Appendix Government Response to the
Environmental Audit Committee's Seventh ReportAviation:
Sustainability and the Government Response
This memorandum is the Department for Transport's
response to the above-titled report from the Environmental Audit
Committee. The Department reiterates its commitment to tackling
the environmental impacts of air transport, at both domestic and
international levels, as part of a balanced and measured approach
to aviation's development over the next 30 years. We will be
happy to assist the Committee if any aspect of Government policy
on this subject remains unclear.
"The quality of the Government response is
poor and not of the standard we would normally expect. In rejecting
so much of our report without adequate consideration or explanation
and in such an overtly challenging manner, the Department for
Transport is failing to address not only our concerns but the
similar concerns expressed by many other organisations including
the Sustainable Development Commission and the Royal Commission
on Environmental Pollution."
The Department's memorandum of May 2004 to the Committee's
Follow-up Report, reproduced at Appendix 1 to the Seventh Report,
followed the Government's earlier response of December 2003 (Cm
6063) to the Committee's Ninth Report of Session 2002-03. These
responses were additional to other publications, including the
response to the Transport Select Committee's Report on Aviation
(Cm 6047), the document Aviation and Global Warming (published
on 8 February 2004, although dated January on the front cover),
and most notably the Future of Air Transport White Paper
itself (Cm 6046). These are substantial documents based on what
we understand to be the largest consultation exercise ever undertaken
by the Department for Transport or predecessor transport departments.
We are concerned that the Committee was so disappointed
by our memorandum of May 2004. We recognise that the matters under
discussion are of considerable importance and complexity, and
as noted in paragraph 7 of our memorandum, we are ready to assist
the Committee if it has specific queries or uncertainties about
the documentation we have produced.
The Department appreciates the work that has been
put into the summary critique of the Future of Air Transport
White Paper published by the Sustainable Development Commission
(SDC) in June 2004. We are in dialogue with the SDC and look forward
to working further with them on matters of aviation policy. The
Royal Commission On Environmental Pollution's special report The
Environmental Effects of Civil Aircraft in Flight (November
2002) was produced as a response to the major Government consultation
that preceded the Future of Air Transport White Paper.
It provided an excellent synthesis of available scientific and
technical knowledge about aviation's environmental impacts (mainly
in respect of climate change impacts). The five specific recommendations
in the special report are reflected in Government policy where
feasiblefor example our support for the inclusion of aviation
in the EU emissions trading scheme (an idea also supported by
In conclusion, the Department welcomes constructive
criticism and is willing to work with stakeholders and commentators
from across the spectrum of opinion in order to build understanding
and shape policy detail.
"A policy which estimates future demand and
then aims to satisfy almost all of it is self-evidently based
on a 'predict and provide' approach. The Department for Transport
should respond fully to our original conclusion, and explain why
it believes it is wrong to describe the White Paper in that way,
particularly when the Government is actively promoting growth
on the scale envisaged."
The Department's previous memorandum sought to explain
that The Future of Air Transport White Paper did not pursue
a 'predict and provide' approach, but a balanced and measured
approach which fully recognizes the importance of environmental
constraints in particular. Paragraphs 2.11 to 2.16 of the White
Paper deal at the strategic level with the limitations to growth
of the air transport sector, and the theme is reprised in Chapter
3 and in the later references to environmental constraints for
individual airports, including stringent noise controls, compliance
with emissions limits near airports, and maintenance of the agreement
not to build a new runway at Gatwick before 2019.
The Committee will also recall that the forecasts
of future demand include a notional offset allowance for an economic
instrument equivalent to a 100% fuel tax (see Annex A paragraph
11), notwithstanding that a fuel tax, as such, is currently precluded
by our international obligations.
The demand forecasts up to 2030 imply that an economic
case exists for three additional runways in South East
England. However, The White Paper acknowledges that simply building
more and more capacity to meet demand would not be a sustainable
approach and concludes that only two new runways can be justified
in the South East.
