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KEY INSIGHTS
COMPONENTS OF A SUSTAINABLE FRAMEWORK
UK Aviation would benefit from a policy
framework that is both robust and flexible;
The CAA considers that clarity and durability can
be achieved by formulating the policy framework at
two distinct levels:
o At the strategic level, the Policy Framework
should set clear objectives and outcomes;
o At the level of implementation, it is important that policy isconsistent with the levers available to Government, in order to
create a credible platform for delivery.
STRATEGY: DEFINING OBJECTIVES AND OUTCOMES
The CAA has a primary duty to ensure safety. Once safety has been assured, the CAAs view is that
the Governments focus should be to maximise consumer benefit subject to environmental constraints.
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The objective of the policy framework should be to facilitate development of an aviation sector that is:
o Safe and secure;
o Geared to delivering choice and value to consumers;
o Environmentally sustainable.
Safe and Secure
Safety and security underpin all other aspirations that the sector might have. Aviation policy should
be designed to ensure that flying remains amongst the safest ways to travel, with policy backed up by
a focus on continuous improvement by those best placed to deliver. This document does not focus on safety issues in detail. The Policy Framework should recognise
the State Safety Programme as the primary source of UK aviation safety policy.
Choice and Value for Consumers
The development of the Sustainable Aviation Framework offers an opportunity to look beyond
current economic difficulties and develop a sustainable framework that is consumer-focused at all
levels. The CAA considers that the Policy Framework should focus on delivering choice and value for
aviation consumers.
International comparisons show that UK aviation consumers are currently very well served in terms
of the choice available to them. The CAA suggests that the framework should set as a policy outcomethat the levels of aviation connectivity that UK consumers currently enjoy are at least maintained.
On the basis of the analysis set out in Aviation Policy for the Consumer, we consider that the
following broad levels of service provision would be consistent with achieving this outcome:
o For principal short-haul routes: All UK consumers should have access to direct connections to
principal short-haul destinations;
o For medium and long-haul routes: Consumers should have access to direct services from the UK to
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key global markets UK. Recognising that some routes may only be commercially viable if operated from
a hub airport, the Government should seek to facilitate successful hub operations in the UK. Consumers
using other UK airports should have single-stopover transfer access to the same key global markets.
Environmentally sustainable
The aviation sector will need to address and mitigate its environmental impacts in the areas of
climate change, noise and local air quality if aviation consumers are to continue to enjoy current levels
of choice and value.
Climate change outcomes should be framed in order to maximise emissions reduction whileminimising carbon leakage and competitive distortions.
The development of the aviation policy framework presents an opportunity to develop a new, twin-
track approach to noise policy focused on two high-level noise outcomes:
o Continued reductions in the numbers of people affected by noise; and
o Improved engagement with local communities.
The current framework for managing local air quality already sets clear national policy outcomes,
through mandatory targets.
IMPLEMENTATION: ACHIEVING OUTCOMES WITH LIMITED LEVERS
It is important that Government limits the outcomes it sets to those that it can achieve or influencethrough use of levers that it controls, or has the ability to create.
In considering the potential for policy intervention to deliver the outcomes, the Government should
address three questions:
o Whether to intervene?
o At what level to intervene?
o How to intervene?
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ADDRESSING THE CONSUMER OBJECTIVES
Direct short-haul connections for all consumers
The CAA does not consider that specific intervention is currently required in order to facilitate
continued high-levels of direct short-haul connectivity across the UK.
Direct access to key global markets from at least one UK airport
A number of non-infrastructure measures have the potential to enable better use of existing
capacity and introduce additional flexibility and resilience into the system, particularly in the short
and medium-term. We do not judge that these measures will have sufficient impact to represent a long-term
solution to the costs to consumers generated by capacity constraints.
Appropriate additional capacity could therefore deliver significant benefits for consumers. The
Framework should seek to set in place a platform which will facilitate a credible path to provision
of additional capacity.
Given the challenges to the delivery of major infrastructure in the UK, the development, in due
course, of a National Policy Statement for Aviation may help to build long-term confidence in the
Framework.
Single-stopover transfer access from other UK airports Passengers in the UK regions will continue to need to use a transfer airport to access the
majority of global destinations: either a UK hub, accessed by surface transport or a domestic
flight, or a foreign airport.
The Government faces a strategic choice in terms of how to ensure global access for aviation
consumers in the UK regions. Options available to the Government include:
o Facilitate access for regional consumers to a UK hub airport for example, by providing
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additional capacity, or;
o Explore, in discussion with European partners, the development of a network of European
hubs as a way of tackling security of supply issues.
ADDRESSING THE ENVIRONMENTAL OBJECTIVE
Climate Change
Climate change is a global challenge. The Government should continue to promote and
pursue a coordinated global solution for the aviation sector.
Despite the challenges to the inclusion of aviation in EU ETS, the European Union EmissionsTrading System (EU ETS) offers a next-best and interim solution.
Technical and operational measures, in particular the modernisation of UK airspace, offer
significant potential to improve the UKs performance on aviation emissions.
Noise
A number of policy options that are available to Government, the regulator and sector players
to reinforce the current trend towards noise reduction. The measures span changes to regulatory
or operational approaches, potentially backed-up by economic instruments.
In Aviation Policy and the Environmentwe also proposed a number of potential measures that
the Government could explore in order to unblock the policy stalemate around aviation noise. Areformed institutional framework could allow the debate to focus on bespoke solutions for
individuals or specific communities.
Air Quality
The CAA considers that the current framework for managing local air quality is seen as credible
and effective. We do not see merit in Government seeking to amend the existing approach.
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CONTENTS
KEY INSIGHTS 2
INTRODUCTION 8
PART 1: The Components of a Sustainable Framework 11
PART 2: Strategy: Defining Objectives and Outcomes 13
PART 3: Implementation: Achieving Outcomes with Limited Levers 18
PART 4: Creating a Framework for Delivery 24
Achieving Choice and Value 24
Direct short-haul connections for all consumers 24
Direct access from the UK to key global markets 25
Single-stopover transfer access from other UK airports 31Achieving Environmental Sustainability 35
Climate Change 35
Aviation Noise 36
Local Air Quality 38
Conclusions 40
References 41
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INTRODUCTION
In the CAAs response to the
Governments scoping consultationI
we set out how we consider that clarity
and durability can best be achieved by
formulating the policy framework at two distinct levels:
The strategic level: the Government should set broad objectives
and the outcomes it is seeking to achieve;
The implementation level: the Government should then set out the steps that it
intends to take in order to make the outcomes come to pass; ensuring the
Government only intervenes where it has the ability to drive forward strategy.
