CONSULTATION PAPER
Department of the Environment, Transport & the Regions

THE FUTURE OF AVIATION
Submission by THE GENERAL AVIATION AWARENESS COUNCIL

DETR CONSULTATION PAPER 'THE FUTURE OF AVIATION': SUMMARY

1. The UK has no unified national policy for aerodromes. Without such a policy the national transport infrastructure is at risk. [para.5]

2. GA issues should not be decided at local level unless it is in the context of a strong national policy that recognises the worth of each individual site to the national transport infrastructure. [para. 10]

3. Regional Planning Guidance as it affects aviation should be strengthened, not weakened as in the draft guidance. [para. 11]

4. Planning Policy Guidance should be strengthened. [paras. 12 and 14]

5. The closure of local aerodromes or the eviction of flying training organisations from existing aerodromes without there being satisfactory alternative sites is contrary to consumers' interests. [para.20]

6. The pollution caused by GA is minimal. [para. 22]

7. Artificial restriction of the growth in aviation would have serious consequences for the economy. [para. 25]

8. Every inhabitant of the UK is a consumer of aviation services. [para. 27]

9. Regulation is essential where safety is involved. [para. 29]

10. Aviation developments bring positive economic benefits to local economies. [para. 33]

11. Local aerodromes should be developed to facilitate the more efficient conduct of business not only within the UK, but more particularly with the rest of Europe. [para. 33]

12. Noise issues must be addressed by embodying national standards in a revised PPG 24. [para. 37]

13. Noise reduction kits accepted in other JAA states should be accepted in the UK without further costly certification. [para. 38]

14. GA must not be priced out of the sky by penal landing and other charges. [para. 40]

15. The provision of pilot training facilities is a national problem that cannot be left to decision at local authority level. (para. 40)

16. GA interests should be represented in any aerodrome consultative procedures. [para.43]

17. If an integrated transport policy is to have any meaning central government must be involved where aerodrome closures are threatened. A statutory procedure for closures should be introduced. [para.44]

18. Alternatives to road connections between the London airports must be developed. [para. 45]

19. Central government must accept that General Aviation is an essential component of the national transport, business and leisure infrastructure and that the preservation and development of its facilities should not be left to the parochial whim of local authorities. [para. 48]

'Future of Aviation' - Consultation Paper December 2000
Submission by the General Aviation Awareness Council

Introduction.

1. The General Aviation Awareness Council (GAAC) is the body that oversees the matters that are of concern to all sectors of General Aviation (GA). The Council concentrates its efforts on matters concerned with planning and education in the widest sense. A list of Member bodies of the Council is given at Appendix I.

2. GA embraces a wide variety of activities ranging from flying training to business aviation, recreational aviation and model aircraft flying. To place GA in perspective, the commercial airlines in the UK operate about 850 aircraft and use 23 airports. The UK GA fleet comprises more than 10,000 aircraft that operate from 140 licensed airports and aerodromes and more than 350 private airstrips. More than 70% of all GA activity has some business or safety purpose. 85% of all seats sold by airlines are for pleasure purposes.

3. Pamphlets issued by the Council have covered both these aspects. Three pamphlets produced by the Council are relevant to the 'Future of Aviation' consultation paper. They are concerned respectively with explaining the need for 'Your Local Aerodrome', how pilots and aerodrome operators can promote 'More Considerate Flying' and an environmental picture of small aerodromes in 'How Green is your airfield?' [Copies are enclosed with this submission]

4. The allocation of only two pages of the document to GA is out of proportion to the size of the sector, the problems that confront it and their relevance to the health of the whole of UK aviation and the economy.

5. The most important message of this submission is that the UK has no unified national policy on aerodromes. This underlies all the comments that follow. A positive policy for aerodromes must ensue from this consultation process. GA has to be recognised as an essential element of the UK's national transport, business and leisure infrastructure. The policy should incorporate elements of the advice embodied in Planning Policy Guidance circulars (PPGs) and Regional Planning Guidance circulars (RPGs) and hence give such advice added weight in the decision making process.