In reaching the policy conclusions in The Future
of Air Transport, the Government is not "actively promoting"
growth, but is recognizing the reality of historic growth, explaining
the nature of demand for air transport, and setting out how far
and where, in its view, any new development should take place.
And, of course, airport expansion projects will not be promoted
and funded by Government, but by the private sector. Proposals
for new development will need to be considered through the planning
system in the normal way, and full environmental assessment will
be required when specific proposals are brought forward.
It is worth considering the UK position in the context
of the competition it faces. For example, Amsterdam Schiphol
Airport has more runways than Heathrow, Gatwick and Stansted combined,
despite having a much smaller catchment population and fewer air
traffic movements than Heathrow. Elsewhere in the world major
expansion of airport infrastructure is underway, for example in
the United States and China, that dwarfs the balanced and measured
proposals in our White Paper.
"The Government response fails to set out
what detailed studies the Department for Transport has carried
out to explore the social and behavioural impacts of the forecast
growth in aviation, and the manner in which these impacts may
vary for different rates of growth. It should do so, taking into
account the growing sense that the real price of oil is unlikely
to remain at the level assumed in the White Paper."
The air traffic demand forecasts made by the Department
are based on the Government's best assessment of key drivers such
as economic growth, overall trends in air fares (where the central
forecasting assumption is that cost savings will be passed on
through a trend decline of 1% per annum), and oil prices.
The Committee has expressed its concern about these assumptions;
the Department's task here, though, was not to make social or
behavioural judgements but to make an objective assessment of
likely trends, and we stand by these assumptions and forecasts.
Historically, DfT and its predecessor departments' forecasts have
generally proved conservative.
The validity of the assumptions underpinning the
demand forecasts may change in the light of events and the Government
will continue to monitor these closely. The recent increase in
oil prices has resulted in some airlines introducing small fuel
surcharges - a kind of 'oil tax'. However, care should be taken
in extrapolating short term movements in oil prices into the future.
Experience has shown that the real price of oil, for example,
is subject to short term fluctuations that may not be sustained
in the longer term. Even with oil at $45 per barrel or higher,
aviation fuel remains cheap in real terms compared to the 1970s,
and modern aircraft are far more fuel-efficient.
Fuller information on how the demand forecasts are
calculated is set out in Annex A of the Future of Air Transport
White Paper, and in even greater detail in the supplementary document
Passenger Forecasts: Additional Analysis, dated
December 2003 and published as a supplementary document to the
White Paper on 8 February (available on the Department's web site).
Under the "high capacity" scenario in 2030, passenger
forecasts suggest there would be an average of just under two
return trips per UK resident in 2030, compared with 0.8 return
trips in 2000. We do not explicitly divide increases in mppa
between people who otherwise would not fly at all and people already
flying who take additional flights.
The Integrated Policy Appraisal (IPAsee also
response to recommendation 6 below), at Annex E to the White Paper,
discusses social and distributional impacts of aviation with reference
to specific regions and airports. In the process of conducting
the IPA, DfT and other Departments considered whether new detailed
aviation-specific studies in these areas would add materially
to our understanding of the effects, and significantly improve
the accuracy of the forecasts and assessments. We did not identify
social or behavioural aspects where such studies would be likely
to provide new information critical to the White Paper decisions.
It would be mistaken to think that the Department
lacks knowledge on social attitudes to flying. As noted in the
White Paper, there is considerable knowledge about individuals'
'propensity to fly' (airlines and holiday companies have sophisticated
market research techniques in this field), and the fact that half
the British population flies at least once a year is oft-quoted.
The Committee will also find interesting information in the study
commissioned from Arthur D Little Limited by the then Department
of the Environment, Transport and the Regions and published alongside
the national consultation that preceded the Future of Air Transport
Particular attention is drawn to Chapter 2Economic
and Social Trendswhich discusses issues such as globalisation,
demographics, lifestyle changes and leisure travel patterns.
