, in 2002 the RCEP noted 'recent ministerial comments, following publication of the consultation documents' which suggested that 'the government believes that current airport capacity must inevitably be increased to meet predicted demand' [44]. The Environmental Audit Select Committee notes that 'the White Paper makes it clear that these 'stringent environmental criteria' amount to no more than respecting existing targets on air and water quality, ensuring that developments are consistent with existing arrangements for the control of the noise impacts of aviation, strengthening proposals for mitigating environmental impacts, and gradually introducing tighter standards for noise and emissions as it becomes feasible to do so' [45].

Predict-and-provide in the Draft Master Plan
25. The predict-and-provide approach is even more evident in the Draft Master Plan. Activity at BIA is expected to grow from 9.1 million passengers per annum (mppa)/116,040 Air Transport Movements (ATMs) in 2003 to 33 mppa/278,000 ATMs by 2030'(Baseline Scenario) [46], with future growth arising as a result of 'an increase in demand from the Airport's regional catchment area and a greater retention, or 'claw back', of traffic which currently travels outside the region to start air transport journeys at other airports' [47].

26. Like the White Paper, the Draft Master Plan adopts a policy 'which estimates future demand and then aims to satisfy almost all of it', an approach 'self-evidently based on a 'predict and provide'' [48]. For instance, Section 1 describes the purpose of the Master Plan as providing 'a detailed statement of the future land use requirements and sustainable development strategies, which will be necessary to accommodate the forecast growth in air transport activity' [49]. Section 2 describes the purpose of the Draft Master Plan as to identify 'the new airfield, passenger terminal and associated ancillary facilities which can best accommodate the forecast growth in air traffic to 2030' [50].

27. The Draft Master Plan's supposedly 'sustainable' 'integrated, multi-modal Surface Access Strategy' is almost a textbook case of predict-and-provide. Not only is the further development of the Strategy seen as 'essential to support and sustain the forecast growth in activity at the Airport' [51], but the surface access policies themselves are designed along classic predict-and-provide lines. For example, based on the 'long term passenger forecasts', the Airport Company will 'provide sufficient car parking spaces at the Passenger Terminal Site' in order 'to meet the forecast growth in car parking demand for passengers and visitors' [52]. Even assuming that BIA meets the White Paper's target of a 25 per cent Public Transport Modal Share by the end of the plan period, parking demand is forecast to rise from 13,555 car parking spaces today (Appendix: Existing Site & Facilities at Birmingham International Airport', p136) to 41,350 spaces in 2030 [53].

28. The Draft Master Plan's predict-and-provide approach spills over into a wish list of desired highway network 'improvements'. For instance, the Airport Company expects the M42 motorway and Junction 6 (J6), 'in the longer term', to run out of sufficient capacity to 'accommodate the forecast growth in road traffic for the M42 corridor', requiring 'additional link capacity on the M42 and a new or improved junction south of J6' and 'new or improved link roads to the Passenger Terminal Site' [54]. Another example is the Airport Company's support for the proposed widening of the M42 (SAP4).

29. Only casual reference is made to alternative strategies such as 'road pricing', 'congestion charging' or 'some form of restraint in the growth of background traffic'. The Airport Company 'recognises the role of such measures and seeks to work Government, local authorities, and regional stakeholders to consider how such measures can be successfully applied to the West Midlands' [55], but is clearly more strongly committed to the predict-and provide approach long since discredited in connection with road building. The Government on the other hand has estimated that network-wide road pricing would reduce congestion by five to ten times more than all the schemes in its Ten Year Transport Plan, and with better benefit-cost ratios. Indeed, 'there is no sustainable transport strategy without demand management', and the 'only demand management tool which can pay for itself is road pricing' [56].

30. A particularly interesting illustration of the way in which predict-and-provide arguments once advanced in support of road-building have been resurrected for airports is the strategy to reduce 'unnecessary' surface journeys by enabling regional airports to 'claw back' aviation activity from the south-east. The logic of 'claw-back' is that the provision of a more extensive network of services at BIA will enable the Airport to satisfy a larger proportion of the growing regional demand for air travel where it arises, within the West Midlands region. Thus by capturing a greater proportion its regional market, in the form of passengers who would otherwise travel outside the region to start air transport journeys at other airports, BIA will apparently 'reduce the overall volume of surface journeys in the UK' and with it the 'congestion and environmental impacts of unnecessary surface journeys' [57].

