Yet again, Europe is getting out of kilter over aircraft noise - and yet again it is doing so to the detriment of its credibility. This time, it is the European Civil Aviation Conference (ECAC) which is trying to drag the European legislative process into disrepute, by formulating rules which would limit the use of Chapter 2 aircraft which have been modified to satisfy the quieter Chapter 3 requirements, to the point where they would effectively be banned.

Any operator which has already hushkitted, or is hushkitting, a Chapter 2 aircraft to Stage 3 compliancy in the expectation of extending that aircraft's life in Europe beyond the end of 1999 would rightly feel aggrieved by this. The rules as they exist make no mention of subdivisions within Chapters of noise compliancy: a Chapter 3 aircraft is a Chapter 3 aircraft, no matter what its history.

As the ECAC and the European Commission (EC) would have it, however, a Chapter 3 aircraft which used to be a Chapter 2 aircraft would still be regarded as a Chapter 2 machine, with a few dispensations. It would be like a convicted criminal who has served his sentence, but who still carries the stigma of the crime. Such an aircraft would have a massively reduced market value, both inside and outside the European Union, probably to the point where the operator would never be able to recoup the cost of the hushkitting. (Once the rules are re-written to create this new sub-species of Chapter 3, it will be even easier to extend the discrimination against these apparently marginal Chapter 3 aircraft into operating-hours restrictions and the like, making them even less attractive.)

Nobody wants airlines to operate aircraft which are noisier than they need to be - least of all the airlines themselves. There is enough hassle attached to running an airline in Europe already, without having to cope with being singled out for special attention by noise protesters and legislators. Neither, however, do most people want to pay extra for the services which these noisier (but still legally noisier) aircraft provide. Most of them are used on either freight/parcels services or on low-fare passenger services.

Freight and parcels aircraft, in general, have very low utilisation rates (though much of that utilisation is in the most noise-sensitive period, at night) which would make the use of quiet new aircraft prohibitively expensive. Those freight and parcels services perform a vital role within Europe, however - a function on which ECAC and EC bureaucrats depend as much as anybody else for distributing their tonnes of documentation. The EC also depends on the low-cost start-up carriers for the implementation of its policies. It is not the inefficient, high-cost-base, subsidised state-owned airlines of Europe with their expensive modern aircraft which are advancing the EC's deregulation dreams, but the start-ups using older-generation equipment.

Again, none of those airlines has a deep-seated attachment to running these old aircraft but, equally, few of them can afford to create new niches on the back of the high costs of owning new equipment. If the EC wants to foster extra competition on European routes to drive down what it claims are too-high fares, it must accept that the competition will be noisier than the ideal, at least while the start-ups establish themselves to the point of being able to justify acquiring new equipment.

There is a very real need to reduce the environmental impact of aviation, but that will be best achieved with the co-operation of the industry, not through alienating it. The aim of getting the entire European fleet to full Chapter 3 compliancy (and then on to a future Chapter 4) is a laudable one, but it will not be served well by the retrospective introduction of bad new rules.

The old aircraft which have been converted (and would have been, but for this untimely intervention) comprise a small and ever-diminishing part of the European fleet. They contribute an even smaller proportion of the combined absolute noise of European aviation, because of their generally low utilisation. They would have naturally faded away over the next few years without the ECAC's attempt at retrospectivity. Moving against those who have complied with the rules will do nothing except bring the whole process into deserved ill-repute.

Source: Flight International