Our submission on the Civil Aviation Bill


On the 17th of February, we made an oral submission to the Infrastructure and Transport Committee, following our written submission. Watch the video here:

Alternatively, you can read the full transcript of our submission here:

Guardians of the Bays is an incorporated society representing 400 concerned residents opposing any increase in airport activity until its adverse effects can be mitigated. Whether its air quality, noise or climate change, we believe we have reached peak pollution when it comes to aviation.

We also believe this Bill must make sure it puts New Zealanders and communities first, and then after, aviation. Groups like ours spend considerable of personal time and personal resources in a true David versus Goliath situation. This new Bill represents an opportunity to empower New Zealanders and communities in the face of the aviation industry.

According to Minister of Transport Michael Wood: “This Bill repeals and replaces the Civil Aviation Act 1990 and the Airport Authorities Act 1966 with a single, modern statute that will provide a platform for safety, security, and economic regulation of civil aviation now and well into the future.”

But there’s a gaping hole in it as it does almost nothing to address aviation’s contribution to the climate crisis.

Airports’ relentless drive to expand their flight and passenger numbers represents a threat both to climate and to local communities. Airports’ argument relies on demand they say they have to cater for. This forgets the induced demand created by airports’ growth itself. Very much like highways, roads, or bike lanes, “build it and they’ll come”. Letting airports grow contributes to create artificial demand, which leads to greater traffic and greater emissions. In the light of New Zealand’s international commitments to become carbon neutral, a Bill ignoring the intense aviation emissions would be deeply unwise to say the least.

While air travel often falls under international legislation, it is important this Bill includes strong emissions reductions domestically and includes New Zealand aviation emissions abroad as much as possible. We owe it to New Zealanders of today and tomorrow.

As outlined in our written submission, it is our view the climate-related measures in the Bill are entirely inadequate to the scale of the problem. Therefore, we have made clear and simple suggestions that stronger measures to reduce greenhouse gas emissions from aviation be included in the purpose clauses of the Bill and instantiated throughout the Bill.

Most importantly, amongst other suggestions outlined in our written submission, we have proposed to amend Clause 3, Main purpose to “The main purpose of this Act is a safe and secure civil aviation system that contributes to specific, measurable, and urgent greenhouse gas emissions reductions.”.

We are also suggesting the following changes within Clause 4, Additional purpose:

That subclause 4(e) is amended to read “to take into account the adverse effects of civil aviation on the interests of people, property, and the environment, with particular regard to the adverse effects of greenhouse gas emissions resulting from civil aviation”;

To add three new subclauses:

4(f) “To ensure that bringing about specific, measurable and urgent greenhouse gas emissions from aviation operations, including flights, is a primary consideration in all decisions regarding airport licensing and operations, including but not limited to proposals to build new airports, expand existing airports, extend airport runways or build new runways”;

4(g) “To implement a cap on gross domestic and international aviation emissions at 2021 levels, and to reduce this cap annually to ensure sharp reductions in gross aviation emissions during the first three budget periods of the Government’s Emissions Reduction Plan, and thereafter.”;

4(h) “To ensure the monitoring and minimisation of high aviation flight paths, especially of international flights, to reduce particulates of carbon dioxide, nitrogen oxides, sulphates, soot and water vapour in aircraft contrails which have the greatest climate changing impact”.

On noise, one should never underestimate the cost on living close to an aiport for local residents. The induced stress of being submitted constantly to noise has deep and severe consequences on people’s lives. It is no wonder it is used as torture technique. That’s why it is vital this Bill takes noise into strong consideration.

As stated in our written submission, we support Clause 58 Rules for noise abatement purposes which reads: “The Minister may make rules under section 52 prescribing flight rules, flight paths, altitude restrictions, and operating procedures for the purposes of noise abatement in the vicinity of aerodromes.”. Subsequently, we request that:

1. Noise levels in the environs of each airport be capped at or below current noise levels, to ensure that additional airport operations will not create any additional noise exposure for nearby residents;

2. That particular attention be given to significantly reduce recreational aviation operations in urban areas, as the noise adversely affects large groups of residents for the benefit of a small number of recreational flyers.

As a conclusion, Guardians of the Bays experiences first hand how communities around airports suffer the environmental consequences of capital expenditure on those airports and how these plans don’t consider the consequences of noise, visual, landscape and environmental issues on these communities. This Bill has an opportunity to ensure aviation in New Zealand continues to work for New Zealanders and for communities, those of today, and those of tomorrow. For that, we kindly ask members of this Select Committee to consider the proposed changes in our submission.