"The Department for Transport must publish
a formal statement of what it understands by sustainable consumption
in the context of air travel. As part of this statement, it should
explain how the projected growth from 180 Mppa to 476 Mppa by
2030 can be reconciled with the commitment made by the UK Government
in Johannesburg to encourage more sustainable approaches to consumption;
and it should also set out what policies it is pursuing to discourage
unnecessary air travel."
Changing Patterns, the
UK Government Framework for Sustainable Consumption and Production
(SCP) explains the Government's approach to taking forward the
commitments agreed at the World Summit on Sustainable Development
in 2002. The SCP Framework acknowledges that 'greener travel',
including air transport, is an important action area for consumers.
It explains the importance of making progress in parallel on
three frontseconomic development, environmental protection
and social cohesionand sets out a core definition of SCP
in the following terms: "Continuous economic and social progress
that respects the limits of the earth's ecosystems, and meets
the needs and aspirations of everyone for a better quality of
life, now for future generations to come".
As the SCP Framework explains, the Government is
looking to develop the debate on sustainable consumption and we
have been taking this forward as part of the current consultation
on our Sustainable Development Strategy. The Sustainable Development
Commission and the National Consumer Council have recently established
a Roundtable on Sustainable Consumption, supported by Defra and
the DTI, which will be trying to build some consensus around the
features of more sustainable patterns of consumption and lifestyle,
including travel and mobility issues. The Government certainly
recognises that more needs to be done to tackle aviation's environmental
impacts, but this is a long term project: to this end we hope
that the consultative processes under way on sustainable consumption
and the UK Sustainable Development Strategy will contribute constructively
to thinking within civil society as well as across government.
We note the Committee's concern that "unnecessary
air travel" should be discouraged. We are in fact very open
to constructive ideas for rethinking travel needs. But we doubt
that at present there is any commonly accepted definition of what
constitutes "unnecessary air travel" and therefore we
doubt that the Government should attempt judgements about the
'necessity' or otherwise of flights taken by individual travellers.
The Department's air travel forecasts are non-judgmental.
The basis for them is explained in Annex A of the Future of
Air Transport. Briefly, the forecasts are derived by modelling
long term factors such as future growth in UK and world GDP, increased
world trade, declining air fares, and exchange rates. The forecasts
make various assumptions about the composition of demand, including
different assumptions about demand from business and leisure passengers,
and from UK and foreign passengers, bearing in mind that many
passengers on flights to and from the UK are not UK residents.
For example, demand from foreign leisure passengers is forecast
to grow faster than demand from UK leisure passengers up to 2020,
reflecting higher economic growth rates for countries outside
of Western Europe. The discussions at the World Summit on Sustainable
Development in Johannesburg emphasised the importance of market
access for developing countries and the availability of affordable
transportation, as well as concerns about environmental problems.
Finally, the Committee may be aware of voluntary
initiatives whereby travellers can calculate estimated CO2
emissions from flights and make voluntary payments to offset those
emissions if they wish. Such a scheme has been endorsed by the
German government recently, and the concept may merit further
investigation in the UK.
"We calculated the environmental impacts
of the forecast growth in aviation to be minus £42 billion
(net present value), but were unable to identify from departmental
appraisals the total producer and consumer surpluses to set against
this figure. The Department for Transport has entirely ignored
this point and should respond in full to our original conclusion.
The basis of the Committee's estimate of £42
billion environmental costs is unclear. Presumably it relates
to an increase in national throughput from 180 mppa in 2000 to
476 mppa by 2030, an increase of 296 mppa. (para 28 of "Pre-Budget
Report 2003: Aviation follow up" refers).
