Heathrow and Gatwick submit their responses on Aviation & Climate Change to Airports Commission

Both Heathrow and Gatwick airports have submitted their responses to the Aviation Commission’s discussion paper on Aviation and Climate Change. Both base their aspirations of high growth rates over coming decades on evidence from the industry body “Sustainable Aviation”.  Not surprisingly, both airports’ submissions are attempts to justify the unjustifiable: to claim that emitting huge amounts more carbon dioxide can be achieved with no net emissions, by various probable and improbable means.  They hope improvements in efficiency by airlines and air traffic control, as well as improved aircraft design, will cut their emissions. They place unrealistic hopes in “sustainable” biofuels, with Gatwick’s submission saying “…by 2050, sustainable fuels could offer between 15 and 24% reduction in CO2 emissions attributable to UK aviation.” Gatwick also wants considerable Government support (ie public expense) to develop biofuels for the industry. And both depend to an enormous extent on international agreements through ICAO, and systems for carbon trading that do not currently exist.


Heathrow: UK aviation can grow and meet climate change targets

15 May, 2013  (Heathrow)

The Heathrow response to the Airport Commission’s discussion paper on Aviation & Climate Change is at  Heathrow response
Aircraft Blue Sky 2
Heathrow says:

Growing the UK’s airport hub capacity is consistent with meeting UK climate change targets, according to Heathrow’s response to the ‘Aviation and Climate Change’ discussion paper published by the Airports Commission.

The response, submitted today, cites projections by Sustainable Aviation1, [see below for their Roadmap graphic]  the UK aviation cross-industry association, that new aircraft and engine technology, operational efficiencies and sustainable biofuels will allow the UK to more than double air traffic by 2050 without a substantial increase in gross emissions [very optimistic on biofuels which, in reality, are not likely to be available in large amounts] consistent with the UK’s long term legally set climate change targets. Together these developments have already improved fuel efficiency by over 70 per cent in the last 40 years2.  [In reality, the older planes were more fuel efficient. Then the new jets took over, which were fuel inefficient; and the new improvements are only getting back now to where they were 40 years ago ….]

If international carbon trading is added to these factors, Sustainable Aviation forecasts that emissions over time would actually be reduced, achieving the global industry’s commitment to halve 2005 carbon emissions by 20502 [ ie. depending on carbon trading with other sectors to negate aviation carbon emissions. Not real cuts. by the industry – just hoping to buy permits from other sectors which actually make carbon cuts.]

Heathrow’s submission adds that constraining growth at a hub airport is an inefficient and ineffective way of reducing carbon emissions for three reasons:

  • Without additional UK hub capacity, passengers will still travel, but in less carbon efficient ways, so carbon will not be cut. UK long-haul passengers will have to transfer through EU hubs, adding an additional landing and take-off to each journey – the most carbon-intensive part of a flight. International passengers travelling to the UK may need to detour via a European hub, adding extra miles to long-haul routes. The Airports Commission concludes that by 2030, the carbon emissions from increased transfer trips would exceed any carbon savings made by those that would choose not to travel3. In addition, the UK would lose the economic benefits of direct connections.
  • All sectors need to play a role in reducing carbon emissions. Aviation delivers more than twice the economic value per tonne of carbon compared to other sectors [very unscientific figure – how could such a general claim be justified? how exactly were the figures derived? work done by Frontier Economics  on 2009 data]  so there is greater value-for-money in reducing carbon emissions in other non-transport areas4.
  • The unique long-haul routes from the UK’s only hub airport, Heathrow, deliver over twice the economic value per carbon tonne from trade and tourism compared to those from other UK airports4.


The existing transport infrastructure around Heathrow also provides additional carbon emissions benefits compared to other UK hub options.

The submission shows that, even if development of Stansted or a new Thames Estuary airport included significant investment in new transport infrastructure, Heathrow would still have 4.5million more people within a 60minute public transport catchment area than either airport. This means passengers and staff would create a significantly smaller carbon footprint when travelling to and from Heathrow.

Matt Gorman, Heathrow’s Sustainability Director, says: ‘Our submission argues that it is possible to grow the UK’s hub airport, Heathrow, without exceeding the UK’s long term climate change targets. This is thanks to exciting advances made by the aviation industry across technology, operational procedures and sustainable fuels which have changed the impact of this industry for the better and will continue to do so in the future.’