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The CAA committed to publish a series of three Insight Notes to build on its initial consultation
response:
Aviation Policy for the Consumerconsiders the issue of connectivity from the perspective of
current and future consumers. In particular, it addresses the implications of forecast demand
growth for the choice and value offered to UK consumers;
Aviation Policy for the Environmentconsiders how UK aviation can grow without
unacceptable environmental consequences, focusing on the key challenges of climate change,
noise and local air quality;
Aviation Policy for the FutureCreating a Sustainable Framework is the final document in the
series. It considers a number of the challenges that will need to be addressed to ensure that the
framework provides a robust strategic platform for successful delivery of the investment and
improvements to the UK aviation system that will be needed to meet the needs of aviation
consumers and the UK economy.
Part 1 reviews the principles underlying the two-stage approach to development of aviation
policy that the CAA recommended in its Scoping Response;
Part 2 draws on the analysis and evidence presented in Aviation Policy for the Consumerand
Aviation Policy for the Environmentto recommend a set of policy outcomes;
Part 3 considers the challenge facing Government to put in place a credible policy framework
given that it has limited levers at its disposal. This section provides advice to inform
Governments choices as to when, at what level and how to intervene;
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Part 4 addresses the implications for policy, and covers some of the issues that the
Government may wish to include in the draft framework it is due to publish in Spring 2012.
The purpose of this Insight Noteis not to recommend what policy should be; the CAA is
clear that such policy decisions rest with Ministers. This document seeks to set out a
direction of travel and highlights a number of areas that Government should explore in its
forthcoming consultation.
The Scoping Response and all three of the Insight Notesare available on the CAAwebsite: www.caa.co.uk/sustainableaviationframework
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INTRODUCTION
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UK Aviation would
benefit from a policy
framework that is bothrobust and flexible
PART 1: THE COMPONENTS OF A SUSTAINABLE FRAMEWORK
In the CAAs response to the Governments Scoping Consultation, we outlined an approach to
the Framework which we consider would create an appropriate balance between the desire
to give credible long-term investment signals to the sector and a recognition that policy will
need to be sufficiently flexible and agile to adapt as and when circumstances demand.
The development of the policy framework creates an opportunity to shape the future of UK
aviation by sending credible signals about the long-term direction of policy. In doing so, the
Government can help to align decisions in a way that is consistent with a common strategicdirection. The more effective Government is in generating policy stability, and the more
robust the policy framework, the more effective the investment signals it sends to industry.
However, policy stability should not come at the cost of restricting the sectors ability to
adapt to change. The framework should be designed in such a way as to enable the industry
to adapt its approach to the inevitable unforeseen challenges that aviation will inevitably face.
Stability should provide a platform which encourages innovation rather than stifling it.
The CAA considers that clarity and durability can best be achieved by formulating the policy
framework at two distinct levels, with a clear separation between strategy, which should beexpected to be robust over time, and implementation, which will need to balance the need
to be sufficiently flexible as to adapt to change while ensuring sufficient stability to drive
investor confidence.
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At the level of
implementation, it is
important that policyis consistent with the
levers available to
Government, in order
to create a credible
platform for delivery
The Governments initial focus should be to set the objectives and outcomes which it wants to
achieve through aviation. These objectives and outcomes should be expected to remain stable
through time in order to provide long-term credibility that supports investment in assets or
technology, and promotes innovation in service delivery. Without credibility, the framework will
not sustain and support the sector in meeting Governments objectives.
The policy levers at Governments disposal are limited. Many regulatory aspects are governed by
European and international law. The aviation sector is largely privately-owned and liberalised. The
framework needs to recognise these constraints whilst recognising that Government can exertconsiderable influence through the mechanisms it has for engaging and incentivising the actions
of stakeholders.
Therefore, as well as setting out the actions that Government will take, the Government should
also specify those actions which it expects over stakeholders to take. In doing this, the
Government should recognise that service delivery in the aviation sector involves multiple
organisations interacting as part in a complex supply chain.
Effective delivery is only likely to occur where the sector is incentivised to deliver the outcomes.
Where incentives are not aligned, Government will need to consider whether it has the levers topromote and encourage delivery of the desired outcomes. Where Government does not have
powerful levers to guide delivery, or it considers that the use of available policy levers would
inconsistent with wider Government policy, its ability to prescribe outcomes in detail without
taking some direct control for delivery will be limited.
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PART 1: THE COMPONENTS
OF A SUSTAINABLE
FRAMEWORK
At the strategic level,
the Policy Framework
should set clear
objectives and
outcomes
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PART 2: STRATEGY: DEFINING OBJECTIVES AND OUTCOMES
The Government set out in its Scoping Consultation document that aviation should be able to
grow, but to do so, it must be able to play its part in delivering our environmental goals and
protecting quality of life of local communities. The CAA supports this high-level proposition.
The objective of the policy framework should be to facilitate development of an aviation sector
that is:
Safe and secure;
Geared to delivering choice and value to consumers; Environmentally sustainable.
SAFE AND SECURE
The UK aviation industry has one of the best safety records in the world. However, pressure
on this record is expected to increase in the future; demand growth will potentially put strain
on airspace management and airport capacity while technological development will increase
the complexity of the total aviation system. The need to improve aviation safety in a
proportionate and cost-effective way is therefore one of the major challenges faced by the
aviation sector.
This document does not focus in detail on safety issues. The UK State Safety Programme,
which incorporates the CAA Safety Plan, is the primary mechanism for driving improved
safety performance across all sectors of the industry. The CAA Safety Plan has been
developed in partnership with industry because although the CAA has a safety oversight
responsibility, industry has prime responsibility for managing their safety risk.
The CAA has a primary
duty to ensure safety.
Once safety has been
assured, the focus of
policy should be to
maximise consumer
benefit subject to
environmentalconstraints.
Safety and security
underpin all other
aspirations that the
sector might have.
Aviation policy should
be designed to ensure
that flying remainsamongst the safest
ways to travel.
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The State Safety Programme and the CAA Safety Plan are consistent with the outcome-based
approach the CAA proposes for the policy framework. Both initiatives focus on delivery of
improved safety outcomes, codified as a clear set of high-level goals developed in collaboration
with the aviation community. The CAA therefore considers that the policy framework should
recognise the State Safety Programme as the primary source of UK aviation safety policy.
