Select Committee on Environmental Audit Written Evidence


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
GasCO2NOx CO2NOxCO2 NOx
Cost (Euro/kg)0.0070.940 0.0100.9700.090 3.920
Cost (Euro/seat/route) *0.251 0.3070.3590.317 3.2311.281
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/route0.558 0.6764.5120.798

* 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 emissions", Journal of Transport Economics and Policy, 31, 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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