The original national consultation on the future
development of air transport in the United Kingdom (July 2002,
reissued February 2003) contained detailed information on the
economic appraisal of different airport capacity options. We also
published figures (in Chapter 5 of Aviation and Global Warming)
that show the benefits at the national level from two new runways
in the South East. An increase of 35 mppa in national throughput
by 2030, from 428 mppa to 463 mppa, would lead to an increase
in global warming costs of £4bn. The corresponding increase
in net economic benefits, including consumer surplus and producer
benefit, is estimated at £17.1bn. Paragraphs 5.25-5.35 of
Aviation and Global Warming focus on the costs of global
emissions compared with net economic benefits. Not all the additional
capacity in the South East feeds through to an increase in national
throughput; in some cases it means that fewer passengers with
South East origins or destinations have to travel through regional
The supporting paper to the White Paper, Passenger
Forecasts: Additional Analysis, reports at Table C.1 that
the net economic benefits of increasing capacity in the South
East from that approved in the planning system (with a national
throughput of 414 mppa, in 2030) to the ' maximum use of existing
capacity ' (431 mppa in 2030) is £13.7bn. Economic benefits
per mppa get larger for lower increments in capacity from today's
levels; a higher ' fare premium ' is required to price off demand
when there is less capacity (see for example The Future Development
of Air TransportSouth East Consultation Document,
chapter 14 and Annex B, and the supporting paper to this on Economic
So the net economic benefits from providing capacity
such that national throughput in 2030 is 466 Mppa rather than
414 Mppa approach £31bn. No attempt has been made to quantify
the economic impact of capacity in 2030 of 180 Mppa rather than
that sufficient to enable a throughput of 414 Mppa. The economic
benefits, however, of moving from 180 Mppa to 414 Mppa would be
"The Department for Transport should also
respond to our conclusion that the Integrated Policy Appraisal
appended to the White Paper was particularly weak in its assessment
of climate change impacts and the difficulties posed by the growth
in aviation emissions in the light of the Government's 60% carbon
reduction target. (Paragraph 16)"
Estimates of the environmental costs associated with
aviation's contribution to climate change were published in the
DfT/HM Treasury discussion paper, Aviation and the Environment:
Using Economic Instruments (March 2003). These estimates
of damage costs are independent of the Government's 60% CO2
reduction target for domestic emissions.
There may be some confusion about the purpose of
the Integrated Policy Appraisal (IPA). IPAs are used as a means
of gathering together in one place a summary of the expected impacts
of a policy or project. They are meant to be a useful digest
of impacts, not a comprehensive analysis. The entire preparation
of the Future of Air Transport White Paper represented
a major analytical and policy development process, of which the
IPA was just one small part.
"We expressed our astonishment at the lack
of essential research to underpin the incorporation of aviation
in the EU Emissions Trading System, and recommended that the Department
for Transport should set out what needed to be done and by when
to achieve this goal. Our conclusion and recommendation was totally
ignored, and the Department should now provide a full response.
The Department recognises that there is a large amount
of work to be done to ensure aviation's incorporation into the
EU Emissions Trading Scheme (EU ETS). We are pursuing this vigorously,
but we do not underestimate the difficulties in the design and
implementation of aviation's inclusion into the EU ETS.
The Committee appears to have drawn the wrong conclusion
from a comment made by a DfT official in response to a specific
question about modelling. The Committee concluded that
this comment was referring to research. There is, in fact,
a large and growing body of research (some of it funded or part-funded
by the Department) into this subject. Recent examples include
major research projects by (i) ICF Consulting for the ICAO Committee
on Aviation Environmental Protection, (ii) OXERA for BAA plc,
and (iii) the Institute of Applied Ecology for the German Environment
Agency. The conclusions from this research support emissions
trading as an effective way forward. At the time of writing the
European Commission (DG ENV) is also in the process of letting
a major research contract to consider the incorporation of aviation
into the EU ETS, which we hope will lead to a formal proposal.
In addition, the Department is aware that work has been undertaken
by various UK investment analysts in this subject.
The Department is having discussions with various
stakeholders to discuss the modalities of including aviation in
the EU ETS, as well as bilateral discussions with major EU Member
States. The purpose of these discussions is to gather support
for the UK's initiative and to seek views on potential answers
to some of the difficult design issues. We envisage this work
continuing and intensifying as the UK Presidency of the EU approaches,
in the second half of 2005. The details of aviation's participation
in the EU ETS will be decided by what the Commission proposes,
and what is negotiable and practicable. Concerning the timetable
of the steps that need to be taken, we are ultimately dependent
on the Commission making a proposal. We know that it will consider
doing so in the light of the research project it has commissioned
and we would welcome an early start to the process of introducing
new EU legislation on the issue, so that the necessary technical
preparations can be made in time for a 2008 start to emissions
trading in the aviation sector.