In addition, the framework should recognise the interdependency between safety and the
Governments consumer and environment objectives. Measures to deliver improved consumer
experience and environmental performance will need to satisfy the relevant safety requirements.The framework should also create appropriate incentives to drive the investment necessary to
deliver continuous improvements in safety performance.
CHOICE AND VALUE FOR CONSUMERS
The development of the Sustainable Aviation Framework offers an opportunity to look beyond current
economic difficulties and develop a sustainable framework that is consumer-focused at all levels.
Aviation Policy for the Consumershowed that UK aviation consumers are currently very well
served in terms of the choice available to them. UK consumers currently enjoy a very high
level of airport accessibility with nearly 90% of the population living within two hours traveltime of at least two international airports. The choice and frequency of services offered by
Londons five major airports make the UK capital one of the worlds best connected cities.
Despite the current economic uncertainty in the UK and Europe, growth elsewhere in the world
is forecast to stimulate significant growth in demand for aviation over the next 20 years. While
this demand growth may lead to increased route choice for consumers at some regional airports,
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PART 2: STRATEGY:
DEFINING OBJECTIVES
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The Policy Framework
should focus on
delivering choice and
value for aviation
consumers.
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The framework
should set policyoutcomes such that
the levels of aviation
connectivity that UK
consumers currently
enjoy are at least
maintained.
capacity constraints at many UK airports, particularly in the South-East, will increasingly limit the
choice and value available to consumers.
While regional passengers may benefit from capacity constraints in the South-East if this leads to
increased choice of direct routes, routes to London are likely to be squeezed further. The
development of significant hub-and-spoke networks at regional airports seems unlikely.
On the basis of the analysis set out in Aviation Policy for the Consumer, we consider that the
following broad levels of service provision would be consistent with meeting this objective: For principal short-haul routes: All UK consumers should have access to direct connections to
principal short-haul destinations;
For medium and long-haul routes: Consumers should have access to direct services from the UK to
key global markets. Recognising that some routes may only be commercially viable if operated from a
hub airport, the Government should seek to facilitate successful hub operations in the UK. Consumers
using other UK airports should have single-stopover transfer access to the same key global markets.
These outcomes are intended to be indicative not prescriptive. The CAA considers that where
there is effective competition, airlines are best placed to configure route networks that meet
consumer demands. The purpose of the Policy Framework should be to create the conditions thatwould enable the market to provide this connectivity.
ENVIRONMENTALLY SUSTAINABLE
The aviation sector will need to address and mitigate its environmental impacts in the areas of
climate change, noise and local air quality if aviation consumers are to continue to enjoy current
levels of choice and value.
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PART 2: STRATEGY:
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Climate Change
The aviation sector continues to make progress in terms of improvements in aircraft efficiency. However,
given the scale of the challenge, it is likely that the rate of progress will need to accelerate over the coming
decades. Further improvements in the CO2 emissions performance of the sector remain a priority.
Global aviation accounts for around 2% of global aviation CO2 emissionsII. However, as other
sectors decarbonise and as global demand for air travel grows, that impact is going to grow
proportionally unless significant action is taken.
UK aviation CO2 emissions account for around 6% of UK CO2 emissions. That proportion could
rise to up to 25%III, even if aviation emissions return to 2005 levels by 2050 and UK carbon budgets
are metIV. Reducing emissions is therefore a matter of priority. In parallel, aviation entered the EU
Emissions Trading System (EU ETS) at the start of 2012 and with emissions capped at 95% of 2004-
06 levels from 2013 to 2020, the sector is forecast to rely on allowances to meet this target due to
forecast demand growth in the latter part of the decade.
Non-CO2: There are potentially significant non-CO2 effects from aviation which arise from the
emissions of gases and particles including contrails and induced cloudiness. Considerable work has
been undertaken in the past decade to quantify these effects and to assess potential policy optionsfor reducing non-CO2 impacts, for example through a multiplier or a flanking instrument. Scientific
understanding of non-CO2 climate change impacts of aviation needs to be improved further before
policy action can be taken.
Overarching outcomes should ideally be set at an international level. At a national level, there is potential for
outcomes to be specified in order to encourage and incentivise implementation of airspace modernisation.
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PART 2: STRATEGY:
DEFINING OBJECTIVES
AND OUTCOMES
The Policy Framework
should frame
outcomes in order to
maximise emissions
reduction while
minimising carbon
leakage and
competitive distortions.
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The development of
the aviation policy
framework presents
an opportunity to
develop a new, twin-
track approach to
noise policy focused
on two high-leveloutcomes:
Continued
reductions in the
numbers of people
affected by noise;
and
Encouraging better
engagement with
communities.
Noise nuisance
The noise generated by aviation activity can have a significant impact on the quality of life of those
living close to airports or under flight paths. As many as 725,000 people around Heathrow and under
its flight paths are affected by aircraft noise, based on the European standard measure of 55LDen. Within
the range of noise impacts, night noise is generally considered to be the most contentious issue.
Recent decades have seen considerable progress in reducing noise generated by aircraft. This has
been driven by technological improvements and controls on the expansion of aircraft operations at
selected airports.
However, the experience of recent years suggests that a policy approach based exclusively on
noise reduction is likely to be insufficient. Despite the positive trends towards noise reduction, the
strength of feeling of those affected by noise has arguably increased. Improved engagement and
communication between the aviation sector and local communities would appear to be a
prerequisite for a framework which aims to generate lasting consensus around aviation policy.
Local Air Quality
Many specific locations across the country, most frequently at roadsides, have been assessed as
having levels of nitrogen dioxide that exceed European limits. Road transport is the major source ofair pollution at most hotspots. Aviation contributes to local air pollution near airports through a
combination aircraft engine emissions, ground operations, and surface access road transport.
The current framework for managing local air quality sets clear outcomes, through mandatory
targets. The CAA considers that this framework is seen as credible and effective. We do not see
merit in Government seeking to amend this framework.
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PART 3: IMPLEMENTATION: ACHIEVING OUTCOMES WITH LIMITED LEVERS
The UK aviation sector is largely driven by private investment. While some areas of the sector are
highly regulated, many other aspects of aviation have been increasingly liberalised over many
years. Accordingly, Government alone cannot deliver choice, value or sustainability. We discussed
this challenge in some detail in our initial scoping response.
