Last week’s Flight International contained a very interesting article about huskitting, and the different stances taken by the USA and EU on the issue. Having had a week to think about it, I thought I’d post my thoughts in the hope there might be some discussion on the matter. I nearly didn’t because I was worried this could turn into a slanging match, but I’m sure we can control ourselves!
First the rule; On the 4th May no more hushkitted aircraft can be added to EU registers unless they have a history of operation into the EU since 1995.
The EU is reasonably claiming this is on environmental grounds, there is little argument that hushkitted aircraft only just scrape within the stage 3 rules they still have higher levels of not only noise, but also harmful emissions. Also noise tradeoffs are allowed, which means aircraft may exceed the stage 3 rules in one area if they meet them in the other 2 parameters comfortably. For example the F100 has a noise margin of 7.8dB, with no shortfall – while the MD-87 only has a margin of 1.9dB, including a shortfall in sideline noise limits, remember the dB scale is logarithmic. If the MD-80 only just meets the requirements, older technology aircraft must come within the rules by a knife-edge.
The USA, home to the hushkitting industry and most airlines operating hushkitted aircraft, claims this threatens the industry and aircraft resale values. However, this doesn’t seem borne out by reality. European airlines operate very few hushkitted aircraft, they generally have more modern fleets than their US counterparts – it’s quite rare to see a 737-200, 727 or DC-9 at many airports now, even though they still proliferate in the US. The EU ban may prevent EU airlines buying hushkitted aircraft, but they were never going to do so anyway in all except a few very small airlines. There are less than 30 hushkitted aircraft in Europe – and in the future there will be even less as they are retired. How will this ban affect resale values of hushkitted aircraft, when there is only a tiny market for them in Europe anyway? Europe, having totally revamped it’s airline fleets with the likes of modern 737s and A320s is unlikely to start purchasing older, hushkitted aircraft in any significant numbers. Let’s not forget, if the aircraft has operated in the EU since 1995 it can still be sold, bough and hushkitted in the EU.
With Europe’s more congested airspace, higher airport density and airports closer to cities the environmental concerns should be regarded as valid. Noise and pollution from aircraft has a daily impact on the lives of millions across the Union every day. The way the US policy on huskitting has operated appears to have forced hushkitting, and help create the problem that now exists. They brought in the stage 2 ban over 2 years ahead of ICAO’s 2002 deadline, 75% of aircraft had to be stage 3 compliant by 1998 etc. This is significant when you consider the 737NG wasn’t available until 1997, and both this and the A320 lines are very busy. This left airlines with little option than to hushkit. By making a short-term gain in noise reduction with hushkitting, the rule has meant there will be many noisier aircraft flying around just under the limits for a good many years where they would otherwise have been replaced by new, much quieter aircraft, as in Europe. US airlines just had huge numbers of stage 2 aircraft, which couldn’t be replaced within the reduced timeframe the USA laid down. European airlines were allowed time to wait for new aircraft to be delivered.
While I’m not saying the EU’s stance isn’t illegal , it probably is, because they’re interpreting the ICAO rules more strictly than were intended, but they do appear good reasons for it – and potential harm to the market for hushkitted aircraft sales appears very small. Plus, aside from any EU rules many airports here make hushkitted aircraft very unwelcome, with large hikes in landing fees that would make it unviable to operate hushkitted aircraft into and out of them.
Sorry about the length of this!