Draft Aviation Policy Framework – Climate Change

Date added: 1 October, 2012

The section on Climate Change is Pages 37 – 47

The only questions on this section are:

6. Do you have any further ideas on how the Government could incentivise the aviation and aerospace sectors to improve the performance of aircraft with the aim of reducing emissions?

7. Do you have any other comments on the approach and evidence set out in Chapter 3?

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Climate Change

AirportWatch view, in summary:

Chapter 3: Climate Change

The Government needs to use all the tools it has available to tackle climate change from aviation. It cannot rely solely on “cleaner” technology, the EU Emissions Trading System and the Single European Sky Agreement to guarantee emissions will fall sufficiently.

It also needs to bring in clear targets by including aviation in its carbon budgets and to endorse the target of cutting aviation emissions to at least their 2005 level by 2050.It makes no sense for one of the dirtiest industries on the planet to receive the tax breaks it does.

It simply creates an artificial demand for the product. We appreciate that international action is required to deal with tax-free fuel but the Government should commit itself to leading an international campaign to remove the barriers to taxing aviation fuel.

The statement that rail and video conferencing are important alternatives to flying, and particularly short-haul flights, is welcome. But affordable and attractively-priced fares are also essential if rail is to fulfill its potential

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Further comments made by AirportWatch members:

Chapter 3: Climate Change

6. Do you have any further ideas on how the Government could incentivize the aviation and aerospace sectors to improve the performance of aircraft with the aim of reducing emissions?

Aviation accounts for at least 13% of theUK’s greenhouse gas emissions (if radiative forcing is included – about 6.5% without it) and the proportion is growing. The Committee on Climate Change (CCC): the Government advisors, recommended emissions from aviation should be back at their 2005 levels by 2050. This is a challenging target, but less so than for other sectors of the economy. But the aviation industry is greedy – if it were to grow as much as it wants to, alone it will account for 25% of the UK’s emissions – leaving every other sector struggling to meet their targets.

The Government needs to use all the tools it has available to tackle climate change from aviation. The Government cannot rely solely on “cleaner” technology, the EU Emissions Trading System and the Single European Sky Agreement to guarantee emissions will fall sufficiently. It also needs to bring in clear targets by including aviation in its carbon budgets and to endorse the target of cutting aviation emissions to at least their 2005 level by 2050.

Question 6. . Do you have any further ideas on how the Government could incentivize the aviation and aerospace sectors to improve the performance of aircraft with the aim of reducing emissions?

The Government’s focus should be upon providing a clear framework for controlling aviation emissions, consistent with its commitment to be the ‘greenest government ever’, and not upon subsidizing R&D in the aviation and aerospace sectors with the objective of reducing aircraft emissions. In any event, this objective is essentially the same as improving aircraft fuel efficiency and so it is very much in the industry’s own commercial interests to invest in this type of R&D.

Moreover, the Government should re-affirm the commitment made in January 2009 by the previous Government to limit UK aviation emissions to below 2005 levels by 2050. This would mean a fixed budget of 37.5m tonnes of CO2 p.a. for the aviation industry and so provide an added incentive to improve the emissions performance of aircraft because the industry would not be able to grow except to the extent that the emissions performance of aircraft improved.

The other key element of this framework is for the Government to accept the CCC recommendation to bring aviation emissions into the UK’s national carbon budgets from 2016 onwards.

Aviation’s non-CO2 effects also need to be brought under control. Research by Lee et al (2009) indicates that aviation is responsible for 4.9% of global greenhouse gas (‘GHG’) emissions. There remains some uncertainty regarding the precise effect on the climate of aviation’s non-CO2 emissions but this should not be an excuse for ignoring their impact.

Present scientific knowledge indicates that the CO2 effect should be multiplied by a factor of 2 in order to allow for the non-CO2 effects. Some suggest that the multiplier should be higher; the IPCC (1999) estimated aviation’s non-CO2 climate effects to be about 2 to 4 times greater than the effects of CO2 alone, suggesting a mid-range value of 2.7 for 1992 and a range of 2.2 to 3.4 for 2050 (not allowing for the effects of contrails).