Notes to editors

1Sustainable Aviation 2050 C02 Roadmap, 2012.

2IATA, A global approach to reducing aviation emissions.http://www.iata.org/SiteCollectionDocuments/Documents/Global_Approach_Reducing_Emissions_251109web.pdf

3Airports Commission, Discussion Paper 03: Aviation and Climate Change, April 2013.https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/186683/aviation-and-climate-change-paper.pdf

4The impact on the UK economy of reducing carbon emissions in Aviation, by Frontier Economics, 2011. Commissioned by Heathrow Airport. www.heathrowairport.com/mediacentre



The Heathrow response to the Airport Commission’s discussion paper on Aviation & Climate Change is at  Heathrow response


[Heathrow comments, under the effects of climate change, that ….. “that the material consideration is the risk of sea level rise for any potential future airport option at a coastal or estuary location and we suggest that this is an issue which the Commission might take into account.”

There will have to be a horrific level of climate change to cause that degree of sea level rise. Can aviation really justify its continued growth when the climate, and the sea level has already risen that much? ]



Gatwick Airport’s response to the Commission’s Aviation & Climate Change discussion paper

…..   Gatwick has also separately submitted its response to the Airports Commission on Aviation and Climate Change – an area of key importance and focus for the airport. While there is much work to be done by the whole industry to manage climate change issues, innovation is already taking place in areas such as aircraft technology, which is reducing C02 levels. Within its submission, Gatwick has reiterated its commitment to its sustainability programme ‘Decade of Change’ and highlighted the use of biofuels as a key focus for the Airports Commission to consider for the future.


London Gatwick’s full submission is at Aviation and Climate Change


Gatwick airport, like Heathrow, places huge faith in biofuels to solve their future carbon problems. The Gatwick submission says (page 8)

We also believe that the DfT forecast for penetration of biofuels is too low. We endorse and the support the figure outlined in the Sustainable Aviation CO2 road map. We fully expect that penetration will be greater than 2.5% by 2050 particularly if the Government provides more support in this area in line with the approach outlined in SA’s CO2 road map.

Accordingly, we believe that by 2050, sustainable fuels could offer between 15 and 24% reduction in CO2 emissions attributable to UK aviation. This assumption is based on a 25-40% penetration of sustainable fuels into the global aviation fuel market, coupled with a 60% life-cycle CO2 saving per litre of fossil kerosene displaced.


The sort of reasoning that Gatwick and Heathrow use to justify large aviation expansion in future can be seen from these graphics:

Sustainable Aviation road map


From the Gatwick submission:

Gatwick airport climate submission May 2013

Another comment that reveals the tone of the response is (page 11):

“Behavioural change is not an approach supported by Gatwick. We believe the long term solution to managing the industry’s carbon emissions lies in delivering alternative low CO2 fuels in conjunction with other technological advancements. This will allow aviation to grow and meet demands from passengers in a sustainable manner ensuring the economic prosperity of the UK. ”



“…….the most compelling opportunity for the UK to exert an influence over CO2 emissions from aviation is not by constraining demand for UK aviation, but rather through investment in advanced technologies which can be deployed globally, earning export revenues for the UK while contributing to a more environmentally efficient industry world-wide. This would then allow for sustainable growth in the UK aviation sector ensuring UK connectivity and protecting the valuable contribution the industry makes to the economy.”



“The industry has already demonstrated significant carbon savings. Analysis by IATA (IATA, 2010) has shown that global commercial airline fuel efficiency has improved by over 30% in the past two decades, saving over 400 million tonnes of CO2 per annum at current activity levels, relative to the fleet efficiency in 1990. In contrast, total annual emissions of CO2 attributable to UK aviation correspond to less than one tenth of this figure. In line with
IPCC (sic) we believe that aviation can grow by around 60% and still achieve the Governments (sic) carbon emissions reduction targets.”

“However in order to achieve this sustainable growth, there need to be continued technological advances and developments and there will need to be significantly more support from Government to develop alternative fuels and a workable solution to carbon trading. These measures combined with the operational savings achievable from airspace changes and efficiencies in ground operations, will deliver the headroom which enables the industry to grow, whilst achieving the governments (sic) emission targets.”