Aviation Environment Federation sets out 3 main gaps in the Airports Commission’s assessment of CO2 from UK aviation with a new runway
In the rush to build a new runway in the south east, the vital issue of whether or not a new runway would be compatible with national climate change commitments has been largely overlooked. The Airports Commission gives the impression that the issue has been fully considered. In fact, it has not. The AEF has set out 3 simple points on which the Commission needs to answer questions – and which people writing responses to the consultation should include. These relate to the accuracy of CO2 forecasts; the lack of any policies to build a runway and still keep UK aviation CO2 down to the required level; and the lack of any assessment of how much less of an economic benefit a runway might be, if the carbon was properly factored into the calculations. AEF suggests raising these. On forecasts, the Commission should “Explain why its CO2 emissions forecasts are lower than the Government’s latest forecasts, what assumptions are made and how sensitive to the results are to them.” On policy it should: “Set out in meaningful detail what policy developments would be required in order to limit emissions to the aviation cap while building new capacity.” And on cost-benefit it should “Fully include the economy-wide cost of keeping national aviation emissions to within 37.5 Mt in its cost benefit analyses.”
The carbon gap in the Airports Commission’s new runway analysis
A key issue in the airport expansion debate is whether or not a new runway would be compatible with national climate change commitments. The Airports Commission gives the impression that the issue has been fully considered, but in fact a number of questions remain to be answered.
We have three major concerns about the Commission’s approach to analysing the climate change implications of airport expansion. Below each issue we have given our recommendations of what the Airports Commission needs to do before publishing its final report. We would urge everybody responding to the Airports Commission’s consultation, which closes on the 3rd February, to include our three recommendations in their response to questions 4, 5 or 6.
Issue one: Forecasts
The Airports Commission has produced its own forecasts of carbon dioxide emissions from aviation that are lower than official forecasts from the Department for Transport.
No explanation has been provided for the discrepancy, which applies both to national level forecasts of aviation and to the anticipated (no new runway) ‘baseline’ emissions for Heathrow and Gatwick. As a result, we are concerned about the reliability of the Commission’s forecasts of emissions from a new runway.
What the Airports Commission should do: Explain why its CO2 emissions forecasts are lower than the Government’s latest forecasts, what assumptions are made and how sensitive to the results are to them
Issue two: policies to reduce emissions
Even with lower emissions forecasts, the Airports Commission’s own work has shown that building a new runway would be inconsistent with UK climate change commitments unless new, unspecified action was taken by Government to cap aviation emissions.
The sustainability assessment for each short-listed scheme predicts that national aviation emissions would be higher than the level consistent with the Climate Change Act if the runway scheme proceeds, even if aviation is included in a carbon trading scheme.
The Commission has claimed that working out what additional policy action would be needed to limit emissions (new taxes or planning restrictions on other airports, for example) is outside its remit, as is, indeed, assessing the likelihood that even carbon trading policies will be successfully extended to cover aviation.
What the Airports Commission should do: Set out in meaningful detail what policy developments would be required in order to limit emissions to the aviation cap while building new capacity
Issue three: Economic analysis
The economic analysis of the shortlisted expansion options does not include the economic costs of restraining greenhouse gas emissions from UK aviation to a level compatible with the Climate Change Act.
The Committee on Climate Change, the Government’s official climate advisers, told the Airports Commission in an open letter in 2013:
“Given the need to limit aviation demand growth in a carbon constrained world, we recommend that this should be reflected in your economic analysis of alternative investments. For example, for each investment, you should assess whether this would make sense if demand growth were to be limited to 60% by 2050.“
The Commission has not completed this analysis, citing technical difficulties and the fact that the carbon component (costs associated with restraining emissions) “would dominate the capacity appraisals”. The Airports Commission’s estimates of the economic benefits that would arise from each its shortlisted schemes are therefore misleadingly high. The admittance by the Airports Commission that it has not included the ‘carbon costs’ in its economic analysis is in an paragraph on page 25 of the consultation document.
What the Airports Commission should do: Fully include the economy-wide cost of keeping national aviation emissions to within 37.5 Mt in its cost benefit analyses, in line with the recommendations of the Committee on Climate Change. This analysis should be presented prominently in the final report.
Background information from AEF on the importance of climate change in the airport expansion debate is available to download here.
How to respond to the Airports Commission consultation
Responding to the Airports Commission final consultation on a possible new runway
As well as the main consultation document, there are over 55 technical documents, with supporting detail.
It is therefore almost impossible for most people to read all these. In order to help people to make a response, without needing to set aside a week or so of their lives to do so, both HACAN at Heathrow, and GACC at Gatwick, have given guidance on how a simple consultation response can be written.
Responses don‘t have to be long, or technical. Just write your views.
1. First, here are links to the main documents:
The main consultation
The main consultation documents(the consultation document itself, documents on two Heathrow and on Gatwick runway options) https://www.gov.uk/government/consultations/increasing-the-uks-long-termaviation-capacity
The large number of technical supporting documents https://www.gov.uk/government/collections/additional-airport-capacity-consultationsupporting-documents
2. Second, how to actually send in a response:
Responses should be e-mailed to: email@example.com
or by the online form at http://www.smartsurvey.co.uk/s/134578HXHDU
you should get an acknowledgement
Responses can also be submitted by post to:
Airports Commission Consultation
PO Box 1492WokingGU22 2QR
you will not get an acknowledgement
Copy in your elected (and even prospective parliamentary candidates) so they are aware of your views.
The findings of the Commission‘s consultation will be published in a consultation report. This report will include details of the number of responses received and the key topics, points and themes that the consultation generated. The report will alsocontain details of the framework used to analyse the responses.
The Commission will also publish all substantive, technical responses it has received. All these will be published alongside the publication of the Commission‘s final report, due in the summer of 2015.
3. Third, documents from HACAN and from GACC to help with responses:
Heathrow:Airports Commission consultation explained
Heathrow:Consultation Special – guidance on how to respond to the consultation
10 reasons to oppose a 3rd runway: http://hacan.org.uk/10-reasons-to-oppose-a-3rd-runway/
Gatwick: The Runway Facts
Gatwick Unwrapped -A critical examination of the plansfor a 2nd runway at Gatwick