In considering the potential for policy intervention to deliver the outcomes, the Government will
need to address three questions:
Whether to intervene? At what level to intervene?
How to intervene?
WHETHER TO INTERVENE?
Efficient markets can provide accurate signals such that the decisions made by airport operators
and airlines produce economically and socially optimal outcomes, as long as the framework within
which the market operates is well-specified. However, it is important not to take a nave view of
markets. Issues such as externalities, market power, information asymmetries, or other factors
can all lead to market failure and have a detrimental impact on consumers or the general public.
Many of the challenges facing aviation derive from the existence of market failures, in
particular externalities such as CO2 emissions and aircraft noise. Where market failures exist,
the Government should assess the extent and significance of these failures and determine
whether there is potential to improve outcomes with proportionate policy measures, including
by encouraging the market to take full account of costs and benefits to other actors and to
society in general.
Government should
limit the outcomes it
sets to those that it
can achieve or
influence through use
of levers that it
controls, or has the
ability to create.
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Intervention in a commercial and competitive sector comes with risks, but can improve outcomes. Indeed,
there is a broad consensus that, in the absence of policy intervention, the decisions taken by actors in the
aviation industry, in common with many other markets, would not reflect the full cost of environmental harm,
and that measures such as noise regulations and emissions trading can improve outcomes, despite their costs.
AT WHAT LEVEL TO INTERVENE?
One of the key challenges for Government will be to determine the appropriate level for intervention,
recognising that, in many cases, action may be more effective if taken by others. In developing a strategic
national level framework, the Government will need to ensure that the framework effectively balances
economic and consumer benefits, for which governance is primarily national, and environmental impacts which
are either global, in the case of climate change, or highly localised in the case of aviation noise and air quality.
Local: As we examined in Aviation Policy for the Environment, some of the most contentious policy
issues around aviation concern highly localised environmental impacts such as noise and local air quality.
We noted that the lack of effective engagement between the aviation sector and local communities was
one barrier to effective progress on aviation policy, and that the development of the policy framework
represents an opportunity to develop a more constructive approach. This would also be consistent with the
current Governments localism agenda;
National: While policy measures will need to be tailored to the specific challenges of individual locations,
the CAA considers that it is important that the strategy is set at the national level in order to facilitate the
integration of the Government aviation policy into wider transport policy, as well as to ensure consistency
with the Governments strategic agenda in other policy areas;
International: Aviation is a global industry. International and European law place a number of constraints
PART 3: IMPLEMENTATION:
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on Governments scope to intervene. For instance, international aviation law limits Governments
ability to link aviation taxes to fuel consumption or to include noise-incentives in aeronautical
charges. In addition, a number of key policy levers and enablers operate at European or
international level. The Single European Sky and SESAR airspace programmes are prominent
European initiatives that have a major impact on national policy.
HOW TO INTERVENE?
Whilst it is difficult to recommend particular forms of intervention or reforms to market
processes, less prescriptive approaches are likely to be more flexible and resilient to change. The
policy framework should be clear where markets and other decision-making approaches are
expected to deliver, and where Government intends to intervene directly.
The principal levers available to Government under the existing structure of the sector are:
Planning Policy;
Regulatory approaches;
Operational approaches;
Intermodality;
Environmental measures;
Taxes and Subsidies; Improved information.
Planning Policy
The planning system has an important role to play in generating certainty among stakeholders, in
particular infrastructure investors. Given the long lead times involved in delivering aviation
infrastructure and in developing new technologies, this stability will be crucial to generating the
PART 3: IMPLEMENTATION:
ACHIEVING OUTCOMES
WITH LIMITED LEVERS
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PART 3: IMPLEMENTATION:
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investment necessary to deliver Governments objectives.
The CAA considers that the Governments programme of planning reform and the
development of a National Infrastructure Plan are positive steps as they potentially provide a
more robust and credible foundation for infrastructure delivery. The development, in due
course, of a National Policy Statement for UK Aviation may help to generate long-term
confidence in the framework.
Regulatory Approaches
The CAA considers that effective competition amongst airports, airlines and other service
providers, with consumers being suitably empowered to engage, generally offers the best way
to promote consumer interests. The UK has adopted a regulatory approach to the sector that
based on liberalisation of the sector and encouraging competition in the market. However,
there are a number of areas which continue to be subject to regulation.
The CAA continues to regulate charges at Heathrow, Stansted and Gatwick airports, as these
airports are designated by the Secretary of State, and the CAA is currently consulting on its proposed
approach to the next regulatory period, Q6 in order to ensure that this approach adequately protects
consumers and strikes the appropriate balance between competition and regulation.
Operational Procedures
UK airspace is an essential component of our aviation infrastructure. A policy framework that
takes a holistic view of fully integrating airspace into future aviation needs would be beneficial.
The CAAs Future Airspace Strategy (FAS) aims to establish safe, efficient airspace that has the
capacity to meet reasonable demand, balances the needs of all users and mitigates the impact of
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aviation on the environment. In Aviation Policy for the Environmentwe outlined a number of additional
operational measures that have the potential to mitigate aviations environmental impacts.
Intermodality
Improved integration of UK airports into the wider surface access network, including through the
Governments proposals for high-speed rail, has the potential to increase accessibility to aviation. As we
noted in Aviation Policy for the Consumer, UK aviation consumers currently benefits from very high-levels of
surface connectivity to airports with nearly 90% of the population living within two hours travel time of at
least two airports. However, at the level of individual airports, surface access improvements can increase the
size of catchment area and potentially influence the range and frequency of services that can be maintained.
It is important that proposed surface access improvements are subject to appropriate funding arrangements.
Where airport operators would be expected to contribute to any investment, the Government should
provide clear guidance setting out how the level of such contributions would be determined.
Environmental measures
All of the major environmental challenges facing aviation involve significant externalities. Accordingly,
there is a case for intervention to address aviations environmental impacts. Aviation Policy for the
Environmentconsiders these issues in detail. Environmental sustainability is also a key focus of this note.
The Framework should set clear and credible environmental parameters. In addition, policy measures
should adhere to the following principles:
Government should ensure that intervention to address environmental challenges takes place at the
level where it is most effective and proportionate;
Where policy intervention is appropriate, measures should be designed in a way which maximises
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their effectiveness and efficiency;
Intervention should be based on robust information and recognise the trade-offs inherent in the
formulation of policy to address environmental challenges.
