Nic Ferriday Statement
I work as a volunteer at the Aviation Environment Federation (AEF). I have a Physics degree and worked as an engineer at British Telecom before I took early retirement. I have been interested and concerned in environmental issues for many years. I live in the London Borough of Ealing, in West London and have done for many years. I was previously involved locally in Friends of Earth and it was apparent to us that Heathrow Airport and any possible expansion was the most significant local environmental issue.
The Aviation Environment Federation describes on its website in the following terms:
“the principal UK NGO campaigning exclusively on the environmental impacts of aviation and promoting a sustainable future for the sector. We formed as a federation in 1975 at a time when the sector was beginning to grow rapidly and noise was becoming an issue around airfields and airports. As aviation is exempt from noise nuisance legislation our members sought action to influence the national policy level.
AEF continues to focus on policy change but our work now extends beyond national policies to influencing European and global policy makers. Aviation has environmental, social and economic impacts and so despite being an organisation that is small in size, our work covers issues ranging from local air quality to global climate change, and from local participation in an airport consultative committee to the overall national economic impact of a new runway.”
I took part in the Public Inquiry into Terminal 5 at Heathrow Airport from 1995 onwards and gave evidence to that public enquiry.
Being a resident of Ealing, I am personally directly affected by Heathrow Airport. Most noticeably I am affected by noise. When there are easterly winds, planes take off directly overhead. I do not know if I am personally affected by air pollution, but would say I probably am simply based on the fact Heathrow is by far the biggest polluter in the area and we are downwind from Heathrow. I am unaware of any personal health problems attributable to air pollution. The biggest source of air pollution where I live is road traffic.
My work at the AEF consists of being a Case Officer. If members of public or organisations came to us with an enquiry I would take up the issue and see if I could assist. In short, my work involves conducting research, advice and advocacy. I have been doing this for around 15 years now.
I do not have technical qualifications on air pollution monitoring or forecasting/simulation, but have a general understanding of the government policy and social and political issues surrounding air pollution. I have a scientific background and so am comfortable interpreting the various scientific research and publications within my area of expertise.
In terms of air pollution, my understanding of the aim of UK Government policy is to protect the population’s health in accordance with national, European and international obligations on air pollution. There is a recognition and acceptance that air pollution has a substantial negative impact on the population’s health and causes and contributes to ill health and premature death. However, based on my experience, we have had successive governments which have failed to take action on air pollution. Because of this failure to do so, the Government were taken to the Supreme Court by ClientEarth and lost, because of their failures to address air pollution and abide by their own commitments to abide by EU air pollution directives.
This approach towards the Government’s legal obligations in terms of air pollution seems to have permeated into the Airports Commission’s work, and the importance that Commission’s work has attributed towards air pollution.
The Airports Commission started its work about three years ago. The purpose of the Airports Commission was to look at how Britain could protect and enhance its Airport hub status. It rapidly morphed into looking at whether we need more capacity, and in particular in the south-east. Hub airports are where people change flights and service long distance flights. The majority of flights however are short–haul. The hub debate seems to come down to whether we ought to expand Heathrow to protect its status as a hub vis-à-vis, say, Dubai.
The Commission looked at demand and concluded fairly early the UK needed a new runway in the South East. They brushed aside arguments that we did not. They then looked at a long list of possible options for new runways. This then narrowed to a shortlist of three comprising of the Heathrow NW option (which has been recommended), an extended Northern runway at Heathrow and an extra runway at Gatwick Airport. They only looked at air pollution in very rudimentary terms. Levels of air pollution were lower at every other location, but nonetheless the shortlist of three included two options at Heathrow Airport. This fact alone indicates that air pollution was not a significant consideration when it came to selecting the most suitable option for a new runway, and indeed is reflective of the Government’s attitude generally towards air pollution and aviation policy.
In November 2014 the Airports Commission published the first major report by Jacobs Consultancy. I have doubts over the independence of the consultancy as they were being paid by the Commission. It was subsequently accepted the report had shortcomings and they did more detailed computer simulations on air pollution modelling before publishing a further report in May 2015. A critique of both reports, together with context of the reports, is available on request.
The Airports Commission’s concluding report in July 2015 seemed not to take into account the May 2015 air pollution study in anything more than a superficial way. This is unsurprising given the timing of the publications. This seemed to suggest they were going through the motions with this May 2015 study and had always intended to have Heathrow as the preferred option, whatever the later air pollution study said.
Regardless of the established links between aviation and climate change and air pollution, all the main political parties bar the Green Party think aviation has a strong ability to transform the economy, much in the same way that people used to think about motorways. Within the Conservative party there is something of a divide. Generally there is quite a lot of support for growth of aviation in terms of expanding capacity. There is however much more opposition to growth at particular places. Opposition to Heathrow Airport is perhaps the most prominent of these examples because of the levels of pollution and the number of people affected. Zac Goldsmith MP (for Richmond-upon-Thames) is prominent amongst these local opponents. It seems the support for the principle of expansion is there, but not for the local reality. The same is true in the Labour Party; there has been general support for the apparent economic benefits of airport expansion but fierce opposition from local opponents such as John McDonnell MP.
People outside of London have accused local residents of wanting to halt growth to the economy by prioritising their local concern. It’s true to say the issue is difficult. If people are driving, using airports and other industrial processes, it seems to me it is hard, but by no means impossible, to comply with the environmental legislation.