6. The following comments refer specifically to Chapter 11, but, as many issues relevant to GA arise in other parts of the document, comments on the rest of the paper follow those on GA.

Comments on the General Aviation section (Chapter 11):

7. While the economic impact of business and leisure aviation may be regarded as having different economic impacts so far as the primary activity is concerned, both have the same secondary impacts on local economies in terms of the supporting services required and the local employment created.

8. Although the planning system may be regarded as appropriate for resolving issues such as noise at both large airports and smaller aerodromes, it is heavily weighted in favour of the larger airport. In such cases the resources available to handle the planning process guarantee a successful outcome for the larger airport, which will usually have Government backing on transport policy grounds. Despite the national transport policy implications of providing a local hub for commercial activity, central government refuses to make any input where the future of local aerodromes is involved. All the running at local planning inquiries is made by the NIMBY lobby which generally secures the support of the majority of local councillors and the local MP, all of whom know that there are more votes to be obtained by supporting the anti-aviation section of the electorate. This highlights the impossibility of ensuring that factors of national import are given due weight.

9. The GAAC has reservations not only about the absence of national considerations being introduced into the planning equation, but also about the objectivity of the planning system. This is called into question when an incident occurs such as that when a planning inspector was replaced because local objectors learned that he held a pilot's licence and claimed that he could not possibly be impartial. Have inspectors at road planning inquiries been replaced because they hold a driving licence?

10. It is clear therefore that GA issues should not be determined at the local level, unless in the context of a strong national policy which recognises the worth of each individual site to the national transport infrastructure in the context of an integrated strategy for all forms of transport. It is all too easy for one District/Borough or County to have a restrictive policy in place without any consideration to the "knock-on" effects on surrounding areas. For example, the attitude of County Councils such as Warwickshire or Surrey ignores the fact that these authorities are part of a national picture. In the continuing absence of a national policy on GA issues - as part of an aviation policy for the UK - these serious problems will continue unchecked.

11. The GAAC has already registered its concern at the backward step taken in the latest draft RPG for the South East Paragraph 6.40 of the current version of RPG9 provides a helpful background on GA issues, whereas any such reference is omitted from the latest draft..

12. The strengthening of PPG 13 could be effected with only minor changes to the current draft, which should read:

" ..... Small aerodromes are also important. They serve business, recreational, training and emergency services' needs. As demand for commercial air transport grows General Aviation (GA) finds access to larger airports increasingly restricted. GA operators therefore have to look to smaller airfields - or new sites - to provide facilities. In formulating their plan policies and proposals, local authorities should take account of the fact that GA aerodromes are part of the national transport infrastructure. More particularly they make a valuable contribution to local and regional economies. to the national need for pilot training and to the locality which benefits from having suitable facilities."

13. It is not however only the direct commercial activity of business aviation that benefits the areas in which GA aerodromes are situated. Economic activity is generated by all types of GA in the form of the supporting engineering and commercial services and the downstream employment that each creates. There is a strong contrast between the attitude of local authorities in the UK with that of those in France where most towns of any size have aerodromes that are regarded as playing an essential role in the economic well-being of the town and which are frequently run by the local Chamber of Commerce.

14. Turning to the specific questions posed in the document:

a) PPG 13 The reply is that the PPG can obviously strengthened as is suggested above. This however is only a Guidance document and can be respected or ignored as the local authority thinks fit. There is frequently another PPG that a local authority can quote to support its case for rejecting any application associated with increased aviation activity (eg. PPG 24 on noise). 15. A major defect in the planning system, so far as it affects local aerodromes, is that it gives no weight to national factors. Local factors have supremacy. The fact that there is a superior case to be made on national policy grounds invariably plays no part in decisions affecting local aerodromes.

