Department for Transport's environmental
guidance to the CAA
66. Environmental guidance set by the Department
for Transport in 2002—Guidance to the CAA on the Environmental
Objectives Relating to the Exercise of its Air Navigation Functions—sets
a framework within which the CAA must operate when making decisions
on airspace change proposals. The 19-page document states that
the CAA must consider "the need to reduce, control and mitigate
the environmental impacts of civil aircraft operations",
in particular aircraft noise and emissions. However, the guidance
is largely discursive in nature: it does not provide a clear Governmental
policy view about priorities in airspace design, other than safety
being paramount. The guidance has also not been updated since
2002, despite climate change having risen up the Government's
agenda considerably in recent years. Thus, it does not take account
of major shifts in Government thinking such as the Stern Review
on climate change (2006) and the Eddington Transport Study (2006).[79]
67. Several witnesses criticised the environmental
guidance as lacking clarity, especially in terms of determining
the priorities of different environmental impacts such as noise
and emissions. NATS argued for "greater clarity […]
in […] environmental policy on matters such as concentration/dispersal
of noise and the relative importance of noise and emissions; this
in turn will enable clearer guidelines provided by the CAA for
airspace design and future airspace rule-making".[80]
The Guild of Air Traffic Control Officers said the existing guidance
was "woolly". It wanted "more prescriptive guidance"
because currently there was no "clear guidance when you are
designing and developing the airspace as to what environmental
criteria you are meant to be adhering to".[81]
The Aviation Environment Federation said:
You have got different constituents out there and
the community will always be interested in noise. Increasingly,
the Government will be interested in the emissions side, and the
inclusion of aviation into the Emissions Trading Scheme will make
sure that airlines will be saying to NATS, "Design us a system
that gives us the most efficient routes in and out", but
you have got to try and reconcile that. […] I think that
the CAA and NATS taking that value judgment about which to prioritise
over the other is inappropriate. It is exactly why we argue that
you have to have "sophisticated" guidance.[82]
68. We recommended, in our 2006 Report on The
work of the CAA, that the Government amend its 2002 environmental
guidance to give the CAA and others better information about how
to balance different environmental factors.[83]
The Pilling Strategic Review of the CAA, reporting in July 2008,
made similar recommendations.[84]
69. The Department for Transport told us it was currently
re-examining the 2002 guidance, following the findings of the
Pilling Review.[85] The
Minister acknowledged that concerns about CO2 emissions were "much
more prominent" now compared to even a couple of years ago.[86]
The CAA said that the new guidance would have to include any relevant
findings from the Stern or Eddington reports. However, it warned
that the guidance was intended to be of a general nature, and
there was no such thing as a "perfect formula" for the
Directorate of Airspace Policy to apply. It said different environmental
considerations had to be considered in different locations throughout
the UK.[87]
70. The CAA is not an elected body and it would be
inappropriate for the authority to be the final arbiter of decisions
or decision-making criteria, regarding airspace design changes
that have significant environmental impacts. The CAA should be
basing its decisions on clear principles set out by Government
on its environmental priorities, to enable the authority to better
make the difficult decisions where the advantages of direct flight
routeings and noise impacts have to be balanced against one another.
The Department for Transport (DfT) should issue up-to-date
Environmental Guidance to the CAA before the end of the year.
The guidance should represent current Government thinking on CO2
and other emissions in relation to transport decision-making.
The guidance must be clear about the basic policy principles by
which the Government expects the CAA to make its airspace assessments.
71. The CAA's own airspace change guidance document,
CAP 725, is partly based on the existing DfT environmental guidance.[88]
The process set out in CAP 725 has to be followed by those organisations
proposing airspace changes, usually air traffic service providers
or airports. CAP 725 is described as a "living document"
subject to occasional revision.[89]
The environmental requirements set out in the document are out-of-date
regarding key Government policy reports, such as Stern and Eddington,
despite CAP 725 last being revised in March 2007. We asked the
CAA whether it was satisfied that its airspace policy documents
reflected current Government policy. The CAA said the documents
"reflect Government policy as given to us through the [Department's]
environmental guidance".[90]
72. Once the DfT has issued new environmental
guidance to the CAA, the CAA must produce clear and comprehensive
new guidance on airspace change for the industry. The CAA should
adopt a regular review cycle to update the environmental material
in the document.
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