"We reject the accusation contained in the
Government response that our figures for the impact of aviation
in relation to other UK emissions are misleading and inappropriate.
The underlying truth is not in dispute: that the global warming
impacts from aviation are forecast to increase massively just
as we are striving to make huge cuts in emissions from all other
sectors of the UK economy. (Paragraph 22)"
There is no disagreement that aviation's share of
greenhouse gas emissions is forecast to increase. The RCEP's
special report of November 2002 (see response to recommendation
1 above), referring to the global impacts of aviation, concluded
unless there is some reduction in the growth
in the sector, or technology improves considerably more than was
assumed by IPCC,
by 2050 aviation will be contributing at least 6% of the total
radiative forcing consistent with the necessary stabilisation
of climate. A safer working hypothesis is that it will be in
the range 6% - 10%." (paragraph 3.41).
The DfT analysis for the Future of Air Transport White
Paper concluded that if, for analytical purposes, international
were allocated to the UK domestic emissions inventory, then by
2050 aviation's share of total UK climate change impacts could
reach approximately 33%. This calculation is explained in the
table included with our memorandum of May 2004.
The UK figure is so high (33%) because of the key
role that the UK, and particularly London, plays in the global
air transport system. As noted in the Future of Air Transport
White Paper, one fifth of all international air passengers in
the world are on flights to or from an UK airport. Drastic measures
to bring down the UK figure would cause significant damage to
the UK's position in the global economyand for very little
environmental benefit, because many of the passengers would simply
fly elsewhere instead and the total quantum of flights
(and emissions) would be little affected.
Whether the aviation share of UK greenhouse gas emissions
in 2050 is 33% or some higher or lower figure does not alter the
importance of taking action to limit or reduce emissions from
international aviation. The Government believes that this can
be best achieved through a well-designed emissions trading scheme
and is actively pursuing this goal.
Emissions trading is a key instrument for achieving
such reductions because it gives companies flexibility about the
way they meet emissions reduction targets and delivers real environmental
benefits. As well as mitigating, through participating in the
scheme, some of the environmental harm it causes, aviation may
help the scheme more generally by increasing the demand for emissions
allowances and therefore making it economic for more sectors to
reduce their emissions. A well-designed European Union emissions
trading scheme would be a valuable first step towards international
action. But the Air Transport White Paper makes it clear that
we reserve the right to act unilaterally or bilaterally with like-minded
partners if progress towards tackling aviation emissions at an
international level proves too slow.
"Given the priority apparently being accorded
to the need to tackle global warming, we find it bizarre that
the Government response, in calculating aviation in relation to
other UK emissions, assumes that there will be no reduction in
greenhouse gases, other than carbon dioxide, over the next 50
years. In setting the 60% carbon reduction target last year,
the Government failed to clarify how it relates to greenhouse
gases other than carbon dioxide and what baseline should be used
to measure achievement against. It must do so as a matter of
urgency. (Paragraph 25)"
We understand the Committee's general concern on
this point, though it's statement is not quite correct.
The reduction in emissions of gases other than carbon
dioxide was significant in the in the decade 1990-2000, with a
fall from 44MtC equivalent to 28.9 MtC equivalent. However, these
reductions have slowed over recent years, and are forecast to
slow even further in the future.
The Government has assumed non-CO2 GHG
emissions (28.9MtC equivalent in 2000) to fall to 2020 (25.8MtC
equivalent) in line with projections in Chapter 4 of The
UK's Third National Communication to the United Nations Framework
Convention on Climate Change. But it is correct that no further
fall was included for 2020 to 2050. This was because we do not
have projections of non-CO2 gases beyond 2020. If the
same 60% cut applied to non-CO2 gases by 2050, then
aviation's share rises from the 33% estimated by DfT to about
35%. This difference is well within the uncertainties for calculations
of this type. UK projections of non-CO2 greenhouse
gases are currently being reviewed.