16. There is generally a lack of appreciation of aviation issues at local authority level with the result that while the majority of aviation planning applications are refused, the majority of those that go to appeal are subsequently successful. This is in stark contrast to all other categories of planning application. The fact that so many have to go to appeal to be successful reveals a lack of understanding of aviation planning issues and results in unnecessary costs being imposed not only on the appellant, but also on the local authority. (e.g. South Cambs District Council in the case of Little Gransden).

17. b). Access of Business Aviation to major airports. With better management there is no reason why there should not be increased access by Business Aviation (BA). There must however be a fair tariff for the use of major airports' services. In several cases GA operations are being squeezed out by the imposition of extortionate landing charges that cease to make the GA operation viable at that airport. The availability of dedicated GA/STOL runways at the busier major airports would facilitate more efficient passenger movement and reduce road congestion. A further study of how business aviation and commercial air transport manage to operate successfully side by side at very busy airports in the USA would demonstrate that there is scope for increased access to major airports by business aviation.

18. The following comments cover aspects of the remainder of the document that are relevant to GA.

Main questions (Chapter 2)

19. a) Unless consumers' needs for aviation services are met or restrictions on aviation growth are imposed Europe-wide, there will be an inevitable switch of air transport hubs to the continent and London airports will go the same way as the port of London.

20. Consumers may object to aviation developments as they directly and overtly affect the environment in which they live, but woe betide any government that restricts their freedom to travel as they wish on holiday flights. Thus the closure of local aerodromes that launch future airline pilots on their careers , or the exclusion of GA without an alternative location, is contrary to consumers' interests.

21. b) So far as the environmental effects of aviation fuel use is concerned the following figures for the year 1999 put the pollution caused by aviation activity in perspective:

22. Taking a parochial UK environmental stance it is clear that pollution from air transport is minute compared with that from road transport. While virtually all the road fuel will be consumed on UK roads and the pollutants discharged at ground level, the large majority of the fuel 'consumed' by air transport is not used in UK airspace. So far as General Aviation is concerned the largest proportion of GA aircraft use aviation gasoline (Avgas) of which consumption is insignificant compared with that of aviation turbine fuel (Avtur).

23. Given the nature of air transport operations, any initiative taken to levy an environmental charge on aviation fuels would have to be subject to international agreement.

24. c) If aviation meets its environmental costs there is no reason to limit its growth. Except over the shortest routes rail transport fails to offer an acceptable alternative to air travel. There are of course some exceptions to this. For example the Eurostar service from central London has reduced the demand for air services to Paris and Brussels, as have high speed rail services in France and Germany.

25. d) There would be a serious impact on the UK economy if it were to reduce its role as a major hub for international traffic. There is considerable scope for developing services from regional airports and for encouraging the development of small aerodromes that permit direct connection with towns within the UK and on the Continent and thereby improve business efficiency and, by permitting direct flights, reduce demand on major airports and the road traffic congestion around them.

26. e) Capacity has to be made available to meet UK consumers' needs for both freight and passenger traffic if economic growth and employment are not to be impaired. Imposing additional taxes on air travellers, particularly on business travel would have an unacceptable inflationary effect and would further affect UK competitiveness.

Consumer Issues (Chapter 4)
Who are the consumers?

27. Consumers embrace the whole of the community to a greater or lesser extent. At the front are the regular commercial air transport travellers - pleasure and business - and the users of freight services, but every member of the population is a consumer of aviation services to a greater or lesser degree. Many imported goods - particularly perishables - arrive in the UK as air freight and much of the distribution of post and newspapers within the UK is provided by air operators. Many other services to the public are also dependent on the aviation industry, for example air ambulances, security patrols, traffic monitoring, fishery protection. The list is endless. The message that every person in the population is a consumer of air transport and general aviation services must be conveyed to the public

28. To the extent therefore that aviation growth is artificially curbed in any way it will impact on every inhabitant. It is against this background that the following comments are offered.