Taxes and Subsidies
Where Government is minded to use taxation as part of its aviation policy toolkit, any measures should
be non-discriminatory in order to minimise distortions and unintended consequences. Tax measures are
likely to result in sub-optimal outcomes if they are used in an attempt to shape the sector.
The CAA recognises the importance of Public Service Obligations (PSOs) in supporting lifeline
services to remote areas, in particular in the Highlands & Islands of Scotland. However, at the level
of national policy, the CAA considers that PSOs have, at best, a marginal role to play. Similarly, State
Aid restrictions around the use of Route Development Funding limit the potential for such
measures to have a long-term impact.
Improved Information
There may be more that could be done to monitor industry performance and facilitate informed
consumer decisions through the improved provision of information. Consumers need clear
information on price and service quality in order to make informed choices and to ensure thatmarkets deliver consumer benefits in practice.
Research undertaken by the CAAV found that almost two fifths (38%) of consumers thought that
having access to information about the environmental impact of the flight they were booking,
including carbon emissions, is very or quite important. Making environmental information available to
consumers may result in better informed passengers choosing better performing airlines and airports.
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In Part 2 of this note, we set out a set of high-level outcomes that Government could adopt in
order to deliver its consumer and environmental objectives. In this section, we consider some of
the implementation measures that might contribute to achieving these outcomes.
ACHIEVING CHOICE AND VALUE
DIRECT SHORT-HAUL CONNECTIONS FOR ALL CONSUMERS
The analysis we set out in Aviation Policy for the Consumerindicates that UK aviation
consumers from all regions benefit from very high levels of connectivity on short-haul routes.
Competition, facilitated by liberalisation, has delivered significant benefits for consumers in
terms of choice and value.
Capacity constraints at the larger London airports are likely to result in some short- and
medium-haul routes being squeezed out of these airports in favour of higher yielding long-
haul services and/or fares increasing on these routes. DfT forecasts indicate that all London
airports will be full by 2030. At the same time, while there is significant spare capacity outside
of the South-East, a number of the smaller regional airports face challenges in terms of
commercial viability.
The CAA does not
consider that specific
intervention is currently
required in order to
facilitate continued
high-levels of direct
short-haul connectivity
across the UK.
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The CAA considers
that, as a result of the
costs to consumers of
capacity constraints,
policy intervention
may be justified in
order to facilitate
direct access for UK
consumers to global
markets.
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DIRECT ACCESS FROM THE UK TO KEY GLOBAL MARKETS
Airport and airspace capacity constraints in London and the South-East are already affecting
consumers by: restricting competition, restricting route choice, affecting value through higher
fares, and affecting service quality as a result of resilience issues. These impacts are expected to
become more pronounced in the future as a result of forecast demand growth.
Capacity constraints at Londons airports may already mean that they are less able than
airports in other European cities to adjust as global economic activity shifts to emerging markets
such as China, India and South America. This trend is likely to become more pronounced;
Capacity constraints will increasingly shape network configuration by reinforcing the trend
towards focusing on the most profitable, high-yield routes. At Heathrow this is likely to lead to
further specialisation on long-haul routes, in particular those routes for which geography or
economic, cultural and historical links give London an advantage;
The additional opportunity cost of launching new routes may result in airlines being less
likely to take a chance on launching services to emerging markets from London, especially
where UK-based demand does not generate a sufficient volume of premium traffic;
The lack of available capacity at Heathrow has already had a negative effect on the UKs
ability to liberalise Air Services Agreements with foreign states, which would potentially open
up routes into emerging markets. This trend is likely to become more acute as Londons otherairports become more congested;
Fares at congested airports are predicted to increase significantly as a result of capacity
constraints. The value of fare premiums resulting from capacity constraints at UK airports is predicted
to total 1.7bn in 2030. This equates to an additional 10 per passenger on a return air fare;
Resilience issues will become more widespread as more airports become congested, if
appropriate mitigations are not put in place.
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MAKING BETTER USE OF EXISTING AIRPORT CAPACITY
The measures that could enable better use of existing capacity broadly fall into three categories:
Regulatory approaches,
Operational approaches, and
Intermodality.
Regulatory approaches
The CAA considers that effective competition amongst airports, airlines and other service
providers, with consumers being suitably empowered to engage, offers the best way to promote
consumer interests. The UK has adopted a regulatory approach to the sector that based on
liberalisation of the sector and encouraging competition in the market. However, there are a
number of distinct areas where further improvement is possible:
Legislative framework for regulation
While the UK has a diverse and competitive airport sector that delivers significant benefits for
consumers, economic regulation is necessary in some cases where competition is more limited.
The current legislation governing economic regulation is out-dated and in acute need of reform.
The proposed revisions to the regulatory framework, which give CAA a new duty to put the
interests of passengers and cargo users first, coupled with a more modern licence-basedregulatory regime, will enable more flexible and responsive regulation. The proposed reforms also
promote the improved provision of information as a means of informing consumer choices and
incentivising better performance.
Airline competition
Liberalisation of Air Service Agreements. Despite the fact that the airline sector is one of the
A number of
measures have the
potential to provide
additional flexibility
and resilience into the
aviation system,
potentially enabling
better use of existing
capacity, particularly
in the short and
medium-term.
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most international of industries, rules governing access to foreign markets remain highly restrictive in
many cases. Liberalisation of intra-European aviation services in the 1990s and the increasing number of
Open Skies style agreements have delivered significant consumer benefits. The Framework provides
an opportunity for the Government to reiterate its commitment to liberalisation of aviation markets and
give a renewed impetus to the opening up of the remaining restrictive air service agreements.
Reform of airport slot allocation rules. Airline competition is dependent on access to take-off
and landing slots. Scarcity of slots at congested airports can therefore represent a barrier to effective
competition. Secondary slot trading has proven to be very useful in allowing airlines to respond to
shifting market conditions and encouraging efficient use of scarce airport capacity. Current proposals
for reform of the existing EU Slot Regulation offer an opportunity to further improve the system of
secondary trading in the UK and elsewhere in Europe, potentially increasing the liquidity of the
market for slots.
Operational approaches: Improving Airport Resilience and Airspace Management
Airport Resilience
Through the work of the South East Airports Taskforce (SEAT) and the Airport Performance
Facilitation Group (APFG) a number of mechanisms are being developed, including performance
charters and capacity guidelines, which have the potential to avoid or mitigate the resilience issuesexperienced at some South-East airports being replicated at other airports if demand growth continues.
