Air Departure Tax: consultations and environmental report

Consultations relating to our policy for an overall 50% Air Departure Tax (ADT) reduction by the end of the current session of Parliament. Includes a Strategic Environmental Assessment (SEA).


6 Biodiversity, Flora and Fauna

6.1 Environmental Objectives

6.1.1 Existing environmental protection objectives stem from a number of pieces of legislation and policy relating to the protection of biodiversity, flora and fauna. These objectives are largely aimed at protecting habitats and species from disturbance and damage, principally through the identification and conservation of areas of particular value. The policies define a hierarchy of protection from international and European levels down through to local level. International convention includes the development of the Aichi Biodiversity Targets [205] set by the United Nations Convention on Biological Diversity [206] .

6.1.2 At the European level, the Natura 2000 network of sites aims to protect key natural assets under the EC Habitats [207] and Birds Directives [208] , both of which have been transposed into UK and Scottish regulations. The Natura 2000 network is made up of Special Areas of Conservation (" SAC") and Special Protection Areas ( SPA). The majority of SPAs and SACs are also underpinned by Site of Special Scientific Interest (" SSSI") legislation as part of the Nature Conservation (Scotland) Act [209] .

6.1.3 The designation of European protected species, and the identification of species and habitats requiring conservation action in the UK, demonstrates the prioritisation of conservation ambitions at European and national levels. The 2020 Challenge for Scotland's Biodiversity [210] is Scotland's response to the 20 Aichi Targets set by the United Nations Convention on Biological Diversity and the European Union's Biodiversity Strategy for 2020. The 2020 Challenge supplements the 2004 Scottish Biodiversity Strategy [211] and focuses on the importance of healthy ecosystems and an outcome that "Scotland's ecosystems are restored to good ecological health so that they provide robust ecosystem services and build on our natural capital".

6.1.4 Beyond site and species designations there are also longer term aspirations for enhancing biodiversity, improving landscape-scale ecological networks and addressing the impacts of climate change on the natural environment.

6.2 Environmental Context

6.2.1 Scotland is rich in biodiversity, evident in the wide array of species and habitats found within its many unique terrestrial, coastal and marine ecosystems. Biodiversity plays a key role in supporting our lives through the provision of crucial resources like fresh air, clean water and food [212] . It is commonly used as a measure of the health of ecosystems, and provides many of the ecosystem services that are the basis of life, such as soil formation, nutrient recycling, flood regulation, and pollination, amongst others [213] . As such, biodiversity is closely linked with other environmental topics such as water and soil.

6.2.2 Many of Scotland's species and habitats are recognised for their vulnerability and/or importance at the European, UK and national levels. This is demonstrated through the establishment of a range of environmental designations aimed at safeguarding biodiversity. Such designations include 239 SACs, 153 SPAs, 51 Ramsar sites and 2 Biosphere reserves, amongst other internationally designated sites [214] . Further national level designations include 1,425 SSSIs, 30 Marine Protected Areas and 2 National Parks [215] .

6.2.3 Some of these protected sites are located in the vicinity of Scotland's airports, with many more located along air traffic flight paths and near to important transport hubs connecting these airports with urban centres. For example, Glasgow Airport is located adjacent to Black Cart SPA and Glasgow-Prestwick Airport is located approximately 200 miles south east of Troon Golf Links and Foreshore SSSI. In addition, Edinburgh Airport is located adjacent to the River Almond which flows into the Firth of Forth, which is itself an SPA.

6.2.4 Biodiversity loss has been well documented over the last 50 years, and today there are a range of pressures on Scotland's wildlife and biodiversity. Key issues such as climate change, changing land use and management leading to loss or damage of natural habitats, and the pollution of air and water, have been noted [216] .

6.2.5 Birds can be a significant hazard to aircraft, particularly during take-off and landing. The CAA states that roughly 85% of bird strikes involve aircraft below 800 feet in altitude [217] . As a consequence, control measures such as landscaping and noise and flare gun deterrents are used at many UK airports to reduce bird strike. There is also an online system for reporting incidents.

6.3 Findings

What are the likely implication of increased passenger and flight numbers on biodiversity, flora, and fauna?

