Report for the CCC recommends not only a levy on number of flights someone takes, but their length (and seat class)
A report written by Dr Richard Carmichael from Imperial College London, for the Committee on Climate Change, sets out several important recommendations on how to reduce the demand for, and the carbon emissions from, air travel. One recommendation is to impose a frequent flyer levy, that not only takes account of the number of flights a person takes in a year, but the distance travelled (and thus the carbon emitted). This should also include class of ticket bought, as premium classes cause the emission of much more carbon than economy seats. The levy would help discourage long-haul flights: as most flying is for leisure, some shift from long-haul to short-haul destinations would be expected, delivering further emissions reductions. Averaging-out flying habits over a longer period than one year would also be fairer: a 3-4-year period, for example, could mean a traveller could take a long-haul trip without incurring a substantial levy if they took few other flights during the rest of the period. The complexity of administering this levy need not be onerous, though would need a central database storing total miles flown in the accounting period under a passport number.
Behaviour change, public engagement and Net Zero
A report for the Committee on Climate Change
By Dr Richard Carmichael
Centre for Energy Policy and Technology (ICEPT) and
Centre for Environmental Policy (CEP) Imperial College London
Below is just the section dealing with aviation:
2.4 Aviation demand
The number of passengers flying, miles flown, number of flights and emissions are all rising (CCC, 2018). Forecasts indicate that demand for aviation will continue to grow in the period to 2050. Under the CCC’s Further Ambition Net Zero scenario, allowing for a 60% increase in aviation demand from 2005 levels (25% from present levels), this sector will by 2050 account for around 30% of the remaining positive UK emissions. There is a risk, however, of larger increases in demand for flying, with estimates of up to 127% for long-haul (DfT, 2017).
Sensitivity about pricing annual holidaymakers out of the sky has discouraged greater taxation on flights and policy has not addressed rising aviation demand. However, well-designed fiscal measures could offer effective, fair and publicly acceptable means to confront the risk of unrestrained growth in demand in the absence of alternative low-carbon aviation technologies. Fairness and how impacts are distributed are of key importance to public acceptability of policy in general (IPCC, 2018) and will be especially important for aviation.
If averaged over all households, UK aviation now makes up around 12% of a household’s carbon footprint. However, emissions from flying vary enormously between households. While the average household’s annual carbon footprint is approximately 8.1 tonnes (CCC, 2016a) return flights from London to Los Angeles for two people have a carbon footprint of approximately 5.7 tonnes CO2e for Economy Class and over 9 tonnes CO2e for Premium Economy. The emissions from one return ticket from London to New York are roughly equivalent to that of heating a typical home in the EU for a whole year (European Commission, 2019).
Seventy per cent of flights are for leisure and three quarters of this air travel is by members of the ABC1 social classes (Hopkinson, Sloman, Newson and Hiblin, 2019). While half of the UK population do not fly at all in any given year, it is estimated that 70 per cent of flights are taken by just 15 per cent of the population (DfT, 2014). There is a finite budget of carbon emissions allowable if global warming is to be held below 1.5 degrees so this highly uneven distribution of emissions due to flying raises equity concerns.
The greatest beneficiaries of aviation’s generous tax treatment in the UK (it is exempt from fuel duty and zero-rated for VAT) are therefore those who pollute most and could most easily afford to pay more. The norm of unlimited flying being acceptable needs to be challenged and, as a very highly-polluting luxury, it is suitable to taxation.
Suggestions have been made to replace the Air Passenger Duty with a Frequent Flyer Levy (Devlin and Bernick, 2015; Fellow Travellers, 2015; Hopkinson et al., 2019). Given the small number of frequent fliers, most of the population would be unaffected by the levy and families would not be penalised for an annual holiday in the sun.
Frequent flyers, who strongly tend to be wealthier and less price-sensitive, would incur increasingly powerful taxation to discourage additional flights. A levy which escalates in line with excessive flying behaviour would be less regressive than a simple carbon tax on flying (e.g., via aviation fuel tax) as instead of all passengers being equally exposed to the same tax per mile on all flights, those flying infrequently would pay less for the same flight than those flying frequently. At least some of the revenue from the levy could be directed towards research into lower-carbon aviation technology, further increasing the levy’s acceptability and helping to tackle this hard-to-decarbonise sector.
A recent UK survey found that people prefer a Frequent Flyer Levy over other potential policy options and over doing nothing: 56% agreed that a levy on frequent flyers would be fair, while only 26% felt it would be unfair (10:10 Climate Action, 2019).
However, a frequent flyer levy based on number of flights could fall more heavily on travellers who take several short-haul flights than those talking fewer but much more damaging long-haul flights: a flight from London to Melbourne Australia has approximately 15 times the impact of a London-toBarcelona flight.
An alternative replacement for the Air Passenger Duty which should be considered and explored is an Air Miles Levy which escalates with air miles travelled rather than simply the number of flights taken. It should also factor in the much larger emissions for First Class tickets which can have 7 times the emissions of an economy ticket (Murray et al., 2019) due to more spacious cabins and more unfilled seats.
By factoring-in distance, the levy would be more closely linked to emissions and fall more heavily on those polluting more. It would also more effectively discourage long-haul flights: as most flying is for leisure, some shift from long-haul to short-haul destinations would be expected, delivering further emissions reductions.
Averaging-out flying habits over a longer period than one year would also be fairer: a three or four-year period, for example, could mean a traveller could take a long-haul trip without incurring a substantial levy if they took few other flights during the rest of the period.
Travel for work should be kept separate from personal allowances and the 3-year cycle should be based on travellers’ dates of birth, rather than calendar year or tax year, to prevent distorting demand at the beginning and end of these periods.
