TAG Guidance Notes on responding to the Civil Aviation Authority s consultation on its Five Year Strategy 1. Introduction (Deadline for consultation responses is 19 February 2016) The CAA is currently consulting on its Five Year Strategic Plan. The plan can be found at: http://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=7074 The form for responding to the consultation can be found at: https://www.surveymonkey.co.uk/r/caa5yearplan 2. Why you should respond to the consultation The CAA is the UK s aviation regulator. On its website, it states that its role is to ensure that: the aviation industry meets the highest safety standards consumers have choice, value for money, are protected and treated fairly when they fly we drive improvements in airlines and airports environmental performance the aviation industry manages security risks effectively. However, the CAA website also acknowledges that it has a key role around aviation noise and the environment. Its three key roles around aviation noise are described as: We manage the way airspace is used, so can help limit the effects of noise through the routes that aircraft take. We monitor noise around UK airports, and publish information about noise levels and impacts. We do this for a range of customers including the UK Government, airport operators, airspace change proposers and local authorities. We collaborate on and review research into the effects of noise and how they can be reduced, and offer advice to Government on these effects. The CAA also states that as aviation's regulator we ourselves have a key role to play. In light of this the CAA has adopted a sustainability objective as part of our five-year Strategic Plan. Our objective is as follows: To improve environmental performance through more efficient use of airspace and make an efficient contribution to reducing the aviation industry s environmental impacts. Finally, the CAA states that one of the major challenges it faces in the years ahead is playing a driving role in the biggest series of airspace changes ever in the UK in some of the busiest airspace in Europe, including taking into account the views of all stakeholders impacted. Its five year strategy will help to shape how it approaches this challenge and it is therefore vital that overflown residents and communities influence this. TAG has produced some guidance notes that you may find of use when completing the consultation survey. 1
Teddington Action Group Guidance on the completion of the CAA consultation into its Five Year Strategic Plan The Five Year Plan and consultation survey can be found at: https://www.caa.co.uk/our-work/corporate-reports/strategic-plan/our-five-year-strategicplan/ You complete the survey via an online web tool Survey Monkey. The questions and our guidance notes for completing them are shown below. 1. Please complete your contact details This asks for your organisation (if applicable). We would advise you to leave this blank as if they receive a number of responses attributed to TAG, they may aggregate these and include them as a single organisational response. 2. Are you happy for us to contact you to discuss your responses in more detail? If you feel comfortable with this, we would encourage you to tick yes 3. How would you best describe your interest in this consultation? We suggest that you write Overflown resident in the Other category. 4. Do you broadly agree with our vision for how aviation might be made to work better now and in the future? - No mention of reducing the environmental impact of aviation. - Benefits of new technology are acknowledged, but only for consumers and not overflown residents - Welcome that the CAA intends to take proper account of the overflown. 5. Do you agree with how we have described our roles and purpose (in the context of our statutory duties)? - There is no mention of the environment. - Welcome the statement that the CAA intends to step in to balance the interests of those who fly and communities affected by noise on the ground in a fair and objective way. But disappointing this appears to be of lower priority than wishes of consumers. - No proposals for how CAA will look to resolve the inherent conflict of interest between the CAA representing the interests of consumers and the aviation industry, but also being the sole organisation responsible for protecting residential communities from aviation noise. 6. Do you agree with the description of our context, in particular the drivers for the next five years? - The list of CAA achievements focuses on what it has done to benefit the aviation industry and consumers. Only brief mention of residents and the CAA recognising that distribution of noise is an increasingly significant issue. 2
Does not give confidence that CAA considers residents as an important stakeholder. - Absence of any reference to Future Airspace Strategy which will impact 29million people in UK. - Absence of reference to reducing environmental impact of aviation and need to meet worldwide and European emissions targets. - Does not acknowledge that the introduction of new technology e.g., PBN technology has had a negative impact on the quality of life of people on the ground. This technology should not be introduced before a proper assessment of public annoyance/health impacts has been undertaken. - Does not mention how new technology can reduce noise for residents and the importance of this is not recognised as a driver. 7. Do you agree with our guiding principles? - Principles give impression that CAA aren t responsible for delivering anything, but they are given specific responsibilities through legislation and are responsible for delivering these, including reducing noise impacts. - Principles state CAA will seek solutions that deliver the desired outcomes with minimal intervention. This does not give confidence to the public who look to CAA to protect it on safety grounds as well as noise and the environment. - The we will work hard to meet the expectations of others section is focused on the industry s wishes and gives the impression CAA exists to make the industry s life easier rather than be an independent regulator whose first priority is to protect the public. 