Position Paper on Balanced Approach

Position paper on the revision of the Balance Approach

Airport Regions Council (ARC), the organization of cities and regions hosting an airport in their territories, on one hand, recognizes and supports that airports are vital nodes in Europe’s connectivity and economic competitiveness and, on the other, considers noise as the most important environmental impact to population living nearby. Therefore, we would like to express our concerns and proposal regarding the actual revision of the Balanced Approach.

First of all, we consider that this regulation was a good initiative but after so much time with the increase of number of flights in all European airports and the increase number of people living nearby and the increase of the wish of people to enjoy the minimum standards of a good quality of life, the Balance Approach must move forward.

First, and most important, airport authorities and territorial authorities (national, regional and local governments) should have the right to participate in the balance approach process if they consider so, but they can propose too whatever measure they may can consider without going through the balance approach process. It cannot be accepted by any means that Balanced Approach can remove the democratic rights of public authorities to set and defend their own aviation policy nor either the right of airports to decide what might be in their best interest in running an airport. Airports, owned or managed with public or private money, must remain seen and considered as public transport infrastructures like the rest.

The participation requirements also fail to meet the standards arising from the Aarhus Convention. It’s true, and well considered, that stakeholders are formally involved, but the procedure is, in our opinion, too technically and economically dominated what means, in fact, local governments and even regional ones have no real opportunity to exert influence. Access to information is limited, the underlying models are often not public -just the other way around-, and decision-making takes place within a closed expert culture in which the aviation sector holds a clear -and sometimes abusive- dominant position. This is at odds with the principle of effective participation and undermines trust in decision-making. What it’s really a bad situation for all stakeholders including the airports their self as this situation this fosters a rejection by local governments of any initiative to expand airport infrastructure or any operational changes. Furthermore, a clear test of proportionality and subsidiarity is lacking.

Two last comments and remarks:

The Balanced Approach document advocates that measurable criteria should be used when measuring noise. So, we defend that the present most efficient metrics should be implemented and used in all airports.

As the Balanced Approach outlines good practices to reduce aviation noise already implemented in different airports across Europe, it should propose procedures and regulations to obligate all airports and airlines to adopt all good practices outlined in a concrete period of time.