31. New road building schemes were frequently justified in similar terms, with developers and the government arguing that new roads would remove traffic from towns and thus reduce local pollution and congestion. But, as the Standing Advisory Committee on Trunk Road Assessment (SACTRA) has shown, this resulted in a vicious circle of increasing traffic prompting more road building which, in turn, generated increased traffic and congestion. The predict-and-provide approach to airport expansion is not confined to the Midlands. Other airport operators are preparing their own master plans around accommodating their own growth forecasts. Attempting to 'claw back' passengers currently being lost to airports in the South East might have made sense if the Government had opted to constrain the growth of Stansted, Heathrow, Gatwick and Luton, but it has not. The supposed environmental (and economic) benefits of capturing an increased proportion of the BIA's regional demand will only be felt if the overall growth in air travel and associated surface access journeys is prevented from growing so much and so fast as to cancel out the savings in emissions, time etc.

32. As with noise and air quality, BIA should not rely on national government policies like road pricing to deliver the Airport's sustainable surface transport strategy. As with aircraft noise and air quality, there is no substitute for the proactive policy of continuous environmental improvement, backed up with clear targets for preventing the impact of surface traffic growth from outstripping the rate at which the impacts can be reduced. Such a policy is vital if BIA is to 'enable a more efficient use of the Airport's operational land and reduce the environmental impact of the Airport' [58].

33. Effective targets for environmental improvement should be based on raw data, not on misleading percentage figures. A good example of the need for raw-data targets is the White Paper's long-term target of 25 per cent surface access by public transport. A surface access strategy based on this 25 per cent Public Transport Modal Share target can deliver 'significantly greater use of public transport' [59], but only at the cost of allowing a vastly greater parallel increase in the volumes airport-related surface traffic on an already over-stretched local road network. The Draft Master Plan includes numerous welcome proposals aimed at promoting public transport use among passengers, airport staff and visitors, such as the policies to develop Green Travel Plans, and an Air Rail Access Strategy, and to expand and improve the Airport Bus Network. But without an absolute limit on the growth of private car journeys by all users of the Airport, the private car will continue as the largest mode of surface access, and local to the Airport 'and on key access routes within the West Midlands', the forecast growth of BIA will continue to 'place increased demands on the surface transport network and systems' [60].

34. In conclusion, the potential for forecast air traffic growth to outstrip the rate of the continuous environmental improvement made possible through technological and operational innovation, and therefore to result in environmental deterioration, means that forecast growth in passenger numbers/ATMs should not serve as the principle guide to the nature and timing of the Master Plan proposals. The policy that 'a runway extension, second runway and the necessary airspace capacity are provided, as demand arises' [61] is incompatible with the Genuinely Balanced Approach. Growth of the Airport should be determined by the rate at which Airport Company policies can deliver continuous environmental improvement over time. There can be no reason to allow the rate of growth in air transport to overtake the rate of environmental improvement brought about through innovations in aircraft design and operational methods.

5. Applying the Genuinely Balanced Approach to the Master Plan

Back to top

35. The Draft Master Plan policies can be divided into five broad categories: Category 1 policies, such as the new Second Runway, intended to accommodate the forecast growth in air traffic; Category 2 policies intended to support Category 1 policies; Category 3 policies intended to enable 'best use' to be made of the Airport's existing capacity up to the 'maximum single runway capacity of 48 movements per hour' [62]; Category 4 policies intended to 'mitigate' environmental impacts; and Category 5, miscellaneous policies.

Table 2: Summary of a Genuinely Balanced Approach to the Draft Master Plan proposals

6. Conclusion: Putting the economic impact in perspective

Back to top

36. The Genuinely Balanced Approach does not preclude the Airport continuing to 'serve the Midlands' need for access to air travel and air transport', bring 'direct economic and social benefits to the Central England Region' and support 'regional economic development and regeneration' [63], but it does attempt to place 'environmental progress' on a equal footing with economic growth and social inclusion.

37. We strongly dispute the Government's claim that 'not providing additional capacity would significantly damage the economy and national prosperity' [64]. Even in purely economic terms, transport growth is far from an unmixed blessing. The White Paper itself, after initially extolling the economic benefits of both in-bound and out-bound tourism', admits that the Government is concerned about the widening gap in the tourism balance of payments [65]. As SACTRA has argued, while in certain circumstances transport schemes may bring added economic benefits to an area needing regeneration, 'in other circumstances the opposite might occur. Better communications will enlarge markets for goods, services and workers: the area may gain or lose from this depending on the structure and competitiveness of the local economy. It follows that there is no simple, unambiguous link between transport provision and local regeneration' [66].

