New EAC report says government must provide clarity about its intentions on Heathrow CO2 emissions
The EAC has now published a follow up report to its November 2015 report, after the oral evidence given by Chris Grayling on 30th November. It is highly critical of the government on its assurances that the runway will meet carbon limits. The EAC says: “The Government claims that Heathrow expansion can be delivered within “the UK’s climate change obligations”. The Government has not set out what it means by “obligations”, let alone how it will meet them. It has not decided whether to accept the Committee on Climate Change’s recommendation on limiting emissions from international aviation. It has not decided on whether to follow the CCC’s advice on offsetting. The Airports Commission told us the appropriate body to make recommendations on managing aviation emissions is the CCC. It would not be a credible position for the Government to claim that it can deliver Heathrow expansion within emissions limits whilst rejecting independent advice as to what those limits should be and how they should be met.” … The EAC says though Chris Grayling said told them the Government had not decided whether it intended to work towards the planning assumption [of limiting UK aviation to 37.5MtCO2 by 2050], when asked if he “had consulted other Ministers or sectors over the higher emissions reductions that they might be required to make if the planning assumption was not met. He said he had not yet done so.” And much more ….
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New EAC report Carbon Emissions, Air Quality and Noise Seventh Report of Session 2016–17
23.2.2017
The Environmental Audit Committee (EAC) in the House of Commons has been a key means of holding the DfT, Heathrow and the government to account on the environmental impacts of aviation expansion.
There are reports and associated evidence on all its inquiries, on the EAC website.
In November 2015 the EAC published an interim report on the Airports Commission’s recommendation for airport expansion in the South East of England. In October 2016 the Government announced its support for a third runway at Heathrow, in line with the Commission’s recommendation. The Government has since published a draft Airports National Policy Statement.
The EAC has now published a follow up report to their November 2015 report. It deals with air pollution (including surface access), carbon emissions and noise.
The EAC heard oral evidence from Chris Grayling, the Transport Secretary, and Caroline Low of the DfT, on 30th November 2015.
In the summary of the new report, the EAC say:
“We have seen little evidence so far of the “step change” in the Government’s approach to environmental mitigation which we called for in our interim report. To inform the National Policy Statement process, the Government needs to set out new modelling on air quality following the High Court’s latest ruling and a new approach to air quality post 2019; an emissions reduction strategy that will allow the UK’s carbon budgets to be met and effective noise mitigation measures enforced by an Independent Aviation Noise Authority. The Government must not allow our air quality standards to be watered down as a result of leaving the EU.”
Below are just the sections from the February 2017 EAC report on carbon emissions
The Airports Commission Report Follow-up: Carbon Emissions, Air Quality and Noise Seventh Report of Session 2016–17
23.2.2017
Carbon emissions
There has been no clarity from the Government on carbon emissions. The Government’s headline cost-benefit analysis for Heathrow expansion is based on a hypothetical international framework to reduce emissions which would leave international aviation emissions 15% higher than the level assumed in the Fifth Carbon Budget (2028–2033).
The Government has said Heathrow “can” be delivered within emissions limits but it hasn’t decided or stated what these limits are. It is considering rejecting the Committee on Climate Change’s advice on the limits that should be adhered to and the level of passenger demand which is compatible with those limits. The Government’s revised aviation strategy must set out its approach to reducing emissions, the target it will work to and the measures it will take to close the policy gap between where we currently are and where we will need to be in each carbon budget period to 2050. If the Government does reject the Committee on Climate Change’s advice on aviation emissions it should set out clearly the resulting additional emissions reduction requirements on other sectors of the economy and the resulting costs to those sectors. These assumptions should be tested with industry and subjected to independent scrutiny by the Committee on Climate Change.
Background
46.
