APPENDIX 2
Memorandum from the Bartlett School of
Planning University College London
In the last three years a research on airline
and railway integration is being carried at the Bartlett School
of Planning at UCL. The research, part of a PhD study, evaluates
the benefits from substituting aircraft services with High Speed
Train (HST) services. A main part in the research is the evaluation
of aircraft operation impact on climate change and local air quality
(LAQ). Based on this research, and previous response to the Government's
consultation on "The future development of air transport
in the United Kingdom: South East" where we asked to draw
the Government's attention to, amongst other things, the environmental
impact from the air transport industry operation, we would like
to comment on the Government's latest consultation.
1. GENERAL
(a) There is no dispute that the operation
of the air transport industry results in environmental damage.
For this, and other, reasons there is no justification to exempt
the industry from taxes (such as VAT and Fuel Duty) that are borne
by other industries. Such exemptions leads to economic distortion,
which creates artificially high demand, and as a result, increases
in environmental damage that has no economic justification.
(b) We believe the "polluter pays"
principal should apply to the air transport industry operation
as to any other human activity that result in environmental damage.
Accordingly, the industry must bear the environmental costs it
imposes.
(c) However, at present those costs cannot
be evaluated in a robust manner in order to charge the industry
for the environmental damage it causes. Yet, current research
and understanding of the industry operation impact on the environment
is sufficient to determine policy and set regulations and taxes
that will reduce this impact.
(d) One of the main features in airlines'
operation and competition strategy, which contribute to the industry
impact on the environment, is service frequency. Higher frequency,
although usually by smaller less polluting (in total sum) aircraft,
inevitably leads to higher pollution and to congestion at airports
and in the sky, which further contributes to environmental damage
from aircraft operation. But, current regulation and charges does
not take account of this side effect of airlines' competition.
For example, landing charges at many major airports can be kept
relatively low due to the "single till" approach, and
do not represent the scarcity of runway capacity. This impede
an efficient use of the runways.
(e) Taxes as well as regulations should be
used, and set, at a level that will change airlines behaviour
in a way that airlines will take account of the environmental
impact their activity imposes. In Sweden, for example, a 30% increase
in landing charge is imposed on the most polluting types of aircraft.
If this was imposed on a London to Paris flight it would have
increased the flight operating costs of a B737 by only 3%, probably
not a strong enough incentive for airlines to retire the oldest
most polluting aircraft.
(f) Revenues from taxes imposed for environmental
reasons should be used, exclusively, towards mitigating the environmental
damage caused by the air transport industry operation.
2. CLIMATE CHANGE
(a) The evaluation of aircraft CO2 emission
on climate change is considered robust and accurate, compare to
the evaluation of other gases. This is because CO2 emission is
directly related to fuel consumption, and the affect of CO2 emission
on climate change is not related to where, or at which altitude,
emission occurs, which is not the case with other gases. Yet,
while the DfT uses an emission estimate of 3.15 tonnes of CO2
for every tonne of fuel consumed Archer (1993) uses an estimate
of 2.95. This suggests uncertainty does exist, when evaluating
aircraft CO2 emission on climate change, already at the level
of measuring emission.
(b) When other gases are considered this
certainty is lost, and the uncertainty in evaluating aircraft
operation impact on climate change seems to be no different from
when evaluating aircraft operation impact on noise and LAQ.
(c) The affect of other gases on climate
change is considered by the Treasury through scaling up of CO2
emission by 2.7, to take account of the Radiative Forcing effects
of other gases. But, the literature provides much larger estimates,
which between them vary considerably (see extract one Annex A).
(d) Using some of these estimates show that
on a flight from London to Paris NOx emissions are responsible
for more climate change than CO2 emissions (see Annex B table
1). However, there is still no clear understanding of the way
NOx emissions, especially when emitted at the troposphere and
stratosphere as oppose to emission of NOx at ground level, effect
climate change (see extract 2 in Annex A). This does not allow
for a robust evaluation, using available estimates, of NOx emission
impact on climate change, and hence aircraft operation impact
on climate change. We can probably conclude with confidence that
aircraft operation contributes to climate change, but we cannot
say, at this point by how much.