The biggest source of air pollution is road traffic where I live. You would have to constrain road traffic to reduce air pollution significantly. The problem at Heathrow is that when the airport is added, it makes things worse. Clearly if the airport is expanded, this will make things worse. There has been a suggestion of imposing a congestion charge around Heathrow to tackle this. This seems inconceivable politically. I cannot see the air pollution problem being solved any time soon. This new proposal to expand Heathrow will make it worse.
As far as the UK Government and the EU are concerned, air pollution limits are absolute. The limits do not allow breaches for economic growth or any other reason. The EU has said UK is in breach at a number of locations and UK is required to take action to reduce these levels to acceptable levels as soon as possible. The UK Government has now published a plan (which has been criticised by ClientEarth) to comply within a certain number of years.
When looking at the proposed mitigation to counter the effects of air pollution at an expanded Heathrow Airport in the Airports Commission, my initial reaction was that this is not much more than a series of good ideas. The mitigation was not actually recommended by the Airports Commission. In my view, given the importance of this issue it is not good enough to simply have good ideas that might work.
I am aware that the Airports Commission has said that capacity should not be released if a new runway is built until the air pollution standards are met. I cannot believe that once billions of pounds of taxpayers and private sector money had been spent on expansion, it will be possible to resist the pressure to use the runway, regardless of the levels of air pollution. It would be politically inconceivable to leave a runway empty whilst there was an argument about whether to use it because of air pollution. Without the confidence in concrete proposals and recommendations to solve the air pollution problem, the Airports Commission ought not to have recommended it be built.
There has been opposition at various levels to airport expansion. People who would lose houses have more immediate and different concerns than air pollution and long term health issues. Then there is a swathe of people affected by aircraft noise and also concerned about air pollution and road congestion at local and regional levels. There is then a third category of people concerned about aviation policy in general such as Friends of Earth and the AEF, who are more concerned about the relationship between aviation and climate change.
As an organisation, the AEF have engaged throughout the process. The Airports Commission held quite a lot of sessions with individual groups and big public meetings. Lots of documents have been put out for consultation. We have responded fully to those. We have written to MPs and explained the situation as we see it. We have done as much as we could bearing in mind we are a national organisation. We have also attended party political conferences and done press work. We only have three full time staff. Our director represents all the world’s NGOs on the International Civil Aviation Authority, concerned particularly with Climate Change. The Aviation industry and Heathrow Airport have hugely more resources and it is difficult to counter the scale of their PR.
I do think that we have had an impact but if I am honest, I think it has been modest. It is not because of the quality of work we have done, but the quantity.
I think we are listened to by officials at the Department for Transport and MPs. But broadly speaking we are listened to by people who are already supportive of our work. Our ability to influence the public at large has been much less given the levels of PR from Heathrow Airport and Business First and the majority of the press.
Even when drawing the relationship between air pollution and premature death, we have not had great successes in bringing about the shift in policy that would be needed to reduce these levels of death. I think this is because there is a lack of understanding and willingness to understand public health issues. The contrast in publicity and concern between the 29,500 people who die annually from air pollution and the handful who die tragically in terrorism is huge. Most people appear not to want to know, either because it is an uncomfortable truth or gets in the way of other policies. The fact there are legal obligations in regard to air pollution does not seem to make much difference.
I have been a campaigner for nearly 40 years. In my experience, writing to MPs, responding to consultations, meeting officials and other conventional methods seem to have very little impact. As an organisation we run the risk of being co-opted onto committees which take up considerable time and compromise our independence. We see consultation processes which are charades, where policy has been determined in advance.
The democratic process is a bit of a sham. Unfortunately in reality it does not work when it comes to complex public policy processes such as this.
I am of the view that action is necessary to address air pollution and climate change caused by aviation. As a society we have known about the health impacts for a number of years and there has been virtually no action. All the work of the existing institutions and policy consultations have not succeeded in addressing these problems of air pollution. It may be the Government does indeed want to take action, but it cannot in the face of vested interests such as the motoring lobby and other business interests.
In this particular case, the thing which could have made a difference would have been if the government appointed somebody genuinely independent to chair the Airports Commission. It was so clear it was not independent. Howard Davies was chosen by government and was in contact with the government throughout the process. The secretariat for the Airports Commission was drawn largely from the Department for Transport.
We have experience as an organisation of lobbying the Department for Transport. Lobbying civil servants has been fairly soul-destroying. Air pollution is the statutory responsibility of the Department for the Environment, Farming and Rural Affairs (DEFRA). It is a weak department and has been heavily cut. In comparison to the Department for Transport (which is responsible for aviation policy), it does not appear to have much clout in determining policy which affects air pollution and climate change.
Even where the evidence of the link between aviation, air pollution and climate change is accepted and the consequences of those are clearly established, and legal obligations in place purporting to ensure compliance, the political process has not produced policy which allows for compliance with these obligations and reduce the harmful effects of non-compliance. I do not feel the conventional approaches have worked on this issue. I have learned it is not good enough to just be right on an issue or have legislation in place, when there are so many people who do not want to take action. It is my view therefore that the Defendants were justified in taking the action that they did and that it was necessary for them to do so.