In our interim report, we examined the Airports Commission’s analysis of the potential impact of differing carbon policies on the viability of expanding airport capacity in the South East of England. By far the largest climate change impacts come from additional international flights, we have therefore focused on these rather than the mitigation measures proposed in relation to construction and operation.64 We found a significant policy gap between aviation emissions policy as it stood and the measures modelled by the Commission. We noted that, whilst the Airports Commission had modelled various carbon policy scenarios,65 it had not made recommendations on how emissions should be managed. The former Commissioners argued this was for the Committee on Climate Change. We recommended that the Government’s decision on airport expansion should be accompanied by a package of measures to demonstrate a commitment to bringing emissions from international aviation within the economy-wide target set by the Climate Change Act 2008.66
47.
Since our interim report, the Government has legislated for the Fifth Carbon Budget,67 which starts in 2028, but is yet to publish its plan for meeting the Budget. The International Civil Aviation Organisation’s (ICAO) has also agreed a Global Carbon Offsetting and Reduction Scheme (CORSIA).68 The UK has indicated it will participate from the beginning of the scheme in 2021.69
48.In announcing the Government’s decision, the Secretary of State for Transport said “it [Heathrow expansion] can be delivered within carbon […] limits”.70 The draft National Policy Statement document repeats this claim–acknowledging that the Heathrow additional runway scheme generates the most additional CO2, but stating this was not considered a differentiating factor between schemes because “The Airports Commission concluded that any one of the three shortlisted schemes could be delivered within the UK’s climate change obligations, as well as showing that a mix of policy measures and technologies could be employed to meet the Committee of [sic.] Climate Change’s planning assumption”.71 The Government has said it will update its aviation strategy—including on carbon emissions—later this year.72
International Aviation and the Climate Change Act 2008
49.
As set out in our interim report, the Committee on Climate Change and Government are required by the Climate Change Act 2008 to take international aviation emissions into account when setting carbon budgets.73 To do this, the Committee on Climate Change includes “an appropriate planning assumption” into carbon budgets for the purposes of setting contributions from other sectors. This assumes that UK gross74international aviation emissions will be no more than 2005 levels—37.5 MtCO2—in 2050. This is in line with a target set by the then-Government in 2009 and has been described by the CCC as consistent with passenger growth of around 60% over the 2005–2050 period.75 This is less than the carbon reduction targets set for other sectors, such as energy or industry, reflecting the technical challenges of developing non-fossil fuel alternatives for aviation fuel.76
50.
The status of the planning assumption in relation to Government policy has been the source of some confusion during our inquiry. The Secretary of State told us “there is no law of the land that requires us to meet any particular [international aviation emissions reduction] target” and pointed out that the Climate Change Act 2008 does not require international aviation to be included in the carbon budgets.77 However, the planning assumption played a key role in the Airports Commission’s report and was perceived by some of our witnesses, including Heathrow Ltd. itself, to be a Government target.78
51.
The aviation industry also has its own emissions reductions targets, although they are less ambitious than the CCC’s planning assumption which was used by the Government when legislating for the Fifth Carbon Budget. The ICAO agreement aims at a “global aspirational goal of keeping the global net CO2 emissions from international aviation from 2020 at the same level”. The Aviation Environment Federation (AEF) have set out a number of ways in which it falls short of meeting the planning assumption and, as we set out below, it assumes carbon prices lower than those assumed under the Airports Commission’s carbon-traded model.79 Sustainable Aviation published a “CO2 Road Map” in 2012 which aimed to show how the UK aviation industry could “accommodate significant growth to 2050 without a substantial increase in absolute CO2emissions” and reduce net levels to 50% of 2005 levels through internationally agreed carbon trading.80 The planning assumption requires reductions in actual emissions to 2005 levels, as opposed to calculating net emissions after the operation of a carbon trading system, which both the ICAO and Sustainable Aviation focus on.81
52.