8. Do you agree with our priorities as set out in the Plan and reproduced below? We suggest that you tick no for all five priorities. You may wish to include the following points within - Risk based regulation : gives the impression of prioritising reducing the administration and cost of regulation over all else - Empowering consumers: aviation environmental considerations should not be included here and should be a priority in their own right. Consumers and the public (including residents) do not necessarily have the same priorities and the CAA should recognise this. - Infrastructure optimisation: section focuses on the benefits of new infrastructure for airports, airlines and consumers but again, residents appear not to be a key stakeholder for the CAA. - Service excellence: no mention of residents or communities here. Does the CAA not consider it important to provide a good service to these stakeholders? - Technological innovation: the priority here appears to be reassuring aviation companies that CAA will limit its interventions and this does not reassure the public that the CAA sees its responsibility to protect the public as paramount. 9. Do you agree with the key elements of our internal change programme? 3
- Better application of information and intelligence - here the CAA commits to an annual survey of consumer attitudes but there is no similar initiative to survey attitudes of residents and overflown communities. Are their views not important to the CAA? Also, there is no mention of how the CAA will use improved information and intelligence in how it measures noise and annoyance associated with aviation. - Service excellence: there is no mention of how the CAA intends to improve the service it provides to the public (including residents in overflown communities) and its complaints process. - Communication and engagement this section lacks detail and fails to reflect that different stakeholders require different communication and engagement approaches. 10. Are there innovation opportunities, including changes in regulatory approach, or ways of working that we should consider over the next five years that are not mentioned in the draft strategic plan? We suggest that you tick yes. You may wish to include the following points within - The CAA s approach and the aviation regulatory framework should take full account of the feedback documented in the Helios report published on 8 December, the Independent review of the Civil Aviation Authority's Airspace Change Process which reflected a number of concerns from a range of stakeholders about the current process. - Opportunities through technology to reduce the noise burden should be prioritised - The CAA should give much greater weight to limiting the effects of aviation noise and its role in improving the environmental performance of the industry. - The responsibility for protecting residential communities/the public from aviation noise and pollution should be taken away from the CAA and given to an independent regulator. It will be necessary to get this regulator effective sanctions against the CAA and/or air-traffic control, the airports and airlines. 11. Which of our organisational functions are most relevant to you? We suggest that you tick: Safety, Security, Environment and Better Regulation. 12. For those selected above are the key programmes proposed broadly the right ones? - Safety and security: no mention of safety concerns of residents and overflown communities, which is of particular concern for communities living under Heathrow s flight paths because it is such a densely populated area. - Environment Disagree that the CAA does not have any formal powers to reduce the noise or environmental impact of aviation as these are set out under Section 70 of the Transport Act and tasks the CAA with, amongst other things, the need to reduce, control and mitigate as far as possible, the environmental impacts of civil aircraft operations. If CAA feels that it needs additional powers to fulfil its duties, it should identify what powers are necessary. As noted above, consideration should be given to having formal sanctions against the CAA for not performing its duties in this regard. 4
- Better Regulation no mention of how the CAA can improve its regulatory approach to benefit residents and overflown communities, its main concern appears to be reducing the cost and burden on aviation-related businesses. On this basis, how can residents have any confidence in the CAA to protect them? 13. For those selected above, do you agree with the consumer and public outcomes and our other proposed measures that are set out in the strategic plan? - The consumer and public outcomes overlook residents and stakeholder groups as a stakeholder group in their own right - As a result, this group s needs and concerns have been completely overlooked within the outcomes and proposed measures. - Environmental outcomes and proposed measures have also not been given sufficient weighting 14. Over the next five years, are there any other significant areas that you believe we should be addressing but are not addressed in this strategic plan? You may wish to include the following points in your response: - Climate change needs to be considered in much more depth and in particular the new targets that countries have to meet to reduce harmful emissions and how the aviation industry will contribute to this reduction. - The extensive research pointing to serious adverse health and educational effects linked to aviation and how the regulatory framework needs to be adapted to reflect this. - The CAA should enforce general compliance of the aviation industry with international health advice and regulations on reducing the noise and atmospheric effects of aviation. 15. Do you have any final comments in the strategic plan? You may wish to include the following points in your response: - It is very disappointing that both the environmental impact of aviation as well as the interests of residents in overflown communities have been given so little consideration throughout the document. - The CAA appears to place greater weight on its role to protect consumers and support the aviation industry than on its duties to protect the public, including to the need to reduce, control and mitigate as far as possible, the environmental impacts of civil aircraft operations. If the CAA feels that it cannot do this effectively, the powers should be given to another, truly independent body who has sanctions over the CAA, airports and airlines. 5