29. a) In striking the balance between regulation and voluntary action there is one aspect that has to be the subject of regulation, namely safety. This has to embrace the aircraft, their operation and air traffic control. Additionally, ensuring that airports are located in a safe environment and that the area around airports of all sizes is adequately safeguarded has to be the subject of regulation. In these instances the body responsible for ensuring safety by regulation has to be the Civil Aviation Authority. Delegating powers to local authorities or other bodies unfamiliar with aviation practice can only result in a lowering of safety standards. The CAA's review of the allocation of responsibility for aerodrome safeguarding, which it is assumed has as an objective the reduction of CAA responsibilities in this area, is a very worrying development in the safety context

30. Another area in which there is a case for intervention by the Government or the CAA, according to the particular issue, is where there are capacity constraints that should not be resolved solely by market forces or the power of a dominant airline. Examples of this are rife. Smaller operators are being excluded from some of the larger airports in the UK in order to accommodate claimed increases in commercial movements. This is effected by either terminating the tenancy of the user or by raising airport charges such as landing fees to a level at which economic operation ceases to be viable. This is a major problem because there are seldom alternative locations for the displaced operation, particularly where flying training is involved.

31. Except where safety and health are concerned the majority of other issues can be left to be resolved by normal competition between the suppliers and users.

32. The GAAC has no formal views on the other consumer issues

Economic Effects (Chapter 5)

33. The GAAC has no evidence of negative economic effects associated with the development of airports. In fact the reverse would appear to be the case as an airport attracts associated activities that can only be of benefit to the local economy. There is considerable scope for developing local aerodromes as is recognised in PPG 13 - see the foregoing General Aviation section of the consultation document. Their development could greatly benefit business users by facilitating direct access to other towns in the UK and more importantly to markets within the rest of Europe. This would reduce the time taken for business travel by cutting out the need to route via busy larger airports and also contribute to a reduction in road congestion around them.

34. Such imaginative developments as that of the Farnborough F1, which depends on the availability of a national network of smaller aerodromes, cannot succeed unless central government not only accepts such a network as being an essential part of the national transport infrastructure, but is also prepared to change its policy and recognise this.

35. The GAAC has no formal views on the other questions posed in this section.

Environmental Effects (Chapter 6)

36. The environmental impact of General Aviation is minimal, though one would not think this to be the case given the antipathy to GA that exists in some quarters. The scale of the pollution effect was given in the introductory section, but is worth repeating here. The use of aviation gasoline - the fuel used by the majority of GA aircraft - amounted to only 44 thousand tonnes in 1999 compared with 21.5 million tonnes of motor gasoline.

37. Noise is the issue that is most frequently raised when there are objections to GA operations. The present noise measurement arrangements are haphazard and unsatisfactory, different standards being used at different locations with the result that an operator facing a public inquiry has no foreknowledge of whether his operation is likely to meet the criteria set down in a particular case. There is an overwhelming case for establishing national standards. This would economise greatly on the time taken in the whole process of aerodrome planning, particularly where an application goes to public inquiry. The GAAC has in preparation a report on how the situation might be rationalised. This will be submitted to government with recommendations later this year..

38. Noise reduction kits - improved silencers and alternative propellers - are fitted to many foreign registered aircraft. However there is a financial disincentive to use such kits in the UK, as the CAA insists that they should undergo further certification tests, despite the fact that they are acceptable in other JAA states. In several cases noise reduction kits have been removed from imported aircraft, the alternative being to undergo full re-certification to accord with CAA standards, often at a cost in excess of the kits themselves. This inflexibility on the part of the CAA must be addressed if environmentally friendly operation is not to be penalised.

39. Further views on Aircraft Noise mitigation were submitted to the Department in our response to the Consultation Document on Aircraft Noise in September 2000.