6.3.1 Growth in the aviation sector has risen steadily over the last decade and a number of airport masterplans have set out a vision to facilitate this growth within current airport capacity. However, these plans acknowledge that, from 2020 to 2040, it is likely that increased pressure on infrastructure though passenger growth will potentially lead to some airports undertaking development. The figures used in the masterplans to predict growth do not reflect any additional increase that has been estimated to arise as a result of the preferred policy option. As such, it would be reasonable to assume this has the potential to lead to further pressure on the ability of some airports to accommodate growth within existing infrastructure.

6.3.2 Aviation activity can have a negative impact on biodiversity through habitat loss and fragmentation, wildlife can be disturbed by increased noise and vibration levels, and measures taken to reduce the risk of planes colliding with birds can have their own disruptive effects [218] . Construction and development activities can also have a negative impact, for example, through noise and disturbance. The SEA of the NPF3 noted that there would be the potential for loss of habitats arising from the proposed Strategic Airport Enhancements and disturbance during construction activities [219] . It further stated that, in some instances, consideration would be required to be given to situations where the proposed development may impact on designated sites nearby.

6.3.3 The above are considered as potential secondary impacts that may arise as a result of the preferred policy option. Another secondary impact likely to arise is the contribution to GHG emissions arising from the aviation sector. The predicted effects of climate change and the potential for associated impacts on biodiversity, flora, and fauna are well documented, with evidence showing the wide range of effects that a changing climate can have on flora and fauna, species and their habitats [220] .

6.3.4 There is the potential that the above impacts will be influenced by the degree of increase in passenger and flight numbers. For example, the greater the increase over current levels experienced, the greater the potential pressure placed on existing infrastructure. When considering the illustrative scenarios of adopting a differential approach to delivering the preferred policy option, applying a zero tax rate amount to only short-haul flights could exert more pressure on infrastructure through higher passenger numbers than compared to reducing the tax charged on both short and long-haul flights by an equal proportion. Conversely, the additional pressure on infrastructure may be lower by applying a zero tax rate amount to only long-haul flights and maintaining the tax charged on short-haul flights at current UK APD levels.

6.3.5 It is considered that there would be no direct impact on passenger and flight numbers as a result of the reasonable alternative of applying tax rates that would remain the same as that currently set under UK APD as this represents a "like for like" approach. As such, activity in the sector would continue on the current trajectory predicted.

What wider context and potential mitigation measures should be taken into account?

6.3.6 Airport masterplans consider potential development up to 2040, with acknowledgement that predicting requirements up to this stage is complex due to the many variables surrounding passenger demand, such as economic and global events.

6.3.7 Any future airport and supporting infrastructure development would be outwith the remit of the preferred policy option to influence. It is likely that any proposals for future significant infrastructure works will be required to undertake an Environmental Impact Assessment (" EIA"). Further project level assessment, including EIA screening, will therefore be required to establish significance. Travel connectivity for Scotland's airports is also widely addressed through Local Development plans, which are currently subject to SEA.

6.3.8 Airports manage large sites which are not accessible to the general public and therefore can also provide an opportunity to support biodiversity in some instances.

What is the likely significance of the predicted impacts?

6.3.9 At this stage of the SEA process it is difficult to predict with any degree of certainty the extent and significance of the identified impacts. It has been assumed that the preferred policy option will lead to increased growth in the aviation sector and place further pressure on existing airport infrastructure. The extent to which this increase is realised is likely to be further influenced through the different pathways that could be taken to in order to meet the 50% reduction in the overall ADT burden set out in the preferred policy option.

6.3.10 The scale and location of any proposed works may also be influenced by a number of factors: for example, the creation of more accessible and sustainable transport infrastructure links, as set out in NPF3. Additionally, technological and operational developments at individual airports may accommodate the estimated growth without the need for further development in the short-term.

6.3.11 Due to the nature of the identified changes, impacts that could arise from infrastructure requirements are likely to be realised at a local level and could be long-term in nature. Short-term impacts may also arise from construction activities. Further to this, there may be impacts on biodiversity as a result of climate change.

Box 6.1 Biodiversity, Flora and Fauna: Summary of impacts and key points

Impacts
  • Infrastructure requirements (including construction activities) can lead to negative impacts on habitats and species.
  • Noise disturbance from aviation activity can impact on biodiversity.
  • Bird populations can both harm and be harmed by aircraft.
Key Points
  • Scotland is rich in biodiversity and many species are of international or European importance.
  • Mitigation against these impacts is best identified and undertaken at the project level.
  • Climate change continues to be a primary stressor on biodiversity and may exacerbate the effects of other pressures, such as those arising from the preferred policy option.

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