(e) Nor can we quantify the cost of climate
change caused by aircraft operation in a robust way. The robustness
of evaluating aircraft operation impact on climate change further
decreases when considering the cost of climate change. This is
evident from the wide range of cost estimates found in the literature
for CO2, and other gases, impact on climate change (see Annex
B table 1).
3. LOCAL AIR
QUALITY (LAQ)
(a) Paragraph 3.22 concludes that "noise
and LAQ impacts are less certain [than climate change impact],
although it is possible to obtain estimates for the external cost
of noise". We disagree with this conclusion since it gives
the impression that: first, it is not possible to obtain estimates
for air pollution impact, and second that such estimates will
be much less certain than estimates for climate change impact.
(b) "Emissions above 915 meters are
not measured, factored, nor accounted for in an aircraft pollution
profile" (Archer, 1993: 45). The IPCC state that "the
International Civil Aviation Organisation has begun work to assess
the need for standards for aircraft emissions at cruise altitude
to complement existing LTO standards for NOx and other emissions"
(IPCC, 1999: 11). This alone suggests there is more data available
to assess aircraft operation impact on LAQ than on climate change.
(c) The Environment Protection Agency (EPA,
1999) provides detailed emission rates for the different LTO stages
for different types of aircraft, allowing a relatively accurate
estimate of aircraft emission profile. However, the EPA does not
provide data on PM10 emission. PM10 is considered as one of the
main pollutants affecting LAQ.
(d) Our research shows that when low cost-estimates
of aircraft operation impact on climate change are used the impact
of a London to Paris flight on LAQ, in terms of cost, is higher
than the impact on climate change (see Annex B table 2). It is
important to note that the only way to compare aircraft operation
impact on LAQ and climate change is by using cost estimates, in
itself, as suggested here, not an accurate nor a robust way to
compare environmental impacts.
(e) While UK policy, regulations, and taxes
can influence and reduce aircraft operation impact on LAQ (and
noise), it can hardly effect climate change without actions at
international level. Therefore, the scope for the UK to reduce
aircraft operation impact on the environment lies more within
LAQ and noise than with climate change. This does not mean that
the Government policy should not take account of aircraft operation
impact on climate change.
4. SURFACE ACCESS
TO AIRPORTS
(a) Analysis showed that surface journeys
to and from the airport has a significant contribution to the
air transport industry impact on the environment. This contribution
is mainly in terms of LAQ and it is mainly associated with car
use to access and egress airports.
(b) Accordingly, there are suggestions to
tax those journeys (when made by airport's passengers, employees,
suppliers, etc) for the environmental damage they impose. While
this is justified, according to the "polluter pays"
principal, there seems to be no reason to charge car trips to
airports, for the environmental damage they cause, separately
from any other car journeys. Therefore, such charges should be
dealt with outside the debate on aircraft operation impact on
the environment. Nevertheless, the contribution of these journeys
to the aviation industry impact on the environment must be recognised.
(c) At the same time, there is no place,
and it is in contrast with the general policy to encourage the
use of public transport to access airports, for higher fares for
passengers using public transport to access airports. For example,
during Autumn 2002 a train ticket from London Kings Cross to Gatwick
was £9 for a daily return journey, but £18 for return
on a different day, a clear discrimination against the airport
passengers who usually do not return on the same day. There might
be an environmental case for subsidising public transport journeys
to airports, but no place for taxing them.
5. CONCLUSIONS
(a) We welcome the Treasury's consultation
on using economic instruments to decrease the impact of aviation
on the environment. However, we do not feel appraisal of this
impact in monetary terms is robust enough, at present, to allow
accurate charging of the industry for the environmental damage
it causes. Instead, we welcome the use of economic instruments
to encourage more efficient and less environmentally damaging
operation of the industry.