38. We acknowledge that, in a competitive market dominated by aggressively expansionist airport operators and airlines, BIA would be taking a considerable risk by adopting the Genuinely Balanced Approach alone. However, we believe airport operators can and should influence national policy in the direction of genuinely sustainable development. This year's progress report on the White Paper offers an opportunity to promote the Genuinely Balanced Approach as a much needed alternative to current government aviation policy.

39. It is interesting to note that the 2003 Energy White Paper is currently undergoing review. Peter Ainsworth MP has suggested that, as has already occurred in the energy sector, 'we may be on the threshold of a paradigm shift in terms of the development of aviation', a shift that has the potential to 'destroy departmental planning' [67]. For instance, in the 1970s, the Government was forecasting that the demand for electricity-generating capacity would grow at a rate of 7 per cent per annum, as it had done for the previous thirty years. On that basis, it developed plans for a new generation of nuclear power stations. But by the end of the decade the Government's forecasts had been proved wrong, and of the ten nuclear power stations envisaged only one, Sizewell B, was eventually built.

7. Note on the Health Impact Assessment

Back to top

40. Although the DfT in its guidance on the preparation of airport master plans did not consider it necessary to produce a Health Impact Assessment (HIA) as part of the master plan process, BIA has opted to undertake producing such an HIA covering the major development proposals and set up of an independently chaired 'Health Impact Assessment Group' [68].

41. The London Health Commission defines HIA as 'an approach to ensure that decision making at all levels considers potential impacts on health and health inequalities, and identifies actions that can enhance positive effects and reduce or eliminate negative effects' [69]. Although HIA is a new and developing approach, it is increasingly being recognised nationally and internationally. Developing and promoting the use of HIA is one of the supporting priorities of the London Health Commission, and the organisation has a number of resources available to support those considering or conducting HIAs.

42. BANG welcomes BIA's decision to go beyond the Government's requirements in proposing an HIA and we concur with the recommendation of Solihull Regeneration and Community Safety Scrutiny Board (20th January 2006) that BIA should 'progress swiftly' with the proposed HIA. We would like to see the Genuinely Balanced Approach explored above in relation to environmental impacts applied also to the heath impacts of the Airport's development and operation. Broadly, this would involve a proactive policy to reduce (or prevent from increasing) the Airport's impact on the health of the local population over the plan period.