Whilst international aviation is not yet included in carbon budgets, other sectors’ contributions have been calculated assuming that the planning assumption for international aviation will be met by 2050. This point was made in a letter from the Chairman of the CCC, Lord Deben, to the Secretary of State for BEIS, Rt Hon Greg Clark MP, following the Government’s announcement on Heathrow. Lord Deben noted that the Government’s headline analysis of the costs and benefits of expansion in its announcement on expansion was based on modelling which assumed the planning assumption would be exceeded by 15% in 2050. Lord Deben observed that exceeding the planning assumption would result in other sectors having to make deeper reductions in their emissions. He said the CCC has “limited confidence” that such reductions could be achieved.82 We also note that the modelling used by the Airports Commission in this scenario assumes the UK’s continued participation in the European Emissions Trading Scheme up to 2030.
53.
The Government intends to set out further details about its approach to aviation emissions in a series of documents to be published later this year.83 Caroline Low said the Government would be looking to put “flesh on the bones” of the Airports Commission’s carbon sensitivity model.84 The Government argued this analysis demonstrates it is possible to meet the planning assumption with a higher rate of passenger growth—80% between 2005 and 2050—than the CCC believes is compatible.85 The Secretary of State said that three elements would make this possible: improvements in aircraft efficiency, biofuels (which the Government has just launched a consultation on) and the ICAO agreement on offsetting.86 In our interim report we noted that current Government policy fell short of meeting some of the assumptions modelled by the Commission in these areas alongside concerns that some of these may not be achievable practically or politically.87
54.
Although the Secretary of State argued that the Airports Commission Report showed it was possible to deliver Heathrow expansion and additional passenger growth whilst still meeting the planning assumption, he did not say that this was necessarily the Government’s intention. He told us that the Government had not decided whether it intended to work towards the planning assumption.88 Nor had the Government decided whether to work towards a target of reducing actual aviation emissions (as recommended by the CCC) or one of reducing net emissions (which would count offset emissions as a reduction).89 We asked whether he had consulted other Ministers or sectors over the higher emissions reductions that they might be required to make if the planning assumption was not met. He said he had not yet done so.90
55.
In its draft National Policy Statement, the Government states that the Airports Commission Report showed “that a mix of policy measures and technologies could be employed to meet the Committee of Climate Change’s [sic.] planning assumption”.91 In our interim report, we identified a “policy gap” between the theoretical measures modelled by the Airports Commission to control aviation emissions and current policy.92 The AEF, in their supplementary evidence, argued that the Government had tacitly accepted the existence of a policy gap in their announcement and had decided to dispense with the planning assumption rather than try to meet it.93 The Secretary of State denied that such a gap existed—citing the Airports Commission’s work and the measures discussed above.94 The draft National Policy Statement states that Heathrow Airport will be expected to take “ambitious measures” to limit carbon emissions, however, as discussed earlier, the main generator of CO2 will be through flights themselves.95
56.
As an example, we asked the Secretary of State about carbon prices. The ICAO envisages a carbon price of between $12 and $40 per tonne in 2035.96 The price modelled by the Commission for 2035—under the carbon-traded scenario which underpins the headline figures in the Government’s announcement and which would miss the planning assumption by 15% in 2050—was £101 per tonne.97 For other scenarios, particularly the carbon-capped scenario in which the planning assumption is met—the price modelled by the Commission was higher.98 We note the uncertainty in carbon price forecasts, and that the price of an emissions allowance in the EU’s Emissions Trading Scheme was around €4.60 when this report was produced. In our interim report we remarked that these “give an indication of the scale of intervention likely to be required” to meet the CCC’s planning assumption.99
57.
In our interim report we noted scepticism from some witnesses that future Governments would be likely to sign up to such prices, although Heathrow Ltd. were confident of their ability to prosper under them.100 In oral evidence, to the Committee in 2015, the former Commissioner, Professor Dame Julia King, agreed that the lower carbon prices–for the carbon traded model–were in line with CCC and Government modelling, but higher prices–those needed to meet the planning assumption–“are such high carbon prices that […] I do not think it is entirely sensible to regard them as in any way real carbon prices.”101 When asked if he could envisage carbon prices reaching those levels the Secretary of State said “The answer is we don’t know [but] the Airports Commission has taken some fairly prudent assessments on this.”102
Non-CO2 Emissions
58.
