At page 35 the JAAP refers to the need for a sustainable operating strategy and includes reference to a "carbon and environmental management plan". It is important that the JAAP should acknowledge the scientific reality that aviation is not sustainable. Any suggestion that it is sustainable is irrational. Aviation could be sustainable if fuel were to be derived from non-fossil fuel resources and any greenhouse gases emitted were captured and sequestered. But fuel currently derived from sources such as algae are believed to be so prohibitively expensive that only the super rich could ever afford to fly.

The airport owners should be required to publish annually the total quantity of the various greenhouse gas emissions associated with the flights to and from the airport, and all emissions from the ground based operations.

The airport should also be required to publish an annual report and certificate on compliance with the handling of de-icing and other contaminants. This report should detail how contaminated water and other effluent are handled and detail any leaks into the surrounding water courses.

It is irrational and dangerous not to include these.

The councils should also require that the airport owners undertake to investigate all complaints relating to other contaminants that land on property and provide an annual report on the outcome of these investigations.

Page 35 notes that planning applications will be welcomed that contribute to modal shift. The JAAP should in fact set out what penalties it will put in place to deter the airport owners from offering flights to destinations that can be reached by rail.