James Botham
Secretary
Birmingham Airport anti Noise Group (BANG), March 2006

8. References

Back to top

1. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.4.8 and para.4.10.
2. Ibid., para.6.1.2. The sentiment is echoed by the Airport Company's 'vision for sustainability': 'Bringing direct economic and social benefits to the Central England Region, and playing our part as a responsible and proactive citizen whilst minimising the impact of our operations and activities on the environment', para.6.1.6.
3. Ibid., para.6.1.1.
4. House of Commons Environmental Audit Select Committee, 'Environmental Audit: Third Report', March 2004, para.9. See www.publications.parliament.uk/pa/cm200304/cmselect/cmenvaud/233/23305.htm.
5. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.4.8.
6. Ibid., para.10.1. The Airport Company 'will seek and promote environmental improvement through the continuous development of an Environmental Management System', para.6.5.1.
7. The major environmental impacts, for which environmental studies were undertaken as part of the Master Plan Review process, include: noise, air quality, water resources, ecology (& archaeology), and landscape and visual. Greenhouse gas emissions should also be included, although no work has been done to assess the impact of the Draft Master Plan proposals in this crucial area. Surface traffic growth, for which separate work was carried out, can be considered a cross-cutting impact, with its own implications for all the areas listed.
8. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.6.5.1.
9. Ibid., para.7.2.3.
10. Ibid., para.7.3.12.
11. Ibid., para.10.12, para.10.15 and para.10.18.
12. Ibid., para.10.13-14.
13. Ibid., para.10.9.
14. HM Department for Transport, 'The Future of Air Transport' White Paper, December 2003, para.3.10.
15. 'Aircraft Noise', AirportWatch briefing, 2003.
16. 'Aviation and Noise', AirportWatch briefing, December 1998.
17. The Times, 27th May 2003.
18. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.10.29.
19. London Health Commission, 'Noise & Health: Making the Link', August 2003, p5. See www.londonshealth.gov.uk.
20. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.10.27.
21. Ibid., para.10.28.
22. Ibid., para.10.18.
23. Ibid., para.10.26.
24. Ibid., para.9.2.
25. Kageyama et al., 'A population study on risk factors for insomnia among adult Japanese women: a possible effect of road traffic volume', Sleep 20, 1997, pp963-71, cited in London Health Commission, 'Noise & Health: Making the Link', August 2003, p7.
26. HM Department for Transport, 'The Future of Air Transport' White Paper, December 2003, para.3.30.
27. 'Transport is now the main source of air pollution as industrial emissions drop', News Environment, 11th February 2005.
28. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.10.39
29. Ibid., para.10.41.
30. Ibid., para.10.40.
31. 'The Environmental Effects of Civil Aircraft in Flight', Royal Commission on Environmental Pollution, November 2002.
32. HM Department for Transport, 'Aviation and Global Warming', January 2004, para.3.44. See www.dft.gov.uk/stellent/groups/dft_aviation/documents/page/dft_aviation_031850.pdf.
33. P. M. Peeters, J. Middel & A. Hoolhorst, 'Fuel efficiency of commercial aircraft: An overview of historical and future trends', National Aerospace Laboratory, November 2005, p3. See www.t-e.nu/docs/Publications/2005pubs/2005-12_nlr_aviation_fuel_efficiency.pdf.
34. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.10.41 and ENV13-16.
35. Ibid., para.6.5.1.
36. University of Aberdeen Media Release, 'New study reveals true extent of Government's road-building programme', Issued by the Public Relations Office, University of Aberdeen, King's College, Aberdeen, 13th December 2000. See www.abdn.ac.uk/mediareleases/archive/2000/pr780.hti.
37. HM Department for the Environment, Transport and the Regions, press release No. 216, 1997.
38. DETR, 'A New Deal for Transport: Better for Everyone', White Paper, July 1998. See www.dft.gov.uk/stellent/groups/dft_about/documents/pdf/dft_about_pdf_610276.pdf.
39. Alistair Darling MP, 'The Future of Transport: Preface by the Secretary of State CM 6234', July 2004.
40. HM Department for Transport, 'The Future Development of Air Transport in the United Kingdom: South East (full report)', February 2003, para.5.2. see www.dft.gov.uk/stellent/groups/dft_aviation/documents/page/dft_aviation_026012-08.hcsp#P473_61466.
41. House of Commons Environmental Audit Select Committee, 'Environmental Audit: Third Report', March 2004, para.11-12.
42. Peter Ainsworth MP, 'Environmental Questions the Review should ask', speech to the Greener By Design Conference, Royal Aeronautical Society, London, 2nd November 2005. See www.nobristolairportexpansion.co.uk/ainsworthspeech.html.
43. Royal Commission on Environmental Pollution (RCEP), '18th Report: Transport and the Environment', October 1994.
44. RCEP, 'The Environmental Effects of Civil Aircraft in Flight', November 2002, para.1.7. See www.rcep.org.uk/aviation/av12-txt.pdf.
45. House of Commons Environmental Audit Select Committee, 'Environmental Audit: Third Report', March 2004, para.9. The comment refers to para.3.5-3.7 of the White Paper.
46. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.5.18. Figures for 2003 from 'Appendices: Air Transport Trends at Birmingham International Airport', p138.
47. Ibid., para.5.8.
48. 'Aviation: Sustainability and the Government Response', House of Commons Environmental Audit Select Committee Seventh Report of Session 2003-04, HC 623, June 2004. This report was the Committee's response to the Government's formal reply to the Committee's previous report on aviation, published March 2004.
49. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.1.9, italics added.
50. Ibid., para.2.ii, italics added.
51. Ibid., para.9.4.
52. Ibid., para.9.32.
53. Ibid., para.9.30.
54. Ibid., para.9.23.
55. Ibid., para.9.65.
56. Prime Minister's Strategy Unit, 'Predict and Provide', February 2006. See www.strategy.gov.uk/downloads/su/transport/achieving.pdf.
57. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.1.5 and para.9.1.
58. Ibid., para.9.37.
59. Ibid., para.9.35.
60. Ibid., para.9.2.
61. Ibid., para.5.16.
62. Ibid., para.7.2.8.
63. Ibid., para.4.8.
64. Ibid., para.4.2.i.
65. HM Department for Transport, 'The Future of Air Transport' White Paper, December 2003, para.4.21-4.23.
66. HM Department of the Environment, Transport and the Regions (DETR) & Standing Advisory Committee on Trunk Roads Assessment (SACTRA ), 'Transport Investment, Transport Intensity and Economic Growth: Interim Report', 1998.
67. Peter Ainsworth MP, 'Environmental Questions the Review should ask', speech to the Greener By Design Conference, Royal Aeronautical Society, London, 2nd November 2005.
68. BIA Ltd. Draft Master Plan, 'Towards 2030: Planning a Sustainable Future for Air Transport in the Midlands', October 2005, para.10.73-4
69. London Health Commission, 'Noise & Health: Making the Link', August 2003, p16. See www.londonshealth.gov.uk/hia.