At Heathrow, a set of operational freedoms is currently being tested. These additional measures
allow the airport to apply certain tactical measures to prevent or mitigate disruption and to facilitate
recovery. The measures include, for example, use of temporary departure routes and temporary
desegregation of runway operation. Use of these measures is subject to rigorous safeguards and
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confined to certain defined and limited situations. There is no increase in the number of flights at
Heathrow which remain capped at pre-existing levels.
Airspace Management
Future Airspace Strategy. Ensuring that national airspace is not a constraint on reasonable
demand growth is a key element of the CAAs Future Airspace Strategy (FAS). The FAS has the
potential to make a substantial contribution to the Governments objectives as part of a
sustainable framework that will guide the aviation industry in its investment and technological
development plans.
There are already congestion hotspots in UK airspace today that must be addressed as predicted
traffic flows increase, in order to minimise delay and to deliver continuous improvements in
safety. Under the levels of traffic growth set out in the Governments latest demand forecasts,
the pressure on the UKs airspace system will continue to grow with a changing profile of
demand from different user groups leading to a tightening in the supply/demand balance for
airspace at certain times and in certain places, in particular in the South-East.
Intermodality
Improving the integration of aviation into the wider transport system has potential to improveconsumer choice, quality of experience and, at the margin, may lead to more efficient distribution
of demand between airports at the margin. Governments proposals for High-Speed rail may have
some impact on demand for aviation, but should be considered alongside other improvements to
surface transport:
Improved surface access to airports may have the potential to increase airport catchment areas.
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This could facilitate the provision of additional routes from these airports, increasing choice and
value for consumers. Where catchment areas overlap, consumers would further benefit from
increased competition.
Substitution from air to rail would be expected to reduce demand for aviation on a limited
number of domestic and very short-haul routes. This may free up a limited amount of capacity at
congested airports;
Integration between high-speed rail and airports along the high-speed network may provide
additional feeder traffic at these airports. This may support the development of some additional
long-haul routes from these airports.
Reduced rail journey times between Manchester and London have had an impact on market
share of point-to-point air traffic, demonstrating the potential for air to rail modal shift. However,
even with existing rail journey times of approximately 2 hours, demand for onward air
connections from transfer passengers continues to sustain demand for multiple daily flights. In
addition, 60% of UK domestic passengers in 2010 were travelling either on routes which do not
pass through any London airport or on which currently proposed high-speed rail routes would
offer no significant journey time benefit.
Evidence on the complementarity between rail and air is limited. A credible rail-air product wouldneed to maximise intermodal convenience, ensuring that the rail-air interface was as seamless as
possible and in particular minimised connection times. Relevant factors would include the
proximity of the railway station to the main airport terminal as well as the provision of through-
ticketing, remote baggage handling and other procedural formalities.
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Appropriate additional
capacity could deliver
significant benefits for
consumers. The
Framework should
seek to set in place a
platform which will
facilitate a credible
path to provision of
additional capacity.
TOWARDS A LONGER-TERM SOLUTION
The initiatives and measures outlined above offer some potential to improve the flexibility of the
UK aviation system and ease capacity constraints, particularly in the short and medium term.
However, we do not judge that they have sufficient impact to represent a long-term solution to
the consumer and economic costs of capacity constraints.
The CAA does not consider that it is necessary or appropriate to take a view on the location of
any additional capacity at this stage. This should be the subject of a further process.
However, Aviation Policy for the Consumerhighlighted that capacity constraints are likely to have
a particular impact on the ease with which airlines could establish new routes to the key
emerging markets that are likely to drive economic growth in the future. Accordingly, there would
appear to be some benefit in any additional capacity being fit-for-purpose for the hub operations
that may help support the commercial viability of such routes.
It is also appropriate and timely to propose some criteria that any proposed new capacity would
need to meet. The CAA considers that these should be set out in any call for evidence on
additional capacity:
Overall consumer benefit: As with any transport project, proposals should be subject to a full
analysis of costs and benefits, with proposals only considered for approval where it is clearly
demonstrated that they would be expected to deliver overall net benefits.;
Affordability and commercial viability: Any additional capacity would need to commercially
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viable and affordable. Additional capacity funded through steep increases in the charges faced by
consumers may not deliver overall consumer benefits;
Operational feasibility: Airspace in the South-East of the UK is among the most congested in
the world. Developments proposed as part of airspace modernisation programmes being taken
forward at national and European level offer some potential relief. But it would be important that
any additional capacity were consistent with these initiatives in order to ensure that additional
capacity could be utilised in a safe and efficient manner.
Integration into the national surface transport network: As we discussed earlier in this note,
surface access improvements, including the Governments proposals for High-Speed rail, have
potential to improve consumer access to UK airports. Any additional capacity should be
integrated into the national transport network to ensure ease of access for the maximum feasible
number of consumers.
Environmental sustainability: The Government has made it very clear that environmental
sustainability is one of the key objectives of the framework. The CAA supports this view.
Accordingly, the provision and utilisation of any additional capacity would need to be consistent
with achieving the environmental outcomes we set out in Part 2.
SINGLE-STOPOVER TRANSFER ACCESS TO GLOBAL MARKETS FROM OTHER UK AIRPORTS
A limited number of long-haul routes operate from some of the larger regional airports. These
tend to be focused on a limited number of destinations, principally in North America and the
Middle East, leisure destinations in the Caribbean, and routes where the UK has particular cultural
ties, such as parts of South Asia.
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The Government faces a
strategic choice in terms
of how to ensure global
access for aviation
consumers in the UK
regions.
Regional passengers may benefit to some extent from capacity constraints in the South East if
this leads to increased choice of direct long-haul routes. Such routes are mostly likely to be
focused on links to foreign hubs. The CAA considers that significant hub-and-spoke networks are
unlikely to develop at regional airports seems unlikely.
As a result, passengers in the UK regions will continue need to use a transfer airport to access
the majority of global destinations: either Heathrow, accessed by surface transport or a domestic
flight, or a foreign airport.
The options available to Government include:
Ensure access to a hub airport from across the UK for example, by providing additional
capacity and improving surface access;
Explore development of a wider hub network to tackle security of supply issues.
Additional hub capacity in London and the South-East
Aviation Policy for the Consumernoted that as a result of forecast demand growth and capacity
constraints in the South-East, there are likely to be increasing pressures on regional connectivity
to London. The provision of additional capacity would be expected to at least partially relieve this
pressure, creating slots for commercially viable regional services.