The complexity of administering this levy need not be onerous, though would need a central database storing total miles flown in the accounting period under a passport number.
Flight-booking software would need to access this database to calculate flight cost and to update the air miles total on central database once the flight is paid for. The class of passenger tickets would also need to be recorded and it would be desirable to add a calculation reflecting the carbon intensity of the flight or ticket; this could go some way towards encouraging improvements in fuel efficiency per passenger.
Finally, data on the distribution within society of flying behaviour appears to be limited, so a database for an Air Miles Levy could also give Government accurate and up-to-date data for designing future policy for aviation demand and monitoring its impacts.
Flying is a uniquely high-impact activity and is the quickest and cheapest way for a consumer to increase their carbon footprint. An air miles levy is a promising option if policy objectives are to: limit rising demand for flying in a way which does not make it inaccessible to lower-income households; encourage shift in demand from flying to trains and from long-haul to short-haul; and generate funds for lower-impact aviation and improving high-speed rail networks. Given the scope for frequent flyers to have carbon footprints many times that of the average UK household, a lack of policy in this area is likely to be increasingly seen as inconsistent and unjust and risks damaging public engagement with climate action.
There is also evidence that mobility can be induced, or fulfil purposes other than transport needs. For instance, as much as 60% of Low-Cost-Carrier (LCC) demand may be stimulated by low prices. Evidence also suggests that frequent flyers engage in additional flights to maintain their privileged traveller status (so-called ‘mileage runs’ or ‘status runs’) and that frequent flying is related to status and social identity (Gössling and Cohen, 2014). Introducing restrictions to ‘all-you-can-fly’ passes and loyalty schemes which offer air miles would remove incentives to excessive or stimulated flying.
Advertising and marketing of holiday destinations and airlines also stimulate demand for flying and help set norms and aspirations about flying. Advertising and packaging for alcohol and tobacco has long been tightly controlled in view of their health risks, and gambling marketing must warn about irresponsible betting.
More responsible flying could also be encouraged by new regulations for the marketing and promotion of flights and holiday destinations by requiring that carbon footprints of flights are stated in the advertising material. This could raise awareness and begin to change the norm of unproblematic unlimited flying.
• Introduce an Air Miles Levy which escalates as a function of air miles travelled by the individual traveller and factors-in larger emissions for First Class tickets. This would provide strong price signals against excessive flying by 15% of the UK population responsible for 70% of flights without raising prices for other travellers as an aviation fuel tax would. It would also encourage shifting from long-haul to short-haul leisure destinations while using 3 or 4- year accounting periods would allow travellers greater flexibility for an occasional long-haul flight without incurring the levy
• Introduce a ban on air miles and frequent flyer loyalty schemes that incentivise excessive flying (as was enforced in Norway 2002-13).
• Encourage more responsible flying by mandating that all marketing of flights show emissions information expressed in terms that are meaningful to consumers (e.g., as proportion of an average household’s annual emissions now and under Net Zero).
2.4.1 Work-related flying
Business travel accounts for approximately 19% of flights and has declined as a proportion of flights, mostly due to growth in flights for leisure (DfT, 2017). A separate scheme to the Air Miles Levy will also be needed for business travel in order to avoid loopholes or gaming the system. Also, over a third of business passengers travel first or business class, compared with only 1 in 17 leisure (POST, 2000) and these classes of tickets are associated with much higher emissions due to the larger space taken up onboard and more unfilled seats.
Tele-conferencing and telepresence technologies offer an alternative to some work-related travelling and measures to promote these alternative ways of working and doing business could deliver economic savings and benefits for well-being as well as emissions reductions. For institutions with employees flying frequently, match-funded financial support could be provided for the installation of video-conferencing/tele-presence suites. Funding for venues to install facilities for hosting ‘nodal conferences’ (where a conference is distributed over numerous sites around the globe) or fully ‘distributed meetings’ (Le Quéré et al., 2015) could also be piloted. Such investments and new practices would contribute to shifting norms and workplace cultures towards alternatives to physical meetings and work-related travel, and should also stress other benefits, such as improved accessibility (Ibid).
It is well-established that making the positive behaviour of others more visible can increase wider engagement in low-carbon behaviour (Schultz, Nolan, Cialdini, Goldstein and Griskevicius, 2007). Among academics for example, survey data has found over 80% would support an organisation-wide policy to reduce flying (Le Quéré et al., 2015). Other surveys suggest there is an ‘appetite for leadership’ and that high profile individuals reducing or giving up flying appears to contribute to changing norms and a collective effort to reduce flying (Westlake, 2018). Funding could be made available for the development and introduction of ICT systems which monitor and make more transparent work-related flying behaviour, avoided flying, and the use of alternatives in order to help to make visible others’ efforts to minimise flying.
• Provide match-funded financial support to institutions (with employees flying frequently) for the installation of video-conferencing/tele-presence suites.
• Funding for venues to install facilities for regional hosting of nodal conferences and fully distributed meetings offering an alternative to physically attending conferences/meetings.
– Summary of recommendations (re. air travel)
• Introduce an escalating Air Miles Levy to discourage excessive flying by the 15% of the UK population estimated to be responsible for 70% of flights. Unlike a fuel tax, this would provide strong price signals for frequent flyers without raising prices for people taking an annual holiday. It would also encourage shifting from long-haul to short-haul leisure destinations while 3 or 4-year cycles would allow travellers greater flexibility for long-haul. The levy should also factor in the much larger emissions for Business and First Class tickets.
• Introduce regulation to ban frequent flyer reward schemes that stimulate demand.
• Raise awareness and encourage more responsible flying by mandating that all marketing of flights show emissions information expressed in terms that are meaningful to consumers.
See full report at