(b) While we recognize that measuring aircraft
related CO2 emission impact on climate change is relatively robust
and accurate, we feel that the total impact of aircraft operation
on climate change is still not understood enough to allow as a
robust analysis. Therefore, estimating aircraft operation impact
on climate change according to the amount of CO2 emitted can be
misleading and underestimated, especially since some research
indicates that NOx emission impact on climate change (which is
still not entirely understood) is greater than CO2 emission impact
on climate change. Furthermore, the effect of contrail formation
from aircraft operation on climate change is still unclear.
(c) The same level of uncertainty probably
exists in estimating aircraft operation impact on LAQ, and therefore
the same attention should be given to this effect of aircraft
operation on the environment. Even more so because at the national
and local (airport) level there is more scope for the Government
to achieve substantial reductions in environmental impact by addressing
the LAQ problem. The same can be said regarding noise pollution.
(d) While measuring CO2 emission is relatively
accurate, evaluating the cost of climate change associated with
this emission is not. This is even more true for other gases and
impacts. Therefore, determining the exact charge/tax airlines
will need to pay for every flight or seat they offer, which will
represent the environmental damage they cause, is not possible
at present.
6. RECOMMENDATIONS
(a) We recommend using the knowledge already
gained on aircraft operation impact on the environment to promote
a more environmentally efficient operation of the industry. This
can be achieved, amongst other things, by using economic instruments
such as an increase in landing charges.
(b) The landing charges should represent
each flight impact on the environment in three categories. First
according to noise impact, measured in aircraft "Chapter"
category. Second, according to the flight impact on climate change
taking into consideration the flight distance. Third, according
to the flight impact on LAQ, this charge should be fixed for every
LTO cycle. The LAQ part of the charge should not be according
to aircraft size in order to encourage airlines to reduce frequency
by, for example, replacing three B737 flights with one B747 flight
and saving two charges for LTO cycle. Such landing charge should
be set at a level that is high enough to encourage airlines to
determine service frequency in respect to the environmental impact
each flight imposes. Such landing charges could be an interim
charge until science is better developed to allow more robust
estimate of the cost of environmental impact caused by aviation.
(c) The purpose of taxation is to ensure
that the full environmental costs are paid by the polluter, and
to ensure that aviation contributes to climate stabilization,
and improved LAQ around airports. To make taxation acceptable,
it is important that the revenues generated will be reinvested
in developing new clean aircraft technologies, and in promoting
more environmentally clean alternatives. Such an alternative,
according to the research carried at the Bartlett School of Planning,
is the use of High Speed Trains to substitute aircraft on short
haul routes.
(d) We also recommend that the Government
will conduct research to identify a more environmentally sustainable
operation of the air transport industry. Specifically, it is important
to identify the contribution of the hub and spoke operation to
the industry's impact on the environment.
(e) The UK government should press for international
actions so that actions taken by the UK, to reduce the aviation
industry impact on the environment, will be followed by other
countries. Only actions at international level, through the EU
and the ICAO, can achieve a significant reduction in the aviation
industry impact on climate change.
April 2003
Annex A
Extracts from Givoni (2002)
EXTRACT 1:
Maddison et al. (1996) defines the Global Warming
Potential (GWP) of a gas which allow to compare the impact of
different gasses on climate change. The GWP is the immediate impact
of the gas integrated over their lifetime residency in the atmosphere.
The immediate impact of a gas is defined as the product of its
increase in atmospheric concentrations multiplied by the increase
in radiative forcing per unit of concentration. GWP's are expressed
relative to that of CO2, which is given a GWP of unity. NOx GWP
is 270 (Maddison et al. 1996, our emphasize). More information
that can be used for analysing the impact of CO2 emission relative
to NOx emission, and NOx emission at ground level compare to NOx
emission in the troposphere is given by Archer (1993) who writes
(no reference to sources is given):
"According to the IPCC and the UK DoE, NO2,
through its production of O3, has on average 150-160 times the
global warming effect of CO2. According to a study made at ETSU,
one gram of NO2 has three times as potent a greenhouse effect
at ground level as the same amount of CO2, and in the upper atmosphere
335 times the effect."