Since the best scientific estimate presently available suggests a multiplier of 2, and since this does not allow for the effects of contrails, it is the minimum multiplier which should be used.

Industry claims are invariably more optimistic than the figures produced by independent studies so it is surprising that the DfT has accepted the assertions of IATA and Airbus regarding the industry’s progress on improving fuel efficiency (para 3.31).

Statistics provided to the House of Commons on behalf of the Secretary of State in 20098 showed a strong correlation between aviation CO2 emissions and passenger numbers with only a 12% reduction in fuel consumption per passenger fuel efficiency gains were being offset by an increasing proportion of long haul flights, a trend which is likely to continue.

The CCC estimates 0.8% annual improvement in industry fuel efficiency to 20509 and we would urge the DfT to use this independent evidence base, rather than relying upon optimistic industry projections, when developing its sustainable aviation policy framework.

Question 6. Do you have any further ideas on how the Government could incentivize the aviation and aerospace sectors to improve the performance of aircraft with the aim of reducing emissions?

In any event, this objective is essentially the same as improving aircraft fuel efficiency and so it is very much in the industry’s own commercial interests to invest in this type of R&D.

Moreover, the Government should re-affirm the commitment made in January 2009 by the previous Government to limit UK aviation emissions to below 2005 levels by 2050.

This would mean a fixed budget of 37.5m tonnes of CO2 p.a. for the aviation industry and so provide an added incentive to improve the emissions performance of aircraft because the industry would not be able to grow except to the extent that the emissions performance of aircraft improved. The other key element of this framework is for the Government to accept the CCC recommendation to bring aviation emissions into the UK’s national carbon budgets from 2016 onwards.

Aviation’s non-CO2 effects also need to be brought under control. Research by Lee et al (2009) indicates that aviation is responsible for 4.9% of global greenhouse gas (‘GHG’) emissions.

There remains some uncertainty regarding the precise effect on the climate of aviation’s non-CO2 emissions but this should not be an excuse for ignoring their impact.

The DfT has, in the past, variously used multipliers of 1.9 and 2.0 to try to take account of aviation’s non-CO2 climate effects but DfT now seems to be saying that aviation’s non-CO2 effects should be disregarded until there is better scientific understanding. This would lead to a grossly misleading underestimate of aviation’s overall impact on climate change. Since the best scientific estimate presently available suggests a multiplier of 2, and since this does not allow for the effects of contrails, it is the minimum multiplier which should be used.

The targets announced by ICAO and IATA for reducing aircraft emissions referred to in the DAPF are welcome but these are purely aspirational, not binding commitments, and, looking at the track record of these organizations, we are not led to expect much in terms of positive achievement. Industry claims are invariably more optimistic than the figures produced by independent studies so it is surprising that the DfT has accepted the assertions of IATA and Airbus regarding the industry’s progress on improving fuel efficiency (para 3.31).

Statistics provided to the House of Commons on behalf of the Secretary of State in 2008 showed a strong correlation between aviation CO2 emissions and passenger numbers with only a 12% reduction in fuel consumption per passenger. Ffuel efficiency gains were being offset by an increasing proportion of long haul flights, a trend which is likely to continue.

The CCC estimates 0.8% annual improvement in industry fuel efficiency to 2050 and we would urge the DfT to use this independent evidence base, rather than relying upon optimistic industry projections, when developing its sustainable aviation policy framework.

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It is essential, in whatever steps Government may choose to take, that there is no move to replace atmospheric pollution by noise pollution, whether through “direct routings” which redirect aircraft over populated areas, or through introduction of “open rotor” engine technology unless this can be independently verified as being less polluting in both noise and atmospheric terms.

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The Government should rigorously pursue opportunities to reduce greenhouse gas emissions from air transport through work at an international level. The UK should be seen as a leader in seeking international agreements. At a national level the Government should look to incentivise reductions in greenhouse gas emissions but should not look to adopt unilateral measures which would significantly undermine the UK’s international trading role.

The measures identified in Chapter 3 regarding efforts to improve the performance of aircraft with the aim of reducing emissions are supported. The proposed new powers for the Civil Aviation Authority regarding improved public information on the environmental effects of civil aviation will help raise awareness amongst the industry and air passengers, and will establish benchmarks against which progress can be measured.