Network of Hubs
Regional passengers can use a range of hubs to access global destinations. The evidence
presented in Aviation Policy for the Consumershowed that the majority of consumers from
Northern England and Scotland who use a transfer airport to reach long-haul destinations
already connect at a foreign hub rather than connecting in the UK. There is currently a
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particularly rich network of connections between regional airports and the hubs at Amsterdam
and Paris Charles de Gaulle.
The UKs geographical position on the North-West of Europe means that airlines operating out of
London can offer competitive journey times for connections to North America compared to other
European hubs. Geography, and other factors such as economic, historical and cultural links,
would suggest that other European airports might represent more convenient transfer points for
routes to other world regions such as Asia, Africa and South America.
Accordingly, the other major hubs in Western Europe and beyond play a positive and important
role in providing additional choice and value to UK consumers. However, there may be security
of supply risks if foreign hubs also become capacity constrained in the future. Forecast published
by EurocontrolVI predict that by 2030, capacity constraints at airports across Europe could means
as many as two million flights, some 10% of predicted demand, will not be accommodated.
Under this scenario, it might be expected that connections to UK regional routes would get
squeezed as has been the case at Heathrow over recent years.
There may therefore be merit in considering a network approach in order to ensure
connections for UK regional consumers to a variety of hubs. Such an approach would better
take account of the cross-border nature of some of the challenges facing UK aviation in
meeting the needs of consumers and would also be consistent with the joined-up approach
taken with the Single European Sky airspace initiative.
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Outcomes Actions Levers Issues
Choice: Direct short-
haulconnections Direct accessfrom UK tokey globalmarkets; One stopaccess fromother UKregions
Value: Effective
competitiondrivesconsumervalue
Capacity: Additionalcapacity in
South-East; Agnostic onlocation.
Planning System: Development of a National PolicyStatement may help generateinvestor confidence
Economic Regulation Any additional capacity would havea significant impact on airportcompetition and would haveregulatory implications.
Economic Regulation / Funding: Affordability / Commercially viability; Additional capacity could result in consumerdetriment if charges become prohibitive;
Operational Issues: Airspace management; Resilience
Operational Issues: Interaction between airports; Optimal vs potential capacity
RegionalConnectivity:
Strategic choice: Connections toLondon; Connections toother hubs
Surface Access: Developer Contributions
Taxation / PSOs / RDFs:Protect access for regional routes atcongested airports
Taxation measures should be non-distortionary.PSOs and RDFs locally important but limitedscope for widespread use
Additional Capacity in SE See above
Network of Hubs: Explore idea of a wider network ofhub airports
Could help address security of supply issues.UK likely to be net winner.
Achieving Choice and Value for Consumers
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Outcomes should seek
to maximise emissions
reduction while
minimising carbon
leakage and
competitive distortions.
Overarching outcomes
should ideally be set at
an international level.
At a national level,
there is potential for
outcomes to be
specified in order to
encourage and
incentivise
implementation of
airspace modernisation
ACHIEVING ENVIRONMENTAL SUSTAINABILITY
CLIMATE CHANGE
There is greatest potential for overall emissions reduction if policy action is taken at the global
level. An appropriately designed multilateral solution would minimise competitive distortions and
should mitigate carbon leakage between countries.
Climate change is a global challenge. The Government should continue to promote and pursue a
coordinated global solution for the aviation sector. The current debate around the implementation
of the EU ETS potentially creates a window of opportunity to move the global debate forward as
non-EU countries make their positions clear, for the first time in some cases. Progress towards a
global solution is likely to require a combination of both political and technical approaches.
Despite the challenges to the inclusion of aviation in EU ETS, the European Union Emissions Trading
System (EU ETS) offers a next-best and interim solution. In light of the strong case for immediate
action to tackle aviations CO2 emissions and the challenge of achieving multilateral consensus, the
EU ETS, which will cover approximately 25% of global aviation emissions when it comes into force,
offers a next-best solution. However, EU ETS is, and was always envisaged as, an interim solution
and should not be seen as an alternative to a full global agreement.
The options for intervening at the national level in response to a global challenge such as climate
change are extremely limited. Where multilateral measures are in place, for example through the EU
ETS or the development of a global solution, it is not necessary to set a national target. Moreover, a
national target is likely to distort behaviours, leading to more limited emissions reductions than a
cross-sectoral approach that optimises reductions across the economy as a whole.
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The development of
the aviation policy
framework presents an
opportunity to develop
a new, twin-track
approach to noise
policy focused on two
high-level outcomes:
Continued reductions
in the numbers of
people affected by
noise
Encouraging better
engagement with
communities.
There are a number of technical and operational improvements that can be taken forward at a
national level or on which the UK can take a leading role. In particular, airspace modernisation has
considerable potential to improve the efficiency with which UK airspace is utilised, leading to
reduced fuel burn and CO2 emissions, as well as potentially delivering noise reduction benefits.
Further work is required to develop scientific understanding to improve the accuracy of quantification
of effects and better judge the most appropriate policy measures. The Framework should be kept
under review to ensure it takes non-CO2 emissions into account as understanding in this area improves.
AVIATION NOISE
We expect there to be a continuation in the trend for improvements in technology to drive down
aircraft noise. Action at the local level, involving regulatory, operational or economic policies, has
the ability to accelerate the uptake of these technologies at specific airports.
In addition, in Aviation Policy and the Environmentwe outlined a number of policy options that are
available to Government, the regulator and sector players to reinforce this trend through changes
to regulatory or operational approaches, potentially backed-up by economic instruments.
Improved information: The complexity of the available information on aircraft noise and the
portrayal of its impact is one of the significant barriers to better engagement on noise issues.
Improvements in information may have an important role to play, both in incentivising
improvements in aircraft noise performance and facilitating more constructive debate between the
aviation sector and communities affected by aviation noise. The CAA has already undertaken work
to develop information that can be presented in a form that is more readily understood. Future
advances in this area will be investigated.
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Regulatory Approaches: Policy decisions on the approach to airspace regulation can have a
significant impact on the way that noise is distributed. The decision on whether to favour dispersion or
concentration of flight paths is of particular importance. The Government has an opportunity to clarify
its policy in this area.
Operational Practices: The operational practices employed by airports and airlines can have a
considerable influence on the level of noise created, the impact of the noise and the populations
affected. A number of alternative practices could be employed to reduce noise emissions including
continuous descent approaches (CDAs), steeper approaches and displaced thresholds for landings
and continuous climb departures for take-offs. Many of these measures are being advanced as part
of the CAAs Future Airspace Strategy workstream.
