BEIS “Clean Growth Strategy” admits aviation CO2 cannot be kept below 37.5MtCO2 – it has no plan on aviation carbon



Clean Growth Strategy fails to address aviation policy gap

The long-awaited Clean Growth Strategy was published today, setting out how the Government plans to increase the pace of action needed to deliver the Climate Change Act. The Government’s webpage boldly claims that “This strategy sets out our proposals for decarbonising all sectors of the UK economy through the 2020s.”

But there’s a catch: the Government has no plan for aviation.

Despite the CCC repeatedly asking for one, despite forecasts showing that the sector’s emissions will take up at least 25% of the total budget for 2050, and despite evidence that a third runway will make the CCC’s recommendation for the sector impossible to achieve, the Government says it “has not reached a final view on the appropriate level of aviation emissions in 2050.”

There are two glaring omissions from the plan published today:

  1. No policies to deliver the assumption of 37.5 Mt in the fourth and fifth carbon budgets

The Committee on Climate Change, the Government’s official advisors on delivery of the Climate Change Act, has consistently said that aviation emissions should be no higher than 37.5 Mt by 2050. While aviation remains outside formal carbon budgets, the CCC’s “planning assumption” has been assumed in all the carbon budgets so far legislated, including the fourth and fifth budgets (from 2023-2032).

The Clean Growth Strategy sets out how the Government intends to up the current pace of decarbonisation in order to meet these budgets, with plans – for example – for an Industrial Energy Efficiency scheme, support for home energy efficiency, investment in Carbon Capture and Storage, and an end to the sale of new conventional petrol and diesel cars and vans by 2040. But beyond vague mentions of biofuels and offsetting schemes there is not a single policy proposal for limiting aviation emissions to the level assumed in the modelling.

  1. No promise to stick to the aviation limit beyond 2032

This is, of course, not just an oversight. All reputable evidence to date indicates that keeping aviation emissions to the level of the planning assumption (which is set at the level of the sector’s emissions in 2005) will be challenging even without runway expansion, and probably impossible if the Government’s plan for a third Heathrow runway goes ahead.

In its progress report to Government this June, the CCC had the following to say on aviation:

“If aviation emissions are anticipated to be higher than 2005 levels – as in the central case in the business case for an additional runway at Heathrow airport – then other sectors would have to plan for correspondingly higher emissions reductions. We would expect to see this reflected in the Government’s plan for meeting the fourth and fifth carbon budgets.”

The government plan for squaring the circle on this issue should, in other words, have been set out in today’s strategy. But while the strategy seems to imply that yes, somehow the question can be answered and yes, somewhere they’ve answered it, the details are shrouded in mystery.

Quoting analysis by the Airports Commission, the strategy says on p153:

“For the case of expansion at Heathrow (a new northwest runway), the AC estimated UK gross aviation emissions in its “carbon traded” scenario to be around 44 MtCO2e in 2050. This scenario for gross UK aviation emissions above the CCC planning assumption provides a useful basis for a sensitivity test. Our analysis shows that it is possible to meet the 2050 target under the Climate Change Act domestically if aviation emissions are 44 MtCO2e – this is the case for our three pathways to 2050. Further action could be taken after the fifth carbon budget in order to offset these higher aviation emissions through action elsewhere in the UK. The action taken in the remaining UK sectors depends on the wider pathway to 2050.”

So how has the Government pulled off this magic trick of showing how the anticipated emissions cuts from other sectors will not only be met but exceeded?

Who will make up the shortfall caused by aviation and what impact will it have on consumers’ bills? What are the ‘actions’ the strategy mentions? We’ve searched through today’s strategy and can’t find the answers. Even more mysteriously, Table 10 of the report, which shows the three possible pathways to the 2050 emissions target, includes a figure of 44 Mt CO2e from aviation and shipping combined (not for aviation alone as suggested in the text).

AEF’s reaction:

Cait Hewitt, AEF Deputy Director, said:

The Government claims to have shown today how it will decarbonise all sectors of the economy. But it doesn’t seem to have noticed the aviation sector, which has no meaningful alternative to fossil fuels, and growing passenger demand.

Heathrow airport, already responsible for half the total emissions from UK aviation, must not be allowed to expand until the Government has an answer on how to tackle the sector’s CO2. Today’s strategy effectively admits that it’s not possible to meet the CCC’s recommendation for keeping aircraft emissions within the limits of the Climate Change Act while building a third runway, but seems to have no answer on how it will account for this.

The relevant section of the table, showing the aviation and shipping emissions together (though in the text aviation alone accounts for the 44 MtCO2).  P 151 of

The footnote 346 says:   Includes domestic and international aviation and shipping, in line with advice from the Committee on Climate Change. CCC (2015) Sectoral scenarios for the fifth carbon budget

The text in the report says:  “Our analysis shows that it is possible to meet the 2050 target under the Climate Change Act domestically if aviation emissions are 44 MtCO2 e350 – this is the case for our three pathways to 2050. “(Page 153)


In-depth: How the ‘Clean Growth Strategy’ hopes to deliver UK climate goals

12.10.2017 (By multiple authors at Carbon Brief)

Today, the UK government published its long-awaited Clean Growth Strategy, setting out how it hopes to meet the nation’s legally binding climate goals

[It is a long article, and just the sections relating to aviation are copied below].

On aviation and shipping, it says:

“We will set out our strategic approach to the aviation sector in a series of consultations over the next 18 months, including a paper on how to support growth while tackling the environmental impacts of aviation. This will culminate in the publication of a new Aviation Strategy for the UK by the end of 2018…On domestic shipping, the Government will continue to work with industry to develop improved fuel efficiency technologies, including new propulsion systems, hull design and aerodynamic structures.”

(See the 2050 Pathways section below for more on the government’s long-term view on how it sees aviation emissions sitting within the 2C target.)

The strategy includes a short section devoted to greenhouse gas removal (GGR) technologies, also known as negative emissions. (See Carbon Brief series of articles on the topic.)

The government admits that they “are likely to have an important role to play in offsetting difficult-to-cut emissions, by removing greenhouse gases from the air”.

This is because, as the UK approaches 2050, its remaining emissions “will likely be in the sectors where it is the most difficult to cut them – in industry, agriculture, aviation and shipping”.

It says it wants the “UK’s entrepreneurs, universities and engineering industries to be well placed to exploit the advantages of global demand for these new technologies”.


It’s noteworthy that in its emissions removal pathway it shows that the power sector would actually be removing 22MtCO2e in 2050, thereby allowing more headroom for transport, buildings and agriculture to decarbonise more slowly. It also assume no CCS in pathway 1 (electricity).

It’s also eye-catching that all three pathways assume the same emissions from the aviation and shipping sectors. The number given seems to be something of a placeholder, though. This is because: “The Government has not reached a final view on the appropriate level of international aviation and shipping emissions in 2050.”

It adds, by way of further explanation for the figure chosen in the table:

“Our analysis shows that it is possible to meet the 2050 target under the Climate Change Act domestically if aviation emissions are 44MtCO2.” (Given this part of the strategy is discussing both aviation and shipping, the absence of the word “shipping” here is noticeable.)

However, as Carbon Brief reported last year, the CCC has said that UK aviation emissions should be limited to no more than 2005 levels, if the UK is to meet its 2050 carbon targets as cheaply as possible. This would mean a cap of 37.5MtCO2e for UK-based air travel.

It is important to stress that the strategy is only “2C compatible”. It does not seek to set out policies which would guide the UK towards meeting the 1.5C goal of the Paris Agreement.

See the full analysis at