We asked the Secretary of State whether its upcoming aviation strategy would examine greenhouse gas emissions other than CO2. He said that non-CO2 emissions would be reduced alongside CO2, but “there is no clear scientific basis to look at other emissions and put those at the heart of our strategy”.103 The Assessment of Sustainability says that non-CO2 emissions “are likely to be up to two times the magnitude of the CO2 emissions themselves, but […] cannot be readily quantified due to the level of scientific uncertainty and therefore have not been assessed”.104
Conclusions
59.
The headline cost and benefits figures in the Government’s announcement on Heathrow and the draft National Policy Statement assume a black hole in the 2050 carbon budget that other sectors, such as energy or industry, would have to fill. It also assumes continued participation in the European Emissions Trading Scheme up to 2030, it is imperative that the UK remains within the EUTS or any future European emissions trading scheme. The Government has told us it intends to base its policy on another scenario which incorporates assumptions about the level of passenger demand compatible with managing emissions which are more optimistic than the Committee on Climate Change’s advice. The business case for Heathrow expansions must be assessed against a cost/benefit analysis which uses realistic carbon policy assumptions, in line with the Government’s aviation strategy, and takes account of the resulting impacts on other airports and other sectors of the economy. These must be the headline figures in future Government publications, including the final National Policy Statement.
60.
The Government claims that Heathrow expansion can be delivered within “the UK’s climate change obligations”. The Government has not set out what it means by “obligations”, let alone how it will meet them. It has not decided whether to accept the Committee on Climate Change’s recommendation on limiting emissions from international aviation. It has not decided on whether to follow the CCC’s advice on offsetting. The Airports Commission told us the appropriate body to make recommendations on managing aviation emissions is the CCC. It would not be a credible position for the Government to claim that it can deliver Heathrow expansion within emissions limits whilst rejecting independent advice as to what those limits should be and how they should be met.
61.
The signing of the ICAO agreement is a necessary first step to reducing emissions from international aviation, but it is not sufficient in itself. The Government should reconfirm its intention to participate in this scheme from 2021, which is after the date when the Government intends to have formally completed leaving the EU, urge other major emitters, including the United States, to live up to their commitments to participate from the earliest possible date, and work towards strengthening the agreement during its review periods.
62.
Our interim report noted a significant policy gap between the modelling done by the Airports Commission and meeting the Committee on Climate Change’s advice on aviation emissions. The Committee on Climate Change has repeatedly urged the Government to draw up an emissions reduction strategy for aviation. The ICAO agreement means the Government no longer has any excuse not to do so. In the absence of concrete policy proposals from Government, we cannot assess whether the additional emissions from additional flights to and from Heathrow can be properly mitigated. Expanding Heathrow without drawing up such a strategy would, therefore, be putting the cart before the horse.
63.
The Government’s aviation strategy should be integrated with the cross-Government emissions reduction plan. It should set out costed policies to either meet the Committee on Climate Change’s planning assumption or to make up the shortfall from other sectors. This decision will have to take account of the limited progress towards decarbonisation outside the energy sector and the likely additional climate change impact of some non-CO2 emissions. Where the Government makes assumptions that are more optimistic than the Committee on Climate Change’s advice it should subject those assumptions to independent scrutiny from industry and the CCC and, if necessary, revise its plans accordingly. This strategy should be available well before the end of the scrutiny period for the draft National Policy Statement and consultation on it should be completed before the National Policy Statement is finalised.