Economic instruments could play a greater part in dealing with noise, consistent with
polluter pays principle.
Noise-based charging is already well-established part of the pricing structures at a number of
airports in the UK, including the three noise-designated airports, Heathrow, Gatwick and
Stansted. However, Air Navigation Service Providers (ANSPs) currently make no distinction in
their charging structures to account for the noise performance of different aircraft.
Using a similar concept to the cap and trade approach used in emissions trading schemes, a
noise trading system could be adopted. As with other cap and trade schemes, the benefit
of such an approach is that it would lead the aircraft operators who generate the noise
disturbance to internalise the impact of the disturbance caused to local communities.
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The current framework
for managing local air
quality sets clear
outcomes, through
mandatory targets. The
CAA considers that this
framework is seen as
credible and effective.
In Aviation Policy and the Environmentwe also proposed a number of potential measures that
the Government could explore in order to unblock the policy stalemate around aviation noise.
Improved engagement and communication between the aviation sector and local communities
would appear to be a prerequisite for a framework which aims to generate lasting consensus
around aviation policy. Given the starting point, it will clearly be challenging to achieve such
consensus. However, there do not appear to be any reasons in principle why the aviation sector
and civil society should not be able to engage more effectively on noise issues.
It follows that a reformed institutional framework should allow the debate to focus on bespoke
solutions for individuals or specific communities. Given the need to tailor solutions to local needs,
the menu of potential options is necessarily very broad. Some illustrative examples that could be
worthy of consideration include such measures as a council tax rebate scheme funded through a
levy on airport charges or greater airport engagement in community projects, for example
providing funding for community facilities or services.
LOCAL AIR QUALITY
The UK has adopted an outcome-based, non-sectoral approach to addressing air quality, based on
the implementation of European legislation. We do not see merit in Government seeking to
amend this approach.
Indeed, there may be lessons that could be learned from the outcome-based, non-sectoral
approach to air quality that could be useful in addressing other environmental impacts, for
example as part of an alternative approach to noise policy.
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Outcomes Actions Levers Issues
Reduce overallGHG emissions
Work towards globalsolution
Exert influence at ICAO Limited prospects of a solutionin short- or medium-term
Implementation ofEU ETS
EU ETS EnforcementStakeholder engagement
Challenges to EU ETS
AirspaceModernisation
FAS / SES and SESAR;NATS efficiency metric
Improve understandingof non-CO2 impacts
R&D funding
Noise: Improve aviationsnoise performance; Improve communityengagement on noiseissues
Operational measures Displaced thresholds;Steeper approaches
This is a menu of options forconsideration. All would needfurther development.
Safety requirementsPolitical choice betweenconcentration and dispersion
Legacy of broken promises
Regulatory approach Air Navigation GuidanceConcentration vs dispersion;Noise Envelope
Economic instruments Noise-based chargingAirport level cap and trade
CommunityEngagement toimprove trust
Improved InformationExplore measures which would give atangible benefit to local residents
Air Quality: Reduce PM10 and NOxemissions from aviation
EU Air Quality Directivealready implementedthrough UK regulations
Current non-sectoral, outcome-based approach works well.Seen as credible and trusted.
Achieving Environmental Sustainability
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CONCLUSIONS
Aviation Policy for the Futureis the final document in the CAAs series of three Insight Notes
intended to inform the development of a Sustainable Framework for UK Aviation.
In this note we have:
Outlined an approach to the Framework which we consider would create an appropriate
balance between the desire to give credible long-term investment signals to the sector and a
recognition that policy will need to be able to adapt as and when circumstances demand;
Proposed a set of policy outcomes which are consistent with achieving the Governments
stated objective that aviation should be able to grow, but to do so, it must be able to play its part
in delivering our environmental goals and protecting quality of life of local communities.
Considered the challenges facing Government in putting in place a credible policy framework
given that it has limited levers at its disposal.
Addressed the case for policy action against a number of the key challenges:
o Additional capacity we identify a case for the Framework to support and promote the
provision of additional capacity in the South-East, subject to meeting a number of criteria.
o Connections from regional airports to major hubs Overseas hubs play in an important
role in offering choice and value to aviation consumers in the UK regions. A wider network of
competing hubs, may offer a solution to potential security of supply issues that may arise if
and when these hub airports become capacity constrained;
o A new approach to noise policy We propose a twin-track approach to noise, addressing
both noise reduction and improved community engagement. We propose a number of
potential policy approaches that the Government may wish to explore.
CONCLUSIONS
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REFERENCESI http://www.caa.co.uk/docs/589/UK_CAA_Response_To_Sustainable_Aviation_Framework.pd f
II Committee on Climate Change (2009), Meeting the UK aviation target options for reducing emissions to 2050
III Committee on Climate Change (2009), Meeting the UK aviation target options for reducing emissions to 2050
IV Committee on Climate Change (2011), Meeting Carbon Budgets - 3rd Progress Report to Parliament
V Accent Research into Consumer Preferences,
http://www.caa.co.uk/docs/2107/2131ConsumerResearch06122011.pdf
VI http://www.eurocontrol.int/statfor/gallery/content/public/forecasts/Doc415-LTF10-Report-Vol1.pdf
CAA
INSIGHT
NOTE:
AVIATION POLICY
FOR THE FUTURE REFERENCES
http://www.caa.co.uk/docs/589/UK_CAA_Response_To_Sustainable_Aviation_Framework.pdfhttp://www.caa.co.uk/docs/589/UK_CAA_Response_To_Sustainable_Aviation_Framework.pdfhttp://http//www.caa.co.uk/docs/2107/2131ConsumerResearch06122011.pdfhttp://www.eurocontrol.int/statfor/gallery/content/public/forecasts/Doc415-LTF10-Report-Vol1.pdfhttp://www.eurocontrol.int/statfor/gallery/content/public/forecasts/Doc415-LTF10-Report-Vol1.pdfhttp://http//www.caa.co.uk/docs/2107/2131ConsumerResearch06122011.pdfhttp://www.caa.co.uk/docs/589/UK_CAA_Response_To_Sustainable_Aviation_Framework.pdfhttp://www.caa.co.uk/docs/589/UK_CAA_Response_To_Sustainable_Aviation_Framework.pdfTop Related