[We] welcome the Government’s recognition that further detailed analysis of aviation’s non carbon dioxide emission impacts is needed in order to provide a more consistent analysis of the impacts of policy measures.

Question 7. . Do you have any other comments on the approach and evidence set out in Chapter 3?

The DAPF considers the potential for biofuels (para 3.36) and concludes that a better understanding is required of the issues involved before any judgment can be made on the way forward. We broadly agree with this conclusion because very considerable doubts remain concerning the supply of biofuels, competition with land transport, their cost and efficiency and the fact that they will still emit GHGs. The CCC also considered the use of biofuels for aviation fuel and concluded that ‘it [would not be] prudent to assume that biofuels in 2050 could account for more than 10% of global aviation fuel’. Again, we would urge the DfT to take careful note of the CCC’s independent conclusions.

The EU Emissions Trading System (‘ETS’) may in the future become a valuable tool for constraining carbon emissions. Aviation has only been included in the system since January 2012 and has been given preferential treatment compared to other sectors in that its limits are based on 2004-06 average emission levels rather than the 1990 levels that apply to all other sectors. In addition, generous allocations of permits within the EU ETS and the methods for offsetting have meant that the carbon price has stayed extremely low and the system has done nothing to reduce aviation emissions. Another shortcoming is that the ETS does not take aviation’s non-CO2 emissions into account.

“Aviation is… likely to make up an increasing proportion of the UK’s total GHG emissions as other sectors decarbonise more quickly over time.”

(Draft aviation policy, section 3.1).

Question 7. Do you have any other comments on the approach and evidence set out in Chapter 3?

The DAPF considers the potential for biofuels (para 3.36) and concludes that a better understanding is required of the issues involved before any judgment can be made on the way forward. We broadly agree with this conclusion because very considerable doubts remain concerning the supply of biofuels, competition with land transport, their cost and efficiency and the fact that they will still emit GHGs. The CCC also considered the use of biofuels for aviation fuel and concluded that ‘it [would not be] prudent to assume that biofuels in 2050 could account for more than 10% of global aviation fuel’. Again, we would urge the DfT to take careful note of the CCC’s independent conclusions.

Question 7. Do you have any other comments on the approach and evidence set out in Chapter 3?

We fully support efforts to achieve global agreement on aviation emissions and are actively participating in the UN discussions on this.

Alongside this, we support aviation’s inclusion in the EU Emissions Trading System as a first step towards bringing the sector into line with climate goals.
In the UK, aviation must be included in the Climate Act and carbon budget.
The Government must be realistic about the part that aviation will need to play in achieving long term emissions reductions. The Committee on Climate Change states that the Government’s vision for UK aviation should be based on the assumption that actual UK aviation emissions (without trading) will be no higher in 2050 than in 2005; they are currently forecast to be much higher than this. AEF believes that even this level of aviation emissions would be unjustifiably high.

If there is one area in which the Government could adopt a clear and unequivocal environmental target in relation to aviation it is climate change. The last government, while approving in principle a third runway at Heathrow, said that this would go ahead only if it proved compatible with a national emissions cap for the aviation sector.

Separately, the Committee on Climate Change – the Government’s official advisory body – has recommended that aviation should in future be included in the UK’s carbon budgets. The draft policy, however, declines to give a view on either of these possible approaches to bringing aviation into line with UK climate change policy instead talking up our involvement in global talks on aviation emissions.

Part of the reason for this relies on a faulty logic that conflates where emissions take place with where the solutions are agreed. “Flights departing from UK airports to international destinations account for about 95 per cent of UK aviation emissions”, notes the draft paper, “so measures to tackle CO2 emissions from UK aviation need bilateral or multilateral agreement.”

But just as in the UK we impose our own security measures on both UK and international passengers travelling overseas, so there is no reason why we can’t define our own stance on limiting the growth of UK aviation emissions. It is worth noting that the Government fully supports aviation’s inclusion in the EU Emissions Trading System (EU ETS), even though this imposes charges for emissions in relation to the whole of a journey – not just those in UK or EU airspace.