(Archer 1993 pp: 64)
EXTRACT 2:
Emission of NOx have two major impacts in relation
to climate change: it creates Ozone and depletes Methane. Since
both are GHGs NOx emission affect climate change in opposite ways.
It causes warming by the creation of Ozone and cooling by the
depletion of Methane, but the effects do not cancel each other.
For example, emission of NOx at high level (10-12km) results "in
enhanced Ozone generation, lower Methane removal rate and greater
radiative impact per unit of Ozone produced" (ETSU 1992 in
Archer 1993 pp: 62). In general, aircraft emissions of NOx are
more effective in producing ozone in the upper troposphere than
an equivalent amount of emission at the surface (IPCC 1999). Although
aircraft sulphur and water emissions in the stratosphere tend
to deplete ozone (IPCC 1999) aircraft considered in this paper
do not fly in the stratosphere thereby we can consider NOx emissions
from aircraft to contribute to increase in Ozone and thus to increase
in global warming. The ETSU study (1992) concludes:
"The global warming impact of NOx from aircraft
is enhanced relative to ground-level emissions of NOx. This is
due to much of the NOx being injected into the troposphere at
the height where it has most impact on global warming. Ground-level
emissions of NOx and subsequent greenhouse gases are largely removed
by chemical reactions before they reach this level"
(ETSU 1992 in Archer 1993 pp: 63)
Annex B
Table 1
THE COST OF CO2 AND NOx EMISSION IMPACT ON
CLIMATE CHANGE
| Cost estimate source
| Maddison et al 1996 |
Eyre et al, 1997 | DETR, 2000
| | | |
| Gas | CO2 | NOx
| CO2 | NOx | CO2
| NOx | | |
|
| Cost (Euro/kg) | 0.007 | 0.940
| 0.010 | 0.970 | 0.090
| 3.920 | | |
|
| Cost (Euro/seat/route) * | 0.251
| 0.307 | 0.359 | 0.317
| 3.231 | 1.281 |
| | |
| Total cost** | 0.558
| 0.676 | 4.512
| | | |
* Cost of climate change impact related to CO2 and NOx emission
per seat offered on LHR to CDG flight (assuming B737-300).
Table 2
COST OF CLIMATE CHANGE AND LAQ IMPACT CAUSED BY ONE SEAT
SUPPLIED ON THE ROUTE LHR TO CDG (EURO/SEAT/ROUTE, ASSUMING B737-300)
| Category | Climate change
| Air pollution* |
| Euro/seat/route | 0.558 |
0.676 | 4.512 | 0.798
|
* Based on average of cost estimates from different studies (Cherie
et al, 2001).
References:
Archer L. J. (1993), "Aircraft emissions and the environment:
COx, SOx, HOx & NOx", OIES papers on energy and the environment,
Oxford Institute for Energy Studies, Oxford.
Cherie H. Y. L., Morrell P. (2001), "Evaluation and
implications of environmental charges on commercial flights",
Transport Reviews, 21(3), pp: 377-395.
DETR, Department of the Environment, Transport and the Regions
(2000), "Valuing the external costs of aviation", DETR,
12 December.
EPA, Environment Protection Agency (1999), "Evaluation
of air pollutant emission from subsonic commercial jet aircraft",
EPA, EPA420-R-99-013, April.
Eyre N. J., Ozdemiroglu E., Pearce D. W., Steele P. (1997),
"Fuel and location effects on the damage costs of transport
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pp: 5-24, in: Lu H. Y. L., Morrell P. (2001), "Evaluation
and implications of environmental charges on commercial flights",
Transport Reviews, 21(3), pp: 377-395.
Givoni M. (2002), "A comparison of the (marginal) environmental
effect and cost of aircraft and HST operation on climate change",
University College London, March, Not published.
IPCC, Intergovernmental Panel on Climate Change (1999), "Aviation
and the global atmosphere", Cambridge University Press, Published
for the Intergovernmental Panel on Climate Change.
Maddison D., Pearce D., Johansson O., Calthrop E., Litman
T., Verhoef E. (1996), "The true cost of road transport"
Earthscan Publications Ltd, London.
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