1. The aviation White Paper actively promotes a huge
growth in air travel over the next 30 years. The environmental
impact of thisin particular in terms of emissions and the
contribution of aviation to global warmingwill be massive.
The DfT has failed to recognise this adequately or to accept
the disparity between its policy on aviation and the major commitments
the Government has given to reduce carbon emissions and develop
a sustainable consumption strategy.
2. DfT has implicitly adopted a 'predict and provide'
approach which is based on assuming a substantial real decrease
in the price of air travel. We are emphatically not arguing for
a hairshirt approach or 'pricing people off planes'. But we do
feel that the DfT, in conjunction with the Treasury, could have
used economic instruments more to moderate the forecast increase
in growth and to send out a long-term signal to the aviation industry.
3. The failure of the DfT to give adequate consideration
to global warming impacts is reflected in the poor quality of
the Integrated Policy Appraisal published as part of the White
Paper, and the inadequacy of the Department's economic appraisals.
The DfT has recognised the latter by belatedly attempting to
include global warming costs in its supporting paper, Aviation
and Global Warming. But the analysis is opaque and poorly
documented, raising concerns about the consistency of treatment
of costs and benefits, and it therefore fails to provide a proper
response to our concerns.
4. In addition, by restricting economic appraisal
analyses only to the provision of new runwaysas opposed
to new terminals, runway extensions, and operational improvements
to maximise the use of existing runwaysthe Department has
failed to provide an appraisal of the overall environmental impacts
resulting from the future increase in air travel which the Government
5. The prospects for including aviation in the EU
Emissions Trading Scheme are uncertain. Given the admission by
the DfT that the UK is "ploughing a lonely furrow" in
its advocacy of emissions trading, there is little prospect of
implementing in the foreseeable future an international emissions
trading system to cover aviation emissions. It is therefore disappointing
that the UK has not shown leadership by pursuing alternative strategies.
6. Given the Government's expressed desire to incorporate
aviation in the EU Emissions Trading System from 2008, we are
astonished that the DfT appears to have done no research on some
of the key issues which need to be resolved or to model the impact
of including aviation in a cross-sectoral emissions trading system.
Such research is essential even before any draft proposals can
be contemplated. Given the timescales involved, we think it might
soon be too late to achieve the target date of 2008.
7. It is by no means obvious that an EU or international
emissions trading system can generate sufficient credits to allow
aviation to expand as forecast, while at the same time delivering
carbon reductions of the order needed. The DfT supporting paper,
Aviation and Global Warming, implicitly recognises this
potential difficulty. The price of carbon could, in such circumstances,
go through the roofprovided there was sufficient political
will to maintain targets and enforce penalties.
8. If aviation emissions increase on the scale predicted
by the DfT, the UK's 60% carbon emission reduction target which
the Government set last year will become meaningless and unachievable.
The most we could hope to attain would be about 35%. The DfT
admitted that the target would need to be looked at should international
emissions be allocated to national inventoriesand this
can only mean with a view to watering it down.
9. The Government should recognise the difficulties
it faces in meeting its 2050 carbon target. If it did so, it
would be forced to take more action now and develop an adequate
policy response. It should not continue to hope that the solution
lies in technological advances as the weight of evidence suggests
that the scope for these is limited.