Aircraft noise and gaseous emissions regulations
1. PURPOSE AND INTENDED EFFECT
(i) The Issue and Objective
UK legislation on noise from any future supersonic aircraft and microlights and helicopters and gaseous emissions from jet aero-engines is contained in different Statutory Instruments. In some cases, the latest standards agreed in ICAO need to be incorporated. (These are set out in Volumes I and II of Annex 16 to the Convention on International Civil Aviation 1944 ("the Chicago Convention").)
The proposed Order:
Consolidates in one document the relevant provisions
Harmonises certain applicability dates with those in Volumes I and II of Annex 16
Implements in UK legislation the most recent provisions in Annex 16, Volume II relating to carbon monoxide (CO) and oxides of nitrogen (Nox), and
Simplifies the existing UK national regulation relating to noise levels for microlight aircraft.
(ii) Risk Assessment
(a) Microlight Aircraft
Problem
The permitted noise levels for microlight aircraft need to be updated to take into account developments in technology. Consultation with the microlight industry and the CAA indicate that it is feasible to require that where a microlight is type certified after the coming into force of the Order:
except where the static tip speed of the propeller exceeds a Mach number of 0.7, it should cease to benefit from a correction applied to the noise measurement data to allow for temperature difference. This represents a slight increase in stringency; and
it should meet a unified limit of 80 dBA whether single- or two-seater. This represents a relaxation in stringency for single seat microlights but is an increase for two-seat models.
Risk estimation
There is no accepted way of quantifying the risk associated with nuisance from microlight noise.
Options
Since the proposals are based upon developments in noise reduction technology by industry they represent the minimum action required to combine a unified noise certification level with a worthwhile increase in noise reduction.
Estimating the impact of the options on the risk
The proposals in the Order would have some effect in reducing noise compared with the do nothing option but it is not possible to quantify the likely reduction in the number of people affected by microlight noise.
Monetary valuation of the benefits of the options
The benefits of the proposals in the Order can only be assessed qualitatively in terms of advantages to manufacturers of a unified noise certification level and to the residents around airfields in terms of lower noise levels. It is Government policy to reduce aircraft noise.
Compare the costs with the benefits
Do nothing - no costs, no benefits.
Proposals in the Order - The CAA has costed the proposals in the Order by using data from the 1999 registration index. They have calculated that if all machines registered in that year had been required to meet the new conditions, there would have been a cost to manufacturers of £5,100 (1999 price3s) in redesigning some machines to meet the new limits. Furthermore, microlight user purchasing existing non-compliant types would have had to pay about £25,000 in total (£100 to £500 each) for off-the-shelf modifications such as new propellers or engine mufflers, before being allowed to register the machines. The cost to the manufacturers would be a one-off, non-recurring cost, since all new types would be designed to be compliant with the new limits. Existing types which could be modified to meet the new limits would continue to be manufactured and purchasers of such machines would have to pay for the modifications. However, this figure would lessen after the first year of the new limits as compliant machines were progressively introduced.
Summary and recommendations
The benefits of the proposal in terms of the reduction of noise around airfields can be expressed only in qualitative terms, but they are expected to be real. The costs to microlight users and industry are expected to be some £30,000 at 1999 prices against sales in that year of £2.4M. It is recommended that the proposals be accepted.
(b) Oxides of Nitrogen
Problem
The UK has not yet introduced the internationally agreed standards for the emission of oxides of nitrogen (NOx) in Volume II of Annex 16 to the Chicago Convention 1944.
Risk estimation
The UK supported this tightening of emissions standards within ICAO. There is an unquantifiable risk that not implementing these standards would jeopardise the Government's policy of pressing for appropriate measures on aircraft emissions, taking into account scientific evidence and the precautionary principle, and would weaken its stance on sustainable development.
Options
To do nothing or to introduce the standard.
Estimating the effect of the options on the risk
Owing to the uncertainties in scientific knowledge about the global environmental impact of air craft emissions, reductions in emissions should be regarded only as a proxy for benefits. Introducing the standard would have some impact in reducing global NOx emissions are compared with the option of doing nothing.