The reduction of 60% in CO2 is calculated
from 1990 levels. It would therefore be reasonable to apply a
similar starting point to any long term forecast for non-CO2
gases, but since we have not formally set a non-CO2
greenhouse gas target, we have not set a formal baseline either.
"Figures presented by the Government, both
in the Government response and in Aviation and Global Warming,
contain apparent inconsistencies. This reflects the poor quality
of documentation and appraisal carried out by the Department for
Transport in this area. It would be helpful if the Department
could set out comprehensive and well documented statistics to
inform further discussion of this topic. (Paragraph 27)"
The Committee highlights two particular issues when
comparing the Government response and the DfT's Aviation and
Global Warming which are explained below. The Department would
again like to state its willingness to clarify figures to the
Committee should they be unsure as to their origins, and also
highlight that, to the best of our knowledge, the UK is the only
country in the world which has attempted to publish long term
forecasts of international aviation related greenhouse gas emissions
on a national basis.
The first inconsistency highlighted by the Committee
concerns differences in UK domestic emissions of carbon dioxide
in 2000 and 2030. The figures in paras 2.9 -2.10 of Aviation
and Global Warming are derived from the DTI paper Energy
Projections for the United Kingdom, which accompanied the
energy White Paper, Our Energy Future Creating a Low
Carbon Economy. For 2000, the figure (147 MtC) excluded emissions
from land use change and forestry, which are not included in DTI
The emissions given in the Government response, including
152.2 MtC for 2000, are derived from the UK Greenhouse Gas
Inventory, 1990 to 2002, published in April 2004. These
figures include emissions from land use change and forestry.
The Government response then assumes a linear trend in emissions
to reach the 65.8 MtC carbon dioxide emissions in 2050 target.
The figure of 94.0MtC in 2050 of the UK total emissions
including domestic emissions in the table attached to the Government
response is not just the sum of 65.8MtC carbon dioxide emissions
plus 25.8 4MtC GHGs from sectors other than aviation. Radiative
forcing due to domestic aviationwhich is included in the
Energy White Paper total ust also be added, and was included.
"We said last year that the airports consultation
"fails to take on board the new direction in policy
initiated by the Government's Energy White Paper; while the growth
proposed in aviationeven
on a constrained basiswould wreck the aspirations
it contains." The Future of Air Transport White
Paper has done nothing to alter our view: aviation policy remains
the most glaring example of the failure of Government to put sustainable
development at the heart of policy making. (Paragraph 30)"
The Government remains firmly committed to the goals
set out in the Energy White Paper. The Spending Review 2004 announcement
(13 July) also committed DfT to join with Defra and the DTI in
a joint Public Service Agreement target to put the UK on a path
to a 20% reduction in domestic CO2 emissions by 2010
compared to 1990 levels.
The Future of Air Transport White Paper contains
a balanced package of measures and proposals that sets out a long
term strategy for the aviation sector. It reflects the economic,
social and environmental pillars of sustainable development and
is consistent with the environmental goals of the Energy White
Paper. An approach that arbitrarily constrained the UK air transport
industry could potentially cause lasting harm to the UK economy
and the interests of the travelling public without delivering
the worldwide environmental benefits which both the Committee
and the Government wish to see. Our task is to ensure that the
Future of Air Transport is now implemented, and that our
environmental commitments at home and abroad are pursued vigorously.
Department for Transport
5 Study to Identify Future Commercial Trends Affecting
the Aviation Industry in the Period 2000 to 2015 - Final Part
1 Report (May 2001).Details of how to obtain this report can be
found on page 180 (Doc Ref No 41) of the Future Development of
Air Transport in the United Kingdom: South East - second edition
(February 2003). Back
Intergovernmental Panel on Climate Change. The RCEP is here referring
to the IPCC report Aviation and the Global Atmosphere (1999). Back
For these purposes "international aviation" is defined
as all international departures from UK airports. Back