Conclusions and recommendations document at
https://www.publications.parliament.uk/pa/cm201617/cmselect/cmenvaud/840/84008.htm
Carbon Emissions
9. We reiterate that we foresee legal and commercial risks down the line if clear responsibilities and accountability for meeting air quality targets are not set out at the beginning of the process. For example, Heathrow have said there will be “no more cars on the road” as a result of expansion. (Paragraph 45)
10. There needs to be clarity over how this pledge will be delivered and monitored, the consequences if it is not met and the implications of that for local authorities’ responsibilities to deliver air quality compliance. (Paragraph 45)
11. The headline cost and benefits figures in the Government’s announcement on Heathrow and the draft National Policy Statement assume a black hole in the 2050 carbon budget that other sectors, such as energy or industry, would have to fill. It also assumes continued participation in the European Emissions Trading Scheme up to 2030, it is imperative that the UK remains within the EUTS or any future European emissions trading scheme. The Government has told us it intends to base its policy on another scenario which incorporates assumptions about the level of passenger demand compatible with managing emissions which are more optimistic than the Committee on Climate Change’s advice. (Paragraph 59)
12. The business case for Heathrow expansions must be assessed against a cost/benefit analysis which uses realistic carbon policy assumptions, in line with the Government’s aviation strategy, and takes account of the resulting impacts on other airports and other sectors of the economy. These must be the headline figures in future Government publications, including the final National Policy Statement. (Paragraph 59)
13. The Government claims that Heathrow expansion can be delivered within “the UK’s climate change obligations”. The Government has not set out what it means by “obligations”, let alone how it will meet them. It has not decided whether to accept the Committee on Climate Change’s recommendation on limiting emissions from international aviation. It has not decided on whether to follow the CCC’s advice on offsetting. The Airports Commission told us the appropriate body to make recommendations on managing aviation emissions is the CCC. It would not be a credible position for the Government to claim that it can deliver Heathrow expansion within emissions limits whilst rejecting independent advice as to what those limits should be and how they should be met. (Paragraph 60)
14. The signing of the ICAO agreement is a necessary first step to reducing emissions from international aviation, but it is not sufficient in itself. (Paragraph 61)
15. The Government should reconfirm its intention to participate in this scheme from 2021, which is after the date when the Government intends to have formally completed leaving the EU, urge other major emitters, including the United States, to live up to their commitments to participate from the earliest possible date, and work towards strengthening the agreement during its review periods. (Paragraph 61)
16. Our interim report noted a significant policy gap between the modelling done by the Airports Commission and meeting the Committee on Climate Change’s advice on aviation emissions. The Committee on Climate Change has repeatedly urged the Government to draw up an emissions reduction strategy for aviation. The ICAO agreement means the Government no longer has any excuse not to do so. In the absence of concrete policy proposals from Government, we cannot assess whether the additional emissions from additional flights to and from Heathrow can be properly mitigated. Expanding Heathrow without drawing up such a strategy would, therefore, be putting the cart before the horse. (Paragraph 62)
17. The Government’s aviation strategy should be integrated with the cross-Government emissions reduction plan. It should set out costed policies to either meet the Committee on Climate Change’s planning assumption or to make up the shortfall from other sectors. This decision will have to take account of the limited progress towards decarbonisation outside the energy sector and the likely additional climate change impact of some non-CO2 emissions. Where the Government makes assumptions that are more optimistic than the Committee on Climate Change’s advice it should subject those assumptions to independent scrutiny from industry and the CCC and, if necessary, revise its plans accordingly. This strategy should be available well before the end of the scrutiny period for the draft National Policy Statement and consultation on it should be completed before the National Policy Statement is finalised. (Paragraph 63)
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See the EAC report
- Read the report summary
- Read the report conclusions and recommendations
- Read the full report: The Airports Commission Report Follow-up: Carbon Emissions, Air Quality and Noise
The Environmental Audit Committee, chaired by Mary Creagh, heard oral evidence from Chris Grayling, and Caroline Low (Dft) on 30th November.
“The Airports Commission Report: Carbon Emissions, Air Quality and Noise, HC 840 Wednesday 30 November 2016
Members present: Mary Creagh (Chair); Peter Aldous; Caroline Ansell; Glyn Davies; Caroline Lucas; Mr Gavin Shuker.
Questions 1 – 133 Witnesses: Rt Hon Chris Grayling MP, Secretary of State for Transport, and Caroline Low, Director of Airport Capacity, Department for Transport.
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