Airports (Chapter 7)
Airport Capacity

40. A major problem facing GA is the increasing reluctance of the larger airports to accept GA movements, particularly flying training. Measures used to discourage GA include the reduction of the number of flying training operators permitted at a particular location and the raising of landing charges to such an extent that continued operation is no longer commercially viable. It is essential that as such operations are displaced the government should support applications to establish alternative training facilities. Ministerial statements that "We will seek to continue to support general aviation…" (House of Lords, 27 February 2001) are at variance with the recent written statement to the Aircraft Owners and Pilots Association that "The Government remains of the view that the development or closure of an airfield is a matter between the owner developer and the local planning authority…" The provision of GA facilities, particularly for pilot training, is a national problem. It cannot be left to decision at local authority level.

41. Northolt aerodrome provides useful facilities for business aviation, but although it handles relatively few movements these have reached the maximum agreed with the government some years ago. An increase in the number of permitted GA movements would reduce the pressure on the other London airports and facilitate a growth in business aviation movements and an improvement in business efficiency.

Airport Planning

42. a) PPG24 guidance is not easy to understand or interpret. While this PPG provides some useful guidance regarding the location of new development in proximity to noise generators, it does not provide similar advice in respect of the introduction of a new flying site. It also fails to provide adequate guidance regarding smaller sites (with under 30 daily movements). This has led to a considerable variety of interpretations of noise measurement, especially in the context of planning appeals. Furthermore, it has not been taken into account in a number of cases where new developments have been proposed in the vicinity of flying sites. As mentioned above the GAAC will shortly be submitting recommendations to standardise the approach to noise measurement with a view to making PPG24 less open to misinterpretation and dispute.

43. c) Where airport consultative committees are established there should be GA representation. There will be no airport at which there are no GA operations.

Integrated Transport

44. This section of the document refers only to the substitution of other forms of transport for air transport. It fails to refer to the scope for reducing traffic from the major airports, and hence the access traffic to those airports, by using smaller aerodromes for business flights for direct communication with European markets and other towns in the UK. The fairly recent loss of aerodromes with great GA potential, such as Ipswich, Leavesden and Hatfield, and the threat currently hanging over Rochester and some other aerodromes, indicate the need for an effective central integrated transport policy that can over-ride the parochial views of local planning authorities. The government's policy of allowing all planning matters affecting the smaller aerodromes to local council decision runs completely counter to the concept of an integrated system. One local authority may see its priority as being the provision of additional housing, completely disregarding the national transport requirements for which it has no responsibility. To safeguard the infrastructure it is essential that central government should have a positive role in the decision process. One way of ensuring that aerodromes are not lost without all factors being considered would be to ensure that the closure of licensed aerodromes should be subject to a statutory closure process similar to that followed before a railway line may be closed.

45. Another way in which road congestion could be relieved at and around the London airports and air journey times improved would be the restoration of the helicopter link between Heathrow and Gatwick and the introduction of similar links between all the London airports. This could reduce the reluctance of airlines to relocate to the airports at which there is still spare capacity. Direct rail links would be the optimum solution, which should be considered for the longer term. The Heathrow - Gatwick helicopter link ceased with the completion of the M25, but the M25 is quite incapable of providing a satisfactorily reliable connection between the two airports or with Luton and Stransted.

Airspace (Chapter 8)

46. The only observation that we wish to register under this section is that provision must be made for the vast number of GA aircraft that can and do operate outside controlled airspace. It is essential therefore that GA continues to be represented on bodies concerned with airspace allocation and classification irrespective of the future arrangements for the operation of NATS.

Airlines and Air Freight (Chapters 9 & 10)

47. The GAAC has no comments to offer on these chapters.

Conclusion

48. It is imperative that there is an acceptance by central government that General Aviation is an essential component of the national transport, business and leisure infrastructure and that the preservation and development of its facilities should not be left to the parochial whim of local authorities. 'Future Aviation Policy' must reflect this.

General Aviation Awareness Council
6 March 2001

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