A second reason for focusing on international measures, the policy suggests, is cost; the EU ETS – a market-led solution in which permits can be bought and sold – is presented as a more economically efficient way of reducing emissions than imposing sector-specific targets.

The problem, however, as highlighted by the advice of the independent Committee on Climate Change in relation to aviation, is that if too many sectors assume that they will be able to continue buying permits rather than making their own emissions reductions one of two things will happen: either the permits will become extortionate as demand rises, companies will fail and infrastructure will lie abandoned, or political pressures will conspire to weaken the terms of the EU ETS. Neither option looks attractive.

For the EU ETS to work, and for international efforts to agree on emissions curbs (efforts we are ourselves engaged in) to succeed, politicians must plan for the future and accept that aviation won’t be able to keep buying cheap emissions permits for very much longer.

Ruling out a third runway at Heathrow for this term in Government is no substitute for putting in place the right long-term conditions to frame future capacity decisions. Just as we can’t leave bankers to run the economy, we can’t rely on carbon traders to tackle climate change.

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Question 7. Do you have any other comments on the approach and evidence set out in Chapter 3?

It has been very convenient for the aviation industry, which is uniquely polluting in global warming terms through its injection of pollutants at high level in the atmosphere, that experts cannot decide whether the net global warming effect is twice, 2.7 times or 4 times that of generating the same quantity of carbon-based fuel at ground level. One authoritative estimate[1] put the multiplier value at 2.7, and later EU survey work[2] accepted such a value as a good and sustainable estimate. However, the ball remains in the long grass and, as a consequence, there is no consensus on whether and how to mitigate them nor any attempt so to do. Until such agreement is reached the industry and its associates in the biofuel industry can continue to claim that bio-jet fuel is carbon-free, “green” etc.

Independent analysis[3] points out the ineffectual nature of carbon trading in reducing the real impact of aviation’s emissions. Carbon trading etc. is, in effect, little better than buying indulgences and in such a way that aviation’s emission growth is funded by increasing the costs of energy to other consumers. Nowhere in the consultation document is there any reference to the most effective way of reducing emissions (and noise) – making fewer flights by managing both demand and supply.

It is worth noting that should the government decide to build a new airport for London, perhaps in the Thames Estuary, it would enable airlines to plan for the long term as well as supporting potential future growth in air passenger capacity. Such a strategic initiative would include the following benefits: it would support employment in the short, medium and longer term; be a shorter distance to European destinations with the balance of the journey into the UK more probably being undertaken by high-speed (less polluting) train; reduce flight departure and arrival delays. The benefits would be through reduced air and noise pollution over urban areas, reduced plane holding patterns saving fuel, and most probably reduction of car travel to the airport, thereby supporting increased use of public transport. This may have a dramatic effect in reducing car travel to and from existing London airports.

[1] IPCC (1999)

[2] EU TRADEOFF survey (2005)

[3] “Predict and Decide” (Environmental Change Institute of the University of Oxford, September 2006).

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[We] welcome the Government’s commitment (paragraph 3.3) to participating in and helping to fund a number of projects into non carbon dioxide impacts. As evidence of the effects of non carbon dioxide emissions emerges, the Government is urged to use this evidence to inform the overall aviation policy and ensure these impacts are addressed.

If a re-think of overall aviation policy in relation to climate change is required, the Government should undertake this with full stakeholder consultation. The Government is urged to consider a range of additional measures to address aviation’s impact on climate change otherwise 2020 and 2050 emissions targets will not be met.

The Government’s objectives of encouraging shorter movements by train is supported, however, greater consideration should be given to the surface transport issues at airports other than Heathrow. Airports such as Gatwick need to be supported by improved surface level access. At a strategic level this may involve investment beyond that which could be accommodated in local surface transport strategies.

Draft Aviation Policy Framework is at Draft Aviation Policy Framework (PDF – 618 kB)

The overview of the consultation, and link to the survey form, are at https://consultation.dft.gov.uk/dft/aviation-policy-framework/consult_view…

and the online form to fill in is at Online Survey

End of consultation is 31st October 2012

There is more information on the consultation, and the other sections of it, at