Compare the costs with the benefits
The UK's only manufacturer of jet engines Rolls Royce, has been consulted and has indicated that it has incurred research and development costs in developing engines which would comply with the standards in Annex 16. The company has released data on this to the DTI but has asked that it not be made public for reasons of commercial confidentiality. However, it could be argued that the decision to develop such engines was a commercial one taken to maintain the company's international competitiveness.
Political considerations
The UK supported the revised NOx standard within ICAO's Committee on Aviation Environmental Protection and has a long-standing commitment to introduce it.
Summary and recommendation
It is recommended that RR's wish for commercial confidentiality be respected and that the standard for NOx be introduced.
2. COMPLIANCE COSTS FOR A TYPICAL BUSINESS
Microlights
In 1999, sales of microlight aircraft in the UK were £2.4M. One concern accounted for £0.85M of this. The estimated cost of compliance for them would be £1500. The other major company accounted for £0.40M of sales, and the estimated cost of compliance for them would be £3000. Three other manufacturers would have £200 each compliance costs.
Summary of costs and other key information
1. Only the proposals relating to microlight aircraft and introduction of the ICAO NOx standard may increase costs to industry. There will be significant savings in relation to the proposed simplification of noise certification of light helicopters.
|
BUSINESS |
NON-RECURRING COSTS |
RECURRING COSTS |
|---|---|---|
|
Manufacturers of microlight aircraft |
£5,100 |
£0 |
|
Jet engine manufacturer (Rolls Royce) |
Company unwilling to release cost information (commercial sensitivity) |
Company unwilling to release cost information (commercial sensitivity) |
|
Manufacturers and importers of light helicopters |
£0 |
$315,000 per noise certification. (Likely to be intermittent. Westland recorded 3 tests in 1988 - 1999.) |
2. Other main points
There is unlikely to be any effect on the UK's international competiveness:
Non implementation in the UK would not reduce costs to Rolls Royce since the company's engines have to compete in the global market; and
There are no cost implications for existing monitoring and review arrangements.
Business sectors affected
Jet aircraft engines
The only UK manufacturer has indicated that they have incurred research and development costs and will continue to do so in order to comply with the NOx standard in Annex 16, Volume II. The company has supplied the DTI with their estimate of these costs, but has asked for them not to be made public on the grounds of commercial sensitivity. However, the research and development costs of complying with the ICAO standard might be regarded as having been incurred to maintain the company's international competitiveness and to have been a commercial decision.
COMPLIANCE SAVING
The saving arises because the test procedures required to certificate light helicopters with a maximum take-off weight of less than 273kg under Chapter 11 of Volume I of Annex 16 are much less complex than those used for heavier machines. However, tests are infrequent and occur only when new helicopter types are developed, making it difficult to assess the effect on any one company.
EFFECT ON INTERNATIONAL COMPETITIVENESS
There are unlikely to be any effects on the international competitiveness of UK companies.
ARRANGEMENTS FOR MONITORING AND REVIEW
No new or revised arrangements for monitoring compliance or savings will be required.
ALTERNATIVE APPROACHES
Microlight aircraft have been regulated for noise in the UK since 1984. The proposed Order takes account of improvements in technology and simplifies the certification requirement. Provisions on fuel venting, smoke and unburned hydrocarbons already exist in UK legislation the internationally agreed standards on emissions of carbon monoxide and oxides of nitrogen which the UK supported in the International Civil Aviation Organisation (ICAO).
3. RESULTS OF CONSULTATION
Microlight aircraft
We have consulted directly with the organisations that represent the UK microlighting community - the British Microlighting Association and the Popular Flying Association. No objections to the proposed measures have been raised.
Jet aircraft engines
Rolls Royce has been consulted during the development of the amendment to the Chicago Convention and in the drafting of the Order directly and via contacts in the Department of Trade and Industry and the Defence Evaluation Research Agency. Rolls Royce is content with the Order in the light of the waiver contained in Article 10(4)(a).
Light helicopters
Westland was consulted via the Safety Regulation Group of the Civil Aviation Authority.
CONTACT POINT
Mr Len Britton
Avaition Environmental Division 1
Department for Transport, Local Government and the Regions
Zone 1/31
Great Minster House
76 Marsham Street
SW1P 4DR
Tel: 020 7944 4876
Date: 15 November 2001
